HomeMy WebLinkAbout08-3709Phelan, Hallinan & Schmieg, LLP
By: Francis S. Hallinan, Esquire
Identification No. 62695 Attorney for Plaintiff
One Penn Center A Suburban Station
Suite 1400
Philadelphia, PA 19103
(215) 563-7000
Beneficial Consumer Discount Company d/b/a Beneficial Mortgage
Company of Pennsylvania Court of Common Pleas
10385 Westmoor Drive, Ste. 201
Westminster, CO 80021 Civil Division
V. Cumberland County
George G. Schaeffer Term
Or Occupants p
10 Patricia Drive No. Qg - 3709
Enola, PA 17025
CIVIL ACTION - EJECTMENT
Civil term
**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 #: 175186
1. Plaintiff is Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of
Pennsylvania.
2. Defendant is George G. Schaeffer Or Occupants.
3. Plaintiff is the record owner of premises located at 10 Patricia Drive Enola, PA 17025, 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 Sheriff's deed recorded April
28, 2008 in the Office of the Recorder of Cumberland County in book 200813596, Page , a true and
correct copy of which is attached hereto, made party hereof, and marked as Exhibit "A".
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.
ancis S. Hallinan, Esquire
Attorney for Plaintiff
i
_:,
EXMBIT "A"
Tax Parcel No. 09-14-0836-159
Know all Men by these Presents
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 company of Pennsylvania
REAL ESTATE SALE NO, 67
Writ No. 2007.5358 Civil Term of Pennsylvania
Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company VS
George G. Schaeffer and Debra W. Schaeffer
Attorney Terrence McCabe
DESCRIPT)ON
C of Cumberland
ALL that certain piee or parcel of land situate in the Township of East Pennsboro, ounty and State of Pennsylvania, bounded and described as follows:
Beginning at a point on the north5 ern anline of Patricia Drive on the hereiVk er mentioned PI of Lots at
d 16 on said plan; thence b the dividing line between Lots No. 15 e
dividing line between Lots No- 1 0 seconds West, one
and 16 on said Plan, North 31 degrees 21 ruin thence by land of Clinton OrrisN orth 5ledegrees 5 twenty-
and
three one-hundredths (148.23) feet to a point; line between
East, ninety-six and fifty-four one (96.54) feet to a point; tone hence dr the dividing land sixty-eight
Patricia Drive; ?then a by the northern line of
Lots No. 14 and 15 on said Plan,
to point on the northern line minutes
one-hundredths (143.63) feet feet to a point, the place of
Patricia Drive, South 49 degrees 30 minutes West, one hundred twenty (120)
beginning. County
reco
which Plan
d in the Being Lot No. 15 in the Plan of Lots of Sherwood Park, ar of Sherwood Park isrthe names Planof Lots laid out
Recorder s Office in Plan Book 12, at page 2
by Theodore E. Sgrignoli, et ux, and designated as Nola Acres, which Plan was not recorded.
Subject, nevertheless, to the utility easements as shown on said Plan and a 25 foot set-back line from the
northern line of Patricia Drive. dwelling. thereon erected a ranch type g•
Tax Map Parcel Number: 09-14-0836-159
Being !mown as 10 Patricia Drive, Enola, PA 17025 deed dated
Being the same premises which Frederick B. Walters and Lois J. Walters, husband and wife, by m Deed
Book berland Co Book 978 and recorded land c nveyed to George G. Schaeffer and Debra Schaeffer husband and
Y27, page 434, granted
wife, in fee.
The same having been sold by me to the said grantee on the 5th day of March Anno
Domini Two Thousand and Eight (2008) after due advertisement according to law,
under and by Virtue of a Writ of Execution issued on the 9th day of November Anno
Domini 2007out of the Court of Common Pleas of Cumberland County, Pennsylvania, as
of civil Term, Two Thousand and Seven (2007) Number 5358 at the suit of Beneficial
Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania
against George G. Schaeffer and Debra W. Schaeffer
In Witness Wereof, I have hereunto affixed my signature this 24th day of April
Anno Domini Two Thousand and Eight (2008)
R. Thomas Kline, Sheriff
Commonwealth of Pennsylvania, ss.
County of Cumberland
Before the undersigned, Curtis R. Long, Prothonotary of the Court of Common
Pleas of Cumberland County, Pennsylvania, personally appeared R. Thomas Kline,
Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts
Set forth in the foregoing Deed are true, and that he acknowledged the same in order that
Said deed might be recorded.
Witness my hand and seal of said Court, this 24th day of April
Two Thousand and Eight (2008)
Anno Domini
M11MMAR , NOTARY MM
CARlJ3LE CUMBLAND COUNTY COMM
MY COMMSSION Dff' S JANUARY 4, 2010
I hereby certify that the residence
And Post Office address of the
Within Grantee is
961 Weigel Drive
Elmhurst, IL 60126
Solicitor
'R
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number - 200813596
Recorded On 4/28/2008 At 1:45:43 PM
* Instrument Type - DEED-SHERIFF'S
Invoice Number -19638 . User ID - RAK
* Grantor - SCHAEFF X GEORGE G
* Grantee - BENEFICIAL CONS' DISC CO
* Customer - CUMBERLAND SHERIFF
* FEES
STATE WRIT TAX $0.50
STATE JCS/ACCESS TO $10.00
JUSTICE
RECORDING FEES - $12.50
RECORDER OF DEEDS
AFFORDABLE HOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
EAST PENNSBORO SCHOOL $0.00
DISTRICT
EAST PENNSBORO TOWNSHIP $0.00
TOTAL PAID $39.50
* Total Pages - 5
Certification Page
DO NOT DETACH
This page is now part
of this legal document.
I Certify this to be recorded
in Cumberland, County PA
RECORDER O
- Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
umMUiwiinA
VERIFICATION
Fcaneis.& Hall'inan, Esqu r+e.heceby states that he is the Attorney for the Plaintiff in this
matter, that Plaintiff is outside the jurisdiction of the-covrt andfor the verification could
not be obtained widrin the time allowed for the filing of the pleading, that he is
authorized to take this. Verification, pursuant to Pa. I .C.P. 1024 (c) and that the
statcamets made in the foregoing Civil Action in Ejechnent arse true and correct to the
best of his knowledge, information. and belief. Furthennore, it is counsel's intention to
substia to 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 unworn falsification to authorities.
Francis S. Hallinxu, Esgaire
Attorney for Plaintiff
Date:
1
"64- 77
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I
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-03709 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
SCHAEFFER GEORGE G
KENNETH GOSSERT Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - EJECTMENT was served upon
SCHAEFFER GEORGE G the
DEFENDANT , at 1943:00 HOURS, on the 26th day of June 2008
at 10 PATRICIA DRIVE
ENOLA, PA 17025 by handing to
GEORGE SCHAEFFER
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
Service
Affidavit
Surcharge
/040Y ?,
So Answers:
18.00
15.00 _
.004!- -G
10.00 R. Thomas Kline
00
43.00 06/27/2008
PHELAN HALLINAN SCHMIEG
Sworn and Subscibed to
before me this day
of
By:
t
A. D.
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
Beneficial Consumer Discount Company d/b/a
Beneficial Mortgage Company of Pennsylvania
vs.
George G. Schaeffer
Or occupants
10 Patricia Drive
Enola, PA 17025
Attorney for Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
No. 08-3709 Civil Term
Cumberland County
PRAECIPE FOR JUDGMENT IN EJECTMENT
TO THE PROTHONOTARY:
Kindly enter Judgment in Ejectment in favor of the Plaintiff, Beneficial Consumer Discount Company d/b/a
Beneficial Mortgage Company of Pennsylvania and against the Defendant(s) George G. Schaeffer and Or
occupants for possession of premises, 10 Patricia Drive, Enola, PA 17025 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.
yorneFrcis S. Ha llinan, Esqui e
y for Plaintiff
Default Judgment entered as indicated above.
DATE
Phelan Hallinan & Schmieg, LLP
By: Francis S. Hallinan, Esquire Attorney for Plaintiff
Identification No. 62695
1617 John F. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103
(215) 563-7000
Beneficial Consumer Discount Company d/b/a
Beneficial Mortgage Company of Pennsylvania COURT OF COMMON PLEAS
CIVIL DIVISION
VS. No. 08-3709 Civil Term
Cumberland County
George G. Schaeffer
Or occupants
10 Patricia Drive
Enola, PA 17025
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 George G. Schaeffer Or occupants, is over 18 years of age, and resides
at 10 Patricia Drive, Enola, PA 17025.
This statement is made subject to the penalties of 18 PA. C.S.S 4904 relating to unworn
falsification to authorities.
ran s S. Halliinan, uire
tt ney for Plaintiff
PHELAN HALLINAN & SCHMIEG
Francis S. Hallinan, Esquire
ID# 62695
One Penn Center, Suite 1400
1617 JFK Boulevard
Philadelphia, PA 19103
(215) 563-7000
Beneficial Consumer Discount
Company d/b/a Beneficial Mortgage
Company of Pennsylvania
vs
George G. Schaeffer
Or Occupants
TO: George G. Schaeffer or occupants
10 Patricia Drive
Enola, Pa 17025
DATE OF NOTICE: July 17, 2008
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
No. 08-3709 Civil Term
Cumberland County
**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.**
IWORTANT 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 (10) 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 notice to a
lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to
find out where you can get legal help:
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
aLegal Assistant
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PRAECIPE FOR WRIT OF POSSESSION
COMMONWEALTH OF PENNSYLVANIA.
County of Cumberland
Beneficial Consumer Discount Company d/b/a
Beneficial Mortgage Company of Pennsylvania COURT OF COMMON PLEAS
CIVIL DIVISION
vs. No. 08-3709 Civil Term
Cumberland County
George G. Schaeffer
Or occupants
10 Patricia Drive
Enola, PA 17025
PRAECIPE FOR WRIT OF POSSESSION
TO THE PROTHONOTARY:
Issue Writ of Possession in the above matter for possession of:
10 Patricia Drive, Enola, PA 17025
**PLEASE SEE THE ATTACHED LEGAL DESCRIPTION***
Being Known as No. 10 Patricia Drive
jr isSHallinan, Esq e
ney for Plaintiff
11 R
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`64
44.
CIA
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DESCRIPTION
ALL that certain piece or parcel of land situate in the Township of East Pennsboro, County of Cumberland
and State of Pennsylvania, bounded and described as follows:
Beginning at a point on the northern line of Patricia Drive on the hereinafter mentioned Plan of Lots at the
dividing line between Lots No. 15 and 16 on said Plan; thence by the dividing line between Lots No. 15
and 16 on said Plan, North 31 degrees 21 minutes 30 seconds West, one hundred forty-eigbt and twenty-
three one-hundredths (148.23) feet to a point; thence by land of Clinton Orris, North 51 degrees 5 minutes
East, ninety-six and fifty-four one-hundredths (96.34) feet to a point; thence by the dividing line between
Lots'No. 14 and 15 on said. Plan, South 40 degrees 30 minutes East, one hundred forty-three and sixty-eight
one-hundredths (143.63) feet to a point on the northern line of Patricia Drive; thence by the northern line of
Patricia Drive, South 49 degrees 30 minutes West, one hundred twenty (120) feet to a point, the place of
beginning.
Being Lot No. 15 in the Plan of Lots of Sherwood Park, which Plan is of record in the Cumberland County
Recorder's Office in Plan Book 12, at page 29. The Plan of Sherwood Park is the same Plan of Lots laid out
by Theodore E. Sgrigaoli, et ux, and designated as Nola Acres, which Plan was not recorded.
Subject, nevertheless, to the utility easements as shown on said Plan and a 25 foot set-back line from the
northern line of Patricia Drive.
Having thereon erected a ranch type dwelling.
Tax Map Parcel Number: 09-14-0836-159
Being known as 10 Patricia Drive, Enola, PA 17025
Being the same premises which Frederick B. Walters and Lois J. Walters, husband and wife, by deed dated
7/31/1978 and recorded 7/31/1978 in the Office of the Recorder in and for Cumberland County in Deed
Book Y27, page 434, granted and conveyed to George G. Schaeffer and Debra W. Schaeffer, husband and
wife, in fee.
W2
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL MORTGAGE
COMPANY OF PENNSYLVANIA
VS.
No. 08-3709 Civil Term
GEORGE G. SCHAEFFER
OR OCCUPANTS
Costs
Attorney's $ 159.50
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))
BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE
COMPANY OF PENNSYLVANIA
being: (Premises as follows):
10 PATRICIA DRIVE, ENOLA, PA 17025
(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.
- Avgg?3-i.
C is R. Long, Pro eta'
Common Pleas ourt of Cum rland County, PA
Date 7/31/08
(Seal)
? ? y
2of2
No 08-3709 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL MORTGAGE
COMPANY OF PENNSYLVANIA
VS.
GEORGE G. SCHAEFFER
OR OCCUPANTS
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
Att'y $ 159.50
Plff (s) $
Prothy $ 2.00
Sheriff $
Plaintiff (s) attorney name and address:
FRANCIS S. HALLINAN, ESQUIRE
PHELAN HALLINAN & SCHMIEG, LLP
1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400
PHILADELPHIS, PA 19103
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
Sworn and subscribed to before me this
Day of ,
Prothonotary
So Answers,
Sheriff
By
Deputy
DESCRIPTION
ALL that certain piece or parcel of land situate in the Township of East Pennsboro, County of Cumberland
and State of Pennsylvania, bounded and described as follows:
Beginning at a point on the northern line of Patricia Drive on the hereinafter mentioned Plan of Lots at the
dividing line between Lots No. 15 and 16 on said Plan; thence by the dividing line between Lots No. 15
and 16 on said Plan, North 31 degrees 21 minutes 30 seconds West, one hundred forty-eigbt and twenty-
three one-hundredths (148.23) feet to a point; thence by land of Clinton Orris, North 51 degrees 5 minutes
East, ninety-six and fifty-four one-hundredths (96.54) feet to a point; thence by the dividing line between
LotsWo. 14 and 15 on said. Plan, South 40 degrees 30 minutes Bast, one hundred:forty--thrce and sixty-eight
one-hundredths (143.63) feet to a point on the northern line of Patricia Drive; thence by the northern line of
Patricia Drive, South 49 degrees 30 minutes West, one hundred twenty (120) feet to a point, the place of
beginning.
Being Lot No. 15 in the Plan of Lots of Sherwood Park, which Plan is of record in the Cumberland County
Recorder's Office in Plan Book 12, at page 29. The Plan of Sherwood Park is the same Plan of Lots laid out
by Theodore E. Sgrignoli, et ux, and designated as Nola Acres, which Plan was not recorded.
Subject, nevertheless, to the utility easements as shown on said Plan and a 25 foot set-back line from the
northern line of Patricia Drive.
Having thereon erected a ranch type dwelling.
Tax Map Parcel Number: 09-14-0836-159
Being known as 10 Patricia Drive, Enola, PA 17025
Being the same premises which Frederick B. Walters and Lois J. Walters, husband and wife, by deed dated
7/31/1978 and recorded 7/31/t978 in the Office ofthe Recorder in and for Cumberland County in Deed
Book Y27, page 434, granted and conveyed to George G. Schaeffer and Debra W. Schaeffer, husband and
wife, in fee.
By virtue of this writ, on the S t h day of November 2 0 0 $ I caused the within
named B e n i f i c i a l Con s um e r D i sthav4bssession of the premises described v1IEW
* tRMgAKO 10 Patricia Drive, Enola, PA 17025
So Answ s ,
Sworn and subscribed to before me this .??
Day of ,
Sheriff
By.
.j?A( Alas
Sheriffs Return:
Docketing
Surcharge
Prothy
Milage
Possession
Poundage
r., e`%
18.00
30.00
2.00
28.00
30.00
2.16
IOM7? 14/3/o,
Advance Costs: 150.00
Sheriff's Costs 110.16
39.84
Refunded to Atty on 11/6/08
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A.1
Arc. 217113
2of2
No 08-3709 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL MORTGAGE
COMPANY OF PENNSYLVANIA
VS.
GEORGE G. SCHAEFFER
OR OCCUPANTS
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
Att'y $ 159.50
Plff (s) $
Prothy $ 2.00
Sheriff $
Plaintiff (s) attorney name and address:
FRANCIS S. HALLINAN, ESQUIRE
PHELAN HALLINAN & SCHMIEG, LLP
1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400
PHILADELPHIS, PA 19103
Attorney for Plaintiff (s)
By virtue of this writ, on the
named
appurtenances, and
Where papers may be served
day of , . I caused the within
_, to have possession of the premises described with the
Sworn and subscribed to before me this
Day of ,
Prothonotary
So Answers,
Sheriff
By
Deputy
tof 2
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL MORTGAGE
COMPANY OF PENNSYLVANIA
VS.
No. 08-3709 Civil Term
GEORGE G. SCHAEFFER
OR OCCUPANTS
Costs
Attorney's $ 159.50
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))
BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE
COMPANY OF PENNSYLVANIA
being: (Premises as follows):
10 PATRICIA DRIVE, ENOLA, PA 17025
(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.
Date 7/31/08
(Seal)
z S & ?..
C R. Long, Protho ry,
Common Pleas of Cumbe nd County, PA
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
Beneficial Consumer Discount Company
d/b/a Beneficial Mortgage Company of
Pennsylvania
VS.
George G. Schaeffer
or occupants
Plaintiff
Defendant(s)
Attorney for Plaintiff
Court of Common Pleas
Cumberland County
No. 08-3709
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 entered on this case discontinued and ended, upon payment of your costs
only.
Date
F ancis S. Hallinan
Attorney for Plaintiff
PHS# 175189
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