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HomeMy WebLinkAbout08-3861Phelan, 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 Pennsylvannia, Inc 3476 Stateview Blvd. Fort Mill, SC 29715 V. Eric P. Johnson Or Occupants 1620 Valley Road Mechanicsburg, PA 17055-4854 Attorney for Plaintiff Court of Common Pleas Civil Division Cumberland County Term No CIVIL ACTION - EJECTMENT a8- 38GI C" "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 #: 181301 1. Plaintiff is Wells Fargo Financial Pennsylvannia, Inc. 2. Defendant is Eric P. Johnson Or Occupants. 3. Plaintiff is the record owner of premises located at 1620 Valley Road, Mechanicsburg, PA 17055-4854, 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 June 11, 2008, as evidenced by the Sheriff's deed recorded June 27, 2008 in the Office of the Recorder of Cumberland County in Instrument Number 20082074. 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. Ffancis S. Hallinan, Esquire Attorney for Plaintiff ALL THAT CERTAIN lot of ground situate in the Township of Lower Allen, County of Cumberland and State of Pennsylvania, bounded and described according to a Plan as surveyed by William E. Sees, Jr., registered surveyor, dated April 3, 1953 as follows to wit: BEGINNING at a stake on the South side of a public road, now known as Valley Road, at lands now or formerly of Samuel I. Ritter; thence along said lands of Ritter, South 12 degrees 55 minutes East, one hundred eighteen and three-tenths (118.3) feet to a stake, said stake being twelve (12) feet, more or less, form the Yellow Breeches Creek; thence along said Creek, South 59 degrees 45 minutes West, fifty and seven- tenths (50.7) feet to a stake at lands now or formerly of Mark J. Lehmer and Helen F. Lehmer, his wife; thence along lands now or formerly of Mark J. Lehmer and Helen F. Lehmer, his wife, North 10 degrees 55 minutes West, one hundred thirty-four and eight-tenths (134.8) feet to a stake, at the South side of the aforementioned public road, now known as Valley Road; thence along said road, North 78 degrees 45 minutes East, forty-five and six-tenths (45.6) feet to a stake, the Place of BEGINNING. Premises: 1620 Valley Road 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. .2 0, - Date/ F antis S. Hallinan, Esquire Attorney for Plaintiff ?_ ha r -3 6t1 i ? ,,.,i_i SHERIFF'S RETURN - REGULAR CASE NO: 2008-03861 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO FINANCIAL PENNSYLV VS JOHNSON ERIC P SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon JOHNSON ERIC P the DEFENDANT , at 0020:33 HOURS, on the 11th day of July 2008 at 1620 VALLEY ROAD MECHANICSBURG, PA 17055 by handing to ERIC JOHNSON DEFENDANT 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 '711 sbF So Answers: 18.00 14.00 .00 10.00 ! T omas Klin e00 42. 07/14,12008 PHELAN HALLIN a SC M EG 0 Sworn and Subscibed to before me this of By. day j Deputy Sher A. D.