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Home My WebLink About09-0058Phelan, Hallinan & Schmieg, LLP By: Francis S. Hallinan, Esquire Identification No. 62645 Attorney for Plaintiff One Penn Center A Suburban Station Suite 1400 Philadelphia, PA 19103 (215)563-7000 Suntrust Mortgage 1001 Semmes Avenue, P.O. Box 27767 Court of Common Pleas Richmond, VA 23224-7767 Civil Division v. Cumberland County Paul E. Kuhn Term i?I~~~ 1 Or Occupants ~, ~~s--~ 1000 West Foxcroft Drive No. Q 1 Camp Hill, PA 17011 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 aze 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 aze 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 te{ephone 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 #: 194957 1. Plaintiff is Suntrust Mortgage. 2. Defendant is Paul E. Kuhn Or Occupants. 3. Plaintiff is the record owner of premises located at 1000 West Foxcroft Drive, Camp Hill, PA 17011, 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 December 10, 2008, as evidenced by the Sheriffs deed recorded December 29, 2008 in the Office of the Recorder of Cumberland County in Instrument 200840575. 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. ..~(. Cam' S-r~/ F ancis S. Hallinan, Esquire Attorney for Plaintiff ALL that certain lot of land situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit; BEGINNING at a point on the western side of Foxcroft Drive, said point being the northeastern corner of Lot No. 70, Section D of the hereinafter mentioned plans of lots; thence by the western side of West Foxcroft Drive, South 09 degrees 15 minutes 33 seconds East 92.16 feet to a point; thence by the same on a curve to the right having a radius of 10 feet, an arc distance of 13.29 feet to a point on the northern side of Echo Road; thence by the north side of Echo Road, South 60 degrees 54 minutes 27 seconds West 120.89 feet to a point; thence by the western line of Lot No. 70, Section D., North 09 degrees 15 minutes 33 seconds West 130.78 feet to a point; thence by the northern line of Lot No. 70, Section D North 80 degrees 44 minutes 27 seconds East 125 feet to the place of BEGINNING. BEING Lot No. 70, Section D, of the Plan of Lots of Riverview as recorded in Plan Book 11, Page 9, Cumberland County records and being subject to utility easements and building and use restrictions and conditions of record. BEING THE SAME PREMISES which Martha A. Collins, widow, by her Powers of Attorney, Karen Leaman and Kathy Jo Collins, now by reason of marriage Kathy Jo Jachowski, granted and conveyed to Jay A. Young by deed dated June 29, 2001 and recorded July 3, 2001 in the Recorder of Deeds in and for Cumberland County, PA in Record Book 247, Page 1111. Premises: 1000 West Foxcroft Drive . i. 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. G ~ ~ S-7'U Date Francis S. Hallinan, Esquire Attorney for Plaintiff c ~ ~ -~ ~~Yi• ~~ ~V' ~ ~Q,, _Ls~ r,::: V -.> t~ c.... `"°~. ~S C.J ;:;~ ~~ r._ 1 ~ ~I Y ` `? 7 :',` ^g '.~ J