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Home My WebLink About09-0059c~' s Phelan, 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 Deutsche Bank National Trust Company, As Trustee For Morgan Stanley Ixis Real Estate Capital Trust 2006-1 Court of Common Pleas 3476 Stateview Blvd. Fort Mill, SC 29715 Civil Division Cumberland County v. Gregory A. Ponder Or Occupants 140 Lancaster Boulevard Mechanicsburg, PA 17055 Term ~~ (~1 No. d~!- f~~3-~1 CIVIL ACTION -EJECTMENT '"`This firm is a debt collector attempiing 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 appeazance 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 telephone the oflce 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 #: 194467 1. Plaintiff is Deutsche Bank National Trust Company, As Trustee For Morgan Stanley Ixis Real Estate Capital Trust 2006-1. 2. Defendant is Gregory A. Ponder Or Occupants. 3. Plaintiff is the record owner of premises located at 140 Lancaster Boulevard, Mechanicsburg, PA 17055, 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 Sheriff s deed recorded December 29, 2008 in the Office of the Recorder of Cumberland County in Instrument 200840576. 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. _ .S F ancis S. Hallinan, Esquire Attorney for Plaintiff v ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Lower Allen, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the Southwest corner of Oxford Drive and Lancaster Boulevard of the hereinafter mentioned plan; thence by the Westerly side of Lancaster Boulevard South 44 degrees 38 minutes East 82 feet to a point at the dividing line between Lots No. 8 Block N, of the plan and Lot No. 7, Block N, Page 10, Orchard Crest Manor; thence by said dividing line South 45 degrees 22 minutes West 110 feet to the Western line of Lower Allen Township; thence by said line North 44 degrees 38 minutes West 92 feet to a point on the Southerly side of Oxford Drive; thence by Oxford Drive North 45 degrees 22 minutes East 110 feet to a point at the Southwest corner of Oxford Drive and Lancaster Boulevard, the place of BEGINNING. BEING Lot No. 8, Block N, Plan 9, Orchard Crest manor, which plan is recorded int eh Cumberland County Recorder's Office in Plan Book 21, Page 79. HAVING thereon erected a brick and aluminum bi-level dwelling house known and numbered as 140 Lancaster Boulevard. BEING THE SAME PREMISES granted and conveyed unto Gregory A. Ponder, by Deed of Guern W. Fealtman and Donna N. Fealtman, dated February 20, 2000 and recorded February 22, 2001 in the Cumberland County Recorder of Deeds Office in Deed Book 239, Page 902. This is a transfer from husband and wife to husband and wife and is therefore exempt from Pennsylvania Realty Transfer Tax. Premises: 140 Lancaster Boulevard 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 sheriff s sale. I am making this verification rather than a representative of the Plaintiff because I have personal knowledge of the purchase of this properly 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 Fr ncis S. Hallinan, Esquire Attorney for Plaintiff ~ r-a ~~ ~ ,-' ~~ ~ - _~ jf--i W W v ~ C.J "rx = ` } V ,.~ -~