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HomeMy WebLinkAbout10-068840- Phelan, Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 `francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michelle M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq. Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq. Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No.206779 Andrew C. Bramblett, Esq., I.D. 208375 One Penn Center A Suburban Station Suite 1400 Philadelphia, PA 19103 (215) 563-7000-7000 Sovereign Bank 601 Penn Street Reading, PA 19601 TH- 2910 JAN 28 AM 10: 21 Attorney for Plaintiff Court of Common Pleas Civil Division V. Joshua L. Shindel Or Occupants 464 Sample Bridge Road Enola, PA 17025-1024 Cumberland County No. 16 - 688 Term 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 alien 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 #: 228873 01 w-00 PO AT H e?'# 9054Zo P'* .13(090f J* 1. Plaintiff is Sovereign Bank. 2. Defendant is Joshua L. Shindel Or Occupants. 3. Plaintiff is the record owner of premises located at 464 Sample Bridge Road Enola, PA 17025-1024, 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 January 6, 2010, as evidenced by the Sheriff s deed recorded January 20, 2010 in the Office of the Recorder of Cumberland County in instrument 201001602. 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. By: bHallinan & Schmieg, LLP Laww??nce T. Phelan, Esq., Id. No. 32227 --ancis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq. Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq. Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq. Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff J I? ALL THAT CERTAIN tract of land situate in the Township of Silver Spring, County of Cumberland, and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the north side of Township Road 596 (50 feet wide), at the corner of land now or formerly of Oscar N. Bricker and Mabel E. Bricker, his wife, said point being North 75 degrees West, 141.94 feet from the western line of a proposed utility easement, running between said land now or formerly of Oscar N. Bricker ad Mabel E. Bricker, his wife, and land now or formerly of Albert Jacobs; thence along the north side of said Township Road 596, North 75 degrees West, 139.45 feet to a point; thence along a proposed 50 foot right-of-way, North 20 degrees 58 minutes East, 204.66 feet to a point; thence continuing along said proposed right-of-way, North 24 degrees 47 minutes West, 59.07 feet to a point; thence along the line of land now or formerly of Oscar N. Bricker and Mabel E. Bricker, his wife, South 80 degrees 50 minutes East, 113.77 feet to a point; thence continuing along lands of same, South 05 degrees 40 minutes West, 264 feet to a point on the north side of the public Township Road 596, the place of BEGINNING. The above described tract of land is to be considered as Lot No. 21 in the Plan of Lots of Oscar N. Bricker, known as Log Cabin Ville. BEING known and numbered as 464 Sample Bridge Road, Enola, Pennsylvania. BEING THE SAME PREMISES which Thelma L. Kauffman, Executrix of the Last Will and Testament of James B. Webb, by Deed dated July 27, 1984 and recorded September 7, 1984 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book W, Volume 30, Page 694, granted and conveyed unto Steven Rickrode and Jean Rickrode, husband and wife, Grantors herein. All VERIFICATION I hereby state that I am 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. Date Attorney for Plaintiff Phelan, Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 `_Erancis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michelle M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq. Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq. Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No.206779 Andrew C. Bramblett, Esq., I.D. 208375 One Penn Center A Suburban Station Suite 1400 Philadelphia, PA 19103 (215) 563-7000-7000 Sovereign Bank 601 Penn Street Reading, PA 19601 V. Joshua L. Shindel Or Occupants 464 Sample Bridge Road Enola, PA 17025-1024 ?. r 2010 JAN 28 AP1 10: 21 Attorney for Plaintiff Court of Common Pleas Civil Division Cumberland County No. 16 - X08$ 0';'111 Term 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 alien 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 attomey 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. PHS #: 228873 CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 (888)-990-9108 O1 *ga.oo PQ ATH P;r* x 3 C,9o i A 1. Plaintiff is Sovereign Bank. 2. Defendant is Joshua L. Shindel Or Occupants. 3. Plaintiff is the record owner of premises located at 464 Sample Bridge Road Enola, PA 17025-1024, 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 January 6, 2010, as evidenced by the Sheriffs deed recorded January 20, 2010 in the Office of the Recorder of Cumberland County in instrument 201001602. 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. _ By: )Ik? Phelan, Hallinan & Schmieg, LLP La ce T. Phelan, Esq., Id. No. 32227 --f> s S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq. Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq. Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq. Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~tith, of "'4"RairiLrt'lfy A Y r~V ~ ; ~.`~ ~~ P~?AY ZOtQMAR -3 ~M 9~ kZ p~tNSYRVq~q~'~' Jody S Smith Chief Deputy Edward L Schorpp Solicitor Sovereign Bank vs. Joshua L. Shindel Case Number 2010-688 SHERIFF'S RETURN OF SERVICE 02/23/2010 08:15 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February 23, 2010 at 2015 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Joshua L. Shindel, by making known unto himself personally, at 464 Sample Bridge Road, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. 02/25/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Occupant of 464 Sample Bridge Road, Enola, PA 17025, but was unable to locate them in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Occupant. Joshua L. Shindel is the only resident at 464 Sample Bridge Road, Enola, PA 17025. SHERIFF COST: $100.00 February 25, 2010 SO ANS RO R ANDERSON, SHERIFF gy Daputy heriff (oj GountySuite Shenff. Teleosoft, Inc. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor Sovereign Bank vs. Joshua L. Shindel ~-,_~~ _ `~ L . F 20IQ~~~'~ ~3 ~~ ~: ~~ ~' r Case Number 2010-688 SHERIFF'S RETURN OF SERVICE 04/16/2010 07:23 PM -Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on April 16, 2010 at 1923 hours a true copy of the within writ of possession was attempted to be served upon the defendant, to wit: Occupant, of 464 Sample Bridge Road, Enola, Cumberland County, Pennsylvania 17025. Deputy Cobaugh states that the house appears to be vacant; per a neighbor, defendant moved out a week ago. 04/16/2010 07:23 PM -Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on April 16, 2010 at 1923 hours a true copy of the within writ of possession was attempted to be served upon the defendant, to wit: Joshua L. Shindel, of 464 Sample Bridge Road, Enola, Cumberland County, Pennsylvania 17025. Deputy Cobaugh states that the house appears to be vacant; per a neighbor, defendant moved out a week ago. 04/23/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of possession is returned STAYED, per request from plaintiff's attorney. SHERIFF COST: $65.23 April 23, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF r. B ,; Sharon R. Lantz ~~'~'~~~~ C~ . SHERIFF'S OFFICE OF CUMBERLAND COUNTY g~~+~t~=' =, ti i~~itrrr,:r, v ~ ' ~~ ~~~b~~