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HomeMy WebLinkAbout10-3619 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 VLauren 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., I.D. 208375 One Penn Center A Suburban Station Suite 1400 Philadelphia, PA 19103 (215) 563-7000-7000 American Home Bank, A Division Of First National Bank Of Chester County, f/k/a American Home Bank N.A. 3840 Hempland Road Mountville, PA 17554 Jae Hong Chung Or Occupants 1800 Eliza Way, Lot 26 Mechanicsburg, PA 17050 FUQ-Q"t RPCk 'NOT OF THE Pp,0THC MY 2010 JEAN -2 PM 1: 41 CUM E i " . ? fN1Y PR NSYLVA?`yA Attorney for Plaintiff Court of Common Pleas Civil Division Cumberland County Term No. Ib -3(019 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 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 s (717) 249-3166 4Q1.Oo Po 1a-1w (888)-990-9108 '! PHS #: 225856 1q3 c)10 1. Plaintiff is American Home Bank, A Division Of First National Bank Of Chester County, f/k/a American Home Bank N.A. 2. Defendant is Jae Hong Chung Or Occupants. 3. Plaintiff is the record owner of premises located at 1800 Eliza Way, Lot 26 Mechanicsburg, PA 17050, 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 9, 2009, as evidenced by the Sheriff's deed recorded April 5, 2010 in the Office of the Recorder of Cumberland County in instrument # 201008198, a true and correct copy of which is attached hereto, made party hereof, and marked as Exhibit "N'. 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 possessioemises. T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele .Bradford, Esq., Id. No. 69849 Judith omano, Esq. Id. No. 58745 Y'r R. Shah-Jani, Esq., Id. No. 81760 R. Davey, Esq., Id. No. 87077 n n 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 EXHIBIT "A" ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201008198 Recorded On 4/5/2010 At 10:50:50 AM * Total Pages - 6 * Instrument Type - DEED Invoice Number - 63302 User ED - AF * Grantor - CHUNG JAE HONG 1705 fidef irv DR ? /6 / Q w * Grantee - MERICAN HOME BANK * Customer - SHERIFF * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $12.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 Certification Page DO NOT DETACH This page is now part of this legal document. ROD ARCHIVES FEE $3.00 CUMBERLAND VALLEY SCHOOL $0.00 DISTRICT HAMPDEN TOWNSHIP $0.00 TOTAL PAID $63.00 I Certify this to be recorded in Cumberland County PA ° RECORDER O D DS i * - information denoted by an asterisk may change during the verification process and may not be reflected on this page. OOOPQO Ill llllilllllllll llllllll lii he?me Know all Men by these Presents Tax Parcel No. 10-14-0842-179 111111111111111111 OOOPQO That I, 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 American Home Bank, a Division of First National Bank of Chester County, f/k/a American Home Bank, N.A. Writ No. 2008-3030 Civil Tenn American Home Bank, N.A. Vs Jae Hong Chung Dong Nyeo Chung ALL THAT CERTAIN parcel of land located in the Township of Hampden, County of Cumberland, State of Pennsylvania accordance with a plan entitled 'Final Subdivision Plan for Watts Tract, dated August 19, 1999 and last revised July 25, 2000. Said parcel being more fully described as follows: BEGINNING at an iron pin to be set located along the northern right of way line of Eliza Way at the dividing line between unit 27 and unit 26 as shown on the above said plan; thence along unit 27, North 19 degrees 22 minutes 18 seconds West, a distance of 184.57 feet to an iron pin to be set along the land now or formerly of Frank & Donna Conte; thence along said lands and lands now or formerly of Pamay Development Co. and lands now or formerly of Robert & Deborah Lekberg, South 79 degrees 13 minutes 23 seconds East, a distance of 369.64 feet to an iron pin to be set at the dividing line between unit 25 and unit 26; thence along unit 25 the following (2) two courses and distances: 1. South 02 degrees 37 minutes 05 seconds West, a distance of 94.36 feet to an iron pin to be set; 2. South 74 degrees 21 minutes 58 seconds West, a distance of 214.91 feet to an iron pin to be set along the eastern right-of way line of Eliza Way as shown on the above said plan; thence along Eliza Way, along a curve to the left having a radius of 70:00 feet, a delta angle of 93 degrees 44 minutes 16 seconds, an arc length of 114.52 feet, and a chord bearing and distance of North 62 degrees 30 minutes 10 seconds West, 102.17 feet, to an iron pin to be set at the dividing line between unit 26 and unit 27, the place of BEGINNING. CONTAINING 1.135 acres or 49,441 square feet more or less. Subject to all covenants and agreements of record. C BEING LOT 26 as shown on the Final Subdivision Plan of the Watts Tract prepared by Dawood Engineering, Inc. dated August 19, 1999 (cover sheet dated July 22, 1999), last revised July 25, 2000 and recorded in Cumberland County Plan Book 81, Page 99. UNDER AND SUBJECT to the Declaration of Pinehurst Hills, a Planned Community, dated September 7, 2000 and recorded September 15, 2000 in Cumberland County Recorder of Deeds Office in Misc. Book 654, Page 1002. FURTHER UNDER AND SUBJECT to restrictions, reservations, easements and conditions of record. BEING THE SAME PREMISES which was conveyed to Jae Hong Chung and Dong Nyeo Chung, h/w, by Deed from W. Lee Roland and Rosalie H. Roland, h/w, dated 06/08/2006, recorded 06/13/2006, in Deed Book 275, page 619. PREMISES: 1800 Eliza Way, Lot 26 Mechanicsburg, PA 17050 TAX PARCEL NO.: 10-14-0842-179 The same having been sold by me to the said grantee on the 9th day of December Anno Domini Two Thousand and Nine (2009) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 26th of August Anno Domini 2009 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Eight (2008) Number 3030 at the suit of American Home Bank, N.A. -vs- Jae Hong Chung and Dong Nyeo Chung in Witness Wereof, I have hereunto affixed my signature this 30th day of December Anno Domini Two Thousand and Nine (2009) R. Thomas Kline, eriff Commonwealth of Pennsylvania, ss. County of Cumberland Before the undersigned, Renee Simpson, First Deputy of the 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 30th day of December Anno Domini Two Thousand and Nine (2009) ell NOTARIAL SEAL PROTHONOTARY, NOTARY PUBLIC ISLE CUMBERLAND COUNTY COURTHOUSE COMMISSION EXPIRES JANUARY 4, 2010 ty for the Pro onotary of epu +FD ourt of Common Pleas of Cumberland County, Pennsylvania I hereby certify that the residence And Post Office address of the Within Grantee is 3840 Hempland Road Mountville, PA 17554 K 1011-01 Solicitor 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 falsificatior ? A40 Date tiLLorney for riumuiu SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ~9t~},tr ~l ~'uinbcfi}~~r D ~~ s ~ ~ , ~~ r. , . Q~fI~rE f~'~ THE ~"Ri~F F}~E['-~~riCE `,~~ ?N~ ~ ;'~'''' , ,~;;-may ZOlO J~1~~~ -9 A~ 8~ 43 American Home Bank NA Case Number vs. Jae Hong Chung 2010-3619 SHERIFF'S RETURN OF SERVICE 06/04/2010 04:05 PM -Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on June 4 2010 at 1610 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Occupant of 1800 Eliza Way Lot 26, Mechanicsburg, PA 17050 , by making known unto Young Choonhan, current occupant at 1800 Eliza Way Lot 26, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. L~£/!~- STEPHEN BENDER, DEPUTY 06/04/2010 04:05 PM -Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on June 4 2010 at 1610 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Jae Hong Chung, by making known unto Young Choonhan, Grandmother of defendant at 1800 Eliza Way Lot 26, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. LG/[_--! TEPHE BENDER, DEPUTY SHERIFF COST: $53.44 June 07, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF cl founiySuite Sheriff. Teleosoft. Inr.. 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 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 Tsbas, 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. Goldmaa, Esq., Id. No. 205047 Courtenay R Dunn, Esq. Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 One Penn Center @ Suburban Station Suite 1400 Philadelphia, PA 19103 (2151563-7000 American Home Bank NA vs Jae Hong Chung Or occupants 1800 Eliza Way, Lot 26 Mechanicsburg, PA 17050 ,`.., - ~~r~p~3.~.ot ~~-=. . .~ Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION No. 2010-3619 Cumberland County PRAECIPE FOR JUDGMENT IN EJECTMENT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff, American Home Bank NA and against the Defendant(s) Jae Hong Chung and Or occupants for possession of premises 1800 Eliza Way, Lot 26, Mechanicsburg, PA 17050 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. Phelan, alli Sc 'eg, LLP Lawrence T. Phel sq., Id. No. 32227 Francis 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 Default Judgment entered as indicated above Chrisovalante P. Fliakos, Esq., Id. No. 94620 DATE Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq. Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff s ~y.oo p~- "~" G~~` q8'~t X07 f~o~cG ~t leoC Phelan Hallman and Schmieg, LLP 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 (215)563-7000 American Home Bank NA Plaintiff Court of Common Pleas V Jae Hong Chung or occupants Defendant TO: !ae Hong Chung or occupants 1800 Eliza Way, Lot 26 Mechanicsburg, PA 17050 DATE OF NOTICE: July 21, 2010 Civil Division No. 2010-3619 Cumberland County **TH[S FIRM [S A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED W[LL BE USED FOR THAT PURPOSE. [F YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE M BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THLS CORRESPONDENCE [S NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** IMPORTANT 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: OFFICE OF THE PROTHONOTARY CU AND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 UTH BE STREET 1 COURTHOUSE SQUARE CA E, PA 17013 CARLISLE, PA 17013 (717) 249-3166 (717)240-6195 By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallman, Esq., id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., [d. 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 20233 Jay B.lones, 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 r Phelan, Hallman &Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallman, 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 RShah-Jana, 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 One Penn Center @ Suburban Station Suite 1400 Philadelphia, PA 19103 r21s 563-7000 American Home Bank NA vs Jae Hong Chung Or occupants 1800 Eliza Way, Lot 26 Mechanicsburg, PA 17050 Attorney for Plaintiff COURT OF COMMON PLEAS CML DIVISION No. 2010-3619 Cumberland County VERIFICATION OF NON-MILITARY SERVICE I hereby verify that I am Attorney for Plaintiff in the above captioned matter, and that on information and belief, I have 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 Jae Hong Chung Or occupants Or occupants, is over 18 years of age, and resides at 1800 Eliza Way, Lot 26, Mechanicsburg, PA 17050. This statement is made subject to the penalties of 18 PA. C.S. relatmg sworn falsification to authorities. Phelan, Hallman &Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallman, 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 20233 - 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 PHS# 203608 Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff F1..~=; ,_ T ~-~' ,~ .'f ~-- ~~oAu9'1~ AM 10:O~ J ..v ~ ~ f DISCOVER BANK Plaintiff vs. ASHLEY JANEL BROWN Defendant No: 10-3871 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue,-Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 08332794 C A Pit SGM Judgment Amount $2195.36 ~I~.oo PQ ~-'tr/ C~ ~7~65(0 5 ~~ a~losgy IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ~~ ~~~ DISCOVER BANK Plaintiff vs. ASHLEY JANEL BROWN TO THE PROTHONTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 10-3871 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT . Kindly enter Judgment against the Defendant ASHLEY JANEL BROWN above named, in the default of an Answer, in the amount of $2195.36 computed as follows: Amount claimed in Complaint Less payments / adjustments made Interest on the remaining principa $1904.49 from April 10, 2010 to @ the interest rate of 28.990$ Attorney's fees TOTAL $1904.49 $o.oo 1 balance of July 29, 2010 per annum $165.87 $125.00 $2195.36 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.F.A. By: James C. 08332794 C/A fit SGM Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, P 15219 And that the last known address of the De dant is ASHLEY JANEL BROWN 325 EUTAW AVE NEW CUMBERLAND, PA 17070 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 10-3871 CIVIL TERM ASHLEY JANEL BROWN NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order of Judgment was entered against you on B~~~JIO (xx) Assumpsit Judgment in the amount of $2195.36 plus costs. ( )..Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Pro By: ASHLEY JANEL BROWN 325 EUTAW AVE NEW CUMBERLAND, PA 17070 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 10-3871 CIVIL TERM NON-MILITARY AFFIDAVIT ASHLEY JANEL BROWN The undersigned, who first duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant ASHLEY JANEL BROWN is not in military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMSC), which states that the DMDC does not possess any information indicating the individual status. ASHLEY JANEL BROWN 325 EUTAW AVE NEW CUMBERLAND, PA 17070 is not in the military service. Further Affiant sayeth naught. Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Aug-03-2010 06:21:19 Last First/Middle Begin Date Active Duty Status Active Duty End Date Service A enc Name g y ASHLEY Based on the information you have furnished, the DMDC does not possess BROWN JANEL any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). rte, r~ .1~.~,-a~.- Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/faq/pis/PC09SLDR.htm1. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 8/3/2010 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Case No. 10-3871 CIVIL TERM vs. ASHLEY JANEL BROWN Defendant IMPORTANT NOTICE TO: ASHLEY JANEL BROWN 325 EUTAW AVE NEW CUMBERLAND, PA 17070 Date of Notice: Z- 1 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 AGT WITHIN TEN GAYS 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 PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, THlS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 A7 A REOUCEO FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 248-3166 WELTMAN, WEIN~f~G~ REIS CO., L.P.A. gy; ® y Matthew Urban P.A. I. D.# 90963 WELTMAN, WEINBERG &REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 8332794 A PIT T4S r •r _- PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND American Home Bank NA vs Jae Hong Chung Or occupants 1800 Eliza Way, Lot 26 Mechanicsburg, PA 17050 COURT OF COMMON PLEAS CIVIL DIVISION No. 2010-3619 Cumberland County PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of 1800 Eliza Way, Lot 26, Mechanicsburg, PA 17050 **PLEASE SEE THE ATTACHED LEGAL Being Known as No. 1800 Eliza Way, Lot 26 Lawrence T. Phelan, Esq., Id. No. 32227 Francis 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 c~ ~, -- _ , - -~, ~,. _ _., -, 4~ 3 ..~ ..~... -. s 2`l• D0 P~~~ ~~ q~oo~ R-~ ~,~1~7/~ 4' /y.OQ c orb B ~ `q~, oo a p ~ ~3,y`1 r u a~ ~~'3, y~ pd-~j ~'~,,oa ~~~ Co ~~ ` ALL THAT CERTAIN parcel of land located in the Township of Hampden, County of Cumberland, State of Pennsylvania accordance with a plan entitled 'Final Subdivision Plan for Watts Tract', dated August 19, 1999 and last revised July 25, 2000. Said parcel being more fully described as follows: BEGINNING at an iron pin to be set located along the northern right of way line of Eliza Way at the dividing line between unit 27 and unit 26 as shown on the above said plan; thence along unit 27, North 19 degrees 22 minutes 18 seconds West, a distance of 184.57 feet to an iron pin to be set along the land now or formerly of Frank & Donna Conte; thence along said lands and lands now or formerly of Pamay Development Co. and lands now or formerly of Robert & Deborah Lekberg, South 79 degrees 13 minutes 23 seconds East, a distance of 369.64 feet to an iron pin to be set at the dividing line between unit 25 and unit 26; thence along unit 25 the following (2) two courses and distances: 1. South 02 degrees 37 minutes 05 seconds West, a distance of 94.36 feet to an iron pin to be set; 2. South 74 degrees 21 minutes 58 seconds West, a distance of 214.91 feet to an iron pin to be set along the eastern right of way line of Eliza Way as shown on the above said plan; thence along Eliza Way, along a curve to the left having a radius of 70.00 feet, a delta angle of 93 degrees 44 minutes 16 seconds, an arc length of 114.52 feet, and a chord bearing and distance of North 62 degrees 30 minutes 10 seconds West, 102.17 feet, to an iron pin to be set at the dividing line between unit 26 and unit 27, the place of BEGINNING. BEING Lot 26 as shown on the Final Subdivision Plan of the Watts Tract prepared by Dawood Engineering, Inc. dated August 19, 1999 (cover sheet dated July 22, 1999), last revised July 25, 2000 and recorded in Cumberland County Plan Book 81, Page 99. a - _~ i lot 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN HOME BANK NA VS. No. 10-3619 Civil Term JAE HONG CHUNG OR OCCUPANTS 1800 ELIZA WAY, LOT 26 MECHANICSBURG, PA 17050 Costs Attorney's $ 183.44 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)) AMERICAN HOME BANK NA being: (Premises as follows): 1800 ELIZA WAY LOT 26, MECHANICSBURG, PA17050 (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 AUGUST 12, 2010 (Seal) Da ell, rothonotary, Common Pleas Court of Cumberland County, PA . ~ 2 of 2 No 10-3619 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN HOME BANK NA VS. JAE HONG CHUNG OR OCCUPANTS, 1800 ELIZA WAY, LOT 26 MECHAICSBURG, PA 17050 WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 183.44 Plff (s~, $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: VNEK SRIVASTAVA, ESQ., PHELAN HALLINAN & SCHMIEG, LLP, SUITE 1400, 1617 JFK BOULEVARD, PHILADELPHIA PA 19103-1814 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 ALL THAT CERTAIN parcel of land located in the Township of Hampden, County of Cumberland, State of Pennsylvania accordance with a plan entitled 'Final Subdivision Plan for Watts Tract', dated August 19, 1999 and last revised July 25, 2000. Said parcel being more fully described as follows: BEGINNING at an iron pin to be set located along the northern right of way line of Eliza Way at the dividing line between unit 27 and unit 26 as shown on the above said plan; thence along unit 27, North 19 degrees 22 minutes 18 seconds West, a distance of 184.57 feet to an iron pin to be set along the land now or formerly of Frank & Donna Conte; thence along said lands and lands now or formerly of Pamay Development Co. and lands now or formerly of Robert & Deborah Lekberg, South 79 degrees 13 minutes 23 seconds East, a distance of 369.64 feet to an iron pin to be set at the dividing line between unit 25 and unit 26; thence along unit 25 the following (2) two courses and distances: 1. South 02 degrees 37 minutes 05 seconds West, a distance of 94.36 feet to an iron pin to be set; 2. South 74 degrees 21 minutes 58 seconds West, a distance of 214.91 feet to an iron pin to be set along the eastern right of way line of Eliza Way as shown on the above said plan; thence along Eliza Way, along a curve to the left having a radius of 70.00 feet, a delta angle of 93 degrees 44 minutes 16 seconds, an arc length of 114.52 feet, and a chord bearing and distance of North 62 degrees 30 minutes 10 seconds West, 102.17 feet, to an iron pin to be set at the dividing line between unit 26 and unit 27, the place of BEGINNING. BEING Lot 26 as shown on the Final Subdivision Plan of the Watts Tract prepared by Dawood Engineering, Inc. dated August 19, 1999 (cover sheet dated July 22, 1999), last revised July 25, 2000 and recorded in Cumberland County Plan Book 81, Page 99.