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Home My WebLink About04-2891Federman and Phelan, LLP By: Francis S. Hailinan, Esquire Identification No. 62695 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103 (215) . 63-7000 Attorney for Plaintiff U.S. Bank National Association, as Trustee under The Pooling and Servicing Agreement, dated as of October 1, 2002, among Credit-Based Asset Servicing and Securitization LLC, PPT ABS LLC, Litton Loan Servicing LP and U.S., Bmxk National Association, PPT Asset-Backed Certificates, Series 2002-1, Without Recourse 4828 Loop Central Drive Houston, TX 77081-2226 Bonnie L. Wemi Or Occupants 4708 East Trindle Road Mechanicsburg, PA 17050 Court of Common Pleas Civil Division Cumberland County Term No. Oq CIVIL ACTION - LIECTMENT **This firm is a debt collector attempting to collect a debt and any information obtained will be used for that pm~se. If you have previously received a discharge/n banlcruptcy and th/s debt was not rea/Hrmed, this correspondence is not and should not be construed to be an attempt to collect a debt, but only enforcement of a lien against woperty.** NOTICF, You have been sued in court. If you wish m defend against the claims set forth in the following pages, you must take action within twenty (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 any other claim or relief requested by the plafutSff. 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, got to or telephone the office set forth below. This office can provide you with the information about hiring a lawyer. If you catmot 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800) 990-9108 Plaintiffis U.S. Bank National Association, as Trustee under The Pooling and Servicing Agreement, dated as of October 1, 2002, among Credit-Based Asset Serv/cing and Securitization LLC, PPT ABS LLC, Litton Loan Servicing LP and U.S., Bank National Association, PPT Asset-Backed Certificates, Series 2002-1, Without Recourse. 2. Defendant is Bonnie L. Wemi Or Occupants. Plaintiff is equitable owner of premises located at 4708 East Trindle Road, Mechanicsburg, PA 17050, a legal description of which is attached. Plaintiff became equitable owner of said premises as a result of foreclosure and judicial sale by the Sheriffof Cumberland County, on Jnne 9, 2004. Plaintiff, by virtue of the above, is the equitable 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. Plaintiffhas 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. Attorneys for Plaintiff Order Number: A83052 Client Number: 1691803 Premise~: 4708 'EAST TRINDLE ROAD, TOWNSHIP OF HAMPDEN CUMBERLAND COUNTY PENNSYLVANIA Based upon the examination of evidenc~ in the appropriate public records, Company cenif'ms that thc premises endorsed hereon are .subject to Se liens, e~:umbrar~ces and exceptions to title hereinafter set forth. This Certificate does not constitute title insucance; liability hereunder is asstuned by the Company solely itl its capacity as an obstructor for its negligence, mistakes or omissions in a sum nut to exceed Two Thousand Dollars. _DESCRIPTION ALL TItAT CERTAIN lot. piece or parcel of ground situate in Hampden Township. Cumber'land County. Pe,nsylvania. bo-nded and described as follows, to wit: BEGINNING at aa iron pin in the Southern right-of-way line of thc Triudle Spring Road at the North~.st corner of lands N/F of Thomas C. and Betty J. Mitchell; thence North aixty-eight (68) degrees zero (0) minutes -l~st, eighty (80) feet along said right-of-way line [o a~ iron pin: thence South twenty-five (25) degrees twenty-three (23) minuY,~s East, one hundred fifty-nat and seven tenths (151 feec along the lmds N/F of Fredrick T. and Adeline E. Fox to an iron pm: thence Sotlfll sixty-eight (68) degrees fifty-two (52) minutes West, eighty (80) feet along lands N/F of George E. Schweitzer oral. to an kon pin; thence North cwentyffive (25) degrees twenty-three (23) minutes Wes~ one hundred fifty and five teulhs (150.5) feet along lan4s N/F of the said Thomas C. and Betty J. Mitchell, to the place of beginning. HAVING then'eon erected a one stOry brick dwelling house. TAX PARCEL #10-22-0527-t48 VERIFICATION Francis S. Hall/nan hereby states that he is the attorney for the Plaintiff in this eviction action and is authorized to make this verification. The statements nuade 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 inan, Es~fiire r Plaintiff Federman and Phelan, LLP By: Francis S. Itallinan, Esquire Identification No. 62695 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103 (21 S) Aurora Loan Services, Inc. 601 5th Avenue Scottsbluff, NE 69361 Kcvin F. Gill Or Occupants 4 Dartmouth Court Mechanicsburg, PA 17055 Attorney for Plaintiff Court of Common Pleas Civil Division Cumberland County Term CIVII. ACTION - EJIE, CTM'ENT **This firm is a debt collector attemptin~ to collect a debt and any information obtained wilt be used for that purpose. yon have previously received a discb~ge in bankruptcy and this debt was not real~'med, 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.** NOTIf"F. 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 t~venty (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 any 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, got to or telephone the office set forth below. This office can provide you with the information about hiring a lawyer. ff 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 fcc or no fec. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800) 990-9108 Plaintiffis Aurora Loan Services,/nc.. Defendant is Kevin F. Gill Or Occupants. Plaintiff is equitable owner of premises located at 4 Dartmouth Court, Mechanicsburg, PA 17055, a legal description of which is attached. Plaintiffbecame equitable owner of said premises as a result of foreclosure and judicial sale by the Sheriffof Cumberland County, on June 9, 2004. Plaintiff, by virtue of the above, is the equitable owner of said pren~ises, 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. Plaintiffhas 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. /~ Fra~ Federman, Esquire ~ L~re. nc~e ~T; .P..halen, Esquire ~Francis ~. Hallinan, Esquire Attorneys for Plain~ff l~emises: 4 DARTMOUTH COURT, TOWNSIIlP OF UPPER ALLEN CUMBERLAND COUNTY PENNSYLVANIA Based upon the examination of evidence in the appropriate public records, Company certifi~ tlmt the premises endorsed hereon are subject to the liens, encumbrances and exceptions to title hereinafter set t6rth, This Certificate does not constitute title insurance; liability hereunder is assumed by the Company ,solely in its capacity as an abstracter for its negligence, mistakes or omissions in a sum not to exceed Two Thousand Dollars. DESCRIPTION ALL TItAT CERTAIN piece or parcel of land situate in Upper Allen Township, Cumberland County, Pconsylvania, a,s set thrth on a Final Subdivision Plan for Arlington Hills, prepared by Macomber Associates, Inc. and recorded io the Recorder of Deeds Office of Cumberland County, Pennsylvania, in Plan Book 36, Page 105, and more particu 'larly bounded and described as follows: BEGINNING at a point on the Northern right of way line of Dartmouth Cowl, a public street (50' wide), at the dividing line between Lots Nos. 142 and 141 as shown on tt~e aforementioned subdivision plan; THENCE along said right of way line of Dartmouth Court, North 78 degrees 08 minutes 55 seconds East a distance of 20.00 feet to a point at the dividing line between Lot Nos. 141 and 140; THENCE along same, Noah 11 degrees 51 minutes 05 seconds West, a distance of (18.94 feet to a point at lands now or formerly of Robert E. and Priscilla B. Gray; THENCE along same South 83 degrees t2 minutes 27 seconds West a distance of 20.08 feet to a point at the dividing line of Lot No. 142; TIIENCE along the dividing line of Lot No. 142, South Il degrees 51 minutes 05 seconds East a distmtce of 120_71 t~et to a point on the Northerly right of way line of Darmoutb Court, the po[ut and place of beginning. CONTAINING two thousands three hundred ninety-six (2,396) square feet, more or leas. HAVING thereon erected a three-story townhouse dwelling known and numbered as Dartmouth Court. BEING Lot No. 141 on the aforesaid Final Subdivision Plan for Arlington Hills. 'Fax Parcel #42-27-1890-I02 Date/ VERIFICATION Francis S. Hallinan hereby states that he is the attorney for the Plaintiffin 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 Plaintiff's 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 sheriff's 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. //" Fr~hcis S. Hallinan: .~E~uire ~A~torney for Plaintiff SHERIFF'S RETURN - REGULAR CASE NO: 2004-02891 P COMMONWEALTH OF PENNSYLVANIA: COD-NTY OF CUMBERLAND U S BA/qK NATIONAL ASSOCIATION VS WERNI BONNIE L ROBERT BITNER Cumberland County, Pennsylvania, says, the within COMPLAINT - EJECTMENT WERNI BONNIE L DEFENDANT , at at 4740 BRIAN ROAD MECHANICSBURG, PA 17050 FRANK A SEARS a true and attested copy of COMPLAINT - Sheriff or Deputy Sheriff of who being duly sworn according to was served upon 1340:00 HOURS, on the 28th day of June by handing to the EJECTMENT together with law, 2004 and at the same time directing His attention to the contents thereof. Additional Comments NO ONE LIVES AT 4708 E TRINDLE ROAD MECHANCSBURG, HOWEVER THERE ARE THINGS INSIDE AND A DOG THERE. Sheriff's Costs: Docketing 18.00 Service 8.97 Affidavit .00 Surcharge 10.00 .00 36.97 Sworn and Subscribed to before me this ~ day of ~ ~rotho~otary ' , ' So Answers: R. Thomas Kline 06/29/2004 FEDERMAN & PHELAN FEDERMAN AND PHELAN, LLP By: Frank Federman, Esquire I.D. No. 12248 Lawrence T. Phelan, Esquire I.D. No. 32227 Francis S. Hallinan, Esquire I.D. No. 62695 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT, DATED AS OF OCTOBER 1, 2002, AMONG CREDIT-BASED ASSET SERVICING AND SECURITIZATION LLC, PTT ABC LLC, LITTON LOAN SERVICING LP AND U.S., BANK NATIONAL ASSOCIATION, PPT ASSET-BACKED CERTIFICATES, SERIES 2002-1, 14rITHOUT RECOURSE VS. Plaintiff Court of Common Pleas CUMBERLAND County No. 04-2891-CIVIL TERM BONNIE L. WERNI OR OCCUPANTS Defendant(s) PRAECIPE TO WITHDRAW COMPLAINT, WITHOUT PRE]UDICE r AND DISCONTINUE AND END TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the instant matter, without prejudice, and mark this case discontinued and ended, upon payment of your costs only. Federma~, Esquire nce T. Phelan, Esquire Francis S. Hallinan, Esquire Attorneys for Plaintiff