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Home My WebLink About04-3239Federman and Phelan, LLP By: Francis S. Hallinan, Esquire Identification No. 62695 One Penn Center Plaza Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Attorney for Plaintiff Chase Manhattan Mortgage Corporation 3415 Vision Drive Columbus, OH 43219 Douglas Loisell Or Occupants 427 Fairview Avenue Enola, PA 17025 Court of Common Pleas Civil Division Cumberland County Term No. c, CTVTT, AC, TTCIIST - E.]W,,c, qflwE, ISIT **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 hen 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 ff 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 rehef 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1. Plaintiff is Chase Manhattan Mortgage Corporation. 2. Defendant is Douglas Loisell Or Occupants. Plaintiff is equitable owner of premises located at 427 Fairview Avenue, Enola, PA 17025, a legal description of which is attached. Plaintiff became owner of said premises as a result of foreclosure and judicial sale by the Sheriff of Cumberland County, on June 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. Plaintiff has demanded possession of the said premises from the said defendant who has refused to deliver up possession of same. WHEREFORE, plaint'~ff seeks to recover possession of said premises. Attorney for Plaintiff IIEGINNING ~t a paint on the ner~em line ~ltl~ ~1 ~ t~e do.lo ~e ~lli~ ho~ 150 f~t to ~e P~k ~ p~ of BEGINNING. FI A~N6 ll'lerean ere~ad ~he weNem hail of sgid cloul~e frame dwelling being 1¢ ~ as 427 Fain~lew Ave~ut AND SUBJECT to any ex~Bng c~ven~, easements, ~nc~Khmen=, and for C~nberland County In Deed B~k le0, Page 2~7, grarRed and conveyed 'J,,qto Ten3, L. Throne end Audrey F. Throne. PREMISES ON 427 FAIRVIEW AVENUE Francis S. HaHinan 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 Plaintiff% predecessor in interest in the underlying foreclosure action. ! 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 representaU~ve 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. Attorney for Plaintiff SHERIFF'S RETURN - CASE NO: 2004-03239 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NOT FOUND CHASE MANHATTAN MORTGAGE CORP VS LOISELL DOUGLAS Thomas Kline duly sworn according to law, says, that he made a diligent inquiry for the within named DEFENDANT LOISELL DOUGLAS unable to locate Him in his bailiwick. ,Sheriff or Deputy Sheriff, who being search and but was He therefore returns the COMPLAINT - MORT FORE , the within named DEFENDANT 427 FAIRVIEW AVENUE ENOLA, PA 17025 427 , LOISELL DOUGLAS FAIRVIEW AVENUE ENOLA IS VACANT. NOT FOUND , as to Sheriff's Costs: Docketing 18.00 Service 11.10 Not Found 5.00 Surcharge 10.00 .00 44.10 So answers: R. Thomas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 07/13/2004 Sworn and subscribed to before me this /~ day of ~ ~ A.D. nota'ry ' 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 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff VS. DOUGLAS LOISELL OR OCCUPANTS Coqart of Common Pleas CUMBERLAND County No.. 04-3239-CIVIL TERM Defendant(s) P~RAECIPE_ TO I¥ITHDRAW COMPLAINT, WI'!'HOUT PREIUDICE ~AND DISCONTINUE AND EN~_~-'-~ -- ~ 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. Lawrence T. Phelan, Esquire Francis S. Hailinan, Esquire Attorneys for Plaintiff