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HomeMy WebLinkAbout10-7274 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHESAPEAKE LOAN SERVICING, LLC, Plaintiff, vs. MELVIN E. EHLING a!k/a MELVIN EHLING and TERRE TENANT, Defendants. TO: DEFENDANT YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. BY:/ ,~ " ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THE ADDRESS OF PLAIN'T'IFF IS: 4 STATE ROAD, #520 MEDIA, PA 19063 AND THE DEFENDANT IS: 122 East Locust street Mechanicsburg, PA 17055-384 ~_- BY: ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE WHICH IS THE SUBJECT OF THIS LITIGATION IS: 122 East Locust Street, Mechanicsburg, PA 17055-3840 Borough of Mechanicsburg, 2°d Ward BY: ATTORNEY FOR PLAINTIFF CIVIL DIVISION <:":a r..a c""7 t~ +_`~ ; T ~~ ~ ~ ~7 :-r7 C ° ~ ~: --, ~° ~- ._. ~a~ ~~ .;~ Issue No.: Code: TYPE OF PLEADING: CIVIL ACTION - EJECTMENT COMPLAINT FILED ON BEHALF OF: PLAINTIFF COUNSEL OF RECORD FOR THIS PARTY: KIMBERLY J. HONG, ESQUIRE PA I.D. #74950 P.O. BOX 285 OAKMONT, PA 15139 (412) 841-4493 P~~ ~9~ G° ~~ ~'~"y n~~ ~~~~ ,~~~ as ~ ~5~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHESAPEAKE LOAN SERVICING, LLC, Plaintiff, No.. vs. MELVIN E. EHLING a/k/a MELVIN EHLING and TERRE TENANT, Defendants. NOTICE TO DEFEND 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 TWENTY (20) DAYS AFTER THIS COMPLAIT 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 CLAIl~iED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IIVIPORTANT 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: Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHESAPEAKE LOAN SERVICING, LLC, Plaintiff, No.. /~ ` ~ ~~ ~ GNl vs. MELVIN E. EHLING a/k/a MELVIN EHLING and TERRE TENANT, Defendants. CIVIL ACTION -EJECTMENT AND NOW, comes Plaintiff, CHESAPEAKE LOAN SERVICING, LLC, by and through its attorney, Kimberly J. Hong, Esquire, and files this Complaint in Ejectment, averring in support thereof the following: 1. The Plaintiff is CHESAPEAKE LOAN SERVICING, LLC, with a business address of 4 State Road, #520, Media, Pennsylvania 19063 (hereinafter "Plaintiff'). 2. The Defendants are MELVIN E. EHLING a/k/a MELVIN EHLING and TERRE TENANT, individuals with a last known address of 122 East Locust Street, Mechanicsburg, PA 17055-3840 (hereinafter "Defendants"). 3. The premises known as 122 East Locust Street, Mechanicsburg, PA 17055-3840 (hereinafter "Foreclosed Premises"), which are described at Exhibit "A", attached hereto and incorporated herein by reference were sold at the Cumberland County Sheriffs Sale on September 8, 2010. The Sheriff's Sale was conducted on September 8, 2010, after due advertisement and according to law, under and by virtue of a Writ of Execution issued to satisfy a Judgment entered in the Court of Common Pleas for Cumberland County at the suit of Wells Farces Financial Pennsylvania. Inc. v. Melvin EhlinQ, as Court Docket Number 10-1918. 4. The Foreclosed Premises were purchased by the Plaintiff at the Sheriff's Sale, said sales results being a matter of public record. 5. The Plaintiff is the record and real owner of the Foreclosed Premises, pursuant to a Sheriffs Deed recorded on October 20, 2010 in the Cumberland County Recorder of Deeds at Instrument Number #201030008. 6. The persons in possession of the Foreclosed Premises are believed to be the Defendants in this action and are occupying the Foreclosed Premises without right and without claim to title. 7. Plaintiff has demanded possession of the Foreclosed Premises ftom the Defendants who have refused to deliver up the possession thereof. 8. Defendants have unjustly and unlawfully retained possession of the aforesaid Premises to the detriment of Plaintiff. WHEREFORE, Plaintiff, Chesapeake Loan Servicing, LLC, respectfully requests entry of judgment for immediate possession of the Foreclosed Premises, issuance of a Writ of Possession and a judgment of its costs and disbursements in this action. KIMBERLY J. HONG, ESQUIRE Kimberly J. Hong, Esquire Pa. I.D. #74950 Attorney for Plaintiff P.O. Box 285 OAKMONT, PA 15139 (412) 841-4493 '09/06/2018 13:30 ~.. aQ~ ~ ~oz :~ ~ ~ ~ c°> ~ ~ ~ A F- ~ "- ~ G= ~ Q N -,~ u= ~ C7 J M ~ •_. ;-. cv . C 570-374-4761 ~ ~ y~ w /Q k HARVEY P HURRAY JR Tax ~d No. i7-23-0565-171 PAGE 83/15 MADE TkLTS o~3r`~day of 14' uqus#-, inn tho year of our Lord two thausaod two (2002), ]A~~V1~N' MARX 1~ATLEX, x~av, C~tetar, ~ MEI.VJN E. Ts1~LING, C~tantx, ~1 ~!'71VESSETB, the in ~ ~ ~EV~N"I'Y TWO THOUSANl7 FNIr HUNDRED - - - (57~,540.00) DC1I.I.ARS, m hand laid., ~e xocti~c ~vl~p~of ~ ha,~y aclcttvwled~xl, the said duce - ~ asd ~'e9 to the said g~tLoe, b~is heirs affi assigns, Au. 'I'fIAT CSiTAIN h~ asd tar of Smtmd ao- tTyc south side a~ Eaac Stt~eet in the Sfeooud Ward a~f the Borough og Mrg, Coimtp of Ctimnbe~ct and State of lpfi-aa3~, b~vasded and descp'bed as So1Uo~vs, to wit BEGIlJI~NG a< a poiait on the ~ side of East l.acust Street at ~e cas»ex of the property sow or fcvs>er~y of John A. J ; the~toc ~vatdly the south side of said str~c sweaty a~qd fma C~p•s) ~ ~ a P~ ibesce Partidoa a-ala of the doable house, ~ which the lt~so a~ on a line tbie ~~ one fired d on tizis lat of ~ n~--thtea (193) fea, mgge of Icss, m St. Jo31n's~ the east half, eastwardly by said Alley twctntp and fnre-orbs (~p.3) Peet to a poaut ~ coraGr of p,y now oc faemerly of John A. A~nan Fss~C; t>tence n'~ ~$ the bioae of said property one huadred ffinety-tlmce (193) feet, more or less, to the sot~h side of Eau ~„ocaait S ~ d~ place of BEGINNING. The house crecoeci on tl~ above lot of grautd is ttte eastern half of a double frame dvweIling ltatsc, and numbered 122 Bast Irocx~ Street. 9oax 253 PAr~i.790 3J09N2010 12:47:06 PM Ct1M8ERtAND COUNTY k~s«F 2007.34642 - Page 1 of 3 EX ti,~~~~ ~' a '' X9/08/2010 13:36 570-374-4761 HARVEY P MIJRRAY JR PAGE 84/15 B,E~TC3 the same p w~ Raberc L. 5mysea aad ?~saie E. S~ysa, heard and wine, by ~ Hoed lased Sepoamber 23, 1935 artd ra~ottied ian t~mtberland Canny Drool Baodc I6- S, page 373. ~ J~~ ~ C. gamey and I~m~' may, ~~at~d and wife. Hoarser C. 8eatky ~ wlraa~ sok tide oo said pondmixs became vested im 1VIary Stag, by ~~TJ ~` ~ ~ to ea~a+e4se.~. U' ~ 1 ~ ~7 7D~.-J bey .8~~ rnvmana and agroca ~ she vv$1 wazraot specmlty tb~ prey IN WlTNF.SS WEER$pF, said gr ~ baennto ~ ~. hand anti seal the ley and year ideal above wri~,a. ~a~ ~~~ pce > ti ~ ~ Caurny of Cw~b~a ss. ~ ~, ~ z3 ~ day of ~, 9" r-E 20©2 bcbvre me the tmdersig~ged Qffioex, ~3' >Kary Kinky, >cavwn m mo (or s~~~ p m be the l~ wbioae name is subbed to the within ~, and ~ that ~ wed wane for the ~utpoaes tt-ei+ein cowed. l~1 WTt'NPSS WHEREOF, I ~,my band abd o~ial seal. -~~~ Notary Pablzc , NoT,wua~ s ~' Capp Born' C ~Lun 6 ~ N1y iNrxnf~lon ExpMes Jtsy ~. 2005 °.!!/~rr ~~ r vi ~/A9ROt0 1~4T.OE PM CUMBERLAND COUNTY Instal' 2A0294Rd~ . aa,,. ~ .,~ a VERIFICATION The undersigned does hereby verify subject to the penalties of 18 P.A.C.S. §4904 relating to unsworn falsifications to authorities, that she is the authorized representative of Chesapeake Loan Servicing, LLC, plaintiff herein, that she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of her knowledge, information and belief. _~ Shelby She SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff rt y FILED-OFFICE 4`L"1p GL tl,Mfirtf,ld OF THE i" RO 1 HONG bilk!? Jody S Smith Chief Deputy 2010 DEC -7 AM 8: 111 Richard W Stewart Solicitor E ; ERFF CUMBERLAND COUNTY PENNSYLVANIA Chesapeake Loan Servicing, LLC Case Number vs. Melvin Elwoo Ehling, Jr. 2010-7274 SHERIFF'S RETURN OF SERVICE 11/24/2010 08:46 PM - Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on November 24, 2010 at 2046 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Janet Warner, by making known unto herself personally, current occupant at 122 E. Locust Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. v VALERIE WEARY, DEPUTY 11/24/2010 08:46 PM - Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on November 24, 2010 at 2046 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Melvin Elwoo Ehling Jr., by making known unto Janet Warner, adult in charge at 122 E. Locust Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $53.00 November 29, 2010 VALERIE WEARY, DE TY SO ANSWERS, RON R ANDERSON, SHERIFF jci Gouty. sure S^e? `f. Te?eosoft. Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHESAPEAKE LOAN SERVICING, LLC, CIVIL DIVISION Plaintiff NO.: 10-7274-Civil n o 0 -? , z -n vs. ISSUE NO.: ? C3 --? o t C -n MELVIN E. EHLING a/k/a MELVIN EHLING and CODE: o r-) c1'rA TERRE TENANT, ?-' ` CO ;;o Defendants. TYPE OF PLEADING: PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE FILED ON BEHALF OF PLAINTIFF: Kimberly J. Hong, Esquire Pa. I.D. #74950 P.O. BOX 285 Oakmont, PA 15139 (412) 841-4493 J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHESAPEAKE LOAN SERVICING, LLC, CIVIL DIVISION Plaintiff, NO.: 10-7274 Civil vs. MELVIN E. EHLING a/k/a MELVIN EHLING and TERRE TENANT, Defendants. PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE Kindly Settle and Discontinue the instant action without prejudice. KIMBERLY J. HONG, ESQUIRE Kimberly J. Hong, Esquire Pa. I.D. #74950 Attorney for Plaintiff P.O. BOX 285 OAKMONT, PA 15139 (412) 841-4493