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HomeMy WebLinkAbout11-0392N Phel.In llallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. liallinan, 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. 'Cabas, 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 Allison F. Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 SOVEI IFIGN BANK 601 PENN STREE'I READING. PA 19601 V. KEITH D. BREAM or Occupants 514 SCHOOL AVENUE CARLISLE, PA 17013-3832 Attorney for Plaintiff FIL?D-OFFICE OF THE PROTHONOTARY 2011 JAR 13 AH10- 41 CUMB-- ' LINTY r7l .iA P Court of Common Pleas Civil Division CUMBERLAND County No. 26 11.3a;), CiV" Te"" 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 hav e 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 belom 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 PHS P 260597 ga,oo poab 11t; 104 7 gPq ?Z44 25383$ 1. 111 intiffis SOVEREIGN BANK. 2. Defendant is KEITH D. BREAM or Occupants. 3. Plaintiff is the record owner of premises located at 514 SCHOOL AVENUE, CARLISLE, PA 17013-3832, 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 12/08/2010, as evidenced by the Sheriff's deed recorded 01/07/2011 in the Office of the Recorder of CUMBERLAND County in Instrument No. 201101090. 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. i WHEREFORE, plaintiff seeks to recover possession of!said Ldwrence T. Phelan TEsq.,--Yd. No. X27 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 2 J irt'e R. Davey, Esq., Id. No. 87077 auren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay 13. 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. 2050,47 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 Attorney for Plaintiff Legal Description ALI, "CHAT CERTAIN house and lot of ground situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point at the northeastern corner of the herein described lot, which point of beginning is South 76 degrees West, a distance of 110 feet from the western line of School House Avenue, an 18 foot wide public street, which point on the western line of said School House Avenue is 241 feet South of the center line of Willow Street; thence from said point of beginning, South 14 degrees East, a distance of 70 feet to a point; thence South 76 degrees West, a distance of 61 feet to an iron pin in line of land now or formerly of Franklin Poore, Jr. and wife; thence by the same, North 14 degrees West, a distance of 70 feet to a stake; thence North 76 degrees Fast, a distance of 61 feet to a point, the Place of BEGINNING. HAVING thereon erected a 1 story stone ranch type dwelling house known as and numbered 514 School House Avenue. TOGETHER with the right to use in common with the owners and occupiers, their heirs and assigns, of the houses and lots of ground known as 510, 512, 514, 516 and 518 School House Avenue, the lot of land containing 70 feet in front on School House Avenue and extending westwardly, a distance of 110 feet, and lying immediately East of the above-described tract of land, f'or the purposes of ingress, egress and regress to the dwelling houses and lots surrounding said 70 x 110 loot tract of land, as well as for parking, recreational purposes, and for installation of water, sanitary sewer, storm sewer, gas, electric, telephone, and such other utility lines as may be necessary or convenient for the owners of the dwelling houses and lots of ground abutting said tract. BFING the same premises which George M. Morton, Jr. and Gerlinde B. Morton, his wife, by Deed dated February 20, 1992 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book N, Volume 35, Page 677, granted and conveyed unto Francis E. Freet, single person, Grantor herein. Premises: 514 School Avenue Ow 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 1 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 author 1? i? 1) tc Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Je a R. Davey, Esquire .auren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter.l. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Allison F. Wells, Esquire Attorney for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson SheriffILED-OFFIDE ?4NNrtrr OF THE PROTHONOTARY Jody S Smith Chief Deputy 2011 JAN 25 PM 12: 28 Richard W Stewart Solicitor CUMBERLAND COUNTY PENNSYLVANIA Sovereign Bank Case Number vs. 2011-392 Keith D. Bream SHERIFF'S RETURN OF SERVICE 01/21/2011 08:36 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on January 21, 2011 at 2036 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Keith D. Bream, by making known unto himself personally, at 514 School Avenue, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. W GUT ALL, DEPUTV- SHERIFF COST: $33.40 January 24, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF ci Gour t s ll c 5';' SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?4?t?ttr of C?r?1?4rrf?,?rA 0MCE %- S--RIFF y, of A. Sovereign Bank vs. Keith D. Bream Case Number 2011-392 SHERIFF'S RETURN OF SERVICE 03/03/2011 09:55 AM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on March 3, 2011 at 0955 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Keith d. Bream, by making known unto Lori Bream, Adult it Charge and wife of defendant, at 514 School Avenue, Carlisle, Cumberland County, Pennsylvania 17013 it: contents and at the same time handing to her personally the said true and correct copy of the same. SO ANSWERS, March 04, 2011 RON R ANDERSON, SHERIFF Gerald Worthing , Deputy (c GouotySuite Shentt, Teleoso 1, inc.