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Home My WebLink About12-1982f ' Phelan Hallinan & Schmieg, LLP By: Allison F. Wells, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 HSBC BANK USA, NA, AS TRUSTEE FOR NHEL HOME EQUITY LOAN TRUST, SERIES 2006-WF1 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff V. MICHAEL A. DREBOT or Occupants 330 5TH STREET NEW CUMBERLAND, PA 17070-1912 Defendant Attorney for Plaintiff ;r ? ? AR, 28 r?F? 18 i ?, Court of Common Pleas ^Ui!BERLANO COUNT -, Civil Division s' -t4NSYLVANIA CUMBERLAND County 4117 01'V(1 No. A I a-- 19 p0 , 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 (717) 249-3166 PHS # 289526 6? 0 of % I ds75 Pd ?kt? li?ac?€a 2 ?f a73os9 al? L Plaintiff is HSBC BANK USA, NA, AS TRUSTEE FOR NHEL HOME EQUITY LOAN TRUST, SERIES 2006-WF 1. Defendant is MICHAEL A. DREBOT or Occupants. Plaintiff is the record owner of premises located at 330 5TH STREET, NEW CUMBERLAND, PA 17070- 1912, a legal description of which is attached. Plaintiff became the owner of said premises as a result of the foreclosure and judicial sale by the Sheriff of CUMBERLAND County, on 01/04/2012, as evidenced by the Sheriffs deed recorded 02/24/2012 in the Office of the Recorder of CUMBERLAND County in Instrument No. 201205574. 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. Plaintiff has demanded possession of the said premises from the said defendant who h deliver up possession of same. WHEREFORE, Plaintiff seeks to recover possession of the Premises. Allison F. Wells, Esq`, td-Nb.309519 Attorney for Plaintiff Legal Description ALL THAT CERTAIN lot, tract of land, parcel, piece of ground with the buildings and improvements thereon erected, in D. R. Kebaughs Addition to the Borough of New Cumberland as recorded in the Recorder's Office in Carlisle, Pennsylvania, known and numbered on said Plan as Lot No. 19, situate in New Cumberland Borough, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point distance Seventy-four and Five tenths (74.5) feet East of the easterly corner of Reno and Fifth Streets on the dividing line between Lot Nos. 29 and 20; thence eastwardly along the southerly line of Fifth Street, Twenty-five (25) feet to the line of Lot No. 18 on said Plan; thence southwardly along the said dividing line between Lot Nos. 18 and 19 at right angles to Fifth Street One Hundred Twenty-three (123) feet to the line of a Ten (10) foot wide public alley; thence westwardly along the line of said last mentioned public alley, Twenty-five (25) feet to the line of Lot No. 20; thence northwardly along the line of said Lot No. 20 and through the center of the partition wall of a double frame dwelling house, One Hundred Twenty- three (123) feet to Fifth Street, THE PLACE OF BEGINNING. BEING Lot No. 19 on said Kebaugh Plan of Lots as recorded at Carlisle and having thereon erected the easterly half of a two and one-half story frame dwelling house. BEING THE SAME PREMISES which Thomas Endrizzi, Executor of the Estate of Abigail Endrizzi, deceased, by Deed dated May 26, 1993 and recorded on June 17, 1993 in the Recorder of Deeds Office in and for Cumberland County in Deed Book 1-36, page 736, granted and conveyed unto Thomas Endrizzi, Grantor herein. Premises: 330 5TH STREET ? VERIFICATION Jennifer L. Williams hereby states that he/she is VP Loan Documentation for Wells Fargo Bank, N.A. as attorney in fact, for HSBC BANK USA, NA, AS TRUSTEE, FOR NHEL HOME EQUITY LOAN TRUST, SERIES 2006-WFI in this matter, that he/she is authorized to make this Verification, and that the statements made in the foregoing Civil Action in Ejectment are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement in made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Wells Fargo Bank, N.A. as attorney in fact for FISBC BANK USA, NA, AS TRUSTEE FOR NHEL HOME EQUITY LOAN TRUST, SERIES 2006-WFI , c DATE: y: J$QaWJrI- Williams T!Y- an Documentation PHS # 289526 Return to: Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400, One Penn Center Plaza Philadelphia, PA 19103 Attn: Eviction Department Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY _ `FLED-Or FICE 2012 APR 20 AM 8: 45 CUMBERLAND COUNTY _ PENNSYLVANIA HSBC Bank USA, N.A. Case Number vs. 2012-1982 Michael A. Drebot SHERIFF'S RETURN OF SERVICE 04/18/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Michael A. Drebot, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Michael A. Drebot. Request for service at 330 5th Street, New Cumberland, Pennsylvania 17070 is vacant. SHERIFF COST: $50.00 April 18, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF