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Home My WebLink About12-3050li0helan Hallinan & Schmieg, LLP By: John Michael Kolesnik, Esq., Id. No.308877 Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza ? rV1 mo Philadelphia, PA 19103 . - t Cl) ,Ts c 215-563-7000 CHASE HOME FINANCE, LLC Court of Common Pleas 11 l 1 POLARIS PARKWAY '- `- COLUMBUS, OH 43240 Civil Division Plaintiff V. CUMBERLAND County CHRISTOPHER W. GONZALEZ or Occupants ' 360 OLD STATE ROAD No. 305 0 Vi GARDNERS, PA 17324-8938 Defendant 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 1'ou 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 # 299691 0-% /03.75 PO ATry k, a 75198 i. Plaintiff is CHASE HOME FINANCE, LLC. 2. Defendant is CHRISTOPHER W. GONZALEZ or Occupants. 3. Plaintiff is the record owner of premises located at 360 OLD STATE ROAD, GARDNERS, PA 17324- 8938, 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 09/08/2010, as evidenced by the Sheriffs deed recorded 10/13/2010 in the Office of the Recorder of CUMBERLAND County in Instrument No. 201029293, a true and correct copy of which is attached hereto, made party hereof, and marked as Exhibit "A". 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 has refused to deliver up possession of same. WHEREFORE, Plaintiff seeks to recover possession of the An Michael Kolesnik, Esq., Id. No.308877 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP EXHIBIT "A" PHS # 299691 I 6-2,- 11111111111'1 o? C_ 001 YEO ?j ? ?' Tax Parcel No. 08-38-2175-026 f1 08-38-2175-016 Know all Men by these Presents ( That 1, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $ 1.00 (One Dollar), to me in hand paid, do hereby grant and convey to Chase Home Finance, LLC Writ No. 2009-6443 Civil Term Chase Home Finan Vs Christopher W. Gonzalez Erin M. Ferguson TRACT NO. 1: ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described, as follows, to wit: BEGINNING at a point in the center of the old or abandoned road leading from Carlisle to Gettysburg; thence along the center of said road and lands now or formerly of Ella Myers, North 14 112 degrees East, 302.3 feet to a point in the center of said abandoned Carlisle-Gettysburg Road; thence along lands now or formerly of Mrs. Ardell Graver, South 81 degrees East, 145.4 feet to a point in the center of the concrete road leading from Carlisle to Gettysburg known as State Highway Route 34; thence along the center of said last mentioned highway and along lands now or formerly of Mrs. C.H. Musselman, South 6 3/4 degrees East, 337.1 feet to a point in the center of said State Highway Route 34; thence along lands now or formerly of Hoyt Sowers, North 76 degrees West, 266.5 feet to a point in the center of the old or abandoned Carlisle Road, the Place of BEGINNING. CONTAINING 1 acre, 79 perches and 101 square feet, as shown by the survey made by P.S. Orner, Registered Surveyor, on the 17th day of January, 1946. BEING improved with a dwelling house known as 360 Old State Road, Gardners. TRACT NO. 2: ALL THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described pursuant to a compass survey by Tom O. Bietsch, R.S., in August 1970, as follows: BEGINNING at a point in the center of the Old Gettysburg Road; thence by land now or formerly of G.E. Murray, South 73 degrees 45 minutes East, 150 feet to a stake; thence by land now or formerly of Eugene C. Jacoby, South 14 degrees 45 minutes West, 100 feet to a stake; thence by land now or formerly of Earl G. Rank, Jr., North 73 degrees 45 minutes West, 150 feet to a point in the center of Old Gettysburg Road aforesaid; thence by the center of said road, North 14 degrees 45 minutes East, 100 feet to the Place of BEGINNING. TITLE TO SAID PREMISES IS VESTED IN Christopher W. Gonzalez and Erin M. Ferguson, single persons, as joint tenants with right of survivorship, by Deed from Thomas E. Myers and Molly S. Myers and Robert J. Marsh and Amy L. Marsh, h/w, dated 1011812007, recorded 10/19/2007 In Instrument Number 200740138. PREMISES BEING: 360 OLD STATE ROAD, GARDNERS, PA 17324-8938 PARCEL NO. 08-38-2175-026/ 08-38-2175-016 The same having been sold by me to the said grantee on the 8th day of September Anno Domini Two Thousand and Ten (2010) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 29th of March Anno Domini 2010 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Nine (2009) Number 6443 at the suit of Chase Home Finance, LLC -vs- Christopher W. Gonzalez and Erin M. Ferguson In Witness Whereof, I have hereunto affixed my signature this 20th 'day7of C;eptember 1-1 Anno Domini Two Thousand and Ten (2010) Sheriff Commonwealth of Pennsylvania, ss. County of Cumberland Before the undersigned, David D. Buell, Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared Ronny R. Anderson, Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts Set forth in the foregoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. Witness my hand and seal of said Court, this 20th day of September Ann.o Domini Two Thousand and Ten (2010) Pr thonotary WW=.1D t I hereby certify that the residence And Post Office address of the ` Within Grantee is 3415 Vision Drive i r Columbus, OH 43219 Richard W. Stewart Solicitor ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201029293 Recorded On 10/13/2010 At 11:56:43 AM Instrument Type - DEED-SHERIFF'S Invoice Number - 74603 User ID - MSW * Grantor - GONZALEZ, CHRISTOPHER W * Grantee - CHASE HOME FINANCE LLC * Customer - SHERIFF OFFICE * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $12.50 RECORDER OF DEEDS PARCEL CERTIFICATION $20.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 CARLISLE AREA SCHOOL $0.00 DISTRICT DICKINSON TOWNSHIP $0.00 TOTAL PAID $73.00 * Total Pages - 5 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER O ID DS treo * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 11111111111111111111111111111 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 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 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 ai 1/////Z- _ Date J Michael Kolesnik, Esq., Id. No.308877 ney for Plaintiff n Hallinan & Schmieg, LLP PHS # 299691 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?4??a1a Gf ? IttN?tpr???? OFF,CECr t-E -ERIFF r L ,.-. '012 KAY 24 PM is ?g CUB 2ERLAND C0L'r4T PENNSYLVAMA Chase Home Finance LLC vs. Case Number Christopher W. Gonzalez 2012-3050 SHERIFF'S RETURN OF SERVICE 05/22/2012 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: Christopher W. Gonzalez, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Christopher W. Gonzalez. Request for service at 360 Old State Road, Gardners, Pennsylvania 17324 is vacant. SHERIFF COST: $44.00 SO ANSWERS, May 22, 2012 RON R ANDERSON, SHERIFF ( CountySuite Sheriff. Teiecsott. Ir:c. Phelan Hallinan & Schmieg, LLP Robert W. Cusick, Esq., Id. No.80193 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelhia, 215-563p-7000 A 19103 C O U N 1 ?i ?.?a?v .SYl?YA1?IA ourt of Common Pleas CHASE HOME FINANCE, LLC Plaintiff Civil Division Vs. CHRISTOPHER W. GONZALEZ Or Occupants Defendant(s) CUMBERLAND County No. 12-3050 CIVIL TERM PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached verification initially filed with the complaint in ejectment in connection with the above referenced action. Date: ' , Robert W. Cusick, Esq., Id. No.80193 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP PHS# 299691 VERIFICATION 1 10114 U67'tereby states that he/she is f!J& ViCc ?A,cS;d; --J (name (rile) of Prvicing agent for Plaintiff 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 is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. ell a l", " - Si DATE: a- PHS # 299691 Return to: Phelan, Hallinan & Schmieg, LLP One Penn Center, suite 1400 1617 JFK Boulevard Philadelphia, PA 19103 Attn: Eviction Department PHS # 299691