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Home My WebLink About12-4645Phelan Hallinan & Schmieg, LLP By: Melissa J. Cantwell, Esq., Id. No.308912 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A., SB/M TO WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff V. BRIAN K. LANDIS or Occupants 7 WEST BEALE AVENUE ENOLA, PA 17025-2806 Defendant Attorney for Plaintiff OTNONOTA('r 201? JUL 25 AM 10: 30 Court of Common Ple%MBERLAND COUNTY Civil Division PENNSYLVANIA CUMBERLAND Coun? No. 19-gjp4S C.!UI 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 # 305307 C5) ?-? a?8yog Legal Description ALL THAT CERTAIN tract or parcel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Gerrit J. Betz, R.S. dated July 30, 1974, as follows: BEGINNING at a point on the northern line of West Beale Avenue, said point being 175 feet east of the northeast corner of West Beale Avenue and a 15 foot wide alley; thence along the division line between Lots Nos. 42 and Lots Nos. 40 and 41 on the hereinafter mentioned Plan of lots, North 05 degrees 30 minutes West, 150 feet to a point on the south side of Covert Street; thence along same, North 84 degrees 30 minutes East, 50 feet to a point on the division line between Lots Nos. 40 and 41 and Lot No. 39 on said plan; thence along same, South 05 degrees 30 minutes East, 150 feet to a point on the northern line of West Beale Avenue; thence along same, South 84 degrees 30 minutes West, 50 feet to a point, the Place of BEGINNING. HAVING THEREON ERECTED a one and one-half story frame dwelling and frame garage, known as 7 West Beale Avenue, Enola, PA 17025. Premises: 7 WEST BEALE AVENUE 1. Plaintiff is WELLS FARGO BANK, N.A., S/B/M TO WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC.. 2. Defendant is BRIAN K. LANDIS or Occupants. Plaintiff is the record owner of premises located at 7 WEST BEALE AVENUE, ENOLA, PA 17025-2806, 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 06/06/2012, as evidenced by the Sheriffs deed recorded 07/16/2012 in the Office of the Recorder of CUMBERLAND County in Instrument No. 201221095. 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 Premises. Melissa J. Cantwell, Esq., . No.308912 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP 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 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. . §49 4 relating to unsworn falsification to thorities. Date Melissa J. CantZ,., Id. No.308912 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP PHS # 305307 ~- I~~.~-~°FF1G~ Phelan Hallinan &Schmieg, LLP ~B:' '~ ~~~ p~S~~H~~~~A~~~ Melissa J. Cantwell, Esq., Id. No.308912 1617 JFK Boulevard, Suite 1400 ~~ ~ 2 AUG 2 4 PM { ~ ~ O One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ~'UMB~RLA GD~JNTY VANIACourt of Common Pleas WELLS FARGO BANK, N.A., SB/M TO WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff Civil Division Vs. CUMBERLAND County BRIAN K. LANDIS No. 12-4645-CV Or Occupants Defendant(s) 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: ~a ~ ~ By: Melissa J. Cantwell, Esq., 0.308912 Attorney for Plaintiff Phelan Hallinan &Schmieg, LLP PHS# 305307 VERIFICATION ~~~p,(/ SSa ~~/ I'~X~ hereby states that he/she is V I ~ ~, ~~a~al~u ~i (name ( (Tii~ of ~~,,r~T2W/il /V~ servicing 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 ofhis/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 unsworn faisifieation to authorities. DATE: „_,_ ~ ! /~ PHS # 305307 Return to: Phelan, Hallinan & Schmieg, LLP One Penn Center, suite 1400 1617 JFK Boulevard Philadelphia, PA 19103 Attn: Eviction Deparhnent Signature AWA.SON Vice President loan Documentation PHS # 3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy t f",rl, a. L1??i M 1i?4.. TFE PROThONOT, .€ Z012 SE° -ti AM D 13 Richard W Stewart Solicitor CUMBERLAND COUNTY PENNSYLVANIA Wells Fargo Bank, NA vs Case Number . Brian K. Landis 2012-4645 SHERIFF'S RETURN OF SERVICE 08/27/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on August 27, 2012 at 1110;hours, he was unable to serve a true copy of the within Complaint In Ejectment, upon the within nameld defendant, to wit: Brian K. Landis. After eight attempts at 7 W. Beale Avenue, Enola, Penn$ylvania 17025 Deputies were unable to find anyone at the residence. A neighbor advised only occasionally would they see anyone at this address. On August 24th, 2012 a sticker stating "property deemled vacant" was placed on the door of the residence. SHERIFF COST: $58.00 August 29, 2012 SO ANSWERS,' RON R ANDERSON, SHERIFF (c) County$uite Shenf, Teleosoft. Inc.