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Home My WebLink About05-1203 Phelan, Hallinan & Schmieg By: Francis S. Hallinan, Esquire Identification No. 62695 One Penn Center Plaza Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Attorney for Plaintiff Citifinancial Mortgage Company, Inc. F/K/A Citifinancila Mortgage Consumer Discount Company 8333 Ridge Point Drive Irving, TX 75063 Court of Common Pleas Civil Division v. Cumberland County Ronald E. Lambert Or Occupants 3 Elmwood Court Camp Hill, PA 17011 Term No. OS - j:(D] Ct'v~ L ~~1.-rJ CTVTJ. Ar.TTON - lj:JJU~'I'MRN'J' "''''This finn is a debt collector attempting to collect a debt and any intonnation 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 o1'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 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 loan: E5000195938 1. Plaintiff is Citifinancial Mortgage Company, Inc. F/K/A Citifinancila Mortgage Consumer Discount Company. 2. Defendant is Ronald E. Lambert Or Occupants. 3. Plaintiff is equitable owner of premises located at 3 Elmwood Court, Camp Hill, PA 17011, a legal description of which is attached. 4. Plaintiff became owner of said premises as a result of foreclosure and judicial sale by the Sheriff of Cumberland County, on March 2, 2005. 5. Plaintiff, by virtue of the above, is the equitable 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. WHEREFORE, plaintiff seeks to recover possession of said premises. ~.SW~ F ncis S. Hallinan, Esquire Attorney for Plaintiff AU. T1!A T CERT AIl'f pi=: or {lIrC4I of luKi, aiIll= in HlUIlpIleA To~ (off lbl: Ciearvlcw fin ~l, Cllmllerlaa4 c-t, ~yl'Allla, IJICtC pllrlicu1arly bounded IDd descrillcd IS ~1:IlWS. III \\ it: BE( ItNNINO lit . poiDt an the W_ty side of E1mwoad Court whicll pow II lit tile 4i~isiclllllle otLgIs N~. 20811l4 209 olllllc III:n:iDIftc mtmI~ pia ot lala; 1heIll:e So\UI1....eIlQ/~ dcF cell lbrty mi.aura West JlODC aid divlslan UIrl: . dis_ of ~ IlIl1lWc11tY-seYCll 0lW' IllmdmUItI rcc fO . poiau lit * cIiYlam llae =- Llll3 Not. 2l>> 111C1171 OD aid JlIa4: _::e Nattb I.WO aecms 1Ill1ty-aiIII: mi1lIItes We$. aIa1lg IIiQ dlvl"ioD lilac IIICI bcyolld a d~ 0( (I:IC lllaadl'cd ~ te.et fO . paiIlt OIl the SOIIdlm> lido or Lac No. 104 an Wd pIm; tbl:IlC= Sou lll'octy-two ~ twtlI~ IlliIIulI2 East liGIlJ tIIz: c1ivlalollllne b_ Locs Nos. 21Q moi7l1J l dII1lIZIco of cmr: lI1IDI1rId lItcy-twQ mf eicb=D ~ fc:r tl:I a. plliIR Oil * Wcotaly sidll ofBlmwood Cawt; IIIcDcc ill a ~Iy dl::aiOa 10 u w: slane SI1\rNQO\l ccun a dl '... offarl)'-tlve tcec to & poiDt, lIII: ~ of BeGINNlNG. IT llEINO Lot No. 209 all the G=l P\Aa at Scs:ticn 2 lIIlll 3 of ClclIrvlcw FarmI m:arded in PIal, BookS!, pap~_ SA "lNO rlIeteaa erected . siDJIe btia rallCll type dwelling, said pr=~ being known &lid _~ u Number 3 E!Imwood Court. VR~TFJ(WrTON Francis S. Hallinan hereby states that he is 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 sherifPs sale. I am making this verification rather than a representative of the Plaintiff because I have personal knowledge of the purchase ofthis property at sherifPs sale. The undersigned understands that this statement is made subject to the penalties d"f t-<7' ndte' of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. ~S.~ FranCIS S. Hallman, Esqmre Attorney for Plaintiff ~ \:) tI( Q i( \r1, \t- V( 1::. ~ , - - -lJ ~ In vv '" <:::Y cY -+-- ( ~ ~ <~ .::..!''' ~ ~ , cP C' (~! t;-;;. -.eCI :::<. o ." 9...' \~'\~ ;;,,<.:( '()\C) _,...~.~ "'f' ~, 0-"; ,~; ~ \~i~~ I';? '0 g ..- ..- SHERIFF'S RETURN - REGULAR CASE NO: 2005-01203 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIFINANCIAL MORTGAGE CO INC VS LAMBERT RONALD E CPL. TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon LAMBERT RONALD E t e DEFENDANT at 1245:00 HOURS, on the 21st day of March , 2005 at 3 ELMWOOD COURT CAMP HILL, PA 17011 by handing to MARIAN PATRICK, MOTHER IN LAW ADULT IN CHARGE a true and attested copy of COMPLAINT - EJECTMENT together ith and at the same time directing Her attention to the contents th reof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 10.36 .00 10.00 .00 38.36 So Answers: ?,f;J?~,~~~' R. Thomas Kline 03/22/2005 PHELAN HALLINAN SCHMIEG A.D. Sworn and Subscribed to before me this I J day of ..~~..1J c~ PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T. Phelan, Esquire J.D. No. 32227 Francis S. Hallinan, Esquire J.D. No. 62695 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff CITIFINANCIAL MORTGAGE COMPANY, INC. F/KIA CITIFINANCIAL MORTGAGE CONSUMER DISCOUNT COMPANY Plaintiff Court of Common Pleas CUMBERLAND County No. 05-1203-CIVIL TERM vs. RONALD E. LAMBERT OR OCCUPANTS Defendant( s) PRAECIPE TO WITHDRAW COMPLAINT, WITHOUT PREJUDICE, AND DISCONTINUE AND END TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the instant matter, without prejudice, and mark this case discontinued and ended, upon payment of your costs only. L/) //7 fl;Js / " Date 7~1?(!/~~ Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Attorneys for Plaintiff ~-:) ,.~\