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Home My WebLink About05-3123 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 Aurora Loan Services, Inc. 601 5th Avenue Scottsbluff, NE 69361 Court of Common Pleas Civil Division Cumberland County v. Patricia T. Mcallister Or Occupants 1431 Enola Road Carlisle, PA 17013 Term No. oS - 31)J {!/'vl.L ~~ CIVIL ACTION - EJECTMENT ""This firm is a debt collector attempting to collect a debt and any infonnation 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 loan: EOl04l53051 1. Plaintiff is Aurora Loan Services, Inc. 2. Defendant is Patricia T. Mcallister Or Occupants. 3. Plaintiff is equitable owner of premises located at 1431 Enola Road, Carlisle. PA 17013, 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 June 8, 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 withou.t right and so far as the plaintiff is informed. without claim of title. 6. Plaintiff has demanded possession ofthe said premises from the said defendant who has refused to deliver up possession of same. WHEREFORE, plaintiff seeks to recover possession of said premises. F ancis S. Hallinan, Esquire Attorney for Plaintiff ALL "tHAT CERTAIN tract or pllIl;el of land am! premluca, DIN.te. lying end b<:ing In the Town.hip of . Nor1b M\ddlaton in the County of Cumberland lU1d Comlt1onwealth of Penrtaylvanla. more: particulMly deacrlbed as foRo",.; BEGINNING at a point in th.. centel' DC /'l:nn4ylvanla Highway Route 944, th" Enola Road, on the dividing line bctwe= Lot Nos. .. and 5 on the hereinafter menliOllcd Plan of Lota; thence by said dividing Iinc:. South I" degre"" 30 It1inutea &tat, 392.89 l'eet lo II. point; thence South 79 degrcea 11 m1nute~ WI!at, 169.35 fllCllo a point; theacc II)' the c1Mding line bcewun Lot .Noa. S al'd 6 00 ","<1 PI_ DlLate, Norfu 14 degrc:ca 30 Ulfnutca West, 381 feet to a POint In the cCl'1tcTofPennayh'anla. Jnah""'Y ~Ollte 94<f, aloreaWd; thQlCc by the ea1tct DC aaid road. North 75 dcgn:ea 30 Jllioulea E:ast., 169 feet w the plw;c ofBEGINNlNO. :;QNTNNING 1.499 acres, mOre or 1<:50. aEING Lot No.5 on the Plan or Lota o(Mluy G. Ronan. Qa recotdc:d in the OUi"e of the Rccord..r of )ecd. lor Cumberl4xuf County in Plan Book 28, rage 20. ~E1NG J<nown IUld nUmbered as 1431 Enola Road, Cuu.lc,l'c:nn4yhlluJla.. - 3&NG TIlE SAME PImM.lSES V<hlch Ro.ytAOnd C. Bailey. Jr. and Shlrley Y. Ba.iley.lti_ wife. by Peed Iated Sc:ptclDber:W. 1989 anc1 n:e<m1C1l Oc1ober 8. 1989 In the Ofti<:e of the ~ OfOccda In rnd lor CumberlAnd County, PamsylVlU\la.In Peed Book F. Vo1uA>c 34. i>"8e 31, pantO!d and <IlJV~ unto Jam<:a..... Elc1ridgc and Pl\yllla 1. Eldridge, his wife, Gnmf<lr>> herein. -.-t.' ,~~ . . . VERIFICATION 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 sheriff's 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 sheriff's sale. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. b Jsjr,- DatE! rancis S. Hallinan, Esquire Attorney for Plaintiff ~ \.. - () V'\ ~ -IC. l.r( lrt V( -t. \J ~~ ~t ~ ~ '7'- \\- Q ~2'. i' ,...> (",--~',,> ~ ~, ..,." ,.:.:- ~ 0' ~ .-\ ::r:.,., rl1r _am .,<:;:1 c:),c:) ~1::T1 'I:)C~ Zrn , , -~ ~p -4 re ....., > r;-? (n c'" - PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T. Phelan, Esquire I.D. No. 32227 Francis S. Hallinan, Esquire I.D. No. 62695 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff AURORA LOAN SERVICES, INC. Plaintiff Court of Common Pleas CUMBERLAND County No. 05-3123-CIVIL TERM VS. PATRICIA T. MCALLISTER 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. ;;/dc5/(}~ Date +~/l~/~ Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Attorneys for Plaintiff "-lo ("2 "', c.? = '..." (-- c:: r--- 1".) -' -v -c 1;? C') , cr-