The URL can be used to link to this page

Home My WebLink About05-4891 ..., 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 Countrywide Home Loans, Inc. 7105 Corporate Drive PIano, TX 75024 Court of Common Pleas Civil Division Cumberland County v, Gregory A. Rowe Or Occupants 447 3rd Street West Fairview, PA 17025 Term No, tJ5- Lj'ttfl q;J 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 2 LlBERTY AVENUE CARLISLE, PAl 70 13 (717) 249-3166 loan: E51302809 1. Plaintiff is Countrywide Home Loans, lnc, 2, Defendant is Gregory A. Rowe Or Occupants, 3. Plaintiff is equitable owner of premises located at 447 3rd Street, West Fairview, PA 17025, 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 September 7, 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. ~AO?105sJ1~ rancis S, Hallinan, Esquire Attorney for Plaintiff - Lceal D$rinooll: tAl sho1Vll. In Mort~} ALL THAT CERTAIN LO'r OR PIECE OF GROUND SITUATE IN THE BOROUGH 0' WEST FAIRVltW, NOW THE TOWNSHIP OF EAST PENNSBORO. CUMlJERLAND COUNTI'. PENNSYLVANIA. BOUNDED ANO Pl:$ClU1lEP IN ACCORDANCE WITH A SURVH:\' AND PLAN THEREOF MADE BY ERNFSf J. WALKER, PROFt:SSIONAL ENCINEER. DATED IVL\' U, 196&, AS FOLLOWS: BEGINXING AT THE INTERSEcrrON OF TIlE NOR.THEASTERN LINE OF TQlRO STREET AND THE SOUTHEASTERN LINE OF LOCUST STREET. THENCE AWNGWCUST STREET NORTH OS DEGREES 5S MINUTES EAST 1 t, FEET TO THE SOUTHWESTERN UNI!: OF AN ALLEV; Tl<<NCE ALONG SAID ALLEV SOurH 34 DEGREES 55 MINUTES EAST D.1l FEET TO A POST AT A CORNER OF LAND NOW OR LATE OF fRANK WAGNER; TH~CE ALONG SAID LAND SOl.1TH S1 DECREES WEST 1t1 FEET TO AN mON PlN ON THE NORTHEASTERN LINE OF TlItRO STREET; THENCE ALONG THE SAME NORm 33 DEGREES WEST JO FEET TO THE POINT AND PLACE OF BEGINNING, Vtstlnlllnf_don: Vestl:d "y: Adulln..trat.r', Warqnty Deed dated 3/18104. given by Jana P. Hollm', Admioistntr'U or tll~ Hatlle or Vlrahtlll C. Row~ allcIa Virginia Ro",-e to Gng A. Rowe recorded StI&'04 in Hoole 163 Page 1Jn PREMISES BEING: 447 3RD STREET, WEST FAIRVIEW, PA 17025 , . 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 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 authorities, 1 {'9/(}~ Dat ! ~2'~~ rancis S. Hallinan, Esquire I . Attorney for Plaintiff - ~~ ~. ~ ""-. ('t, ~ ~\ ~ \J c.<\ ~. ~ ~ ~ ~~ . \?\ \A '^ \S, ~ ~~ ~ ~ ~ ~ t-., ~ ~ ~ ~-:Q -o~ ~bq 61.) ::~~\ ~ Qr> ,.~ (5 It' ~ -~ ~~ ~ ~~- ~ t:6 r" o ~ "'"t) (~.; l~~r", ( /" '~;l'~ 't~\:: -7 :::, ~- -------- -...-------- SHERIFF'S RETURN - REGULAR CASE NO: 2005-04891 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS ROWE GREGORY A VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon ROWE GREGORY A the DEFENDANT , at 1552:00 HOURS, on the 30th day of September, 2005 at 447 3RD STREET WEST FAIRVIEW, PA 17025 by handing to GREGORY A ROWE a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: "....,p' ~....;~<~.,.:'___c._. ../ .",,""_.~1 ....-.....,.,..,,; f <~1,,.,.". ,,,/?' ~"" ."C~'~~-- _,</'"::4i:~~~.<;,''''ft?;''' / 18.00 12.00 .00 10.00 .00 40.00 R. Thomas Kline 10/03/2005 PHELAN HALLINAN SCHMIEG Sworn and Subscribed to before By: I/d- ~~ Deputy Sh lff me this day of .D. ary PHELAN HALLINAN & SCHMIEG By: Francis S. Hallinan, Esquire Identification No. 12248 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 (2t5) 563-7000 ATTORNEY FOR PLAINTIFF Countrywide Home Loans, Inc. COURT OF COMMON PLEAS CIVIL DIVISION vs Gregory A. Rowe Or Occupants 447 3rd Street West Fairview, PA 17025 No. 05-4891 Civil Cumberland County PRAF.CTPF FOR .mnc.MFNT TN F.TRCTMFNT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff, Countrywide Home Loans, Inc. and against the Defendant(s) Gregory A. Rowe and Or Occupants for possession of premises 447 3rd Street, West Fairview, PA 17025 for failure to file an Answer within twenty (20) days of service. I hereby certify that according to Rule 237.1, written IO-day notice of Plaintiffs intention to file a praecipe for Entry of default Judgment was mailed to Defendant(s), a true and correct copy of which is attached hereto. --~5\L/~~ F ncis S, Hallinan, Esquire Attorney for Plaintiff Default Judgment entered as indicated above. DATE PHELAN HALLINAN & SCHMIEG Francis S. Hallinan, Esquire ID# 62695 One Penn Center, Suite 1400 1617 JFK Boulevard Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FORPLAlNTWF Countrywide Home Loans, Inc. COURT OF COMMON PLEAS CIVIL DIVISION vs Gregory A. Rowe Or Occupants No. 05-4891 Civil Cumberland County TO: Gregory A. Rowe or occupants 447 3m Street West Fairview, PA 17025 DATE OF NOTICE: Odnher 27, 2005 **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 ofa lien against property.** TMPORTANTNOTTCF You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY COURTHOUSE COURT ADMINISTRATOR 4TH FLOOR CARLISLE, P A 17013 (711) 240-6200 F cis S. Hallinan, Esquire Attorney for Plaintiff ~' PHELAN HALLINAN & SCHMIEG By: Francis S. Hallinan, Esquire Identification No. 62695 One Penn Center Plaza, Suite 1400 Philadelphia, P A 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF Countrywide Home Loans, Inc. COURT OF COMMON PLEAS CIVIL DIVISION vs Gregory A. Rowe Or Occupants 447 3rd Street West Fairview, PA 17025 No. 05-4891 Civil Cumberland County VFRIFTCATlON OF NON-MIUTARV SFRVTCF. Francis S. Hallinan, Esquire, hereby verifies that he is Attorney for Plaintiff in the above captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) That the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) That defendant Gregory A. Rowe Or occupants, is over 18 years of age, and resides at 447 3rd Street, West Fairview, PA 17025 . This statement is made subject to the penalties of 18 P A. C.S.S 4904 relating to unsworn falsification to authorities. ~. aLU'lvO'Y'- F ancis S, Hallinan, Esquire !tomey for Plaintiff D ~ t 70 -:-G ~ t- ~ I) \) 0 ....., r ~ -0 C. .;.:-:::;1 0 - c;.:;.> (;""'1 -q ~ '\"" F ."... -< C> <c> c:::) ::r:.." -.: 1'\1-- .--~ ~ ~ fT' f~j }<J 0 E 0 (S ~ ! -C:J ";:! c~~ ~ -' '----L.. r:::> C5.-rl ., ''-' ~':5 w .< PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland Countrywide Home Loans, Inc. COURT OF COMMON PLEAS CIVIL DIVISION vs Gregory A. Rowe Or Occupants 447 3 rd Street West Fairview, PA 17025 No. 05-4891 Civil Cumberland County PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 447 3rd Street, West Fairview, PA 17025 "PLEASE SEE THE ATTACHED LEGAL DESCRIPTlON*** Being Known as No. 447 3rd Street ~----itYXO~~CU~ rancis S. Hallinan, Esquire A TTO RNEY FOR PLAINTIFF s ~ e, --- ~~~ -- ~~ () iCl- :-() ...GU1\)U( :- 1- 0 VI C' V1 C \) \J C> ~ C \> \) - -.J::. I ~~ ~ P I -.:z II 'i:> IN :::. \) \) "- - ~ - ~ r U( - W~ fl\ - - - YP:- iJI V'\ V\ - \)- L-- kf l ......, ~::; C) .':J' "f .-,. 2~-:; ~ ....:;::,.: r:l:D ~!(~ C-~ ~'_:j Q , .;(~) N ,;~~~ "-.) ?G w .< , lof2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COUNTRYWIDE HOME LOANS, INC. VS. NO.05-4891 Civil Term_ GREGORY A. ROWE OR OCCUPANTS 447 3RD STREET WEST FAIRVIEW, PA 17025 Costs Attorney's Plaintiff 5 Prothonotary $ 119.50 $ $ 1.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumber]and County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (5)) COUNTRYWIDE HOME LOANS, INC. being: (Premises as follows): 447 3RD STREET WEST FAIRVIEW, PA 17025 (2) To satisfy the costs against the defendant (s) you are directed to ]evy upon any property of the defendant (s) and sell his/her (or their) intere Date NOVEMBER 10, 2005 (Seal) By: Irene Morrow Deputy , 20f2 No 05-4891 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COUNTRYWIDE HOME LOANS, INC. VS. GREGORY A. ROWE OR OCCUPANTS 447 3 RD STREET WESTFAIRVIEW, PA 17025 WRIT OF POSSESSION P.R.c.P, 3160-3165 ETC, Costs All'y Plff (sl Pro thy Sheriff $ 119.50 $ $ 1.00 $ Plaintiff (s) attorney name and address: FRANCIS S. HALLINAN, ESQUIRE PHELAN HALLINAN & SCHMIEG ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 215-563-7000 I.D.# 12248 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the _ day of , . I caused the within named , to have possession of the premises described with the appurtenances, and So Answers, Sworn and subscribed to before me this Day of Sheriff By C'l_I{:?9( -.. (,::!..LJ. f>' ~ -S.~ ~- D-j~" rYt' ---_._~-'~._".._~'--_.....,.--' ..",--~ By virtue of this writ OIl the named Countrywide Home L ~~~X 1 I ',(' -. ii _~~-------....-_~.~____'_'~_ l.~-~;: lOt rf2' of January. ,2005 . I cansed the wi~~~ -~- . ~I ~~~~~'(,~o~ef'IW~sdeSCribed~~& . subscribed to before me this lY ~ ,,)IJ'OI.. SO~.~~, CJ Sheriff & '/ By(J" t91 >----' t./lJhdlt Sheriff's Docket:j..ng Surcharge Pro thy Possession Milage Poundage Return: 1$,00 20.00 1.00 30.00 41,76 2,22 112. 98 Advance Costs: Sheriff's Costs: 150.00 112.98 37,02 Refunded to Atty on 1/11/06 ......... ,..... I .,,0 . /.;):SlD (A... " , ,~ !1~tJ~J . "a JJUOl(S - JO Ana sll() OUI OlOJOq 0) poqllJsqns pun U10MS 'Sl;M:\SUV oS pue 'sJJu~uaundde aqllJl~A\ paqp:lsap sas1lliaJd aql JO uo~ssassod JACq Ol ' pamuli ml()lM ol() posnnJ I . , JO "np - Olf) uo ')!1A' srl()Jo Oll)lIA "a pOAlOS oq "mu slodnd OJol(M (s) JJ1)um[d 10J "OUlOllV 8\7ZZ I WU'! OOOL-t9,",IZ to!6! Vd'vIHd'13av'1IHd 00\71 3lmS 'VZVld ~3LN3::J NN3:d 3NO 031WH:JS "8 NVNIIIVH NVl3:Hd 3'llInOS3 'NVNIIIVH 'S SIJNV<Itl :ss~.rppl' pun OUIl'U A~illOnl' (s) JJIjll1l'Id $ 00') $ $ OS'6lJ $ 1J!.mQS ^ljlOld (s)JJld ^,llV SjSO;) ':)cL3 59lE-09lE 'd':)"H'd NOISS3SS0d.>lO UlIM. ,lOLl Vd 'MtlI^~IVd LSi'IA\ Li'Ii'I~LS a,S L\7\7 SLNV dLl:):)O ~O tlMOll 'V A1l00ffiIO 'SA ':)NI 'SNVOi tIV\lOH tIarMA~LNI10:) VINV KIASNN3.d 'A.LNilO:J UNV'TII:!IID\Iil:J .>10 SV3.'1d NOWWO:J 110 nmo::J 3.H.L NI UUOL fIAT:) 1681>-1'0 oN Z:JO 'Z ~ - . t - 101"2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V AN1A COUNTRYWIDE HOME LOANS, INC. VS. No. 05-4891 Civil Term_ GREGORY A. ROWE OR OCCUPANTS 447 3RD STREET WESTFAIRVIEW,PA 17025 Costs Attorney's Plaintiff s Prothonotary $ 119.50 $ $ 1.00 COMMONWEALTH OF PENNSYL V ANlA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) COUNTRYWIDE HOME LOANS, INC. being: (Premises as follows): 447 3RD STREET WEST FAIRVIEW, PA 17025 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell hislher (or their) intere therein. ..... berland County, PA Date NOVEMBER 10. 2005 (Seal) By: Irene Morrow Deputy PHELAN HALLINAN & SCHMIEG, LLP By: Francis S. Hallinan Esquire Atty. J.D. No.: 62695 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. Plaintiff Court of Common Pleas CUMBERLAND County No, 05-4891 CIVIL vs, GREGORY A, ROWE OR OCCUPANTS Defendant( s) PRAECIPE TO WITHDRAW COMPLAINT, SATISFY JUDGMENT AND DISCONTINUE AND END ACTION. WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the instant matter, without prejudice, satisfy the judgment and mark this case discontinued and ended, upon payment of your costs only. 2/4/0{.. , . ;f~~s J!,L F ancis S. Hallinan Attorney for Plaintiff Date PHS # 123395 -, ~{; -I] ~-j ;-;-1 C~. r:;i (...1 ....,j CJ