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Home My WebLink About06-1426 i , '" Phelan, Hallinan & Schmieg, LLP By: Francis S. Hallinan, Esquire Identificatiou No. 62695 One Penn Center A Suburban Station Suite 1400 Philadelphia, P A 19103 (215) 563-7000 Attorney for Plaintiff Lasalle Bank National Association, As Trustee Under The Trust Agreement For The Structured Asset Investment Loan Trust Series 2005-1 3476 Stateview Bou]evard Fort Mill, SC 29715 Court of Common Pleas Civil Division Cumberland County v. Term Mary K. Shanabrook Or Occupants 6305 Stanford Court Mechanicsburg, P A ] 7050 No.O("- JJ..;J...b e'o~L~~ 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 helow to find out where you can get legal help. If you cannot afford to hire a lawyer, this office may be ahle to provide you with information about agencies that may offer legal services to eligihle persons at a reduced fee or uo fee. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLlSLE,PA ]7013 (717) 249-3166 PHS #: 13273 I .. -. ~ I. Plaintiff is Lasalle Bank National Association, As Trustee Under The Trust Agreement For The Structured Asset Investment Loan Trust Series 2005-1. 2. Defendant is Mary K. Shanabrook Or Occupants. 3. Plaintiff is equitable owner of premises located at 6305 Stanford Court, Mechanicsburg, P A 17050, a legal description of which is attached. 4. Plaintiff became owner of said premises as a result offoreclosure and judicial sale by the Sheriff of Cumberland County, on March 8, 2006. 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. c.A.<>1'VCt ~ ~,~ Premises: 6305 Stanford Court, Mechanicsburg, P A 17050 Cumberland County Pennsylvania DESCRIPTION ALL THAT CERTAIN UNIT AND THE PROPERTY KNOWN, NAMED AND IDENTIFIED IN THE DECLARATION REFERRED TO BELOW AS 'STANFORD COURT CONDOMINIUM II', SITUATE IN THE VILLAGE OF WESTOVER, HAMPDEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, WHICH HAS HERETOFORE BEEN SUBMITTED TO THE PROVISIONS OF THE PENNSYLVANIA UNIFORM CONDOMINIUM ACT, 68 P A. C.S.A. 3101 ET SEQ. BY THE RECORDING IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY OF A DECLARATION DATED MAY 29, 1987 AND RECORDED JUNE 3,1987 IN MISC. BOOK 334, PAGE 905, AS THE SAME SHALL BE AMENDED FROM TIME TO TIME, BEING AND DESIGNATED IN SUCH DECLARATION, AS THE SAME IS AMENDED FROM TIME TO TIME, AS UNIT NO. 5-F, WHICH SAID UNIT IS MORE FULLY DESCRIBED IN SAID DECLARA nON, AS THE SAME MAY BE AMENDED FROM TIME TO TIME, TOGETHER WITH A PROPORTIONATE UNDIVIDED INTEREST IN THE COMMON ELEMENTS (AS DEFINED IN SAID DECLARATION) OF 3.58%. GRANTORS RESERVE THE RIGHT, IN ACCORDANCE WITH SAID DECLARATION, TO REDUCE AND REALLOCATE GRANTEES PROPORTIONATE UNDIVIDED INTEREST IN THE COMMON ELEMENTS AS PROVIDED IN THE DECLARA nON, AS THE SAME MAY BE AMENDED FROM TIME TO TIME. . ......... VERIFICA nON 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 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.S. 94904 relating to unsworn falsification to authorities. 3/3 lOCo Date ' ~~,5'U~ F ancts S. Halhnan, Esquire Attorney for Plaintiff - ' -,i 0 i0.- --1 ~ ~ Ii U'l lrt V'( - " .:r. Q - - ~ "'J -J t-.-'. In ..0 U( ~ t'- ~ ~ () ~ ~ ---" " 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 LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE UNDER THE TRUST AGREEMENT STRUCTURED ASSET INVESTMENT LOAN TRUST SERIES 2005-1 Plaintiff Court of Common Pleas CUMBERLAND County No. 06-1426 CIVIL TERM vs. MARY K. SHANABROOK 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 rnatter, without prejudice, and mark this case discontinued and ended, upon payment of your costs only. 01,/')((O~ Date 3 rZioU--, , ~;' /lc:vl.J!r"C!IL Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Attorneys for Plaintiff PHS # 132731 r) ~l. .-\ -:1: ('II r-'. ,~".., ....:1 SHERIFF'S RETURN - REGULAR CASE NO: 2006-01426 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOC VS SHANABROOK MARY K RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon SHANABROOK MARY K the DEFENDANT , at 2105:00 HOURS, on the 23rd day of March 2006 at 6305 STANFORD COURT MECHANICSBURG, PA 17050 by handing to MARY K SHANABROOK a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So 18.00 9.68 .00 10.00 .00 37.68 Answers: //~;r. _ rfJt!t:~d;~ /~ R. Thomas Kline me this /I' 'l'3 day of 03/27/2006 PHELAN HALLINAN SCHMIEG By: ~L7~ Deputy Sheriff Sworn and Subscribed to before 7w"i ;(dV~ A.D. Prothonotary