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Home My WebLink About06-4285 . Phelan, Hallinan & Schmieg, LLP By: Francis S. Hallinan, Esquire Identification No. 62695 One Penn Center A Suburban Station Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Attorney for Plaintiff Chase Home Finance LLC 3415 Vision Drive Columbus, OH 43219 Court of Common Pleas Civil Division v. Cumberland County Carla J. Linnane Or Occupants 18 Plainview Road Camp Hill, PA 17011 Tenn No. 0(. - 4,;J?S CiOltT~~ CIVIL ACTION - EJECTMENT "1'his firm is a debt colleclor attempting 10 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 wos not reaffirmed, this correspondence is not and should not be construed 10 be an attempt 10 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 bave a lawyer or cannot afford one, go to or telephone the office set fortb below to find out wbere you can get legal belp. 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 COUNlY BAR ASSOCIA nON 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 PHS #: 138532 I. Plaintiff is Chase Home Finance LLC. 2. Defendant is Carla J. Linnane Or Occupants. 3. Plaintiff is equitable owner of premises located at 18 Plainview Road, Camp Hill, P A 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 June 7, 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. rancis S. Hallinan, Esquire Attorney for Plaintiff ~Il' _: l' l'LAJNVlEW ROAD. 7OWN8BlP OF LOWIlR AUJiN CI.JM8LAND COVHrY PBHNS1'LVANlA J ," .... ~ I 4 II! ,.~\. All. THAT CIlR:l'AIN UWllof1*'* of....~ ill Lowet ADea To.ftIIIIlp, 0''''''-'''.... COlIlIO. ~j1"'" _J*lIadId1...._a&..I'... ...... 'II...,. iIIIGn, fD wit . BBGJNNING ilia paiac _* 1 1, "111 PIIiIIriDw a.J.1fIlidl p.. is 101..81 fizt HoIdI.r 1bc ~conerot~Drbeaa4 _.. 'Jewlllllllll...........,... 1& 61161& U.lIcIMcRLOII Nca. 1111I4 12. Bkdt .&." .._ L>i/ 'IIl:t. "1--11'Ja or .Loll; 11_ ...... &ItIr ty IiIle IlfPlllill4_....__......_.u'~OlUrlllti..Nu..... I 1) ~ 41."..0.....21.20 leec lD II poial; dIIIIcc flInJa .... -. N.- 42 . ~ ClllI20 ~ 'Nell SS.13 ft= to a, IliaC at diftIiac liIIIB W.... Loll Mol. n ad 13, BIDet or 0Il18l4/PIM: *_ .... d dIYIdiI r,llac NClIIII47 ...~ 040~: .1_ HIlt., 125 .. fD a paiIit; ... .... _ '''1IIIledr Iiae cI. Ua ) 'IlL 9 ... 10. BIDct "It" OIl ad:I t'III, ,... c ~- 3) ..' "- BIll:. ." fl. .. a .... Ii dlYidIIalllle 1>4__ LallI NOlI. 11 aad l2, IIIoct T' ...~ IIlelleC -. SOlldJ lrt r . ~ 40 m..... w., 123.17 feet !O a -. ...,... or~.~.. . BEING a....v1'CC1 wIdlllldl:lr.llIIl ~DIII:b~ bawD. .. .-Il u4 18 - . new IIoIll. BIlING 14 No. l2.. BIocIt .K," . PIIII at CoaDy.& TUW~", ,. .wbida. . l'fm is _Ja1 In _ CUIlIblltIaad QIDlIIy Jl'o...... of ""* 0ftIce la ,. 1,llr .~ . : '. ~. ,~ - .Tn PD:eI ~ . 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 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. ~4904 relating to unsworn falsification to authorities. ~C/O~ Date ~~J.S'w~ F neis S. Hallinan, Esquire Attorney for Plaintiff ~~ ~ ~ ~j "0 ~ B ~ ~ - '-:'~ c> ~ ,':) "11 ,..... -......-\ 'I~ h1 r~? (.,,) -'- C~~ r",~ _J ~ ....' ....., SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-04285 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND r CHASE HOME FINANCE LLC VS LINNANE CARLA J R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT LINNANE CARLA J OR OCUPANTS but was unable to locate Her ln his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , NOT FOUND , as to the within named DEFENDANT , LINNANE CARLA J OR OCUPANTS 18 PLAINVIEW ROAD CAMP HILL, PA 17011 18 PLAINVIEW IS VACANT 18.00 12.32 5.00 10.00 .00 45.32 -:/ PHELAN HALLINAN ~ 1/;;.5'/0/" 08/04/2006 Sworn and Subscribed to before Sheriff's Costs: Docketing Service Not Found Surcharge s~_~ R. Tho ---1{1 ine Sheriff of Cumberland County SCHMIEG me this day of A.D. 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 CHASE HOME FINANCE LLC Plaintiff vs. CARLA J. LINNANE OR OCCUPANTS Defendant( s) Attorney for Plaintiff Court of Common Pleas CUMBERLAND County No. 06-4285 CIVIL TERM PRAECIPE TO WITHDRAW COMPLAINT, WITHOUT PREJUDICE I 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. _ __ /1/0 B /06 Date PHS # 138532 ---~.-J rQ I"] 6 '..r ~..t:& I'~':;> ~ Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Attorneys for Plaintiff r....:> <;;;;;;> C.::."') ~ o .." --1 ... Pi; :D r- :ge; ~~r_;) :~~ s;i "Xl -< 2 <..-:; ..-:c..: w J_-- o CO