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Home My WebLink About06-5801 Phelan, Hallinan & Schmieg, LLP By: Francis S. Hallinan, Esquire Identification No. 62695 Attorney for Plaintiff One Penn Center A Suburban Station Suite 1400 Philadelphia, PA 19103 (215)563-7000 Chase Home Finance LLC 3415 Vision Drive Columbus, OH 43219 Court of Common Pleas Civil Division v. Tiffani M. Stoner Cumberland County Or Occupants Term 12 Adams Street / Enola, PA 17025 NO' ~~° _ `~~l ~~ V 1,`, ~~ l~ CIVIL ACTION -EJECTMENT **"I'his firm is a debt collector attempting to rnllect 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 LIB>/RTY AVENUE CARLISLE, PA 17013 (717) 249-3166 PHS #: 141867 1. Plaintiff is Chase Home Finance LLC. 2. Defendant is Tiffani M. Stoner Or Occupants. . 3. Plaintiff is equitable owner of premises located at 12 Adams Street, Enola, 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 6, 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. ''t'~S_~G~,t.C,~il (~~ F ands S. Hallinan, Esquire Attorney for Plaintiff 8CHEbULE C RROP6RTY DESQRiPT10N The land referred to in this Commitment is descried as follows: ALL THAT CERTAIN tract or parcel of land and premises, s'~tuate, lying and b9ing in the Townshy of east Per~sboro in the Courtly of Cumberland and Cammanwealth of Pennsylveniia, more patticutarl~r des xlbed as follows: In Accordance with a survey and plan thereof made by Emest J. W81kc~r, Professional gine?r, dated August 21, 1976, as follows: BEGINNNG et the southeast corner of a 12 feet wide alley and West Adams Strut; ihenoa abr~ the s~ loth skis of West Adams Street, North 78 degrees 30 minutes Eest 25 feet to a comer of i ~r9mi6es known as No. t0 West Adams Street; Thence along said premises and passing through tliq canter of a p®rition welt, South 11 ~;iegrees 30 minutes East 1517 feet to a point on the North side of a 12 feet wide auey; tf ante abngg the same ~ B~wth 78 degrees 30 minutes West 25 feet to a point on tha East sMe of the first said 12 f ~t wide aNey; thence a ~~ong the same North 1 ~ degrees 30 minutes West 150 feet to thei point and place of BEGIN VING. HAVING THEREON EREC?ED, a two and one-help story fremedweNing known as No. 12 West Adams St r;-et. UNDER AND SUBJECT ,nevertheless to easements, restrictions, reservations, auditions and rights -of-~+,ay 4f re BEING THE SAME PREMISES which Timothy M. Osman and Sheri A. Osman, I ry their deed dated Ma '~,~ 30th, 2001, and recorded in ate t3ftice of the Recorder of deeds in and for Cuntbertand County in heed Beck 242, Page 270, granted and conveyed unto Patrick S. NaJdeK, herein. 4 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 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. Date Fr Weis S. Hallinan, Esquire Attorney for Plaintiff ~, n ~. ~ ~ .~ ~ D c:, c ;, p,, , c' .J H ~_~ o-. c~ c-; ---i G'a -n r5 r'~-- -cf r r,~ C~ l{-~ "(~ l~ '7 f \/ Phelan Hallinan & Schmieg, LLP By: Francis S. Hallinan, Esquire Identification No. 62695 One Penn Center Plaza, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103 (215) 563-7000 Chase Home Finance, LLC Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION vs Tiffani M. Stoner Or Occupants 12 Adams Street Enola, PA 17025 No. 06-5801- Civil Term Cumberland County VERIFICATION OF NON-MILITARY SERVICE 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 Tiffani M. Stoner Or occupants, is over 18 years of age, and resides at 12 Adams Street, Enola, PA 17025. This statement is made subject to the penalties of 18 PA. C.S.S 4904 relating to unsworn falsification to authorities. lF'ran s S. Hallinan, E A ev for Plaintiff C? C a 'TJ ~' ~,, ~ ~~ r _ f , c.~ try _~. _ o ~:~ ~ r ~ =~: _. ~,. ~ ~ -r# ~~ ` ~' C c~ ~ ~ ,~"' Phelan Hallman & Schmieg, LLP By: Francis S. Hallman, Esquire Identification No. 62695 One Penn Center Plaza, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103 (215) 563-7000 Chase Home Finance, LLC Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION vs No. 06-5801- Civil Term Cumberland County Tiffani M. Stoner Or Occupants 12 Adams Street Enola, PA 17025 PRAECIPE FOR JUDGMENT IN EJECTMENT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff, Chase Home Finance, LLC and against the Defendant(s) Tiffani M. Stoner and Or Occupants for possession of premises, 12 Adams Street, Enola, PA 17025 for failure to file an Answer within twenty (20) days of service. I hereby certify that according to Rule 237.1, written 10-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. rancis .Hallman, Esquir tto ey for Plaintiff Default Judgment entered as indicated above. DATE y `' ~" P.HELAN HALLINAN & SCHMIEG, LLP - By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis 5. Hallman, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Philadelphia, PA 19103 X215) 563-7000 CHASE HOME FINANCE LLC :COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION Vs. CUMBERLAND COUNTY TIFFANI M. STONER OR OCCUPANTS Defendants : NO. 06-5801-CIVIL TERM TO: TIFFANI M. STONER OR OCCUPANTS C' `L E 12 ADAMS STREET ENOLA, PA 17025 DATE OF NOTICE: NOVEMBER 9, 2006 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THI5 CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE 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 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 F NCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff .-~ ,. ~ ~ ~u F r "` ~~ p`i y ~ (!`'w ~ V 2 -~. -a ~c c -~- C .~y~~~1_ ~~V^yy !h~ S,,:w jT{...1 .+4~~-- rA_:. ~. ~"` . ~~ ~:~ {Y; 4~ W N .,,s Sri ~~ .~-3 ~3 J -K y PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA County of Cumberland Chase Home Finance, LLC COURT OF COMMON PLEAS CIVIL DIVISION vs No. 06-5801- Civil Term Tiffani M. Stoner Or Occupants Cumberland County 12 Adams Street Enola, PA 17025 PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession o£ 12 Adams Street, Enola, PA 17025 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION*** Being Known as No. 12 Adams Street ran s S. Hallinan, Esq re ey for Plaintiff ~~ M ~ ~9Y, ;9- +~ :~- .~ ~ ~ '~ ~ c G c ~ C ~ ~ W 1 ,~ ~ ~ .. ~ ~ ~ ~ ;, ,, ~ Oe? . ~`1 -„ ~ ~ ~ .. ~~~ w ~ ~~ ~_. ~, =~ ~~_, _, lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC VS. No. 06-5801 Civil Term TIFFANI M. STONER OR OCCUPANTS Costs Attorney's $ 120.70 Plaintiff's $ Prothonotary $ 1.00 COMMONWEALTH OF PENNSYLVANIA: 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)) CHASE HOME FINANCE, LLC being: (Premises as follows): 12 ADAMS STREET, ENOLA, 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 his/her (or their) interest therein. C s R. Long, .notary, Common Pleas Court of Cum erland County, PA Date NOVEMBER 30.2006 (Seal) 2of2 No 06-5801 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE, LLC VS. TIFFANI M. STONER OR CCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 120.70 Plff (s~ $ Prothy $ 1.00 Sheriff $ Plaintiff (s) attorney name and address: FRANCIS S. HALLINAN, ESQUIRE PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER PLAZA, SUITE 1400 1617 JOHN F. KENNEDY, BOULEVARD PHILADLEPHIA, PA 19103 By virtue of this writ, on the named appurtenances, and Sworn and subscribed to before me this Day of , Attorney for Plaintiff (s) Where papers maybe served day of I caused the within _, to have possession of the premises described with the Prothonotary So Answers, Sheriff By Deputy ~ -~ l3CHt:bU1.E C PROPERTY DESCRiPT10N The land referred to in b~is Commitment is df3scnbfad as fobf~(s: ALL THAT CERTAIN tract or parf3el of land and premkes, situate, lye and b9ing in the Toumshk of east Pernstrav in the County of Gumberiand and Ccmmonwfealth of Panr~yhreri~p, move paficutariy deaf rfbed as fellows: In Aacondance with a survey and plan ttretefyf made by Emest .!. 1lVebu.r, Ptofieesiortai a ?r, dated August 2! ,1978, as fdlows_ BEGINNh10 st the southeast corner of a 12 feet wide easy and West Adams Sir+rfs~ thence abnp tt~ f31 nilh side of Wsst Adams Street, Nortfi 78 degrees 30 minutes East 25 feet t0 a comer Of I~t@rrli6e6 known af3 No. d0 West Adams Sleet; 17~enae along said prfttnlses end pf3ssing th'C~ugh the f~nnter of s petition web. Soufh ! 1 degrees 3a frinutes East 150 feat to a print on the Nfx~ side of a 12 feet wk>B aNey; if+3nce the frd' r11e ~.~xtth 79 degrees 3a minutes West 25 feet to a pf~int on the East side of he ftr9t said 121 ~E-t wide tt~ance ~ dorlp the same North 11 de8reea 3a mhutea west 15o feet tQ the pf~(r-t and place of BEGIN VfNG. HAVING THEREON ERECTED, f3 two and aye-help story framedweNing known a8 No. 12 West Adams St 'lff~t. UNDER ANO SUB.IEC7' , nevertheless tQ easements, nastrif~ons, reservations. rx nditions and ruts -ofa r.ay of re BEING THE SAME PREMISES which Timothy M. Osman and Shari A Osman, t fy their deed dated Ma '~::h 3ti1h, 2001, and rfa:orded in he Office of the Rreoonder of deeds in and fur Cumbers and Courtly in Deed 8 ~ ok 242. gage 270, ~antf3d and vonveyed tmto Patrick S. Naldek, herein. r SHERIFF'S RETURN - REGULAR CASE NO: 2006-05801 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE HOME FINANCE LLC VS STONER TIFFANI M 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 STONER TIFFANI M the DEFENDANT at 1746:00 HOURS, on the 19th day of October 2006 at 12 ADAMS ~TRRRT ENOLA, PA 17025 MICHAEL STONER, SPOUSE by handing to 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: So Answers: Docketing 18.0 0 ,.,~ S e rv i c e 13.2 0 ~~s~,r-~ ~~~ Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 41.20~j 10/20/2006 ,~~~ PHELAN HALLINAN SCHMIEG Sworn and Subscibed to g~,; ~!+/" before me this day Deputy Sheriff of A.D. PHELAN HALLINAN £~ SCHMIEG, LLP By: Francis S. Hallinan Esquire Atty. I.D. No.: 62695 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1$14 (215)563-7000 CHASE HOME FINANCE, LLC vs. Plaintiff TIFFANI M. STONER OR OCCUPANTS Defendant(s) Attorney for Plaintiff Court of Common Pleas CUMBERLAND County No. 06-5801-CIVIL TERM 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. Date ~~~ ~ ~~~~ Francis S. Hallinan Attorney for Plaintiff PHS # 141867 t':? ~ O ~- o n (Ts~ _. = ~ "C:} . ~ - i ~ L ' ~ r-~ ~.. _ ~': ~ `~ ~ T~ ' . eC4 " ~ ~~~~ ~, ~ ~ By virtue of this writ, on the ~ 5 day of _ J a n u a r y , 2 O O 7 _ I caused the within named __ C~ a c P H o m fi n a n c e , to have possession of the premises described iKo~t~aY ~I4~#~Idd~ 12 Adams St Enola PA. 17025 Sworn and subscribed to before me this Day of , So A.nsw ~~ ~~~~ eriff BY ..r ~~~1~(.e-:mod. Sheriff's Return: Sheriff's Costs: 150.00 Advance Costs: 83.85 Docketing 18.00 66.15 Poundage 1.65 Prothy 1.00 Milage 13.20 Refunded to Atty on 1/26/07 Surcharge 20.00 Possession 30.00 83.65 / ~ 9 0~ ~ ~ o~ 4, `~ ~~ g~l~ ~~ ~~~~ 2 of 2 No 06-5801 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE, LLC VS. TIFFANI M. STONER OR CCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 120.70 Plff (s~ $ Prothy $ 1.00 Sheriff $ Plaintiff (s) attorney name and address: FRANCIS S. HALLINAN, ESQUIRE PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER PLAZA, SUITE 1400 1617 JOHN F. KENNEDY, BOULEVARD PHILADLEPHIA, PA 19103 Attorney for Plaintiff (s) By virtue of this writ, on the named appurtenances, and Where papers may be served day of , I caused the within _, to have possession of the premises described with the Sworn and subscribed to before me this Day of , Prothonotary So Answers, Sheriff By Deputy T ' ~ l0(2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC VS. No. 06-5801 Civil Term_ TIFFANI M. STONER OR OCCUPANTS Costs Attorney's $ 120.70 Plaintiff's $ Prothonotary $ 1.00 COMMONWEALTH OF PENNSYLVANIA: 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)) CHASE HOME FINANCE, LLC being: (Premises as follows): 12 ADAMS STREET, ENOLA, 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 his/her (or their) interest therein. C s R. Long, P notary, Common Pleas Court of Cum erland County, PA Date NOVEMBER 30, 2006 (Seal)