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Home My WebLink About06-7056Phelan, 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 Countrywide Home Loans, Inc 7105 Corporate Drive Court of Common Pleas Plano, TX 75024 Civil Division v. Cumberland County Michelle L. Darhower Or Occupants Term 2006 Connie Drive /~ Enola, PA 17025 No. Q~ ~. ~~'~ ~/~ U l C 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 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 PHS #: 145796 1. Plaintiff is Countrywide Home Loans, Inc. 2. Defendant is Michelle L. Darhower Or Occupants. 3. Plaintiff is equitable owner of premises located at 2006 Connie Drive, 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 December 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. ~, _ Fran s S. Hallinan, Esquir A rney for Plaintiff LEGAL DESCRIPTIQN ALL that certain piece or parcel of land situate in the Hampden Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the Northern line of Michaele Drive, said point being located and referenced South 81 degrees 30 minutes West, 225.00 feet from the northwest corner of the intersection of Michaele and Dawn Drives; thence along the Northern line of Michaele Drive South 81 degrees 30 minutes West, 82.$2 feet to the point where the northern line of Michaele Drive intersects the eastern line of Connie Drive; thence along the eastern line of said Connie Drive North 29 degrees 30 minutes West, 187.45 feet to the southern line of 15.00 feet right of way; thence along said right of way North 81 degrees 30 minutes East, 150.00 feet to the northwest corner of Got No, 20; thence along the western line of said Lot No. 20 South 08 degrees 30 minutes East, 175.0 feet to a point on the northern line of Michaele Drive, the place of beginning. BEING Lot No. 21 (erroneously state Lot 21 and 22 in prior deed) oa plan of lots of property of Max L. McCombs and Ester McCombs recorded in Plan Book 7, Page 19. HAVING thereon erected a dwelling known and numbered as 200b Connie Drive, Enola, Pennsylvania 17025 BEING Parcel No 10-14-0842-022A. BEING the same premises conveyed unto Gary Poticher and Ruth Poticher, his wife, by Deed dated 08/01/01 and recorded 08/02/01 in Deed Book Volume 247, page 3706, granted and conveyed from Debra L. Brewbaker, single person. PREMISES: 2006 CONNIE DRIVE 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 U Fran s S. Hallinan, Esquire A rney for Plaintiff ~ ~ ~ ~ ~~ ~ ~A 0 C'? r__ _'{_: ~'~ .~ ev ~--~ CIS ~~ ~J ~~ ~. ~ C:3 ~ -rt ~~ ""l i~ `Y 1 l ,. 7 .= ~'t i ----~ _~'' .Aa '~ s Phelan Hallinan & Schmieg, LLP By: Francis S. Hallinan, Esquire Attorney for Pl~a>Intiff Identification No. 62695 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Countrywide Home Loans, Inc. COURT OF COMM N PLEAS CIVIL DIVISION vs. No. 06-7056-Civil T m CumberlandCounty Michelle L. Darhower Or Occupants 2006 Connie Drive Enola, PA 17025 PRAECIPE FOR JUDGMENT IN EJECTMENT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff, Countrywide Home Loans Inc. and against the Defendant(s) Michelle L. Darhower and Or Occupants for possession of 2006 Connie Drive, Enola, PA 17025 for failure to file an Answer within twenty (20) days bf service. I hereby certify that according to Rule 237.1, written 10-day notice of Plaintiffs intention ~o file a praecipe for Entry of default Judgment was mailed to Defendant(s), a true and correct copy oi~`which is attached hereto. Default Judgment entered as indicated above. S~ . Hallinan, E for Plaintiff DATE .. PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Philadelphia, PA 19103 (2151 563-7000 COUNTRYWIDE HOME LOANS, INC. :COURT OF COMMON PLEAS Plaintiff V s. MICHELLE L. DARHO WER OR OCCUPANTS Defendants CUMBERLAND COUNTY NO. 06-7056-CIVIL TERM TO: MICHELLE L. DARHOWER OR OCCUPANTS 2006 CONNIE DRIVE ENOLA, PA 17025 DATE OF NOTICE: JANUARY 22, 2007 FILL THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO~ INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PUR] PREVIOUSLY RECEIVED A D15CHARGE IN BANKRUPTCY, THIS CORRESPOl SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A D~ ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APP PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFF~P OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HE MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YC INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO F INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PE REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 YOU WITH AT A FRANCIS S. HALLI N, ESQUIRE Attorneys for Plaintiff~'~ CIVIL DIVISION ~ ~, ~~ -T1CE IS SENT TO .REIN, AND ANY E.IF YOU HAVE 1CE IS NOT AND BUT ONLY AS ;ARANCE SES OR 1 DAYS FROM THE BRING AND YOU VE A LAWYER, WITH Phelan Hallinan & Schmieg, LLP By: Francis S. Hallinan, Esquire Attorney for Plaintiff Identification No. 62695 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Countrywide Home Loans, Inc. COURT OF COM N PLEAS CIVIL DIVISION vs. No. 06-7056-Civil'. rm CumberlandCounty Michelle L. Darhower Or Occupants 2006 Connie Drive Enola, PA 17025 VERIFICATION OFNON-MILITARY SERVICE FRANCIS S. HALLINAN, ESQUIRE, hereby verifies that he is Attorney for Plain ~ff in the above captioned matter, and that on information and belief, he has knowledge of the foil wing facts, to wit: (a) That the defendant(s) is/are not in the Military or Naval Service of the Unity States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relie Act of Congress of 1940, as amended. (b) That defendant Michelle L. Darhower Or occupants, is over 1$ years of age, resides at 2006 Connie Drive, Enola, PA 17025. This statement is made subject to the penalties of 18 PA. C.S.S 4904 relating to falsification to authorities. S. Hallinan, Es v for Plaintiff ~ ~ ~., ~ ~._. _~ t_~ ~ - ~~ -~ G, ~ ~ _ a~ o ~ _ ~: ... o 'T] _.~ ~.-~ _„ ,~; _a --~~, :. ~~ ..~ PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA County of Cumberland Countrywide Home Loans, Inc. . COURT OF COIN. ON PLEAS CIVIL DIVISION vs. No. 06-7056-Civil erm CumberlandCounty Michelle L. Darhower Or Occupants 2006 Connie Drive Enola, PA 17025 PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 2006 Connie Drive, Enola, PA 17025 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION*** Being Known as No. 2006 Connie Drive Franc s S. Hallinan, E Att nev for Plaintiff f 1 `^~_. ti~ Q n ~, M ~' a W °'SC \^4 M G :, ~~~~ ~ ~ C V M + ~ T~ ~ v e ~~--. ., , ~"`~ :" _, ~ ; r~ C..~J '.r' 1 {~i~i ~., ;;.., f2 _~ ~'~ ~_ t3~~ :~ WRIT Off' POSSESSION (Ejectment Proceedings PROP 3160'- 3165 etc.) COUNTRYWIDE HOME LOANS, INC. I1V THE COURT OF C MON PLEAS OF CUMBERLAND COUNT PENNSYLVANIA No. 2006-7056-CIVIL TERM Term No. Term vs. MICHELLE L. DARHOWER OR OCCUPANTS Costs Atty. _ Pl'ff (s) Prothy. $ 118.06 $ l.oo 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 following described property to: COUNTRYWIDE HOME LOANS, INC. possession of the being: (Premises as follows): 2006 CONNIE DRIVE ENOLA, PA 17025 Plaintiff (s) (2} To satisfy the costs against the defendant (s) you are directed to levy upon any property'o~f the defen- dant (s) and sell his/her (or their) interest therein. I Common date February 6, 2007 By: (SEAL) Pennsylvania Deputy a CAD ~ z o ~ ~~ a 0 9 N M ~ o ~ ~ d c~ `~ O H "~. ~ ' ~ ~ r' ,. < ~, ~ b ~ ~ o a"' ^ ~ O ti b~ ~ ~ n y ;d O ~ b o ~ W V] ~+ ~ ~ ~ ~ ~o A. - - ~ sg ~ ~ n Z t N O n By virtue of this writ, on the day of I caused the within named have possession of the premises described with the appurtenances, and C Z ~ -+~ ~ ~ r~ y0 z~ d y n O O ,~ y0 z~ zz ~ '~ ,~ r r~ C z z 0 0 0 rn I 0 H c H r' H C=i ~ ~ , to So Answers, Sworn and subscribed to before me this day of Prothonotary By Sheriff ~ n H ~ C'~ ~ x Z Cr1 H r r ~ ~ H r d ~ a ~ ~ x O t., ' b ~' Z r ; O ~ A ~ H ~ z b z H Deputy _.____-- SHERIFF'S RETURN - REGULAR CASE NO: 2006-07056 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS DARHOWER MICHELLE L SHAWN HARRISON Cumberland County,Pennsylvania, who being duly sworn according to law, Sheriff or Deputy Sheriff of ... ;~ says, the within COMPLAINT - EJECTMENT was served upon DARHOWER MICHELLE L the ,. ;«. DEFENDANT at 2030:00 HOURS, on the 28th day of December 2006 at 2006 CONNIE DR ENOLA, PA 17025 by handing to MICHELLE DARHOWER 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: So Answers: Docketing 18.00 ~ ,;i Service 10.56 ~~'~" ~'~ ..... Affidavit . 00 ~"""` Surcharge 10.00 R. Thomas Kline .00 38.56E 01/02/2007 p~ PHELAN HALLI SC IEG ~-~''ou~ Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. ~~ -'- ~'~ ~~~ --~ J~ $~. i ~~. G *~ cc .~ ~, c~ .~ ~. R cu zo ~~ o ~ n o ~, 9 H ~ 0 ., ~d ~ ~ H "~. U' tC~~-. b o (D ,y `< ro a --++~ ~ n ~ n 0 ~ _ ~ w ~. 0 :~ ~ ~ n y ;b O W ~ ~ 00 ~~ O~ ~ ~ ~ o~ ~~ H n x r~ r r d 0 O ro z H (") z H d ~o t'' < a H z By virtue of this writ, on the 8 th day of March 1 caused the within named County wide Home Loans , Inc` have possession of the premises described ~Xr~1~~I~t~~1£$~~bi~~i _ Drive, Enola, PA 17025 2007 ti --, J ~- ti~ . _.. .. _~ w M . __ ~z ~y ~~ rn O z~ d y C~ O ~ ~ C z~ ~~ Q zz z ,~ `~ r C ~' ~~ zo °. Y.1 Y ~Z /'~ z z O .~ ~ ~ to 2006 Connie Sheriff's Return• Advance Costs: 1050./00 Docketing $ 18.Cf0 67.95 Poundage 1 61 Refunded tn_At~~~ nn '~/~/Q7 _ Prothy 1.00 Possession 30.00 Milage 11.44 ~3J r~~1,o7 ~- $~- So Answers, Sworn and subscribed to before me this /~~-~'~-~, day of ~ Sh -, B ~- -7r } y Prothonotary y ~ ~ ~ ~ J Aga l,~ -WRIT OF POSSESSION (Ejectment Proceedings PREP 3160 - 3165 etc.) COUNTRYWIDE HOME LOANS, INC. No. vs. MICHELLE L. DARHOWER OR OCCUPANTS Att'y._ PI'ff (s) Prothy. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2006-7056-CIVIL TERM No. Term Term $ ~is.o~ $ 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; COUNTRYWIDE HOME LOANS, INC.. Plaintiff (s) being: (Premises as follows): 2006 CoNNIE DRIVE ENOLA, PA 17025 (2) To satisfy the costs against the defendant (s) yon are directed to levy upon any property of the defen- dant (s) and sell hislher (or their) interest therein. Prothon ,Common o umberland County, Pennsylvania Costs date February 6, 2007 gy_ (SEAL} PHELAN HALLINAN ~ SCHMIEG, LLP By: Francis S. Hallinan Esquire Atty. I.D. No.: 62695 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215} 563-7000 COUNTRYWIDE HOME LOANS, INC. vs. Plaintiff MICHELLE L. DARHOWER OR OCCUPANTS Defendant(s) Attorney for Plaintiff Court of Common Pleas CUMBERLAND County No. 06-7056-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. 0 ~/~~f ~ ~ Date Francis S. Hallinan Attorney for Plaintiff PHS # 145796 ~'7 ~ p C' ~ -rt ~ V , ~ -:r , 7+~ ~"° --f ' . t t. S ;7 ,~..y ~ ~~ ..~ """" a _ ''- f "'"' ~ _ ~~' L ~S __f