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HomeMy WebLinkAbout02-4467FEDERMAN AND PHELA~/, LLP By: Frank Federman, Esq~re Identification No. 12248 ~ One Penn Center Plaza Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Attorney for Plaintiff Bankone, National Association, Trustee 201 Parkhill N54 W13600, Woodale Drive Minomonee Falls, WI 53051 Paula Stahl Or Occupants 2101 Lambsgap Road Enola, PA 17025 Court of Common Pleas Civil Division Cumberland County Term ~TVIT, A~.~TFIM _ ~.ll~.~5~fl~.NT~ _ -~020 Please be advised that this firm is a debt collector attempting to collect a debt. Any information received 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. 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 ffyou 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. LAWYER REFERRAL SERVICE ALLEGHENY COUNTY BAR ASSOCIATION KOPPERS BUILDING, SUITE 400 436 SEVENTH AVENUE PITTSBURGH, PA 15219 (412) 261-0518 1. Plaintiff is Bankone, National Association, Trustee. 2. Defendant is Paula Stahl and Or Occupants. 3. Plaintiff is the owner of premises located at 2101 Lambsgap Road, Enola, PA 17025, a legal description of which is attached. Plaintiff became owner of said premises by a Deed from the Sheriff of Cumberland County, which Deed was lodged and settlement made with the Sheriff (Abstract of Title). Plaintiff, by virtue of the above, is the 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 dehver up possession of same. WHEREFORE, plaintiff seeks to recover possession of said premises. K FEDERMAN, ESQUIRE Attorney for Plaintiff lyin~ and ~ei~ lr~ the Township of ~amp~e~, in land~ end CommonWealth o~ - Penne~l~eni ..... . -- F Cumbec eam~ No~h 10 ~eg~eea 30 m~n~e~ ~8 a~ffiond8 fleet, 469,2~ £~et to e way of L,R. 2105 R. 21051~ thence thc ~e~ line a£ L.~*,2105I Sou~h 27 ~eg~ee~' ~u3~; thence eZonff bite cart- to a ~oint~ .thence along $ame ~outh ~ degreea 14 minu~es feet', 117.70 ~eet ~o a POint In ~l~e cenEer~llne oE.znte~section of L.~. 21051 e~ld {IAVXNG ~hereon erected a atone and f~eme dwelli~g i~ouae, Small cottage, garage, and other smell a~XNG the mama P~emlea~ which David L. weight by their Deed d~ed Oeaembe= 9~ 1983, ~eao~d~d in the O~fice the Reoocdac DE Deeds ~n and foe Cembe~la:]d Deed Book H30~ Page 505, greeted an~ ~onve~ed unto oa~y ~. S~ah~ and Paula [1~ Stehl, his wife~ G=&nto=s herein. ' VERIFICATION Frank Federman, Esquire hereby states that he is the Attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to take this Verification, pursuant to Pa. R.C.P. 1024 (c) and that the statements made in the foregoing Civil Action in Ejectment are true and correct to the best of his knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa, C.S. Sec. 4904 relating to unsworn falsification to authorities. Date:~ _ r.'ra}ik Federmar~, Esquire Att~orney for Plaintiff FEDERMAN AND PHELAN L.L.P. BY: FRANK FEDERMAN Identification No. 12248 One Penn Center ~ Suburban Station, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF Bankone National Association, Trustee VS Panla Stahl Or Occupants 2101 Lambsgap Road Enloa, PA 17025 COURT OF COMMON PLEAS CIVIL DIVISION No. 02-4467-Civil Term Cumberland County PRAI~ITIPF, FOR .HrDGMI~NT IN FJE~[~TMENT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff, Banktme National Association, Trustee and against the Defendant(s) Paula Stahl and Or Occupants for possession of premises 2101 Lambsgap Road, Enloa, 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 pmecipe for Entry of default Judgment was mailed to Defendant(s), a mae and correct copy of which is attached hereto. Default Judgment entered as indicated above. DATE EED , SQ ALA rueY for P nfif Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) ~63-7000 BANKONE, NATIONAL ASSOICIATION, TRUSTEE Plaintiff vs. PAULA STAJiL OR OCCUPANTS Defendant (s) : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. C'2-4467 TO: PAD-LA STAHL OR OCCUPANTS 2101 LA~BSGAP ROAD ENOLA, PA 17025 DATE OF NOTICE: OCTOBER 17 2002 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 A/fY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. You are in default because you have failed 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: CUlVEBERLAND COUNTY CUMBERLA2qD COU2qTY BAR ASSOCi~ON 2 L~BERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN L.L.P. BY: FRANK FEDERMAN Identification No. 12248 One Penn Center Plaza ~ Suburban Station, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 Bankone National Association, Trustee VS Paula Stahl Or Occupants 2101 Lambsgap Road Enloa, PA 17025 A'rTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION No. 02-4467-Civil Term Cumberland County YERIFICATION OF NON-N/III,ITARY ,qFRVICI~ FRANK FEDERMAN, 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 no.t 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. Co) That defendant Pania Stahi Or occupants, is over 18 years of age, and resides at 2101 Lambsgap Road, Enloa, PA 17025. This statement is made subject to the penalties of 18 PA. C.S.S 4904 relating to unsworn falsification to authorities. 3~rK F ~I~ER~N, ESQUIRE rney f r~p~dntiff PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA County of Cumberland Bankone National Association, Trustee VS Paula Stahl Or Occupants 2101 Lambsgap Road Enloa, PA 17025 COURT OF COMMON PLEAS CIVIL DIVISION No. 02-4467-Civil Term Cumberland County PRAECIPE FOR -WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 2101 Lambsgap Road, Enloa, PA 17025 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION*** Being Known as No. 2101 Lambsgap Road (~'TTORNEY FO~LAINTIFF and be~g ~ ~e Towns~ o~ ~Am~e~, in the'County of Cumber- way of ~.R. 2lOlL No=~ 73 deg=oes 33 m~nUh~s 14 seconds E~st, 20.59 b.R. 2LOOL~ ~he pLAC= OF ~EG~NNZNG. Pau~a ~]. StahL, tls wLfe, Grantors hege£n. Th£s Ls a~ exempt t=ans~er %~RIF Of POSSESSION BANKONE NATIONAL ASSOCIA~I~, TRUSTEE PAULA STAHL OR OCCUPANTS ' Elec:~,,¢nt ProceedLngs PRC P $i60 - 3163 C 0 U5i'¥ OF ........ _BANKONE NATIONAL ASSOCIATION, TRUSTEE i-.- ....................................................................................... P!aL~[ff o~:=~: iP.":=--;.~ ~ :'o~ow~) : 2101 LAMBSGAP ROAD ENOLA, PA !7025 ._~_ Curtis R. Long ..... r .... i- ............. ? ......... .- ............ P.'~c..or. oc-J.: .-. C~.-':r.~.-:¢:}. ?!~...s C~,.:.--. o~  ' ~ ~00 ~r:==o[:~Z~ ' ' -. ~' ' - ........................................... '.~'~L '~ ~ ..................... ~ cz~ ~c w~a~m n~ .......................... Raturned STAYED this Data~ Property is Vaaant Sheriff's Costs: ..................... ~a~ae__Ons~: .... ~5~-~ .......... ~8~%-~ ..... ~--~-00- ........ Sheriff ~o~.~. .... ~4~ ....................................................... ~z::~_ ......... Surahar~e 20.00 Rsfunded ~la~ ............ ~2~-42 ..................................................