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Home My WebLink About02-4914 FEDERMAN AND PHELAN, LLP By: Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza Suite 1400 Philadelphia, PA 19103 (215) 563'7000 Attorney for Plaintiff Secretary of Veterans Affairs, An Officer of The United States of America Varo Cleveland (MDP 262 PHI) P.O. Box 99640 Cleveland, OH 44199 Court of Common Pleas Civil Division v. Cumberland County Steven Durham Or Occupants 9 Eastwood Drive Carlisle, PA 17013 Term No.O;/' ~ .lJ9Ii Cu: L ~t.a..r>t rmTn, A~'l'TON _ R.m~'l'MF.N'I' _ ~n~m NO'l'TnlJ: 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 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. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1. Plaintiff is Secretary of Veterans Affairs, An Officer of The United States of America. 2. Defendant is Steven Durham and Or Occupants. 3. Plaintiff is the owner of premises located at 9 Eastwood Drive, Carlisle, PA 17013, a legal description of which is attached. 4. 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). 5. 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 deliver up possession of same. WHEREFORE, plaintiff seeks to recover possession of said premises. ~vl{"'/}1j tftd.)/)~ F FEDER , ESQUIRE Attorney for Plaintiff ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Silver Springs in the County ofCumberJand and Commonwealth of Pennsylvania, more particularly described as follows: BEING Lot No.7 on the Plan of Lots known as Jay Ridge Manor, Section "A", as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 16, Page 79. SAID lot containing 65 feet along Eastwood Drive, a depth along the North of 150 feet, a width in the rear of 130 feet and a depth along the South of 166.26 feet. HA VING THEREON ERECTED a bi-Ievel dwelling with integral garage known and numbered as 9 Eastwood Drive, Carlisle, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Steven E. Durham and Ann M. Durham, His Wife by Deed from Terry A. Shope and Barbara A. Shope, his wife dated 8/23/1 999 and recorded 8/24/1999 in Record Book 206, Page 350. BEING KNOWN AS: 9 EASTWOOD DRIVE CARLISLE, PA 17013 , I 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. RC.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: 1117 loc_ o / Fr k Federman, squire Attorney for Plaintiff (Q~"/c;l, rLlf; ~ ~ o~ () Iv ~ ~ -I ::. ~ p:: ~ -c:. rTl ;.... ~ (/) . ~./ g[-~ ~~ :<l " .') "m.t I \ .;::~ :::> C) ....~ 8 __,,-, -< SHERIFF'S RETURN - REGULAR CASE NO: 2002-04914 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SEC OF VETERANS AFFAIRS VS DURHAM STEVEN JODY SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon DURHAM STEVEN the DEFENDANT , at 1512:00 HOURS, on the 11th day of October ,2002 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQ CARLISLE, PA 17013 by handing to STEVEN DURHAM 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: Docketing Service Affidavit Surcharge So Answers: 18.00 3.45 .00 10.00 .00 31.45 /'J /~/ ~ ~>>f:;;"-~'!:f~ R. Thomas Kline 10/14/2002 FEDERMAN & PHELAN Sworn and Subscribed to before 7:"thJ.s ~ day of j:~ ~<<:~ AD. Prot notar1'l -~ By: ,,--'(~ J ,-~t~ Deput Sheriff PHELAN HALLINAN & SCHMIEG, LLP BY: FRANCIS S. HALLINAN, ESQUIRE Identification No. 62695 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Department of Veterans Affairs ATTORNEY FOR PLAINTIFF Court of Common Pleas Plaintiff Civil Division vs. Cumberland County Steven Durham Ann Durham Defendant( s) No. 02-4914 PRAECIPE TO THE PROTHONOTARY: X Please mark the above referenced case Discontinued and Ended without prejudice. _Please mark the above referenced case Settled, Discontinued and Ended. Please mark Judgments satisfied and the Action settled, discontinued and ended. Please Vacate the judgment entered and mark the action discontinued and ended without prejudice. Please withdraw the complaint and mark the action discontinued and ended without prejudice. Date: !1\&\1 o( ~AI1(~<)11~ ~ Francis S. Hallinan, Esquire Attorney for Plaintiff - 0 "-' c <= 0 = en -n " (/) ~ ...., -0 f11::!J N -oF,; W :."9 ~o -0 ~5:}~ ::x C~' -7("") ~? Om :Z .-j =<' c::> 55 -<