HomeMy WebLinkAbout00-04575
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FEDERMAN AND PHELAN
By: Frank Federman, Esquire
Identification No. 12248
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19102-1799
(215) 563-7000
Attorney for Plaintiff
BANK UNITED
3200 SOUTHWEST FREEWAY, MAIL DROP 1422
HOUSTON, TX 77027
Court of Common Pleas
Civil Division
v.
CUMBERLAND County
Term
JENNIFER MORN
OR OCCUPANTS
226 NORTH 36TH STREET,
NK/A 226 WOOD STREET
CAMPHILL,PA 17011
No. 00 - ,,",S7$'
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CTVTT, ACTION - F..TF.CTMF,NT - ~020
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.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY A VENUJE
CARLISLE,PA 17013
(717) 249-3166
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1. Plaintiff is BANK UNITED.
2. Defendant is JENNIFER MOHN OR OCCUPANTS.
3. Plaintiff is the owner of premises located at 226 NORTH 36TH STREET, AIKJ A 226 WOOD
STREET, CAMP HILL, PA 17011, 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 oftitle.
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.
~~
. NK FEDE
Attorney for Plaintiff
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DESCRIPTION
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ALL THAT CERTAIN lot of land situate in the Township of Hampden, County of Cumberland and
State of Pennsylvania, more particularly bounded and described as follows:
/
BEGINNING at a point on the Southwestern legal right-of-way line of Wood Street at the
Southeastern corner of lands now or formerly of Albert and Elizabeth Schaffhauser; thence along the
legal right-of-way line of Wood Street by a curve to the left having a radius of 58 feet, an arc
distance of 60.72 feet to an "x" in the concrete at the intersection of the southern legal right-of-way
line of Wood Street with the western legal right-of-way line of North 36th Street; thence through
Lot No. 162 of which this was formerly a part, the following three courses and distances; (1) South
. 46 degrees 17 minutes 23 seconds West. a distance of 75.87 feet; (2) through the party wall
separating the house known as 226 Wood Street, hereon erected. and house known as 224 Wood
Street, South 54 degrees 42 minutes 40 seconds West. a distance of 30.077 feet; (3) South 72
degrees 18 minutes 58 seconds West, a distance of 167.29 feet to a p.k. nail in tree; thence North
19 degrees 24 minutes 30 seconds West. a distance of 45 feet to a tree at the Southwestern corner of
lands now or formerly of Albert and Elizabeth Schaffhauser; thence along lands now or formerly of
Schafthauser. North 63 degrees 07 minutes 0 seconds East, 225,14 feet to a point. the place of
beginning,
BEING the Northern portion of Lot No. 162 as shown on Plan of Hollywood Development. as
recorded in Plan Book 9, page 17, Cumberland COUnty Records. and further being Lot No. 162-B,
Preliminary-Final Subdivision of Lot No, 162 Hollywood Development. dated January 22, 1981
recorded in Plan Book , page
HAVING thereon erected a semi-detached dwelling known as 226 North 36th Street, Camp Hill,
penns~lvania. Also being known as 226 Wood Street, Camp Hill, Pennsylvania.
Tax Parcel /I 10-20-1850-040D
TITLE TO SAID PREMISES IS VESTED IN Jennifer Lynn Mohn, single and Andrew M. Cover,
Jr., single as Joint TenantS with the Right of Survivorship by Deed from Thomas M. Markley and
Dinah Scabo-Markley, his wife and Doris J. Mowery, single person dated 11/30/92, recorded
12/4/92, in Deed Book A-36, Page 448.
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VERIFICATION
Frank Federman, Esquire hereby states that he is the Attorney for the Plaintiff in this matter, that
he is authorized to take this Verification, 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.
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.
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Attorney for Plaintiff
Date: t? / iJ-o/-;ttJ
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-04575 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BANK UNITED
VS
MOHN JENNIFER ET AL
WILLIAM DIEHL
, Sheriff or Deputy Sheriff of
Cumberland County, Pensylvania, who being duly sworn according to law,
says, the within COMPLAINT - EJECTMENT
was served upon
MOHN JENNIFER
the
DEFENDANT
, at 1956:00 HOURS, on the 10th day of July
2000
at 225 NORTH 36TH STREET
CAMP HILL, PA l7011
by handing to
JENNIFER MOHN (K/N/A MANATT)
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:
Docketing
Service
Aff idavi t
Surcharge
So Answers:
18.00
8.68
.00
lO.OO
.00
36.68
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R. Thomas Kline
07/11/2000
FEDERMAN AND PHELAN
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Deput ff
Sworn and Subscribed to before
me this M te day of
~q;; A.D.
Q, fiw.L~
r thonotary )
By:
',',
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2000-4675 CIVIL TERM
JAMES B. COCKER,
Plaintiff
LUCY B. BARGER,
Defendants
CIVIL ACTION-LAW
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 twenty (20) days after this complaint
and notice are served, by entering a written appearance personally or by an 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 any 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 Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
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JAMES B. COCKER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2000-4675 CIVIL TERM
v.
LUCY B, BARGER,
Defendants
CIVIL ACTION-LAW
COMPLAINT
AND NOW, comes the Plaintiff, James B. Cocker, by and through his attorney,
Michael A Scherer, Esquire, and respectfully represents as follows:
1. The Plaintiff, James B. Cocker, is an adult individual residing at 4214
Livingstone Drive, York, York County, Pennsylvania, 17402.
2, The Defendant, Lucy B. Barger, is an adult individual who resides at 1491
Lutztown Road, Boiling Springs, Pennsylvania, 17055.
3. The facts and occurrences hereinafter related occurred on or about
December 13, 1999 at about 5:00 p.m. on Route 11 in the northbound lane at its
intersection with East Main Street in New Kingstown, Cumberland County,
Pennsylvania.
4. At the aforesaid time and place, the Plaintiff's son, James B. Cocker, Jr.
was traveling north on Route 11 when a school bus, which was being operated by the
Defendant, pulled directly into the path of the automobile being operated by James B.
Cocker, Jr.
5, The collision resulted in severe damage to the Plaintiff's vehicle, which
was a 1991 Chevrolet Prizm. The Plaintiff's vehicle was considered to be a total loss
by the Plaintiff's insurance company.
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in that she:
damages:
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The accident was caused as a result of the negligence of the Defendant
a. failed to keep her vehicle entirely within her own lane of travel, in
violation of section 3309(1) of the Vehicle Code;
b. failed to yield the right of way to James B. Cocker after having
stopped at the stop sign at the intersection in violation of section
3323(b) of the Vehicle Code;
c. failed to have his vehicle under proper control; and,
d. operated his vehicle in a careless manner.
7.
As a result of the aforesaid accident, Plaintiff suffered the following
a. Loss of fair market value of 1991 Chevrolet Prizm: $ 2,400.00
b.
$ 120.00
Tax, title and fees incurred at purchase of Prizm:
c.
Towing bill to Miller and Sams
$
$ 2,615.00
95.00
Total damages
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of
$2,615 plus costs of suit, which total $64,00,
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
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1.0. # 61974
17 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
mas.dir/genlitlcocker.com
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VERIFICATION
I verify that the statements made in the foregoing Complaint are true and correct to
the best of my knowledge, information and belief. This verification is signed by Michael
A. Scherer, Esquire, Attorney for Plaintiff and is based upon the statements provided by
the Plaintiff, as well as documents reviewed by the undersigned as attorney for the
Plaintiff. This verification will be substituted and ratified by a verification signed by the
Plaintiff who is presently unavailable to sign said verification. I undersigned that false
statements herein are made subject to penalties of 18 Pa.C,S. ~4904, relating to unsworn
falsifications to authorities.
~d.>i6
Michael A. cherer, squire
Dated:
7.20.00
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CERTIFICATE OF SERVICE
I hereby certify that on July @., 2000, I, Jennifer S. Lindsay, secretary to Michael
A. Scherer, Esquire, did serve a copy of the Complaint, by first class U.S. mail, postage
prepaid, to the party listed below, as follows:
Barry A. Kronthal, Esquire
Margolis Edelstein
3510 Trindle Road
Camp Hill, Pennsylvania 17011
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FEDERMAN AND PHELAN
BY: FRANKFEDERMAN
IDENTIFICATION NO. 12248
Suite 900/Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
BANK UNITED
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
vs
JENNIFER MORN
OR OCCUPANTS
226 NORTH 36TH STREET,
AlKJA 226 WOOD STREET
CAMP HILL, PA 17011
No. 00-4575
CUMBERLAND County
PR A RCTPR FOR .rrmr.MRNT TN R.TF:CTMRNT
TO THE PROTHONOTARY:
Kindly enter Judgment in Ejectment in favor of the Plaintiff, BANK UNITED and against the
Defendant(s) JENNIFER MOHN and OR OCCUPANTS for possession of premises 226 NORTH 36TH
STREET, AIKI A 226 WOOD STREET, CAMP HILL, P A 170 II for failure to file an Answer within
twenty (20) days of service.
1 hereby certifY that according to Rule 237.1, written 10 day notice of Plaintiff's 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.
F~~~~
Attorney for Plaintiff
Default Judgment entered as indicated above.
DATE
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FEDERMAN AND PHELAN
Frank Federman, Esquire
Identification Number l2248
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19l02-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
BANK UNITED
COURT OF COMMON PLEAS
CIVIL DIVISION
v.
CUMBERLAND COUNTY
JENNIFER MOHN
OR OCCUPANTS
No. 00-4575 CIVIL
TO: JENNJ:FER MORN OR OCCUPANTS
226 NORTH 36~ STREET, A/K/A
226 WOOD STREET
CAMP HJ:LL, PA 17011
DATE OF NOTICE:
AUGUST 11. 1998
THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.
:IMPORTANT NOTJ:CE
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 (lO) 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:
CUMBERLAND COUNTY BAR ASSOCJ:ATJ:ON
2 LJ:BERTY AVENUE
CARLJ:SLE, PA 17013
(717) 249-3166
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F ank Feder-mAn; Esquire
ttorney for Plaintiff
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FEDERMAN AND PHELAN
BY: FRANKFEDERMAN
IDENTIFICATION NO. 12248
Suite 900/Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
ATTORNEY FORPLMNTIFF
BANK UNITED
COURT OF COMMON PLEAS
CIVIL DIVISION
vs
JENNIFER MOHN
OR OCCUPANTS
226 NORTH 36TH STREET,
NKIA 226 WOOD STREET
CAMP HILL, PA 17011
No. 00-4575
CUMBERLAND County
VF,RTFTC'ATTONOFNON-MTTJTARV SF.RVTCF.
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 !lot 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 JENNIFER MOHN Or occupants, ,is over 18 years of age, and resides at
226 NORTH 36TH STREET, A/KJA 226 WOOD STREET, CAMP HILL, PA 17011.
This statement is made subject to the penalties of 18 P A. C.S.S 4904 relating to unsworn
falsification to authorities.
~~
F K FEDE ,ESQUIRE
Attorney for Plaintiff
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PRAECIPE FOR WRIT OF POSSESSION
C0Ml\.10NWEAL TH OF PENNSYL VANIA
COUNTY OF CUMBERLAND
BANK UNITED
COURT OF COMMON PLEAS
CIVIL DIVISION
vs
JENNIFER MOHN
OR OCCUPANTS
226 NORTH 36TH STREET,
AIKI A 226 WOOD STREET
CAMPHILL,PA I701I
No. 00-4575
CUMBERLAND County
PRAECIPE FOR WRIT OF POSSESSION
TO THE PROTHONOTARY:
Issue Writ of Possession in the above matter for possession of:
226 NORTH 36TH STREET, A1K1A226 WOOD STREET, CAMP HILL, PA I70II
**PLEASE SEE THE ATTACHED LEGAL DESCRIPTION***
Being Known as No. 226 NORTH 36TH STREET, AIKIA 226 WOOD STREET
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ATTORNEY FOR PLAINTIFF
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DESCRIPTION
ALL THAT CERTAIN lot of land situate in the Township of Hampden, County of Cumberland and
I State of Pennsylvania, more particularly bounded and described as follows:
BEGINNING at a point on the Southwestern legal right-of-way line of Wood Street at the
Southe;lS[ern corner of lands now or formerly of Albert and Elizabeth Schaffuauser; thence along the
/ legal right-of-way line of Wood Street by a curve to the left having a radius of 58 feet, an arc
distance of 60.72 feet to an "x" in the concrete at the intersection of the southern legal right-of-way
line of Wood Street with the western legal right-of-way line of North 36th Street; thence through
Lot No. 162 of which this was formerly a part, the following three courses and distances; (1) South
. 46 degrees 17 minutes 23 seconds West, a distance of 75,87 feet; (2) through the party wall
separating the house known as 226 Wood Street, hereon erected, and house known as 224 Wood
Street, South 54 degrees 42 minutes 40 seconds West, a distance of 30,077 feet: (3) South 72
degrees 18 minutes 58 seconds West, a distance of 167.29 feet to a p.k. nail in tree; thence North
19 degrees 24 minutes 30 seconds West. a distance of 45 feet to a tree at the Southwestern corner of
lands now or formerly of Albert and Elizab.eth Schaffhauser: thence along lands nO\v or formerly of
Schaftbauser. North 63 degrees 07 minutes 0 seconds East, 225.14 feet to a point. the place of
beginning,
BEING the Northern portion of Lot No, 162 as shown on Plan of Hollywood Development. as
recorded in Plan Book 9, page 17, Cumberland County Records. and further being Lot No, 162-B,
Preliminary-Final Subdivision of Lot No, 162 Hollywood Development, dated January 22, 1981
recorded in Plan Book , page
HAVING thereon erected a semi-detached dwelling known as 2~6 North 36th ~treet, Camp Hill,
Pennsvlvania. Also being known as 226 Wood Street, Camp HIll, Pennsylvama.
.
Tax Parcell/ 10-20-1850-040D
TITLE TO SAID PREMISES IS VESTED IN Jennifer Lynn Mohn, single and Andrew M. Cover,
Jr., single as Joint Tenants with the Right of Survivorship by Deed from Thomas M. Markley and
Dinah Scabo-Markley, his wife and Doris J. Mowery, single person dated 11/30/92, recorded
12/4/92, in Deed Book A-36. Page 448.
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R. Thomas Kline, Sheriff, who being duly sworn according to
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Docketing $18.00 Sheriff's Costs: 39.07
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"VRlT OF POSSESSIO~- [Ejecrment Proceedings PRe P 3160 - 3165 etc)
BANK UNITED __
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IX THE coeR l' OF CO~1110), PLEAS OF
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JENNIFER MORN OR OCCUPANTS
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226 NORTH WOOD STREET
CAMP HILL, PA 17011
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CO~DIO:_iWEAL TH . OF PE.."':\i"SYL VANIA:
COl":'lTY OF Cl":\IBERL."-"TI:
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:oUowing described property .:0:
BANK UNITED
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being: '. P=L<es 3S foEows): 226 NORTH 36TH STREET, A/K/ A
226 NORTH WOOD STREET,
CAMP RILL, PA 17011
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