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Home My WebLink About03-0152THE SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA, THE DEPARTMENT OF VETERANS AFFAIRS, Plaintiff RICHARD D. BARTLETT, Defendant · IN THE COURT OF COMMON PLEAS : CUMBERLAND CO., PENNSYLVANIA · CIVIL ACTION - LAW : IN EJECTMENT 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 have been served. To defend against the aforementioned claims, a written appearance stating your defenses and objections must be entered and filed in writing by you, the defendant, or by an attorney. You are warned that if you fail to take action against these claims, the coud may proceed w thout you and a judgment for any money claimed in the Compla nt or for any other claim required by the plaintiff may be entered against you by the Court without further notice. You may lose money, 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 Assn. 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas damandas expuastas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENNE ABOGAD O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVlClO, VAYA EN PERSONA O LLAME POR TELEFONE A LA OFIClNA CUYA DIRECClON SE ENCUENTRA ESCRIDA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENClA LEGAL: CUMBERLAND COUNTY Cumberland County Bar Assn. 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 THE SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA, THE DEPARTMENT OF VETERANS AFFAIRS, Plaintiff RICHARD D. BARTLETT, : IN THE COURT OF COMMON PLEAS · CUMBERLAND CO., PENNSYLVANIA · CIVIL ACTION - LAW : IN EJECTMENT COMPLAINT IN EJECTMENT 1. THE SECRETARY OF THE DEPARTMENT OF VETERANS AFFAIRS, IS AN OFFICER OF THE UNITED STATES OF AMERICA, (hereinafter "Plaintiff"), who represents the Department of Veterans Affairs, a federal agency located in Washington D.C., with local administrative offices at 5000 Wissahickon Avenue, Philadelphia, Pennsylvania 19101. 2. The Defendant, ROBERT D. BARTLETT is an adult individual (hereinafter "Defendant"), currently residing at the property known as 12 Rockaway Drive, Camp Hill, Cumberland County, Pennsylvania 17011, which is more fully set forth in the legal description attached hereto and marked Exhibit "A". 3. The Defendant is occupying said premises without claim of right, title or interest because the title to the premises is held by the Plaintiff as set forth in the following abstract of title: a) Ownership was acquired by Plaintiff at SherifFs Sale on November 6, 2002. b) Title to Plaintiff was conveyed by the Sheriff of Cumberland County. c) The Deed into the Plaintiff's name was recorded in the Recorder of Deeds Office of Cumberland County. d) The property conveyed by the Deed is 12 Rockaway Drive, Camp Hill, Cumberland County, Pennsylvania 17011. e) The interest conveyed by the Deed is fee simple. 4. Plaintiff avers that by virtue of the aforementioned abstract of title, it is the current owner of the premises in question and has full right to immediate possession, notwithstanding the possession by the Defendant or any persons named pursuant to Pa. R.C.P. No· 410(b)(2). 5. Plaintiff avers that any rights the Defendant might have had in the premises were terminated by the Sheriff's sale of the properly as set forth in Paragraph 3 herein. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an Order granting it possession of the premises set forth in this Complaint, and further requests this Court to permit Plaintiff to direct the Prothonotary to issue a Writ of Possession. (va.dir\bartlett. comp) Respectfully submitted, Jill/¢. Wineka, Esquire AttOrney ID # 58802 PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorneys for Plaintiff described as t'ollows amy, re~nsylvan/a, more particularly bounded and BP.,GII~'~I~G at a point on thc easterly line of Rockaway Dr/ye which point is $01.04 feet North of thc northca.Stcrly comer of Rockawav I16 ~vc and Palmer [)rive at a dividing tiuc between /.ets Nos. I9and20, BlockIIon , ~:~ ~, . ot'R.ockaway Drive North 42 degrees 20 to a point at the dividin~ line between Lots Ho~. 20 and 21, Block H in said Plan; thrace along said dividing line North 47 dcg~.a 40 mi~lltes a~lst 125 Ibet to apt;/tit t?ri thc westerly line of Lot N,,. S, Biotic H on said plan; thence along the westerly line of Lots Nos. 5' and 6, Block H on iaid Plan South 42 degrect 20minuteaFast80fe~tloa" ' ' ' - . .. ~ .: , , Im !~t st dlvlchng line b.tu. ee:~ h.,m betwceit Lots Nos Ii) and 20, Block H *.for*said; thence along same S,.,u!h 47 degrees 40 minmcs West 125 f~t to a pOint, the pla~e of BI'GINNING. HAVING THI!RI~oN ERI~CTE"D a single brick and frame ranch type dwelling, said pmmis~s b~n~ imown and -umbered as 12 Rockaway Drive. AND BEING Lot No. 20, Block _r~_o_,'ded in il~ Cumberland County Reco~'s Office in De-.d Book 7, Page 41. UIqDER AND SUB/I~CT, NI~VI~RTHI~F.,S$, ~ad fights of way ofr~onL THE SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA, THE DEPARTMENT OF VETERANS AFFAIRS, Plaintiff ROBERT D. BARTLETT, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND CO., PENNSYLVANIA : : NO. : CIVIL ACTION - LAW : : IN EJECTMENT : STATE OF PENNSYLVANIA COUNTY OF PHILADELPHIA _pLAINTIFF'S AFFIDAVIT FOR COMPLAIN'[ : :SS : JANICE P. DiBENEDETTO, Acting Loan Guaranty Officer, being duly sworn according to law, deposes and says that she is a duly constituted representative for the Secretary of Veterans Affairs, Plaintiff in the foregoing Complaint; that she is duly authorized to make this Affidavit; that she has personal knowledge concerning the unlawful possession which is the subject of the action above captioned; and that the facts set forth in the foregoing Complaint are true to the best of her knowledge, information and belief. SWORN to and subscribed to before me this/_~_,~day of ~.~y~==, 2002. /- Acting Loan Guaranty Officer SHERIFF'S RETURN - REGULAR CASE NO: 2003-00152 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CI/MBERLAND SECRETARY PF VETRAMS AFFAIRS VS BARTLETT RICHARD D BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon BARTLETT RICHARD D the DEFENDANT , at 1803:00 HOURS, on the 15th day of January , 2003 at 12 ROCKAWAY DRIVE CAMP HILL, PA 17011 by handing to SARA BARTLETT, WIFE 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 18.00 Service 8.97 Affidavit .00 Surcharge 10.00 .00 36 . 97 Sworn and Subscribed to before me this 2~ day of ~ ~2~ A.D. / / Prothonotary So Answers: R. Thomas Kline o1/1 /2oo3 PURCELL KRUG HALLER By: D~uty Sheriff THE SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA, THE DEPARTMENT OF VETERANS AFFAIRS, Plaintiff RICHARD D. BARTLETT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 03-152 - CIVIL TERM CIVIL ACTION - LAW IN EJECTMENT PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly mark the above-captioned matter discontinued without prejudice. Respectfully submitted, Dated: 2-/,.~/(.~ Jill,l~l~ Wineka, Esquire Atli;~rney ID # 58802 PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorneys for Plaintiff CERTIFICATE OF SERVICE I, Barbara A. Shadel, an employee of the law firm of Purcell, Krug & Hailer, do hereby certify that I served a true and correct copy of the foregoing Praecipe to Discontinue upon the following by depositing same in the United States Mail, First Class Postage, Postage Prepaid, addressed as follows: Richard D. Bartlett 12 Rockaway Drive Camp Hill, PA 17011 Pro Se Defendant Barbara A. Shadel Dated: