The URL can be used to link to this page

Home My WebLink About00-07665 "lib' " ",1'- ,-,-. ",., -"~I:'f':_ , FEDERMAN AND PHELAN LLP. By: Frank Federman, Esquire Identification No, 12248 Two Penn Center Plaza, Suite 900 Philadelphia, P A 19102-1799 (215) 563-7000 Attorney for Plaintiff SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA V ARO CLEYELAND (MDP 262 PHI) P.O. BOX 99640 CLEVELAND,OH 44199 Court of Common Pleas Civil Division v, CUMBERLAND County Term MICHAEL JOHNS OR OCCUPANTS 1436 BRIDGE STREET NEW CUMBERLAND, PA 17070 No. 00 - 7(,{,S CVlL~ CIVIL ACTION - EJECTMENT - 3020 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 LffiERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 L _ I,~ , ., , _M' ~ . -- <' "" [If) l.l'\\ .c. 1. Plaintiff is SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA. 2. Defendant is MICHAEL JOHNS OR OCCUPANTS. 3. Plaintiff is the owner of premises located at 1436 BRIDGE STREET, NEW CUMBERLAND, P A 17070, 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 posses'sion of said premises. :'.,;\ " ~ RANK FED N Attorney for Plaintiff Order Number: Client Number: Premises: Ii;.., --I ill- t ARACOR Search and Abstract Services, Inc. One Penn Center, 1617 J.F.K. Boulevard, Buite305 Philadelphia, penns/zvania 19103 (215) 496-0900 FAX (215) 496-0904 -~-REC()RD OWNER AND LIEN CERTIFICATE Effective Date: 8/14/99 A34941 JOHNS 1436 BRIDGE STREET, BOROUGH OF NEW CUMBERLAND CUMBERLAND COUNTY PENNSYLVANIA 4 Based upon the examination of evidence in the appropriate public records, Company certifies that the premises endorsed hereon are subject to the liens, encumbrances and exceptions to title hereinafter set forth. This Certificate does not constitute title insurance; liability hereunder is assumed by the Company solely in its capacity as an abstractor for its negligence, mistakes or omissions in a sum not to exceed Two Thousand Dollars. DESCRIPTION / ALL THAT CERTAIN lot or piece of land Situate in the Borough of New Cumberland, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Southerly line of Bridge Street, which point is 25 feet East of the Southeasterly corner of 15th and Bridge Streets; thence along the Southerly line of Bridge Street South 43 degrees 30 minutes East, 25 feet to a point; thence South 46 degrees 30 minutes West 150 feet to a point at the Northerly line of a 16 feet wide private alley; thence along the same North 43 degrees 30 minutes West 25 feet to a point; thence North 46 degrees 30 minutes East 150 feet to a point, the place of beginning. BEING premises known as 1436 Bridge Street. TOGETHER with the right to use the said 16 feet wide private alley in common with other owners and occupiers abutting thereon. Tax Parcel # 26-23-0541-178 < , . Il' _ _r _ ~, ---"-' iJ,wi 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 falsificatlohto authorities. d~~ Attorney for Plaintiff Date: /~/cufCO i iJi#m<< ~ ~i$!WlllF~[li ,,,," ~"ifl;~~~\l~llIlll .iJU-li.~. '<t lil'IlQ,..tilr ~ -........... . ~ ~ A) ~ '6 8 It:. CI). ~ V) ~ (') (:) 8 () c (:) ... 0 --l ...... () -Ow r> -,- 0- ~m -I Nlp! I :J:::I W !q 2:r- eN :g~ ci5J; (:) ~ ~ ~ VJ -<L_ () ~o ~"-f _ ""'" ,..,..., f r ~ 3:Eo :x 7)-" 20 ;1>0 \.0 011"1 1 ~ ., ~ (:) (.;> -< .^ , -~ , . I:., -I . L --~ ,',. ~--,~"~,~ '.ire SHERIFF'S RETURN - REGULAR CASE NO: 2000-07665 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SECRETARY OF VETERANS AFFAIRS VS JOHNS MICHAEL BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon JOHNS MICHAEL the DEFENDANT , at 0018:50 HOURS, on the 3rd day of November, 2000 at 1436 BRIDGE ST NEW CUMBERLAND, PA 17070 by handing to BRANDI RALPH (CURRENT RESIDENT) 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 18.00 10.54 .00 10.00 .00 38.54 SOAn~ ~ ~ 1~ R. Thomas Kline 11/06/2000 FEDERMAN & Sworn and Subscribed to before By: ~14, &u/J Deputy Sheri~ me this tz-, ''1~ / day of ~. ,2hMJ A.D. Q (2 . rl' <4,. ~~ ~rothonotary , , '. --,j JIo.,,- .~ . -I _ ~ ..' ,; '~N' ,,,_,__'~ - "'~-f~~' FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Attorney for Plaintiff Suite 1400 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD PHILADELPHIA, PA 19103-1814 (215) 563-7000 SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. NO. 00-7665 MICHAEL JOHNS OR OCCUPANTS CUMBERLAND COUNTY Defendants J'RARCTPF. TO TNllRXRAT,PHRRANllT AS ORFF.NllANT TO THE PROTHONOTARY: Pursuant to P.A RCP. 410 (a)(2), kindly index Ralph Branni as Defendant in the above captioned matter. Ralph Brandi was found in possession of the premises and was served with a copy of the Complaint on November 3, 2000. '.l~ -=+--Jk.. Frank Federman, Esquire Attorney for Plaintiff Date: Novpmnpr 74 7000 ~~t~~!tljMOO~Jijf~~.il1!~ail!iJll~~,;~~~~~~;i~ili;M~I!Jj~_ ..~ -"._-~~ . _.~~ (r~.' ~" .. ..;,..",~-,J _~ \'i " ~ C) (::) C C) ::-::- 9.2~ :::i .-.< ."0':': ;I-~ Z c- r,) '-i.:i ~::'~- ,.0 ,.-,' ~~ -C ~:--~() -,- --~ I I '~_~.3 :;f! 7\.'; )>c (~ en ~ ~ 0> r.., Xi -< f.;