Loading...
HomeMy WebLinkAbout00-07687 Jj ,~ ~ I >" ,-- I~ " , ,:;;,-- O~ ~ "'&J~ < FEDERMAN AND PHELAN L.L.P. 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 TIlE UNITED STATES OF AMERICA V ARO CLEVELAND (MDP 262 PHI) P.O. BOX 99640 CLEVELAND, OR 44199 Court of Common Pleas Civil Division v. CUMBERLAND County Term RICHARD A. SHERWOOD OR OCCUPANTS 416 WATER STREET NEW CUMBERLAND, PA 17070 No.()o~ 7'P7 G('>lL'--r~ 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) 24!rc3166 .);.\"'; .", i :ijl."', -,~ '''';'' .L:LJ...',-' 'II ,-,I," 1,' .iii :";f: 1. Plaintiff is SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA. 2. Defendant is RICHARD A. SHERWOOD OR OCCUPANTS. <\L\ 3. Plaintiff is the owner of premises located at 416 WATER STREET, NEW CUMBERLAND, PA 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 of title. 6. Plaintiff has demanded possession of the said premises from the said defendant who has refused to deliver up possession ofsame-; WHEREFORE, plaintiff seeks to recover possession of said premises. ~fL A~ C/~~~ Attorney for Plaintiff ".',.,-" , ':~ s rac ervl e, nc. One Penn Cehter, 1617 J.F.K. Bouievard Suite 305 , . Philadelphia, Pennsylvania 19103 (215) 496-0900 FAX (215) 496-0904 RECORD OWNER AND LIEN CERTIFICATE ~" --- -- Effective Date: 2/14/99 ~ Order Number: Client Number: A30559 SHERWOOD / Premises: 416 WATER STREET, BOROUGH OF NEW CUMBERLAND CUMBERLAND COUNTY PENNSYLVANIA Based upon the examination of evidence in the appropriate public records, Company certifie~ 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, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Southerly line of Water Street at the center of the center wall between houses Nos. 414 and 416 Water Street, New Cumberland, Pennsylvania; thence in a Westerly direction along the Southerly line of Water Street, thirty seven and one-half (37-1/2) feet, more or less, to Lot No. 37 on the General Plan of New Cumberland; thence in a Southerly direction along said Lot No. 37, one hundred fifty (150) feet to Walnut Alley; thence in an Easterly direction along the line of Walnut Alley, thirty-seven and one-half (37-1/2) feet, more or less, to a point; thence on a line parallel to the dividing line between Lot Nos. 36 and 37 on said plan and through the center of the center wall between houses Nos. 414 and 416 Water Street, one hundred fifty (150) fcet to the Southerly line of Water Street, the place of beginning. HA VING thereon erected one-half of a double frame dwelling house known as No. 416 Water Street, New Cumberland, Pennsylvania 17070. Tax Parcel # 25-24-0813-052 . '.~ ~", I I ' .;,,~I' J" ~-:~:"~,! 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. d~~ Attorney for Plaintiff Date: / tJ /';;-5/a; f ' " ~ \o( \ :,' ". Jll '~~'il~~ ' '," Ji:~~IiiiQ,i:lillii&~~~~ ' " ,',' ~, <-'-"' d.~"~~ _~ , (CJ ~ t "'9.. () !i:- t G..'J !'l 0t c: a 0 "'Off; :::> -1'1 ......... & ~ a 52'" CJ ;~f8 C\ C> z::t! -< C'. w '" C/) '" ,8~ tI) tV I I ;:::;~ a jJ < ~ ~CJ ~ ~o -0 '.i(.) :3: ~" Ii' ;;;:0 c,lj ~ .,)0 ~t ~ om =< II',) ~ <xl -< ~ ~ ~ ., .LJ . I, J""",,,~_I ,~"""" ... SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-07687 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VETERANS AFFAIRS SECRETARY OF VS SHERWOOD RICHARD A R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT SHERWOOD RICHARD A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT NOTI CE , NOT FOUND , as to the within named DEFENDANT , SHERWOOD RICHARD A DEFENDANT.NJR-ANY OCCUPANTS COULD BE LOCATED AT ADDRESS STATED, PRIOR TO EXP I RATON , 9 ATTEMPTS Sheriff's Costs: Docketing Service Not Found Return Surcharge 18.00 21.08 5.00 10.00 .00 54.08 ~~ R. Thomas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 12/05/2000 Sworn and subscribed to before me this JLI~ day of ~ c2h/i) A.D. g':h;' ,a. "/Pu.U'z", , ~~ Pr h notary i-" " I " ',L~ '_''1-'"' , .'~ > ~ "'"" ... FEDERMAN AND PHELAN L.L.P. By: Frank Federman, Esquire Identitication- N>h- 122f8 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102-1799 (2 I 5) 563-7000 Attorney for Plaintiff SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA V ARO CLEVELAND (MDP 262 PHI) P.O. BOX 99640 CLEVELAND, OH 44199 Court of Common Pleas Civil Division v. CUMBERLAND County Term RICHARD A. SHERWOOD OR OCCUPANTS 416 WATER STREET NEW CUMBERLAND, P A 17070 No. 00- 7t"P7 CIVIL ACTION - EJECTMENT - 3020 NOTICE . c"o.:c ~ 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 LmERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hind atid tile ~ said Court at CarlllIle, PI. '-- ~~: d~Yp~~.-y~ honotary ,"lL I I,,' /jIij, -...;~~'(.. '''' ... 1. PlaintifLll; ~ECRET ARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA. 2. Defendant is RICHARD A. SHERWOOD OR OCCUPANTS. 3. Plaintiff is the owner of premises located at 416 WATER STREET, NEW CUMBERLAND, PA l7070, a legal description of which is attached. 4. Plaintiff became owner of said premises by a Deed from the Sheriff of CUMBERLAWD 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 infonned, 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. cZ~~~0m'Y7 Attorney for Plaintiff , . .I /1 IH!Ii tll, Ci!.IEW Ll:l)U.1U:!tr,l~t~; WC:" One Penn Celuer. 1617 J.F.K.Bouievard Suite 305 Philadelphia, Pennsylvania 19103' ~ (215) 496-0900 FAX (215) 496-0904 RECORD OWNER AND LIEN CERTIFICATE "~ ~~"' "" " '"~\ '- . . -----, - -" Effective Date: 2/14/99 ~ Order Number: Client Number: A30559 SHERWOOD / Premises: 416 WATER STREET, BOROUGH OF NEW CUMBERLAND CUMBERLAND COUNTY PENNSYLVANIA . .- 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. DESCRIPTIO"" / ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Southerly line of Water Street at the center of the center wall between houses Nos. 414 and 416 Water Street, New Cumberland, Pennsylvania; thence in a Westerly direction along the Southerly line of Water Street, thirty seven and one-half (37-1/2) feet, more or less, to Lot No. 37 on the General Plan of New Cumberland; thence in a Southerly direction along said Lot No. 37, one hundred fifty (150) feet to Walnut Alley; thence in an Easterly direction along the line of Walnut Alley, thirty-seven and one-half (37-1/2) feet, more or less, to a point; thence on a line parallel to the dividing line between Lot Nos. 36 and 37 on said plan and through the center of the center waJl between houses Nos. 414 and 416 Water Street, one hundred fifty (150) feet to the Southerly line of Water Street, the place of beginning. HA VING thereon erected one-half of a double frame dwelling house known as No. 416 Water Street, New Cumberland, Pennsylvania 17070. Tax Parcell! 25-24-0813-052 ,,'~ ,..~~ ti J '--., ~ ~ '""'C,~ " , , . VERIFICATION Frank Federlllan, Esquire hereby states that he is the Attorney for the Plaintiff in this matter, that he is authorizedt()-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. d~~~~ Attorney for Plaintiff Date: / t' /,?.s /Iv I ' 4