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HomeMy WebLinkAbout01-0024 FX " II FEDERMAN AND PHELAN L.L.P. By: Frank Federman, Esquire Identification No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, 1400 Philadelphia, PA 19103-1814 (215) 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 v, TERESA L. FERNBAUGH OR OCCUPANTS 308 EAST MAIN STREET MECHANICSBURG, P A 17055 Court of Common Pleas Civil Division CUMBERLAND County Term No. OJ - d'( ("NIT, A("TTON - Rffi("TMRNT - ~020 NOTICE C(J~t~~ 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 AVENUE CARLISLE, P A 17013 (717) 249-3166 "k . " = - ~ ~~, ~"""'-' " Yi\o...~ "_ '. 1. Plaintiff is SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERlCA. 2. Defendant is TERESA L. FERNBAUGH OR OCCUPANTS, 3, Plaintiff is the owner of premises located at 308 EAST MAIN STREET, MECHANICSBURG, P A 17055, 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, ~~~ Attorney for . tiff ,,' - ,,,,~~. . I~ ~ ~~,~, ARACOR Search and Abstract Services, Inc. One Penn Center, 1617 J.F.K. Boulevard, Suite 305 Philadelphia, Pennsylvania 19]03 (215) 496-0900 FAX (215) 496-0904 RECORD OWNER AND LIEN CERTIFICATE Effective Date: 7/16/99 Order Number: Client Number: A34167 FERNBAUGH Premises: 308 EAST MAIN STREET, BOROUGH OF MECHANICSBURG 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. DESCRIPTION ALL THAT CERTAIN house and lot of ground situate on the South Side of East Main Street, in the Second Ward of the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, more particularly bounded and described according to survey of John C. Brilhart, Registered Surveyor, dated December 5, 1966, as follows, to wit: BEGINNING at a point on the curb line of East Main Street, at corner of lot now of Boyd Fortney and wife, which said point is referenced as North 72 degrees 45 minutes East a distance of one hundred twenty-two and one-tenth (122.1) feet from the center line of South Walnut Street as measured along said curb line; thence extending along said curb line of East Main Street North 72 degrees 45 minutes East, twenty-four (24) feet to a point at corner of lot fonnerly of Hummell heirs, now of Elizabeth G. Shelly thence along the line of said lot now of Elizabeth G. Shelly, South 17 degrees 15 minutes East, one hundred sixty and eighty one-hundredths (160.80) feet to an ironp:i.n in the northern line of Stouffer Alley; thence along said line of Stouffer Alley, South 72 degrees 45 minutes West, twenty-four (24) feet to a fence post at corner of lot of Boyd Fortney and wife aforesaid; thence along the line of said lot of Boyd Fortney and wife North 17 degrees 15 minutes West, one hundred sixty and eighty one-hundredths (160.80) feet to a point in the southern curb line of East' Main Street, aforesaid, at the point and place of BEGINNING. HAVING THEREON ERECTED a brick dwelling and concrete block garage known and as 308 East Main Street, Mechanicsburgh, Pennsylvania. ' Tax Parcel #17-23-0565-238 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. Date: I~I J-/! /a; I I .,M,_ c .."I r III -T~' ) o~_.nlfflWl.l!:~~$'\1Tll1,__, tt :t ~ .lrt. frl ~ "- ~ ~ g & (;\ ~ fIJ I ~ V ~ p?b f -P- . n'^ ~ ,__ ....,..,;.;, '--'I.'. r'<1(; z::;: z'~~ ),: ~ _.c"' ~(~ ];' S;-..' '--..- :~ =< (; ~ - ..- ~-'liirr-m'''' C) () -;1 " "- ]",,,," " 'I' "':'18 '-',' (~ 1/'0 ":'".J V J .~:~ ict~ - ':: Fr~l :~~ :.0 -' ,.-,- I rv Lj ,r::'" '_,1 [5 t:P ~"*._, ,~I!I~j\\!j!1''!'l$",,''"'''-'''--'!''-C.'''Y''{'"'''f'7'F!'F'H!U",''f'i,S.W\~)_'t''.~:W'HIiiNH'i::;:'~~i'~~~~If~~iI!!E._ ")",,\~"^"?;<,~SN,;> .:]'1' SHERIFF'S RETURN - NOT FOUND ~ CASE NO: 2001-00024 P COMMONWEALTH OF PENNSYLVANIA COu~TY OF CUMBERLAND SECRETARY OF VETERANS AFFAIRS VS FERNBAUGH TERESA L 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 FERNBAUGH TERESA L but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT NOTICE , NOT FOUND , as to the within named DEFENDANT , FERNBAUGH TERESA L DEFENDANT MOVED LEFT NO FORWARDING, PAPER EXPIRED PROPERTY VACANT, NO RESPONSE FROM ATTY. Sheriff's Costs: Docketing Service Not Found Return Surcharge 18.00 6.20 5.00 10.00 .00 39.20 ~ So answe . ~.....-- R. ~omas Kline Sheriff of Cumberland ~ /~> County FEDERMAN & PHELAN 02/06/2001 Sworn and subscribed to before me this .... 1.2 '- day of 1~ d+o ( A.D. Qx"!J. tMdl,_~ ~ P t onotary I ",," 11"'1 .~. "'- . \ FEDERMAN AND PHELAN L.L.P. By: Frank Federman, Esquire Identification No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff SECRETARY OF VETERANS AFFAJRS, AN OFFICER OF THE 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 TERESA 1. FERNBAUGR OR OCCUPANTS 308 EAST MAIN STREET MECHANICSBURG, P A 17055 No. 01 -~'f dv~(~~ CTVTT. ACTION - lUFCTMF,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. I , , . , ~i: i TRUE COPY FROMRECORO hi TlItlmonYwl1er8Of. I here unto SIt my hind .., lOt... ~.... ~PL ~~r1. " ..~~ CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 , , 1:"'" , '" ",., , Il "'- . 1. Plaintiff is SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA. 2, Defendant is TERESA L. FERNBAUGH OR OCCUPANTS. 3, Plaintiff is the owner of premises located at 308 EAST MAIN STREET, MECHANICSBURG, P A 17055, 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 ofthe said premises from the said defendant who has refused to deliver up possession of same, WHEREFORE, plaintiff seeks to recover possession of said premises. <- -dt~ FE Attorney for tiff ',_,~ , ,~ ~, ,'",' ~",'l. ,,' '~.. ... ARACOR Search and Abstract Services, Inc. One Penn Center, 1617 J.F.K. Boulevard, Suite 305 Philadelphia. Pennsylvania 19103 (215) 496-0900 FAX (215) 496-0904 RECORD OWNER AND LIEN CERTIFICATE Effective Date: 7/16/99 Order Number: Client Number: A34167 FERNBAUGH Premises: 308 EAST MAIN STREET, BOROUGH OF MECHANICSBURG 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. DESCRIPTION ALL THAT CERTAIN house and lot of ground situate on the South Side of East Main Street, in the Second Ward of the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, more particularly bounded and described according to survey of John C. Brilhart, Registered Surveyor, dated December 5, 1966, as follows, to wit: BEGINNING at a point on the curb line of East Main Street, at corner of lot now of Boyd Fortney and wife, which said point is referenced as North 72 degrees 45 minutes East a distance of one hundred twenty-two and one-tenth (122.1) feet from the center line of South Walnut Street as measured along said curb line; thence extending along said curb line of East Main Street North 72 degrees 45 minutes East, twenty-four (24) feet to a point at corner of lot formerly of Hummell heirs, now of Elizabeth G. Shelly thence along the line of said lot now of Elizabeth G, Shelly, South 17 degrees 15 minutes East, one hundred sixty and eighty one-hundredths (160.80) feet to an iron pin in the northern line of Stouffer Alley; thence along said line of Stouffer Alley, South 72 degrees 45 minutes West, twenty-four (24) feet to a fence post at corner of lot of Boyd Fortney and wife aforesaid; thence along the line of said lot of Boyd Fortney and wife North 17 degrees 15 minutes West, one hundred sixty and eighty one-hundredths (160.80) feet to a point in the southern curb line of East Main Street, aforesaid, at the point and place of BEGINNING, HA VING THEREON ERECTED a brick dwelling and concrete block garage known and as 308 East Main Street, Mechanicsburgh, Pennsylvania. Tax Parcel #17-23-0565-238 . "' ", .- ~ .. ~ ", " 1'-'- , ! ., . ''''''.,jI .. i;' Date: :1 ';C;,",,_ """,,, 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. ~~ca-~~ Attorney for Plaintiff /.J,,-/ }J7 /a; I I .,. ~" ,I.. 1 ",1 ' ',- ~ ,- r I lil '" "," " elYl ,2iiJ ~ ~ ,~ ,L"". ' ',' __ _w ..qIN..q^l),stHf3(\ -:.nsnH'rJ:) \0. ~ptl ca tlt'f ,,Qt~~~~ ~~n"c:l~~., " ' ~~ , ,_ ""'f' ''1'-.'>" '; ,"~ 'f/J~""f''''"~''''~~l~E'~ , ,f!O.,.,....~,,_ .. ~ ~ ~ ~ ~I , "",' "'I'"[I"'.fII' _1'"'- . . ~,.lI~""-..,.""",,,,,, -~,r~' ~fl, ,JJ!:fH'