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HomeMy WebLinkAbout01-0026 FX FEDERMAN AND PHELAN L.L.P. By: Frank Federman, Esquire Identification No. 12248 One Penn Center at Suburban Station 1617 JohnF, Kennedy Boulevard, 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff SECRETARY OF VETERANS AFFAlRS, AN OFFICER OF TIIE 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 MICHAEL A. BOYER, SR. OR OCCUPANTS 902 HUMMEL AVENUE LEMOYNE, PA 17043 No. Of - .:21::, C,U.'(, '-r~ CTVrr, ACTION - R.TRCTMF.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 LffiERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ,""~~- " I ., , I~ r"l ~,'~ > '1 1. Plaintiff is SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA. 2. Defendant is MICHAEL A. BOYER, SR. OR OCCUPANTS. 3, Plaintiff is the owner of premises located at 902 HUMMEL AVENUE, LEMOYNE, P A 17043, 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. a:r~~ ',',' >-'''- , I~ I~'; "I . ALL THAT CERTAIN piece or parcel of land situate in the Borough of Lemoyne, County of Cumberland and State of Pennsylvania, more particularly pounded and described as follows, to wit: BEGINNING at a point on the southwest corner of Hummel Avenue and Ninth Street, formerly Armstrong Street, and extending in a southerly direction along the west side of Ninth Street, one hundred forty-eight and ninety-five one hundredths (~48.95) feet, more or less, to a point on the north side of a fifteen (15) feet wide alley; thence in a westerly direction along the north side of side fifteen (15) feet wide alley, sixty-one and eighty-seven one hundredths (61.87) feet to a point; thence in a northerly direction by a line at right angles to the north side of said fifteen (15) feet wide alley one hundred forty-two and one-tenth (142.1) feet, more or less, to a point on the south side of Hummel Avenue, thence in an easterly direction along the south side of Hummel Avenue, sixteen and six-tenths (16.6) feet toa point on the west side of Ninth Street and the place of BEGINNING. HAVING THEREON erected"a three story frame dwelling building known as Nq. 902 Hummel Avenue, Lemoyne, Pennsylvania. BEING THE SAME PREMISES which Kenneth B. Kramer and Amy E. Kramer, his wife, by their deed dated August 23, 1991 and recorded August 29, 1991 in the office of the Recorder of Deeds for Cumberland County in Deed Book H, Volume 35, Page 142 granted and conveyed to Jeri A. Donadee and Debra K. Donadee, his wife. . Y'fiB1-CClfR7) ^MERICAN LAND TITLE MSOCIA liON COMMITMENT .1992 ,......: / . \ Date: ,~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. (.)-- / J-'1 / to / I ""'," 1'1 ' " . "' E5 ~p -" "', ,44r_ ",~,~,~ I'~ '.- "'.'^ "~-~ ,~, "-- ~ -, ,~, - . J ~ ~ ~ olq ~ 0 C) CJ (;) n h c: -on () ~~ \,- "4 -r~ .-,-', :,(:;1," ~':~ ::"J 8 '-'(d ~ ;:::; fI) !;'-i ~.{: "/"'" vv C> 2~:;'" , ",--:,"n .",,-,U_' CI} [''0 ':"?rS ~ , -, ~ ( [~.:: -~') ~;:" ~ ~ j',~ ,~, ...;) t~,j -"'" ,;;C:: '0 If' (....1 >: rn ,-' Z ~ 'J1 ~> ,-{ :0 ~ -<. ....) -< ~,.,~~w~: "",~_,~,"'~~~~*'j'l>'!"N'''''''.i'1{!~"""qf.''-PP'jW''''~Wj""'i!'\'ffl'1!1l'i!"~'r~m*w'''<t!''''''T''ii-<f~~~~~JlI~I;~iij! I -"; SHERIFF'S RETURN - NOT FOUND .... CASE NO: 2001-00026 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VETERANS AFFAIRS SECRETARY OF VS BOYER MICHAEL A SR 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 BOYER MICHAEL A SR but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT NOTICE , NOT FOUND , as to the within named DEFENDANT , BOYER MICHAEL A SR RESIDENCE AT ADDRESS STATED IS VACANT, RETURN NOT FOUND AS PER JOE GARDENO ON 1/8/01 Sheriff's Costs: Docketing Service Not Found Return Surcharge 18.00 9.92 5.00 10.00 .00 42.92 ~ So a~sw :, ".,,- ~ R. Thomas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 01/08/2001 Sworn and subscribed to before me this II 18, day of Q.u" h'J c20.01 A.D. ~C_ >n,/~.. ~ Pr t onotary /' h , , II ~ ~~ f. , , 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 Court of Common Pleas Civil Division v, CUMBERLAND County Term MICHAEL A. BOYER, SR. OR OCCUPANTS 902 HUMMEL AVENUE LEMOYNE,PA 17043 No. 0 I - ~b. au~l't-~ CTVrr, ACTION - F.T1f.c:TMFNT - 1020 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 TRUE COpy FROM RECORD hi TllIStlmony wberOOf, I here unto set my hand aid ttle ~of said Coo~," ........ ... , ~fV>~~ ~~ , ry ,,,," '. 0 ~ "". ..~. - ~ " . . . 1. Plaintiff is SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERlCA. 2. Defendant is MICHAEL A. BOYER, SR. OR OCCUPANTS. 3. Plaintiff is the owner of premises located at 902 HUMMEL AVENUE, LEMOYNE, P A 17043, 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. ~~ -,,; ~ - " - " , ~* . , , ALL THAT CERTAIN piece or parcel of land situate in the Borough of Lemoyne, County of Cumberland and State of Pennsylvania, more particularly pounded and described as follows, to wit: BEGINNING at a point on the southwest corner of Hummel Avenue and Ninth Street, formerly Armstrong Street, and extending in a southerly direction along the west side of Ninth Street, one hundred forty-eight and ninety-five one hundredths (148.95) feet, more or less, to a point on the north side of a fifteen (15) feet wide alley; thence in a westerly direction along the north side of side fifteen (15) feet wide alley, sixty-one and eighty-seven one hundredths (61.87) feet to a point; thence in a northerly direction by a line at right angles to the north side of said fifteen (IS) feet wide alley one hundred forty-two and one-tenth (142.1) feet, more or less, to a point on the south side of Hummel Avenue, thence in an easterly direction along the south side of Hummel Avenue, sixteen and six-tenths (16.6) feet to a point on the west side of Ninth Street and the place of BEGINNING. HAVING THEREON erected'a three story frame dwelling building known as Nq. 902 Hummel Avenue, Lemoyne, Pennsylvania. BEING THE SAME PREMISES which Kenneth B. Kramer and Amy E. Kramer, his wife, by their deed dated August 23, 1991 and recorded August 29, 1991 in the office of the Recorder of Deeds for Cumberland County in Deed Book H, Volume 35, Page 142 granted and conveyed to Jeri A. Donadee and Debra K. Donadee, his wife. . r.fiA7.C(I/R7) AMERIC^N LAND TITLE MSOCIA TlON COMMITMEN r .1992 ,...". / -, - . . . " 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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