HomeMy WebLinkAbout01-07067
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FEDERMAN AND PHELAN L.L.P.
By: Frank Federman, Esquire
Identification No, 12248
One Penn Center @ Suburban Station, Suite 1400
1617 John F. Kennedy Boulevard
Philadelphia, PA 19103-1814
(215) 563-7000
Attorney for Plaintiff
Manufacturers and Traders Trust Company
One Fountain Plaza
Buffalo, NY 14203
Court of Common Pleas
Civil Division
v.
Cumberland County
Dale L. Cromer
Or Occupants
448 North Pitt Street
Carlisle, PA 17013
Term
No.OI- ~O~7 (!;u~L~~
CTVTT, ACTION - F"TF.CTMFNT - ~/I2/1
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 fmd out where you can get legal help,
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, P A 17013
(717) 249-3166
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1. Plaintiff is Manufacturers and Traders Trust Company.
2, Defendant is Dale L. Cromer Or Occupants,
3.
Plaintiff is the owner of premises located at 448 North Pitt Street, Carlisle, P A 17013
legal description of which is attached,
a
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 fur 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.
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Premises:
448 NORTH PITT STREET, BOROUGH OF CARLISLE
CUMBERLAND COUNTY
PENNSYL V ANlA
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 simate in the Fifth Ward of the Borough of Carlisle,
Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan
thereof made by Gerrit J, Betz, Registered Surveyor, dated September 22, 1971, as follows:
BEGINNING at a point on the West side of North Pitt Street, said point being 108,6 feet South of
the Southwest corner of North Pitt Street and "A" Street; thence along the West side of North Pitt
Street South 10 degrees 30 minutes West 30 feet to a corner of premises now or formerly of Ralph
McKee; thence along said premises and passing through the center of a partition wall North 79
degrees 30 minutes West 165 feet to a point on the East side of a 15 foot alley; thence along said
alley North 10 degrees 30 minutes East 30 feet to a corner of land now or formerly of Charles C.
Yinger; thence along said land South 79 degrees 30 minutes East 165 feet to the point and place of
beginning.
HA VING thereon erected a two story frame dwelling house, known and numbered as 448 North Pitt
Street, Carlisle,
TAX PARCEL #06,20-1798,277,
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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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F Fede an, quire
Attorney for ntiff
Date: /1 /(1 / ~I
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II
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-07067 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MANUFACTURERS AND TRADERS TRUS
VS
CROMER DALE L
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SHAWN HARRISON
Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
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says, the within COMPLAINT - EJECTMENT
was served upon
CROMER DALE L
the
DEFENDANT
, at 0905:00 HOURS, on the 20th day of December, 2001
at 448 NORTH PITT STREET
CARLISLE, PA 17013
by handing to
DALE CROMER
a true and attested copy of COMPLAINT - EJECTMENT
together with
NOTICE
and at the same time directing His attention to the contents thereof.
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Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
3.25
.00
10.00
.00
31.25
So Answers:
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R. Thomas Kline
Sworn and Subscribed to before
12/26/2001
FEDERMAN AND PHELAN
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By:
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