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Home My WebLink About99-04337t ,t•: FEDERMAN AND PHELAN By: Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 MELLON MORTGAGE COMPANY 3100 TRAVIS STREET HOUSTON, TX 77006 V. ROBERT L. ERB OR OCCUPANT 108 SHOLLY DRIVE MECHANICSBURG, PA 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 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 17055 Attorney for Plaintiff Court of Common Pleas Civil Division CUMBERLAND County Tenn No. jlf ,4/3 3 Cam-' CIVIL ACTION - EJECTMENT - 3020 1. Plaintiff is MELLON MORTGAGE COMPANY. 2. Defendant is ROBERT L. ERB OR OCCUPANT. 3. Plaintiff is the owner of premises located at 108 SHOLLY DRIVE, MECHANICSBURG, PA 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. /7? FIRANK FEDER AN Attorney for Plaintiff / JLL. 25 '95 13:44 FR MMJ-CN-FC713-524-7563713 524 7563 i0 FEDERrjqN,,pHELqN V. lliYL! EXHIBIT A ALL SNIT CERTAIN tract of land situate is Upper Allen Township. Cumberland County, Pennsylvania, being more fully *bounded, limited and described as follows, to wits ¦962NNINC at a point, said point being on the western line of a 50-foot rigbt-of-way for Shelly Drive, at the division line between Lots 26 and 27: thence aleng said GoL 26 North eighty-two (S2) degrees thirty (30) mirtutas west, a distance of two hundred three and twenty-seven hundredths. (203.27) feet to a point at Lot 63 on the plan of Spacious Acres: thence along said toot 63 and Lot 64 on the Plan of Spacious Acres North fifty-Lour (54) degrees nineteen (19) minutes thirty-five (35) seconds Bast a distance of seventy-three and fourteen hundredths (73.14) feet to a polat: thence along said Lot 64 yarth thirty-Cent (34) degr as eighteen (16) minutes forty .(40) seconds East a distance of fifty-sir and six hundredths (56.od) feet to a point at Let F6: thence along said Lot 2a south s'--sty-eight (6s.) degcpes fifty-eight (5a) minutes fifty-throe (53) seconds Bast a distance of one hundred thirty-five and thirty-two hundredths (135_x2) feet to a point on the western lino: of a 50-foot eight-of-way for Shelly Drive: thence along said right-of-way by a curve to the left having an are distance of fity-eight and inecy-nAne hundredths (58.99) foot and a radius of two hundred fifty (250) feet to a 'point: thence along same aouth seven (07) degrees thirty (30) minutes Nest a distance of ton and no hundreths (10.00) feat to a point# the place of BSCINNING. CONTAINING 13,979 square foot. !KING Lot 27 an the plan of Edgewcod, which said Plan is recorded 7 ,in the Office of the Recorder of Coeds in and for Cumberland County, Pennsylvania. in Plan Seek 46, Page 136, November 21, 3964. , J ( PRE141SES: 108 SHOLLY DRIVE MECHARICSBURG. PA 17055 rlb3 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 unswom falsification to authorities. F ank Federman, E quire Attorney for Plaintiff Date: y * F- i =, n 0 CT) SHERIFF'S RETURN - REGULAR CASE NO: 1999-04337 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MELLON MORTGAGE CO VS. ERB ROBERT L SHANNON SUNDAY Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT IN was served upon ERB ROBERT L OR OCCUPANT the defendant, at 9:30 HOURS, on the 2nd day of August 1999 at 2 ANDES DRIVE MECHANICSBURG, PA 17055 CUMBERLAND County, Pennsylvania, by handing to SANDRA ERB (WIFE) a true and attested copy of the NOTICE AND COMPLAINT IN together with EJECTMENT and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 6.82 Affidavit .00 n? ' ' Surcharge 8.00 3F10 L ? 3 eri FEDER MAN PHELAN 08/03/ 1999 by y 4 epu S i X1. L Sworn and subscribed to before me this J..co( day of 1991 A.D. rocnonotar FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 900 TWO PENN CENTER PLAZA Philadelphia, PA 19102 (215) 563-7000 MELLON MORTGAGE COMPANY Plaintiff VS. ROBERT L. ERB OR OCCUPANTS Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-4337 Civil Cumberland County PRAECIPE TO REINSTATE CIVIL ACTION/EJECTMENT TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Ejectment with reference to the above captioned matter. LV-YT UOI'? Frank Federman, Esq ire Attorney for Plaintiff Date: August 11, 1999 wQ c; n¢ L ?i zr,: J rCiE- L 0- c j LIR 'l ws., ? ML ` ya g m U L FEDERMAN AND PHELAN By: Frank Federman, Esquire Atty. I.D. No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 MELLON MORTGAGE COMPANY V. ROBERT L. ERB Or Occupants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County No.99-4337 CIVIL PRAECIPE TO WITHDRAW COMPLAINT AND SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Plaintiff hereby withdraws the complaint filed in this matter. Please mark this case discontinued and ended without prejudice. Date Frank Federman, Esquire Attorney for Plaintiff U.i V. 71 L ? (.J SHERIFF'S RETURN - REGULAR CASE NO: 1999-04337 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MELLON MORTGAGE CO VS. ERB ROBERT L HAROLD WEARY , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon ERB ROBERT L OR OCCUPANT the defendant, at 16:25 HOURS, on the 30th day of AuSust 1999 at 2 ANDES DRIVE MECHANICSBURG, PA 17055 CUMBERLAND County, Pennsylvania, by handing to SONDRA ERB (WIFE) a true and attested copy of the COMPLAINT - EJECTMENT together with NOTICE and at the same time directing Her attention to the contents thereof. Additional Comments: PROPERTY AT: 108 SHOLLY DRIVE, IS VACANT, DEFENDANT WAS SERVED BY HANDING TO WIFE AT CURRENT RESIDENCE. Sheriff's Costs: So answersDocketing 18.00 Service 7.44 Affidavit .00 .? 2 Surcharge 8.00 omas in 5 eri -.qPHELAN by _ :7,f epu y erg Sworn and subscribed befor?j me this t- day of Prui jr 19_ A.D. &It &4jt-sue r ono ary -?