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HomeMy WebLinkAbout99-06188 x? x yk? { `Y v' f d t x k? 4 o ? s *s r ( A 12t ^iVt e tJl'i' h ?Q ? a x r L?l ilt ? # A N" 5 Sz y j, $ ? n y 4 r? x QL b}j P NN tr a s f h?a?Sy t .?lU 5- f ? j s A 'rY 'f t O ? ? 4 S A 4 4 e "' fix'" ,f {f'i 1 n y iyt t, w ? T 4 n:. - - - - ----------- QA1 vl? t ,a ON V, lS. C :.3 t L, AXT J gi . pp FEDERMAN AND PHELAN By: Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA, VARO CLEVELAND (MDP 263 PHI) P.O. BOX 99640 CLEVELAND, OH 44199 V. PAUL PEFFER OR OCCUPANTS 413 PITT STREET ENOLA, PA 17025 Attorney for Plaintiff Court of Common Pleas Civil Division CUMBERLAND County Term /• No. R / `` &19 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 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1. Plaintiff is SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA, VARO CLEVELAND (MDP 263 PHI) . 2. Defendant is PAUL PEFFER OR OCCUPANTS. 3. Plaintiff is the owner of premises located at 413 PITT STREET, ENOLA, PA 17025, 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 d efendant who has refused to deliver up possession of same. WHEREFORE, plaintiff seeks to recover possession of said premises. FRANK FEDERMAN Attorney for Plaintiff ALL THAT CERTAIN tract of land situate in the Township of East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described according to a survey of D. P. Raffensperger, Registered Surveyor, dated March 29, 1960, as follows: BEGINNING at a point on the southerly line of Lafayette Street 150 feet westwardly of the southwesterly comer of Lafayette Street and Givler Avenue, also being at the dividing line between Lots Nos. 3 and 4, Block "F", on hereinafter mentioned Plan of Lots; thence southwardly 150 feet to a point on the northerly line of Pitt Street extended; thence extending South 79 degrees 00 minutes West along same 50 feet to a point at the dividing line between Lots Nos. 4 and 5, Block "F" on said Plan; thence extending North 11 degrees 00 minutes West along same 150 feet to a point on the southerly line of Lafayette Street; thence extending eastwardly along same 50 feet to a point, the place of BEGINNING. BEING Lot No. 4, Block "F" on Plan of Enola Terrace recorded in Plan Book 1, Page 3 and being known and numbered as 413 Pitt Street (extended). TAX PARCEL NUMBER: 09-14-0834-045 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 gcctment 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 unworn falsification to authorities. Date: Flan P k Federman, Esquire FEDERMAN AND PHELAN By: Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA, VARO CLEVELAND (MDP 263 PHI) P.O. BOX 99640 CLEVELAND, OH 44199 V. PAUL PEFFER OR OCCUPANTS 413 PITT STREET ENOLA, PA 17025 Attorney for Plaintiff Court of Common Pleas Civil Division CUMBERLAND County Term No. 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 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FEDERMAN AND PHELAN ATTORNEY FILE COPY PLEASE RETURN 1. Plaintiff is SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA, VARO CLEVELAND (MDP 263 PHI) . 2. Defendant is PAUL PEFFER OR OCCUPANTS. 3. Plaintiff is the owner of premises located at 413 PITT STREET, ENOLA, PA 17025, 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. FI?iANK FED Attorney for Plaintiff AND PHELAN MVEY FILE COPY VLEF,SERETURN : . .r' i ALL THAT CERTAIN tract of land situate in the Township of East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described according to a survey of D. P. Raffensperger, Registered Surveyor, dated March 29, 1960, as follows: BEGINNING at a point on the southerly line of Lafayette Street 150 feet westwardly of the southwesterly comer of Lafayette Street and Givler Avenue, also being at the dividing line between Lou Nos. 3 and 4, Block "F", on hereinafter mentioned Plan of Lots; thence southwardly 150 feet to a point on the northerly line of Pitt Street extended; thence extending South 79 degrees 00 minutes West along same 50 feet to a point at the dividing line between Lots Nos. 4 and 5, Block OF on said Plan; thence extending North 11 degrees 00 minutes Wesi along same 150 feet to a point on the southerly line of Lafayette Street; thence extending eastwardly along same 50 feet to a point, the place of BEGINNING. BEING Lot No. 4, Block "F" on Plan of Enola Terrace recorded in Plan Book 1, Page 3 and being known and numbered as 413 Pitt Street (extended). TAX PARCEL NUMBER: 09-14-0834-045 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. ?he undersigned understands that this statement is made subject to the penalties of 18 Pa, C. S. Sec 4904 relating to unworn falsification to authorities. Funk Federman, Esquire Date: M ? ?' ? .?'.: Y ?? i 4 tl ? ni i v 1 R. i 1? ?..? e J?? t *y?x I k`,i SHERIFF'S RETURN - NOT FOUND CASt- NO: 1999-06188 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SECRETARY OF VETERANS AFFAIRS VS. PEFFER PAUL R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: PEFFER PAUL but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT NnTTrP. NOT FOUND as to the within named defendant PEFFER PAUL DEFT. NO LONGER RESIDES AT ADDRESS STATED: IS BELEIVED TO BE AT: 2311 VAN NESS AVE, NAT. CITY CA Sheriff's Costs: So answe s: f i Docketing 18.00 Service 9.92 NOT FOUND RETURN 5.00 _..r" Surcharge 8.00 I? $? 10/19 MAN 1999 PHELAN Sworn and subscribed to before me this day of 19_? A.D. FEDERMAN AND PHELAN By: Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA, VARO CLEVELAND (MDP 263 PHI) P.O. BOX 99640 CLEVELAND, OH 44199 V. PAUL PEFFER OR OCCUPANTS 413 PITT STREET ENOLA, PA 17025 Attorney for Plaintiff Court of Common Pleas Civil Division CUMBERLAND County Term No. ew - ZO/ Iff 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 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 TRUE DOPY FROM REOORD In TtaaWW whereof, I here umo sat MY hard d t of,?I al rllA, Pa. 1. Plaintiff is SECRETARY OF VETERANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA, VARO CLEVELAND (MDP 263 PHI) . 2. Defendant is PAUL PEFFER OR OCCUPANTS. 3. Plaintiff is the owner of premises located at 413 PITT STREET, ENOLA, PA 17025, 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. Ne ?A FRANK FEDERMAN Attorney for Plaintiff ALL THAT CERTAIN tract of land situate in the Township of East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described according to a survey of D. P. Raffensperger, Registered Surveyor, dated March 29, 1960, as follows: BEGINNING at a point on the southerly line of Lafayette Street 150 feet westwardly of the southwesterly comer of Lafayette Street and Givler Avenue, also being at the dividing line between Lots Nos. 3 and 4, Block "F", on hereinafter mentioned Plan of Lots; thence southwardly 150 feet to a point on the northerly line of Pitt Street extended; thence extending South 79 degrees 00 minutes West along same 50 feet to a point at the dividing line between Lots Nos. 4 and 5, Block "F" on said Plan; thence extending North 11 degrees 00 minutes West along same 150 feet to a point on the southerly line of Lafayette Street; thence extending eastwardly along same 50 feet to a point, the place of BEGINNING. BEING Lot No. 4, Block "F" on Plan of Enola Terrace recorded in Plan Book 1, Page 3 and being known and numbered as 413 Pitt Street (extended). TAX PARCEL NUMBER: 09-14-0834-045 VERtIFTCATION 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 unworn falsification to authorities. Date: -nk 7? F Federman, tEsquire M 4 -.1 r-` OfffCE OF TH° S KERtFF ? ?t Ia4aA9'99 ' PENNSYL`IA111A