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Home My WebLink About01-7067FEDERMAN 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 (21S) S63-7000 Attorney for Plaintiff Manufacturers and Traders Trust Company One Fountain Plaza Buffalo, NY 14203 Vo Dale L. Cromer Or Occupants : 448 North Pitt Street Carlisle, PA 17013 : Court of Common Pleas Civil Division Cumberland County Term No. "lot,.7 CMl, ACTION = E.11E~CTMENT = 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. Plaintiffis Manufacturers and Traders Trust Company. 2. Defendant is Dale L. Cromer Or Occupants. Plaintiffis the owner of premises located at 448 North Pitt Street, Carlisle, PA 17013 legal description of which is attached. 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). 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 plaintiffis informed, without claim of title. 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. Premises: 448 NORTH PITT STREET, BOROUGH OF CARLISLE 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 lot or piece of land situate 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 comer 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 comer 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 comer 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. HAVING thereon erected a two story frame dwelling house, known and numbered as 448 North Pitt Street, Carlisle. TAX PARCEL #06-20-1798-277. 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 tree 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. Date: [. ~ reaelInan,~l~qmre VAttorney for~atari~ti ff SHERIFF'S RETURN - CASE NO: 2001-07067 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS AND TRADERS TRUS VS CROMER DALE L REGULAR SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to says, the within COMPLAINT - EJECTMENT was served upon CROMER DALE L the DEFENDANT at 0905:00 HOURS, on the 20th day of December at 448 NORTH PITT STREET 2001 CARLISLE, PA 17013 DALE CROMER a true and attested NOTICE copy of COMPLAINT by handing to - EJECTMENT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.25 Affidavit .00 Surcharge 10.00 .00 31.25 Sworn and Subscribed to before me this ~ day of ~ ,~ ~-~ A.D. IP~othonota~y ~ ~ So Answers: R. Thomas Kline 12/26/2001 FEDERMAN AND PHELAN By:, ,/~~