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Home My WebLink About04-3421Johnson, Duffle, Stewart & Weidner By: Wade D. Manley I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff DENNIS W. CHAMBERS Plaintiff JEFFREY D. POLLAK POLLAK, his wife, and Defendants JOANNE : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW COMPLAINT IN EJECTMENT NOTICE TO DEFEND To the Defendant: 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 twenty (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 defense 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 any 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 Bar Association 32 S. Bedford Street Carlisle, PA 17013 717-249-3166 Johnson, Duffle, Stewart & Weidner By: Wade D. Manley I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff DENNIS W. CHAMBERS Plaintiff JEFFREY D. POLLAK POLLAK, his wife, a~ JOANNE Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW COMPLAINT IN EJECTMENT COMPLAINT 1. The Plaintiff, Dem~is Chambers, is an individual residing at 45 Kermer Drive, Marysville, Pennsylvania 17053. 2. The Defendants, Jeffrey D. and Joanne Pollak, are individuals residing at 424 East Winding Hill Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 ("the premises" more fully described in the legal description attached hereto as Exhibit "A" and made a part hereof by reference). 3. The Plaintiff is the owner of the premises acquired pursuant to a Sheriff's Deed after purchase at a Sheriff's Sale conducted on June 9, 2004. 4. The Defendants have no valid legal right to possession or title to the premises. 5. The Plaintiffclaims the right to possession of the premises to the exclusion of the Defendants. 6. The Defendants have willfully remained in possession of the Plaintiff's property and still refuse to vacate the premises and still occupy the same after notice thereof to vacate was given to the~. VERIFICATION I, Dennis W. Chambers, the Plaintiff named in the foregoing Complaint, have knowledge of the facts set forth in the foregoing and that said facts are tree and correct to the best of my knowledge, information and belief. I understand that false statements made h~rein are subject to the penalties of 18 Pa.C.S. {}4904 relating to unswom falsification author/ties. Dated: :232082 11251-5 WHEREFORE, the Plaintiff prays for possession of the premises known and numbered as 424 East Winding Hill Road, Mechanicsburg, Cumberland County, Pennsylvania 17055, more fully described in Exhibit "A" attached hereto and made a part hereof by reference. :232082 11251-5 Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Plaintiff x SHERIFF'S RETURN - REGULAR CASE NO: 2004-03421 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHAMBERS DENNIS W VS POLLAK JEFFREY D ET AL SHAWN HARRISON , Cumberland County, Pennsylvania, says, the within COMPLAINT - EJECTMENT POLLAK JEFFREY D DEFENDANT , at 1952:00 HOURS, at 424 EAST WINDING HILL ROAD MECH3kNICSBURG, PA 17055 JOANNE POLLAK, WIFE a true and attested copy of COMPLAINT Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 19th day of July , 2004 by handing to - EJECTMENT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18 Service 8 Affidavit Surcharge 10 36 00 88 00 00 00 88 Sworn and Subscribed to before me this f ~ day of ro ~ ~ A.D. thonotar!~ So Answers: R. Thomas Kline 07/20/2004 JOHNSON DUFFIE STEWART WEIDNER rif SHERIFF'S RETURN - REGULAR CASE NO: 2004-03421 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHAMBERS DENNIS W VS POLLAK JEFFREY D ET AL SHAWN HARRISON , Cumberland County, Pennsylvania, says, the within COMPLAINT - EJECTMENT POLLAK JOANNE DEFENDANT , at 1952:00 HOURS, at 424 EAST WINDING HILL ROAD MECHANICSBURG, PA 17055 JOANNE POLLAK a true and attested copy of COMPLAINT Sheriff or Deputy Sheriff of who being duly sworn according was served upon on the 19th day of July by handing to to law, the , 2004 - EJECTMENT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ~ day of J~ { A.D. ' / Prothonotary So Answers: R. Thomas Kline 07/20/2004 JOHNSON DUFFIE STEWART WEIDNER ~ohnson, Duffle, Stewart & Weidner By: Wade D. Manlcy I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff DENNIS W, CHAMBERS, : : Plaintiff : : V. : JEFFREY D. POLLAK and JOANNE POLLAK, : his wife, : : Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-03421 CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Please withdraw the Complaint filed in the above-captioned matter. :234057 11251-5 Respectfully submitted, JOHNSON, DUFFLE, STEWART & WEIDNER Wade D. Manley~ Attorney I.D. No. 872~4 301 Market Street "-.-/ P.O, Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Plaintiff ,CERTIFICATE OF SERVlCF AND NOW, this f ~'~'day of August, 2004, the undersigned does hereby certify that she did this date serve a copy of the foregoing PRAECIPE upon the other parties of record by causing same to be deposited ir the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Jeffrey D. and Joanne Pollak 424 East Winding Hill Road Mechanicsburg, PA 17055 JOHNSON, DUFFLE, ST~WA.R~T & WEIDNER 'Car)e.en S. Jensen ~.~