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HomeMy WebLinkAbout02-0189 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 Secretary of Veterans Affairs, an Officer of The United States of America Varo Cleveland (MDP 263 Pill) P.O. Box 99640 Cleveland, OR 44199 Court of Common Pleas Civil Division v. Cumberland County Term Robert D. Smith Or Occupants 8 Walnut Lane CampRill,PA 17011 No. 0;;' - If? Ct"u~C/~ (,lVll, AC.TION - F..rn.C.TMF.NT .1020 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 LffiERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1. Plaintiff is Secretary of V eterans Affairs, an Officer of The United States of America. 2. Defendant is Robert D. Smith Or Occupants. 3. Plaintiff is the owner of premises located at 8 Walnut Lane, Camp Hill, P A 17011 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. Premises: 8 WALNUT LANE, TOWNSHIP OF LOWER ALLEN 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 THA T CERTAIN house and lot of ground situate in the Township of Lower Allen. County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Northern line of Walnut Lane, (50 feet wide). at the dividing line between Lots Nos. 7 and 8, Block "F', on the hereinafter mentioned Plan of Lots; thence along Lot No.7, Block "F", on said plan, North 31 degrees 39 minutes West, a distance of 85.00 feet to a point; thence North 48 degrees 15 minutes East, a distance of 72.27 feet to a point on the line of Walnut Circle; thence along Walnut Circle by a curve to the right having a radius of 30.3 feet, a distance of 35.87 feet to a point; thence by the same South 31 degrees 39 minutes East, a distance of 44.55 feet to a point of a curve; thence by a curve to the right having a radius of 25.0 feet, a distance of 39.27 feet to a point on the Northern line of Walnut Lane, 50 feet wide, aforesaid; thence by the same, South 58 degrees 21 minutes West, a distance of 65.00 feet to a point, the place of beginning. BEING Lot No.8, Block "F", on the Plan of Lots of Cumberland Park, which said Plan is recorded in the Cumberland County Recorder's Office in Plan Book No.5, at page 22. HA VING thereon erected a single family dwelling house known and numbered as 8 Walnut Lane, Camp Hill, Pennsylvania. BEING Tax Parcel # 13-24-797-41. 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. ~ F Fede , Es 're Attorney for . Iff Date: /1 ~ / -;Ja?;}- . . (:) ..fIJ .tq ~ '1. ~ ~ fGJ h D () 0 C r'0 " 8 g (g $: L.. ../ ...... :t V(;-; ~,:-- " mp, ;;1:: y..; Z=C-i ~ J 655, '-:, 0 I "."'1 .1:"' .o":;(~: -<L. " "'-J r ~ ~C~j l) ~JK ~ >(-) - 2(-, .5> -) W ;::~;Jlj C '.,_.... ~ .-{ ::z (.) )'."> :<! :.0 .j':"" -< . PHELAN HALLINAN & SCHMIEG, LLP BY: FRANCIS S. HALLINAN, ESQUIRE Identification No. 62695 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Secretary of Veterans Affairs, USA ATTORNEY FOR PLAINTIFF Court of Common Pleas Plaintiff Civil Division vs. Cumberland County Robert D. Smith Defendant( s) No. 02-189 PRAECIPE TO THE PROTHONOTARY: X Please mark the above referenced case Discontinued and Ended without prejudice. _Please mark the above referenced case Settled, Discontinued and Ended. Please mark Judgments satisfied and the Action settled, discontinued and ended. Please Vacate the judgment entered and mark the action discontinued and ended without prejudice. Please withdraw the complaint and mark the action discontinued and ended without prejudice. Date:~ ~ cUJ YUJJ. . Francis S. Hallinan, Esquire Attorney for Plaintiff n f: ~ = e:.:;1 .c.J'\ el) n'\ ~.; 1" 0" ~ ::$ o -n -' -::c -r\ h'r~ -"CD. :()'-( '~:21(;;), ~S~;~ ;.~"\.rn ~\ ::;; ::< f..:.') -