HomeMy WebLinkAbout12-7525PENN TOWNSHIP, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COiTNTY, PENNSYLVANIA
v. N0.2012 - 7S"',a ~ CIVIL TERM
DAVID S. FETTROW, JR. and CIVIL ACTION - IN EQUITY
DEBORAH L. FETTROW,
Defendants
NOTICE TO DEFEND
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, order and
notice aze 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 aze 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 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 South Bedford Street ~--, ~:,
Carlisle, Pennsylvania 17013 ~ ~-' - ~rv+
(717) 249-3166 ~ ~ °
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1-800-990-9108 ~
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Americans with Disabilities
Act of 1990
The Court of Common Fleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our
office. All arrangements must be made at least 72 hours prior to any hearing or business before the
court. You must attend the scheduled conference or hearing.
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PENN TOWNSHIP,
Plaintiff
v.
DAVID S. FETTROW, JR. and
DEBORAH L. FETTROW,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0.2012 -
CIVIL TERM
CIVIL ACTION -INEQUITY
COMPLAINT IN EOUITY
AND NOW, this 6~' day of December 2012, comes the Plaintiff, PENN TOWNSHIP,
by its solicitors, IRWIN & McKNIGHT, P.C., and makes the following Complaint in Equity
against the Defendants, DAVID S. FETTROW, JR. and DEBORAH L. FETTROW:
1.
The Plaintiff is Penn Township, a second class township located in Cumberland County,
Pennsylvania with its office situate at 1301 Centerville Road, Newville, Pennsylvania 17241.
2.
The Defendants are David S. Fettrow, Jr. and Deborah L. Fettrow who are adult
individuals residing at 237 West King Street, Apartment #1, Shippensburg, Pennsylvania 17257.
3.
The Defendants are the owners of real estate situate at 231 Southside Drive, Newville,
Pennsylvania 17241 in Penn Township, Cumberland County, Pennsylvania.
4.
For a period of years, the Defendants have permitted their property to deteriorate and
have permitted unlicensed motor vehicles, junk, and debris to accumulate on their property.
5.
The Defendants have received numerous letters, visits, and have been cited by Penn
Township in an attempt to have the Defendants clean up their properly.
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6.
The Defendants still have unlicensed vehicles, junk, and debris on their real estate. The
Plaintiff requests that the Court authorize the clean-up of the property of the Defendants within
thirty (30) days or grant Penn Township authorization to clean up the property and sell any
remaining vehicles and junk to pay for the clean-up costs as well as the outstanding legal fees
and costs expended to date by Penn Township in an effort to have the Defendants clean up their
property.
7.
The relief requested by Penn Township is as follows:
A. That the Defendants be ordered to clean up the property within thirty (30) days
From the date of the Court Order;
B. If the Defendants fail to do so, that Penn Township be authorized to clean up the
property and sell any remaining unlicensed vehicles and junk in order to pay for
the clean-up expenses; and
C. That reasonable legal fees and the outstanding clean-up expenses be entered as a
judgment against the real estate.
WHEREFORE, the Plaintiff, Penn Township, requests Your Honorable Court to grant
the relief requested in paragraph seven (7) above.
Respectfully submitted,
IRWIN B~yMCKNI~IT, P.C.
By: Marcu~ A. cKnig6t, I ,Esquire
60 West Po fret Street
Carlisle, Pe lean' 013
(717) 249-2353
Supreme Court I.D. No. 25476
Attorney for plaintiff
Date: December 14, 2012
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VERIFICATION
The foregoing document is based upon information which has been gathered by
counsel and myself . in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
GARY 'I'II~1
Chairman, Penn Township
Date: fZ-Co-/2
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