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HomeMy WebLinkAbout00-01223 u., i ~ __eo_ ~ CUMBERLAND COUNTY HOUSING AUTHORITY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. 1'J.'d.3- 2000 CIVIL TERM v : CIVIL ACTION - LAW FLORENCE P. RODGERS BETTY L. STANTON AND, HEIRS AND ASSIGNS OF WILLIAM P. STANTON, : ACTION IN QUIET TITLE Defendants 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 twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by an 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 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 Two Liberty Avenue Carlisle, PA 17013 717 - 249-3166 , CUMBERLAND COUNTY HOUSING AUTHORITY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. iW-P.lJ 2000 CIVIL TERM v : CIVIL ACTION - LAW FLORENCE P. RODGERS BETTY L. STANTON AND, HEIRS AND ASSIGNS OF WILLIAM P. STANTON, : ACTION IN QUIET TITLE Defendants COMPLAINT AND NOW, comes the Plaintiff, by and through its attorney, Christopher C. Houston, Esquire, who avers as follows: 1 The Plaintiff is the Cumberland County Housing Authority, of 114 North Hanover Street, Carlisle, Cumberland County, Pennsylvania. 2 Defendant Florence P. Rodgers is an adult individual currently residing at 217 N. West St., Carlisle, Cumberland County, Pennsylvania. 3 Defendant Betty L. Stanton is an adult individual currently residing at 154 W. North St., Carlisle, Cumberland County, Pennsylvania. 4 Defendants heirs and assigns of William P. Stanton, other than other named ~~ Defendants herein, are unknown and the whereabout unknown. 5 William P. Stanton acquired title to real property known as 161 West Locust Avenue, Carlisle, Cumberland County, Pennsylvania (the "Premises"), by deed dated June 14, 1977, and recorded June 18,1977, in Deed Book Q, Volume 25, Page 983, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, which is more particularly described as follows: All that certain tract of land with the improvements thereon erected located in the Fourth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly described as follows, to wit: On the north by property now or formerly of Susan Hipple; on the East by an alley; on the West by property of Troy Laundry, formerly of Blake Bysel; and on the South by Locust Alley. This property is also known as No. 161 West Locust Avenue, Carlisle, Pennsylvania. Containing 21 feet, more or less, in front along Locust Alley and extending in depth 52 feet, more or less. 6 On or about June 15, 1999, William P. Stanton died, intestate, with an estate being opened in the Register of Wills of Cumberland County at file number 99-573, naming Defendant Betty L. Stanton as Administratrix. 7 The Cumberland Count Tax Claim Bureau, pursuant to a Petition for Judicial Sale filed in the Court of Common Pleas of Cumberland County, Pennsylvania, at 1999-02962, did obtain an Order of Court dated August 1 2, 1999 ordering that the Premises be sold at public sale. l' I' 1"-"' 8 The Plaintiff did purchase the Premises at public sale on September 24, 1999. 9 The Tax Claim Bureau of the County of Cumberland, Pennsylvania, as Trustee did convey by Tax Claim Bureau deed dated December 3, 1999, the Premises to the Cumberland County Housing Authority, with said deed recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 212, Page 659. 10 By Order of Court dated January 19, 2000, the Court did confirm the judicial sale in response to the Tax Claim Bureau's Petition for Confirmation of the sale, with said Order to be made final, if no exceptions are taken within thirty (30) of the date of said Order. 1 1 No exceptions have been filed to the Confirmation of sale Order, within said thirty (30) day time period. 12 The Plaintiff seeks confirmation of the validity of the deed conveying the Premises to the Plaintiff and to further confirm possession of the land sold at judicial sale, pursuant to Pa.R.C.P. 1061 (3) and (4). . .~ 1- "" r~-' . . " WHEREFORE, Plaintiff requests this Honorable Court to enter an Order declaring that the Defendants are barred from asserting any right, lien, title, or interest in the Premises, to confirm the validity of the deed from the Tax Claim Bureau to Plaintiff dated December 3, 1999, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 212, Page 659, and to grant possession of the Premises to Plaintiff. Christopher C. ouston, Esquire Attorney for Plaintiff CUMBERLAND COUNTY HOUSING AUTHORITY 114 North Hanover Street Carlisle, PA 17013 717-249-0789 :-"1 ~ ~ - , : -,,",'1, . . I verify that the statements in the foregoing pleading are true and correct. understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. CUMBERLAND COUNTY HOUSING AUTHORITY By u!;L~ . . .' .." " , '..-',--',-,.'- - ~-- , o 7:>F t\:c'tt- ~ -/=:. <;' (:; ...0 IV - (]I Gt ~. Vi (J) \) ~ j (") ~ ~~}j -7'"-. (,~; ,',~~ c=b ...> ,.!-~.>- :-., ~t--'J J> ,~~~ ~ a o o --n , . E~ IT ~)1'r"flf~"__Ff!W-""Hlll"'.'lmf~I'OfflI~ f!ll'!llF _ T~.rf[m."'I'f!liW~!l!li.:!.:r, ,_~ ~__~ ::!: J;.'la- ;7.3 I C,.) :::--.1 f~lfQ -("lIT! ~(iCJ g(~) ~!~ :lJ ~_J_~", ;<~rn _J :!{} :JJ -< :;':".:.0 o ::> tD i_ ___ ,__" ---If v tAAR 0 1 2000 fYJ CUMBERLAND COUNTY HOUSING AUTHORITY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. ) ~ 1. 3 - 2000 CIVIL TERM v : CIVIL ACTION - LAW FLORENCE P. RODGERS BETTY L. STANTON AND, HEIRS AND ASSIGNS OF WILLIAM P. STANTON, : ACTION IN QUIET TITLE Defendants ORDER OF COURT AND NOW, this 1"'" day of tIL~ , 2000,. upon a MOTION FOR SPECIAL ORDER FOR SERVICE BY PUBLICATION PURSUANT TO P.A. R.C.P. 430 , it is hereby ordered and directed that the Plaintiff shall be authorized to make service upon the persons named in the motion, by publication once in the Cumberland Law Journal and in The Sentinel. Service shall be complete upon the publication in the _:.pl~ JK ?/~~~ J. second of the two publications. ".~, ,. ll9Ill_IiII:'~lili . --"'~-. .~ "'." T""""'" IIiIMlIIII. '. . FILED-<iFFIOE ., OF THE PROTHONOTARY 00 MAR -8 AM B:I 5 CUMBERU\ND COUN'/Y PENNSYLVANIA CUMBERLAND COUNTY HOUSING AUTHORITY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. I 1, ~ ~ ~ 2000 CIVIL TERM : CIVIL ACTION - LAW FLORENCE P. RODGERS BETTY L. STANTON AND, HEIRS AND ASSIGNS OF WILLIAM P. STANTON, : ACTION IN QUIET TITLE Defendants MOTION FOR SPECIAL ORDER FOR SERVICE BY PUBLICATION PURSUANT TO P.A. R.C.P. 430 AND NOW, comes the Plaintiff, Cumberland County Housing Authority, by its attorney, Christopher C. Houston, Esquire, who represents as follows: 1 The Petitioner is the Cumberland County Housing Authority, the above-captioned Plaintiff . 2 Simultaneously with the filing of this Petition, the Plaintiff has filed a Complaint setting forth an action in Quiet Title for the premises located at 161 West Locust Avenue, Carlisle, Cumberland County, Pennsylvania. 3 The Plaintiff is the record owner of the Premises pursuant to a Tax Claim Bureau deed dated December 3, 1999, and recorded in the Office of the Recorder of Deeds in and !'-. ~ T'~- ~ .. for Cumberland County, Pennsylvania, in Deed Book 212, Page 659. 4 The prior record owner of the premises, as per the office of the Recorder of Deeds, was William P. Stanton (the "Decedent"), who died intestate on June 5, 1999. 5 An estate was opened in the office of the Register of Wills of Cumberland County at 99-573, with Letters of Administration issued to Betty L. Stanton. 6 The estate file indicates that the sole surviving heirs of the Decedent are the named Defendants, Florence P. Rodgers and Betty L. Stanton. 7 Betty L. Stanton did execute a release dated October 19, 1999, a copy of which is attached hereto and marked as Exhibit "A", setting forth an affirmation that she was authorized to receive the Decedent's personal effects which were located in the Premises. 8 Plaintiff's investigation cannot confirm that the said Florence P. Rodgers and Betty L. Stanton are in fact the sole surviving heirs, successors, and/or assigns of William P. Stanton, but that, based on the estate file and the release attached hereto, Florence P. Rodgers and Betty L. Stanton may be the sole surviving heirs, successors, and lor ':"" ,~, "T' assigns. 9 Service of the Complaint by personal service will be obtained upon Florence P. Rodgers and Betty L. Stanton. WHEREFORE, the Petitioner requests this Honorable Court to enter an order under PA RCP 430 permitting service upon the heirs and assigns of William P. Stanton, other than Florence P. Rodgers and Betty L. Stanton, by publication, with the notice for publication to be in the form attached hereto. Respectfully submitted, ~ Christopher C. Houston, Esquire Attorney for Plaintiff/Petitioner CUMBERLAND COUNTY HOUSING AUTHORITY 114 North Hanover Street Carlisle, PA 17013 717-249-0789 ^'!~ ,~.. I~'- 10/18/99 14:45 FAX 717 2416970 Chr1s Houston 14102 . -- RELEASE I, _&t~ (")tAntlin , of 1':;1-/ (Je"j /I1ir-l f... i?&eet} CAt" J I:') le~ I}J. have rllQUe the Cumberland County Redevelopment AuthoritY (the "AuthoritY") to obtain access to the premises located at 161 West Locust Avenue, Carlisle, Cumberland County, Pennsvlvania Ithe "Real Property"1. for purposes of retrieval of personal property therefrom belonging to the late William P. Stanton (the "Deceased"). The undersigned does hereby affirm and acknOwledge that she is authori;roo to receive said porsonaJ property of the DecesNd and that she will provide the Redevelopment Authority of Cumberland County with an inventory of the items of personal property removed from the aforesaid real property. NOW, THEREFORE, with the intent to be legelly bound, and in consideration of the authorization given by the Authority to the undersigned, on behalf of herself, her heirs, executors, administrators, assigns, and the Estate of William P. Stanton (the "Estate"), does hereby release the Authority, its successors and assigns, from all rights, claims, and actions which the undersigned and her above-mentioned heirs, successors, assigns, and the Estate now have or may hereafter have against the Authority and its above-referenced successors and aasigns arising out of the entry into the Real Property and the removal therefrom of the persollal property therein. It is agreed and understood that the undersigned will provide an inventory, as aforesaid, to the Authority and shall only enter into the Reill Property upon the advance permission and direction of the Authority. "f\- IN WITNESS WHEREOF. the undersigned does hereby set forth her hand and seal this l.L.. day of October, 1999. i., 'J v-' l-t'n e ~c:.5 _JA1J:J:Nrss:.... ~- o Utl , S ~ ~-' t,>-y> ;fif &> i:rL EXHIBIT "A" ~~ , 'W. ~'-;"'" - ---- "l'<",' C, ~ ,.: -_~ - - '",. - -C" , _ '~"I H ;~"",' '-",..~-'-;, ~.~-~. ,. !"~~<,-.,, . . 4'i'"' d' _______'_.T_teft'~__toL~LfluL>>._.Lb.LCae:':>t . b,.;ClA<;'( J1.Jen.....e. / CI9,- (':;,/e.._ P(<)f-&-~ bo-_i3_e.~.5.-bI7.')fv"'_-D-JCLn~i(JbeL 19, j (j 99 . __ __ - _~_ ~______ . ___0_- _____.__. ____ . .n,nU_ d__-j~lve,/ btlf/'JI ,_._._,. .____.__plq ~.~____: _ ' "" .,..._' n' 'nn_ .,." n _ U ..-Y-Af-t~f~~-_=---~------ -- ,( / JU (J......o '" ,.,,--'Jj.,...-,' -7).'- 'n"......' ... ,---m-----.-~f~Lh7_;:-~(/l:jZ-ej'y~-I2..{JJLn-- _n d_nn . " __ ..__'..__m_..__CfJY1""e._friQ_ __."..___.,__.___._ ,-,.,-. .----.-.--___ft~_Q"'f'j.fi ~ L .00. ----., ~Id,.,;/I.~~~~'--~~~-=--df;f2 ,=~-~ (/ ~4~~ I n '--.__n_'....__',d. ..,........'._n_ "" '. .,,_"d ,.1-,,- '. .', n~ __=__-n~-.:,____,_.__ ' '- . . CUMBERLAND COUNTY HOUSING AUTHORITY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000 CIVIL TERM v : CIVIL ACTION - LAW FLORENCE P. RODGERS BETTY L. STANTON AND, HEIRS AND ASSIGNS OF WILLIAM P. STANTON, : ACTION IN QUIET TITLE Defendants AFFIDAVIT I, Christopher C. Houston, Esquire, of the Cumberland County Housing Authority, Carlisle, PA, hereby submit this Affidavit pursuant to Pa RCP 430 (a), affirming that the foregoing MOTION FOR SPECIAL ORDER FOR SERVICE BY PUBLICATION PURSUANT TO P.A. R.C.P. 430 correctly details the nature and extent of the investigation of the whereabouts of the several Defendants for whom the Special Order is sought, and the reasons whereby service in the regular course will not be able to be made. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. Date: 1!;l. ~/l.()CV ~A /1 ~S~C.~ESqUire @_/.!I~- ^f ~- ~-'~I ". . . . . _~~ !!I\l~~-- -",-..." . , . 0 C:J 0 " c 0 -n T :~ '-I ql ~< :.!;~ :r " .', ;:"',J f11 c ,00- 1= .. r-'" I "orn f_;~1 .,,-. C.0 "7 .,,-j ~ [5 9cJ :r.:.:. 9~ (-:f ~ s;: C' C5 , c')fn "'.:" ..., p. =< ::Cl -< 1'J""~1lr,""lI'i~"'Ifw,'1nll""~"""'_~~. ~ r-~I!'Il". ~ ,~fl~~I\\_~, ft!W8'IlIII~ ... SHERIFF'S RETURN - REGULAR .. ... ~ '.. CASE NO: 2000-01223 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CUMBERLAND COUNTY HOUSING AUTH VS RODGERS FLORENCE P ET AL CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pensyl vania , who being duly sworn according to law, says, the within COMPLAINT TO QUIET TITLE was served upon RODGERS FLORENCE P the DEFENDANT , at 0007:59 HOURS, on the 23rd day of March , 2000 at 154 W NORTH ST CARLISLE, PA 17013 by handing to BETTY L. STANTON a true and attested copy of COMPLAINT TO QUIET TITLE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.10 .00 10.00 .00 31.10 ~~~~t:~!. R. homas Kl ine ' 03/27/2000 REDEVELOPMENT AUTH OF Sworn and Subscribed to before By: me this t,.~ day of cJu- '.JI cZ.trr...o _A. D . Q'f~ a ~ ~' P othonotary , "'~ "= , 1 . , SHERIFF'S RETURN - REGULAR . CASE NO: 2000-01223 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CUMBERLAND COUNTY HOUSING AUTH VS RODGERS FLORENCE P ET AL CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT TO QUIET TITLE was served upon STANTON BETTY L the DEFENDANT at 0019:59 HOURS, on the 23rd day of March , 2000 at 154 W NORTH ST CARLISLE, PA 17013 by handing to BETTY L. STANTON a true and attested copy of COMPLAINT TO QUIET TITLE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 sO;:~~t:~ R. Thomas Kline 03/27/2000 REDEVELOPMENT Sworn and Subscribed to before By: me this Go (b, day of ~ ~ A.D. 0:;1" () !kJ}~o/.~ r thonotary . \-l'm"O 1- CUMBERLAND COUNTY HOUSING AUTHORITY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 1223 - 2000 CIVIL TERM v : CIVIL ACTION - LAW FLORENCE P. RODGERS, BETTY L. STANTON and HEIRS AND ASSIGNS OF WILLIAM P. STANTON, : ACTION IN QUIET TITLE Defendants PRAECIPE Pursuant to CCRP 1066.4, please enter on the appearance docket and on the decree of May 1, 2000, a notation that the Defendant failed to take the action directed in the last advertisement within the time therein limited; and transmit to the Recorder of Deeds a certified copy of the decree containing the notation above described. ~HOO":"' E'O,;re Attorney for Plaintiff 114 North Hanover Street Carlisle, PA 17013 717-249-0789 GIi:< lJ.oocJ I J Date: .", ;"1__. I"" .. I ~ " ~ , I , ['-I, ~~ ~~,II'!~!l!IIl!~~ ~~,. ~'-'-~""'~', ,~ ."."... 0 c::> 0 c 0 -n :;;: '- _4 -neo c: ~~~p nlfT"l -~ ~ Z:1] :~i~ Zt;:.~ N rA~, -'< .. S.2CJ :c.... j~f~ ~o ::;;: -0 c:? :PC: '...! -, ~ N '> ::0 en -< .. ~......~~wE~''i'fil'li'~m'''"IWif'~1'Iil!l1_,~~~"",'W'''rl'fffi\1l!ll~~~lII!lIWM'li\< Y.. - APR 2 8 200atP (J CUMBERLAND COUNTY HOUSING AUTHORITY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 1223 - 2000 CIVIL TERM v : CIVIL ACTION - LAW FLORENCE P. RODGERS, BETTY L. STANTON and HEIRS AND ASSIGNS OF WILLIAM P. STANTON, : ACTION IN QUIET TITLE Defendants NISI ORDER AND NOW, this ~f day ~ ' 2000, upon presentation am due consideration of "'" the within Motion and it appearing that all Defendants were either personally served by the Sheriff or pursuant to the Special Order of Service of March 7, 2000, and that no answer or other pleading was ~-,-. ... filed by any Defendant, it is ordered that the Defendants be forever barred from asserting any right, lien, title, or interest in the premises involved in this case, that the deed from the Tax Claim Bureau to Plaintiff dated December 3, 1999, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 212, Page 659 is hereby confirmed, and that possession of the premises is hereby granted to Plaintiff, unless such Defendants file an ejectment action against Plaintiff within thirty (30) days of the last publication of this Order in accordance with PA.R.C.P. 1066(b)(1) and CCRP 1066-2. // ~,'- .// By tJ;lEl Court, ." J. The Defendant has CopwjJ -5 -;2 ;00 failed to take the action directE. K3 Date: 1.2::f7t4/~1JO ,", ~iiiIis. '::i --'-1fMi'ilIJlllIiillllrlllii;; .- J '" cJ JfJ IlIfl ~"" ~ ,~,"""",,,.,~, ~'"'"-'--"'-i'IliIIl..-W l&ei!<<i~"f1j.."",(\j~1i&i,.&ll1!iiM ,~,~~ , ~ ,....". ~{ i5- '\ !", \~. '... . \J" . ,'\ \,). ;:,\t; ~- '''''''''~ ",. "'-'""'-~^ ,: v-::'~ ~"' ,',,"," l, ,'1'- ....,0:' -"~ -,,-, -- ,\-~ ...~} . ~ J ~-''''''''-~-1IIii'1iIl " ,~ o ~ riJ,~\' ~,C~: Z_I~. (I} <~,-' _~J'--:: ~C_' ~k ?~). /' c_ -7 :-:;;, .4 ,. .., ,~ (:) o ~ ~~ 7 _.- -.,).,. - - ::.n \-<> 1'1\ 1'1\ " \o~ "i ' ~ " ~~ ! I " ',. " LocMot CUMBERLAND COUNTY HOUSING AUTHORITY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 1223 - 2000 CIVIL TERM v : CIVIL ACTION - LAW FLORENCE P. RODGERS, BETTY L. STANTON and HEIRS AND ASSIGNS OF WILLIAM P. STANTON, : ACTION IN QUIET TITLE Defendants MOTION FOR JUDGMENT UPON AFFIDAVIT PURSUANT TO PA RCP 1066 TO THE HONORABLE JUDGES OF SAID COURT: The Motion of Plaintiff, Cumberland County Housing Authority, by its attorney, Christopher C. Houston, Esquire, respectfully represents: 1 That Plaintiff has heretofore filed a Complaint in this quiet title case. 2 That said Defendants Florence P. Rodgers and Betty L. Stanton were personally served with a Complaint containing the appropriate Notice to Defendant by the Cumberland County Sheriff on March 23, 2000. 3 A copy of the Notice that was sent to Florence P. Rodgers and Betty L. Stanton pursuant to Pa.R.C.P. 237.1 is attached hereto and marked as Exhibit A. I i h__""""'I '''''''''"""1 " . ., 4 The aforesaid Defendants have not filed an Answer to the Complaint, nor have they otherwise pleaded thereto. 5 This Honorable Court on March 7, 2000, and upon Plaintiff's Motion, made a Special Order of Service applicable to the Defendants, heirs and assigns of William P. Stanton 6 The aforesaid Special Order of Service required that service by publication be effected one time in the Cumberland Law Journal and in The Sentinel upon the Defendants, heirs and assigns for William P. Stanton. 7 Publication per the aforesaid Order was effected in the Cumberland Law Journal on March 24, 2000, and in The Sentinel on March 16, 2000, with proofs of publication therefore being attached hereto as Exhibits Band C, respectively, and which advertisements contain the appropriate Notices to Defend. 8 Attached hereto as Exhibit D is an Affidavit of Plaintiff to comply with Pa.R.C.P. 1 066(a). WHEREFORE, the Plaintiff requests this Honorable Court to enter an Order pursuant to Pa.R.C.P. 1066(b), forever barring Defendants from asserting any right, lien, title or interest in the premises, to confirm the validity of the deed from the Tax Claim Bureau to Plaintiff dated December 3, 1999, recorded in the Office of the Recorder of 1- _ " Deeds in and for Cumberland County, Pennsylvania, in Deed Book 212, Page 659, and to grant possession of the premises to Plaintiff, unless Defendants bring an Action of Ejectment against Plaintiff within thirty (30) days of the last publication of this Order. hristopher C. Houston, Esquire Attorney for Plaintiff 114 North Hanover Street Carlisle, PA 17013 717-249-0789 , CUMBERl.AND COUNTY HOUSING AUTHORITY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 1223 - 2000 CIVIL TERM v : CIVIL ACTION - LAW FLORENCE P. RODGERS, BETTY L. STANTON and HEIRS AND ASSIGNS OF WILLIAM P. STANTON, : ACTION IN QUIET TITLE Defendants TO: Betty L. Stanton Florence P. Rodgers DATE OF NOTICE: April 13, 2000 IMPORTANT NOTICE YOU ARe IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY COURT CARLISLE, PA 17013 717-249- Christopher C. ouston, Esquire Attorney for Plaintiff 114 North Hanover Street Carlisle, PA 17013 717-249-0789 EXHIBIT A ,- ,~_ ,,~_ _,h. _~~ " . ,-." -j 'r , PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland. Sherry Clifford, Classified Ad Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz COPy of Notis:;ecof D..hl;,..",ti'Clll "'" -'Cl.JfJlBERLAND COUNTY IN THE COURT OF COMMON HOusmG AUTHORITY, PLEAS OF CUMBERLAND Plaintiff ,- COUNTY. PENNSYLVANIA NO. 1223-2000 CIVIL TERM ~ .;{- 'FLORENCE P. RODGERS ~ANTONAND, > HEIRS AND ASSIGNS OF WILLIAM P. STANTON. Defendants CIVIL ACTION - LAW TO: HeirS and assigns ofWlltiam P. Slanlon _TAKE ffOTlCE: - - That 'the Cumberland County Housing Authority. Plaintiff in this ~ has commenced the above suit agaInst you. The ,rea! ..estate=involved is located at 161 West Locust Avenue, qarllsle. CUmb~~land County, Pennsylvania. and further described as ,..-follows: All Ina! certain tract of land with the improvements there- on-erected located in the Fourth Ward of the Borough 01 _Carllilla Cumtl~rland County. Pen.nsylvania. more par. :.- UcUlariy described as follows, fo Wit . ~ _ _ Ort'O'!e North by property now or formerly of Susan Hippie; ---o-n~East by an alley; on the West by property of Troy ~Lal,liiary formerly of Blake Bysel; and on the South by .~-tocUst Alley, This property is also known ~s No. 161 We15f. Locust Avenue, Carlisle, Pennsylvania, .::.- Containing 21 feet, more or less, in front along Locust _ Allay and extending in depth 52 feet more or less. , NOTICE 11 you wish to Clefend, you must enter a written appearance personally or by attorney and file your defenses or objections _ in wrltlQ!:J wjth the Court You are warned t~at it you fall to do so, ~the ease may proc€'lfd withouryou a!1d a Judgment may be en- _ tered-against you without fl/(ther notlce for the rellel requ~sted _ byJh~J?I?intiff. You may lose money or property or other fights '1m O'Itantto you. - " ~_-~au_SHOULDTAKE THIS NOTICE TO YOUR LAWYER AT 'UNCJ:2::TF YOU 00 NOT HAVE A LAWYER OR CANNOT AF. 't:.ORUUNE,-GO To-erA TELEPHONE THE OFFICE SET -EORTH BELOW TO FIND OUT WHERE YOU CAN GET , LEGAL HELP: ,CUMBERLAND COUNTY BAR ASSOCIATION TWO UBERTY AVENUE - CARLISLE, PA 17013 717-249.3166 ~- ----.,...,...",.,.,.-~~- ~~- y~J 11151J8-1100 March 16, 2000 Affiant further deposes that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Sworn to and subscribed before me this 23 day of March , 2000 f).J)~ ~ Notary Public My commission expires: NOTARIAL SEAL SHIRLEY O. DURNIN, Notary Public Carlisle Bora., Cumb9rJ,1-,d County M CommfssiG;l Expirf>s AllrJ, 9, 2003 EXHIBIT B , '.\ . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz MARCH 24, 2000 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are RO~itor SWORN TO AND SUBSCRIBED before me this 2:4 day of MARCH. 2000 " SEAL lOl6 E. SNYDER, Notary Public Ca~ioIe 1010, Cumbotland Caunty, PA My Commission Expire, Marr-h S, 200 i "'''------~~,-,-- EXHIBIT C ,''I ~,' ", _.~ :-, n ~~"' _"t " < ,~- --. >, '~ ~ l... . . NOTICE In the Court of Common Pleas of Cumberland County. Pennsylvania Clv1l Action-Law No. 1223 2000 Civil Term CUMBERLAND COUNlY HOUSING AUTHORITY, Plaintiff v. FWRENCE P. RODGERS, BETIY L. STANTON AND. HEIRS AND ASSIGNS OF WILLIAM P. STANTON. Defendants ACTION IN QUIET TITLE TO: Heirs and assigns of William P. Stanton TAKE NanCE: That the Cumberland County Housing Authority. Plaintiff in this case, has commenced the above suit against you. The real estate involved is located at 161 West LocustAvenue. Carlisle. Cumberland County, Penn- sylvania, and further described as follows: All that certain tract of land with the improvements thereon erected located in the Fourth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, more particu- larly described as follows, to wit: On the north by property now or formerly of Susan Hipple; on the East by an alley: on the West by property of Troy LaundIy, formerly of Blake Bysel; and on the South by Locust Alley. This property Is also known as No. 161 West Locust Avenue, Carlisle, Pennsylvania. Conta1n:in.g 21 feet, more or less. in front along Locust Alley and ex- tending in depth 52 feet, more or less. NanCE If you wish to defend, you must enter a written appearance person- ally or by attorney and file your de- fenses or objections in writing with the Court. You are warned that !fyou fail to do so, the case may proceed without you and a judgment may be entered against you without further notice for the relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TIllS NO- TICE TO YOUR LAWYER AT ONCE. IF YOU DO Naf HAVE A LAWYER OR CANNaf AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNlY BAR ASSOCIATION Two Uberty Avenue Carlisle. PA 17013 717-249-3166 Mar. 24 Cumberland Notices -"' 3 . ' , , ... ' . . CUMBERLAND COUNTY HOUSING AUTHORITY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 1223 - 2000 CIVIL TERM v : CIVIL ACTION - LAW FLORENCE P. RODGERS, BETTY L. STANTON and HEIRS AND ASSIGNS OF WILLIAM P. STANTON, : ACTION IN QUIET TITLE Defendants AFFIDAVIT REQUIRED BY PA. RCP 10661a) Christopher Gulotta, hereby avers, subject to the penalties of 18 Pa.C.S. 4904, that the facts set forth in the foregoing Motion are true and correct and incorporate same in this Affidavit in the same manner as if here set forth at length, particularly with respect to such facts as relate to the Complaint in this case being served (either by the Sheriff or by publication pursuant to the Court's March 7, 2000 Special Order of Service), that the Notice to Defend was included in the Complaint and that no Defendant has filed an Answer (or otherwise pleaded ."''',,.,' ~ U-U Chris opher Gulotta Executive Director Cumberland County Housing Authority 114 North Hanover Street Carlisle, PA 17013 717-249-0789 EXHIBIT D ,.,~ . . I , . ~ , ,.,....~ ," ~,_~_wm'l '~": n-';.- . (-.... ~:; , C' :::'::..:j -<: - IIiI < " --i""l '",""" '''-,J l)' 1 ~,;) :"--:"1 (..0 '-,~-} '-< ~mtIJ'lIlII!'l ~ ~, >'-~.- ."\, ().{J _ / :< .lJ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. 1.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esqnire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz MAY 12, 2000 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are ROgerlr. Morgenthal, Editor - SWORN TO AND SUBSCRIBED before me this 12 day of MAY. 2000 NOTAIll L LOIS E. SNYDER, Ho1<ity Public Carlisle Boro, Cumberland Caunty, PA My Commiuion Expires MatCh 5, 2001 .,~ ... (/-(J - /')<l ;z. PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland. Sherry Clifford, Classified Ad Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Notice of Publication ---: _---c--- !AJMaERLAND COUNTY HQlJSfNG AUTHORITY, :\N THE COUR.T OF :COMMON PLEAS OF :CUMBERLAND COUNTY, :PENNSYLVANIA : NO. 1223-2000 CIVIL : TERM : CIVIL ACTION - LAW Plaintiff ~v aa~NCE P. RODGERS . BETTY L. STANTON and ;ACTlON IN QUIET rlTLE HEIRS AND ASSIGNS OF --wILLiAM P. STANTON, -=- ~. Defendants . - ~ TO~ -Heirs and Assigns of William P. Stanton = --.~ - =~ Y~e notmeo that an Order has been entered to -'---Cum!er1llncl County Housing Authority v Florence P. EhClgers, Belty L. Stanton and Heirs and Assigns of WIl. liam p~Stanton, at No. 1223-2000 Civil Term, In the ;;, .;Aurl ci, COmmon Pleas of Cumberland County, Penn- :;;ylv~a on the 2nd day of May, 2000, directing that withTri1fiiffy (3111 days after the last publication of this No- . ti'c.t11ia1you shall file an ejectment action aga.\nst the . Plain(f!t:or be fore\ler barred from asserting any right, Ii- ~U.~JI~_or jnter~st m.co!1sistent with.the interest or claim -s:e.lloFfJrTn-Uie Plamlrfrs Complarnt to the land here ..described: All that certain tract of land with the improvements , thereon erected located in the Fourth Ward of the ';'--e-oro-ugh of Carlisle. Cumberland County, Penn- o &1\Yarlll~:. mOTS particularly described as follows, ... tQwif; 0 . =--~Of'i1'fle North by property now or formerly of Susan '-ru~ple; on the East by an alley; on the West by ~ PromrrtY.-. . of Tro.y laundry, form. eny O. f BlaKe Bysel; -, _ _ anctQ:n the South by Locust Alley. This property is ~\so"Jtnown as No. 161 West Locust Avenue, . CairrSle. pennsylvania. . ~~fling 21 fe~tr more.or: I~ss, in front along ~o<;ustAl1ey and extending in depth 52 feet, more orJess. Cumberland County Housing Authority _ - Chf/stopher C. Houston, Esquire Attorney for Plaintiff t 14 North Han.over Street Carlisle', PA 17013 717.249-0789 l~~~- r May 5, 2000 Affiant further deposes that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. >~-o/.g#.-/ May 11, 2000 Sworn to and subscribed before me this 11 day of May , 2000 r&~ 0 ,cflc-u"JWY{ Notary Public My commission expires: NOT I,RIAL SEAL SHIRl~Y O. DURNIN, Not,)/)' Public Carlisle Ekno" Cwn~~::;;lanrf Cr.'p.>, M Commf5:;;~r;.p:.':1i.~~~~~li~. ~~ ~:;-.- '"," ,1!ll!!lllII!I!I 4' $2 g 0 -<I ~ <- ._J, -otQ ~ ~-n ~e::\ -- \ IIp ::..1.1 - -~~~(\7 he:. \'-) ~i~;: --":,~~~l; <LCJ ? ~f:t~\ ~....~ ::::. Zl,) ~C) ....., -pC ~' -, ~ \"~, ~ to"" ::<