HomeMy WebLinkAbout00-04828
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
GARY 1. NEFF,
Plaintiff
vs.
J.E. BROOKS and PAULINE ESTELLA :
BROOKS, his wife, and their respective
heirs, successors and assigns,
Defendants
D-tJ. </ 'i:;"''l
NO. CIVIL 2000
ACTION TO QUITE TITLE
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 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
Petition or for any other claim or relief requested by Petitioner. 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.
COURT ADMINISTRATOR
Third Floor
Cumberland County Court House
Carlisle, P A 17013
Telephone: 717 240-6200
.
.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
GARY 1. NEFF,
Plaintiff
vs.
J.E. BROOKS and PAULINE ESTELLA :
BROOKS, his wife, and their respective
heirs, successors and assigns,
Defendants
y'bJ..'i
NO. rro- CIVIL 2000
ACTION TO QUITE TITLE
COMPLAINT
1. Plaintiff, Gary 1. Neff, is an adult individual residing at P.O. Box
351,Shermansdale, Perry County, Pennsylvania.
2. Plaintiff is the legal title owner to premises situate in East Pennsboro
Township, Cumberland County, Pennsylvania, by virtue of a deed dated February
9, 1988, and recorded in Cumberland County Deed Bool< 224, Page 12, which
premises are bounded and described as follows, to wit:
ALL THAT CERTAIN tract of land in East Pennsboro Township, Cumberland
County, bounded and described as follows:
BEGINNING at a point on the western side of a public road that runs between
Camp Hill and West Fairview, which point is one hundred seventy-nine and one
-1-
tenth (179.1) feet north of the land of the James McCromicl~ Estate;
thence along land of Minnie Jones, two hundred twenty-nine and seven tenths
(229.7) feet to a point at the low water mark of the Conodoguinet Creel~;
thence northwardly up said Creek forty-seven and eight tenths (47.8) feet to a
point;
thence eastwardly along lands of Carrie Stouffer, two hundred twenty-six and four
tenths (226.4) feet to the above-mentioned public road;
thence southwardly along the said public road forty-seven and nine tenths (47.9)
feet to a point, the place of BEGINNING.
3. An abstract of title for the lands of Plaintiff is attached hereto as Exhibit
"A" which is hereby made a part hereof.
4. Plaintiff avers that Defendants, J. E. Brooks and Pauline Estella Brooks,
his wife, are adult individuals whose present whereabouts are unknown to Plaintiffs,
and Plaintiffs further aver that the said Defendants may be deceased; however,
Plaintiffs aver that they have no knowledge or information concerning the identity
or whereabouts of the said heirs, successors or assigns of the said J. E. Brooks and
Pauline Estella Brooks, his wife.
5. Plaintiffs aver that the said J. E. Broob and Pauline Estella Brooks, his
wife, acquired an ownership interest in the premises set forth in paragraph 3 herein
by virtue of a deed from E. B. Mathias and H.M. Mathias, dated January 21,
1933, and recorded in Cumberland County Deed Book "I", Volume 11, Page 182.
6. plaintiff is informed and believe and therefor avers that an examination
of the records in and for the County of Cumberland, Commonwealth of
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Pennsylvania, indicates that the premises described in Paragraph 2 above were sold
by the Treasurer of Cumberland County, Pennsylvania, for unpaid taxes for the
years 1931 and 1932, on April 29, 1940/ with the deed being dated September
26/1940/ and recorded in Cumberland County Treasurer's Sale Bool~ 3, Page 44/
which premises were rated and assessed as the lands of L.B. Mathias.
7. Plaintiffs further aver that the sale of the subject properly in 1940 made
absolutely no reference to the ownership interests of J. E. Brooks and Pauline
Estella Brooks, his wife, even though they were the owners at the time and though
the taxes for which the properly was sold were for years prior to the ownership of J.
E. Brool~s and Pauline Estella Brool~s, his wife.
8. Plaintiffs aver that from and after April 29, 1940/ neither 1. B. Mathias,
nor J. E. Brooks nor Pauline Estella Brooks ever made any attempt to redeem the
tax sale which occurred on that date nor did they ever question the title of any of
the succeeding owners of record which included the Cumberland County Treasurer,
T. Elliott Middleton or Carrie E. Stouffer.
9. Plaintiffs aver that from and after April 29/ 1940, they and their
predecessors in title had been in open/ notorious and continuous and adverse
possession of the subject properly and that none of the named Defendants, nor any
of their heirs, successors or assigns, have ever entered into possession of the said
premises, nor have they questioned the tax sale noted previously in this action nor
the ownership interests of Plaintiffs or their predecessor in title.
10. Plaintiffs aver that by reason of the failure of the tax authorities to
properly identify the owner of the premises in the tax sale in 1940 which was
different from the legal title owner of the property at that time, a cloud exists upon
the Plaintiffs' ownership of the said premises which can only be cleared by an Order
from your Honorable Court declaring that the plaintiff is the owner in fee simple of
the said premises, free and clear of any and all right, title, interest, claim and
demand of the said J. E. Brooks or Pauline Estella Brooks, his wife, and their
respective heirs, successors and assigns and further enjoining said defendants from
denying, impeaching or in any way attacking the plaintiff's ownership of the said
premises.
WHEREFORE, Plaintiff respectfully requests the Court to enter an Order
declaring that the said Plaintiff, Gary 1. Neff, is the owner in fee simple of the
premises set forth in paragraph 2 of this Complaint, free and clear of any and all
right, title, interest, claim, or demand of the said J. E. Brooks and Pauline Estella
Brooks, his wife, by reason of the faJure of the Cumberland County Treasurer's
Office to notify the said owners of the sale of the premises in 1940; and further
enjoining the said Defendants, J. E. Brooks and Pauline Estella Brooks, his wife,
~ , ~
and theiJ[ respective heirs, successors and assigns, from denying, impeaching, or in
anyway attacking the Plaintiff's ownership of the said premises:~~~~ver
pray. -;../ //
bert G. Radebach, Esquire
1'07 Locust Street
Harrisburg, PA 17101
717-234-6655
LD.19255
Attorney for Plaintiffs
FI:_EU'_'C';':Fl~:E
DF .D,nCi':DiAHY
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PENNSYLVANIA
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY,PENNSYLVANU
GARYL. NEFF,
Plaintiff
vs.
lE. BROOKS and PAULINE ESTELLA
BROOKS, his wife, and their respective
heirs, successors and assigns,
Defendants
NO.
S
2000
ACTION TO QUITE TITLE
STATE OF PENNSYLVANIA
SS
COUNTY OF DAUPHIN
AFFIDAVIT
I, Gary L. Neff, being duly sworn according to law deposes and says that I am the Plaintiff in the
forgoing Complaint and that the facts set forth therein are true and correct to the best of my
knowledge, information and belief
Sworn and subscribfi!.to
bef\U~ !P-blJhis ~ day
o ilmY,WOO.
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Notary Public
G~~~ ~ ~~f'
NOT AfI\A.L SE:O~ary public
t IA CALAIliAN. hin Count'i
JOANNE ., burg OaUP .ori\ 8 2<)02
Ci\'j ot \1ar-r\~ E.~pil'e6 A fl .
tiN' CommiSSIon x
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. ITEM #1 TAX PARCEL#:17-1040-032
1. DEED RECORD BOOK, PAGE
2. DEED DATE : February 9/ 1988
3. ACKLDGMNT DATE : February 9, 1988
4. RECORDING DATE: : June 27, 2000
5. EXECUTION OF DEED :OK
6. WARRANTY IN DEED : GENERAL
7. CONSIDERATION: $8/500.00
8. TRANSFER TAXES PAID: STATE:$85.00 LOCAL:$85.00
FEDRL:$O.OO
9. ATTORNEY ON DEED: Robert G. Radebach
1O.GRANTOR: Carrie E. Stouffer a/l~/a Carrie E. Stauffer, widow, by her duly
constituted Attorney-in-Fact James A. Stouffer
1l.GRANTEE: Gary 1. Neff
12. ESTATE CONVEYED: Fee Simple
13. MUNICIPALITY: East Pennsboro Township COUNTY: Cumberland
14. PRIOR CONVEYANCE: 13G442
15.EXCEPTIONS: None
16. PREMISES DESCRIPTION:
ALL THAT CERTAIN tract of land in East Pennsboro Township, Cumberland
County, bounded and described as follows:
BEGINNING at a point on the western side of a public road that runs between
Camp Hill and West Fairview, which point is one hundred seventy-nine and one
tenth (179.1) feet north of the land of the James McCormick Estate;
thence along land of Minnie Jones/ two hundred twenty-nine and seven tenths
(229.7) feet to a point at the low water mark of the Conodoguinet Creel~;
thence northwardly up said Creel~ forty-seven and eight tenths (47.8) feet to a
point;
thence eastwardly along lands of Carrie Stouffer, two hundred twenty-six and four
tenths (226.4) feet to the above-mentioned public road;
thence southwardly along the said public road forty-seven and nine tenths (47.9)
feet to a point, the place of BEGINNING.
.
,~
17. COMMENTS Premises sold to grantee and Mary Calderelli on February 9,
1998, by installment sale as recorded in Cumberland County Miscellaneous Book
346/ Page 1076 - Mary K. Calderelli released her interest by Release recorded in
Cumberland County Miscellaneous Bool< 647, Page 708
- .-~- --'.~-~
- -"- '-, ,. '--,' ,
. ITEM #2 TAX PARCEL#:17-1040-032
1. DEED RECORD BOOK 13G, PAGE 442
2. DEED DATE : June 6, 1946
3. ACKLDGMNT DATE : June 6, 1946
4. RECORDING DATE: : July 23,1946
5. EXECUTION OF DEED :OK
6. WARRANTY IN DEED : GENERAL
7. CONSIDERATION: $1.00
8. TRANSFER TAXES PAID: STATE:$ LOCAL: $
FEDRL:$
9. ATTORNEY ON DEED:
lO.GRANTOR: T. Elliot Middleton
I1.GRANTEE: Carrie E. Stouffer
12. ESTATE CONVEYED: Fee Simple
13. MUNICIPALITY: East Pennsboro Township COUNTY: Cumberland
14. PRIOR CONVEYANCE: 13D437
IS.EXCEPTIONS: None
16. PREMISES DESCRIPTION:
ALL THAT CERTAIN tract of land in East Pennsboro Township, Cumberland
County, bounded and described as follows:
BEGINNING at a point on the western side of a public road that runs between
Camp Hill and West Fairview, which point is one hundred seventy-nine and one
tenth (179.1) feet north of the land of the James McCormick Estate;
thence along land of Minnie Jones, two hundred twenty-nine and seven tenths
(229.7) feet to a point at the low water mark of the Conodoguinet Creek;
thence northwardly up said Creek forty-seven and eight tenths (47.8) feet to a
point;
thence eastwardly along lands of Carrie Stouffer, two hundred twenty-six and four
tenths (226.4) feet to the above-mentioned public road;
thence southwardly along the said public road forty-seven and nine tenths (47.9)
feet to a point, the place of BEGINNING.
17. COMMENTS
"',,,
ITEM #3
1. DEED RECORD BOOK 13D, PAGE 437
2. DEED DATE :January 21,1946
3. ACKLDGMNT DATE :January 21,1946
4. RECORDING DATE: :May 6, 1946
5. EXECUTION OF DEED :OK
6. WARRANTY IN DEED: GENERAL
7. CONSIDERATION : $1.00
8. TRANSFER TAXES PAID: STATE:$
9. ATTORNEY ON DEED:
1O.GRANTOR: Commissioners of Cumberland County
1l.GRANTEE: T. Elliot Middleton
12. ESTATE CONVEYED: Fee Simple
13. MUNICIPALITY: East Pennsboro Township COUNTY: Cumberland
14. PRIOR CONVEYANCE: Treas. DB 3, Page 44
IS.EXCEPTIONS:
TAX PARCEL#:17-1040-032
LOCAL:$
FEDRL:$
16. PREMISES DESCRIPTION:
ALL THAT CERTAIN tract of land in East Pennsboro Township, Cumberland County,
bounded and described as follows:
BEGINNING at a point on the western side of a public road that runs between Camp Hill and
West Fairview, which point is one hundred seventy-nine and one tenth (179.1) feet north of the
land of the James McCormicl. Estate;
thence along land of Minnie Jones, two hundred twenty-nine and seven tenths (229.7) feet to a
point at t],e low water mark of the Conodoguinet Creek;
thence northwardly up said Creel< forty-seven and eight tenths (47.8) feet to a point;
thence eastwardly along lands of Carrie Stouffer, two hundred twenty-six and four tenths (226.4)
feet to the above-mentioned public road;
thence southwardly along the said public road forty-seven and nine tenths (47.9) feet to a point,
the place of BEGINNING.
17. COMMENTS
""
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TAX PARCEL#:17-1040-032
LOCAL:$
FEDRL:$
1l.GRANTEE: Cumberland County Commissioners
12. ESTATE CONVEYED: Fee Simple
13. MUNICIPALITY: East Pennsbora Township COUNTY: Cumberland
14. PRIOR CONVEYANCE: 111182
IS.EXCEPTIONS:
16. PREMISES DESCRIPTION:
ALL THAT CERTAIN tract of land in East Pennsbora Township, Cumberland County,
bounded and described as follows:
BEGINNING at a point On the western side of a public road that runs between Camp Hill and
West Fairview, which point is one hundred seventy-nine and one tenth (179.1) feet north of the
land of the James McCormicl, Estate;
thence along land of Minnie Jones, two hundred twenty-nine and seven tenths (229.7) feet to a
point at the low water marl, of the Conodoguinet Creek;
thence northwardly up said Creel, forty-seven and eight tenths (47.8) feet to a point;
thence eastwardly along lands of Carrie Stouffer, two hundred twenty-six and four tenths (226.4)
feet to the above-mentioned public road;
thence southwardly along the said public road forty-seven and nine tenths (47.9) feet to a point,
the place of BEGINNING.
17. COMMENTS
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. ITEM #5
1. DEED RECORD BOOK llI, PAGE 182
2. DEED DATE : January 21, 1933
3. ACKLDGMNT DATE :January 21,1933
4. RECORDING DATE: : January 23,1933
5. EXECUTION OF DEED :OK
6. WARRANTY IN DEED : GENERAL
7. CONSIDERATION : $1.00
8. TRANSFER TAXES PAID: STATE:$
9. ATTORNEY ON DEED:
1O.GRANTOR: 1. B. Mathias
TAX PARCEL#:17-1040-032
LOCAL: $
FEDRL:$.50
1l.GRANTEE: J.E. Brooks and Pauline Estella Brooks
12. ESTATE CONVEYED: Fee Simple
13. MUNICIPALITY: East Pennsboro Township COUNTY: Cumberland
14. PRIOR CONVEYANCE: llC252
15.EXCEPTIONS:
16. PREMISES DESCRIPTION:
ALL THAT CERTAIN tract of land in East Pennsboro Township, Cumberland County,
bounded and described as follows:
BEGINNING at a point on the western side of a public road that runs between Camp Hill and
West Fairview, which point is one hundred seventy-nine and one tenth (179.1) feet north of the
land of the James McCormick Estate;
thence along land of Minnie Jones, two hundred twenty-nine and seven tenths (229.7) feet to a
point at the low water mark of the Conodoguinet Creek;
thence northwardly up said Creel. forty-seven and eight tenths (47.8) feet to a point;
thence eastwardly along lands of Carrie Stouffer, two hundred twenty-six and four tenths (226.4)
feet to the above-mentioned public road;
thence southwardly along the said public road forty-seven and nine tenths (47.9) feet to a point,
the place of BEGINNING.
17. COMMENTS
_C-
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. ITEM #6
1. DEED RECORD BOOK HC, PAGE 252
2. DEED DATE :May 28, 1930
3. ACKLDGMNT DATE :May 28, 1930
4. RECORDING DATE: :July 23, 1930
5. EXECUTION OF DEED :OK
6. WARRANTY IN DEED: GENERAL
7. CONSIDERATION : $1.00
8. TRANSFER TAXES PAID: STATE:$
9. ATTORNEY ON DEED:
10.GRANTOR: William H. Nelson and Lottie M. Nelson
TAX PARCEL#:17-1040-032
LOCAL $
FEDRL:$
,_::"
lLGRANTEE: 1. B. Mathias
12. ESTATE CONVEYED: Fee Simple
p.MUNICIPAUTY: East Pennsbora Township COUNTY: Cumberland
141 PRISJR CONVEYANCE: 9N252
15',EXCEPTIONS:
16. PREMISES DESCRIPTION:
ALL THAT CERTAIN tract of land in East Pennsboro Township, Cumberland County,
hounded and described as follows: ; ,.
BEGINNING at a point on the western side of a public road that runs between Camp Hill and
West Fairview, which point is one hundred seventy-nine and one tenth (179.1) feet north of the
land of the James McCormicl. Estate;
tJ:,.encea.long land of Minnie Jones, two hundred twenty-nine and seven tenths (229.7) feet to a
point at the low water mark of the Conodoguinet Creek;
thence northwardly up said Creek forty-seven and eight tenths (47.8) feet to a point;
thence eastwardly along lands of Carrie Stouffer, two hundred twenty-six and four tenths (226.4)
feet to the above-mentioned public road;
thence southwardly along the said public road forty-seven and nine tenths (47.9) feet to a point,
the'place of BEGINNING. .
17. COMMENTS
TITLE INTO NELSON IS WELL SETTLED.
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IN THE COURT OF COMMON PLEAS
,oF CUMBERLAND COUNTY, PENNSYLVANIA
GARY lJ. NEFF,
Plaintiff
vs.
J.E. BROOKS and PAULINE ESTELLA :
BROOKS, his wife, and their respective
heirs, successors and assigns,
Defendants
_"\ ~ JI!:
NO.eo CIVIL 2000
ACTION TO QUITE TITLE
ORDER FOR PUBLICATION
AND NOW, this day of
,2000, upon presentation and
consideration of the within Motion and at the suggestion of Robert G. Radebach, Attorney for
Plaintiff, Plaintiff is hereby granted leave to make service of the Complaint upon Defendants,
J.E.BROOKS and PAULINE ESTELLA BROOKS, his wife, and their respective heirs,
successors and assigns, by publication one time in the Cumberland Law Journal and one
newspaper of general circulation in the County of Cumberland, Pennsylvania, as provided by Pac
R.C.P. 430(b).
BY THE COURT,
J.
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IN THE COURT OF COMMON PLEAS 2, g
OF CUMBERLAND COUNTY, PENNSYIN~, ~
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GARY 1. NEFF,
Plaintiff
vs.
J.E. BROOKS and PAULINE ESTELLA :
BROOKS, his wife, and their respective
heirs, successors and assigns,
Defendants
NO.
S
2000
ACTION TO QUITE TITLE
MOTION FOR SERVICE BY PUBLICATION
AND NOW, this 7~y oCH ' 2000, an
Affidavit having been executed and filed herewith on behalf of Plaintiff that the
identities and whereabouts of the Defendants, J. E. Brool~s and Pauline Estella
Brool~s, his wife and their respective heirs, successors and assigns, are unknown to
Plaintiff, Plaintiff by his attorney, Robert G. Radebach, Esquire, move your
Honoratlle Court for leave to serve the Complaint in this action upon said
Defendant and their respective heirs, successors and assigns by publication in such
manner as the Court shall direct, as provided by Pa. R.C.P.
Robert G. Radebach, Esquire
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
GARY L. NEFF,
Plaintiff
vs.
IE. BROOKS and PAULINE ESTELLA
BROOKS, his wife, and their respective
heirs, sUCCessors and assigns,
Defendants
NO.
S
2000
ACTION TO QUITE TITLE
AFFIDAVIT OF LAST KNOwN WHEREABOUTS
COMMONWEALTH OF PENNSYLVANIA
: SS
COUNTY OF DAUPHIN
GARY L. NEFF, being duly sworn according to law, depose and say that he is the
Plaintiff in the foregoing Complaint; that he has personal knowledge concerning the facts and
circumstances set forth in the Complaint filed in this action; and that to the best of his knowledge,
information and belief, the said J. E. Brooks and Pauline Estella Brooks, his wife, and their
respective heirs, successors and assigns, are either dead or their whereabouts are unknown to
Plaintiff; and that the heirs, successors /lnd assigns of each and every of the said Defendants are
unknown to Plaintiff; that Plaintiff has no knowledge concerning the whereabouts of the heirs,
successors and assigns of the said Defendants; and that Plaintiff has made a diligent search in the
community surrounding the premises which are the subject of this action, but that no information
concerning these matters was elicited by said investigation, so that Plaintiff continues to have no
knowledge concerning the Defendants or their heirs, uccessors or as . ns.
'\t-GARY
Sworn and subscribed to before me this 2') day
of 2000.
V-.~
NOTARIAL SEAL
JOANNE M, CALAMAN. Notary Public
City of Harrisburg, Dauphin County
M Commission Ex ires A rilS, 2002
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTI, PENNSYLVANIA
GARY 1. NEFF,
plaintiff
vs.
J.E. BROOKS and PAULINE ESTELLA :
BROOKS, his wife, and their respective
heirs, successors and assigns,
Defendants
NO.
CIVIL 2000
ACTION TO QUITE TITLE
SUPPLEMENTARY AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
: SS
COUNTY OF DAUPHIN
Robert G. Radebach, Esquire, being duly sworn according to law
deposes and says that he is a member of the Bar of the Supreme Court of
Pennsylvania; that he represents the Plaintiffs in the action above-captioned; and
that prior to the commencement of the instant Action to Quiet Title, he entered
upon an independent investigation of the facts and circumstances surrounding the
lands in question and which are the subject of the Action to Quiet Title. This
investigation included a comprehensive examination of the deed indices in and for
the County of Cumberland as well as the Cumberland County Tax Assessment
Rolls and the offices of the Register of Wills and the Pennsylvania Archives. None
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of the aforesaid investigations yielded any beneficial Imowledge regarding the
existence of conveyances of record or not of record for the subject premises. The
tax assessment record clearly indicates a chain of title consistent with the claims
made by the present Plaintiff.
Investigations were further made into the relevant estate proceedings in
the County of Cumberland and that investigation yielded no relevant or helpful
information. No investigation was conducted in any other county in Pennsylvania
due to tIle fact that the subject property is not located .
the boundaries of the County of Cumberland.
Robert G. Radebach
Sworn and subscribed to
'-I""""
before me this 1 day
of JA Or ,2000.
)~/i~
NOTARIAL SEAL
JOANNE M, CALAMAN. Notary Public
City of Hanisburg, Dauphin CQunty
Mv CommiSSIon Expira. Aoril8, 2002
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
GARY 1. NEFF,
Plaintiff
vs.
J.E. BROOKS and PAULINE ESTELLA :
BROOKS, his wife, and their respective
heirs, successors and assigns,
Defendants
O "IP~
NO.o - CIVIL 2000
ACTION TO QUITE TITLE
ORDER FOR PUBLICATION
AND NOW, t1isllty of ~, 2000, upon presentation and
consideration of the within Motion and at the suggestion of Robert G. Radebach, Attorney for
Plaintiff, Plaintiff is hereby granted leave to make service of the Complaint upon Defendants,
J.E. BROOKS and PAULINE ESTELLA BROOKS, his wife, and their respective heirs,
successors and assigns, by publication one time in t1e Cumberland Law Journal and one
newspaper of general circulation in the County of Cumberland, Pennsylvania, as provided by Pac
R.C.P. 430(b).
BY~~
J.
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PENNSYLVANIA
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL V ANlA
GARY L. NEFF,
Plaintiff
vs.
J.E. BROOKS and PAULINE ESTELLA:
BROOKS, his wife, and their respective
heirs, successors and assigns,
Defendants
NO.
_J,',
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S
2000
ACTION TO QUITE TITLE
MOTION FOR SERVICE BY PUBLICATION
AND NOW, fu. ;;tyof H ,2000, on
Affidavit having been executed and filed herewith on behalf of Plaintiff that the
identities and whereabouts of the Defendants, J. E. Brooks and Pauline Estella
Brooks, his wife and their respective heirs, successors and assigns, are unlmown to
Plaintiff, Plaintiff by his attorney, Robert G. Radebach, Esquire, move your
Honorable Court for leave to serve the Complaint in this action upon said
Defendant and their respective heirs, successors and assigns by publication in such
manner as the Court shall direct, as provided by Pac R.C.P.
Robert G. Radebach, Esquire
Attorney for plaintiff
9 12 North River Road
Halifax. PA 17032
(71 7) 896-2666
(717) 896-2754 Fax
ROBERT G. HADE8./\:
ATfORNEY AT LAW
107 Loa.lsf Sfreet
Harrisburg, PA 171 OJ
(717) 234-6655
(717) 234-3550 Fax
I CALL PORAPPOINTMBNT
HOMB VISITS AVAILABLE
...01
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL VANIA
GARYL. NEFF,
Plaintiff
vs.
lE. BROOKS and PAULINE ESTELLA
BROOKS, his wife, and their respective
heirs, successors and assigns,
Defendants
NO.
s
2000
ACTION TO QUITE TITLE
AFFIDAVIT OF LAST KNO~ WHEREABOUTS
COMMONWEALTH OF PENNSYL VANIA
: SS
COUNTY OF DAUPHIN
GARY L. NEFF, being duly sworn according to law, depose and say that he is the
Plaintiff in the foregoing Complaint; that he has personal knowledge concerning the facts and
circumstances set forth in the Complaint filed in this action; and that to the best of his knowledge,
information and belief, the said J. E. Brooks and Pauline Estella Brooks, his wife, and their
respective heirs, successors and assigns, are either dead or their whereabouts are unknown to
Plaintiff; and that the heirs, successors and assigns of each and every of the said Defendants are
unknown to Plaintiff; that Plaintiff has no knowledge concerning the whereabouts of the heirs,
successors and assigns ofthe said Defendants; and that Plaintiff has made a diligent search in the
community surrounding the premises which are the subject of this action, but that no information
concerning these matters was elicited by said investigation, so that Plaintiff continues to have no
knowledge concerning the Defendants or their heirs, uccessors or as' s.
~GARY
Sworn and subscribed to before me this 2') day
of 2000.
\A-~
NOTARIAL SEAL
JOANNE M. CALAMAN, Notary Public
City ()f Harrisburg, Dauphin County
M Commission Ex ires A ril 8, 2002
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
GARY i. NEFF,
Plaintiff
vs.
J.E. BROOKS and PAULINE ESTELLA:
BROOKS, his wife, and their respective
heirs, successors and assigns,
Defendants
NO.
CIVIL 2000
ACTION TO QUITE TITLE
SUPPLEMENTARY AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
: SS
COUNTY OF DAUPHIN
Robert G. Radebach, Esquire, being duly sworn according to law
deposes and says that he is a member of the Bar of the Supreme Court of
Pennsylvania; that he represents the Plaintiffs in the action above-captioned; and
that prior to the commencement of the instant Action to Quiet Title, he entered
upon an independent investigation of the facts and circumstances surrounding the
lands in question and which are the subject of the Action to Quiet Title. This
investigation included a comprehensive examination of the deed indices in and for
the County of Cumberland as well as the Cumberland County Tax Assessment
Rolls and the offices of the Register of wills and the Pennsylvania Archives. None
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of the aforesaid investigations yielded any beneficial knowledge regarding the
eXistencl of conveyances of record or not of record for the subject premises. The
tax assetment record clearly indicates a chain of title consistent with the claims
made byithe present Plaintiff.
Investigations were further made into the relevant estate proceedings in
the County of Cumberland and that investigation yielded no relevant or helpful
information. No investigation was conducted in any other county in Pennsylvania
due to the fact that the subject property is not located'
the boundaries of the County of Cumberland.
Sworn and subscribed to
'/.'-
before me this '1 day
of JAY ,2000.
JJW--U-~
Notary public
NOTARIAL SEAL
JOANNE M, CALAMAN, Notary Public
City of Harrisburg, Dauphin County
MV CommiSSIon Exoires ADril 8, 2002
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
GARY 1. NEFF,
plaintiff
vs.
J.E. BRpOKS and PAULINE ESTELLA:
BROOKS, his wife, and their respective :
heirs, successors and assigns,
Defendants
NO. 00-4828 CIVIL 2000
ACTION TO QUITE TITLE
CERTIFICATE OF SERVICE
AND NOW, this 4th day of August, 2000, I, Robert G. Radebach,
ESQUIRE, attorney for Plaintiffs, do hereby certify that I represent the Plaintiff
above-captioned matter and that the attached Notice of action to Quiet Title
pursuant the Court's order, dated the 11 th day of July, 2000, was duly advertised in
July 20,2000. See proofs of publication attached eret
the Cumberland County Law Journal on July 28, 200 nd th
Robert G. Ra e1Jach,
912 North River Road
Halifax, P A 17032
(717) 896-2666
LD.# 19255
--~Mjsce"aneousNoiices-
IN THE COURT OF COMMON PLEAS
.:OF CUMBERLAN:D COUNTY,
PENNSYLVANIA
NO.oo-482BCIVIL20GO
ACTION TO QUITE TITLE
GARY L. NEFI=,
Plaintiff
v..
J~E. :BROOKS and PAULINE ESTELLA
'ORO"QkS,' his wife. and their respectiVe
beir:&, succe!>sors: and aulllns.
" " Def1!'ndants
NOTICE OF ACTION TO QUIETTI'rLE
To: J. E. Brooks and PcuJlne Estella
BrODkS.. his wIfe and their respective heirs.
suc.cessors and assigns,
NOTICE ISherebyglvethat on the 7th day
of July, 2OOll, the above named Plaintlff lfIed 0
Complaint to Qulet Trtle as above noted
agcdnst you seeking: (I: Court Order decreeing
thot Plal{lWf owns the premises below de-
scribed Inf~e simple. freeand,C:learQtanyand
011 right, fltle, !nterested, claim or demand
. which 'IOU ~ay ha~ 1n and to S(lfd p!'emlses.
Plalritlff claTms to be the owner of said premo .
Tse:; by virtue of regular chains of title which
art' prt'sently SUbject 10 possible Qutst.andlng
'lnt\!lrest of the nami&! defendants. due to unre.
corded .deeds In the chains of tftle 05i well as
Issues regarding Tax Solesof Real Estmeand
!lsSociated variances In the assessment re-
a'lrds upon which sold sales were made, Clnd
iSS!,les regarding volldJfy of tme from the
Cornmonw&llth of PennsYlvania. Plaintiff
further seeks to~cl~r and remove anyc;loud of
title which may ex..st by <<lason of C1uestlons
regarding the saId unrecorded deeds.. Tax
Sales and possibly erroneous. Inconsistent
and detecti~ real estate tax assessments and
InconsJstent grants!)f title from the Common-
wealth of Pennsyl\'anla for the premises
\vhlch are dec1ded os follows:
ALL THAT CERTAIN tract of lond In
Eost PennSYlvania TownshIp, Cum~rland
County, bou~d and described as follows:
BEGINNING at 0 pOInt on the ~stern
side of a public road that runs between Camp I
Hili and West Falrvlewf which point Is one .
hundred sew;nly-nlneanonetenth (l79.1) feet !
nplj,hJl1_tbe land. of. tM.,.Jomes McCr.omiek.
estate; thence Olong land of MlnnleJones.,. two '1'
hundredtwenty-nin~ and sewn tenths (229.7)
feet to a p'olnt at the low water mark of the
-~.Q.gOdoguinet Cre~k: thence northwc:!.fd,Iv...!J.P:
, , ~I~ Creek fortY-se\len and elght f~ntl;'i.\tr!l-l.:ll;l
I . f,e,tto Cl po.lnt; thenceeosIWardly alo,q~o~~.4S;
I O'".C",O,', ',','. 5'.0.", ,",', ", ,." "',, ,h,und~e,d ~l'Jty, ,.,',,1.,",.
amifour ten.ths (226.41 f,eet,fq tb,e,Q,b;q'\!:~J:Tl~n~
tlorieaQll.b:t.lC'('6CW;J:tt~ce'~ou.thwd.r.qh' qlo~g .
,:.tIi'e',:,s'oJd..RubUci ..t"~~;,J.Cldy,~lJefr ~"nd:' nfn!
1:~:::~~i1~~), ,~~,~~: ~~,::1::'~~~' .~~..~.~~,e" ~,,::~r:~: :::,: ,
:::::.:i:',:::,.:''-'VOU'"AR',e.''FU'RTHER' "Nol'fF'IEtf tJi'iif
''"'fne,'toort of'CQiriiftiln P1eas"of Cii"m-wfancf....
, County. PennsYlvaHla,. has ordered that ser-
: vice of ComplaInt be mode upOn J.E. Brooks
and Pauline Estella BrookS.. hIs wife.- and theIr
resDectl\le heirs, successors and assigns, by
on Order dated July J1, 2000, whIch requires
! that this noffce be ptibllshe-d one time in the
, Cumberland Law Journal and also in one
: newspaper 01 general cIrCulatIon in Cumber.
I land COUJ'lty, PennsylvanIa.
! E'N'!~.r~'tv~II~~~~~~g~'A~~~~~~~
'SONALLY'OR BY ATTORNEY AND FILE
YO'UR O.EFENSES OR OBJECTIONS IN
i WRITING WITH THE C,OURT, YOU ARE
: ~:~ffE:~~~~o~~6eh\~gu~Oy~~
: ANO A_JUQGMENT MAY BE ENTeRED
~' '~~~~~ ';-~Ue ~!l~~~TR~~~~~~~DNfN
, THe: COMPLAI NT, YOU MAY LOSE MON-
I EY OR PROPERTYOR OTHER RIGHTS 1M-
I PORTANTTO YOU.
" YOU SHOULD TAKE THIS NOTICE TO
. .YOUR LAWYERAT:ONCE:. IF YOU 00 NOT
":HAVE A' LAWYER OR .CANNOT AFf:'ORD
, ONE, GO :TO OR TEc.EPHONE tHE OF-
I FICE SET 'FORTH BELOW TO FIND OUT
, WHERE YOU AN GET LEGAl. HELP.
COURT ADMINISTRATOR
.. ..... T.hlrd,Floor-
Cumberland County Court House
CQrlisfe, PA 17013
TeleDhone: 711-240-6200
. RQ8:.E,R;TG:_~AD,EBACH,ESQUIRE
'-912 NoWt! ~Iv'll:r ~oad
, ..-HQllhlxI PA 11032
(717)896-:2666
LO.#ll2S
,.ATTORNEY t:OR PLAINTIFF
. '
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THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Undernel No. 587. nooroued Mau 16. 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Michael Morrow bei.ng duly sworn accordi.ng to law, deposes and says:
That he is the Assistant Controller of THE PATRIOT-NEWS CO., a corporation organized and existing under the iaws
of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in
the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-NEWS and
THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street,
in the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established
March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday and Metro editions/issues which appeared on the 20th day(s) of July 2000. That
neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of
the allegations of this statement as to the time, place and character of publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said Cou Iy of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COPY
Sworn to an
Notarial Seal
Terry l. Russell, Notary P .
Harrisburg, Dauphin County
My Gommission Expires June 6. 2002 NARY PUBLIC
Member, Pennsylvania Association 01 ~ieoommission expires June 6, 2002
,
\
ROBERT G. RADEBACH
ATTORNEY-AT-LAW
912 NORTH RIVER ROAD
HALIFAX, PA. 17032
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $
Probating same Notary Fee(s) $
Total $
363.59
1.50
365.09
Publisher's Receipt for Advertising Cost
THE PATRIOT-NEWS CO., publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general
circulation, hereby acknowiedge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid. THE PATRIOT-NEWS CO.
By....................................................................
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATEOFPENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Roger M. Morgentha1, Esqnire, Editor ofthe 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 officia11egal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
isslled 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
JULY 28, 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~ Editor
SWORN TO AND SUBSCRIBED before me this
28 day of JULY. 2000
NOTAfli;I.~:"L
LOtIl E. 5HYl>E~;~ry JIubllc
CarMIe 10.0, Culilbetlond County>, PA
My Commistion f;.p;~,:"h 5;2Oll1 .
..
\
NOTICE
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 00-4828 CML 2000
GARY L. NEFF.
Plaintiff
vs.
J.E. BROOKS and PAULINE
ESTELlA BROOKS. his wJfe. and
their respective heirs. successors
and assigns,
Defendants
ACTION TO QUIEf TITLE
NOTICE
To: J. E. Brooks and Pauline Estella
Brooks, his wife and their re-
spective heirs, successors and
assigns,
NOTICE IS HEREBY GIVEN that
on July 7. 2000. the above named
Plaintiff flIed a Complaint to Quiet
Title as above noted against you
seeking a Court Order decreeing that
Plaintiff owns the premises below de-
scrtbed in fee simple, free and clear
of any and all tight, title, interest.
claJm or demand which you may
have in and to said premises. Plaintiff
claims to be the owner of said prem-
Ises by virtue of regular chains of title
which are presently subject to possi-
ble outstanding interests of the
named defendants due to unre-
corded deeds in the chains of title as
well as issues regarding Tax Sales of
Real Estate and associated vartances
in the assessment records upon
which said sales were made. and is-
sues regarding validity of title from
the Commonwealth of Pennsylvania.
Plaintiff further seeks to clear and
remove any cloud of title which may
J~';, "
exist by reasori of questions regard-
ing the said unrecorded deeds, Tax
Sales and possibly erroneous, incon-
sistent and defective real estate tax
assessments and inconsistent grants
of title from the Commonwealth of
Pennsylvania for the premises which
are described as follows:
ALL THAT CERTAIN tract of land
in East Pennsboro Township, Cum-
berland County. bounded and de-
scrtbed as follows:
BEGINNING at a point on the
western side of a public road that
runs between Camp Hill and West
Fairview, which pOint is one hundred
seventy-nine and one tenth (179.1)
feet north of the land of the James
McCromick Estate;
thence along land of Minnie
Jones. two hundred twenty-nine and
seven tenths (229.7) feet to a point at
the low water mark of the Cono-
doguinet Creek; thence northwardly
up said Creek forty-seven and eIght
tenths (47.8) feet to a paint:
thence eastwardly along lands of
Carrie Stouffer. two hundred twenty-
six and four tenths (226.4) feet to the
above-mentioned public road;
thence southwardly along the
said public road forty-seven and nine
tenths (47.9)feetto a point, the place
of BEGINNING.
YOU ARE FURTIIER NOTIFIED
that the Court of Common Pleas of
Cumberland County. Pennsylvania.
has ordered that service of the Com-
plaint be made upon J. E. Brooks
and Pauline Estella Brooks, his wife,
and their respective heirs, succes-
sors and assigns, by an Order dated
July II. 2000. which requires that
this notice be published one time in
the Cumberland Law Journal and
also in one newspaper of general cir-
culation in Cumberland County,
Pennsylvania.
IF YOU WISH TO DEFEND, YOU
MUSf ENTER A WRITTEN APPEAR-
ANCE PERSONALLY OR BY ATIOR-
CUmberland Notices
1
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.
NEY AND FILE YOUR DEFENSES
OR OBJECTIONS IN WRmNG wrrn
THE COURT. YOU ARE WARNED
TIIAT IF YOU FAlL TO DO SO. lHE
CASE MAY PROCEED WITHOUT
YOU AND A JUDGMENT MAY BE
ENTERED AGAINST YOU wrrnOUT
FURlHER NOTICE FOR lHE RE-
LIEF REQUESTED IN THE COM-
PLAINT. YOU MAY LOSE MONEY OR
PROPERTY OR aTHER RIGHTS IM-
PORTANT TO YOU.
YOU SHOULD TAKE TIllS NO-
TICE TO YOUR LAWYER AT ONCE.
IFYOU DO NOTHAVEALAWYEROR
CANNOT AFFORD ONE. GO TO OR
TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL
HELP.
COURT ADMINISTRATOR
Third Floor
Cumberland County Court House
Carlisle, PA 17013
Telephone: (717) 2.400-6200
ROBERT G. RADEBACH.
ESQillRE
I.D. #19255
Attorney for Plalntlff
912 North River Road
Halifax. PA 17032
[71 7) 896-2666
July 28
2
Cumberland Notices
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
GARY L. NEFF,
Plaintiff
vs.
J.E. BROOKS and PAULINE ESTELLA
BROOKS, his wife, and their respective
heirs, successors and assigns,
NO. 00-4828
CIVIL 2000
Defendants
ACTION TO QUITE TITLE
AFFIDAVIT PURSUANT TO PA.R.C.P. I066(a)
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF DAUPHIN
Robert G. Radebach, Esquire, being duly sworn according to law deposes and says that
he is the Attorney for the Plaintiffs in the action above-captioned and that:
1. This action was commenced by the filing of a Complaint on July 7, 2000.
2. By an Order for Publication dated July 11, 2000, the Court directed that said
Complaint be served by publication of a Notice of Action to Quiet Title once in the Cumberland Law
Journal and once in a newspaper of general circulation in Cumberland County, Pennsylvania.
3. Pursuant to said Order, your Affiant caused the attached Notice to be duly advertised
in accordance with said Order with the last publication appearing on July 28, 2000, see Certificate of
Service filed.
this action which period of time exceeds the period of 20 days
This Affidavit is executed on May 23, 200 .
~>~
00 -~8~
. ....
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} 55
Michael Morrow being duly sworn according to law, deposes and says:
That he is the Ass!. Controller of The Patriot News Co., a corporation organized and existing under the laws
of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in
the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The
Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the
City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th,
1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as print.,d and published in.
their reguiar daily and/or Sunday/ Metro editions which appeared on the 13th day(s) of July 2001. That neither he
nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the
allegations of this statement as to the time, place and character of publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
, statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimousiy passed and
in
NOlarial Seal
Terry L RtJsseJI, Notary PubJic
Harri~b~rg. Dauphin County
My CommIssion Expires June 6, 2002
Member, Pennsylvania AssoCiation of Notaries
lIliscellaneous Notices
1-.:.: "iNT~~:~QURTQF COMMON PLEAS
I,'::::" 'O'F.CUMBERLANDCOUNTY,
. PENNSYLVANIA
.NO. GO-4828 CIVIL 2000
t,... .....CTIONTOQUIETTlTLE
GARY L',~'eFF,
Plaintiff
ROBERTG.RADEBACH
ATTORNEY-AT-LAW
912 NORTH RIVER ROAD
HALIFAX, PAc 17032
"..
:.J.E. BROOKS and PAULINE ESTELLA
BROOKS, hh. wife, and their respective
.heirs, sucCessors and assigns,
Defendants
POS'f-JUDGMENT NOTICE
T'O, ,J~ .e. Brooks ond Pauline Estella
Brooks.. Qncf'Hieir hlllrs sucessorsondassigns
You'are notltk'd that an ORDER FOR
JUDGME,NT .has been entered to No. 00-4828
Civil 2000 In the Co'urt of Common Pleas of'
CUmberlq!:\~ County, Pennsylvania, on Julv2,.
.2001, directing that wIthin 30 dayS after this
pUblicctl,on YOU or any of YOU should com-
mence an"'actlon In Ejectment against the
.above..na,i'jied Plaintiffs, Gary L. Neff lor pas-
sllulan of' the -premises hereinbelow de.
scribed ~ ~ forever barred from asserting
any rlgnf.' Ilen, title or interest Inconsistent
with the I",erestor clalmsetforth lnthe Ploln-
tIff's comPlcllit to the land descrlbed,ClS fol-
. lows: .... '
ALL"THAT CERTAIN tract 01 land In
Eelst perin'.;boro Township, Cumberland
COUnty, bOunded C1nd described os follQWS:
8EGINNING at a point on the western
side ot Pl.lbllc road that runs betweM Camp
Hili and Wftst Falrvlew, which ,POInt Is onl!!
.~hundred:'se\li!lntY-nine and one 'tenth (179.1)
feetnorthot the land ottheJamesMeCromlck
estate: :thence along land of MInnie Jones,
two hurid~,d twenty-nine Qnd seven tenths
(2'J9.?) 1eettoo palntatthe low water markot
the ConO<;loguinet Creek: thence northwardly
UP said Creek rorty-se~n and eight tenths
(47.8) f~ttoClPOlnt; ftwnce-eastwardly olonSl'
lands of Corrie Stouffer I two hundred twenty-
six and lcIur'tenths (226.4) feet to the above-
. menHoned.pubilc road; thence southwardly
along the said publlc road forty-seven and'
nine tenths {41/n feet to a point. the place of
BEGINNING.
RGbfli"t'G. Radebach, Es;qulrlt
912 NOTfl'l River Road
l:fall(a'X.,PA 17032
Attorn'lI\' fOr Plalntlffs
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $
Probating same Notary Fee(s) $
Total $
198.04
1.50
199.54
Publisher's Receipt for Advertising Cost
publisher of The Patriot-News and The Sundav Patriot-News. newspapers of general
~ receipt of the aforesaid notice and publication costs and certifies that the same have
i
I
By....................................................................
.- ~~-
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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, ofthe County
and State ~foresaid, 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
JULY 20, 2001
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
(J
Roger . Morgenthal, Editor -
SWORN TO AND SUBSCRIBED before me this
20 dayof JULY. 2001
NOT.
1.OISE.~NIc
Carfisll!Bolo, CuiIl Capnty
My Com!nission ExpIres MardIS. 2005
--~'"
-
.
.
CUMBERlAND LAW JOURNAL
NOTICE
In the Court of Common Pleas of
Cumberland County. Pennsylvania
No. 00-4828 Civil 2000
GARY L. NEFF.
Plaintiff
vs.
J.E. BROOKS and
PAULINE ESTELLA BROOKS.
his wife. and their respective
heirs. successors and assigns,
Defendants
ACTION TO QUIET TITLE
POST -JUDGMENT NOTICE
TO: J. E. Brooks and Pauline Estella
Brooks, and their heirs succes-
sors and assigns
You are notified that an ORDER
FOR JUDGMENf has been entered
to No. 00-4828 Civil 2000 in the
Court of Common Pleas of Cumber-
land County. PennsylvanIa. on July
2, 2001. dIrecting that within 30
days after this publication you or
any of you should commence an
action in Ejectment against the
above-named Plaintiff. Gat}' L. Neff
for possession of the premises here-
inbelow described or be forever
barred from asserting any right.
lien. title or interest inconsistent
with the interest or claim set forth
in the Plaintiffs complaint to the land
described as follows:
ALL '!HAT CERTAIN tract of land
in East Pennsboro Township. Cum-
berland County, bounded and de-
scribed as follows:
BEGINNING at a point on the
western side of a public road that
runs between Camp Hill and West
Fairview. which point is one hun-
dred seventy-nine and one tenth
(179.1) feet north of the land of the
James McCromick Estate; thence
along land of Minnie Jones, two
hundred twenty-nine and seven
tenths (229.7) feet to a point at the
low water mark of the Conodoguinet
Creek; thence northwardly up said
Creek forty-seven and eight tenths
(47.8) feet to a point; thence east-
wardly along lands of Carrie Stouffer.
two hundred twenty-six and four
tenths (226.4) feet to the above-
mentioned public road; thence
southwardly along the said public
road forty-seven and nine tenths
(47.9) feet to a point. the place of
BEGlNNING.
ROBERT G. RADEBACH.
ESQUIRE
Attorney for Plaintiffs
912 North River Road
Halifax. PA 17032
July 20
2
! .
~'~. -'::',
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
GARY L. NEFF,
Plaintiff
VB.
J.E. BROOKS and PAULINE ESTELLA
BROOKS, his wife, and their respective
heirs, successors and assigns,
Defenda,nts
NO.00-4828 CIVIL 2000
ACTION TO QUITE TITLE
PRAECIPE FOR FINAL JUDGMENT
TO THE PROTHONOTARY:
KiIld]y enter on the Appearance Docket and on the Decree a notation
that the Defendants, J.E. BROOKS and PAULINE ESTELLA. BROOKS, his wife,
and their heirs suooessors and assigns, failed to take the action directed in the
last advertisement within the time therein limited.
KiIld]y transmit to the Recorder of Deeds a certified oOPY of the Decree
oontainiJO,g the notation above desoribed, see affidavit of advertisement
attaohed hereto, which is made a part hereof.
Dated:Maroh 13, 2003
Rob rt G. debach, Esquire
912 North River Road
Halifax, PA 17032
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL VANIA
JUN2 22~
GARY L. NEFF,
Plaintiff
vs.
lE. BROOKS and PAULINE ESTELLA
BROOKS, his wife, and their respective
heirs, successors and assigns,
NO. 00-4828
CIVIL 2000
Defendants
ACTION TO QUITE TITLE
ORDER FOR mDGMENT
AND NOW, this )., Ncl day of U ~/Y'
, 2001, upon presentation
and consideration of the within Motion and at the suggestion of Robert G. Radebach, Attorney for
Plaintiffs, it is hereby ORDERED and DECREED as follows:
1. That the Complaint to Quiet Title has been duly served upon the Defendants above
named by publication which service was completed on July 28, 2000.
2. From and after the aforesaid date of service the said Defendants and their respective
heirs, successors and assigns have neither appeared nor answered said Complaint.
3. Plaintiff appears to be entitled to the relief requested in the Complaint filed in the
above action.
4. It is hereby ordered and decreed that the Defendants, 1 E. Brooks, Pauline Estella
Brooks, his wife, and their heirs successors and assigns be forever barred from asserting any right, lien,
title or interest in the following described premises:
ALL THAT CERTAIN tract ofland in East Pennsboro Township, Cumberland County, bounded and
described as follows:
BEGINNING at a point on the westem side of a public road that runs between Camp Hill and West
Fairview, which point is one hundred seventy-nine and one tenth (179.1) feet north of the land of the
James McCromick Estate;
thence along land of Minnie Jones, two hundred twenty-nine and seven tenths (229.7) feet to a point at
the low water mark of the Conodoguinet Creek;
thence northwardly up said Creek forty-seven and eight tenths (47.8) feet to a point;
thence eastwardly along lands of Carrie Stouffer, two hundred twenty-six and four tenths (226.4) feet to
the above-mentioned public road;
thence southwardly along the said public road forty-seven and nine tenths (47.9) feet to a point, the place
ofBEGINNING.
'"' ~'"
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unless the said Defendants or their heirs, successors or assigns commence an action in Ejectment against
the Plaintiffs for the premises above described, within 30 days after the publication of the Notice ofthis
Order.
5. If the said Defendants fail to act as required by this Order within the prescribed period of time,
then this Order shall become final and the Plaintiff shall be the Owner in fee simple of the herein-
described premises free and clear of any and all right, title, interest, claim or demand of the said J.E.
Brooks and Pauline Estella Brooks, and their heirs successors and assigns, and said Defendants shall be
further barred from denying, impeaching or in any way attacking Plaintiffs title in and to the said
premises.
J~
.:~~
~~j-b\
March 14. 2003. Final Judgment is hereby entered in favor of the Plaintiff
and against the Defendants Pursuant to PA. R.C.P. Rule No. 1066 and Local
Rule 1066.4. The Defendants have failed to take the action directed.
Curtis R. Long. Protho otary
o. ~ "', - ,'L_~~" ,'-J.~--';;;,.'-~ ,-',\h~'_.', ,-__'__L"'_. --"--;i<.,<'::'","-,_';;"'''~~~~",-~'''' "".,',-.:J;":~ .' '",.:'",___,~-.,.-_ ~,,,,~,:,'--,:;,;,,':Ji-c;;i'-~,,,';2-~ __:":";;~A.--hc_'" ,<,,';j',K-Jih,:
. ,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
GARY L. NEFF,
Plaintiff
vs.
J.E. BROOKS and PAULINE ESTELLA
BROOKS, his wife, and their respective
heirs, successors and assigns,
NO. 00-4828
CIVIL 2000
Defendants
ACTION TO QUITE TITLE
MOTION FOR JUDGMENT
AND NOW, this d I.Rt day of ~ ,2001, come the
Plaintiff, Gary 1. Neff, by his attorney Robert G. Radebach, and moves the Court to enter
judgment in his favor and against the Defendants, lE. Brooks and Pauline Estella Brooks, his
wife, and their heirs successors and assigns, and in support thereof assigns the following:
1. This action was commenced on July 7, 2000, by the filing of a Complaint in
the above-captioned matter.
2. By an Order for Publication dated July II, 2000, your Honorable Court
ordered that the Complaint be served upon the Defendants by publication as required once a
week in one newspaper of general circulation in Cumberland County, Peunsylvania, and once in
the Cumberland Law Journal.
3. On July 28, 2000, the said service by publication was completed as evidenced
by the Proofs of Publication which are attached hereto and which are hereby made a part hereof.
4. From and after July 28,2000, none of the Defendants nor any of their
-,-",
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respective heirs, successors and assigns have either appeared in this action or have they filed any
pleadings which period of time now exceeds the space of 20 days.
5. Plaintiff is entitled to an Order subst
fIll provided by PaRC.P.
I 066(b)(I) granting him relief requested in this Co
Robert G. Radebach, Esquire
Attorney for Plaintiff
912 North River Road
Halifax, P A 17032
(717) 896-2666
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,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
GARY 1. NEFF,
Plaintiff
vs.
lE. BROOKS and PAULINE ESTELLA
BROOKS, his wife, and their respective
heirs, successors and assigns,
NO. 00-4828
CIVIL 2000
Defendants
ACTION TO QUITE TITLE
AFFIDAVIT OF ADVERTISEMENT
COMMONWEALTH OF PENNSYLVANIA
: SS
COUNTY OF DAUPHIN
Robert G. Radebach, Esquire, being duly sworn accordin
and says that he represents the Plaintiff in the action above captione d at on J y 13,
2001, the attached Post Judgment Notice was advertised in the P ot ews.
further swears that on July 20, 2001, the attached notice was a e . ed in
Cumberland Law Journal. Proofs of Publication are attached er 0 and
a part hereof.
Further your deponent saith not.
G.Radebach,Esqurre
Attorney for Plaintiff
912 North River Road
Halifax, P A 17032
(717) 896-2666
Sworn to and subscribed before
ethis 24th day~
otary ublic
NOTARIAL SEAL
JOANNE M. BLOSE, Notary Public
Halifax iOWfl$hlp, Dauphin County
M Qemml8lllon Ires rll ~,_~
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PROOF OF PUBLICATION OF NOTICE.
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATEOFPENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, Esquire, Editor ofthe 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
JULY 20, 2001
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Joumal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, an4 that all allegations in the foregoing
statements as to time, place and character of publication are
ROge J Morgenthal, Editor -
SWORN TO AND SUBSCRIBED before me this
20 dayof JULY. 2001
NOli .
LOISE.~PldlIIc
CarlialeBolo. CIIii. CcIIIIlY
My CommlIsIon Elcplr&s Man:h 5. 2005
iliLt:,..!.1WBi',:
-"~
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'"~~~"
CUMBERIAND LAW JOURNAL
NOTICE
In the Court of Common Pleas of
Cumberland County. Pennsylvanla
No. 00-4828 Civil 2000
GARY L. NEFF.
PIalntllT
vs.
J.E. BROOKS and
PAULINE ESTELLA BROOKS.
Ws wife. and their respective
heirs. successors and assigns.
Defendants
ACTION TO QUIET TlTJ.E
POST-JUDGMENT NOTICE
TO: J. E. Brooks and Pauline Estella
BI"Ooks. and their heirs succes-
sors and assigns
You are notified that an ORDER
FOR JUDGMENT has been entered
to No. 00-4828 Civil 2000 In the
Court of Common Pleas of Cumber-
land County. Pennsylvanla. on July
2. 2001. directing that within 30
days after this publication you or
any of you should commence an
action in Ejectment against the
above-named PIalntllT. Gary L. Neff
for possession of the premises here-
inbelow described or be forever
barred from asserting any right.
lien. title or interest inconsistent
with the interest or claim set forth
In the Plalntlll's complaint to the land
described as follows:
ALL TliATCERTAlN tract of land
in East Pennsboro TownsWp. Cum-
berland County. bounded and de-
scribed as follows:
BEGINNING at a point on the
western side of a public road that
runs between Camp Hill and West
FalrvIew. which point Is one hun-
dred seventy-nine and one tenth
(179.1) feet north of the land of the
James McCromick Estate; thence
along land of Minnie Jones. two
hundred twenty-nine and seven
tenths (229.7) feet to a point at the
low water mark of the Conodogulnet
Creek; thence northwardly up said
Creek forty-seven and eight tenths
(47.8) feet to a point; thence east-
wardly along lands of Carrie Stouffer.
two hundred twenty-six and four
tenths (226.4) feet to the above-
mentioned public road; thence
southwardly along the said public
road forty-seven and nine tenths
(47.9) feet to a point. the place of
BEGINNING.
ROBERT G. RADEBACH.
ESQUIRE
Attorney for Plaintiffs
912 North River Road
Halifax. PA 17032
July 20
2
~I ,- ~ ""'~[j
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~
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~
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
GARY L. NEFF,
Plaintiff
vs.
I.E. BROOKS and PAULINE ESTELLA
BROOKS, his wife, and their respective
heirs, successors and assigns,
NO. 00-4828
CIVIL 2000
Defendants
ACTION TO QUITE TITLE
POST-JUDGMENT NOTICE
TO: 1. E. Brooks and Pauline Estella Brooks, and their heirs successors and assigns
You are notified that an ORDER FOR mDGMENT has been entered to No.00-4828 Civil 2000
in the Court of Common Pleas of Cumberland County, Pennsylvania, on July 2, 2001, directing that within 30 days
after this publication you or any of you should commence an action in Ejectment against the above-named
Plaintiffs, Gary L. Neff for possession of the premises hereinbelow described or be forever barred from asserting
any right, lien, title or interest inconsistent with the interest or claim set forth in the Plaintiffs complaint to the land
described as follows:
ALL THAT CERTAIN tract ofland in East Pennsboro Township, Cumberland County, bounded and
described as follows:
BEGINNING at a point on the western side ofa public foad that runs between Camp HiII and West
Fairview, which point is one hundred seventy-nine and one tenth (179.1) feet north of the land of the
James McCromick Estate;
thence along land of Minnie Jones, two hundred twenty-nine and seven tenths (229.7) feet to a point at
the low water mark of the Conodoguinet Creek;
thence northwardly up said Creek forty-seven and eight tenths (47.8) feet to a point;
thence eastwardly along lands of Carrie Stouffer, two hundred twenty-six and four tenths (226.4) feet to
the above-mentioned public road;
thence southwardly along the said public road forty-seven and nine tenths (47.9) feet to a point, the place
of BEGINNING.
Robert G. Radebach, Esquire
912 North River Road
Halifax, P A 17032
Attorney for Plaintiffs
" .
, ",,).-, !~~.
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16,1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Michael Morrow being duly sworn according to law, deposes and says:
That he is the Ass!. Controller of The Patriot News Co., a corporation organized and existing under the laws
of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in
the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publiSher of The Patriot-News and.iM
Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the
City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th,
1854, and September 18th, 1949, respectively, and all have been continuously pubiished ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday/ Metro editions which appeared on the 13th day(s} of July 2001. That neither he
nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the
allegations of this statement as to the time, place and character of publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and SUbsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COpy
................................U~.........................h......
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Sworn to and subscribe b
. 0i'~';iM1lleiianeo~sNotices f,Y,,:'. '.
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$;tVe '"f11MlI;l"IlU'onalenthtl ')r ... .
_....E..a-.:;~...., ......,_. J'1T"'M1-'Ck receipt of the aforesaid notice and publlcation costs and certifies that the same have
""..,"'; Q on;: u. nnle Jones,
two himdred ~tv-nlnt':and AveR fltnths
(229.7) feottoapolr,l;.at!J,e IOW,WOhtr mar~Qf
ll>o coaodo<Nl6et em'" ......nOl1fuiia'dly
us) sQldj::riel(,forty-scvm'.~ 'elQhT,tenths:'
(4.7.8) fiCttoopOlnt; 'ttIinaI Castwotdlv along
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,::llanla""!'A "Ff
Notarial Seal
Terry L. F1ussell, Notary Publ/c
Harrisburg. Dauphin County
My Commission Expires June 6, 2002
Member, PennsylVania Asspciation of Notaries
N TARY PUBLIC
My commission expires June 6, 2002
ROBERT G. RADEBACH
ATTORNEY-AT-LAW
912 NORTH RIVER ROAD
HAliFAX, PAc 17032
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
F6r publishing the notice or publication attached
hereto on the above stated dates
Probating same Notary Fee(s)
Total
$
$
$
198.04
1.50
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