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6, Plnintill's nbstrnclllftitlc is nllnchcd herctllns Exhibit "B".
7. Dclcndnnt wns notificd llf Plnintill's title, bUI dcclincd III dclivcr up Pllsscssionthercof:
WHEREFORE, the Plnintiff pruys this Honllruble Court tll en IeI' n Dccrce tcrminnting nil
rights of the Defcndants herein 10 possession, nnd that the Plainlif1' mny hnve the filllnnd free use
and occupation of the said premises, released and forever discharged of any lien or encumbrance,
and further, that a Writ of Possession be issued and other relief be permitted in order 10 provide the
Plaintiff with clear title and possession of the premises.
Respectfully Submitted,
JAFFE, FRIEDMAN, SCHUMAN, SCIOLLA,
N~?PPLEBAUM' P.c.
BY: v?-
KERR S. SCHUMAN, ESQUIRE
Allorney for Plaintiff
VERIFICATION
I, John Stanifer, agent for the Plaintiff herein, hereby slate I am a duly authorized agent for
Plaintiff in this action and verify that the statements made in the foregoing pleading are true and
correct to the best of my knowledge, infommtion and belief. The undersigned understands that tillse
statements herein arc made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn
falsification to authorities.
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EXHIB1T "A"
ALL THOSE CERTAiN pieces or parcels of land situate in the Township of Silver Spring
County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and
described as follows, to wit:
TRACT NO. I: BEGINNING at a point in the center of the State Highway leading from
Mechanicsburg to Hogestown at comer of Lot No. 12 in the Plan of Lots laid out by W.G.
Rechel; thence along said Lot No. 12, South 34 degrees 45 minutes West. a distance of one
hundred fifty (150) feet to 1I point; thence on a line parallel with said State Highway, South 55
degrees 15 minutes East, a distance of one hundred (100) feet to a point at Lot No.9; thence
along said Lot No.9, North 34 degrees 45 minutes East, a distance of one hundred fifty (150)
feet to a point in the center of said State Highway; thence along the center of the aforesaid State
Highway, North 55 degrees 15 minutes'West, a distance of one hundred (100) feet to Lot No.
12, at the place of BEGINNING.
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BENG Lots Nos. 10 and II in the Plan of Lots laid out by W.G. Rechel, Registered Surveyor,
datcd November 17, 1949.
HA VL.'\fG TIiEREON ERECTED a one and one-half story permastone dwelling house known
as and numbered No. 315 Hogestown Road, Mechanicsburg, Pennsylvania.
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TRACT NO.2: BEGINNING at a point in the center of the public road leading from
Mechanicsburg to Hogestown at lands now or formerly of Walter H. Engel, being Lot No.8
on the hereinafter mentioned Plan of Lots; thence by said lands, SOllth 34 degrees 45 minutes
West, one hundred fifty (150) feet to a point at other lands now or formt:rly of Harry E. Deitz
and Elsie S. Deitz, his wife; thence by said other lands now or formerly of Harry R. Deitz, et
UX" North 55 degrees 15 minutes We:lt, fifty (50) feet to a point at oth.er lands now or formerly
of William Joseph Ulmer and Margaretta E. Ulmer, his wife, being Lot No. 10 on the
hereinafter mentioned plan; thence by tlle same, North 34 degrees 45 minutes East, one hundred
fifty (150) feet to a point in the center of the aforesaid public road from Mechanicsburg to
Hogestown; thence by the center line of said road, South 55 degrees 15 minutes East fifty (50),
feet to a point, the place of BEGINNING. ....
BEING Lot No.9 in the Plan of Lots laid out by W.G. Rechel, Registered Surveyor, dated
November 17, 1949.
BEING the same lot of ground which by D.:ed dated April 29, 1992 and recorded in the Office
of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Book R 35, Page 203
was granted and conveyed by Kenneth J. Ulmer, individually, and Kenneth J, Ulmer, as
Executor of the Estate of margaretta J. Ulmer, unto Kenneth J, Ulmer, the Borrower herein.
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'.;111:r, IiI' '.: liLTUl-:Il
W'T ICOUllf'
C^~~,~ no: l':l':HJol/"'1o'l.>l I'
CUl'INe'NWEAL TH UF PLtlNSYL v AN 1 ^:
COUNTY OF CUMDERLAND
UNITED MORTGAGE t LOAN INVEST
VS.
ULMER KENNETH J ET AL
R, Thomas Kline
, Sheriff, who
being duly sworn according
and inquiry for the within
to law, says, that he made a diligent search
named defendant, to wit: ULMER KENNETH J
but was unable to locate Him
in his bailiwick. He therefore returns
the COMPLAINT - EJECTMENT
NOT FOUND , as to the within named defendant
ULMER KENNETH J
HOUSE LOOKS TO BE ABANDONDED, TALKED TO NEIGHBOR
HAS NOT SEEN ANY BODY AT ADDRESS FOR 3 MONTHS.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
5.58
.00
2,00
$25,~~ JAFFE FRIEDMAN SCHUMAN DCIOLLA
01/30/1998
Sworn and~subscri~.~e;ore me
this ~__ day 0
19 99 A.D.
Ch~O~I'Y~
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EXHIBIT "A"
ALL nrOSE CERTAIN pieces or parcels of land situate in the Township of Silver Spring
County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and
described as foUows, to wit;
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TRACT NO. I: BEGINNING at a point in the center of the State Highway leading from
Mechanicsburg to Hogestown at comer of Lot No, 12 in the Plan of Lots laid out by W.G.
Rechel; thence along said Lot No. 12, South 34 degrees 45 minutes West, a distance of one
hundred fifty (150) feet to a point; thence on a line parallel with said State Highway, South 55
degrees 15 minutes East, a distance of one hundred (100) feet to a point at Lot No.9; the lice
along said Lot No.9, North 34 degrees 45 minutes East, a distance of one hundred fifty (150)
feet to a point in the center of said State Highway; thence along the center of the aforesaid State
Highway, North 55 degrees 15 minutes"West, a distance of one hundred (100) feet to Lot No.
12, at the place of BEGINNING.
BEING Lots Nos. 10 and II in the Plan of Lots laid out by W.G. Rechel, Registered Surveyor,
dated November 17, 1949.
HA VL.'TG nIEREON ERECTED a one and one-half story permastone dwelling house known
as and numbered No. 315 Hoge~town Road, Mechanicsburg, Pennsylvania.
IRACT NO.2; BEGINNING at a point in the center of the public road leading from
Mechanicsburg to Hogestown at laJlds now or formerly of Walter H. Engel, being Lot No. 8
on the hereinafter mentioned Plan of Lots; thence by said lands, South 34 degrees 45 minutes
West, one hundred fifty (150) feet to a point at other lands now or formerly of Harry E. Deitz
and Elsie S. Deitz, his wife; thence by said other lands now or formerly of Harry R. Deitz, et
ux., North 55 degrees 15 minutes We:;t, fifty (50) feet to a point at ot~er lands now or formerly
of William Joseph Ulmer and Marga.retta E, Ulmer, his wife, being Lot No. 10 on the
hereinafter mentioned plan; thence by tlle same, North 34 degrees 45 minutes East, one hundred
fifty (150) feet to a point in the center of the aforesaid public road from Mechanicsburg to
'Hogestown; thence by the center line of said road, South 55 degrees 15 minutes East fifty (50),
feet to a point, the place of BEGINNING. ,".
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BEING Lot No, 9 in the Plan of Lots laid out by W.G. Rechel, Registered Surveyor, dated
November 17, 1949.
BEING the same lot of ground which by D'~d dated April 29, 1992 and recorded in the Office
of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Book R 35, Page 203
was granted and conveyed by Kenneth J. Ulmer, indiVidUally, and Kenneth J, Ulmer, as
E.'(ecutor of the Estate of margaretta J, Ulmer, unto Kenneth J. Ulmer, the Borrower herein,
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OFFlllE OF Tile SIIEIIIFF
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JAM ZG 8 19 AM '90
CM\L1~;LE
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