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HomeMy WebLinkAbout91-1403EGM/January 29, 1991/3025 NANCY T. ANTHONY, HENRY D. TWITCHELL, JR. GEORGE G. TWITCHELL AND CLAIRE E. GRANT Plaintiffs We EBERLY'S MILLS CHURCH OF GOD OF LOWER ALLEN TOWNSHIP Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CIVIL 1991 ACTION IN EJECTMENT NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defense 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 H~VE A LAWYER OR C~qNOT AFFORD ONEv GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU C~ GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND CO COURTHOUSE 1 COURTHOUSE SO CARLISLE PA 17013 3387 (717) 240 6200 4th FLOOR NANCY T. ANTHONY, HENRY D. TWITCHELL, JR. GEORGE G. TWITCHELL AND CLAIRE E. GRANT Plaintiffs We EBERLY'S MILLS CHURCH OF GOD OF LOWER ALLEN TOWNSHIP Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CIVIL 1991 ACTION IN EJECTMENT COMPLAINT Come now, Nancy T. Anthony, Henry D. Twitchell, Jr., George G. Twitchell and Claire E. Grant, through their attorneys, Johnson, Duffie, Stewart & Weidner, and state the following complaint: Plaintiffs are Nancy T. Anthony, an adult individual who resides at 1810 Lamb's Gap Road, Mechanicsburg, Pennsylvania 17055; Henry D. Twitchell, Jr., an adult individual who resides at 4 Hawthorne Road, Winchester, Massachusetts 01890; George G. Twitchell, an adult individual who resides at 106 Spring Lane, West Hartford, Connecticut 06107; and Claire E. Grant, an adult individual who resides at 37 Hudson Road, Box 43, Bangor, Maine 04401. Defendant is Eberly's Mills Church of God of Lower Allen Township, an unincorporated association with an office at 115 Creek Road, Camp Hill, Pennsylvania 17011. The real estate which is the subject of this action is located in Lower Allen Township, Cumberland County, Pennsylvania, as more particularly described on Exhibit "A" attached hereto and made a part hereof. 4. Defendant is in possession of the real estate. Plaintiffs claim fee simple title to the real estate described herein as tenants in common, each of an undivided one-fourth interest, as heirs of Kate F. Gorgas, single women, and George A. Gorgas and Rachel M.G. Gorgas, his wife. The source of Plaintiffs' title is the Deed dated December 15, 1931 from Kate F. Gorgas, George A. Gorgas and Rachel M.G. Gorgas, his wife, to C.W. Fetrow and W.F. Thompson, Trustees of Eberly's Mills Church of God of Lower Allen Township, recorded April 28, 1932 in Deed Book H, Volume 11, Page 68, Cumberland County Recorder of Deeds Office, a copy of which is attached hereto and made a part hereof as Exhibit "B". The grant to the Defendant from Plaintiffs' predecessors in title was a fee simple determinable. Defendant was required not only to use the property for the purpose of holding of socials, plays, festivals, and other community enterprises, with preference to be given to the men's bible class of Eberly's Mills Church of God, but also to maintain any building or buildings erected on said real estate ~n good repair and to maintain a fence on both the north and the east sides of the real estate. Defendant allowed the buildings to fall into disrepair and to deteriorate, failed to maintain a fence on both the north and east sides of said real estate, and failed to use the property for the purposes stated in the Deed, whereby upon the occurrence of such failures, title reverted to the original Grantors in said Deed, their heirs, executors, administrators and assigns. Kate F. Gorgas died in 1942, without issue, and George A. Gorgas died on November 12, 1939 survived by his wife, Rachel M.G. Gorgas, who later died on July 22, 1952, survived by Katherine Gorgas Twitchell. 10. Katherine Gorgas Twitchell died in 1953, survived by four children, the Plaintiffs herein. 11. Defendant's failure to use the real estate or maintain it in accordance with the Deed has caused a reversion of the fee simple title to the Plaintiffs. WHEREFORE, Plaintiffs demand judgment in their favor and against Defendant, its successors and assigns, for possession of the real estate; and pray for the entry of an order confirming that they hold fee simple title as tenants in common. Respectfully submitted JOHNSON, DUFFIE, STEWART & WEIDNER Edmund G. Myers Attorney ' s Identification No. 20558 301 Market Street P.O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiffs VERIFICATION I, the undersigned, verify that the statements contained herein are true and correct to the best of my knowledge information and belief. I understand that the statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 related to unsworn falsification to authorities. Date-. Nancy ~. Anthony ~--__~ [B?T ~A~ DESCR'rPT~ON OF RE~L EST~,TE ALL that certain lot or place of ground situate and being in Lower Allen Township, Cumberland County, State of Pennsylvania aforesaid, bounded and described as follows, to wit: BEGINNING at a post on a public road leading to Hakes Mills; thence by said road south twelve degrees east twelve and six-tenths (12.6) perches to a post in said road; thence by land now or formerly of Henry Stephan, south fifty-nine degrees east, eight and four-tenths (8.4) perches to a stone; thence by the same south eighty-three and one-half degrees east, two and seven-tenths (2.7) perches to a stone; thence by land now or formerly of William R. Gorgas, north nine degrees west, eighteen and three-tenths (18.3) perches to a stone; thence by the same eighty degrees west ten and two- tenths (10.2) perches to the place of Beginning; containing one acre of land neat measure, be the same more or less. NANCY T. ANTHONY, HENRY D. TWITCHELL, JR., GEORGE G. TWITCHELL and CLAIRE E. GRANT, Plaintiffs VSo EBERLY'.S~MILL CHURCH OF GOD OF LOWER ALLEN TOWNSHIP, Defendant : IN THE COURT OF COMMON PLEAS : : CUMBERLAND COUNTY, : : PENNSYLVANIA : : NO. 1403 Civil 1991 : : CIVIL ACTION - LAW : : ACTION IN EJECTMENT NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Answer and New Matter and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defense or objection 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 Answer and New Matter 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. COURT ADMINISTRATOR CUMBERLAND COUNTY COURT HOUSE FOURTH FLOOR 1 COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 17013-3387 (717) 240-6200 NANCY T. ANTHONY, HENRY D. TWITCHELL, JR., GEORGE G. TWITCHELL and CLAIRE E. GRANT, Plaintiffs VSo EBERLY'S MILL CHURCH OF GOD OF LOWER ALLEN TOWNSHIP, Defendant : IN THE COURT OF COMMON PLEAS : : CUMBERLAND COUNTY, : PENNSYLVANIA : : NO. 1403 Civil 1991 : : CIVIL ACTION - LA%~ : : ACTION IN EJECTMENT DEFENDANT'S ANSWER AND NEW MATTER 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. o estate. Denied. Plaintiffs have no interest in said real 6. Admitted in part and denied in part. It is admitted that a deed dated December 15 1931, and recorded in Deed Book H, Volume II, Page 68, Cumberland County Recorder of Deeds Office is the source of Defendant's possession and title to said reality. It is denied that said conveyance created any interest in Plaintiffs. No Exhibit "B" is appended to Defendant's copy of the Complaint. Therefore, Defendant is unable to render an opinion as to the truth or falsity or authenticity of said documents. 7. Denied. It is denied that the transfer in question created a fee simple determinable. To the contrary the transfer created a fee simple in Defendant or a fee simple subject to a right of reentry for breach of condition or a fee simple subject to an executory limitation or a fee simple subject to trust. 8. Admitted in part and denied in part. It is admitted that no separately constructed fence now exists. However, no such fence has existed for at least twenty-one (21) years. A fence row of trees and shrubs does exist delineating the property boundary. It is denied that the Defendant has allowed the building to "fall in disrepair and to deteriorate". To the contrary, the building exists and is structurally sound. It is admitted that the "Men's Bible Class of Eberly's Mill Church of God" no longer meets in the building. However, the class has not used the building since 1964. The building is used for "community enterprises" in that the Defendant, Church of God, used the building for storage of church material and as an annex and adjunct building. 9. Defendant is without knowledge or information sufficient to form an opinion as to the truth or falsity of the averment. The same is therefore denied and proof thereof demanded at trial. 10. Defendant is without knowledge or information sufficient to form an opinion as to the truth or falsity of the averment. The same is therefore denied and proof thereof demanded at trial. 11. Denied. Defendant has breached no "condition" within the deed nor has any reversion occurred. WHEREFORE, Defendant requests that Plaintiff's Complaint be dismissed. -2- NEW MATTER 12. Defendant's ansWers to one through 12. above are incorporated herein by reference. 13. Plaintiff is barred from pursuing this action by the applicable Statute of Limitations, (42 Pa. C.S.A. ~5530). 14. Plaintiffs are barred from pursuing this action by the doctrine of laches. 15. The Rule Against Perpetuities, 20 Pa. C.S.A. ~6104, prohibits enforcement of the language contained in the deed in question. 16. Plaintiff's have waived their right to exert any property interest by reason of their inaction and delay. 17. Plaintiffs are barred from exerting any property right by virtue of the fact that Plaintiffs failed to act within a reasonable time and the law implies a reasonable time limitation for deed limitations of this nature. WHEREFORE, Defendant requests that Plaintiff's Complaint be dismissed. Respectfully Submitted: DISSINGER & DISSINGER By: Wil-liam C. Dissinger ~/~ 28 North Thirty-Seco~ Street Camp Hill, PA 1701]/' (717) 975-2840 VERIFICATION I, Wayne E. Noss, verify that the statements contained to the herein Answer and New Matter are true and correct to the best of my knowledge, information and belief. I understand that the statements herein are made subject to the penalties of 18 Pa. C.S.A. ~4904 related to unsworn falsification to authorities. Date: .5 -- '7,'- Wayne ~ Nos'~')/ CERTIFICATE OF SERVICE I, William C. Dissinger, Esquire do hereby certify that I have this date served a true and correct copy of the foregoing Answer and New Matter upon the person listed below, by depositing the same in the United States Mail, postage prepaid, addressed as follows: Date: Edmund G. Myers, Esquire Johnson, Duffie, Stewart & Weidner 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 EGM/June 6, 1991/7007 NANCY T. ANTHONY, HENRY D. TWITCHELL, JR., GEORGE G. TWITCHELL and CLAIRE E. GRANT, Plaintiffs vs. EBERLY'S MILL CHURCH OF GOD OF LOWER ALLEN TOWNSHIP, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 1403 CIVIL 1991 CIVIL ACTION - LAW ACTION IN EJECTMENT PLAINTIFFS' REPLY TO NEW MATTER AND NOW come Plaintiffs, through their attorneys, Johnson, Duffie, Stewart & Weidner, and file the following reply to Defendant's New Matter. 12. No response required. 13. Denied. This averment is a conclusion of law to which no responsive pleading is required. 14. Denied. This averment is a conclusion of law to which no responsive pleading is required, and no facts have been pleaded in support. 15. Denied. This averment is a conclusion of law to which no responsive pleading is required. 16. Denied. On the contrary, Plaintiffs acted with diligence upon discovering the condition and misuse of the property by Defendant. 17. Denied. On the contrary, Plaintiffs acted with dispatch upon discovering the condition and his use of the property. To the extent that EGM/June 6, 1991/7007 , this averment contains a legal conclusion, such conclusion is denied as no responsive pleading is required. WHEREFORE, Plaintiffs request an entry of an Order for possession of the real estate and confirmation that they hold fee simple title as tenants in common. RESPECTFULLY SUBMITTED, Johnson, Duffle, Stewart & Weidner BY: Edmund G. Myers Attorney'sIdentification No. 20558 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiffs EGM/June 6, 1991/7007 VERIFICATION I, the undersigned, verify that the statements contained herein are true and correct to the best of my knowledge, information and belief. I understand that the statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 related to unsworn falsification to authorities. DATED N&ncy T~ AntHon~ EGM/June 6, 1991/7007 CERTIFICATE OF ~ERVICE The undersigned hereby certifies that he served a true and correct copy of the Plaintiffs, reply to new matter by depositing same, postage prepaid, addressed as follows: William C. Dissinger, Esquire Dissinger &Dissinger 28 North 32nd Street Camp Hill, Pennsylvania 17011 DATED- Edmund G. rs SHERIFF' S RETURN CC~R40~EA_LTH OF PENNSYLVANIA: COUNTY OF CllV~ERLAND Nancy T. Anthony, Henry D. Twitchell Jr. George G. Twitchell and Claire E. Grant VS Eberly's Mills Church of God of Lower Allen Township In the Court of Common Pleas of Cumberland County, Pennsylvania N0. 1403 Civil Term, 1991 Complaint Action in Ejectment and Notice to Defend Harry King · S~~pr Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, that he served the within Complaint Action in Ejectment and Notice to DEfend Eberly's Mills Church of God of upon Lower Allen Township , the defendant, at 11:40 o'clock A .M.X~K/ EDST, on the 25th 115 Creek Road, Camp Hill day of April , 19 25at , Omnberland County, Pennsylvania, by handing to Rev Donald M. Schiewer for Eberly's Mills Church of God of Lower Allen Township a true and attested copy of the Complaint and Notice and at the same t/me directing his attention to the contents thereof and the "Notice to Plead" endorsed thereon. Sheriff' s Costs: Docketing 14.00 Service 8.25 Affidavit Surcharge 2.00 24.25 Pd. by Atty. 4-26-91 Sworn and subscribed to before me this ~ ~ day So answers.~~ R. Thomas Kline, Sheriff ~ . Prothonotary 008004-00001/September 20, 1993/EGM/GMM/29442 NANCY T. ANTHONY, HENRY D. TWITCHELL, JR., GEORGE G. TWITCHELL and CLAIRE E. GRANT, Plaintiffs EBERLY'S MILLS CHURCH OF GOD OF LOWER ALLEN TOWNSHIP, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 1403 CIVIL 1991 ACTION IN EJECTMENT ORDER OF COURT AND NOW this [JO day of {~ , 1993, upon consideration of the attached Stipulatior of the parties, it is hereby ORDERED that judgment shall be entered in favor of the Plaintiffs and against the Defendant for possession of the real estate, and it is further ORDERED that fee simple title is vested in the Plaintiffs. · Nancy T. Anthony, Henry D. Twitchell, Jr., George G. Twitchell and Claire E. Grant, as tenants in common o undivided one-fourth (1/4) interests. B 008004-00001/September 20, 19931EGM/GMM/29442 NANCY T. ANTHONY, HENRY D. TWITCHELL, JR., GEORGE G. TWITCHELL and CLAIRE E. GRANT, Plaintiffs EBERLY'S MILLS CHURCH OF GOD OF LOWER ALLEN TOWNSHIP, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 1403 CIVIL 1991 ACTION IN EJECTMENT STIPULATION The parties, through their respective counsel, hereby stipulate and agree as tbllows: 1. Entry of Judgment. The parties hereby agree that the issues in the litigation shall be resolved b requesting the Court to enter an Order granting judgment in favor of the Plaintiffs and against the Defendant for th relief requested in the Complaint as follows: a. The Plaintiffs are entitled to immediate possession of the real estate; and b. The Plaintiffs hold a fee simple title as tenants in common. 2. Facts and Allegations. For purposes of this Stipulation the parties agree that the facts as alleged in the Complaint shall be uncontested. 3. Confirmation of Title. Defendant agrees to take whatever steps shall be deemed necessary by Plaintiff in order to confirm fee simple title in Plaintiffs, including a properly drawn, executed and acknowledged Quit-Clain Deed from Defendant to be prepared at the expense of Plaintiffs, which Deed shall be delivered within a reasonable period, not to exceed thirty (30) days, after receipt from the Plaintiff. Defendant shall also provide evidence of th~ authority of the Trustees to execute, acknowledge and deliver such Deed as may be necessary by the appropriate governing body which has jurisdiction over the Defendant. 008004-00001/September 20, 1993/EGM/GMM/29442 4. Transfer Tax. Realty transfer tax, if any, required to be paid in connection with the recording of the Order of Court and/or Deed from Defendant, shall be borne by Plaintiffs. IN WITNESS WHEREOF the parties have caused these presents to be duly executed by their respectiv6 counsel. Respectfully submitted, Date: DISSINGER & DISSINGER By: William C.' l~'si~er Attorney for Defendant Date: JOHNSON, DUFFLE, STEWART & WEIDNER By: Edmund G. Myers Attorney for Plaintiffs 008004-00001/September 20, 1993/EGM/GMM/29446 DEED THIS DEED, made this 6th day of December, in the year of our Lord one thousand nine hundred ninety-three (1993) BETWEEN MICHAEL p. ZIMMERMAN, ROBERT L. FOX, SR., and TIMOTHY L. BROTHERS, Trustees of Eberly's Mills Church of God of Lower Allen Township, hereafter GRANTORS NANCY T. ANTHONY, 1810 Lamb's Gap Road, Mechanicsburg, Pennsylvania, HENRY D. TWITCHELL, JR., 4 Hawthorne Road, Winchester, Massachusetts, GEORGE G. TWITCHELL, 106 Spring Lane, West Hartford, Connecticut, and CLAIRE E. GRANT, 37 Hudson Road, Box 43, Bangor, Maine, as tenants in common of undivided one-quarter (1/4) interests, hereafter GRAIVrEES WITNESSETH that the said Grantor, for and in consideration of the sum of ONE AND 00/100 ($1.00) DOLLAR, lawful money of the United States of America, unto it well and truly paid by' the Grantees at and before the sealing and delivery of these presents, the receipt whereof is hereby acknowledged, the said Grantors have hereby remised, released and quitclaimed, and by these presents do hereby remise, release and quitclaim unto the said Grantees, their heirs and assigns, ALL THAT CERTAIN lot or piece of ground situate and being in Lower Allen Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a post on the public road leading to Hakes Mills; thence by said road South 12 degrees East 12.6 perches to a post in said road; thence by land now or formerly of Henry Stephan South 59 degrees East 8.4 perches to a stone; thence by the same South 83~h degrees East 2.7 perches to a stone; thence by land now or formerly of William R. Gorgas North 9 degrees West 18.3 perches · 008004-00001/September 20, 1993/EGM/GMM/29446 to a stone; thence by the same 80 degrees West 10.2 perches to the place of BEGINNING. Containing 1 acre of land neat measure, be the same more or less. BEING the same premises which Kate F. Gorgas, single woman, and George A. Gorgas and Rachel M. G. Gorgas, his wife, by their deed dated December 15, 1931 and recor · . . Volume 11, Page 68, Cumberland County Re ,~,,~ ,.,: ,-,A~ ..... d. ed ~n Deed Book H , ., cor,~,., ,,~ ,-,~s omce, grant~ and conveyed unto C. W. Fetrow and W. F. Thompson, Trustees, Grantors herein. BEING the same premises which by Order of the Court of Common Pleas of Cumberland County in Civil Action 1403 Civil 1991, Action in Ejectment, brought by the Grantees against the Grantors, enter judgment in favor of the Plaintiffs and against the Defendant for the relief requested, said Order and Judgment dated , 1993 and recorded in Miscellaneous Book Page , Cumberland County Recorder of Deeds office. ' THIS DEED is given to the Grantees for the purpose of recording in the Recorder of Deeds office, Cumberland County, to confLrm fee simple title in the Plaintiffs. TOGETHER with all and singular the buildings, improvements, ways, streets, alleys, passages, waters, watercourses, rights, liberties, privileges, hereditaments and appurtenances whatsoever thereunto belonging, or in any wise appertaining, and the reversions and remainders, rents, issues and profits thereof; and all estate, right, title, interest, property, claim and demand whatsoever of them, the said Grantor, in law, equity or otherwise howsoever, of, in, to or out of the same. TO HAVE AND TO HOLD the said lot or piece of ground above described, with the buildings and improvements thereon erected, hereditaments and premises hereby granted or mentioned, and intended so to be, with the appurtenances, unto the said Grantees, their heirs and assigns, to and for the only proper use an behoof of the said Grantees, their heirs and assigns, forever. IN WIT~ WHEREOF, the undersigned, Trustees of Eberly's Mills Church of God of Lower Allen Township, have hereunto set their hands and seals, with intent to be legally bound, on the day and year first above written. · 008004-00001/September 20, 1993/EGM/GMM/29446 Signed, Sealed and Delivered in the Presence of: TRUSTEES OF EBERLY'S MILLS CHURCH OF GOD OF LOWER ALLEN TOWNSHIP COMMONWEALTH OF PENNSYLVANIA · 'SS COUNTY OF Cumberland . On this, the 6th day of Deconnber , 1993, before me, the undersigned officer, personally appeared, MICHAEL ?. ZIMME~ who acknowledged himself to be one of the Trustees of Eberly's Mills Church of God of Lower Allen Township, and that he as such Trustee, being authorized to do so, executed the foregoing instrument for the purposes therein contained by signing the name of the Church by himself as such Trustee. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary PUblic 008004-00001lScp[¢mbcr 20, 1993/EGM/GMM/29440 COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERLg2qD ' SS On this, the 6th day of December , 1993, before me, the undersigned officer, personally appeared, ROBERT L. FOX, SR. who acknowledged himself to be one of the Trustees of Eberly's Mills Church of God of Lower Allen Township, and that he as such Trustee, being authorized to do so, executed the foregoing instrument for the purposes therein contained by signing the name of the Church by himself as such Trustee. IN WITNESS WHEREOF, I hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this, the 6th day of December appeared, TIbIOTHY L. BROTHERS , 1993. before me. the undersigned officer, personally who acknowledged himself to be one of the Trustees Church of God of Lower Allen Township, and that he as such Trustee, being authorized to do of Eberly's Mill~ foregoing instrument for the PUrposes therein contained by signing the name of the Church by himself as such Trustee. so, executed the IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public ~ 008004-0000 I/Scp~cmbcr 20, 1993lEG,M/GM,M/29446 I do hereby certify that the precise residence of the within named Grantees are: Attorney for Grautee COMMONWEALTH OF PENNSYLVANIA · 'SS COUNTY OF CUMBERLAND RECORDED, on this the day of Deed Book . Volume , Page , 1993, in the Recorder's Office of said County, in GIVEN under my hand and the seal of the said oft'ice, the date above written. , Recorder