HomeMy WebLinkAbout03-1056IN RE: UPSET TAX SALE HELD
SEPTEMBER 26, 2002
BY THE CUMBERLAND COUNTY
TAX CLAIM BUREAU
PROPERTY OF: FAMILY TRUST OF:
ALLEN J. GOULEY
FAITH K. GOURLEY
ROBERT S. GOURLEY
SUE F. GOURLEY
TAX PARCEL NO.:
02-20-1800.014
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
RULE TO SHOW CAUSF
day of March, 2003 upon consideration of the within
AND NOW, this
Petition, a Rule to Show Cause is issued upon all interested parties to appear and show
cause why a decree should not be made that the property which is the subject of the
within Petition be sold freed and cleared of all tax and municipal claims, liens,
mortgages, charges and estates, except separately taxed ground rents. Service of this
Rule shall be made to all parties listed at paragraphs four and five of the within Petition
in the manner provided by Section 611 of the Real Estate Tax Sale Law 72 P.S.
§5860.611.
This is not a summons, you are not required to appear before the court, however
you must appear if you desire to preserve your right to any interest or value in the real
estate which is the subject of .this proceeding. If you do not appear you may lose any
ownership interest in the property or any right to any lien or other security interest in the
property.
Rule returnable ~/,~?/.~ z//
, at Cumberland County
Pennsylvania.
,2003 at J.'~,D/~M./~P~rtroom Number
Courthouse, Square, Carlisle,
IN RE: UPSET TAX SALE HELD
SEPTEMBER 26, 2002
BY THE CUMBERLAND COUNTY
TAX CLAIM BUREAU
PROPERTY OF: FAMILY TRUST OF
ALLEN J. GOURLEY
FAITH K. GOURLEY
ROBERT S. GOURLEY
SUE F. GOURLEY
TAX PARCEL NO.:
02-20-1800-014
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2003
PETITION FOR RULE FOR JUDICIAL SALF
AND NOW, comes the Cumberland County Tax Claim Bureau, by its attorney,
Stephen D. Tiley, Esquire, Assistant Cumberland County Solicitor, and files this Petition
for Rule for Judicial Sale, of which the following is a statement:
1. Your Petitioner is the County of Cumberland through its Tax Claim Bureau, a
Bureau created by the Real Estate Tax Sale Law. 72 P.S. [}5860.101, et sic.
2. Pursuant to 72 P.S. §5860.610, your Petitioner respectfully represents as
follows:
Tax claim upon which the property was exposed for sale: 2001
Cumberland County, Cumberland County Library and Carlisle
Borough real estate taxes. 2000-01 through and including 2001-02
Carlisle Area School District real estate taxes. Total amount of
claim, including penalty and interest as of date of tax sale:
$1,627.49.
Neither the owner, his, her, their, or its heirs, successors, assigns,
or legal representatives, or any lien creditor, or his, her, their or its
heirs, successors or legal representatives, or any other person
interested, has caused stay of sale, discharge of tax claim or
removal from tax sale.
The property was exposed to public sale pursuant to 72 P.S.
§5860.601 on: September 26, 2002.
Petition for Judicial Sale (Parcel No. 02-20-1800-014) Page 1
do
Before exposing the property to public sale the Bureau fixed the
upset sale price, pursuant to 72 P.S. §5860.605, which upset price
was $2,866.41.
Your Petitioner, the Bureau, was unable to obtain a bid at the public
sale sufficient to pay the said upset price.
3. Attached hereto, marked Exhibit "A," and incorporated herein by reference
as is fully set forth herein, is a copy of a title report received from a title searcher
retained by the Bureau together with a reduced copy of the most recent deed for the
subject premises, as of the date of the search. The tax parcel number of the property is
02-20-1800-014. The property is situate in the Borough of Carlisle, Cumberland
County, Pennsylvania, and is known as 430 North Bedford Street.
4. The names and addresses of all parties holding tax and municipal claims,
liens, mortgages, ground rents, charges and estates against the property are as follows:
ao
Cumberland County Tax Claim Bureau
One Courthouse Square
Carlisle, Pennsylvania 17013
Delinquent taxes payable through March 31, 2003:$2,986.31
(Includes 2000-01 School real estate tax through and including
2002-03 School real estate tax)
Darlene L. Moyer, Tax Collector
19 S. Hanover Street, Suite 102
Carlisle, PA 17013
2003 County and Municipal taxes at discount in the amount of
$359.19.
Carlisle Borough
53 W. South Street
Carlisle, PA 17013
Carlisle Borough claims all Municipal real estate taxes collected by
Darlene L. Moyer and the Tax Claim Bureau.
Carlisle Area School District
623 West Penn Street
Carlisle, PA 17013
Petition for Judicial Sale (Parcel No. 02-20-1800-014) ' Page 2
Carlisle Area School District claims all School real estate tax
collected by the Tax Claim Bureau.
5. The last known address of the owner of the property as set forth in
the assessment records of Cumberland County is: RD 2, New Bethlehem, PA 16242-
9802. Per the Clarion County Tax Claim Bureau, Allen J. Gourley and Faith K. Gourley
reside at 1933 Sheridan Road, New Bethlehem, PA 16242 and Robert S. Gourley and
Sue F. Gourley reside at 1990 Packing Road, New Bethlehem, PA 16242.
WHEREFORE, Your Petitioner prays your Honorable Court to grant a rule upon
all interested parties, including those listed at paragraphs four and five of the within
Petition, to show cause why a decree should not be made that the property be sold,
freed and cleared of tax and municipal claims, liens, mortgages, charges and estates,
except separately taxed ground rents, pursuant to Section 612 of the Real Estate Tax
Sale Law. 72 P.S. §5860.612(a).
Respectfully submitted,
Stephen D. Tiley, Esquire
Assistant Cumberland County Solicitor
5 South Hanover Street
Carlisle, PA 17013
(717) 243-5838
Attorney I.D. # 32318
Petition for Judicial Sale (Parcel No. 02-20,1800-014) Page 3
VERIFICATION
I, Melissa F. Mixell, Tax Claim Bureau Supervisor, depose and say that the facts
set forth in the foregoing Petition for Rule for Judicial Sale are true and correct based
partly upon personal knowledge and the remainder upon information and belief; I
understand that this Verification is made subject to the penalties of 18 Pa. C.S. §4904,
relating to unswom falsification to authorities.
Cumberland County Tax Claim Bureau
One Courthouse Square
Carlisle, PA 1701
(717) 240-6366
Petition for Judicial Sale (Parcel No. 02-20-1800-014) Page 4
HARVEY P, MURRAY, JR., P.O. BOX 11, SELINSGROVE, PA 17870
[ FAX: 570-374-4761
CUMI~ERLAND, PERRY, DAUPHIN, JUNIATA, SNYDER, UNION & NORTHUMBERLAND COUNTIES
PERRY COUNTY COURT HOUSE (USUALLY THERE ABOUT 12:30 P.M. UNTIL 4 RM.)
PHONE: 717-582-3504 FAX: FAX TO HOME FAX: 570-374-4761
CUMBERLAND COUNTY COURT HOUSE (USUALLY THERE 9 A.M. UNTIL NOON)
PHONE: 717-240-6374 and 6373 FAX TO HOME FAX: 570-374-4761
CAN LEAVE BRIEF MESSAGES WITH SEARCHERS AT EITHER COURT HOUSE.
PREFER THAT ALL APPLICATIONS BE FAXED. SEARCHING SINCE 1965
AFFILIATED WITH CORNERSTONE LAND TRANSFER, INC., MECHANICSBURG, PA - TITLE INS.
FOR:
ORDER #
Cumberland County Tax Claim Bureau
Melissa Mixell
OWNER TO
BE SEARCHED:
PREMISES:
GRANTOR(S):
GRANTEE(S):
DATE OF DEED:
Family Trust of Allen Gourley and Faith Kimko Gourley, Allen
James Gourley and Faith Kimko Gurley, Trustees, and the
Family Trust of Robert S. Gourley and Sue F.Gourley,,
Robert S..Gourley and Sue F. Gourley, Trustees
Cumberland County, Carlisle
North Bedford Street
Deed Book 130-1130
RECORDED:
DEED BOOK:
CONSIDERATION:
COVER DATE: December 18, 2002
PURPOSE: PRESENT OWNER LIEN SEARCH (FROM ACTUAL CONSIDERATION)
MORTGAGE (S): None
JUDGMENT (S): None
FEDERAL TAX LIEN (S): None
TAX CLAIM BUREAU:
2000 delinquent= $404.15+
SECURED TRANSACTIONS
(RECORDER'S OFFICE-LIENS): None
2001: 1277.35+
ASSESSMEN~
TAX PARCEL # 02-20-1 800-01 4
DATE:
December 19, 2002
PLEASE REMIT
TO: HARVEY P. MURRAY, JR., PO. BOX 11, SELINSGROVE, PA 17870 Exhihlt'-'
~&A~
THANK YOU
QUITCLAIM DEED - PENNSYLVANIA
THIS INDENTURE made the 5th day of October in the year of our Lord One Thousand
Nine Hundred Ninety-Five (1995).
FROM PENN CENTRAL PROPERTIES, INC., a Pennsylvania corporation, and
AMERICAN PREM1ER IJNDERWRITERS, INC. (formerly The Penn Central Co~poration), a
Pennsylvania corporation, both having offices at One East Fourth Street, Cincinnati, Ohio 45202 (both
corporations being hereinafter sometimes collectively referred to as the "Grantor"), to THE FAM1LY
TRUST OF ALLEN GOURLEY and FAITIt KIMIKO GOURLEY, Allen James Gourley and
Faith Kimiko Gourley, Trustees, and TIlE FAMILY TRUST OF ROBERT S. GOURLEY and
SUE F. GOURLEY, Robert S. Gmrrley and Sne F. Gourley, Trustees, all of R.D. #2, New
Bethlehem, Pennsylvmfia 16242 (hereinafter referred to as the "Grantee");
WITNESSETH: Tint the Grantor, for and in consideration of the sum of TEN DOLLARS
($10.00) and other good m~d valuable consideration paid by the Grantee, at or before the sealing and
delivery of these presents, the receipt whereof is hereby acknowledged, does by these presents, remise,
release and forever quitclaim unto the Grantee, all right, title and interest of the Grantor of, in and to
the premises described in Schedule "A" attached hereto and made a part hereof.
Actual consideration for this conveyance is $280.00.
Exhibit "A"
PA014101
Cumberland County ID# PAK-100-681
SCHEDULE "A"
ALL THAT PARCEL of land situate in the Borough of Carlisle, County of Cumberland,
Commonwealth of Pennsylvania, being that 'property of the former Pennsylvania Railroad Company
(predecessor ofsald Grantor) further bounded and described accordin8 to a plan of survey made by N.
M. Lake, Inc., Daniel Keller Lake, Registered Professional Engllmer No. PE010223-E, dated
September 12, 1977, as follows:
BEGINNING at m~ iron pipe set at a point wilere the Easterly right-of-way line of I-lanover Street
(30.00 feet from its centerline) intersects the Northerly right-of-way line of the railroad now/fonneriy
of Consolidated Rail Corporation (20.00 feet from the centerline of file railroad track); thence (1) along
said right-of-way of Hanover Street North 44° 55' 20" East, 38.13 feet to a point at the beginning ora
concrete wall at comer of lot now or late of Donna K. Hurley; thence (2) along said concrete wall and
land ofDouna K. Hurley South 45° 43' 30" East, 18.00 feet to an angle in line; thence (3) along same
land and concrete wall South 72° 36' 35" East, 3.1.69 feet to a comer at end of,said wall; thenee (4) by
same land South 86° 12' 20" East, 57.95 feet to an iron pipe set at comer; thence (5) by same land and
the rear I ne of lots now or late of Carol D. Mo, :c and Robert J. Long respecfive/y North 30° 31' East,
47.24 feet to an existing fence post at comer, ~.ne.,~ce (6) along a fence line and land now or late of
Martha Brassler South 55° 07' 15" East, 2.57 ,zet to an existing fence post at the west end of an alley
7 "~
(12.00 feet wide); thence (7) along the end of alley South 61° 58' 35" East, 15.95 feet to m~ iron pipe;
thence (8) along a line &the Borough of Carlisle South 48° 48' 25" East, 60.00 feet to an iron pipe set.
in the North right-of-way line of said railroad (20.00 feet from the centerline of the railroad track);
thence (9) along the North right-of-way line &said railroad North 80° 12' 45" West, 274.63 feet to
the Place of Beginning.
CONTAINING 7,922 square feet (0.182 of an acre), more or less.
Exhibit "A"
PA014102
· ! ID//PAK~I00-681
Cumberland Connty
SCHEDULE "A"
ALL THAT PARCEL of land situate in the Bc~rough of Carlisle, County of Cumberland,
Commonwealth of Pennsylvania, being that property ~f the former Pennsylvania Railroad Company
(predecessor of.said Granto0 further bounded and des~bed according to a plan ofsurvey made by N.
M. Lak~, Inc., Daniel Keller Lake, Registered prOFessional Engineer No. PEO10223-E, dated
September 12, 1977, as follows:
BEGINNING at an iron pipe set at a point whero the Westerly right-of-way line of North Bedford
Street (27.00 feet bom ils centerline) intersects the North right-of-way line of the railroad
now/formerly of Consolidated Rail Corporation (20.00: feet fi-om the centerllne of the railroad track);
thence (1) along said right-of-way ofrailroad North 80° 12' 45" West, 135.20 feet to an iron pipe set
at comer, thence (2) along a line of the Borough of Carlisle North 36° 09' 35" F. ast, 82.38 feet to an
iron pipe at' comer and being a point on the Easterly line of an alley 02.00 feet wide); thence (3) along
the line ora lot now or late ofJohn W. Hoerner South 5~;° 26' 15" East, 120.00 feet to an iron pipe set
in the Westerly right-of-way llne of North Bedford ~ ' .,i, · thence (4) along same South 33° 32' 25"
West, 25.69 feet to the Place of Beginning. :~
CONTAINING 6,530 square feet (0.150 of an acre), more or less.
Exhibit "A"
RESERVING unto Grantor, future pem~anent and perpetual easements in gross, fi'eely
alienable and assignable by the Grantor, for (a) all existing wire and pipe facilities or occupations
wbetber or not covered by license or agreement between Grantor and other parties, of record or not of
record, that in any way encumber or affect the premises conveyed herein, and (b) all future occupations
within 20 feet on either side of the existing occupations, and (c) all rentals, fees and considerations
resulting from such occupations, agreements and licenses and from the assignment or conveyance of
such easements.
RESERVING unto Grantor, its successors and assigns, all oil. gas, natural gas, casing-bead
gas, condensates, related hydrocarbons, coal and all products produced therewith or tberefrom in. or
under tbe premises conveyed herein, with the right to remove same by the use of the usual or proper
and convene it methods, devices or appliances, but excluding the right to entel' upon the surlhce of said
land in any way.
SUBJECT, however, to:
(I) tile state of facts disclosed by the survey hereinabove mentioned; and
(2) rights of the public in that portion, if the premises within the lines of any public road: that
cross the property herein conveyed; and
(3) any easements of record.
GRANTEE acknowledges and agrees that:
(I) should a claim adverse to the title hereby quitclaimed be asserted and/or prove~l, no
recourse shall be had against the Grantor; and
(2) Grantee will assmne all obligations with respect to ownership, maintenance, repal~;
renewal or removal of the drainage structures, culverts and bridges located on, over or under the
premises conveyed berein that may be imposed :fit. er tbe date of this Deed by any governmental agency
having jurisdiction tbereober.
~'~o~ 1,30 rz;r~.:L:~3
Exhibit "A"
TOGETHER with all and singular the tenements, hereditaments and appurtenances therennto
belonging, or in any wise appertaining and the reversion and reversions, remainder and remainders,
rents, issues and profits thereol~ and all the estate, right, fille, interest, property, claim and demand
whatsoever of the said Grantor, as well at law as in equity or otherwise howsoever, of, in and to the
same and eve~ part thereoE
TO HAVE AND TO HOLD all and singular the said premises together with the
appurtenances, unto the Grantee, the heirs or successors and assigns of the Grantee forever,
RESERVING AND SUBJECT as aforesaid.
Penn Central Properties, Inc. is the owner of the said premises and American Premier
Underwriters, Inc. is the holder of record title thereto in order to secure the payment of the purchase
price in a sale of said premises and other property in Pennsylvania by American Premier Underva/ters,
Inc. to Penn Central Properties, Inc.
The words "Grantor" and "Grantee" u~d hereh: shall be construed as if they read "Grantors"
and "Grantees", respectively, whenever the sense of thia ladenture so requires and whether singular or
plural, such words shall be deemed to include in all ct~.~ :: ~he successors and assigns of the respective
parties.
IN WITNESS WHEREOF, the Granto, r has cat:: J this Indenture to be executed the day and
year first above written.
SEALED AND DELIVERED
in tile presence of us:
KAREN PLOGSTEI~'
KAREN PLOGSTEIJ
PENN CENTRAL PROPERTIE§i~:'eS~
s.
S~re~
Exhibit "A"
STATE OF OHIO :
: SS.
COUNTY OF HAMILTON:
ON THIS the 5th day of October, 1995, before me, a Notary Public in and for the state and
county aforesaid, the undersigned officer, personally appeared JOHN A. ANDERSON, who
acknowledges himself to be the Vice President of PENN CENTRAL PROPERTIES, INC., a
corporation, and that he as such Vice President, being authorized so to do, ~ecuted tile foregoing
instrument for the purposes therein containe~t by signing the name of the corporation by himsel£as Vice
President.
,/"~ Notary Public
," ,. JAMES WJ L/.W~ENCE
' Notary Public, State o,
My Comflllsslofl Exl..t :s Jan. 24, 1997
STATE OF OHIO :
:
COUN~ OF H~TON:
ON THIS the 5th day of October, 1995, before me, a Notary Public in and for the state and
county aforesaid, the undersigned officer, per~oonally appeared JOHN A. ANDERSON, who
acknowledges himself to be the Staff Vice President, Real Estate of AMERICAN PREMIER
UNDERWRITERS, INC., a corporation, and that he as such StaffVice President, Real Estate, being
authorized so to do, executed the foregoing instrument for the purpose~ therein contained by s gning
the name of the corporation by himselfas StaffVice President, Real Estate. - ......
· ..,' '.,,~,~I otary Public
'" / JAMES W. LAWRENCE
I hereby certify that [he correct uo~arv Public. State ol Ohio
address of the within named Grant~h~ Cmmnlsslon E~pises Jan. 24. 1997
iS:
Exhibit "A"
IN RE: UPSET TAX SALE HELD
SEPTEMBER 26, 2002
BY THE CUMBERLAND COUNTY
TAX CLAIM BUREAU
PROPERTY OF.' FAMILY TRUST OF:
ALLEN J. GOULEY
FAITH K. GOURLEY
ROBERT S. GOURLEY
SUE F. GOURLEY
TAX PARCEL NO.:
02-20-1800-014
pRDER
IN THE COURT OF COMMON PLEAS
OFCUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2003 -1056
AND NOW, this~Jday of June, 2003 after Hearing on the Rule to Show Cause
filed pursuant to the Petition for Rule for Judicial Sale of the Cumberland County Tax
Claim Bureau, it is Ordered and Decreed that the property which is the subject of the
within Petition be sold freed and cleared of all tax and municipal claims, liens,
mortgages, charges and estates, except separately taxed ground rents, to the highest
bidder at a sale to be held on July 21, 2003 at 2:00 p.m. in the Courtroom, 2nd Floor, of
the Old Courthouse Building of the Cumberland County Courthouse, and that the
purchaser at such sale shall take and thereafter have an absolute title to the property
free and clear of all tax and municipal claims, mortgages, liens, charges and estates of
whatsoever kind, except ground rents, separately taxed.
Advertisement of such sale need only be advertised by one (1) insertion in two
(2) newspapers of general circulation in Cumberland County, and by one (1) insertion in
the Cumberland County Law Journal. Such advertisement shall appear at least thirty
(30) days prior to the sale date and shall include the purpose, t.h~,ti~e, the place and
the terms of such sale with a reference to the prior advertiser~,...etlt~ i~i ~,~.S. § 5860.612).
Edgar B. Bayley, J.
SHERIFF'S RETURN -
CASE NO: 2003-01056 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CUMBERLAiqD TAX CLAIM BUREAU
VS
GOURLEY ALLEN J ET AL
CPL. MICHAEL BARRICK
Cumberland County,Pennsylvania,
says, the within RULE AND PETITION
CUMBERLAND COUNTY TAX CLAIM BUREAU
DEFENDANT , at 1105:00 HOURS,
REGULAR
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
the
on the 21st day of March , 2003
at ONE COURTHOUSE SQ
CARLISLE, PA 17013
MELISSA MIXELL,
a true and attested copy of RULE kND PETITION
by handing to
ADULT IN CHARGE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 3.45
Affidavit 2.50
Surcharge .00
.00
23.95
Sworn and Subscribed to before
me this /~ ~ day of
_~ ~2~0~ A.D.
! Prothonotary
So Answers:
R. Thomas Kline
00/00/0000
Deputy Sheriff
SHERIFF' S RETURN - REGULAR
CASE NO: 2003-01056 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CUMBERLAND TAX CLAIM BUREAU
VS
GOURLEY ALLEN J ET AL
CPL. MICHAEL BARRICK ,
Cumberland County, Pennsylvania,
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
on the 21st day of March
SUITE 102
by handing to
says, the within RULE AND PETITION
MOYER DARLENE TAX COLLECTOR
DEFENDANT , at 1100:00 HOURS,
at 19 S HANOVER STREET
CARLISLE, PA 17013
DARLENE MOYER
a true and attested copy of RULE AND PETITION
the
, 2003
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit 1.00
Surcharge .00
.00
7.00
Sworn and Subscribed to before
me this /~ day of
~P~othonot ary
So Answers:
R. Thomas Kline '
00/00/0000
Deputy Sheriff
SHERIFF' S RETURN - REGULAR
CASE NO: 2003-01056 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CUMBERLAND TAX CLAIM BUREAU
VS
GOURLEY ALLEN J ET AL
DAWN KELL ,
Cumberland County, Pennsylvania, who being
says, the within RULE AND PETITION
CARLISLE BOROUGH
DEFENDANT at 0838:00 HOURS,
at 53 W SOUTH STREET
CARLISLE, PA 17013
PAM LEBO, CLERK
a true and attested copy of RULE AND PETITION
Sheriff or Deputy Sheriff of
duly sworn according to law,
was served upon
the
on the 24th day of March 2003
by handing to
ADULT IN CHARGE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit 1.00
Surcharge .00
.00
7.00
Sworn and Subscribed to before
me this /0 day of
~ t;rothonotary '
So Answers:
R. Thomas Kline
00/00/0000
By:
Deputy Sheriff
SHERIFF'S RETURN
CASE NO: 2003-01056 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CUMBERLAND TAX CLAIM BUREAU
VS
GOURLEY ALLEN J ET AL
- REGULAR
DAWN KELL ,
Cumberland County, Pennsylvania,
says, the within RULE AND PETITION. was served upon
CARLISLE AREA SCHOOL DISTRICT
DEFENDANT , at 0852:00 HOURS, on the 24th day of March
at 623 WEST PENN STREET
CARLISLE, PA 17013
ROBERT C WILLIAMS, BOARD
Sheriff or Deputy Sheriff of
who being duly sworn according to
a true
by handing to
SECRETARY, ADULT IN CHARGE
the
and attested copy of RULE AND PETITION
together with
law,
, 2003
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 6
Service
Affidavit 1
Surcharge
00
00
00
00 R. Thomas Kline
00
00 00/00/0000
Sworn and Subscribed to before
me this /~ ~ day of
! /Prothonotary' ; w
So Answers:
By:
Deputy Sheriff
SHERIFF'S RETURN
CASE NO: 2003-01056 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERIJkND
CUMBERLAND TAX CLAIM BUREAU
VS
GOURLEY ALLEN J ET AL
- OUT OF COUNTY
R. Thomas Kline
duly sworn according to law,
and inquiry for the within named DEFENDANT
GOURLEY ALLEN J
but was unable to locate Him
deputized the sheriff of CLARION
, Sheriff or Deputy Sheriff who being
says, that he made a diligent search and
, to wit:
in his bailiwick.
County,
serve the within RULE AND PETITION
He therefore
Pennsylvania, to
On April 9th , 2003
attached return from CLARION
Sheriff's Costs:
Docketing 6.00
Out of County 9.00
Affidavit 1.00
Dep Clarion Co 100.50
.00
116.50
00/00/0000
this office was in receipt of the
Rf Thomas Kline
Sheriff of Cumberland County
Sworn and subscribed to before me
this /0 ~ day o
~3 A.D.
Prothonotary
In The Court of Common Pleas of Cumberland County, Pennsylvania
Cunberland County Tax Claim Bureau
VS.
F~nily Trust of Allen J. Gourley et al
SERVE: Allen J. Gourley No. 03-1056 civil
Now, March 21, 2003'
hereby deputize the Sheriff of Clarion
deputation being made at the request and risk of the Plaintiff.
, I, SHERIFF OF CUMBERLAND COUNTY, PA, do
County to execute this Writ, this
Sheriff' of Cumberland County, PA
Affidavit of Service
Now, April 2 ,2003 ,at 11:25 o'clock A. M. servedthe
within RULE TO SHOW CAUSE AND PETITION FOR RULE FOR JUCICIAL SALE
upon Allen J. Gourley
at 1933 Sheridan Road, New Bethlehem, PA 16242
byhandingto Faith Gourley, adult person in charge
a
and made lmown to
Her
copy of the originalRule & Petition
the contents thereof.
~.~swers,
Sheriff of ~larion County, PA
Sworn and subscribed belb~c
me this ff_F_z~day of~,~*-JE-~, 20 OS.
.~ ~m ~, ~ ~ I
_ _~m~ ~ ~.1~ I
COSTS
SERS~UE
MILEAGE
AFFIDAVIT
$100.50
SHERIFF ' S
CASE NO: 2003-01056 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CUMBERLAND TAX CLAIM BUREAU
VS
GOURLEY ALLEN J ET AL
RETURN
- OUT OF COUNTY
R. Thomas Kline
duly sworn according to law,
and inquiry for the within named DEFENDANT
GOURLEY FAITH K
but was unable to locate
deputized the sheriff of
, Sheriff or Deputy Sheriff who being
says, that he made a diligent search and
to wit:
Her in his bailiwick.
CLARION County,
serve the within RULE AND PETITION
He therefore
Pennsylvania, to
On April 9th , 2003
attached return from CLARION
Sheriff's Costs:
Docketing 6.00
Out of County .00
Affidavit 1.00
.00
.00
7.O0
oo/oo/oooo
this office was in receipt of the
R. Thomas Kline ~
Sheriff of Cumberland County
Sworn and subscribed to before me
this ./b~ day of~
A.D.
Prothonotary/ I
In The Court of Common Pleas of Cumberland County, Pennsylvania
Cumberland County Tax Claim Bureau
VS.
F~nily Trust of Allen J. Gourley et al
SERVE: Faith K. Gourley NO. 03-1056 civil
]X~OW, March 21, 2003
hereby deputize the Sheriff of Clarion
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
, I, SHERIFF OF CUMBERLAND COUNTY, PA, do
County to execute this Writ, this
Affidavit of Service
NOW, April 2, ,20 03 , at 11:25 o'clock A. m. servedthe
within RULE TO SHOW CAUSE AND PTEITION FOR RULE FOR JUDICIAL SALE
upon Faith K. Gourley
at 1933 Sheridan Road, New Bethlehem, PA 16242
by handing to Faith K.' Gourley personally
a copy of the original
and made known to her
Rule & Petition
the contents thereof.
Sworn and subscribed before
me thisz~aY of~M.~L/_ , 20 ~' 3
7~swers, D sl~eriff
Sheriffof Clarion
COSTS
SERVICE
MILEA GE
AFFIDAVIT
100.50
SHERIFF'S RETURN -
CASE NO: 2003-01056 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAiqD
CUMBERLAND TAX CLAIM BUREAU
VS
GOURLEY ALLEN J ET AL
OUT OF COUNTY
R. Thomas Kline
duly sworn according to law,
and inquiry for the within named DEFENDANT
GOURLEY ROBERT S
but was unable to locate Him
deputized the sheriff of CLARION
serve the within RULE AND
, Sheriff or Deputy Sheriff who being
says, that he made a diligent search and
, to wit:
in his bailiwick.
County,
PETITION
He therefore
Pennsylvania, to
On April 9th , 2003
attached return from CLARION
Sheriff's Costs:
Docketing 6.00
Out of County .00
Affidavit 1.00
.00
.00
7.00
00/00/0000
__ , this office was in receipt of the
So answers_:
R./Thomas Kline
Sheriff of Cumberland County
Sworn and subscribed to before me
this /0~ day of~
~2~ A.D.
Prothonotar~z t -
In The Court of Common Pleas of Cumberland County, Pennsylvania
CLrnberland County T~x Claim Bureau
VS.
F~nily Trust of Allen J. Gourley et al
SERVE: Robert S. Gourley NO. 03-1056 civil
]~OW, March 21, 2003
hereby deputize the Sheriff of Clarion
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
, I, SHERIFF OF CUIvlBERLAND COUNTY, PA, do
County to execute this Writ, this
Affidavit of Service
/~OW,
within
upon
at
by handing to
a
April 2, ,2003 ,at 11:40 o'clock A. M. servedthe
RULE TO SHOW CAUSE AND PETITION FOR RULE FOR JUDICIAL SALE
Robert S. Gourley
1990 Packing Road, New Bethlehem, PA 16242
Sue F. Gourley, adult person in charge
and made known to her
Sworn and subscribed before
me this ~5~day of~-~_,, , 20
C;arlm Bom, Clarion County
My Commission Expires Nov. 10, 200~
copy of the ori~nal
the contents thereof.
S)~no.~,swers' /~ff~
.~'~"~;~' Deputy Sheriff
Sheriff of ~ Clarion troy,
COSTS
~LEAGE
AFFIDA~T
$ 100.50
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2003-01056 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CUMBERLAND TAX CLAIM BUREAU
VS
GOURLEY ALLEN J ET AL
R. Thomas Kline
duly sworn according to law,
and inquiry for the within named DEFENDANT
GOURLEY SUE F
but was unable to locate Her
deputized the sheriff of CLARION
, Sheriff or Deputy Sheriff who being
says, that he made a diligent search and
to wit:
in his bailiwick.
County,
serve the within RULE AND PETITION
He therefore
Pennsylvania, to
On April 9th , 2003
attached return from CLARION
Sheriff's Costs:
Docketing 6.00
Out of County .00
Affidavit 1.00
.00
.00
7.00
00/00/0000
this office was in receipt of the
So answers:
R. EThomas Kline
Sheriff of Cumberland County
Sworn and subscribed to before me
this /6j day o
~3 A.D.
~ ' Prothonotary
In The Court of Common Pleas of Cumberland County, Pennsylvania
Cumberland County Tax Claim Bureau
VS.
F~ily Trust of Allen J. Gourley et al
SERVE: Sue F. Gourley No. 03-1056 civil
NOW, M~rrch 21, 2003 , I, SHERIFF OF CUMBE~ COUNTY, PA, do
hereby deputize the Sheriff of Clarion CoUllty to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriffof Cumberland County, PA
Affidavit of Service
Now, April 2, ,2003 ,at 11:35 o'clock A.
within RULE TO SHOW CAUSE AND PETITION FOR RULE FOR JUDICIAL SALE
UpOI1 Sue F. Gourley
at 664 Packing Road, New Bethlehem, PA 16242
by handing to sue F; Gourley personally
a
and made known to
her
Sworn and sabs,:?~bed bet:ore
me this,?'d,/~ day of~_~.~__/., 20
M. served the
copy of the ori~nal
the contents thereof.
S~,~ ~swers,
Sheriff of Clarion County, PA
COSTS
SERVICE
MILEAGE
AFFIDAVIT
$
ANGELA L. MULLIS,
Plaintiff
ROBERT C. MULLIS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL DIVISION - LAW
: NO. 2003 - 1046 CIVIL TERM
:
: CUSTODY IN DIVORCE
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 complaint or for any other claim or relief
requested by the plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 BEDFORD STREET
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: 717-249-3166
ANGELA L. MULLIS,
Plaintiff
ROBERT C. MULLIS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL DIVISION - [,AW
: NO. 2003 - 1046 CIVIL TERM
:
: CUSTODY IN DIVORCE
COMPLAINT FOR CUSTODY
AND NOW, comes Plaintiff, by and through her attorney, John H. Broujos of Broujos & Gilroy,
P.C., and avers as follows:
1. Plaintiff is Angela L. Mullis, an adult individual residing at 600 N. Baltimore Ave, Apt.
G, Mt. Holly Springs, Cumberland County, Pennsylvania 17065.
2. Defendant is Robert C. Mullis, an adult individual residing at 6940 Deters Mill Road,
Apt. 5, Dover, York County, Pennsylvania 17315.
Plaintiff seeks custody of the Child Jessica Lvnne Mullis residing at 600 N. Baltimore
Ave, Apt. G, Mt. Holly Springs, Cumberland County, Pennsylvania 17065.
Jessica Lynne Mullis was bom October 28, 1993.
The Child was bom out of wedlock.
The Child is presently in the custody of Plaintiff. Plaintiff resides at 600 N. Baltimore
Ave, Apt. G, Mt. Holly Springs, Cumberland County, Peunsylvania 17065.
During the past five years, the Child has resided with the following persons and at the
following addresses:
Persons Address Dates
Mother & 53 Regency Woods May 27, 1997 to
Father Carlisle, PA 17013 July, 1999
Mother &
Father
Mother &
Father
Mother & grandparents,
Jackson & Geraldine Smith
Mother
42 Liberty Drive
Mt. Holly Springs, PA 17065
4195 Carlisle Road
Gardners, PA 17324
278 Long's Gap Road
Carlisle, PA 17013
600 N. Baltimore Ave, Apt. G
Mt. Holly Springs, PA 17065
July, 1999 to
August, 2002
August, 2002 to
January 7, 2003
January 7, 2003 to
April 30, 2003
May 1, 2003 to
present
The Mother of the Child is Angela L. Mullis currently residing at 600 N. Baltimore Ave,
Apt. G, Mt. Holly Springs, Cumberland County, Pennsylvania 17065.
She is married to Defendant.
The Father of the Child is Robert C. Mullis, currently residing at 6940 Deters Mill Road,
Apt. 5, Dover, York County, Pennsylvania 17315.
He is married to Plaintiff.
The relationship of Plaintiff to the Child is that of Mother.
The Plaintiff currently resides with the following persons:
Name Relationship
Jessica Lynne Mullis daughter
The relationship of Defendant to the Child is that of Father.
The Defendant currently resides with the following persons:
Name Relationship
Unknown
The Plaintiff has not participated as a party or witness, or in another capacity, in other
litigation concerning the custody of the Child in this or another Court.
7. Plaintiffhas no information of a custody proceeding concerning the Child pending in a
Court of this Commonwealth or any other state.
8. Plaintiff does not know of a person not a party to the proceedings who has physical
custody of the Child or claims to have custody or visitation rights with respect to the
Child.
9. The best interest and permanent welfare of the Child will be served by granting the relief
requested because the Child has been in the custody of the Plaintiff continuously since
the Child's birth, and because the Plaintiff is capable of providing for the Child.
10. Each parent who has parental rights to the Child which have not been terminated and the
person who has physical custody of the Child are parties to the action.
WHEREFORE, Plaintiff requests this Court to grant custody of the Child to Plaintiff.
~e~ly ~mitte~
~ J0 t~nx,~ornH~yB rfcc~u~' ~';'n 1E: sfq?ir~
BROUJOS & GILROY, P.C.
4 North Hanover Street
Carlisle, Pennsylvania 17013
717/243-45'74; FAX 717/243-8227
Date: April 14, 2004
I verify that the statements in the foregoing pleading are true and correct. I understand that false
statements herein are made subject to the penalties of 18 PaCS 4!¢04 relating to unsworn
falsification to authorities, f
Date: April 14, 2004 ~ ~~_
Angela Li