HomeMy WebLinkAbout00-05116
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RICKY LEE KEESEMAN and
WILMA LEE KEESEMAN,
Plaintiffs
:IN THE COURT OF COMMON PLEAS OF
jCUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
; NO. 2000 - 51 (("
CIVIL TERM,
C.IV:t:.L ~RM
GUY B. ELLIOTT, MARGARET
BELL ELLIOTT, MARIAN E.
SWARTZ, MARTHA B.
ELLIOTT, DOROTHY E. MOHN, :
HELEN E. GOOD, DONNA M. : ACTION TO QUIET TITLE
SNYDER, JOYCE S. PAUL,
RALPH S. PAUL, DOUGLAS E.
PAUL, JOSUHA A. SNYDER,
and NICHOLAS A. SNYDER,
Defendants
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in
the following pages, you must take action within twenty (20) days after this complaint
and notice are served, by entering a written appearance personally or by 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
2 Liberty Avenue
Carlisle, P A 17013
(717) 2403~66
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RICKY LEE KEESEMAN and
WILMA LEE KEESEMAN,
Plaintiffs
:IN THE COURT OF COMMON PLEAS OF
;CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
v.
: NO. 2000 - CIVIL TERM
GUY B. ELLIOTT, MARGARET:
BELL ELLIOTT, MARIAN E.
SWARTZ, MARTHA B.
ELLIOTT, DOROTHY E. MORN, :
HELEN E. GOOD, DONNA M. : ACTION TO QUIET TITLE
SNYDER, JOYCE S. PAUL,
RALPH S. PAUL, DOUGLAS E.
PAUL, JOSUHA A. SNYDER,
and NICHOLAS A. SNYDER,
Defendants
COMPLAINT
AND NOW, comes the Plaintiffs, Ricky Lee Keeseman and Wilma Lee
Keeseman, by and through their attorney, Jacqueline M, Verney, Esquire, and file the
following Complaint to Quiet Title and, in support thereof, aver as follows:
I, The Plaintiffs are Ricky Lee Keeseman and Wilma Lee Keeseman,
husband and wife, who presently reside at 101 Gameland Road, Newville, Cumberland
County, Pennsylvania, 17241,
2, The Defendants, Guy B, Elliott and Margaret Bell Elliott, his wife, both
deceased, are prior owners in the chain of title of the property known as 101 Gameland
Road, Newville, Cumberland County, Pennsylvania, On March 16, 1940, Guy B. Elliott
and Margaret Bell Elliott purportedly transferred by deed said property to Albert E,
Keeseman and Virgie V, Keeseman, Guy B, Elliott predeceased Margaret Bell Elliott, no
record of probate was found in Cumberland County Register of Wills, Margaret Bell
.'
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Elliott died testate on May 18, 1962, naming her two daughters and two granddaughters as
her beneficiaries, Said Last Will and Testament is attached hereto as Exhibit "A" ,
3, The Defendants, Marian E, Swartz, Martha B, Elliott, Dorothy E, Mohn
and Helen E, Good are the lawful beneficiaries named in the Last Will and Testament of
Margaret Bell Elliott, Marian E, Swartz died testate on August 9, 1999, Martha B, Elliott
died intestate with her only heirs at law being Dorothy E, Mohn and Helen E, Good,
Dorothy E, Mohn is an adult individual who resides at 12607 Kemwood Lane, Bowie,
Maryland, 20715, Helen E, Good is an adult individual who resides at 821 Hamilton
Street, Carlisle, Pennsylvania.
4, The following Defendants are the lawful beneficiaries pursuant to the Last
Will and Testament of Marian E, Swartz, attached hereto as Exhibit "B": Donna M,
Snyder is an adult individual who resides at 20 Alters Road, Carlisle, PA. Joyce S, Paul is
an adult individual who resides at 212 Homevale Road, Reisterstown, MS, Edwin 1. Paul
is an adult individual who resides at 531 Forest Lane, Cantonsville, MS, Ralph E, Paul is
an adult individual who resides at 819 Aronoco Street, Alexandria, VA. Douglas E, Paul
is an adult individual who resides at 2705 N. Somerset Street, Arlington, VA. Josuha A.
Snyder is an adult individual whose address is 20 Alters Road, Carlisle, P A. Nicholas A.
Snyder is an adult individual whose address is 20 Alters Road, Carlisle, P A.
5. The Plaintiffs transferred their interest in the property located at 101
Gameland Road on July 17,2000 to Jerry M, Fedin and Elva 1. Fedin,
6, The title insurance company insuring the title for the Fedins has requested
an indemnification agreement from the Plaintiffs pending a Quiet Title Order.
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7, The Plaintiffs held title to the property in question by and through a deed
dated June 10, 1983 and recorded February 17, 1984 from Shirley E, Keeseman recorded
at Deed Book 0 30, Page 384, attached hereto as Exhibit "C", The description of said
property is as follows:
ALL THAT CERTAIN tract of land situate in the Township of Upper Mifflin,
County of Cumberland, Commonwealth of Pennsylvania, bounded and described
according to a survey prepared by Larry V, Neidlinger, P,E, R,S" dated July 13,
2000 as follows, to wit:
BEGINNING at a point in th~ road leading to the mountain (Township Road T-
375) on line ofland now or formerly ofIsaac Barrick; thence by said road along
the lands now or formerly of Isaac Barrick South nineteen (19) degrees, forty-six
(46) minutes, forty-four (44) seconds west 108,00 feet to a point in the road (T-
375); thence by the same and a school house lot South twenty (20) degrees, two
(02) minutes, four (04) seconds West 125.40 feet to a bolt in the township road
(T-375; thence by the land of Paul e, Diehl North eighty (80) degrees, twenty-six
(26) minutes, thirty-three (33) seconds West 332,09 feet to an existing iron pin;
thence along Township RoadT-393 North forty-seven (47) degrees, eleven (11)
minutes, eighteen (18) seconds, West 202.50 feet to a point in said road; thence
along the lands of the Pennsylvania Game Commission North eighty-seven (87)
degrees fifteen (15) minutes, zero (0) seconds East 556.18 feet to bolt in the
Township Road (T-375), the Place of BEGINNING,
8, Shirley E, Keeseman and Eamest Keeseman, husband and wife took title
to the property by deed dated August 31, 1959 and recorded September 2, 1959
.
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from Albert E, Keeseman, widower, attached hereto as Exhibit "D". Earnest Keeseman
died September 18, 1974, thereby vesting full and complete title to ShirleyE Keeseman.
9, Albert E, Keeseman and Virgie V, Keeseman, his wife, purportedly
acquired the property on March 16, 1940 from Guy B, Elliott and Margaret Bell Elliott,
his wife, as evidenced by the Recital clause in the August 31, 1959 Deed to Shirley E,
and Emuest Keeseman, Virgie V, Keeseman died February 24, 1959, with all her title
and interest vesting in Albert E. Keeseman, The March 16, 1940 deed was not recorded
and the deed carmot be located.
10, There are no deeds of record from Guy B, Elliott and/or Margaret B,
Elliott for the same property,
11. The Keeseman family has maintained possession and paid taxes on the
property since March 16, 1940 until the transfer dated July 17, 2000,
12, Plaintiffs ask this court to enter an Order to compel the Defendants to set
forth the nature of their claims, or be forever barred from making said claims,
WHEREFORE, the Plaintiffs request the Court to decree the title to said property to be in
the Plaintiffs and to enjoin the Defendants from setting forth any title to said premises or
from impeaching, denying or in any other way attacking the Plaintiffs title to said
property,
Respectfully submitted, \ I
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cqu 'ne M, Verney, Esquire ID # 231~
44 South Hanover Street
Carlisle, P A 17013
(717) 243-9190
Attorney for Plaintiffs
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VERIFICATION
I VERIFY that the statements set forth in the attached document are true and correct to the
best of my knowledge, information and belief, I understand that false statements herein are made
subject to the penalties of 18 Pa, Section 4904 relating to unsworn falsification to authorities,
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'$.T WILL AND TESTAMENT OF · LAST WILL AND TESTA~mNT OF MARGARET B. ,ELLIOTT
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RGARET B. fELL IOTT DECEASED. · I, ~lARGARET B. ELL 10TT, of the Borough of Newvi lIe,
':)..*.**********~*:*********.***
'Umberland County, Pennsylvania, do make and publish this my last will and testament
all former wills heretofore made by me.
,~"I; ~irect my Executor hereinafter named to pay all my just debts, funeral and
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,inis.trative expenses as soon as conveniently may be done after my death.
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i8~r'[lliv:e,:and bequeath the sum of $200.00 to Newville Cemetery, North Newton Township
'~J'i._7';U._::;?:_~,;'
, .,,, ';CC)!ln,tY, Penll~.ylvania, in trust for the perpetual care and maintenance of
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,indd9 '~n iBlo'ck No. H, situate 'in said Cemetery.
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'~"t&ive ~ndbequeath, to my daughter, Marian E. Swartz, my silverware. table linen,
-Sl, ,,',,,,:,
''fge',mir,ror" marble top table and set of blue flower dishes.
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{i, I..,direct that all the rest, residue and remainder of my property shall be
',,,verted into money and distributed as follows:
r: .
a. One-half thereof to my daughter, Marian E. Swartz;
b. One-sixth thereof to my daughter in 1 ai' , Nartha B. Elliott
c. One-sixth thereof to my grand daughter, Dorothy E. ~101ln and
d. One-sixth thereof to my grand daughter, Helen E. Good.
I nominate and appoint my daughter-in-law Martha B. Elliott, as guardian of the share
,'Helen E. Good, until she reaches her majority.
renominate and appoint Perry Swartz as Executor of this my last will and testament.
I hereunto set my hand and seal this 29th day of July 1954.
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WALED; ,PUBLISHED 'and DECLARED by the above named Testatrix, Margaret B. Elliott, as and
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~i;;t will and testa~ent, in our presence who, in her presence, at her request and
Margaret B. Elliott (SE L)
Margaret B. EllIott
presence of each other, have hereunto subscribed our names as attesting witnesses.
Tom H. Bietsch
Harold S. Irwin, Jr.
COUNTY, SS:
day of June A. D. ,1962, before me John W. Mcm llan ,Jr., Register for the Probate
and granting letters of Administration in and for said County of Cumberland
,
the Commonwealth of Pennsylvania, personally came Tom H. Bietsch and Harold S. Irwin,J .,
. subscribing witnesses to the foregoing instrument of writing purporting to be the
'W'.l.,l.
~tWill and Testament of Margaret B. Elliott, Dated July 29, 1954, late of North
ewton Township, Cumberland County, Pa.. Deceased; "ho being duly S"orn according to law,
that they were present and saw and heard the Testatrix, ~largaret B. Elliot
,
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11I~jt litil! att~ QItsta~m
OF
W\RIAN E . SWARTZ
'I, 'MARIAN E. SWARTZ, of Noj:;:tlh NE;jwton ,Township, Cumberland
County, Pennsylvania, declare tlils instrument to be my Last will
and Testament, in manner and form following:
1. I herehy expressly revoke all wills and Codicils
heretofore made by me.
2. I hereby direct my Executrices to pay all my just debts,
funeral and administrative expenses out of my estate, as soon as
,
practicahle after my death~
3. I direct that all taxes that may be assessed in
consequence of my death of whatever nature and by whatever
jurisdiction imposed shall be paid out of my estate as a part of
the administration of my estate.
4.
I give and bequeath such of my personal property as may
be listed on an unsigned memorandum kept with my will to the
persons named thereon.
In the event that no such memorandum is
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found with my Will, itshallJi)'~'I,conclusively presumed that none
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. wa!;i" prepareid and alimy,p~rs,8d,!~,',';111l,,"'j'lP,'toperty shall be considered a
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part of the, remainder of my estate.
5. I give and bequeath ,the sum of One Thousand Five Hundred
Dollars (,$1,500.001 to each of ,my grandchildren, including 'adopted 1
or step-grandchildren, who ~ur~ive my death.
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6. Ii devise and bequeath the remainder of my estate to my
issue, per, stil:'pes. '
7. I nominate and, appoint my daughters , Joyc,eS..Paul arid'
'.,
D&Jnna S~ Snyder, EXebuj:.!I:'irces!;o4S:thi~ 'lllY Last Will. arid Te$tamE)nti:i;'
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and I directthclt they shall;!'lot he required to file bond .for the
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performance of their duties in any jurisdiction.
IN WITNESS WHEREOF, I have hereunto set my hand and seal
this I st day of
5~
-4Jf~~f:A4
, 1988.
(SEAL 1
WITNESS:
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MADE the day of
in the year ninteen hundred and eighty three (! 983)'
Between SHIRLE'! E. KEESEMAN, of the Township of
Cumberland, and Commonwealth of Pennsylvania,
June
Upper Mifflin, County of
AND
Grantor,
RICKY LEE KEESEMAN and WILMA LEE KEESEMAN, his wife, of Route 2, Box 201,
Witnesseth That in consideration of One Dollar plus other good and valuable
cons1derat1on~-------------------------_________________________________
DollafJf,
grantor
in hand paid.
does,
the receipt whereof is hereby acknowledged, the said
grant and convey in fee simple to said grantee s
All that certsin tract of land situate in the Township of Upper Mifflin.
County of Cumberland and Commonweslth of Pennsylvania, bounded and
described as 'follows, to-wit:
BEGINNING at a point in the rosd lesding to the mountain on line of land
now or formerly of Issac Bsrrick; thence by land of Pennsylvania Game
Commission South 87 degrees, 15 minutes, West 556.18 feet to a point
in the road; thence by same and along a mountain rosd South 44 degrees
44 minutes East 195.5 feet to a post in a Township Road; thence by land
now or formerly of Maude Swsrt~ and along the said, Township Road South
72 degrees Ei:.st 2.0 perches, thenco' by lROuntoin rC'Qd along 0.' st'l'hool hQ"4e
lot North 32 degrees East 7.6 perches; thence by said road and by school
house lot and land now or formerly of Isaac: Barrick North 19 degrees,
8 minutes, East
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BEING the same tract of land which Albert E. Keeseman. widower. by his
deed dated August 31. 1959 and recorded in the Office of the Recorder
of Deeds in and for Cumberland County in Deed Book J, Volume 19 at Page
146, granted and conveyed to Earnest Keeseman and Shirley E.Keeseman,
his wife. Earnest Keeseman died September 18, 1974 thereby vesting full
and complete title in Shirley E. Keeseman, Grantor herein.
THIS IS A CONVE'!ANCE FROM MOTIIER TO SON.
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SOOK D30 rm 384
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;lOI.IIT. WIlHllnl)" UIl'ClOII, Short t-.orm. Aet ul IGoe. SlnKI. Sh..t,
11.1'1', IhllI. Inl".. In.llan.. t....
Jf..lJJ8 'fHA' 31st dOIJ 01 August in the lIe((r
,,111I1/' I,ol'd "'It' /!/lI((sa7ld ni,,,, hundred and fifty-nine
m:TlI'r:l<;N ALBERT E. KEESEMAN, Widower, of the Township of Upper
Mifflin, County of cumberland and State of Pennsylvania,
party of the first part l;rl1l,tlll'
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EARNEST KEESEMAN and SHIRLEY E. KEESEMAN, his wife,
of the Township of Upper Mifflin, County of Cumberland,
and State of Pennsylvania, parties of the second part
(;nl1rlCf' S.
11'17',\'fo:.~Sb'T/I, tllClt in clII",icl"l'ation 01
, One ($1. 00) and all other good and valuable considerations--lJolI,I/....
'" /m"d Mid, 1111' "I'cei})1 w/.....ol i" h.reby lIcknowledued, tlw ""id f/I'an!o,. dll ei,.,.eby IImnl
"71r11'1I/11'rll10 III,' said grt;ntelS . ALL that certain tract of land situate in
...
the Township of Upper Mifflin, County of umberland and State of
Pennsylvania, bounded and described as follows, to-wit:
BEGINNING at a point in the road leading to the mountain on
line of land of Isaac Barrick; thence by land of Pennsylvania Game
Commission South Eighty Seven (87) degrees, Fifteen (15) minutes,
West Five Hundred and Fifty-six and Eight Tenths (556.8) feet to
a point in the road; thence by same and along a mountain road South
Forty-Four (44) degrees Forty-Four (44) minutes East One Hundred
Ninty-Five and Five Tenth (95.5) feet to a post in a Township Read;
thence by land of Maude Swartz and along the said Township Road
South Seventy Two (72) degrees East, Twenty (20) perches; thence
by mountain road along a school house lot North Thirty-Two (32)
degrees East, Seven and Six Tenth (7.6) perches; thence by stid
road and by school house lot and land of Isaac Barrick North
Nineteen (19) degrees, Eight (8) minutes, East
feet, to the place of BEGINNING.
CONTAINING Two (2) Acres, more or less.
BEING part of the same tract of land which Guy B. Elliott,
and Margaret Bell Elliott, his wife by their deed dated the 16th
day of March, 1940, and recorded in Deed Vook ,Volume,
Page , conveyed unto Albert E. Keeseman and Virgie V. Keeseman,
his wife, (Virgie V. K~eseman having died on the 24th day of Februray
1959, thereby vesting entire fee in Albert E. Keeseman) Grantor, here.
in named.
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RICKY LEE KEESEMAN and
WILMA LEE KEESEMAN,
Plaintiffs
:IN THE COURT OF COMMON PLEAS OF
jCUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
v.
: NO. 2000 - 5116
CIVIL TERM
GUY B. ELLIOTT, MARGARET
BELL ELLIOTT, MARIAN E.
SWARTZ, MARTHA B.
ELLIOTT, DOROTHY E. MORN, :
HELEN E. GOOD, DONNA M. : ACTION TO QUIET TITLE
SNYDER, JOYCE S. PAUL,
RALPH S. PAUL, DOUGLAS E.
PAUL, JOSUHA A. SNYDER,
and NICHOLAS A. SNYDER,
Defendants
PRAECIPE TO CORRECT CAPTION
TO THE PROTHONOTARY:
Please correct the Caption of the above matter to include Edwin 1. Paul, who is
identified in Paragraph 4 of the Complaint as a defendant but whose name was
inadvertently excluded from the Caption,
Respectfully submitted, (
five. V~
cqu ine M. Verney, Esquire ID # 2316];Y-'
44 South Hanover Street
Carlisle, P A 17013
(717) 243-9190
And Now, this ; 'I day of J;; I v , 2000, the above Caption shall be corrected to
(
include Edwin 1. Paul.
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Prothonotary {? {'fI~
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-05116 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
KEESEMAN RICKY LEE ET AL
VS
ELLIOTT GUY B ET AL
GERALD W. WORTHINGTON
, Sheriff or Deputy Sheriff of
Cumberland County, pensylvania, who being duly sworn according to law,
says, the within NOTICE & ACTION TO
was served upon
GOOD HELEN E
the
DEFENDANT
, at 0017:15 HOURS, on the 26th day of July
, 2000
at 821 HAMILTON STREET
CARLISLE, PA 17013
by handing to
HELEN E. GOOD
a true and attested copy of NOTICE & ACTION TO
together with
QUIET T!TLE, PREACIPE TO CORRECT CAPTION,
LETTER FROM ATTY TO EACH DEFENDANT
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
3.10
.00
10.00
.00
31. 10
So Answers:
r"~ ~~-t:~~
R, Thomas Kline
07/27/2000
JACQUELINE VERNEY
Sworn and Subscribed to before
me this tAl/"
day of
BY~/~~
Deputy Sheri f
{L~ AD
t2 /tUfj'd ,#'
P othonotary
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-05116 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
KEESEMAN RICKY LEE ET AL
VS
ELLIOTT GUY B ET AL
GERALD WORTHINGTON
, Sheriff or Deputy Sheriff of
Cumberland County, pensylvania, who being duly sworn according to law,
says, the within NOTICE & ACTION TO QUIET was served upon
SNYDER DONNA M the
DEFENDANT
, at 0017:55 HOURS, on the 26th day of July
, 2000
at 20 ALTERS ROAD
CARLISLE, PA 17013
by handing to
DONNA M. SNYDER
a true and attested copy of NOTICE & ACTION TO QUIET together with
TITLE, PREACIPE TO CORRECT CAPTION, LETTER
FROM ATTY TO EACH DEFENDANT
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
3.10
.00
10.00
.00
19,10
So Ans~~~~,. ,
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R, Thomas Kline
07/27/2000
JACQUELINE VERNEY
Sworn and Subscribed to before
me this JAA-
day of
BY:;4 W~
~puty Sh' iff
~.u...J- rJ-fHTD A , D .
~~ Q rv. .00." AfJtli
P othonotary ,
"- ~~ , J.'J!.
.
SHERIFF'S RETURN - REGULAR
CASE NO: 2000-05116 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
KEESEMAN RICKY LEE ET AL
VS
ELLIOTT GUY B ET AL
GERALD WORTHINGTON
, Sheriff or Deputy Sheriff of
Cumberland County, pensylvania, who being duly sworn according to law,
says, the within NOTICE & ACTION TO QUIET was served upon
SNYDER JOSUHA A the
DEFENDANT
, at 0017:15 HOURS, on the 26th day of July
, 2000
at 20 ALTERS ROAD
CARLISLE, PA 17013
by handing to
DONNA SNYDER
a true and attested copy of NOTICE & ACTION TO QUIET together with
TITLE, PREACIPE TO CORRECT CAPTION, LETTER
FROM ATTY TO EACH DEFENDANT
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
.00
16.00
So Answers:
~~~~<~
R. Thomas Kline
07/27/2000
JACQUELINE VERNEY
Sworn and Subscribed to before
me this jAA-
day of
BY~ u.)~
D~ .
Deputy She f
n;:r :ttnrD A. D.
Oy' o. ~ ~
Prothonotary
_l'&T';,
-
SHERIFF'S RETURN - REGULAR
CASE NO: 2000-05116 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
KEESEMAN RICKY LEE ET AL
VS
ELLIOTT GUY B ET AL
GERALD WORTHINGTON
, Sheriff or Deputy Sheriff of
Cumberland County, pensylvania, who being duly sworn according to law,
says, the within NOTICE & ACTION TO QUIET was served upon
SNYDER NICHOLAS A the
DEFENDANT
, at 0017:55 HOURS, on the 26th day of July
, 2000
at 20 ALTERS ROAD
CARLISLE, PA 17013
by handing to
DONNA SNYDER
a true and attested copy of NOTICE & ACTION TO QUIET together with
TITLE, PREACIPE TO CORRECT CAPTION, LETTER
FROM ATTY TO EACH DEFENDANT
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
.00
16.00
Sb Answers:
r~l~,"<:~~
R. Thomas Kline
07/27/2000
JACQUELINE VERNEY
Sworn and Subscribed to before
BY:.-2f1o~ bJ~
Deputy Sher f
me this I~ day of
aq;;dl wi) A. D.
{), n,,,~t?,,.,~,
P othonotary
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RICKY LEE KEESEMAN and
WILMA LEE KEESEMAN,
Plaintiffs
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
..
GUY B. ELLIOTT, MARGARET NO. 2000-5116 CIVIL TERM
BELL ELLIOTT, MARIAN E.
SWARTZ, MARTHA B. ELLIOTT:
DOROTHY E. MORN, HELEN E.: ACTION TO QUIET TITLE
GOOD, DONNA M. SNYDER,
JOYCE S. PAUL, RALPH S.
PAUL, DOUGLAS E. PAUL,
EDWIN L. PAUL, JOSHUA A.
SNYDER, NICHOLAS A.
SNYDER,
Defendants
ORDER
AND NOW, this :3 o' ,day of
(JJU1l"-c....
, 2000, an affidavit of service of
the complaint with notice to defend and notice of Praecipe for entry of judgment by default
having been filed, and no answer having been made by defendants, upon consideration of
the motion of plaintiffs pursuant to Pa,R,C,P, No, 1066(a), it is hereby ORDERED that a
judgment by default be entered against defendants directing defendants, Guy B. Elliott,
Margaret Bell Elliott, Marian E. Swartz, Martha B, Elliott, Dorothy E. Mohn, Helen E. Good,
Donna M, Snyder, Joyce S. Paul, Ralph S. Paul, Douglas E, Paul, Edwin L. Paul, Joshua A.
Snyder, Nicholas A. Snyder and any person claiming under, defendants are permanently
enjoined and restrained from asserting any claim or interest in or to the following real
property or any part thereof,
ALL THAT CERTAIN tract of land situate in the Township of Upper Mifflin, county of
Cumberland, Commonwealth of Pennsylvania" bounded and described according to
a survey prepared by Larry V, Neidlinger, P,E. R.S., dated July 13, 2000 as follows,
to wit
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BEGINNING at a point in the road leading to the mountain (Township Road T.375)
on line of land now or formerly of Isaac Barrick South nineteen (19) degrees, forty-
six (46) minutes, forty-four (44) seconds west 108,00 feet to a point in the road (T-
375); thence by the same and a school house lot South twenty (20) degrees, two
(02) minutes, four (04) seconds West 125.40 feet to a bolt in the township road (T-
375); thence by the land of Paul E, Diehl North eighty (80) degrees, twenty-six (26)
minutes, thirty-three (33) seconds West 332.09 feet to an existing iron pin; thence
along Township Road T-393 North forty. seven (47) degrees, eleven (11) minutes,
eighteen (18) seconds, West 202,50 feet to a point in said road; thence along the
lands of the Pennsylvania Game Commission North eighty-seven (87) degrees
fifteen (15) minutes, zero (0) seconds East 556,18 feet to bolt in the Township
Road (T-375), the Place of BEGINNING.
BY THE COURT,
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,
- .
RICKY LEE KEESEMAN and
WILMA LEE KEESEMAN,
P1ai.nti.ffs
vs.
GUY B. ELLIOTT, MARGARET
BELL ELLIOTT, MARIAN E.
SWARTZ, MARTHA'B. ELLIOTT:
I,', '
DOROTHY E. 'MO~, HELEN E. :
GOOD, DONNA M.. SNYDER,
JOYCE S. PAUL, RALPH S.
PAUL, DOUGLAS E. PAUL,
EDWIN L. PAUL, JOSHUA A.
SNYDER, NICHOLAS A.
SNYDER,
Defendants
,'. .-
MJiJ'-
(
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-5116 CIVIL TERM
ACTION TO QUIET TITLE
MOTION FOR DEFAULT JUDGMENT TO QUIET TITLE
AND NOW, comes, the Plaintiffs, Ricky Lee Keeseman and Wilma Lee Keeseman,
by and through their attorney, Jacqueline M, Verney, Esquire, and files this motion for
default judgment against the defendants and in support thereof avers the following:
1. This is an action to quiet title in which the plaintiffs request that defendants,
Guy B. Elliott, Margaret Bell Elliott, Marian E. Swartz, Martha B, Elliott,
Dorothy E, Mohn, Helen E. Good, Donna M. Snyder, Joyce S, Paul, Ralph S,
Paul, Douglas E. Paul, Edwin L, Paul, Joshua A, Snyder, Nicholas A. Snyder, or
any person claiming under defendants be permanently enjoined and restrained
from asserting any claim or interest in or to real property described in
plaintiff's complaint, a copy of which is attached as Exhibit "A",
2, Attached as Exhibit "B" is an affidavit stating that a complaint containing a
notice to defend and a notice of Praecipe for entry of judgement by default was
served upon the living defendants and that the living defendants did not file an
answer to the complaint.
"""1~\!,"
- .
,
3, Pa. R.C,P, No, 1066(a) allows the Court to grant appropriate relief on affidavit
that a complaint containing notice to defend has been served and the
defendants have not filed an answer,
WHEREFORE, plaintiffs request this Court enter an Order of default judgment
against defendants pursuant to Pa, R,C.P. 1066(a),
Respectfully submitted,
iO'4-ov
~~ (l,\,
I-'---
cq eline M. Verney, Esqu re
Attorney for Plaintiffs
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
1. D. No. 23167
I
2
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ALL THAT CERTAIN tract of land situate in the Township of Upper Mifflin, county of
Cumberland, Commonwealth of Pennsylvania, bounded and described according to
a survey prepared by Larry V, Neidlinger, P,E, R.S" dated July 13, 2000 as follows,
to wit
BEGINNING at a point in the road leading to the mountain (Township Road T-375)
on line of land now or formerly of Isaac Barrick South nineteen (19) degrees, forty-
six (46) minutes, forty-four (44) seconds west 108,00 feet to a point in the road (T-
375); thence by the same and a school house lot South twenty (20) degrees, two
(02) minutes, four (04) seconds West 125.40 feet to a bolt in the township road (T-
375); thence by the land of Paul E, Diehl North eighty (80) degrees, twenty-six (26)
minutes, thirty-three (33) seconds West 332,09 feet to an existing iron pin; thence
along Township Road T-393 North forty-seven (47) degrees, eleven (11) minutes,
eighteen (18) seconds, West 202.50 feet to a point in said road; thence along the
lands of the Pennsylvania Game Commission North eighty-seven (87) degrees
fifteen (15) minutes, zero (0) seconds East 556,18 feet to bolt in the Township
Road (T-375), the Place of BEGINNING.
EXHIBIT "A"
~" .-~
,-
RICKY LEE KEESEMAN and
WILMA LEE KEESEMAN,
Plaintiffs
VS.
GUY B.. ELLIOTT, MARGARET
BELL,ELLIOTT, MARIAN E.
SWAR~Z, MARTHA B. ELLIOTT:
DORO';t'HY E. MORN, HELEN E. :
GOOD, DONNA M. SNYDER,
JOYCE S. ' PAUL, RALPH S.
PAUL, DOUGLAS E. PAUL,
EDWIN L. PAUL, JOSHUA A.
SNYD~R, NICHOLAS A.
SNYD~R,
Defendants
~ ~
, ii'~~~i
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-5116 CIVIL TERM
ACTION TO QUIET TITLE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
: SS
I, Jacqueline M. Verney, Esquire, being duly sworn according to law, deposes and
says that she is the attorney for the plaintiffs in this action and makes this affidavit on
behalf of the plaintiffs, being authorized to do so; that a complaint in this action to quiet
title, containing notice to defend within twenty days of service was duly served on the living
defendants, Heien E, Good, Donna M. Snyder, Joshua A, Snyder, and Nichoias A, Snyder,
by personai service by the deputy sheriff of Cumberland County on July 26, 2000, and
living defendants, Douglas E, Paui, Ralph S. Paul, Dorothy E, Mohn, Joyce E. Paul, and
Edwin L. Paul, by certified mail, return receipt requested, restricted delivery on September
5, 2000, August 14, 2000, July 26, 2000, July 26, 2000, and August 18, 2000,
.,;
.-
--~ ;
'_M
"-
'-=i,i<>
respectively. The sheriff returns and the return receipts are attached hereto as Exhibit
'Ie",
I further certify that a Notice of Praecipe for Entry of Judgment by Default was also
mailed to all living defendants on September 25, 2000 to the addresses at which personal
service and certified mail service was accomplished. Copies of said notices are attached
hereto as Exhibit "0".
More than twenty (20) days has passed since the complaints were served and
more than ten days have passed since the Notice of Entry of Judgment by Default was
mailed, To date, none of the living defendants have filed an answer to the action,
lu^ 9 - 0""<.)
,,:~~~ ;t~. (j
(ilacq 'line M. Verney, Esqu~'
Attorney for Plaintiffs
Sworn to and subscribed before me, this ~ day of~lOOQ)L ,2000.
NOTARIAL SEAL
Vickie J. Group, Notary Public
Borough of Carlisle, County of Cumberland
My Commission Expires Aug. 30, 2004
2
SHERIFF'S RETURN
REGULAR
CASE NO: 200.0-05116 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
KEESEMAN RICKY LEE ET AL
VS
ELLIOTT GUY B ET AL
GERALD W. WORTHINGTON
Sheriff or Deputy Sheriff of
Cumberland County, Pensylvania, who being duly sworn according to law,
says, the within NOTICE & ACTION TO
was served upon
GOOD BELEN E
the
DEFENDANT
, at 0017:15 HOURS, on the 26th day of July
, 2000
at 821 HAMILTON STREET
CARLISLE, PA 17013
by handing to
HELEN E. GOOD
a true and attested copy of NOTICE & ACTION TO
together with
QUIET TITLE, PREACIPE TO CORRECT CAPTION,
LETTER FROM ATTY TO EACH DEFENDANT
and at the same time directing Her attention to, the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
3,10
,00
10.00
.00
31.10
So Answers:
~~~-~~<
R. Thomas Kline
07/27/2000
JACQUELINE VERNEY
Sworn and Subscribed to before
me this
day of
BY:~'/~~_
Deputy SheIi f
A.D,
Prothonotary
SHERIFF'S RETURN - REGULAR
CASE NO: 2000-05116 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
KEESEMAN RICKY LEE ET AL
VS
ELLIOTT GUY B ET AL
GERALD WORTHINGTON
, Sheriff or Deputy Sheriff of
Cumberland County, Pensylvania, who being duly Sworn according to law,
says, the within NOTICE & ACTION TO QUIET was served upon
SNYDER DONNA M the
DEFENDANT
, at 0017:55 HOURS, on the 26th day of July
, 2000
at 20 ALTERS ROAD
CARLISLE, PA 17013
by handing to
DONNA M. SNYDER
a true and attested copy of NOTICE ~ ACTION TO QUIET together with
TITLE, PREACIPE TO CORRECT CAPTION, LETTER
FROM ATTY TO EACH DEFENDANT
and at the same time directing Her attention to the contents thereof.
Sheriff'S Costs:
Docketing
Service
Affidavit
Surcharge
6.00
3.10
.00
10.00
.00
19.10
SO?~~f
R. Thomas Kline
07/27/2000
JACQUELINE VERNEY
Sworn and Subscribed to before
me thi s
day of
By: 24 ~~
'.fl~ '.
" Deputy Sh ' iff
A,D.
. Prothonotary
~ I
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,
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SHERIFF'S RETURN
REGULAR
CASE NO: 2000-05116 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
KEESEMAN RICKY LEE ET AL
VS
ELLIOTT GUY B ET AL
GERALD WORTHINGTON
, Sheriff or Deputy Sheriff of
Cumberland County, Pensyl vania , who being duly SWorn according to law,
says, the within NOTICE & ACTION TO QUIET was served upon
SNYDER JOSUHA A the
DEFENDANT
, at 0017:15 HOURS, on the 26th day of July
, 2000
at 20 ALTERS ROAD
CARLISLE, PA 17013
by handing to
DONNA SNYDER
a true and attested copy of NOTICE & ACTION TO QUIET together with
TITLE, PREACIPE TO CORRECT CAPTION, LETTER
FROM ATTY TO EACH DEFENDANT
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
,00
10.00
.00
16.00
So Answers:
~~~-~~~
R. Thomas Kline
07/27/2000
JACQUELINE VERNEY
Sworn and Subscribed to before
me this
day of
By: 4 IA)~'
ofi...tA-
Deputy Sne f
A.D.
Prothonotary
-
'-
~ - ~i
SHERIFF'S RETURN
REGULAR
CASE NO: 2000-05116 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
KEESEMAN RICKY LEE ET AL
VS
ELLIOTT GUY B ET AL
GERALD WORTHINGTON
, Sheriff or Deputy Sheriff of
Cumberland County, pensylvania, who being duly sworn according to law,
says, the within NOTICE & ACTION TO QUIET was served upon
SNYDER NICHOLAS A the
DEFENDANT
, at 0017:55 HOURS, on the 26th day of July
, 2000
at 20 ALTERS ROAD
CARLISLE, PA 17013
by handing to
DONNA SNYDER
a true and attested copy of NOTICE & ACTION TO QUIET together with
TITLE, PREACIPE TO CORRECT CAPTION, LETTER
FROMATTY TO EACH DEFENDANT
and at the same time directing Her attention to the contents thereof,
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
.00
16.00
So Answers:
r~""tl".c:~~
R, Thomas Kline
07/27/2000
JACQUELINE VERNEY
Sworn and Subscribed to before
day of
BY:-XfD~ IA)~
. Deputy She f
me this
A.D.
Prothonotary
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102695-07-B'()179 Domestic I'IetIl~n Receipt
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item 4 if Restricted Delivery is desired.
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4. Restricted Delivery? (Extra Fee)
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2. Article Number (Copy from service Jabel)-
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PS Form 3811, July 199_e Domestic Return Receipt
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I -Plint yOur 118/11.,~~d address on the reverse of this form 80 that we can retum this
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"~ . -Attach:this 1oro1"1o the front of the mailpiece, or on the back H space does not
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'. Cofti': 'Ie' e 'items 1; 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
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or on the front if space permits.
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4. Restricted Delivery? (Extra Fee)
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2. Article Number (Copy from service JabeQ
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.
:~,\i'
RICKY LEE KEESEMAN and
WILMA LEE KEESEMAN,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
GUY B. ELLIOTT, MARGARET
BELL ELLIOTT, MARIAN E.
SWARTZ ,MARTHA B . ELLIOTT:
DOROTHY E.. MORN, HELEN E. :
GOOD, DpNNA M.. SNYDER,
JOYCE S;PAUL, ltlU.PH S.
PAUL, DOUGLASE. PAUL,
EDWIN L.. PAUL, JOSHUA A.
SNYDER, NICHOLAS A.
SNYDER,
Defendants
NO. 2000-5116 CIVIL TERM
ACTION TO QUIET TITLE
NOTICE OF PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT
To: DOROTHY E. MOHN
Date of Notice: September 25, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN
WRITING WITH THE COURT YOUR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER
AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE
YOU CAN GET LEGAL HELP:
"
~ I ;;z.>/ttV
~
"J
" ~,-.
~~."
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE: (717) 249-3166
.i
{
aceline M. Verney, Esq
Attorney for Plaintiff
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
1. D. No. 23167
/,
2
.
llIHlitoitLil
re
-
RICKY LEE KEES~ and
WILMA LEE KEES~,
Plaintiffs
vs.
G~ B. ELLIOTT, MARGARET
BELL ELLIOTT, MARIAN E.
SWARTZ, MARTHA B. ELLIOTT:
DOROTHY E. MORN, HELEN E. :
GOOD, DONNA M. SNYDER,
JOYCE S. PAUL, RALPH S.
PAUL, DOUGLAS E. PAUL,
EDWIN L. PAUL, JOSHUA A.
SNYDER, NICHOLAS A.
SNYDER,
Oefendants
'"
':
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-5116 CIVIL TERM
ACTION TO QUIET TITLE
NOTICE OF PRAECIPE FOR ENTRY.OF JUDGMENT BY DEFAULT
To: HELEN E. GOOD
Date of Notice: September 25, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN
WRITING WITH THE COURT YOUR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER
AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE
YOU CAN GET LEGAL HELP:
9/:1..'> I,v
~- "
"
.J'
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE: (717) 249-3166
ILL./L
ac ue1ine M. Verney, quire
Attorney for Plaintiff
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
1. D. No. 23167
2
-,," .
-'.-.......--:1'\
'"
RICKY LEE KEESEMAN and
WILMA LEE KEESEMAN,
Plaintiffs
vs.
GUY B. ELLIOTT, MARGARET
BELL ELLIOTT, MARIAN E.
SWARTZ, MARTHA B. ELLIOTT:
DORO'l'HY E. MO~, HELEN E. :
GOOD, DONNA M. SNYDER,
JOYCE S. PAUL, RALPH S.
PAUL, DOUGLAS E. PAUL,
EDWIN L. PAUL, JOSHUA A.
SNYDER, NICHOLAS A.
SNYDER,
Defendants
~,~
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-5116 CIVIL TERM
ACTION TO QUIET TITLE
NOTICE OF PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT
To: DONNA M. SNYDER
Date of Notice: September 25, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN
WRITING WITH THE COURT YOUR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER
AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE
YOU CAN GET LEGAL HELP:
":
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE: (717) 249-3166
1 /~S /t,."
b~ fi;l.V~ -
a 'ueline M. Verney, ~quire
Attorney for Plaintiff
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
1. D. No. 23167
2
.
. .
fJ:+,
RICKY LE~ KEESEMAN and
WILMA LEE! KEESEMAN,
Plaintiffs
vs.
GUY B. E~LIOTT, MARGARET
BELL ELL~OTT,MARIAN E.
SWARTZ, MARTHA B. ELLIOTT:
DOROTHY J!l. ~OHN, HELEN E. :
GOOD, DO~A ~. SNYDER,
JOYCE S.PAUL, :RALPH S.
PAUL, DO~GLAS E. PAUL,
EDWIN L. 'PAUL, JOSHUA A.
SNYDER, NICHOLAS A.
SNYDER,
Defe.ndants
.
-
,_ '~ F'_~
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-5116 CIVIL TERM
ACTION TO QUIET TITLE
NOTICE OF PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT
To: JOYCE S. PAUL
Date of Notice: September 25, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN
WRITING WITH THE COURT YOUR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER
AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE
YOU CAN GET LEGAL HELP:
^
"
_h'
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE: (717) 249-3166
C111- ,;I tJo
~ /c,L,~
ac eline M. Verney, Es uire
Attorney for Plaintiff
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
LD. No. 23167
2
RICKY LEE KEESEMAN and
WILMA LEE KEESEMAN,
Plaintiffs
VB.
GUY ~. ELLIOT.T, MARGARET
BELL ELLIOTT, . MAR:IAN E.
I ,',' ',,'
SlfARTZ, MARTHA~ . ELLIOTT:
DOROTHY E, MORN, HELEN E.:
GOOD, DONNA M.SNYDER,
JOYCE S. PAUL, . RALPH S.
,
P~UL, DOUGLAS E. PAUL,
EJ;1WIN L. PAUL, JOSHUA A.
SlfYDER,NICHOLAS A.
SNYDER,
Defendants
~ . ,
" -,
..........''W:-,i,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-5116 CIVIL TERM
ACT:ION TO QUIET T:ITLE
NOTICE OF PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT
To: RALPH S.PAUL
Date of Notice: September 25, 2000
IMPORTANT NOT:ICE
YOU ARE IN DEFAULT BECAUSE YOU FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN
WRITING WITH THE COURT YOUR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER
AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE
YOU CAN GET LEGAL HELP:
, .
, "
^,- ~
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE: (717) 249-3166
cr(;L~/1P
ac ue1ine M. Verney,
ttorney for Plaintiff
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
1. D. No. 23167
2
cr
RICKY LEE KEESEMAN and
WILMA LEE KEESEMAN,
Plaintiffs
vs.
GUY B. ELLIOTT, MARGARET
BELL EL~I6TT, MARIAN E.
SWARTZ, MARTHA B. ELLIOTT:
DOROTHY E. MORN, HELEN E. :
GOOD, DONNA .M. SNYDER,
JOYCE S. PAUL, RALPH S.
PAUL, DOUGLAS E. PAUL,
EIlWIN L. PAUL, JOSHUA A.
SNYDER, NICHOLAS A.
SNYDER,
Defendants
~ ~~
; ,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-5116 CIVIL TERM
ACTION TO QUIET TITLE
NOTICE OF PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT
To: DOUGLAS E. PAUL
Date of Notice: September 25, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN
WRITING WITH THE COURT YOUR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER
AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE
YOU CAN GET LEGAL HELP:
~
-
-
'$'0-
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE: (717) 249-3166
cr I~s(o"
~\.
. ac eline M. Verney, Es ire
ttorney for Plaintiff
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
1. D. No. 23167
2
~
d/Mil'llil!lliililfil\i!'
-'
RICKY LEE KEESEMAN and
WILMA LEE KEESEMAN I
Plaintiffs
vs.
GUY :S. ELLIOTT, ,MARGARET
, ,
BELL ELLIOT1', ~IAN E.
SWART:Z;, MARTHA a. ELLIOTT:
DOROTHYE. MOEnJ,: HELEN E. :
GOOD. DONNA M. SNYDER,
JOYCES. PAUL, RALPH S.
PAUL ,DOUGLAS E . PAUL,
EDWIN L. PAUL, JOSHUA A.
SNYD~R, NICHOLAS A.
SNYD~R,
Defendants
- '-
-W~-if~-
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-5116 CrvIL TERM
ACTION TO QUIET TITLE
NOTICE OF PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT
To: EDWIN L. PAUL
Date of Notice: September 25, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN
WRITING WITH THE COURT YOUR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER
AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE
YOU CAN GET LEGAL HELP:
g
""
~ ~
""'""-"ji;,;
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE: (717) 249-3166
r I~..)/~
A.th
ac eline M. Verney, E uire
ttorney for Plaintiff
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
1.D. No. 23167
2
"
RICKY LEE KEESEMAN and
WILMA LEE KEESEMAN,
Plaintiffs
vs.
GUY B. ELLIOTT, MARGARET
BELL ELLIOTT, MARIAN E.
SWARTZ, MARTHA B. ELLIOTT:
DOROTHY E. MOHR, HELEN E. :
GOOD, DONNA. M. SNYDER,
JOYCE S. PAUL, RALPH S.
PAUL, DOUGLAS E. PAUL,
EDWIN L. P).UL, JOSHUA A.
SNYDER, NICHOLAS A.
SNYDER,
Defendants
I~K;
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-5116 CIVIL TERM
ACTION TO QUIET TITLE
NOTICE OF PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT
To: JOSHUA A. SNYDER
Date of Notice: September 25, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN
WRITING WITH THE COURT YOUR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER
AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE
YOU CAN GET LEGAL HELP:
,
J,
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE: (717) 249-3166
1 (.:~s /0-0
'11;.0
ac eline M. Verney, Esqu re
Attorney for Plaintiff
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
1.0. No. 23167
2
,,"'
~~-
"~
RICKY LEE KEE$EMAN and
WILMA LEE KEE$EMAN,
Plaintiffs
vs.
GUY B. ELLIOTT, MARGARET
BELL ELLIOTT, MARIAN E.
SWARTZ, MARTHA B. ELLIOTT:
DOROTHY E. MORN, HELEN E. :
GOOD, DOlnfA M. SNYDER,
JOYCE S.PAUL, RALPH S.
PAUL, DOUG~ E. PAUL,
EDWIN L. PAUL, JOSHUA A.
SNYDER, NICHOLAS A.
SNYDER,
Defendants
, "
;t,~::
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-5116 CIVIL TERM
ACTION TO QUIET TITLE
NOTICE OF PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT
To: NICHOLAS A. SNYDER
Date of Notice: September 25, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN
WRITING WITH THE COURT YOUR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER
AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE
YOU CAN GET LEGAL HELP:
.
cr h-s I cr-u
-~-I
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE: (717) 249-3166
~ '
'!y;,',
~-0-
ac e1ine M. Verney, Esqu. e
Attorney for Plaintiff
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
LD. No. 23167
2
lU
~.~
".~~ -- .,
.'-
"'~i!:;
, .
.
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Motion for Default
Judgement for Quiet Judgment was served on the following persons by First Class Mail,
postage prepaid on the date indicated:
Douglas E, Paul
2705 N, Somerset St.
Arlington, VA 22213
Ralph S, Paul
819 Oronoco St.
Alexandria, VA 22314
Dorothy E, Mohn
12607 Kemwood Lane
Bowie, MD 20715
Edwin 1. Paul
5 31 Forest Lane
Cantonsville, MS 21228
Joyce E, Paul
212 Homevale Road
Reisterstown, MS 21136
Helen E, Good
821 Hamilton Street
Carlisle, P A 17013
Donna M, Snyder
20 Alters Road
Carlisle, P A 17013
Joshua A. Snyder
20 Alters Road
Carlisle, P A 17013
Nicholas A. Snyder
20 Alters Road
Carlisle, P A 17013
,,~,. .~-,
.
Date: t/)~t()-rN
,. ~
n~
~~:""
,
cqu ine M, Verney, Esquire #231
44 South Hanover Street
Carlisle, P A 17013
(717) 243-9190
Attorney for natural mother
-. .'~
~,
''!!!<f"
, F:\FILES\DATAFILE\DONEGAL.DOC\J66_def.lImah
Created: 04f25fOl04:21:34PM
Revised: 04/25fOI04:51:50PM
3050.166
JOANNA DANNER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v,
CNIL ACTION - LAW
NO, 2000-5156
KEVIN ULSH, .
Defendant,
JURY OF TWELVE DEMANDED
TO: KEVINULSH, DEFENDANT
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN TillS CASE, UNLESS YOU ACT WITHIN TEN (10) DAYS FROM
THE DATE OF TillS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOUWITIIOUT
A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO ALA WYER AT ONCE, IF YOU DO NOT HA VB A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE
TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Peunsy1vania 17013
Telephone (717) 249-3166
MARTS ON DEARDORFF WILLIAMS & OTTO
By
Ge ge B, Faller, Jr" Esq e
LD, Number 49813
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Plaintiff
Joarma Darmer
Dated, Apri125, 2001
.' ~-~-';!::
, F)FILES\DATAFILE\DONEGAL.DOC\166-aff.app
Created: 07/111001O:49:15AM
Revised: 03/12101 04:16:59 PM
JOANNA DANNER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION - LAW
NO, 2000-5156
KEVIN ULSH,
Defendant,
JURY OF TWELVE DEMANDED
AFFIDAVIT OF APPRAISER
COMMONWEALTH OF PENNSYLVANIA ).
: SS,
COUNTY OF )
Personally appeared before me, a Notary Public in and for the said Commonwealth and
County,}/fCfIal-lt.5 fl. Snt-t1 $/""Jt.. who, being duly sworn according to law, does depose and
state that he is a licensed appraiser; that the appraisal of $/ 'Z~ O.3lttached hereto is true and
.
correct and accurately sets forth the damages to the value ofthe 1991 Ford Ranger owned by Joarma
Darmer and; that he has been engaged in the appraisal business for 11- years and is qualified and
capable to evaluate the appraisal as attached; and value indicated thereon was the amount by which
the damages to this automobile would fairly and reasonably have been evaluated.
J1#tI ~
Sworn to and subscribed before (
me this 3 A"day of "'Pf1;. IL ( 1-;-0 ()
.~4-~ {f .~1L/x?r.
(
'. Notarial Seal
, Eij~ene A. Kostelac, Sr., Notary Public
, $teellon Bor~, l}~\Jphin County
,My'Cornmlssior, ",.,Ores July 7, 2003
l~
.
_M~.;==-~'-_'" __ ~=^~
~~~U"~.~ .."~~,~ . I
~~ .
"~,~
~ ~ .-'~;\;""'ii!il!li6il",i'rl,si,L
. ,.$TARSINIC APPRAISAL SERVICl::
Auto . Heavy Equipment . Home ' ,.
POST OFFICE BOX 7462
STEELTON, PA 17'l13-0462
1:1139-98$1-' 'FAX 711-939-1992
Date: 2RB/IIO 12:12 PM
EstimatlIID: AS.0321-49
Eatimate Vetaion: 0
Committed
PrafilelD: CUSTOMIZED
Damage Alleeesed By: Nicholas V. Statainic
Apprei_ For: STEVE DONEGAL
Condition Code: Good Typo of Loss: Collimon
Date of Loes: 2/17/00
Cantecl Ollie: 2/22IDO
D_ble: UNKNOWN
Fila 'Number: AB-0321-49
Cleim Number: PAElJ522056.4O
Inauted: JOANNA DANNER
Address: 129 BRIDGE STR. #2 NEW CUMBERLAND. PA 17070
TelephOne: Work Phone:(717) 772-2823 Home Phone: (717) 77114454
Milchell Service: 914820
Deacription:
B!.ldY Style:
V1H:
Mileage:
OEM/ALT:
Color:
Options:
1991 Ford Ranger
2D PIwpXCb 6' Bed 125" WB DrfVe'Train: 3.0L Inj6 Cyl2WD
1 FTCRI4UOMPA91ODI Wie....'Y'(-,';!950 PA
109,900 -'-'.,~~l,
A Seerch Code: B17113
RED/SILVER' ,\,. ,';S~,
ALLOY WHEELS. PO~ STEERING; POWER BRAKES, AM-FM SfEIlEO CASSETi'E
4 SPEED MANUAL Tl'WIsMISSION, V6 OveR 4 CV4Z:DOOR PICiClJP " , ,- ",', - '
. _;<,__ ,';_' ::'.bi'f"f'~.j~~~';;_t
'::";);:~h,,, _,~!*k.
-Jf~~
'L~w
-'~isUng
Sublet
Subl.t
Sublet
Exiating
Une Entry Labor 1JJl"ltem
ltell1 Number Type Operation -,I)ascrlP.fiotl ,"" '
~ 426510 REF REFINISH R CAB CORNER PANEL
2 9OD5OO BDY' REMOVElREPLACE . lISPJASH GUARDS
3 9OD5OO FAM' REPAIR '. SET-UP,PULL" SQUARE FRAME
4 9OD5OO MCH' , REMOVElREPLACE FOUR WHEEL AUGNMENT
5 9OD5OO BDY' REMOVElREPLACE CAR COveR EXTERIOR
6 9OD5OO BDY' ADD'L LABOR OP STRIPING
7 429470 BDY REPAIR R PICKUP BOX SIDE PANEL
8 AUTO REF REFINISH R BED SIDE PANEL OUTSIDE
9 9OD5OO BDY' REMOVE/lNSTALL BED ASSY. FOR REPAIRS
10 9OD5OO BDY' REPAIR RT CAB CORNER
11 430470 BDY REMOVEJ1NSTALL TAILGATl: ASSEMBLY
12 430560 BDY REMOVEJ1NSTALL TAlLGATl: FINISH PANEL
13 432750 BDY REMOVElREPLACE R UCENSE LAMP ASSEMBLY
14 9OD5OO BOY' REPAIR TAILGATl: - LOWER
15 REF REFINISH/REPAlR TAILGATl: - LOWER
16 AUTO BDY OveRHAUL REAR BUMPER ASSY
17 433140 BDY REMOVElREPLACE REAR BUMPER FACE BAR
la 433190 BDY REMOVElREPLACE REAR BUMPER STl:P PAD
19 433210 BDY REMOVElREPLACE R REAR OTR BUMPER MOUNTING ARM
20 433220 BOY REMOVElREPLACE L REAR OTR BUMPER MOUNTING ARM
21 433230 BOY REMOVElREPLACE R REAR INR BUMPER MOUNTING ARM
22 433240 BOY REMOVElREPLACE L REAR INR BUMPER MOUNTING ARM
Eldating
Exieting
Dollar Labor
Amount Unilll
2.0
17.54* 0.4*
6,0"
58.95 * 0.0" -,
3.00* 0.0"
35.00 ' 0.3"
5.0"#
2.6
1.5'
2,0"
0.2
0.1l"
5,87 INC #
2.S"
1.0"
1.3
200.95 IHC
5555 INC
8.57 INC
B.57 INC
12.47 INC
12.47 INC
Exiating
New
Existing
New
New
New
New
New
New
eSl1MATl: RECALL NUMBER: 2/28/00 12:11:55 AB-0321-49
UllraMale is a Tradematk of Milchelllntematlona'
Milchell Data Vetaion: FEB_OO_A Copyright (C) 1994 -1999 Mllchell International
All Rights ReaeNed
P_'of3
.'~=-
,..
23 936006
24 933000 REF
25 933002 REF
28 AUTO
:rT AUTO
, 8.tJ"'KAt~AL t)I=KVIl.;I=
',),~;{", -/:,''/:~_:' - - .. ,- .
, 'Uipment ~ i';Iorre ' , '
,_,'''." -r:.
OX 1462
t111:}0462 ',. '.,'".'. '
i,:. ,""':.,..... ""''''1't1 "'<("1"9"
. 'i ~~:~:{i(;:~":~~;:~:f~!'~~ ~ -:~'~'-"'-'f:, -'f;',:'
ADD'L COST
ADD'L OPR
ADD'L OPR
ADD'L COST
ADD'L COST
RUST COATING
lWO TONE
CLEAR COAT
PAlNT/MATERIALS
HAZARDOUS WASTE DISPOSAL
* - Judgement Item
# - laborNcte Applies
R.marks
LKQ PARTS NOT COST EFFECTIVE
Prior Damage
RT BED SIDE - UPPER - 4.0
I. Labor Su_1s
Body
Refinish
Frame
Labor Summaty
:~,J:~,Add'l co:i.' ,..',
~~~!tabor" .i.Aubfei "
R :'f~."""';i:...,/j1'f.{'~'
'--~-t~~' . >iii-*,;'-,~: _; ','< ;.
o!.Ob 0.00 $.80 T
, 0.00 J'.i:,I:,T
Texable'< " f,/I3:lAcl '.
Labor Tax ,~!/~1t:' ~ % 62.00
Units
13.8
7,6
6.0
:rT.4
1,095.40
@
Amount
-..-
142.20
8.53
III. Additional Costs
T8X8bla Casts
Sales Tex
6.llllO%
Total Additional Casts
150,73
Paint!s) of Impact
6 Raar Centar (P)
^ '~
~~ ~ ~ '
...-~ ~i>all;!'_-,i'
Date: 212810O 12:12 PM
EsUrnate 10: AB-0321~9
Estimate Version: 0
Commitled '
Profile 10: CUSTOMIZED
10.00 *
129.20 *
3.00.
@ 8.l1OC1%
IV. Adjuabnents
Customer Raaponsibility
I.
II.
III,
TataI Labor:
Total Replacemant Parts:
Tatsl Additional Casts:
Grass Total:
IV.
Total Adjustmants:
Net Total:
ESTIMATE RECALL NUMBER: 2/28/00 12:11:55 AB-0321-49
UI1r.Ma18 ie a Tradamark of Mltchalllntemetlanal
Mitchall Date Vo,slan: FEB_OO.-A Copyright (C) 1994 -1999 Mitcholllntamational
All Rights Raeo",ed
1.0*
1.0*
Amount
384.94
32.20-
21.16
373.90
Amount
0.00
1,095.40
373.90
150.73
1.620.03
0.00
1,620.03
Paga 2 of 3
~*""'~'''~" ~ '~"~_'M --..
=.
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.
~. ~ "i\It!tll<;jO '';'';'
.~eTARSINIC AP~RAISAL SER\/IC~
<. .: 'Auto . HeavyEqulpment . Home ' ,
, ,POST OF~ICE BOX 7462
.", &TEElTOI'l,PA ~7113-0462
~9891 ";\:1<;; FAX 711-~3a-1992
~ c'. '-; .
Date: 2/28100 12:12 PM
Esti_ID: AB-0321-49
Estimate Version: 0
Commllled
Profils 10: CUSTOMIZED
Inspecllon Site: RESIDENCE
Inspecllon Dale: 2/24/00
Body Shop: LS SMITH FORD
Address: 12TH" MARKET STR.
LEMOYNE. PA 17043
1:;0<,.: -rz; ~at:q ~ tt
REPAIR COST DISCLOSURE:
Costs above the appraised amount may be the responsibility
of the vehicle owner regarding old/unrelated items,
depreciation/betterment or any amounts above what is reasonably
necessary to restore the vehicle to pre-loss condition.
PENNSYLVANIA DISCLOSURE:
AUTHORIZATION TO . REPAIR:". , .', . . " .,., .'. ' '. ,'.,. ". ',"',.'
This is not an au~odza~on tor~ai1:!. ,ve'iji~le'Q"wnef~. responsible
for authorizing $~P to pegin repairs'. If vehicitil. ownelfi.s a third
party orcJ.aimant:;;the insur<U)Cec~yshf:lV,ld~!;;Ontalited to
confirm liability' coveraqe before' audiod2iiilg :rElpaiif. '. " y.
CUSTOMER CHOICE OF SHOPS:
Selection of the repair shop is the responsibility of the vehicle
owner. Vehicle owner is under no obligation to use any specific
repair shop. Starsinic Appr. will pro,,"ide, upoIl request, inform;!ltion
regarding repair facilities that will be able to repair the vehicle
for the appraised amount.
APPBAI'" ~ ~~ P' u~o _l--Y-$'
COpy TO: INS. C ~O~REPAI .~ DATEdJd8"-'\};::)
ESTIMATE RECALL NUMBER: 2/28/00 12:11:55 AB-0321-49
UItraMale ia a Tradamark of Mitchelllnlemalional
Mitchell Data Version: FEB_oo_A CopyJ'ight (C) 1994 -1999 Mitchelllnternalional
All Rights Resetv8d
Page 3 Df 3
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CERTIFICATE OF SERVICE
I, Melinda A. Hall, an authorized agent for Martson Deardorff Williams & Otto, hereby
certify that a copy of the foregoing Notice was served this date by depositing same in the Post Office
at Carlisle, P A, first class mail, postage prepaid, addressed as follows:
Mr. Kevin Ulsh
409-1/2 S 4th Street
New Cumberland, PA 17070
Dated: April 25, 2001
MARTSON DEARDORFF WILLIAMS & OTTO
By (!1l~ 11M
Melinda A, Hall
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
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