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HomeMy WebLinkAbout07-4939~ f ANN CLARK CHILTON FROEHLICH, JOHN FRY CHILTON, III, JAMES ANDERSON CHILTON, ROBERT WILSON CHILTON, JR. and MARY SANBORN CHILTON FOOTE Plaintiffs, vs. CRAIG CORPORATION, INC., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. p 7- ~9~~i' G'' ACTION IN QUIET TITLE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the 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 SAIDIS, IINDSAY 26 WEst High Stteet Carlisle, PA 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 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 T - ANN CLARK CHILTON FROEHLICH, JOHN FRY CHILTON, III, JAMES . ANDERSON CHILTON, ROBERT WILSON CHILTON, JR. and MARY SANBORN CHILTON FOOTE Plaintiffs, vs. CRAIG CORPORATION, INC., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW Q y93 `1 r!~ l NO. ~" ACTION IN QUIET TITLE COMPLAINT AND NOW, come Plaintiffs through their attorneys, SAIDIS, SHUFF, FLOWER 8~ LINDSAY, and aver the following: 1. The tract of land in question is described as set forth in Exhibit "A", and is a tract of land consisting of almost all of Lot No. 27, Block G, Meeting House Heights, all of Lot No. 2, Block G, and a very small portion of Lot No. 1 of Block G of Meeting House Heights, as well as most of Lot No. 1 of Block F of Meeting House Heights, all situate in North Middleton Township, Cumberland County, Pennsylvania. 2. The land in question is a small portion of the land conveyed by SAIDIS, FLOWER Sz LINDSAY 26 West High Street Cazlisle, PA Clarence E. Cornman and Clara J. Cornman to Craig Corporation, Inc., by Deed dated March 15, 1960, and filed in the office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on March 15, 1960, at Deed Book S-19, Page 118, attached as Exhibit "B". The land in question is the sole remaining land which remains titled in the name of Craig Corporation in Cumberland County, Pennsylvania. 3. ROBERT W. CHILTON was an officer of CRAIG CORPORATION, INC. from its inception 4. CRAIG CORPORATION, INC. was a subsidiary of Cutler Federal Corporation. 5. In 1984, the stock of Cutler Federal Corp. was sold to Florida Agronomics. 6. After the sale of Cutler Federal Corp. to Florida Agronomics, ROBERT W. CHILTON, met with an authorized representative of Florida Agronomics, Jerry Diamond, in St. Augustine Beach, Florida. Florida Agronomics agreed to continue to pay Plaintiff ROBERT W. CHILTON, Ten Thousand ($10,000.00) Dollars per year for a period of five years to continue to operate CRAIG CORPORATION, INC. in Cumberland County. 7. Subsequently, Florida Agronomics made the decision to divest its operation in Pennsylvania, and auctioned off almost all of the remaining Meeting House Heights lots owned by CRAIG CORPORATION, INC. The land in question is residual land and was not sold at auction. 8. The last Deed on record in Cumberland County conveying land from CRAIG CORPORATION, INC. was a Deed dated January 21, 1986, recorded at SAIDIS, I~7~OWER ~ Deed Book R-31, Page 994, recorded January 23, 1986, conveying numerous lots in LINDSAY 26 West High street Meeting House to Heights to Hooke, Lebo and Hooke, attached as Exhibit "C". Cazlisle, PA 9. Following that conveyance, CRAIG CORPORATION, INC., and its owner, Florida Agricorp, made the decision to abandon any remaining property in 2 Pennsylvania in order to prevent being liable for any corporate taxes in Pennsylvania. They provided no funds to ROBERT W. CHILTON to provide for taxes and maintenance of the remaining property. 10. Florida Agronomics, through CRAIG CORPORATION, INC., breached the contract to continue to pay ROBERT W. CHILTON Ten Thousand ($10,000.00) Dollars for five (5) years, paying only the first Twenty Thousand ($20,000.00) Dollars agreed to. Since CRAIG CORPORATION, INC., maintained control of the company cash, ROBERT W. CHILTON had to provide for all taxes and maintenance of the subject real estate from his own funds. 11. After the breach of contract by Florida Agronomics and CRAIG CORPORATION, INC., and their abandonment of the residual real estate, ROBERT W. CHILTON formed a good faith belief that he was entitled to ownership of the land in question both as a result of the breach of contract and as a result of his assumption of the costs of maintenance and taxes. 12. For a period of in excess of twenty-one (21) years, ROBERT W. SAIDIS, LINDSAY nno~am~rs.,vuw 26 West High Street Carlisle, PA CHILTON has established an adverse, open, notorious, continuous and uninterrupted possession of the land in question. Copies of a tax bill of CRAIG CORPORATION, INC. and ROBERT W. CHILTON'S personal check, dated May 3, 1986, paying those taxes are attached hereto as Exhibit "D". He has paid all real estate taxes since that date. 13. Real estate taxes for the property in question have been paid by ROBERT W. CHILTON personally in a cumulative amount in excess of Eight Thousand ($8,000.00) Dollars. 3 14. ROBERT W. CHILTON has, during this period, maintained the property and paid for grass cutting, leaf removal, and other maintenance in an amount in excess of Four Thousand Five Hundred ($4,500.00) Dollars. 15. ROBERT W. CHILTON and VIRGINIA C. CHILTON, by their Quit Claim Deed dated March 15, 2005, granted and conveyed all of their right, title and interest in the property in question to their five children, ANN CLARK CHILTON FROEHLICH, JOHN FRY CHILTON, III, JAMES ANDERSON CHILTON, ROBERT WILSON CHILTON, JR. and MARY SANBORN CHILTON FOOTE, the Plaintiffs in this action. 16. The five children of ROBERT W. CHILTON and VIRGINIA C. CHILTON have continued the adverse, open, notorious, continuous and uninterrupted possession of the subject land and now take responsibility for taxes and maintenance on the property in question. 17. Neither Defendant CRAIG CORPORATION, INC., nor any business entity with which it is connected, has paid any expenses, paid any taxes, performed any maintenance or asserted any incidents of ownership of the property in question during the entire 21 year period of the adverse possession by Plaintiffs. WHEREFORE, Plaintiffs request that the Court enter an Order and that SAIDIS, LINDSAY ,Umiw~s.,vuw 26 West High Street Cazlisle, PA the Defendant be forever barred from asserting any right, lien, title or interest on the land inconsistent with the interest or claim of Plaintiff, and enter an appropriate Order that that Plaintiffs, ANN CLARK CHILTON FROEHLICH, JOHN FRY CHILTON, III, JAMES 4 ANDERSON CHILTON, ROBERT WILSON CHILTON, JR. and MARY SANBORN CHILTON FOOTE, have good and marketable title through adverse possession. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff By ~` _ ) James .Flower, Jr., Esq it 26 West High Street Carlisle, PA 17013 Phone: (717) 243-6222 I.D. #27742 SAIDIS, ~~OWER Sz LINDSAY ~~:~W 26 West High Street Carlisle, PA 5 VERIFICATION I, JAMES ANDERSON. CHILTON, one of the Plaintiffs herein, hereby verify that the statements made in this Action to Quiet Title 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.C.S. Section 4904, relating to unsworn falsification to authorities. J es Anderson Chilton Date: July 9, 2007 SAIDIS, FLOWER Sz LINDSAY 26 West High Street Carlisle, PA 6 ~.~ ~_, ~_~f• ~a31~,1~3t1 s3~a3s ooooA ALL THAT CERTAIN tract of land situate in the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described in accordance with a Final Subdivision Plan for Robert W. Chilton and Craig Corporation, dated June 12, 1980, as follows: TRACT NO. 1: BEGINNING at a point in the center of Meeting House Spring Road leading from Pennsylvania Route No. 641 to Meeting House Spring, which .point is further described as being North 13 degrees 51 minutes West 312.54 feet from an iron pin marking the corner of lands of Burr Heights and lands previously conveyed to Craig Corporation; thence along the centerline of aforementioned Meeting House Spring Road North 13 degrees 51 minutes West a distance of 85.48 feet to a point at the corner of lands now or formerly of Robert W. Chilton; thence along same, North 76 degrees 09 Minutes Ptan 5 of East, a distance of 155.0 feet to a point at the corner of Lot No. 2, Block F, Meeting House Heights; thence along same South 13 degrees 51 minutes East, a distance of 85.48 feet to a point ate So th 76 degrees 09 Bm~nutes 010 se onds East House Heights; thence along sam 955.00 feet to a point, the Place of BEGINNING. TRACT N0.2: BEGINNING at a point in the center of Meeting House Spring Road, leading from Pennsylvania Route No. 641 to Meeting House Spring, which point is further described as being North 13 degrees 51 minutes West 606.19 feet from an iron pin marking the corner of lands of Burr Heights and lands previously conveyed to Craig Corporation, and also at the corner of lands now or formerly of Robert W. Chilton. Thence along the centerline of the aforementioned Meeting House Spring Road North 13 degrees 51 minutes West, a distance of 96.27 feet to a point; thence North 76 degrees 9 minutes 00 Plan 5 seconds East, a distance of 146.64 feet to a point in line of Lot No. 26, Block G, of Meeting House Heights; thence along same, South 13 degrees 51 minutes East, a distance of 100 feet to a point; thence along the aforesaid Lot No. 26, North 76 degrees 9 minutes 00 seconds East, a distance of 131.58 feet to a point; thence South 13 degrees 51 minutes 00 seconds East, a distance of 115 feet to a point; thence. South 76 degrees 09 minutes 00 seconds West, a distance of 112.50 feet to a point; thence North 08 degrees 21 minutes West along lands now or formerly of Robert W. Chilton, a distance of approximately 93 feet54 feet totath o'nt at lthe centerline of Meet ngr House seconds East, a distance of 155. p Spring Road, the Place of BEGINNING. TRACT NO. 1 AND NO. 2 BEING part of the same premises which Clarence E. Cornman and Clara J. Cornman by deed dated March 15, 1960 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 195, Page 118, granted and conveyed unto Craig Corporation, Inc. EXHIBIT "A" ,' ~ _ ~~ ~ `~ E ° r~ i i3 ~ ~- -~ 5 S.q' ~ r ~ ~~-. 2~ ~ o Q ~ ~ 0. I I , , @/ I~ ~ I 3 , w o ~ ~ N II I ~ _~ _ ~ ~ 3 ~_ '' I ~ ~' ~ -3 X00 ~ R/c.i.i `¢ ~ U'1 ~ I , - 13, 1 5 !o ~ fV ET ~ 2 i ~ o' Z,. I ~ ,Li i ~~ ~ o I~ ;'~ is OC ; '. ' n V I `-, O,o m 124.og` 2 ~ I N -7~° 09' ~ IS~-.08 j I ~ 3 ~ I I -_ / 'II W Iz I n jn - l~ 4ibo~'~1?/~,~,~ `, 'Q I I I I Z 9, 3 Co 8~ NET ~ ~' ~Z ~ I t~1~7 °o9~E 155.0 I _ Y .:~ 30.0 ~ 12S.cJ' ~' ..{^ ~~ Y. i ~.' N (~ c~ of ~~ z Z~ 2 o ~~ -~ m a ~ t; N~~t~ of of z ~2 Q 0 2 J ~ J .~ ~ ~ d ~' E ~ 19,9, ' ~~~e b ~' U' ~ N , ,1>,5 of pt~~ 2 ~1 Z \ N ~ 0 ~ Q 0 ~. J ~ J m n . ARrn~-rf~or`1G ~ RnP.O Corgi' Ul W I ;~~ N.~~~4~57Co`~TOTAL=88Co~R/tv j(1;^:~¢ 7RIDl.tv~~t_nrz P012.'f1QIJ ~~7(~E r-, I ~ I P: vvJJ 3,Co90~~NET' Or'`~ TC771-I~ ~'Q~S~.IS~ l7 \V 1.1~CZ ~J ,~`-~~ ~N}l"~rLSc p~;~# Go~1 P ~ c~LO r 1 O -.1 S- O [~ L C~ ~~J 1 U I 30.0': ~.tzs,o' o ~ AISO ~T~fE. F ~ I j ~ A, o. ~~a~- ~~ ll- of ~ :I 3 ~ ~ 3 ~~:~2 _~'~~ -~ _ \ 3;'x49 ~ 'T07A L ~ ¢ 'r U Z ~ 30.0. 125;0 3~ ,~.~rc I I J r~ ...._._. I I N ~~° 09' E 15S.o' ~ I ~ a ( LoT N° is ' Lo~r N t~ wE i , ~ BL.octL,.~,. BLOGF~" ~.. Pt-AN N° ~ I PLAN N° 'Z IU MEETIAIG No~SE MEETING Nol.lsrc ~{ElG1-SITS E{E~GI-iTS Fo1NAQt_ SbUgO1V\~~pN PLAN FOR.: EZOBEFZ~T W. CK \ ..TON ~` Cf~R ~~ E~PEN~JA ~, ~~ GRAS G CQFZPORA~TIO,N CARfL\SLE PENNl~,M(ER`. BOROUGI-~ ~JF CAC2LISL.E-CUME3. COUN-Cy- PA. SCALE: I'~ = SOS ~ UIVE. 12~198~ UBLiC, Mprzc~-1 2~,1~£31 C x ~~ ~ ~~ ~--~ ~~j M ~ d °aos ®~31~A~3H s3ia3s oaoos 7~1-A1'-Warnnq DMd. Short Form, Ad of 1009 ~~ ~ Haac7 Fall. Iaa., Iadlaoa, Pa. 600 ~ S ~ ~ ~-,.:1 ~ ~, ~~ • •'''K of CUUkfS b ~ . ,.. a;.k Cif OtcDS C'. 3-~Spr" ~ ` CU'11BEkLAND CDIJNTY ~~~ n~,:,YLV~i`~ADE THE 15th day of March in the year of our Lord one thousand nixe hundred and sixty BETWEEN CLARENCE E, CORN MAN and CLARA J. CORNMAN, his wife, of North Middleton Township, Cumberland County, Pennsylvania, parties of ' the first part, and Grantors , CRAIG CORPORATION, INC, , a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its office and principal place of business in the Borough of Carlisle, Cumberland County, Pennsylvania, party of the second part, Grantee , WITNESSETH, that in consideration of -Sixty Thousand ($60, 000, 00) - in hand paid, the recei t zuhereo Dollars, p f is hereby acknozuledycd, tlae said grants, s uo hereby grant and convey to the said grantee ,its successors and assigns, ALL that certain tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as•follows; BEGINNING at a point, (iron pin), in the center of the public road known as the "Meeting House Springs Road", leading from Utlited States Route No. 641 to Meeting House Springs, which point is a corner of land belonging to the J. Norton Kruger Estate; thence by land of the said J. Norton Kruger Estate, North Eighty-six (86) degrees Forty-two (42) minutes Thirty (30) seconds East, a distance of One Thousand Six Hundred Ninety-two and Fift~T-two hundredths (1692.52) feet to a point, (Iron pin); thence by land of Edward R'[inich, South Thirty-four (34) degrees Twenty-four (24) minutes East, a distance of Foul• Hundred Seventy-three and Sixty-two hundredths (473, 62) feet to a point; thence still by lands of said Edward Minich, South Forty-three (43) degrees Twenty-two (22) minutes East, a distance of One Hundred and Six-tennis (100, 6) feet to a point, (iron pin); thence along lands of the Carlisle School District, South Forty (40) degrees Thirty-eight (38) minutes West, a distance of One Thousand Fifty-six and 0 (1056, 0) feet to a point, (iron pin); thence along lands of Frank A. 'Burr, North Forty-seven (47) degrees Thirty-eight (38) minutes West, a distance of Ninety-four and Twenty-eight (94, 28) hundredths feet to a point, (iron pin); thence still along lands of Frank A. Burr, South Sixty-nine (69) degrees West, a distance of One Thousand One Hundred Five and Five-tenths (1105, 5) feet to a point, (iron pin) in the center of the aforesaid Meeting House Springs Road; thence by the center of said Meeting House Springs Road, North Thirteen (13) degrees Fifty-one (51) minutes West, a distance of Three Hundred Ninety-eight and Two- hundredths (398, 02) feet to a point in the center of said Meeting House Springs Road;, thence by lands, of Clarence E, Cornman and Clara J. Cornman, his wife, the following courses and distances: North Seventy-six (76) degrees Nine (U9) minutes East, a distance of One Hundred Fifty-five and Sixty-four hundredths (155.64) feet to a point; thence Nortli Eight (08) degrees Twenty-one (21) minutes West, a d}stance of One Hundred Eighty-five and Nineteen hundredths (185, 19) feet ~o a point; thence South Eighty-four (84) degrees 00 minutes West, a distance of One Hundred Seventy-five and Three-hundredths (175, 03) feet to a point in the center of the said Meeting House Springs Road; thence along the center of said Meeting House Springs•Road, North Thirteen (13) degrees Fifty-one (51) minutes West, a distance of Two Hundred Forty-three and Seventy-five hundredths (243, 75} 1~ I S.._ ~~~F BOOKS 1;~ i'~~;.:i 1 ~ U AND, the said grantor s, do hereby covenant and agree to and with the said grantee ,that they ,the grantor s their heirs, executors and administrators, shall and will warrant Generally and forever defend the herein above described premises, with the hereditdmenta and appurtenances, unto the said grantee its successors • and assigns, against the said grantor s, and against every other person lawfully claiming or who shall hereafter claim the same or any part thereof. SCN!'OL DISTRICT OF NORiH i,'IC;:L; TO'J 10•,II;JSlIIP TaY ;,n!!ec!or or Agent ~~~~ ~r ~ {`' ``3' :--'~' ~ f ~,I~'~ E1' ~ / IMS .,,rr !r ~., :: ~'a,:, e~ ~ IN WITNESS WHEREOF, said granter s~ ve hereunto set their hand and seal s the day and year first above written. 6tgnrD, SrelrD snD ~rlfarreD In ibr ~rrunrr ut SS~,...~.~ ~.~5~ ............... Clarence ~, Cornman r~ ........................ .............................. BEAL ... .... ....... .......... BEAL Clara J. Cornman ............................................ BEAL. I hereby certify that the precise residence of the within named Grantee is N ~.~. W~ cad ~, w~. ca-Qti. s ~ re.'~, , ( ~cc.- { ~ j ! I~ ii ~i ii ii ii ~ ii ii __ ._. ._ J I _ ~ I I - •_ ___ 1 State of Pennsylvania County of Cumberland On this, the 15th l Ss. day of ~ March 1J 60, before roe, the undersigned o.~cer, personally appeared Clarence E, Cornman and Clara J. Cornman, his wife, known to me (or satisfactorily proven) to be the person s whose names are subscribed to the with- in instrument, and acknowledged that they executed the same for the purposes therein con- tained. IN WITNESS WHEREOF, I hereunto set my hand and offiez:al seal. ~ ~ ..-r.v °~iGlic, Carl~;ir.,-Cusjbr.'r ;iid LLOUiTty"°- --••-- =-.~-:?--T--:-1',i, B I..~ ..,,;,i;11;.i5•U fl ~l.y~,:+ ht. ~:15E LC, 1;l J.i '-.~ .• ~ T } Title: o~ Ofixeer. ~ • • • AlJ ' J Ll ~, " - .:~;; '. ,',; ,~J~ i. . .. feet to a point in the center of said Meeting House Springs Road; thence along the center of said Meeting House Springs Road, North Two (02) degrees Fifty-one (51) minutes West, a distance of Six Hundred Seventy-six and Fifty-six hundredths (676.56) feet to a point in the center of said Meeting House Springs Road, . (iroq pin), the place of BEGINNING. ' CON'I:AINING Forty-nine and Forty-two hundredths (49.42) Acres, more or less, according to a survey made the 29th day of February, 1960 by D. P,. Raffensperger, Registered Surveyor of the State of Pennsylvania. BEING a ,portion of the same tract of land which Romane S. Kruger, (widow), et al, by their deed bearing date the 24th day of January, 1946 said deed being recorded in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania in Deed Book "D", Volume 13, Page 331, granted and conveyed to Clarence E. Cornman and Clara J. Cornman, his wife, GRANTORS herein. ~ l~ ~f31~ EXHiSiT C 'M~~~d °ooe ®p~1pAp3H '~ s3ia3s ooaos ~ 11~1HX3 .~ ~.,r.,.,. _, .. -- ., 711 f4T-D~sd 6om Corporation to Individual or Corp., Attorney's Ack. Fl~nry Hell, Inc., Indiana, Pa. ~~ MADE THE ;2 ~ S ojour Lord one thousand nine hundred BETWEEN CRAIG CORPORATI .~ ..3S ~~ JAN 2 3 1~ ~~ ~~ Ei t Sixyol 86January in theyeor Sh Y (9 ) ON, a Pennsylvania corporation _ ___ ~ A N D HOOKS, LEBO & HOOKS, A Partnership consisting of William H. Hooke, Sr, George 0. Lebo and William H, Hooke, Jr. of Carlisle, Ciunberland County, Pennsylvania hereinafter called Grantees; . K'ITNESSETH, that the said Grantor jorandinconaiderationojthesumof One Hundred Sixty-Five Thousand and no/100 (6165,000.00) lawful money ojehe United States oj,lmerica, unto 1 t the said Grantees well and truly paid by . the receipt whereol'is hereby acknowledged, has granted, bargained, oldoaliened, elnfeojfeddre/eased and confirmed, and by then: presents does grant, bargain, scll, alien, enjeojf, release and confirm unto the said Grarit e e 1 t S heirs and assigns, TRACT 1. aLL that cet~tain tract of land situate in the Boro ennsY vania, bounded and described in acco ~ of Carlisle, Cuirlberland County, as follows: Associates, R. S., dated October 2, 1978 andNovembertg,p1978 a dp3/18/65 (last revisedpl/2/79 BEGINNING at a point on the eastern edge of Meeting Hou,;e Spring Road at corner of Lot,, N0. 2 Block G, Meeting House Heights; thence along Meeting House S rin • Road North 1 de ' 51 minutes West 102.72 feet to a point on road; thence by a curve in r ad, having a radius of F feet and an arc distance of 3. grees North 02 degrees 51 minutes We8836feeg tfeetpto a~pointcinslandsanow oreformerHo~e Spring Road9~ Kruger Estate; thence alon 35. 3 g Kru~r Estate North 86 d~ lY of J. Norton F}~ees 42 minutes 30 seconds Fast 1,162.25 feet to a point in Lot No. 6, Block K, Meeting House Heights; thence along lands of Carlisle School District, South 34 degrees 24 minutes East 1 Meeting House Heights; thence along Lot No. 8, South7423deeet to a point at Lot No. 8, Block K. grees 39 minutes '~5 seconds West 105.12 feet to a point in Bellaire Drive also known as Dunbar Urive; thence along b lAt No. Block 1{, Meeting House Heights by a curve having a radius of 305 feet and an arc distan e6of 1y0.00 feet to corner of Lot No. 6, Block K; thence crossing Bellaire Drive also known as Dunbar Drive approximately 60 feet to a point at corner of Lot Nos.12 and 13, Block H, Meeting House Heights; thence along Lot No. 13, South 11 degrees 21 minutes 56 °econds Wept 1 a point in Lot No. 18, Block H; thence along Lot No. 18, Block H, North 62 ~ 33.70 feet to 30 seconds West 43,89 feet to a point; thence still along Lot No. 18 and Lots 1~9e5203 ~artids22 Block H, South 86 degrees 42 minutes 30 seconds West 440.50 feet to a point in Lot No.~22; thence along part of Lot No. 22, 23, 24 and.25 South 2 de 266.81 feet to a point at Lot No. 26 Block H; thence along Lots 26, 27ua d 2g, sgl~n~HWe~eting House Heights North 86 degrees 35 minutes 20 seconds West 0 Block H; thence along Lot No. 29, Block H, North 53 ~ 3 3.75 feet to a point at Int No. 29, feet to a comrmn corner of hots 1, 2-and 29, Block H; tghence3stillualong LotcNo~29eSouth 65 degrees 46 minutes 24 seconds West 109.35 feet to a point in Cro CY'o~7an Drive approximately 60 feet to a common point on Lots 9 and 10 BlocktG;~thencesalong Lot No. 10 Block G, South 78 degrees 25 minutes 37 seconds West 111.35 feet to a common corner of Lots 7, 8, 9 and 10, Block G; thence along Lot 10 Block G, South 14 de seconds East 169.81 feet to a point in Lot No. 11, Block G; thence along I~t No ~1 1 Block OG ~,, . _-~ 60JK ~ 3~ rni,i ~y' 4 :~ ~. Meeting House Heights South 20 degrees 59 minutes 42 seconds East 161.92 feet at point in Lot No. 25, Block G; thence along Lot No. 25 Block G, South 23 degrees 51 minutes 39 seconds West 97.14 feet to a point; thence still along part of Lot No. 25 and Part of Lot No. 26 southeast- ward]y 100 feet to a common point of Lots 26, 2 and 3 Block G; thence along Lot No. 2, Block G P9eeting house Heights southwestwardly 115 feet to a point on the eastern edge of Meeting House spring Road, the Place of BEGINNING. BEING Lots 1, 2, 3, 4, 5, 6, 7, 8 and 9 Block J; hots 1, 2, 3, 4, 5, 6 and 7 Block K; Lots 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12 Block H and Lots 3, 4, 5, 6, 7, 8 and 9 Block G. 'T'RACT 2 ALL that certain tract of land situate in the Borough of Carlisle, Ct.unberland County, Pennsylvania, bounded and described in accordance with a plan prepared by D. P. Raffensperger, R. S, dated August 26, 1976, and recorded in the Office of the Recorder of Deeds for Currrberland County in Plan Book 30 page 91,:~as follows: BEGINNING at a point on the northern edge of Armstrong Road at corner of Lot iVo, 22, Slock G, Meeting House Heights; thence along Lot No. 22, Block G,~1Vorth 13 degrees 51 minutes West 115.0 feet to a point at corner of Lot No. 23; thence along Lot No, 23 North 40 degrees 36 minutes East 122.y1 feet to a point common to Lots 21, dl 23 and 15, Block G; tnence along Lot No. 20 South 13 degrees 51 minutes East 186.46 feet to a point on the northern edge ~f Armstrong Road; thence along Armstrong Road South 76 degrees 09 minutes West 100 feet to a point on said road, the Place of BEGINNING. BEING LAt No. 21 lock G Meting House Hets. TRACT j xLL L`hat certain tract of tan situate the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described in accordance with a plan prepared by D. P. Raffensperger, R.S. dated August 26, 1976, and recorded in the office aforesaid in Plan Book 30, Page 91, as follows: BEGINNING,at a point on the northern edge of Armstrong Road at corner of Lot No. 21, Block G, Meeting House Heights; thence alon Lot No. 186.46 feet to a common point of lotsg2l, 23, 151andl2o, BlocktG;lthence~along Lotstl5 andt16 South 85 degrees 05 minutes 45 seconds East 100.51 feet to a point at Lot No. 19, Block G; thence along Lot No. 19, Block G South 17 degrees 30 minutes 45 seconds East 153.71 feet to a point on the northern edge of Armstrong Road; thence along Armstrong Road, by a curve to the right having a radius of 365 feet and an arc distance of 23.33 feet; thence still along Armstrong Road, South 76 degrees 09 minutes West 81.67 feet to a point at Lot No. 21, Block G, Meeting House Heights the Place of BEGINNING. BEING Lot No. 2~, Block G. Meeting House Heights. TRACT 4 ALL that certain tract of land situate in the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described in accordance with a plan prepared by U. P. tiaf'fensperger, R.S. dated May 21 1969,. and recorded in the office aforesaid in Plan Book 21, Page 20 as follows: BEGINNING at a point on the edge of Bellaire Drive at the corner of Lot No. 13, Block H; thence along Bellaire Drive by a curve to tha ri~#',t having a radius of 245 feet and.an arc length of 125 feet to a point at Lot No. 15, Block H; thence along Int No. 15, Block H, South 69 degrees 49 minutes 53 seconds West ll5.0 feet to a common point of Lots 14, 15 and 17, thence along Lot No. 17, Bloclt H, North 52 degrees 30 minutes West 63.58 feet to a point at Lot No. 13; thence along Lot No. 13, Block H, North 40 degrees 35 minutes 56 seconds East 135.0 feet to a point on edge of Armstrong Road, the Place of BEGINNING. BEING trot No. 14, Block H, Meeting House Heights. ~~ 5 ALL that certain tract of land situate in the Borough of Carlisle, Cumberland County Pennsylvania,~bounded and described in accordance with a plan prepared by D. P. Raffensperger, R.S., dated May 21, 1969 and recorded in the Office aforesaid in Plan Book 21, Page 20 as follows: BEGINNING at a point on the edge of Bellaire Drive at corner of Lot No. 14, Block H; thence along Bellaire Drive by a curve•to the right having a radius of 245 feet and an arc length of 130 feet. to a point at Lot No. 16, Block H; thence along Lot No. 16, Block H, North 79 degrees 46 minutes West 105.87 feet to a point; thence along Lot No. 17, Block H, North 12 degrees 05 minutes West 71.12 feet to a common point of Lots 14, 15 and 17; thence along Lot No. 14, Block H North 69 degrees 49 minutes 53 seconds East 115 feet to a point in Armstrong Road, the Place of BEGINNING. BEING Lot No. 15, Block H, Meeting House Heights. BEING part of the same premises which Clarence E. Cornman and Clara J. Cornman, his wife granted and conveyed to Craig Corporation by their deed dated March 15, 1960 and recorded in the Office aforesaid,in Iced Book "S", Volume 19, Page 118. aorougA. n~, ~~ C~ .....,,~ Cumb. (`o,~ pe, Sshobt Dist. Cumb. Co., ~Ps: ._~ R.el Etfa+s Tromf.r Tex ` % R..I Eftd. Trand~r T.:_ W ~.r..l ~.~ ~6 F(.~.S~ov a.~.~"~'~3 r~ ~t~~ ~ ~~ • , • ewt/ .... ~ ,... c~.~b. ca. arty. c~i. nat. ~ RCOK'(Z ~~ Pn;;E q~s , c~M6, c.. ~r,r. coi.'4+~..~ R TOGETHER with all and singular tracts of land hereditament: and appurtenance: whatsoever thereunto 6elon ~y~~o a~~~an °ter•couriei, rights, li6ertia, privileges, and remainders, rents, issues and profs: thereoj• and aU the estat~ right, titl~'ttterea~ p ppe~~, claim and demand whatsoever, of the Grantor in law, equity, or otherwise howsoever, of, in and to the same and every part thereof, TO Hds'EdND TO HOLD the said tracts of land mentioned and intended so to be, with the appurtenances, hereditament: and premises herebygranted or unto the said Grantee, its heirs successors acid assigns proper use and behoojojthe said Grantee, its heirs, SUCCessors and wstgns. to and jor the only and assigns and assigns forever. • ~ p COMMONWEALTH OF P[NNSYLVAN~A -' DEPARTMENT OF REVENl1E • .,~. _ ItEAIiY "' == - tea, ;~ ; an TRANSFER tp(?1•'•~~ • TAX JAN2J'BC vr++~ 7 ~ Q ~ Q ti ' ° ~. P.B 1162 I ,._" , -- _.. i . ~ .. dnd the said grantor hereby covenants and agrees that it will warrant ' generally the property hereby conveyed. • "' COMMONWEALTH CF PENNSYLVANIA = ° DEPARTMENT OF REdC-NUE ~ - REALTY ~ ~ ~ ??~ ff -- ° IRAN3FEP, JAN29'88 ~+'~ 9 Q Q, t~•~ __ • - IAX `~' P. B. I 116. The Grantor doth hereby constitute and appoint to be its attornry for it, and in its name and as and jor its corporate act and deed to acknowledge this Deed before any person having authority.by the laws of the Commonwealth of Pennsylvania to take such acknowledgment, to the intent that the same may be duly recorded. ~ IN WITNESS WHEREOF, the said Grantor in its corporate name by its President, and ha caustd to be affixed hereunto the ommontand corporate s ~ of the said corporation, at eereta the Q ~i~~` ry. dayand yearfirat above written. G ~o ,~ Q ~~ CoRP ~b4L g~ B b' L '•~y .. ~ ~ / President. Attest: _ . ~ ,~`~, . ^tNy~- ~~~K (~3~, ~~CE 3~i .....1 1 .1 State of FLORIDA .. ~ .. ~ ... ~ .. . ~;, ' Count o ., .. ~ ..,•.~ra: ,- ., r f 0,4A~ HILL'S8OROUGH , ... , .. .. • ' On this, the 21st . ~ ~ ~ '' ' .. ' - ~ • day of JetlUSZy .19 $( ~. before me, ~ • •' ', :~ • the undersigned o~eer, personally appeared. •. ~ ~ ... ~ ~ -• ' ' .. . • ~ James H. Patterso ~ • know to me (or aatisjactorily proven) to be the person who is the , . , ••.: ~ • ,, acknowledged that he ezeeuted the carne as the act ojhisprincipal jar theP,u Sio eat ~~ `~~' CeR PoR.{Tt~c may., ngnr;ed in t e ~regoing Deed, , aad,.•.~.,; '.;: , ' P P therein coneained• _ .~ "~ ' ~l-n-witness whereof, l hereunto set my hand and.o~cial aeaL ~ ~~ ~ti~' •"`J r~'~) ~~ NOTARY PUALIC STATE Of OAI - _ ~ e s$ L ' '- _~ ~; NT CONNISSIOM EXV, MAR 30, I9B9 ~ °~ ~ ~~ President ~m V.1.U ~ ~ .~ .~;' ,' ~ 60NOE0 iMRU GENERAL INS. UMD, .'G` ; ' CERTIFICATE OF RESIDENCE Title of Office:: ~y; .•; ~ ~ .. ~ ~;,'. ~~~~• :' j"~' named grantee is• ' ' do hereby certify that the precise residence and complete oat office address ojthe within •~• January Z 3 ~19 $( , _"~ Attorney for .____ .G ..... . ~ , • ~~ ~ ~ O + I ~ • ~ ~ ~ H ~ ~ h0 ~ dj o a w x Q H Stets oj____ I ~/l County of ______~,= ~~~ b ~ ~ u, r.''~~' ~ -~ *.< ~...; ~ ~',. RECORDED on thin ~ a~ ,,',.. ; r; Q ~yof ~ h;'~i~' ']~ ' ~' '~~1.D.';19 in the Recorder i •. l I ~ ~~'i (• '~~, '~ ;. , Ogee ojaaid County, in Deed Book ~~ '~~ ~ ,.,, , .y,.~, _ . , ~ , ~ Cwen~under my handand the seal of the said office, the dote above written. ,.:., ,, • mil" n Recorder e~~K R31 Pace X97 C X ~-\1 I~ IT t~~T' s ~ r 3 D n -•n;nn y, ..r. y n. z~n-~ r •~ ~,,. .n ; ;. _y. t Ln C b r T ~1 3 c,3 D s th O 1 fv ;' ."~ b. w z -~ rr s --i 1 ~i -~ N C.7 b~. 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O ,~~`~ ' \ O WI A ~ ~ W ~ A _ `~ `_ -" - RcAL ESTAT£5 fiAX NpT X E TAX YEAR ;~,„CIARLY SLR AREA 5CHQQL. D S STR Y C E c+lECxs SARI.` R K'~~,l.~rrR ABLE TO: k~~ N. ~~N~VC~ ~~ CARLt SSE ~ PA 17013 ....,. ~ %P~ ~~ ULTT Z ~'~ 7 1 G~;T ACCT NOA~~ O'5+~~9~1,647.0~'3 CR~;1Gt CpRPpRA,TIpN ~~p F14RNlER~ TRUST 6LD~ 1 W, #~GH STREET. CA~tI~SLEw PA 17OI3 ___ ------~iit,----,~ TA~.COL ,. ,,., ASSESSMENT BILL NO. AUGUST 1 296 20fl 1090 ~or~~w:~;~s ~ ~ oo AM To ~-~ ~o PNi ~~ ~~br~,v ~1p AM TD ~s~fl PM -Tj----____ ______~ r~URIN = Tti15 PERIOD PAY THIS ApA6l3Al "I '- ~ COUNT --...----.__- - ~ ~ ~6 T~.. FACE ~~-_- auGy~ -~ SEP OC ! NOr ' -~ PENALTY Q~JI~GLAS COURT A!~~' S"`RDf~C~ RpAD ~~T ~7 SECTTQN G ,~ - ~ ~AlG41~7 UriPAID TAXES Tl1RNE0 QwER L: ~: ~0 CU'~SERLAND Co. TAx CLAIM dURE~Ui, ~i~on ~~~ Foy aoo~~ RECEIPTS a~AU~$~~ .~.. -~~. l TAX YEAR ~R~A~_ ~JT/~11 ~S.:.TA/~ IE~kVT~~w.~-. .. 98889 OARL I SL.E AREA SCHOQI =iJ I STR ICT' 1AKE CHECKS EARS,: R KEI,,,.(„~R AYABIETO: 1~~' ~~ ~7ANQ7~R...ST -CAR~,~,SLE~ PA T?~(J13 ~E i' H PENALTY % P . C3 ~ M % P us ` ~ ~+~ 1$6 Q ~.,. r ~; ~' ACCT NO,~ Q5~-1`~~1647~083 - ~ ~"'(~~.~~C~"~ CRAIG.CQRPQRATIQN 2J.a FARMERS TRUST SL,DG 1 W. :HIGH STREET (~ C,AF~L~~'5LE~ PA ~,TQ13 ~~ , . , ,~ ,. DATE ASSESSMENT BILL NO. AUGUST .1.1988 ~`0~ 104+ 9~. o~aAM r-a ,.~,: 3QP~ ~roN ,.... ~MURS . 9;~QQAM TO ~r~4PMI ~RI~AY `' y°r M DURING THIS PERIOD 3 AWG ~~ aEpT' QC~ :R AiaV DOUGLAS COt1RT ~'~ ARMSTRONG ROAD LOT 27 SECTI`OPl G Il PAY THIS AMOUNT - ~ Ali ~ .DISCOUNT "~ AId L /PENALTY ON (3,~/1~f89 UNPAID:`TAXES TURIV~~? OVER TQ. ~UM~~R~,;AND CO~.: TAX'"CL.AIM 841RE,QU. , $~c~~_ ~E~ FOB a~o~~. ~~c~~wTS R~au~~Tfc .. __ __. __ _.. ---~ ---- TAX YEAR ~ ~ A ("' E S T A T ~? ! Q X Iv Q 1 ~ ~ F~ DATE ASSESSMENT BILL NO. 9'.,~- CARC~S~.E t~pR~?UGM __ aQQTi n~ ~ 988 20C 1Q9Q y ~+ /+~ ~_ MAKE CHECKS EA~'l. R KEL,LER~ TANS ~.+p~,~,F1r7'CR M~3N+!l,'~ENI~JRISA'~QO Ah1 ,.• 4~~3t~ MGM PAYABLE TO: ~ ~"} 7 ~ ~ A N Q y ~ 1 ~ r7 T • ~"~'1 ~ . C~ .S ~ t.r !A ~ '~' ~ i ,~ Q P Ml CARIIS~E~ PA 170,3 -~ RhIE '2A5~0257 '-PENALTI IILLS ACCT NOS X5'19-1647-~~~ -CRAIG COKPQRi4TIfJN 21Q FARMERS TRUST BLD~a c~~7 ~ ~ ~, W, H'2 Gti STREET CARLISIE~ PA 17015 ~,~~~G'"' COUI~IT?' L'Ik~RARY SOR , ~ , ,• , • , Q % P '~ ~ * Q M ~ q %P 1 R ~" M ~ ~ %P ~ ~ ~; ~ M % P M DURING THIS PERIOD PAY THIS AM 7~ X29 $=bS ; ~PRS~» iMAY 9;~q 1r~~1r ~ ~.,:E.~ ~' 4;1$ '3 ;~ ; A F T ~' R ~ Y 0= s~ uplJGL,AS COUR'~ ~, ARMS~`RQNG RQAD I~QT,?~ SECTION G Il DISCOUNT FACE PENALTY ON 0~/1S/89 ~JNPAtT~ TA~~S TURNE~'QV~R TQ CUM~FRLANIJ CQ; TAX C~.AIM Sl~Rm~AU* °~I~OC SEE FOR- A1~L~'~. RECEI~'TS REQUE~TSZ TAX YEAR REAL tST~1TE5 TAX ~4~TIC~ *~ 5C,H40L ** Dare- _ _ _ . 9 951-}~ CARLISLE AREA S~~'IC)~}L £~I5TRICT AIJ~;US7 1 1 X91 ASSESSMENT ._ BILL NO. MAKE CtIECK6 PAYABLE T0: ~~aL ~. KELLER 24a 1144 ~ '! 4~' !~( ~iA~74V=,~ ST ~~~~ T4+~• TH11RS 9: 4th 4!~ TO 4:3fl P~! CAP.LISLE~ PA 17413 WAD 9:fl4 AP'! TD 12.40 NOO~i ~HfliVE 24,E-42.57 ,~ x:44 Ahl TO S:fl{3 Q~{ SE13 ALL ~flLIDAYS ;r~ar~r,l n ~ .. :) . 1 ~.bG M~ 9:P ACCT ,N~ a5-1~-'8v47-Of33 ~ Z~t7IFAr~W!R~5~7RUST LLD 1 W. HIGH STREST CARLISLci PA 17'fl13 If Y~iiJ~ TAXEW A'~E 'Ili ESC3?UW, PLEASE ~+~r~iWAI~J THiS SILL T4 Y~3U~ I~(}r~l'GACc L ~ f~ P ~1 !~ Y _ TNIS PERIOD I PAY THIS AMOUNT U~ - S~~T c~r - ~av n4~1~LA5 CJUFT C~~ AR~sTRQuVG R4AG LaT ~7 SECTIUN a Gid 4J1519c U?VPAID TAXES Ti7~NEU UVF;R T4 CU~9'?I:R1..P,Sti33 CJ. Tr~X CLAIP~ ~U~£~tL'. _ ~'1_.S~_~i_ _~~±=__Fd~'_ ~_~~'L R.E..CEIr~TS ~~~l~e~_,5_T%1? TAX YEAR iRtb`l E5T~1TE T~lX N(3T.ICE ",~Ei~ISSD~" )~91-~2 C~i~LISLE ARE~t ~CN4R~L i~IST~tI'GT MAKE CHECKS PAYABLE TO: 147 ~ H~1~i13VE~i 5T ~.~-k~.ISLcr ~~ 1?413 P~d~~E Z~rS-42s7 S C FI ~ q:L DATE ASSESSMENT BILL NO. Al7~a~15T ') 9 9~1 2~ii3 1144 • ~lpi+i, T1l~,~ TWURS '9:44 AFI TO 4;,3~} P~ fRI 9.44 ~Ff Tel 5.14 PM ~.Lf3s-~iD ALL H4l..IQAIfS %P r M %P r M DURING TNIS PERIOD PAY THIS AMOUNT t~~~'~Id E1~5 Al.L~7L1~T ~ T4 7ktE ~ ST~I.C'f ~S 2'l.rs;S #i i;~S ULT 4F P.~SS ~E 4F .~#i~ :, ~El~~_~,AL ~#~ - SEPT 21.35 ?2.3fl ~tPF'$~D ~2i+~TI~?Y~ ~-C ~F 719" °>~' T~i1c ~T - AIOV 22.3CI ~4 53 PENS Y VA~7 ,6 ~' ~-L ASS M~. 3F 3C1 3 ~~~~~ c~~~4~3~~~a ~R~sTa~4~~ ~~,~~ Z1 fl F.AF~l~E~S Tr2~;7157' ~L~~ LET 27 SECTIl11~ ~ 1 _ 1 Mt. HIGH ST3tEET C~RLISi.E~ ~'a~ 17U13 EARL KEL~,ER .. ...... .~#~ Yt~li? TFi;~ES ~~z I~! ESC~i~Wi ~LE~15E CEO ~+115/~2 49°~~'~4I~-...TAXES Ti~RE'~ ~'U!G~t f4~~J~,a~fl TNIS ~I~.L T#7 Y€~J~ ~+itiRT~,~~F T4 Ct3~i3Et2.3_MW~1 tt~. TIIX CL,A.I~ ~d3#~~AZJ. C~~?~.!aY. _.-__. _ _. ...__ _ _ - ~1~~11 _~~_ f~#3_ ~4D~?'~,, R~,C_FI~'TS_RE~.1lES_TF'~i- T Y R' ~i~AL~: E~T,~T~ES SAX AIfl~"ICIE ~`~ ca~~~s~~ ~a~~~~r~ HAKE CHECKS PAYABLE TO: C~RLISL~~P~ "~7n7~-1~?~'S ACCT ~0 U5-9'~~~~~i7-CI~~ C,~~LIS~.~,~,. ~~1~~17~ ~~ ~~~~ ~x~s ~~ ~~a ~~ ~ ~ . * ~ ~ ~~~ ~~ * ~ D T ASSESSMENT ~~~ i~~id-1~13' - iFRID A'~ ~A~M- - 4f~i P~JCI~i~ 7~7-2~3-~?~~ D!~~+~5 ' C~~1~3' BILL NO. '~ 1 E33 `~„-" t+~r~~r~-~-~~~+~ s~.as ~c~x~~~ yyn~ e~,~1t~ Syr .~ ~.tr~rr ~.~~.:~ ~r~+,~~, ~~p~g.~y~~~a~r~h.~,~a~ ~~y~c~~s s,µ~~~t~a~yd~ls ~~t~~,i~R .iv _ir.0'J:~ ~ 7 : _,. n_r..,. _..~. _ i ii ~~f'i:7:i ~4~~~ V a, ias ~ ~ ~+R i.~T~3 i'7 r7v ~k~A'Lir 7AX YEAR DATE ~ ~~'~'4.~.~ ~"~~~~.. ~°a'T~IT~ ~~.~' ~'T.'~C ~ ~Yr ~, ~PI61'F~,~ *`~ ''. ASSESSMENT BILL NO. C~~tLZS~E Hf~~~ SCHUL U7C~'r~ICT ~itl~a~5~' ~ 7~~Z YAKS CHECKS PAYABLE TC: ~t fi: ~ +W y ~•q ~R~Id.EIVC i ~9C7Y~~.s CJ~ CfiCe3 ~1C3tvi~d~Y' ~CDA~ ~5~~ - ~~'7'S 73V E'~? ~~k ~ ~~~ t1~tLZ~~.TM f'~t 1~T~7i~-l~2b ~ ~ A I ~; C ~i #tPC~ 4~ ~! ~° ~ C~ AI i , ~'. l~~6~ STR~~T ;~ iF ~ ~ . t ~ ~ ~ ~ i~lr : ~ L~~# iii. D .ACCT" Y~ ~5-79-~t4~- ~t3~t~L~1.5 Cflk~~T .~ ~9134f92 ~9ft+~upl5~r 22.34 tCN?E~11Q3 ~.~# ~i/15J`~~ l~~t~',~~#~ TA?~~S 711t~~~~ ~~l~N ~~. ~ ~~E ~ A ~~"4. ~ ~C EI FATS ~~~~I EST~a , TAX YEAF# ~` 1-~99~ REAL ESTATE TAX NOTICE CARLISLE BOROUGH lu~laf c:n~acs rAr~eLe Ta DA,RLENE L. MOYER, C/0 CTCB 1~l S HANOVER ST SUITE 102 PO BOX 12.8 CARLISLE PA 17013-0128 * * COUNTY ~E 9E DATE ASSESSMENT BILL NO. C 1 MARCH 01, 1995 200 1157 ' MONDAY - FRIDAY, 8AM - 4PM • PHONE: (717) 243-3725. 4.51 .29 7.06 4.60 .30 7.20 .5.06 .33 7.92 ACCT N0 05-19-1647-083 CRAIG CORPORATION ' 210 FARMERS TRUST BLDG 1 W. HIGH STREET CARLISLE, PA 1.7013 .DOUGLAS COURT & ARMSTRONG ROAD LOT 27 ~#~'~i ~~,+~G g~Yl:~u~~ 11, ~d CH 1'11 i 1`r :F ON 1/15/96 UNPAID TAXES WILL BE TURNED •HIS BILL TO YOUR MORTGAGE COMPANY SIEOOT~EEUFOR ADD~~AX CLAIM BUREAU. MAKE CHECKS PAYABLE TO: r t` '~ i g ~ ~ L. 1 ~Y ^` Q 4j~~~~. ~ ${:' 4 ~E ...f ~ Jr +~r1' RECEIPTS REQUESTED - ---- -- TAX YEAR '~' .._ C _s«.tY;y~ ~~,'- .~~~.,.I~..ti. ~{'~ BILL NUMBER: ~ .. ~~ 7} ASSESSMENT: -;( ~, ,.i ' :m ~.- h Y.. C' ~ 3 ,~¢ ~ '" °~,' ~a $i F3i 4.i ~ ~ 4. ~' DATE. :Ly. i„t °~ °LL •f B HOURS: r+li..~ fr w ~ 9 ~ *•' ~'~ PHONE: ~~ ~ii`~ ~ ~ # "' ~" ~.' 9 '~~ ~3 ~ d ~ ~`^ ... ~ ~ ;s;1 - . i ;,,z%P a s -t€ M % P M %P M %P-. M -...P/ P M DURING THIS PERIOD PAY THIS AMOUNT s . p, fig, y/ 1'. '~" 8...r3 ~. ..9 7 yry _ ~y ~y ,N 4•. x lT p: ~ ,Y S 1 d'xS M ~~:~ ~ ~n$' yl L{ '~F :.l 8.+,,,,2 ii,,, l~g it s.iir~+ : ,,~ 1 I' 1• :I IW' i ~ r ' '~ 5 r. : a: r i ~_ ~ ~ !y c ~ ~a d" k~ ~ti ~_n ~a a~ ~ ~'? i ~"~ a R ~ ., ; .~, .7 ', ~ ,: F< w. °.. 1 :"~ 11 ~ t'.r' 5 r i a r.J •~ ..: ~,:. #v L: S_1 ~ ;.. ~ .c.. 'h.- } ~ ~" ~ ~ »r r`4. ... 1~c r - ~' MAKE CHECKS PAYABLE TO: ~ TAX YEAR: ~ ~ ~ C ~ '9 W 'g! s~ ~ ~ ~ #~ T` 6. ~~ ~ ~ ~g BILL NUMBER: ,~ ~ ,~. r x,~ aa ryy~Y~~ ,w t p ~^ ,y # ~ ~ ~~y :F ~ t '~'~',' ~ ~ ~~} ~ 413 rT '~ ~u +~ ASSESSMENT: ~ ~j ~~Cti~G~Y~ 4• ~M~G~~ 4d'~ #.~L CMf4:twL~Fm` 'R~r~ ~'~~1~~~. L.i~~~j4! DATE:. p~ ~ yy~ {y~,~li~"~ ~ ~ ~ 1r r +Yg ~4~. ~ lei; 3,.: ~j ~dy ~ ~ ~y. .~} ~+ ~1y ~y y +~ !~ w~ ~~ ~,ii`~1 ~ 1A ~ 3 7~ f R7 L Ml ~r~q ~ •~ 4~ ~ ~1 C +e HOURS: ~~ `L ~ f~ J~+ ~' ~`~' Ti ~ ~ i~~. fr ~ GI A ~ ~`~' ~iA ~ ~ ~n - L! ~i +y I+S.~, ~ ~ 4.'~ * ~ r~ * ~.~ ~ ~ ~i V ~ i 48 PHONE: ~l' ~'I it ~'f fr 7 +ir dC"~ ~ +if I G .1 1 I / 1 •• t . %P M %P M % P M % P M % P M DURING THIS PERIOD PAY THIS >M ' ~~:~ ~ltdi l]C. S~~t ~~r~~i ~~~RI.~[~~ 1.•, MoY~R in °_~° C~XC~ ~ . ~ ~, , ~ "r ~'~ ~ ~ Y ~;~ ~ ~~+~ ~M1 ~'~ ~.~ ~.~~' ~ ~ ~.~~ ~ ~~ _i '4,! 4I~ ~` TAXPAYER: ~-. ~ ~~... V ~l:i,.•~±~ ~,... ~ )~~~~ `~ ~, , . XP MI %P PERIOD I PAY DISCOUNT AR. - APR. 11:86 FACE AY - JUNE PENALTY FTER JUNE _ 13.31 .,~ TAXPAYER:. } Y'4 Pnd ..j ti, ~~a•y''Pe z~._ ~z"~M ~ .~. ~1-i^~i ~ . '(` ~ ~ k$44 ~ ~ ~ ~ h £ ~ i. £ ~'': .S cam. ~~.., E ~ ~ r "aIG :JSlli95 91i-?1]1~? ?6.2i cN p~t~„~~ f-ROM "JIM CHILTONiOLDEBELLAIREANTIQ FAX N0. 7172491019 "? :; ; .. ,-:..: - _- -.._ _- _ _ Feb. 15 2.005 10: 51AM P2 4~ U L. ~~ t h ~ 1. ~ Vf ~• ~ I ' fir ~~ Ll L'{ J .. i' _ . . r~ _~`~~`~r,i ~',f~°~ ciiT ~c~;i+4ry-'~r..:, ~~1 1r.tii~..: ~='~.: ,~' .- ~.T-.----. f (9.P ~ 7~`-a - r i ..~ l ~ ^ t i .. fear 'wP L!; ~ t ~ i -~~:i+'gtll?~ :-=:.J,t~fi~7 -3!L~'+~/^/i73~ ..:. ~ ~-. _- { ~i ~i ~i i.~ CrJ, t .C. I..~ C7 : ~ °7 ~ . a ~: ' "~ -, i~ r.&.. ~ _. ... ~' ]] ar3=. (ES qRE ESCROWED, FORWgRU THIS BILL TO YOUR GAGE CO. $1 _UU FEE FOR EACH AODII'lOnlgL RFC[Ipr DARLENE i., MoYEF{, CIO CTCB 19 S HAEVOVER S f, PO •i(jX 128 CARLISLE, Pq ]7013-Oi28 MAPNO~ 05-19•t647-08g DpU(~LAS CUURT ACRES -320 LOT 27 5EC f lUN G Vacant Land VACANT LOT -LESS THAN 1 ACRE ^Aluca - - 24.9 - ~ •- _~ 3. is -~ ? ~ ~~. i; ~-. $ 9" f e~ ~. ~ -. ,U tl :3 . . TAXPAYER COPY Bmenf of Aeal Esnie Taxes r--==---~--- ]zatra .00212900 - C:OI]~TY R~g 5d . 41 motes _ D002o300 ~""- ~--,_ COUNTY Lip eo u~N o~ caRl 6.OB f~ _ Ratee 0 031 . ~7NIC_ R E ----~_ 0000 _ 92,97 TA7C gMOUNT DUE -a lOt 70.85 10; 6.69 103 102.20 g1~s_7a t3i!! No: 1203 Bill Dato~ 3/01/z00~ 1'ot-aI 24,970 2g GJ•12 bd.47 2t 5.95 ti.U6 2~ 91.05 92.9 1 5160.13 . 5163.40 _ _ If Paia OA aI After 3101/x004 S/O1J20Da CRAIG CORPORATION - rt Paid or] or Before a ?D/2DDa _6/,U zoos IP NOT PAID RY 12/13/200a 'ritT3 BZLZ. WILL Bp xL'T[]]tNED '1'o T1 270 FARMERS Tl7UST E3UILD)NG CLA1m l3UREA0 FUR COLLgCTIOtu AND FILING OF A LIEN T T WEST HIGH STREET YouR PROPERTY, ~~~,~ CARL151_E PA 7 7013 G~'7" 'v` MO S AY8 RIpAY a oUAnn-a:onPM CLOSED HOLIDAYS PHONES tai%j 2q3-3725 .r f'rx~I~ lfti/CES./~f.{ 49IC+i8 ih3, ~~ t:N 12~s Return !3ill with Paymont_ Por a Race;pt ,Enclose Scif Addressed Stamped Envelope. 0 ~ ~ ~a ~7 L T~ ~s "" ~'`1 ..~ _ ~ ~r ~ e C~ ~ t '~' -,C SHERIFF'S RETURN - U.S. CERTIFIED MAIL ,~ t CASE NO: 2007-04939 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FROEHLICH ANN CLARK CHILTON ET VS. CRAIG CORPORATION INC R. Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,BETHEA WILLIAM R REGISTERED AGENT FOR SERVICE by United States Certified Mail postage prepaid, on the 24th day of August ,2007 at 1000:00 HOURS, at OF FLORIDA AGRONOMICS INC 401 LAKESHORE DRIVE IMMOKALEE, FL 34142 a true and attested copy of the attached COMPLAINT -QUIET TITLE Together with The returned receipt card was signed by SIGNATURE ILLEGIBLE on 00/00/0000 . Additional Comments: THERE WAS NO DATE ON THE GREEN CERTIFIED MAIL CARD. Additional Comments . Sheriff's Costs: So answe '~ ' ._ Docketing 18.00 Service 6.45 R. Thomas Kline Postage .75 Sheriff of Cumberland County Surcharge 10.00 .00 35.20 / y~d~~61 Paid by SAIDIS FLOWER & LINDSAY on 09/12/2007 . Sworn and Subscribed to before me this day of A.D. SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2007-04939 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FROEHLICH ANN CLARK CHILTON ET VS. CRAIG CORPORATION INC R. Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,KROUL MARJORIE _, REGISTERED AGENT FOR SERVICE by United States Certified Mail postage prepaid, on the 24th day of August ,2007 at 0000:00 HOURS, at OF FLORIDA AGRONOMICS INC 12329 MCGREGOR WOODS CIRCLE SW FORT MYERS, FL 33908 a true and attested copy of the attached COMPLAINT -QUIET TITLE Together with The returned receipt card was signed by RETURNED TO SENDER on 00/00/0000 . Additional Comments: RETURNED TO SENDER. ATTEMPTED - NOT KNOWN. Additional Comments . •~: Sheriff's Costs: So ans Docketing 6.00 ~ .- .._. Service 6.45 R. Thomas Kline Affidavit .00 Sheriff of Cumberland County Surcharge 10.00 .00 22.45 ,/ ~~/lp? Paid by SAIDIS FLOWER & LINDSAY on 09/12/2007 . Sworn and Subscribed to before me this day of A.D. SHERIFF'S RETURN - U.S. CERTIFIED MAIL .~. ~ CASE N0: 2007-04939 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FROEHLICH ANN CLARK CHILTON ET VS. CRAIG CORPORATION INC R. Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,HOLDER HAROLD JR REGISTERED AGENT FOR SERVICE by United States Certified Mail postage prepaid, on the 24th day of August ,2007 at 0000:00 HOURS, at OF CUTLER-FEDERAL CORP 608 RIVERA DRIVE TAMPA, FL 33606 a true and attested copy of the attached COMPLAINT -QUIET TITLE Together with receipt card was signed by RETURNED TO SENDER 00/00/0000 . The returned on Additional Comments: NOT DELIVERABLE AS ADDRESSED UNABLE TO FORWARD. Additional .Comments . Sheriff's Costs: Docketing 6.00 Service 6 .y~5 Affidavit .00 Surcharge 10.00 So ans ms's •- R. Thomas Kline Sheriff of Cumberland County .00 22.5 Paid by SAIDIS FLOWER & LINDSAY Sworn and Subscribed to before me this day of on 09/12/2007 . A.D. 1, r - ~ ~ ., , LINDSAY, and aver the following: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. D7-"799 ACTION IN QUIET TITLE MOTION FOR COURT ORDER PERMITTING SERVICE BY PUBLICATION IN ACCORDANCE WITH PA.R.C.P. ~ 430 AND NOW, come Plaintiffs through their attorneys, SAIDIS, FLOWER 8~ 1. This matter is an action to quiet title of certain land in the Borough of Carlisle which was conveyed to Craig Corporation, Inc. by deed of March 15, 1960, and recorded in the Office of Recorder of Deeds of Cumberland County in Deed Book S, Volume 19, Page 118. A copy of the Complaint in the Action to Quiet Title is attached as Exhibit "A". 2. Prior to his death, Robert W. Chilton gave a Deposition on October FIAWERIS Sz LINDSAY 26 West High Street Carlisle, PA 12, 2005, during which he explained the history of land in question. His deposition is ANN CLARK CHILTON FROEHLICH, JOHN FRY CHILTON, III, JAMES ANDERSON CHILTON, ROBERT WILSON CHILTON, JR. and MARY SANBORN CHILTON FOOTE Plaintiffs, vs. CRAIG CORPORATION, INC., Defendant. attached hereto as Exhibit "'B". 3. In his deposition, Robert W. Chilton explained that the Craig Corporation was created to purchase lots available to customers of Buyers Lumber Company for building individual homes. It was a wholly owned subsidiary of Cutler- 1 ~ ~ ~ Federal (Deposition Page 3). He indicated that Cutler-Federal was sold to Florida Agronomics (Deposition Page 4) and that Florida Agronomics then decided to abandon the small amount of residual real property in Pennsylvania, after selling the bulk of the real property wholesale to Hooke, Lebo & Hooke by deed dated January 21, 1986, (Deposition Pages 5 -6). Although, Plaintiff's believe that Craig Corporation became inactive after the conveyance of bulk of the land to Hooke, Lebo & Hooke in 1986, in order to pursue this action to quiet title it is necessary to make all good faith efforts to serve the Craig Corporation. 4. A search of the date base of the Pennsylvania Department of State yielded a report on the Craig Corporation which suggested that the status was active and the principle office address was at Northwest and Lincoln Streets in Carlisle. A copy of that report is attached as Exhibit "C". The Craig Corporation no longer maintains an office at that address, nor has it done so for many years. When the Craig Corporation did business in Cumberland County, Pennsylvania, its local representative was Robert W. Chilton. 5. Robert W. Chilton advised that Craig Corporation was owned by SAIDIS, FIAWER Sz I.ZNDSAY ,-ruw 26 West High Street Cazlisle, PA Cutler-Federal, Inc. A search of the data base of the Pennsylvania Department of State yielded a report, attached as Exhibit "D", indicating that Cutler-Federal, Inc. was an active foreign corporation with an office at 315 North Front Street, P.O. Box 3787, Harrisburg, PA 17105. That address is not at this time an office of Cutler-Federal, but is the office of the law firm of Boswell, Tintner, Piccola & Alford, the law firm which at one time represented Robert W. Chilton and is believed to have filed the registration of Cutler- Federal, Inc. as a foreign corporation in Pennsylvania. 2 .- r 6. A search was made of the data base of the Florida Department of State. That search did not yield any active corporation, but identified a Craig Corporation ~' which was "dissolved by proclamation". This report is attached hereto as Exhibit "E". The search also identified a Craig Corp. which was also noted as having been dissolved by proclamation, which report is attached as Exhibit "F". A search of the records Cutler- Federal Corp. in Florida, the report of which is attached as Exhibit "G", identified Cutler- Federal Corp. as an inactive corporation administratively dissolved on September 19, 2003. Other corporations related by Mr. Chilton to possibly have connections with Cutler- Federal include Florida Agronomics, Inc. A report on Florida Agronomics, Inc. is attached hereto as Exhibit "H", and indicates that it was involuntarily dissolved on November 21, 1984, and lists a registered agent as a Marjorie Kroul. 7. A report on Florida Agronomics, Inc. is attached hereto as Exhibit SAIDIS, FLOWER SZ LINDSAY 26 West High Street Carlisle, PA "I", which also notes that an administrative dissolution occurred on September 19, 2003, and identified a registered agent as a William R. Bethea. 8. The Plaintiffs requested Sheriff Kline to serve the action to quiet title by certified mail on William R. Bethea, registered agent for service of Florida Agronomics, Inc., Marjorie Kroul, registered agent for service of Florida Agronomics, Inc. and Harold Holder, registered agent for service of Cutler-Federal. 9. The return of service found by the Sheriff's Office in this matter is attached hereto as Exhibit "J". It shows that an attempt was made to serve William R. Bethea and a receipt card was signed by someone with an illegible signature. The attempts to serve Harold Holder, Jr. and Marjorie Kroul by certified mail were unsuccessful. But, that the attempt to serve William R. Bethea was successful is 3 i ~r I suggested by the fact that the undersigned received a telephone call from an individual identifying herself as Marguerite Bethea. This individual indicated that she and her husband received a certified mailing of the Complaint. She indicated that she believes that Florida Agronomics did not have any dealings at any time with any Craig Company in Pennsylvania, and that she believed that Florida Agronomics had no property interests in Pennsylvania. 10. Plaintiffs have prepared a Notice which is believed has the essential information to advise anyone acting on behalf on Craig Corporation, Inc. of the nature of this action to quiet title. The Notice is attached hereto as Exhibit "K". WHEREFORE, Plaintiffs request that this Court enter an order authorizing the service of Craig Corporation, Inc. in this matter by publishing in the Cumberland County Law Journal and the Carlisle Evening Sentinel. SAIDIS, FLOWER & LINDSAY Attorneys for Plaintiff B James D. lower, Jr., uire 26 West High Street a V ~ Carlisle, PA 17013 Phone: (717) 243-6222 I.D. #27742 FLOWER ~ 26 West High Street Carlisle, PA 4 .~ VERIFICATION I hereby verify that the facts set forth in the foregoing Motion are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Date: ~ z ~ 1 0`, FLOWER 8t LINDSAY ~- 26 West High Street Cazlisle, PA ti James .Chilton M.~.d oos ®(131~Aa3d S31d34fi00008 ANN CLARK CHILTON FROEHLICH, JOHN FRY CHILTON, III, JAMES ANDERSON CHILTON, ROBERT WILSON CHILTON, JR. and MARY SANBORN CHILTON FOOTE Plaintiffs, vs. . CRAIG CORPORATION, INC., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW { NO. 07- ~~i`3y' ~~ ACTION IN QUIET TITLE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the 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 SAIDIS, FLOWER Sz LINDSAY 2G West High Street Cazlisle, PA 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 TRUE OPY FROM RE+C®RD 32 SOUTH BEDFORD STREET In Testimony hereof, I here unto set my hand CARLISLE, PA 17013 and the seal f said Court at Carlisle, Pa. (717) 249-3166 This ....~d...... day of... .........., a~`~... ,.........~ .....,~:... . ..... ~~ ..~~~- ,,..mow Prothonotary r ~ L , ~ ANN CLARK CHILTON FROEHLICH, JOHN FRY CHiLTON, 111, JAMES ANDERSON CHILTON, ROBERT WILSON CHILTON, JR. and MARY SANBORN CHILTON FOOTE Plaintiffs, vs. CRAIG CORPORATION, INC., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. ACTION IN QUIET TITLE COMPLAINT AND NOW, come Plaintiffs through their attorneys, SAIDIS, SHUFF, FLOWER & LINDSAY, and aver the following: 1. The tract of land in question is described as set forth in Exhibit "A", and is a tract of land consisting of almost all of Lot No. 27, Block G, Meeting House Heights, all of Lot No. 2, Block G, and a very small portion of Lot No. 1 of Block G of Meeting House Heights, as well as most of Lot No. 1 of Block F of Meeting House Heights, all situate in North Middleton Township, Cumberland County, Pennsylvania. 2. The land in question is a small portion of the land conveyed by SAIDIS, LINDSAY .- 26 West High Street Carlisle, PA Clarence E. Cornman and Clara J. Cornman to Craig Corporation, Inc., by Deed dated March 15, 1960, and filed in the office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on March 15, 1960, at Deed Book S-19, Page 118, attached as Exhibit "B". The land in question is the sole remaining land which remains titled in the name of Craig Corporation in Cumberland County, Pennsylvania. t~„ ~. i~» 3. ROBERT W. CHILTON was an officer of CRAIG CORPORATION, INC. from its inception 4. CRAIG CORPORATION, INC. was a subsidiary of Cutler Federal Corporation. 5. In 1984, the stock of Cutler Federal Corp. was sold to Florida Agronomics. 6. After the sale of Cutler Federal Corp. to Florida Agronomics, ROBERT W. CHILTON, met with an authorized representative of Florida Agronomics, Jerry Diamond, in St. Augustine Beach, Florida. Florida Agronomics agreed to continue to pay Plaintiff ROBERT W. CHILTON, Ten Thousand ($10,000.00) Dollars per year for a period of five years to continue to operate CRAIG CORPORATION, iNC. in Cumberland County. 7. Subsequently, Florida Agronomics made the decision to divest its operation in Pennsylvania, and auctioned off almost all of the remaining Meeting House Heights lots owned by CRAIG CORPORATION, INC. The land in question is residual land and was not sold at auction. 8. The last Deed on record in Cumberland County conveying land SAIDIS, FIAWER ~ LINDSAY nrrotw~ts•aruw 26 West High Street Cazlisle, PA from CRAIG CORPORATION, INC. was a Deed dated January 21, 1986, recorded at Deed Book R-31, Page 994, recorded January 23, 1986, conveying numerous lots in Meeting House to Heights to Hooke, Lebo and Hooke, attached as Exhibit "C". 9. Following that conveyance, CRAIG CORPORATION, INC., and its owner, Florida Agricorp, made the decision to abandon any remaining property in 2 IIr t i ~ ~, e Pennsylvania in order to prevent being liable for any corporate taxes in Pennsylvania. They provided no funds to ROBERT W. CHILTON to provide for taxes and maintenance of the remaining property. 10. Florida Agronomics, through CRAIG CORPORATION, INC., breached the contract to continue to pay ROBERT W. CHILTON Ten Thousand ($10,000.00) Dollars for five (5) years, paying only the first Twenty Thousand ($20,000.00) Dollars agreed to. Since CRAIG CORPORATION, INC., maintained control of the company cash, ROBERT W. CHILTON had to provide for all taxes and maintenance of the subject real estate from his own funds. 11. After the breach of contract by Florida Agronomics and CRAIG CORPORATION, INC., and their abandonment of the residual real estate, ROBERT W. CHILTON formed a good faith belief that he was entitled to ownership of the land in question both as a result of the breach of contract and as a result of his assumption of the costs of maintenance and taxes. 12. For a period of in excess of twenty-one (21) years, ROBERT W. SAIDIS, FIAWER ~ LINDSAY ATIORNEYS•AT L4W 26 West High Street Carlisle, PA CHILTON has established an adverse, open, notorious, continuous and uninterrupted possession of the land in question. Copies of a tax bill of CRAIG CORPORATION, INC. and ROBERT W. CHILTON'S personal check, dated May 3, 1986, paying those taxes are attached hereto as Exhibit "D". He has paid all real estate taxes since that date. 13. Real estate taxes for the property in question have been paid by ROBERT W. CHILTON personally in a cumulative amount in excess of Eight Thousand ($8,000.00) Dollars. 3 c 14. ROBERT W. CHILTON has, during this period, maintained the property and paid for grass cutting, leaf removal, and other maintenance in an amount in excess of Four Thousand Five Hundred ($4,500.00) Dollars. 15. ROBERT W. CHILTON and VIRGINIA C. CHILTON, by their Quit Claim Deed dated March 15, 2005, granted and conveyed all of their right, title and interest in the property in question to their five children, ANN CLARK CHILTON FROEHLICH, JOHN FRY CHILTON, III, JAMES ANDERSON CHILTON, ROBERT WILSON CHILTON, JR. and MARY SANBORN CHILTON FOOTE, the Plaintiffs in this action. 16. The five children of ROBERT W. CHILTON and VIRGINIA C. CHILTON have continued the adverse, open, notorious, continuous and uninterrupted possession of the subject land and now take responsibility for taxes and maintenance on the property in question. 17. Neither Defendant CRAIG CORPORATION, INC., nor any business entity with which it is connected, has paid any expenses, paid any taxes, performed any maintenance or asserted any incidents of ownership of the property in question during the entire 21 year period of the adverse possession by Plaintiffs. WHEREFORE, Plaintiffs request that the Court enter an Order and that SAIDIS, FIAWER Sz LINDSAY ni-[onraers•nTUw 26 Wesr High Srreer Carlisle, PA the Defendant be forever barred from asserting any right, lien, title or interest on the land inconsistent with the interest or claim of Plaintiff, and enter an appropriate Order that that Plaintiffs, ANN CLARK CHILTON FROEHLICH, JOHN FRY CHILTON, III, JAMES 4 ANDERSON CHILTON, ROBERT WILSON CHILTON, JR. and MARY SANBORN CHILTON FOOTE, have good and marketable title through adverse possession. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff By '~ James .Flower, Jr., Esq i~ 26 West High Street Carlisle, PA 17013 Phone: (717) 243-6222 I . D. #27742 SAIDIS, FI.AWER ~ LINDSAY ~~.~•~W 26 West High Street Cazlisle, PA 5 VERIFICATION I, JAMES ANDERSON. CHILTON, one of the Plaintiffs herein, hereby verify that the statements made in this Action to Quiet Title 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.C.S. Section 4904, relating to unsworn falsification to authorities. J es Anderson Chilton Date: July 9, 2007 SAIDIS, FIAWER ~ LINDSAY arm~vs•xnuw 26 West High Srreet Carlisle, PA 6 ALL THAT CERTAIN tract of land situate in the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described in accordance with a Final Subdivision Plan for Robert W. Chilton and Craig Corporation, dated June 12, 1980, as follows: TRACT NO. 1: BEGINNING at a point in the center of Meeting House Spring Road leading from Pennsylvania Route No. 641 to Meeting House Spring, which point is further described as being North 13 degrees 51 minutes West 312.54 feet from an iron pin marking the corner of lands of Burr Heights and lands previously conveyed to Craig Corporation; thence along the centerline of aforementioned Meeting House Spring Road North 13 degrees 51 minutes West a distance of 85.48 feet to a point at the corner of lands now or formerly of Robert W. Chilton; thence along same, North 76 degrees 09 Minutes East, a distance of 155.0 feet to a point at the corner of Lot No. 2, Block F, Plan 5 of Meeting House Heights; thence along same South 13 degrees 51 minutes East, a distance of 85.48 feet to a point at the corner of Lot No. 6, Block F, Plan 2 of Meeting House Heights; thence along same South 76 degrees 09 minutes 00 seconds East 955.00 feet to a point, the Place of BEGINNING. TRACT NO. 2: BEGINNING at a point in the center of Meeting House Spring Road, leading from Pennsylvania Route No. 641 to Meeting House Spring, which point is further described as being North 13 degrees 51 minutes West 606.19 feet from an iron pin marking the corner of lands of Burr Heights and lands previously conveyed to Craig Corporation, and also at the corner of lands now or formerly of Robert W. Chilton. Thence along the centerline of the aforementioned Meeting House Spring Road North 13 degrees 51 minutes West, a distance of 96.27 feet to a point; thence North 76 degrees 9 minutes 00 seconds East, a distance of 146.64 feet to a point in line of Lot No. 26, Block G, Plan 5 of Meeting House Heights; thence along same, South 13 degrees 51 minutes East, a distance of 100 feet to a point; thence along the aforesaid Lot No. 26, North 76 degrees 9 minutes 00 seconds East, a distance of 131.58 feet to a point; thence South 13 degrees 51 minutes 00 seconds East, a distance of 115 feet to a point; thence South 76 degrees 09 minutes 00 seconds West, a distance of 112.50 feet to a point; thence North 08 degrees 21 minutes West along lands now or formerly of Robert W. Chilton, a distance of approximately 93 feet to a point; thence along same, south 84 degrees 00 seconds East, a distance of 155.54 feet to a point at the centerline of Meeting House Spring Road, the Place of BEGINNING. TRACT NO. 1 AND NO. 2 BEING part of the same premises which Clarence E. Cornman and Clara J. Cornman by deed dated March 15, 1960 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 195, Page 118, granted and conveyed unto Craig Corporation, Inc. EXHIBIT "A" ~. I G ~, ~tC7 G d ~-Q~y~ p,"C t ~7 N i 30.0 ~ /t~;~{ t~ 3 c~ ~~ 9~ ~~ '~ ,,~~r,,: ~9 ~ .t~ ~`~~ of at 2~~ r`~2 fl ~~ J ~ ~ ~. 1 'I"d~`~ U O ~ j~ 5_5.4,- ~ t 9.49 ' ~f~~a~: ~ ~ _ ,, ~ ~ ~ ~ ~ ~ / ~ '~ ~ , ~ ~~r ; In 13 ~ Q ~: ~ti~~ ~ nl ~ ~ ~ , -! ~ ~ Z ~.~ "cr ~ ~ -cow ~'- '~ ~' ° ~ ~~ 2 ~ j 2 ,t ~ _ 'I ~ 111 ~ ~° i CD 5 Cc, ~ R( Asa ~ a ~ ' 1 i (~ d ~~ ~ ! r2 Z~ ~ i rs o la4 i ~~%/ ~ ~ _R~ ~' ~ 2~~ ' a ~ 1 30.o N -rte oar E- 154-.~~/ ~Sia ~ ~ y~ ~ ~ ~ ~ ~ 1 '~I ~ ~ , ~ s r, l~ ~_ .._ --~ Z BOOR .S ~.,~ i't;~i .~!(~ AND, the said grantor s, do hereby covenant and agree to and with the aairl grantee ,that they ,the grantor s their heirs, executors and administrators, shall and will wa~-•rattt Generally and forever defend the herein above described premises, with the hereditdmenta and appurtenances, unto the Said grantee its successors and assigns, aflainst the said grantor s, and against every other person lawfully claiming or zuh.o shall hereafter claim the same or any part thereof. SCk{!''~L DISTRICT Of NORffI ~',`.l[';;L: TO'~t ,~l'vl.ySIIIP nt,~u41i r ~`6..QD~.c~ ,,--pp qq~~~~ _~.!.....IY._.. T~~ !'n!!ecln~ or AAgdent / ~~~ I~ y ~ I `_ _~i ly .~, IN WITNESS WHEREOF, said g•rantcr sue, ve hereunto set their hancta and seal s the day and year first above written. nrD, BralrD anD ~lfllOrfrD ~~~~~~~~~ ~~_~~~~`~ 6EA ~ Clarence ~, Cornman In tilt ~Irearnrr at ~_~ ....................~...,.{.,,...~..,......._.........................---................ REAL ..... ,,.. , vvv .. SEAL Clal.a J : COrnlnan .... ...... .............. ...................................._...._.... NEA1. I hereby certify that the precise residence of the within named Grantee is N ate w.e,~ owe d, t, ~. ~ o.~ S ~ ~ , ~.t~.Q.~. , ~cc. . ~ , B~o~; S ~ :~ ~.;~~ ' 1~ feet to a point in the center Qf said Meeting House Springs Road; thence along the center of •said Meeting House Springs Road, North Two (02) degrees Fifty-one (51) minutes West, a distance of Six Hundred Seventy-six and Fifty-six hundredths (676.56) feet to a point in the center of said Meeting House Springs Road, , (iron pin), the place of BEGINNING. CONTAINING Forty-nine and Forty-two hundredths (49.42) Acres, more or less, according to a survey made the 29th day of February, 1960 by D. P,. Raffensperger, Registered Surveyor of the State of Pennsylvania. . BEING a ,portion of the same tract of land which Romane S. Kruger, (widow), et al, by their deed bearing date the 24th day of January, 1946 said deed being recorded in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania in Deed Booh "D", Volume 13, Page 331, granted and conveyed to Clarence E. Cornman and Clara J. Cornman, his wife, GRANTORS herein. i 7114ST--Dad from Corporation to Indi~ldual or Corp., Aflorn~y'^ Ack. Henry Hall, Inc., Indiona, Po. ;,,, q;i a.. i~ nt'. ~ ., i : _........ .. ' ~~~~~ JAN 2 ~ l~$6 ~~ ~~ 1 MADE THE :z l 5 ~ day of January in the year ojour Lord one thousand nine hundred E1 ghty S1X (19 86 ) BETWEEN CRAIG CORPORATION, a Pennsylvania corporation ~A N D HOOKS, LIDO & HOOKS, A Partnership consisting of William H. Hooke, Sr, George 0. Lebo and William H. Hooke, Jr. of Carlisle, Cumberland County, Pennsylvania hereinafter called Grantees; , WlTNESSETH, that the said Grantor for and in consideration of the sum of One Hundred Sixty-Five Thousand and no/100 (:6165,000.00) lawful money of the United Staten of America, unto i t wel! and truly paid by the said Grantees at and before the sealing and delivery of these presents, the receipt whereof is hereby acknowledged, has granted, bargained, sold, aliened, enfeoffed, released and confirmed, an~~l by these presents does grant, bargain, sell, alien, enfeofj, release and confirm unto the said Grantee i t 5 .. ~. . ~ •,1 • • r Meeting House Heights South 20 degrees 59 minutes 42 seconds East 161.92 feet at point in Lpt No. 25, Block G; thence along Lot No. 25 Block G, South 23 degrees 51 minutes 39 seconds West 97.14 feet to a point; thence still along part of Lot No. 25 and Part of IAt No. 26 southeast- warrlly 100 feet to a comTan point of Lots 26, 2 and 3 Block G; thence along Int No. 2, Block I G f~ieeting house Heights southwestwardly 115 feet to a point on the eastern edge of Meeting House spring Road, the Place of 88GINNiNG, BEING Lots 1, 2, 3, 4, 5, 6, 7, 8 and 9 Block J; Lots 1, 2, 3, 4, 5, 6 and 7 Block K; Lots ' 1, 2, 3, U, 5, 6, 7, 8, 9, 10, 11, 12 Block H and Lots 3, 4, 5, 6, 7, 8 and 9 Block G. TRACT 2 ALL that certain tract of land situate in the Boroug~n of Carlisle, Cwriberland County, Pennsylvard.a, bounded and descMbed in accordance with a plan prepared by D. P. Raffensperger, ~`~,_,_ R. S. dated August 26, 1976, and recorded in the Office of the Recorder of Deeds for Cumberland ' County ir3 Plan Book 30 page 91,, gas follows BEGINNING at a point on the northern edge of Armstrong Road at corner of Lot iVo. 22, Block G, Meeting House Heights; thence along Lot No. 22, Block G,•North 13 degrees 51 minutes West 115.0 feet to a point at corner of Lot No. 23; thence along Lot No. 23 North 40 degrees 36 minutes East 122.y1 feet to a point common to Ir~ts 21, ai 23 and 15, Block G; thence along ~t f'! No. 20 South 13 degrees 51 minutes East 186.46 feet to a point on the northern edge of Armstrong Road; thence along Armstrong Road South 76 degrees 09 minutes West 100 feet to a point on said road, the Place of BEGINNING. BEING LAG No. 21 glock G ~ etin House He ts. j TRACT ~ ~ Chat certain tract' o~ land situate the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described in accordance with a plan prepared by D. P. Raffensperger, R.S, dated August 26, 1976, and recorded in the office aforesaid in Plan Book 30, Page 91, as follows: BEGINNING at a point on the northern edge of Armstrong Road at corner of Lot No. 21, Block G, Meeting House Heights; thence along Lot No, 21, Block G North 13 degrees 51 minutes West 186.46 feet to a common point of lots 21, 23, 15 and 20, Block G; thence along Lots 15 and 16 South 85 degrees 05 minutes 45 seconds East 100.51 feet to a point at I.At No. 19, Block G; thence along Lot No. 19, Block G South 17 degrees 30 minutes 45 seconds East 153.71 feet to a point on the northern edge of Armstrong Road; thence along Armstrong Road, by a curve to the right having a radius of 365 feet and an arc distance of 23.33 feet; thence still along Armstrong Road, South 76 degrees 09 minutes West 81.67 feet to a point at Lot No. 21, Block G, Meeting House Heights the Place of BEGINNING. BEING Lot No. 2b, Block G. Meeting House Heights. TRACT 4 ALL that certain tract of land situate iri the Borough of Carlisle, Cumberland County, ,~.-- Pennsylvania, bounded and described iri a,Ccordance with a plan prepared by U. P, tlaffensperger, R,S. dated May 21 1969,. and recorded in the office aforesaid in Plan Book 21, Page 20 as follows: BEGINNING at ,a point on the edge of Bellaire Drive at the corner of Lot No. 13, Block H; thence along Bellaire Drive by a curve to the right having a radius of 245 feet and.an arc length of 125 feet to a point at Lot No. 15, Block H; thence along Is~t No. 15, Block H, South ~o r7orrmra Lq mtnut;es S~ seconds West 115.0 feet to a common point of Lots 14, 15 and 17, thence - _, r_~ ~.~ ,~. • . TOGETHER with all and singular tracts of land ways, waters, water-courses, rights, liberties, privileges, hereditaments and appurtenances whatsoever thereunto 6clongind; or in anywise appertaining, and the reversions and remainders, rents, issues and profits thereof• and all the estate, -igh6 title, interest, property, claim and demand whatsoever, of the Grantor in taw, equity, or otherwise howsoever, of, in and to the same and every part ehereof, TO Hd VEdND TO HOLD the said tracts of land hereditaments and premiss herebygranted or mentioned and intended so to be, with the appurtenances, unto the said Grantee, its heirs successors and assi~ and assigru, to and for the only proper use and behoaf of the said Grantee, its heirs, successors and asslgis and wsigns forever. ° COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE - • ~* _ r~. =_ iRXNSFER JAHT3'8G rv:~~~ 7 ~ Q, ~ Q =' ° -- P.8.I1162 ..~.._ _.__~ . ~ "' dnd the said grantor hereby covenants and agrees that it will warrant ~~ral1 y the property herE6y conveyed. "' COMtv10NWEAtTH CF PENNSYLVANIA =_ DEPAP,TMENi OF REVENUE ,. . _.~.~` ....~ '. ~ • , Received the day ojthe data ojthe above Indgnture orthe above nar-{td Statc of PFt~Bi~t~R FLORIDA • ' ~ , County of ~ HILLSBOROUGH ' ' ' ' '~' ~ - • ~.~ • On thin, the - 21St . ~ _ day of J~,,~.ry ,19 ~ , before me, the undersigned o~cer, personally appeared.. ~ ~ ~ James H. Patterso ~ ' ' ' ~ ~ ' ' ' '. Pt•esldent ~~; ~R~'t 'tort PaltATro r~~:::.,, know to me (or satisfactorily proven) to 6e the 'person who is the s4iar+~er nnrp,ed to the ~regoing Deed, , attd..•'~..,;, , . a, acknowledged that he executed tltit same as the act of his principal for the purposes therein contained.• _ ,~•'~ ~ ~+.i. ~:U /~ "'.,•, !n witness whereof, l hereunto set myhand ond.ojficiol seal ~~'•~~=.~•.. •,,;;'' ~~o~a~,;;, .~ :~ ' s$s.r. ~/ ' .'~ . v~.U' : ' ~ ;. MOtABY pUlUC STATE of t1Ri /-a~-g~ President , ~„ RY CDNMISSIDM CxP. NAR 30,1989 ~''.~\,~' ~,.?' Title of Offieer:~y`, •~ U ~}1 f ~~, OONt)CD iHRU 4FNCRAL 1N5, uND. CERTIFICATE OF RESIDENCE. _ I do hereby certify that the precut residence and complete eost office address of the within named grantee is• 31 Z ~ • ~~^'"''~'^' >T January 2 Z ~19 $( Attorney for ~ t' - y ' ~ ~ ~ - _ _. ~ ~ O ~ ~ wow ""w~,.+.-.- _-..,, r' ~-~ q;'"5e' y m y r m m ~ . T SOD ~ m 1 mx n --' :o n -, O~ y,, ~~ x m ~ '° ~ G^ rn - r- . .-, n . I h, N i s -_J ~ rte. L S 'a r ~~ O '• I~ ~\ ~ I rn Gl 3 C3 . -~ .' f_ f-" ' ~ a ro a 'J i i ~ '1'` :'~J ~ ~ J V% ;:l l IV; J .~ l.~ 'fl O . , _ ~ ~ ' .n --~ 1 ;` -~ i - O r` m as 'I' ~ ~ ~ ~ p1 d ~ ~ '-{ -. ~ n ~ .., _. ' Q, + -n r_ ~. r ~ m o ~~ 6Li ~\ ~ .• , '. 1 9 ? O.. 1I -~ sn C ft. r-: fv D m 7~ ~ n b ! ~ ~ ~ ~ • ~, i '~ ~ O ~, -~ ~yy, ~ a '~ m ly1 n ~~ \ G7 ~L to ~ U-I ~ to i \ ~: n ! ~ ~ ~ ~ ~ ~ - r I n ! ~ r . v x t ~ ~ ~, ~ .> ; u, ~.~ ~ o ii; a' ' ~ • r _, "' ,~ In k ~,' ' ,~ o ~ f, ~ .. 1~'';~ rn ~~' ~ ~ ~~ ~ i , I ~ -- ~ Ch ~, r I a x ; ~ r l ~` EA -1 O -~ 1~ -n ~ Xf o W ti- ~ ' i ~ Q t , ,p ~'fQ n ,1' YF' '~ ~ I 1 ' ~~ t ~, t z ,,,~ i ! r, n '. ~i cn v '" w ~^ ~ , o c -~ --~ ^ r 1 --' ..~ , ' \ -n (i/ rv .T. 4 m o ~ ^C -i -+ v q M1~ ~ Tq a -.~ C Z n x r~ .~ G~ ~. 3 3 T S v p c J cn x, .,~ ' l "q '. I k't, ~ A r S v c a f1# -i -< A ~ .~ n a Ir n ~ .. ~ , ~ ~~a ~ Q G A I 2 O G h, ~ ~ ~ ~1' o ~ ~, ~L-t ~. A ~^ A ~, 'I~ ~ ~ i ~ 'i ~7 C" C Z' m ~ .3 m 1, 'M i , '.R D --I rn m ~ O q~. -~ rr g '~ ` IT X O ~' ~ ~ ~ q ~ n n m Zs X. ~ ~ ~ ~ ~ ~ . k;~ x ~~ ' p I' ~ ~ c v, z ~' - -n ~ c ~ ~ .. r, , p ~ ,~ '~ ~ ~ ~ ' m ~ ^ ~ _ ~; .~, ~ v~ ~ ., ~ ~ fr~ ~ ~ G~ fT, z ~ - ~.r c ` A ~ ~ I ~ , ~ Si O m C D o G ~ I~ ~~h ~ ~ v rn C C m T c " cn . rn z n b ~ -i .Z7 m O 7 c z "~ TAkYEAR ~-- -~ RCA ES t nT~S t r+1/1 [VC~TSCk~ b~,,,~i0.RLI 5LE bREA SCf-i~30L D I STS ~ ~"' :CHECKS ~~~~' R K£~i„~~C ,Blf T0: ~,~~ ~. ~~~~~E~S 5T C+ARI.I Sl,f ~ P,4 ~ TC 1 CM _.._____._.~___~~ ~ i ~_. ___. AITT A6 P M .~., P M' ~;, P Ant ~~,, t' 3 b 3 ? _..__~____ _ T~~~ 1 b;7 --'- -- ---~ ACCT' NO+~ 05~,~9~d547-083 T~ CQ Cli~,,3G' CpRPpRATIpN giv ~i~RM~RS T~usT e~c~~. 1 Wr ~jGH STR€ET CARLI SL.E ~ ~'A 17013 fF `IpUAESIRE d RE[EtPT, F#CLOSE,A3tAil~PFD~bB~SiiLp~1{iJfEgE~'Nryt1EJ(OUR Cpp~ •.. <~{+ ~.~... ;~' ~. :TE ASSESSMENT 'BILL WO. ~~w~ ~~1~.~v cu0 AM ~`0 530 PM __...-_ _ ~ ~ 'BURIN;, ri15 PEkIC}D PAY 'f HIS ADAta~4b .. _. _,-_., __~fi__~_ i~ ~~I _' -_ __ ~ ~Ayy~~.7 •m- A~,ryEf~/ ~ ~6~~~.. D~COUNT ~ w ~ 4/CT .. 7YLJY '~--}-- FACE * PEMALTY i_L.k~~t i~,Fs_R f~. LLEC~' ___ G~JLaGL~AS COU~r AR!~'uTRp~!~ RpAC ~.~T ~~ ~ECTIpN ~ ~~~~~ 1X`!1 ~-~! ~J4/~4~R7 Ut~dP~4,~D TAxES TURNED p~ER ""p Ct1"~'~ERLANl~ ~~0, TAX C~,A:IM BURE~kU~, '~1~O~J ~~E ~'DR ADD~L RECEIPI"S REQUESTED ...~ ~.~~, l TAXYERR ' ; ~REAI.-. ESTATES ~'TAX'~-AIpTI.CE'. -56-89 CARL'ISI.E AREA SCHOQL ;DISTRICT EKE CHECKS EARL,- R KEL.L.ER rnBLE ro: 1~-T . N MANQIIER -ST -CARLI.SLE+ PA 1?013 RNOf~EI 2~r3.0~57 ' NALTY S DATE AUGLJ°ST _ 1 ~ 1~~$ ASSESSMENT 2Op Blll NO, 109+4 9~. QAAM TO -4: ~QRM MON -•- TMUR5 ° 9`QQAM TQ 5:3pPM ~PRIpAY HO ,~~~ ~ , lp°ioP C~ ~ M °cP M °,oP M ioP '~,~',;;~:M~ %~p'"~ M DURING THIS PERIOD PAY THIS AMOUNT 1~2 t} `L (~ ~ ~ AL1G -• SEpT 1~~ 4~W ~ ` 4CT:-~• ~DV E Q'4 ~ ~ • A T R `4 ACCT NO,~ D5--14••-1647~Q83 ~=~~~ ~~'~~,~ ~~7C~r~ pOIJGt~AS COURT -CRAIG CpRPQRATION ~, ARMSTRONG ROAp 21~? FARMERS TRWST BLDG I.OT 27 SECTION G DISCOUNT ACE 'ENALTY I, W• HIGH STREET C.AftL;t~51E• PA ~,?013 • QN (J;~/15/$9_UNPAIp.`TAXES TURNE(~.`O~ER ' ~ TQ ~CI1'MB~Rk;AND Cp. °TAX ,.CLAIM BUREAU. , '• $1,.OQ FEE FOR ADD+L REGENTS REQUESTED TAX YEAR 9 hAKE CHECKS AYABLE TO: I DE -PENALTY IILLS A ~ E .S T A ~ ~ ~ T A. X N ~ ~ ~ ~+ ~ DATE ASSESSMENT BILL NO. CARLISLE S(~R~?UGH ,PAIL' ~,7 1~6~ COQ ~,09~+ EAF'L ~' K~;LLERf TAX C~fl.1.~OT~R' MON.~THURS 9OQ AM .~, 4~3C~ ~'M ~l+~tC?` ATV HgNQ~YyEk S~Tq 4 11~~~r j, • F'R.1 9 s ~QjQ AMr~~ 5 r 3~ ~~ CARLISLE~I ~'A 17013. ~R ~~ r`~~wQG~~ ACCT NO# u5"1~~1~~+~'.-t~3~ CRAIG CQKPpRATTON 2I,Q FARMERS T'f~UST BI.D~ ~7 ~ ~ 1 W* HIGH STREET ~'~. CARLTSLE+ PA. 17013 .~~,J/ .~ ,~ ~ ~~ +.ataraur~n~ ~..~.+,,,r~~ 11 ARMS`~RQNG ROAIJ 4.AT ,~ECT~~N G GpL1~!TY l,'I~RARY SQRt~ ,• ~ , ~• ~ , 1 `(~ %P ~ C,~ ~ D M ], Q % P 1 ~ ~+ M ~• ~ %P~',' Q ~ M % P M DURING THIS PERIOD PAY THIS AM 3;72 ~'~~ 5.b8 ~ taPR I ~„ ~ MAY q54 35~ 30 ' S~- ' ~ .tUNE ~ Y11~~»~' AFTER U 1' r p 415 ~3_ 3 F~~ ~n~ Il DISCOUNT FACE PENALTY ON p?/15,r89 UNPA.I1~ TAXES 1"~1RNEI~ AVER T4 C!,~lM~FRLAND CCU; -TAX C(~AIM SU~~'AU~ ~1.OL? FEE FOR ADL~AIw RECET~Tg R~t1l~~ST~I raxrEnR REAL• rSTA;~S TAX VI~TICE *~ SCH40L ~* DATE ,19~3.1-9~ ~ARl.ISLi AREA S~C~iC3~JL iIISTRICT AUGUST 1 '~ ~~~ ASSESSMENT . _ BILL NO. MAKE CHECKS PAYABLE 70: =~+RL R. KELLE~R 2110 1104 147 fV r~o~r'dOV~R ST ~Ji~r TU~r THURS 9:00 Ai<'i TO 4:30 ~i~ CARLISLE, P~1 17J13 W~la 9:00 Ai~i TO 12:Ot0 5~34~3i~+ ;'H4~l;c 24-0257 9:00 AM TG J:flG ~vl 4 SEli ALL H+3LI~AYS ;rarlni ~ r-- ~ ~• _.7.1~ tJ.~G ~ =, G ,.; ACCT 1~1~ t35-19-1;47-EJr~3 ~ CRAIG CJRP'Or~ATIUIV 21 t7 FAR~iER5 TRUST ~Lf)G 1 W. HIGH STFttET CAt~i.ISLc, PA 1701 .. TF YOtiR TAKirS Adz i1~~ >=;~C%:)kl, PLa:ASE r=0r^~WAND Ti,IIS aILL TC Y~IUR ~~iiTGAl-":c ~t)h'ia'AitY %P M~ DURING THIS l1G - SEPT CT - Svt3U DDsJG~.AS COi,RT C~.~ ARi~STFr()o'VG ROAD ~ GT 27 SECTtCIV G • GJ~1 4,~15/9c U;'tiF'AIi? TAKES Tilrti~!>r~ GV~R Tt7 CUfi~~~~RL~!Sy~ C~. TAX Ci_AIi41 >~iJR£AL"". __ _ _._,`~ 'l . 5~ ~i_ IF ti E _ f G_ F3 ~_ b ~ ' L R E C ~ I r T S R 'E' ~.~ = ,S 7E .D TAX YEAR RE~tsL EST,4TSr '361K NC3TT~C '"~i~VIS~E~" 1951-92 L"A~LISLE A~'1~~~ - Si~10~~. ~3I5T~RI~T MAKE CHECKS PAYABLE TO: EARL ~. i~~:~LGR 14 7 u~ H t~ Su i~ it E S't 5 7 C,ALR:~.ICCS~.~!cr ~~)t ''177;J3 ~i3i~~C 2~~-~G~ T 5 ~ H ~ ~3'L DATE ASSESSMENT BILL NO. ~1USUST '! ~ 9'91 ,~ 200. 1104 ~~6yir Ti1cs T.~ilJ~tS 9:~0 A~fi9 TO 4t~(? F'~I F ~ i 9 : ~D ~3 ~ ~f T ~l ~ ; 0l3 P>~S ~L~5~6 ~1~L ~~GLI:DA~'S P '~ M ~ P ^ ~C "' '~ ' + M DURING THIS PERIOD PAY 7HIS AMOUNY i~E'UEh~l tJ~S A~Lc1CAT ~ Ti3 T4i~ i1 ST.RICT A5 ~?'~.~s5 A R~S 1~LT i:DF ;~,ASSAG~ OF THE . GtNE.RRL OG - SEFT ~''~.~5 ?~. ~I ) Af'F'Rt~ t;F 1'991" °Y T~9~ PI~Ir~TI~iY~- AC CT - ~CaV 2,x.30 , , C~.~;~ ~'~niG~1S _ YLVA~i.Y,A a~ (~'t~ ',AL :A'SS .~Iwt FT ~0 :c 3 CRAIG ~~:;~~~~ r1TC~d ~'~ c ~.~;~wi~.,~s T~~~~T ~~~.~G 1 i~. HIGH STREET L~R1.3Si_irr ir'rh 17t1i:3 ~r~~~:t~s c~~r~T ~''~~ ~,~>;~~ST~~~a~ ~~~~ ~.~T ~'~ S~tTTt)~I ~ I ER,RI. KE~.~.,ER 'T~~ ~c~ll~ct~r St Y1:~13i? T,~~:~5, Anr1I~ ;.';l:~.C9's~ir i'LE~i~a~: CAN 4/15~f92 i'.)4`>~'~k3.~...TA)(ES T~3Rh~~#~ VAR FC~rk'~4.~1? THIS ~I1.L Tt~ Y~'~~t WS4?+~"fGAS~ T1? CE3t~'~3~l~LJ~+i~~ ~l"r. T~IX CLAIM ~~diREA:'U. C;r~~;',r~:~a4'._ _ -_._. _ _ _ ~1_.9:1Ci F~~ ~tl:~_.:~tl.).~"~ ~~C.~I!PT5__'r?~~E~~STEC)_ PAY THIS AMOUNT T YEAR i~i~RL• ~STr~TgS TNX AiflT~~ ~`~~~ c~~~.~~~~ ~o~~~~N . . MAKE CMECN6 PAYABLE Tq~ ~~i ~ ~'~~'~~l~~T Sx 4) k5 ~~( ~ 2 #S ~~R1.TSi.~ ~~ '1~'n9.~-171~ti ~ tJi11~1 ~'Y ~' * D T ASSESSMENT BILL NO. ~~~~+.3~~ ~~~~ ~~~ ~1~~ ~ • PH~~i~ 717-2~+3"~7~."5 %P ~ N ^„p M 96P ~ M >~p M %P GA DURING THIS PERIOD PAY THIS AMOUNT .. .5 ~ ~ ' 9 ~~ ~"F 1~ 1?Y .~ "IC'~?tiiC~3 I~. !~ ~I f ~ R ~1~s~ i+ 3 ~~aq ry Fr 1 . / ~ ' ~ y • J ~ y ~ Y~r ~iY y ~ , - ~ g 1!~ n ~~ ~ i. K ! { l i +~Yii L g y ~ ~s ~ T ' L l' { • ~ y 't. TLl ~pr r ~ .J.J ~~~~ ~~ ~Y yy p~ y JJ~~ y , y ~`~uYA~~i~ ~~~R _~~~'I.I' y ~ r ~ ~ y ~I ~rT7 A~CtT ~~ yf~.~~y'~yy~~~'r~~r~y~}~p,t~~'pyW~IT~~ ~yA 1. il. yi~11~ U X11 pyp yW~ ~ pF~i17 p'c ~iw}1' ¢f~~q ~~s IY !tea ,^ ~~ IJ ~.af. ni"9~RS 1 ik V+7~~1 waJ..Y ~.: ~ ~J. HYrL;H STRiEET ~l1i~L~a~~~r~ P~ '~7'p9, ,~. - o~ra~~~+~ ~g~o~~v~ ~~~` i itl.b8 tC~'f~1iQ3 . [~ YOUR ~'ih~f~~ ~~~ ~~ '~~~8t~3Mfs. PL~~ki~ ~1V~ 9!'y~'S~3 iYi~IPA~t3 3~K~c r TtI~N~~ ~h~IEIR ~O~i~~~2D 7f~iIS ~i.~ T~ '~~:U~t .~'~3~tT~~I~ ~'~ t~l~~I~I.~LV4~k9~ ~C~. Tt~X ~~.~T~6 ~~i~~.:~,~~i. .~Y~9~~4.~Y __--_ ____.... ~~.~t) ~~.~_~F~~.-__~1Yi~?'~,. ~t~_~~1'TS ~JRii~S,I'~:~: TAX YEAR DATE ASSESSMENT BILL NO. 7`~~2-y.~ dt~kL ~ST,~T~ 3AJf `~tJT.~L~ ~'~' K,s'k;~#iJ~J_ '*'~ ~'ll~at)aT ~ 1~~i~ ~,~ #~ L I 5 ~ ,~ A ~~ ~ ~ S ~, Fi. tJ t11. ~ ~ S T ~I ~: ~' 2 ~. L's "~ ~ ,~ S YAKS CHECKS PAYABLE TO: ' IN~A~t,``L.~~iC i,p9~£T3'~~i~.r ~~~ CTCe3 Jed"~~~1943d~k'~yery-/~'~Dr<l~^~ yt~~Al~r - ~+~~i 7i~'d~.'`yy7 yw,r~ ~~'ti~~~Yi,~l ~T )~~.t}ki'~ I Y1~~i'~'~~4 ~J F 1.7 R.1'J .~ ~ i F^ 'Cr u~ ~"~ L''%P ~ i'i. B.1M %P AA %P M %P M %P BA DURING THIS PERIOD PAV THIS AAOU ~~'.~ ~ISZ~i-L~~tT : 1~ ~ 7 7 ~t~ , ~ ~ ~~ ^.~ ~. i~ ) ~ ~ r ~~~ W„~ ~ .~:~4r ~ y ~ ,/ - 7 wq ~ y J t4. ! T! iJ' ~ h . ! O _ 4 . a . : 7 7 iL ~ r L~ hy q ~ ~~ 1'~~~ ~ ,. A y ' y '' *~ fl..~ "i ~ R4 ~ ~ 7 .~ ~ ` y y`~ y ~ ~G. ~s iI LF i ~I. HiC~i JTR~~3' w ,i w• ~~ DC~Ii~L~1 S ~~ ~'~ L,ti~3 a=C:TY CAN ~; TAX YEAF~ ` 1-,995 REAL E6TATE• TAX NOTICE CARLa5LE BOROUGH ~ C~HCCKS ~AYABL~ TQ DARLENE L. MOYER, C/0 CTCB 1~ S HANDVER ST SUITE 102 PO BOX 1~8 CARLISLE PA 17013-0128 DATE ASSESSMENT ** COUNTY ** MARCH O1, 1995 200 MONDAY - FRIDAY', 8AM - 4PM • PHONE: C717) 243-3725. BILL NO. C 1 1157 CO NTY LIBRARY BOROUGH %P M O %P M 1 %P M %P M %P M DURING THIS PERIOD PAY THIS AMOUNT 4.51 .24 7.06 DISCOUNT AR. - APR. 11 86 4.60 .30 7.20 FACE AY - JUNE : .5.06 .33 7.92 PENALTY FTER JUNE 13.31 ACCT NO 05-19-1647-083 CRAIG CORPORATION 210 FARMERS TRUST BLDG 1 W. HIGH STREET CARLISLE, PA 1.7013 DOUGLAS COURT & ARMSTRONG ROAD LOT 27 ~~~.~T~~~r_rG g;/tlil~9 11.8a l:H tt111~; e• ON 1/15/96 UNPAID TAXES WILL BE TURNED F , OVER TO CUMB. CO. TAX CLAIM BUREAU. HIS BILL TO YOUR MORTGAGE COMPANY 51.00 FEE FOR ADD'L RECEIPTS REQUESTED MAKE CHECKS PAYABLE TO: ~ TAX YEAR ~ BILL NUNIBER: _ fy +.~ :... ~ ~ -.tar. 3 ~'~ i.,1 t f ~`' ASSESSNIENT:~ ~ ~J '? i'S >. - r. ~: ~ L, k.::3 I i~~a 4 ~ : ~ i +~. Ski 1 w ~ 6 1. ~ DATE: :u. Ls +~ w ~ `= r>~ s is i'I `~r J 4- ~ 1 f ~ ( ~ c -'. l .~., E+. ~.. } ~. ~ `: ,~ Fc i,;. iW +,. ~' ~'" , 7 '~ ~ a i :r i ~' ~ .~ ~ 3 ~ ^~ a {r,. y .s r.~.t r ~~~'~~r~, ~~~# X~ 1~•~~~ ~, ai ,`~ HOUR,. e Yr ~ .+. i,J y ~~ T . 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E i :I' ~ 'i w, ~ 1 .a ~ ~',i 1~F ? `~+: +F1,a ~. >~~ T'Ei ~ ~ 8 ~ l.. t~, (ES ARE ESCROWED, FORWARD THiS 81LL TO YOUR GAGE 1;Q. $7.0o FEE FOR EACH nDDll'toNAL RFCrsPT DARLENE 1_, MOYER, GID CTGB 19 S HAN~UER SF, PO B(~X 128 CA13L1SLE, PA 17013-0128 MAP NO: 05-19.1(147-083 DOUGLAS COURT ACRES 320 LOT 27 SECTlUt~1 G Uacani Land VACANT LOT -LESS THAN f ACRE CRAIG GORPORATtON 210 FARMERS TlIUST BUILDING 1 WEST" H{GH STREET GARLISI_E PA 17613 MONQAY 8.30AM-4:DOPM TUESDAY-FRIDAY B:OUAM•4:OOPM CLOSED HOLIDAYS PHONE: (717) 243-3725 TAXPAYER COPY 1203 3!01/2004 Control No: 005-OD0082 2004 Statement of 1 Assessed Land Zmproopment Mine1 Values 29.9fU 0 Cd[iN1Y OE trUMBE~LANb Ratca -U021Q9U0 [;(r(7NTY R E 6 Q , 41 Rates _OOD2U30U , COUNTY LTA 6.OB __ 80 UGH Q-F GARU~ Rates .00310000 MfSNIC. RIE 92,97 TAX AMOUNT DUE -~ 6i11 No: Taxes f3i11 Dato: -~ ~ 'tot-dI 29.970 2t 6;1.12 ba.47 a _~ 5.96 ti.U6 2 ~a 91,05 92.91 $160.13 $163.4D T.f Paid Op ar ]liter 3101/x004 5/01/206a 7f Paid Ori or Before ~~3012otl4 613U 2DOd 1r NOT P1.m AY 12/13/200a TRYB HaLI. W1t,L aR xEm~NED •7'o TA CLAIM [jUREAO FUR COLLECTION AND FILING OF A LIEN YOUR PROPER~rY. Penat _ 10~ _ 70. a5 "1Da ~~_ 6.69.. ioa _102-20 $]79.74 'r /o3j2ooa r,~I~ ilbltE7.j~f~ ~9I1"~i8 1E~3.4t~ ~:Ji 1~~i3 ~n Return sib with Paymont. For a i3ecgipt ,Enclose Sctf Addressed Stamped Er7velope. M ~ d Roos ®031~A~3~ sara3s oooos - --.~~_ 1 2 3 9 5 6 7 e 9 to 11 lz 13 14 is 16 17 18 19 za 21 zz 23 29 25 ' 1 ROBERT W. CHILTON, VIRGINIA IN '1'ri~ C:.UUx'1' Ur' C:UMMUN C. CHILTON, ANN CLARK CHILTON PLEAS OF CUMBERLAND FROEHLICH, JOHN FRY CHILTON, COUNTY, PENNSYLVANIA III, JAMES ANDERSON CHILTON, CIVIL ACTION - LAW ROBERT WILSON CHILTON, JR. and MARY SANBORN CHILTON N0. FOOTE, . Plaintiffs, VS. CRAIG CORPORATION, INC., Defendant. ACTION IN QUIET TITLE ~Op~ DEPOSITION OF: ROBERT W. CHILTON TAKEN BY: Plaintiffs BEFORE: Amy R. Fritz, R.P.R. Notary Public DATE: October 12, 2005, 2:10 p.m. PLACE: Saidis, Shuff, Flower & Lindsay 26 West High Street Carlisle, Pennsylvania APPEARANCES: SAIDIS, SHUFF, FLOWER & LINDSAY BY: JAMES D. FLOWER, JR., ESQUIRE FOR - PLAINTIFFS ALSO PRESENT: James Chilton Sandy Foote Jane Chilton '`-~ - ,. ~.~, J ~~/ - ,, ~: ~~o/IZxrt ~eportirlg Services ~ ~1 T -~. "~° r'~00-863-3657 • 717-258-3657 717-2~8-0383 fax ~;,---_„ courtreporte~s4zeC~aal.com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2 DEPONENT Robert W. Chilton INDEX TO TESTIMONY EKAMINATION By Mr. Flower INDEX TO EXHIBITS N0. DESCRIPTION A Final subdivision plan B Photocopy of check and tax bill PAGE 3 PAGE 12 12 . ~ 3 1 2 3 4 5 6 7 8 9 10 11 I2 13 14 15 16 17 18 19 20 21 22 23 24 25 ROBERT W. CHILTON, called as a witness, being duly sworn, was examined and testified as follows: EXAMINATION BY MR. FLOWER: Q. Mr. Chilton, would you give your full name, please? A. Robert Wilson Chilton. Q. And where do you live, sir? A. 345 Mooreland Avenue, Carlisle, PA. Q. And have you in the past been associated with an organization called Craig Corporation? A. Yes, I have been. Q. Would you tell us a little bit about Craig Corporation and how you were connected with it? A. Craig Corporation was an entity created to purchase lots available to the customers of Byer's Lumber Company so we would have a captive audience. Q. So Craig Corporation was -- A. A wholly-owned subsidiary of Cutler-Federal. Q. But Craig Corporation went into the business of acquiring real estate to sell as individual building lots? A. Correct. Q. Now, was the bulk of the land that conveyed by Clarence and Clara Cornman to Craig Corporation in March of . • L E i 8 c 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 4 1960? A. Yes. Q. And, in fact, as 1 understand it, we have put together a description of certain property which is still in the name of Craig Corporation which consists of almost all of lot 27, all of lot number 2, a very small portion of lot 1 of block G of Meeting House Heights as well as most of lot 1 of block F of Meeting House Heights, all in North Middleton Township. Is it your understanding that that's the land we're concerned with today? A. Yes. (Off the record.} BY MR. FLOWER: Q. You're looking at a plan there, and what's been outlined in yellow here is a residual property that's left. Is that right? A. That's correct. Q. And after we're done here, we'll make a copy of this and outline it the same way and attach that to this as Exhibit A. Now, at some point was Cutler-Federal sold to another company? A. Yes. Florida Agronomics, I believe it was called. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 5 Q. Did you ever have a meeting with a representative of Florida Agronomics? A. Yes. Q. Who was that? A. Gerald Diamond. Q. And where did you meet? A. We met at Saint Augustine, Florida specifically to discuss the operation of the balance of .the Craig Corporation since new ownership had taken over. Q. And was that meeting shortly after the sale of the stock in 1984? A. Yes, it was. Q. What was the substance of your meeting with Mr. Diamond on that occasion? A. To discuss the viability of the Craig Corporation development and to determine what I would be able to do to further the interest of that design. Q. Did you come to an agreement that they were going to compensate you in some way? A. The agreement was that they would compensate me $10,000 a year for five years. Q. Okay. What happened after that? Did they make any decision about the Craig Corporation land? A. They decided that they would, contrary to my recommendation, that they would sell as many lots as they i 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 6 could from the development on a wholesale basis. Q. And how did they do that? Was that by auction? A. They ended up using Traiman Company from Philadelphia, and Traiman sold all the lots, and according to the plan, but there were a few that were left that were not included. Q. Now, we found a deed dated January 21, 1986 conveying a substantial amount of Craig Corporation land to Hooke, Lebo & Hooke. Was that the deed that was a result of the auction? A. That was a result of the auction, yes. Q. And that did not convey every single bit of Craig Corporation land, did it? A. Did not. Q. So what we're talking about today in terms of the land which we've described is a residual amount that they -- A. A residual amount. Q. 0}cay. Did Florida Agronomics make any further decision about this remaining property? In other words, did they make any decision about what they wanted to do with any small amount of residual Pennsylvania property? A. No. They wanted to forget that they ever had any property in Pennsylvania because they thought that they would be liable for corporate taxes and they wanted to have 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 ?q 25 no interest outside of Florida. Q. Did they essentially abandon the small amount of residual land? A. That and what the end result was, abandoning what was left. Q. Now, the deal that they had with you to pay $10,000 over five years, how much of that were you actually paid? A. 20,000 for two years. Q. And in your point of view, did they breach the contract to pay you that $50,000? A. They did. Q. Now, this small amount of remaining land that we're talking about, which, by the way, is along one of the roads in that development, is it not? A. I don't understand your question exactly. Oh, yes, over at Meeting House Springs Road. Q. Okay. There were still taxes that came due for this property, were there not? A. Right, yes. Q. Did Craig Corporation leave you any money to pay for taxes and maintenance? A. They had requested all profits be sent down to Florida and left me with no money to maintain the property or to pay taxes. 8 1 9 C E 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Did you make a decision about haw those taxes were going to be taken care of? A. Yes. To maintain the integrity of the development, I felt that I had to expend the funds personally to pay the taxes and to take care of any landscaping or leaf removal, mowing of grass and so forth. That was the requirement under the terms of our relationship with the individual lot owners. Q. I'm going to show you a check which is a check on an account of yours numbered 6344 from May 3rd, 1986. Does that look like one of your checks? A. It looks like a copy of the check, yes. Q. All right. And who is it made payable to? A. Made payable to Earl Keller, who was the tax collector. Q. And how much is it for? A. $9.41. Q. Now, does that match the bill that's at the bottom of that same page? A. It does. Q. And is that a tax bill for the property in question? P_. That is a tax bill for that property. Q. Or at least for some part of that property in question. 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 And, in fact, have you paid all the tax bills on this property since that date? A. Yes. Q. And do you have any estimate as to how much you've spent on real estate and school taxes for the property; that is, you personally, over the years? A. About $8,000. Q. Okay. Now, has there also been grass-cutting and leaf removal and other maintenance on the property? A. Indeed, yes, there has been, and I paid that. Q. You paid all those bills? A. Yes. Q. And what's the approximate amount of the -- A. About $4,500. That includes things that we were required to, on a common area basis, that we had to maintain. Q. Have you, in fact, felt that you've owned this land at least since May 3rd, 1986? A. Yes, indeed. Q. And have you essentially had uninterrupted possession of the land for that. period of time since May 3rd, 1986? A. Yes, uninterrupted. Q. Has Craig Corporation during that extended period ever, to your knowledge, asserted any ownership , 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 interest in the land? A. None. Q. Has anybody else tried to contest your ownership interest in the land? A. No one. Q. And have you done anything on the land that shows that you`re asserting so ownership such as blocking trafficways or anything like that? A. We put up a barrier to keep people from going across the property, and we put a chain between two posts to keep them out; and the Borough had put up a sign, road closed, and there is no road there. Q. Do you have any idea when you might have put up that chain or that barrier? A. Five years ago. Q. All right. So in summary, since May 3rd, 1986 you have paid all the taxes and all the bills associated with this property and you have treated it as your own? A. That's correct. Q. And you've had a good faith belief that based upon the breach of contract and your assumption of the costs and maintenance and taxes, those obligations, that this is your land? A. Yes. MR. FLOWER: Let's go off the record. ' 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Discussion held off the record.) BY MR. FLOWER: Q, Mr. Chilton, is there anything further you'd like to add to kind of flush this out or give any more detail that you think would be appropriate? A. Essentially the Florida Corporation requested and had the right to request all the funds that had been built up by Craig Corporation held in reserve to further the development of that land. And when they took all the funds down to Florida for their use down there, left me, as head of the Craig Corporation, with no operating capital. So, therefore, I had to use my own funds to accomplish what I felt was necessary to maintain the integrity of the development. Q. That reminds me of something that I would li}>e to cover. What was your formal position with Craig Corporation? A. I was the first and only president and one of the incorporators in the very beginning. Q. And what was your role with Cutler-Federal Corporation? A. I was vice president. Q. And it was about 1984 that the stock of Cutler-Federal Corp was sold to Florida Agronomics? A. That's correct. ' 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Anything else you'd like to add, Mr. Chilton? A. Jerry Diamond was my first contact in which we reviewed the contractual relationship. Subsequent to that, a General Thompson came up as a new president. He viewed the ground and made the decision that that should absolutely be sold and that I couldn't hold on to anything more. Q. And how did he communicate that to you? A. In person. We walked across the property and discussed the future. That is at that time that they decided that they wanted to have no entanglement, we'll call it entanglement, with corporate law in Pennsylvania, and they, in effect, wanted to divorce themselves of any tangible assets. Q. And shortly after they communicated that to you they made arrangements for the auction? A. That's correct. MR. FLOWER: Okay. I think that concludes the deposition. (Exhibits A and B were mar}>ed for identification.) (The deposition concluded at 2:30 p.m.) 13 1 2 3 4 5 6 7 8 9 10 11 12 _ 13 1 14 15 16 17 18 19 20 21 22 23 24 ----_ 25 COMMONWEALTH OF PENNSYLVANIA ) J SS. COUNTY OF CUMBERLAND ) I, AMY R. FRITZ, R.P.R., a Court Reporter-Notary Public authorized to administer oaths and take depositions in the trial of causes, and having an office in Carlisle, Pennsylvania, do hereby certify that the foregoing is the testimony of ROBERT W. CHILTON. I further certify that before the taking of said deposition the witness was duly sworn; that the questions and answers were taken down stenotype by the said Reporter-Notary, approved and agreed to, and afterwards reduced to computer printout under the direction of said Reporter. I further certify that the proceedings and evidence are contained fully and accurately in the notes to}:en by me on the within deposition, and that this copy is a correct transcript of the same. In testimony whereof, I have hereunto inscribed my hand this 27th day of October, 2005. ~.~' NOTARIAL SEAL Notary blic '" Amy R. 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T] T[• O Copyright ©2002 Pennsylvania Department of State. All Rights Reserved. Commonwealth of PA Privacy Statement . ~~ . ii______. ,,,,,.„„r„+;,,,.,c data rya nc/rnm/cn.Ckh/~nl'n.~S1177$S97 ~/i ~/?nm ~~ Business Entity Page 1 of 1 ~... Corporations Corporations I Forms ~ Contact Corporations I Business Services search Business Entity Filing By Business Name Date: 7/16/2007 HlstOry By Business Entity ID (Select the link above to view the Verify Business Entity's Filing History) Verify Certification Business Name History Name Name Type CUTLER-FEDERAL, INC. Current Name Business Corporation -Foreign -Information Entity Number: 618511 Status: Active Entity Creation Date: 7/2411975 State of Business.: DE Principal Office Address: 315 NORTH FRONT STREET, P.O. BOX 3787 HARRISBURG PA 17105-0 Mailing Address: No Address Home I Site Map J Site Feedback i View as Text Only I Employment `~~~ryr6`t1r, ~rl 4 ,~~ {~~~ ~ ~ ~7Sr O H;+ms Copyright ©2002 Pennsylvania Department of State. Alf Rights Reserved. Commonwealth of PA Privacy Statement ~^~-~--~•~~~*+.~+.~~ nnrr~~roti rn'7c efaf'P nA nc/r.nrn/cn~~kh/C~m.asti?395568 ~~~i~ ~~-~ „~ r 7/16/2007 www.sunbiz.org -Department of State Home Contact Us E-Filing Services Document Searches Forms Help Yage t or i Previous on List Next on List Return To List Events No Name History Entity Name Search Detail by Entity Name Florida Profit Coraoration CRAIG CORPORATION Filing Information Document Number 147510 FEI Number 000000000 Date Filed 06/20/1946 State FL Status INACTIVE Effective Date NONE Last Event DISSOLVED BY PROCLAMATION Event Date Filed 05/10/1950 Event Effective Date NONE Principal Address NONE Mailing Address NONE Registered Agent Name & Address None Officer/Director Detail Name 8~ Address NONE Annual Reports No Annual Reports Filed Document Images No images are available for this filing. Note: This is not official record. See documents if question or conflict. Home Contact us Document Searches E-Filing Services Forms Help Copyright and Privacy Policies Copyright ©2007 State of Florida, Department of State. http://www.sunbiz.org/scripts/cordet.exe?action=DETFIL&in~doc number=147510&in+~ca... 7/11/2007 .~ ~~ www.sunbiz.org -Department of State rdyG ~ ui ~ ;'_ ~,w Home Contact iJs E-Filing Services Document Searches Previous on List Next on List Return To List Events No Name History Detail by Entity Name Florida Profit Corporation CRAIG CORP Filing Information Document Number 183867 FEI Number 000000000 Date Filed 03/i 1/1955 State FL Status INACTIVE Effective Date NONE Last Event DISSOLVED BY PROCLAMATION Event Date Filed 04/24/1959 Event Effective Date NONE Forms Help Entity Name Search Principal Address NONE Mailing Address NONE Registered Agent Name ~ Address None Officer/Director Detail Name 8 Address NONE Annual Reports Na Annual Reports Filed Document Images No images are available for this filing. Note: This is not official record. See documents if question or conflict. _.. Home Contact us Document Searches E-Filing Services Forms Help Copyright and Privacy Policies Copyright ~ 2007 State of Florida, Department of State. http://www.sunbiz.org/scripts/cordet.exe?action=DETFIL&incLdoc number=X18-3^86/7&i/nom/ca... 7/11/2007 Lam. RCN i h, f 't~'r unbiz.org -Department of State Yage i of ~ Home Contact Us E-Filing Services Document Searches Forms Help Previous_on List Next on_List Return To List Events No Name Nistory Entity Name Search Detail by Entity Name Florida Profit Corporation CUTLER-FEDERAL CORP. Filing Information Document Number P00000077328 FEI Number 043532849 Date Filed 08/15/2000 State FL Status INACTIVE Effective Date NONE Last Event ADMIN DISSOLUTION FOR ANNUAL REPORT Event Date Filed 09/19/2003 Event Effective Date NONE Principal Address 1602 10 ST. SO. (SR590) SAFETY HARBOR FL 34695 Changed 10/29/2001 Mailing Address 1602 10 ST. SO. (SR590) SAFETY HARBOR FL 34695 Changed 10/29/2001 Registered Agent Name ~ Address HOLDER, JR., HAROLD 608 RiVERA DRIVE TAMPA FL 33606 US Name Changed: 10/29/2001 Officer/Director Detail Name 8 Address Titie PST HOLDER, JR., HAROLD 608 RIVERA DRIVE TAMPA FL 33606 Title ASAT HOLDER, SR., HAROLD 900 SCHELLBOURNE STREET RENO NV 89511 http://www.stmbiz.org/scripts/cordet.exe?action=DETFIL&in~doe_number=P00000077328... 7/11 /2007 www.sunbiz.org - llepartment of Mate Home Contact Us E-Filing Services Document Searches Previous on List Next on List Events Name Histo .. Detail by Entity Name Florida Profit Corporation FLORIDA AGRONOMICS INCORPORATED Filing Information Document Number 566690 FEI Number 591807870 Date Filed 02/28/1978 State FL Status INACTIVE Effective Date NONE Last Event INVOLUNTARILY DISSOLVEC Event Date Filed 11/21/1984 Event Effective Date NONE Princiaal Address 12329 MCGREGOR WOODS CIR., S.W. C/O MARJORIE KROUL FT. MYERS FL 33908 Changed 04/16/1982 Mailing Address 12329 MCGREGOR WOODS CIR., S.W. CIO MARJORIE KROUL FT. MYERS FL 33908 Changed 04/16/1982 Registered Agent Name & Address KROUL, MARJORIE 12329 MCGREGOR WOODS CIR.,S.W. FT. MYERS FL 33908 Address Changed: 04/16/1982 Officer/Director Detail Name 8~ Address Title P KROUL, MARJORIE 12329 MCGREGOR WOODS CIR FT. MYERS FL Title ST ~ KROUL, HARTLEY Return To List Forms Yitge 1 U1 L Help Entity Name Search http://www.sunbiz.org/scripts/cordet.exe?action=DETFIL&in~doc_numbser=5/~66690&/in~ca.'.. / 7/11/2007 L www.sunbiz.org - llepartment of atate An'nua,~ Reports Report Year Filed Date 2001 10/29/2001 2002 05/23/2002 Document Images 09/05/2002 -- Amendment 05/23!2002 -- ANNUAL REPORT 10/29/2001 -- ANNUAL REPORT 08/15/2000 -- Domestic Profit 1 CL~. V L v1 V Note: This is not official record. See documents if question or conflict. Home Contact us Document Searches E-Filing Services Forms Help Copyright and Privacy Policies Copyright U 2007 State of Florida, Department of State. http://www.sunbiz.org/scripts/cordet.exe?action=DETFIL&incLdoc_numbex=P00000077328... 7/11 /2007 www.sunbiz.org -Department of State rage i or ~ Home Contact Us E-Filing Services Document Searches Previous on List Next on List Return To List Events No Name History Detail by Entity Name Florida Profit Corporation FLORIDA AGRONOMICS, INC. Filing Information Document Number P01000106222 FEI Number APPLIED Date Filed 11!0212001 State FL Status fNACTiVE Effective Date NONE Last Event ADMtN DISSOLUTION FOR ANNUAL REPORT Event Date Filed 09/19/2003 Event Effective Date NONE Principal Address 401 LAKESHORE DRIVE IMMOKALEE FL 34142 Mailing Address 401 LAKESHORE DRIVE IMMOKALEE FL 34142 Reaistered Aaent Name & Address BETHEA, WILLIAM R 401 LAKESHORE DRIVE IMMOKALEE FL 34142 Officer/Director Detail Name 8~ Address Title PD BETHEA, WILLIAM R 401 LAKESHORE DRIVE IMMOKALEE FL 34142 Title VSTD BETHEA, MARGRETE F 401 LAKESHORE DRIVE IMMOKALEE FL 34142 Annual Reports Report Year Filed Date 2002 08/25/2002 Forms Help Entity Name Search ~ ~' `~ ~~ http://www.sunbiz. org/scripts/cordet.exe?action=DETFIL&incLdoc_number=P01000106222... 7/11 /2007 f ~~ SHERIFF' S RETURN - U . S . C;~;K'1'lr'l~ll N1AlL CASE N0: 20`07-04939 P COMMONWEALTH OF PENNSYLVANIA e COUNTY OF CUMBERLAND FROEHLICH ANN CLARK CHILTON ET VS. CRAIG CORPORATION INC R. Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,BETHEA WILLIAM R _, REGISTERED AGENT FOR SERVICE by United States Certified Mail postage prepaid; on the 24th day of August ,2007 at 1000:00 HOURS, at OF FLORIDA AGRONOMICS INC 401 LAKESHORE DRIVE IMMOKALEE, FL 34142 a true and attested copy of the attached COMPLAINT -QUIET TITLE Together with receipt card was signed by SIGNATURE ILLEGIBLE 00/00/0000 . Additional Comments: THERE WAS NO DATE ON THE GREEN CERTIFIED MAIL CARD. on Additional Comments Sheriff's Costs: Docketing 18.00 Service 6.45 Postage .75 Surcharge 10.00 .00 35.20 Paid by SAIDIS FLOWER & LINDSAY Sworn and Subscribed to before me this day of The returned So answ, e~-~ .. _ - .;,~ -.~ ~R. Thomas Kline Sheriff of Cumberland County on 09/12/2007 A.D. ~y~lr~`Ji T ~ , • ^ Corl7piete items 1, 2, and 3. Also complete si nature _ • item 4 if Restricted Delivery is desired. X (~ ~ ^ Agent • ^ Print your name and address on the reverse ' ~ ^ Addressee so that we can return the card to you. 8. Received b rioted Name) C. Date of Delivery ^ Attach this card to the back of the mailpiece, or on the front if space permits. D. Is delivery address diffen:nt from ftem 11 ^ Yes 1. Article Addressed to: Ii YES, enter delivery address below: ^ No Willia;n R..3ethea Registered agent for sere e of Florida Agronomics, In. 401 .Lakeshore Drive s.~rvicerype Immokalee, FL 34142 CertifledMail ^ Registered ^ Insured Mail 4. Restricted Delive 2'~ 7225 1822 0622 4619 1651 PS Form 3811, February 2004 Domestic Return Receipt ^ Express Mail ~Retum Receipt for Merchandise ^ C.O.D. ry7 (Extra Fee) ^ Yes 07-4939 civil 102595-02-M-1540 SHERIFF ~ S RETURN - U. S . CER'1'lr'lEll MAlL CASE Nb: 20'07-04939 P •'~OMI~ONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FROEHLICH ANN CLARK CHILTON ET VS. CRAIG CORPORATION INC R. Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,HOLDER HAROLD JR , REGISTERED AGENT FOR SERVICE by United States Certified Mail postage prepaid, on the 24th day of August ,2007 at 0000:00 HOURS, at OF CUTLER-FEDERAL CORP 608 RIVERA DRIVE TAMPA, FL 33606 a true and attested copy of the attached COMPLAINT -QUIET TITLE Together with The returned receipt card was signed by RETURNED TO SENDER oo/oo/oooo . Additional Comments: NOT DELIVERABLE AS ADDRESSED on UNABLE TO FORWARD. Additional Comments . Sheriff's Costs : So an~.~-rs : ~ .,~~ ~;~ r.~.~` Docketing 6.00 "~~ Service 6.W~5 ~ R. Thomas Kline Affidavit .00 Sheriff of Cumberland County Surcharge 10.00 Paid by SAIDIS FLOWER & LINDSAY Sworn and Subscribed to before me this day of on 09/12/2007 . A.D. .. ~ 1 house Square nnsylvania~~ ~ ' tia Paa`e~ (\ ~~~e~a~\e4$ ~ `Q ~o ~ b~e'~°~~ fat `eSS +~ t~,6~e ~°~ SQa~ Ch Harold Holder, Jr. `os°~ea~.e~` Q °~° ~ Registered ag or service of Cutler-Federal O ~e~Q~a~ et`OeJ~ `_ COf . ~ P a. ar "~ 608 Ri Drive QN°S~ of Q`°eQ~a°\e ae~ 55 Ta FL 33606 O( ~~o S~~ ~ ~~7 x ~ `~ ~` Qy5 ,.o~~~ Aso r~,. v" :,,.'~`~ :c. ~ RE~'URN ~ECEiPT ~EC~UESTED ©~ `~~u / :Q~etu~ ~eQ~e -. nQ°~ ,..~ ^ Complete items 1, 2, and 3. Also complete A. Signature item 4 if Restricted Delivery is desired. X ^ Agent ^ Print your name and address on the reverse ^ Addressee s0 that we Can return the card t0 yoU. B. Received by (Panted Name) C. Date of Delivery ^ Attach this card to the back of the mailpiece, or on the front if space permits. ', it 17 diff t f dd ^ Yes em eren rom D. Is delivery a ress 1. Article Addressed to: If YES, enter delivery address below: ^ No Harold Holder, Jr. ~ Registered. agent for sere' e of Cutler-Federal Cor p. 608 rivera Drive s. servicerype Tampa , FL 3 3 6 0 6 ~ , ~Certitted Mail ^ Express Man ^ Registered ~ietum Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Deliveryl(Eutra Fee) ~ ^ Yes 9 461 0 16'75 . 2 705 182 0 07-4939 civil PS Form 3811, February 2004 Domestic Return Receipt 102595-o2•M-1540 ( "' ,~ ,~. iti- SHERIFF' S RETURN - U. S . CER'I'IF'IEll MA1L Cl~.SJ ISO: 2d'07-04939 P •~COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FROEHLICH ANN CLARK CHILTON ET VS. CRAIG CORPORATION INC R. Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,KROUL MARJORIE _, REGISTERED AGENT FOR SERVICE by United States Certified Mail postage prepaid, on the 24th day of August ,2007 at 0000:00 HOURS, at OF FLORIDA AGRONOMICS INC 12329 MCGREGOR WOODS CIRCLE SW FORT MYERS, FL 33908 and attested copy of the attached COMPLAINT - with ET TITLE Together receipt card was signed by RETURNED TO SENDER oo/oo/oooo . Additional Comments: RETURNED TO SENDER. ATTEMPTED - NOT KNOWN. on Additional Comments . Sheriff's Costs: Docketing 6.00 Service 6.45 Affidavit .00 Surcharge 10.00 .00 22.45 r, _ ~..- So answ .~_ ,..,.- _ ~~ .~" '_ ~...! R. Thomas Kline Sheriff of Cumberland County Paid by SAIDIS FLOWER & LINDSAY Sworn and Subscribed to before me this day of , The returned a true on 09/12/2007 . A.D. . `;`.~* ,~ i r COUNT`f OF CUMBERLAND ' Office of The Sheriff <F '~ 1 Co ~, v `' '' Carlisle, n ~~ ~. i ~a ;' ~lr . ;~ J _. ~ 'J ~ agent for service of Florida Inc. ~egor Woods Circle, S.W. 33908 ~ RECEIPT RED RETUR y. ,~~., F~.J~, i~p} }G ~.{,Y9~ itflS.t~r-.ti^"4.u:~,>zF ~c-k _ ~.r r..:::~YYd.~~k ~i~iiiiiiui~iii~uui~iiNniiu ~oo, ~,=o oooz .6.9166a A ~ • ~ ^ Complete 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. ^ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Marjorie ~Kroul Registered agent for sere c of Florida Agronomics, In . 12329 McGregor ~~loods Circ Fort M ers FL 33908 A. Signature X ^ Agent ^ Addressee ' B. Received by (Printed Name) C. Date of Delivery D. is delivery address different from item 17 ^ Yes If YES, enter delivery address below: ^ No - y r „,Certified Mail ^ F~cpress Mail ^ Registered `~Retum Receipt for Merchandise ; ' 4 O Insured Mail ^ C.O.D. ~, 4. Restricted Delivery? (Extra Fee) ~ yes ~- 2' 7~~5 182Q ~~Q2 4619 1668 - civi ~ i ~~ PS form 3811, February 2004 Domestic Return Receipt io25s5-o2-M-lsao ~ t "' t '~." •"MTi~. ..rYY 1' N[, ±T^IT.rw/~„"~-~tvY,rr ~J[. r~vt ~~}~Uy+.~.nr..-r ~ h} ;. f_ ; ...~ r_-~ ~~~ r-:,~ C.7 ~~ t ~y r~i ~., -... ~.,,t ~;' '--t 4 i :. i'i »~- . , - ~' Ql ::~ JAN'18 2008 ANN CLARK CHILTON FROEHLICH, IN THE COURT OF COMMON PLEAS OF JOHN FRY CHILTON, III, JAMES CUMBERLAND COUNTY, PENNSYLVANIA ANDERSON CHILTON, ROBERT CIVIL ACTION -LAW WILSON CHILTON, JR. and MARY SANBORN CHILTON FOOTE ll°!3~ Plaintiffs, NO. 07- ~~~7`~ ' vs. CRAIG CORPORATION, INC., Defendant ACTION TO QUIET TITLE ORDER OF COURT SAIDIS, ~~OWER Sz LINDSAY 26 West High Streer Carlisle, PA AND NOW, this 2 3'~-' day of T-~ , 2008, upon consideration of the attached Motion, an Order is entered authorizing the service upon Defendant Craig Corporation, Inc. of the Complaint in this Action to Quiet the Title of certain land in the Borough of Carlisle, which was conveyed to Craig Corporation, Inc., by deed of March 15, 1960, and recorded in the Office of Recorder of Deeds of Cumberland County in Deed Book S, Voiume 19, Page 118, by publishing notice of this action one time in the Cumberland County Law Journal and one time in the Carlisle Evening Sentinel. BY THE COURT: ~~~ ~~°~ r ~1t~ l/ ~ l ,F~~-n ~ ~ I I rs~,~ ~Z ~~'(' ~~"~Z _ .;,-~ ~_~ ~-~_ .~ . _ .. ~~1:a I~ ANN CLARK CHILTON FROEHLICH, JOHN FRY CHILTON, III, JAMES ANDERSON CHILTON, ROBERT WILSON CHILTON, JR. and MARY SANBORN CHILTON FOOTE Plaintiffs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlI'Y, PENNSYLVANIA CIVIL ACTION -LAW NO. OT-4939 CIVIL tERM vs. . CRAIG CORPORATION, INC., . Defendant ACTION IN QUIET TI~'LE MOTION FOR FINAL ORDER QUIETING TITLE IN ACCORDANCE VNIITH Pa.R.C.P. X1066 AND NOW come Plaintiffs and aver the following: 1. Plaintiffs filed an Action to Quiet Title to the albove term and number on August 20, 2007. 2. The tract of land in question is a small remaining tract, which remains in the name of Craig Corporation, Inc., after the bulk of the land owned by the Craig Corporation, Inc., consisting of 38 lots, were sold to Hoake, Hooke & Lebo on January 21, 1986, by Deed recorded in Deed Book "I", Volume 31, Page 994. 3. The original land consists of approximately three building lots. ~IS,~ LINDSAY 26 West High Street Cazlisle, PA 4. After selling the bulk of the lots, Plaintiffs averred in their Complaint that Craig Corporation, Inc., made the decision to abandon any remaining property in Pennsylvania. 5. For a period in excess of 21 years, Robert INV. Chilton, established an adverse, open, notorious, continuous and uninterrupted possession of the land in •'t., question, paying all real estate taxes since May 3, 1986, and paying for all mowing and maintenance since that time. 6. By Deed dated July 15, 2005, Robert W. Chilton and Virginia C. Chilton, conveyed all of their right, title and interest in the property in question to their five children, the Plaintiffs herein. They have maintained adverse, open, notorious, continuous and uninterrupted possession of the subject land, including payment for taxes and maintenance. 7. Having been unable to otherwise serve Craigt Corporation, Inc. with a copy of the Complaint, Plaintiffs filed a Motion for Court Order permitting service by publication in accordance with Pa.R.C.P. §430. In that Motion, plaintiffs detailed all of their efforts to serve Craig Corporation, Inc., or entities which may be interpreted to be related to Craig Corporation, Inc. 8. On January 23, 2008, this Honorable Court entered an Order authorizing service upon Defendant Craig Corporation of the Complaint of the action to Quiet Title, by publishing Notice of this action one time in the Cumberland Law Journal and one time in The Sentinel. 9. Proof of publication in the Cumberland Law Journal on March 7, ~IS,~ LIlVDSAY 26 West High Street Cazlisle, PA 2008, is attached hereto as Exhibit "A". 10. Proof of publication in The Sentinel on March 5, 2008, is attached hereto as Exhibit "B". 11. Having accomplished the aforesaid Notice by Publication, Defendant Craig Corporation has been effectively served with this Action to Quiet Title. 2 12. A period in excess of 97 days having passed since the latter of the two dates of notice by publication, and Defendant not having filed an Answer, Plaintiff requests that the Court enter a final Order forever barring Craig Corporation, Inc. from asserting any right, lien, title or interest in the land inconsistent vu~ith the interest or claim of Plaintiffs, and confirming that Plaintiffs have good and marketable title of said land through adverse possession. SAIDIS, FLOWER & LINDSAY Attorneys for Plaintiffs h James D. Flower, Jr., Esquire 26 West High Strteet Carlisle, PA 17013 Phone: (717) 24$-6222 I.D. #27742 FLOWER 8z LINDSAY 26 West High Street Carlisle, PA 3 VERIFICATION I, JAMES A. CHILTON, hereby verify that the facts sent forth in the foregoing S~AIDIS, FIAWER Si LIlVDSAY 26 West High Street Carlisle, PA Motion are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Date: ~I ~° ~ ~ ~ C~.~, Ja es A. Chilton 4 4 U w U f- ca CL u +u CX fl! 4 O w Y U :tl tt a PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County avid State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952; been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz March 7, 2008 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Coyne, SWORN TO AND SUBSCRIBED before me this 7 day of March, 2008 ~J ~• Notary ;:-- ~HKia~ sEAt ~~£6''~kAti k COLLINS Notary Public. ' `"'`-~c BORO CUM9ERU#ND COUNTY c~rrur+ssion Expires Apr 28, 2010 CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law NO. 07-4939 CIVIL TERM ANN CLARK CHILTON FROEHLICH, JOHN FRY CHILTON, III, JAMES ANDERSON CHILTON, ROBERT WILSON CHILTON, JR. AND MARY SANBORN CHILTON FOOTE Plaintiffs, vs. CRAIG CORPORATION, INC., Defendant ACTION IN QUIET TITLE NOTICE TO THE DEFENDANT CRAIG COR- PORATION, INC. 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 far 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 CAN- NOTAFFORD ONE, GO TO OR TELE- PHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 The land that is subject to this adverse possession action is a small portion of the land conveyed by Clarence B. Cornman and Clara J. Cornman to Craig Corporation, Inc. by Deed dated March 15, 1960, and filed in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on March 15, 1960, at Deed Book "S"-19, Page 118. Said land consists of all of Lot No. 27, Block G of Meeting House Heights, all of Lot No. 2, Block G of Meeting House Heights, a very small portion of Lot No. 1, Block G of Meeting House Heights, and most of Lot No. 1, Block F of Meeting House Heights, all situate in North Middle- ton Township, Cumberland County, Pennsylvania, and more particularly described as follows: ALL THAT CERTAIN tract of land situate in the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described in accor- dance with a Final Subdivision Plan for Robert W. Chilton and Craig Corporation, dated June 12, 1980, as follows: TRACT NO. 1: BEGINNING at a point in the center of Meeting House Spring Road leading from Pennsylvania Route No. 641 to Meeting House Spring, which point is further described as being North 13 degrees 51 minutes West 312.54 feet from an iron pin marking the corner of lands of Burr Heights and lands previously conveyed to Craig Corporation; thence along the centerline of aforementioned Meeting House Spring Road North 13 degrees 51 minutes West a distance of 85.48 feet to a point at the comer of lands now or formerly of Robert W. Chilton; thence along same, North 76 degrees 09 Minutes East, a distance of 155.0 13 CUMBERLAND LAW JOURNAL feet to a point at the corner of Lot No. 2, Block F, Plan 5 of Meeting House Heights; thence along same South 13 degrees 51 minutes East, a distance of 85.48 feet to a point at the comer of Lot No. 6, Block F, Plan 2 of Meeting House Heights; thence along same South 76 degrees 09 minutes 00 seconds East 955.00 feet to a point, the Place of BEGINNING. TRACT NO. 2: BEGINNING at a point in the cen- ter of Meeting House Spring Road, leading from Pennsylvania Route No. 641 to Meeting House Spring, which point is further described as being North 13 degrees 51 minutes West 606.19 feet from an iron pin marking the comer of lands of Burr Heights and lands previously conveyed to Craig Corporation, and also at the corner of lands now or formerly of Robert W. Chilton. Thence along the centerline of the aforementioned Meeting House Spring Road North 13 degrees 51 minutes West, a distance of 96.27 feet to a point; thence North 76 degrees 9 minutes 00 seconds East, a distance of 146.64 feet to a point in line of Lot No. 26, Block G, Plan 5 of Meeting House Heights; thence along same, South 13 de- grees 51 minutes East, a distance of 100 feet to a point; thence along the aforesaid Lot No. 26, North 76 degrees 9 minutes 00 seconds East, a distance of 131.58 feet to a point; thence South 13 degrees 51 minutes 00 seconds East, a distance of 115 feet to a point; thence South 76 de- grees 09 minutes 00 seconds West, a distance of 112.50 feet to a point; thence North 08 degrees 21 minutes West along lands now or formerly of Robert W. Chilton, a distance of ap- proximately 93 feet to a point; thence along same, south 84 degrees 00 seconds East, a distance of 155.54 feet to a point at the centerline of Meeting House Spring Road, the Place of BEGINNING. TRACT NO. 1 AND NO. 2 BEING part of the same premises which Clarence E. Cornman and Clara J. Cornman by deed dated March 15, 1960 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 195, Page 118, granted and conveyed unto Craig Corporation, Inc. Said land having been abandoned by Craig Corporation, and possession and ownership of said land having been asserted by Robert W. Chilton, through payment of all tax bills at least from May 3, 1986, as well as possession and maintenance of the premises, has established adverse, open, notorious, continuous and uninterrupted possession of the land in question, and Plaintiffs, the heirs of Robert W. Chilton, will seek a final Order quieting title in the afore- describedreal property in their favor. Any representatives of Craig Corpora- tion, Inc. may contact the following for any further information. JAMES D. FLOWER, JR., ESQUIRE I.D. #27742 SAIDIS, FLOWER & LINDSAY Attorneys for Plaintiffs 26 West High Street Carlisle, PA 17013 Phone: (717) 243-6222 Mar. 7 14 z w z b U Q w r Z a c~ s 2 a w w c~ w a. a Q w J U V tli IZ ~j`~~~ ~ 1 "t:S' PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Erica Pefierson, Classified Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice oz publication attached hereto is exactly the same as was printed and published un the regular editions and issues of THE SENTINEL on the following day(s): Mazch 5, 200$ COPY OF NOTICE OF PUBLICATION ANN CLAgKf~ItTT?N FZi~ILICH, tN THE COURT OF COYYON PIJfiA8 JONNlR1FJC~7~. Nf, OF CU1M!lRLAND COUNTY. JAONpILT01t, PENNSYt.YANIA TON, d : .CIVIL ACTION -LAW ~~ "~"tylihrtlRa, t+10. g7~fID0 CfYll TtRtY :~ ` ~ 3~ _ ~.tS ~' ' Y~~ - ' CRAKI CORP~ATiON, NIC., Datbrtdranl ACTION IN OtJIlT TITLE . i '~~~', TO`T~D~IOAI~' CNAIQ, CORPORATION, MC. YO{I ~N~ff~1lIED Ml COURT. lfYou iv~tt to ddarrd aQeirlBR tlN alaima Bet forMrir~tl~ iq)iDD6p,ps0e9. You must twice aldlorl wllfdn twenbr (20) days alter thle Corrrpl9Yifand Naioa.are served, try enlerkg a wAUen-sppeoarras pareonaly a bl .aaargey and ting in wdltng w>~ 1116 Cowt your deferr98a of a6~amone to >M olaYae set for!!t ager~et You. Yau are +r6crrred that 11 you f6A to do sa the Casa may proceild rrlCfou! you ent! a Judgement may bs aMereQ agaYat you hY file Court wi~out further natiCe for arty money cfatmsd in the Comp{alnt of for anyolher claim or renal regrre6ted by fhe PlelnYlf. Yar may lose money ar properly ortithsr importarh to y,ou. - , y rOU 8HOULD TAKE TNI6 PAPER TO YOUR LAWYER ATONCE. IF 1/0U DO NOT.ilAtR; A l:AW1rER Qp CANNOT A~ORD ONE, GO TO OR TELlPItONE TH~Olt-lCE EET frQRTtI BELOW TO FlND qUi WHlA~ YOU CAN QtT :.; LFQAE NELP." - Affiant further deposes that he/'she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing mtatement as to time, place and character of p blication are e. r Sworn to and subscribed before me this 12tt~ day of Tune, 2008. CUMBERLAND COUNTY BAR ASSOCIATION 3>t SOUTH BEDFdRO BTAEET ~ ~ ~7~/l+t/L(,11 ~ ~ Cr(.lJ/LJ~ CARLIBt! PA 1TOtb m~~,ab Notary Pub c My commission expires: !~ JS JOd9 WOY1IMAt tiEAt ~owwwlr~wur ~Y ruu~e I;,~lN~ ~OR011CH, CIIIrrtMOCOt~11Y Mhr Corlrltltlfart ~~ JUR ~. ° ~ '~i ~ ' r ~ , r ' i~ t.~"r r 1~ .~,~ `~ ,".7 ~~ `` ::~' ` ~ `3 ~ -... JUN 1 62008 ANN CLARK CHILTON FROEHLICH, JOHN FRY CHILTON, III, JAMES ANDERSON CHILTON, ROBERT WILSON CHILTON, JR. and MARY SANBORN CHILTON FOOTE Plaintiffs, vs. CRAIG CORPORATION, INC., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4939 CIVIL TERM ACTION IN QUIET TITLE ORDER OF COURT SAIDIS, >FZOWER Sz I~NDSAY 26 West High Street Carlisle, PA AND NOW, this /`~" day, of _, 2008, upon consideration of Plaintiffs' Motion for Final Order in this Action to Quiet Title in Accordance With Pa. R.C.P. §1066., IT IS HEREBY ORDERED that Defendant CRAIG CORPORATION, INC. is hereby forever barred from asserting any right, lien, title or interest in the land in question, and that Plaintiffs ANN CLARK CHILTON FROEHLICH, JOHN FRY CHILTON, III, JAMES ANDERSON CHILTON, ROBERT WILSON CHILTON, JR., and MARY SANBORN CHILTON FOOTE, are Ordered and Decreed to have good and marketable title of the land in question situate in North Middleton Township, Cumberland County, Pennsylvania, by virtue of the principle of adverse possession. Attached to this Order is the legal description of said property, as set forth in Exhibit "A" of Plaintiffs' Complaint, as well as the Final Subdivision Plan for Robert W. Chilton and Craig Corporation, dated June 12, 1980, and March 25, 1981, on which the boundaries of said land are marked. BY THE COURT: ./J . /1 J. ~~ , ~,~ C7F THE F ',"~ `~` ~`"::"~~a`l 20~~ J~1i~ E ~ ~ l ! ~ Q;~ cup f _ av .«'Ui'~C f~ ~:,M.~°,~ ti. , ~.,f, 4 4t ~ ~..~t i '. '~ f.'``. ~o y'"a` ~- ~~r41 ~ A ~ ~ .31~, Jam. AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) ss. The undersigned is a Registered Surveyor and performed a survey for the FLOWER 8z LIlVDSAY .~:uw 2G West High Street Carlisle, PA Preliminary/Final Subdivision Plan for the Chilton property, dated December 4, 2008. Attached is a true and correct copy of the accurate legal description generated from that subdivision plan. I am familiar with the real estate which is the subject of this action to quiet title and reviewed the description set forth in the Deed to the present owners from Robert W. Chilton, set forth in Deed Book 268, page 1643. The legal description as described by my survey is a legal description of the same land described in the aforesaid Deed, but is more accurate, having the benefit of modern scientific surveying technology. Date: /~ ~, 2009 f~~ f' Willia John Grow. Registered SuA~i Sworn and subscribed to before me this r day of ~ 7~p ~~_~~ , 2009. ~ NflLi.',AM .ANN GROtN ~ BARBARA E, STEEL, Not~- Public Cartisk Borg Cambal>tnd Coumy, PA My Commission Ex ires Jane 7, 3011 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land, situate in the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a pin in concrete in the eastern right of way line of Meeting FLOWER ~ LINDSAY 26 West High Street Cazlisle, PA House Springs Road and at the corner of lands now or formerly of Peter A. Biasucci; thence along the eastern right of way line of Meeting House Springs Road, North 15 degrees 1 minute 11 seconds West a distance of 389.73 feet to a bent pin at the corner of lands now or formerly of Thomas J. and Jan L. Arminio; thence along line of lands now or formerly of Thomas J. and Jan L. Arminio, North 74 degrees 54 minutes 49 seconds East, a distance of 116.64 feet to a pin in line of other lands now or formerly of Thomas J. and Jan L. Arminio; thence along line of lands now or formerly of Thomas J. and Jan L. Arminio, South 15 degrees 1 minute 11 seconds East, a distance or 100.00 feet to a point; thence along line of lands now or formerly of Thomas J. and Jan L. Arminio, North 74 degrees 58 minutes 49 seconds East, a distance of 131.58 feet to a point in the western right of way line of Douglas Court; thence along the right of way line of Douglas Court, South 15 degrees 1 minute 11 seconds East, a distance of 115.00 feet to a point at the intersection of the right of way lines of Douglas Court and Armstrong Road; thence along the right of way line of Armstrong Road, South 74 degrees 58 minutes 49 seconds West, a distance of 122.50 feet to a point; thence along the western end line of Armstrong Road, and lands now or formerly of Brigetta A. and Thomas A. Guyer, Jr., South 15 degrees 1 ~~r'_~ ""~ ~ ~ ~' i,~,t~°. _. ~ ,, ANN CLARK CHILTON FROEHLICH, JOHN FRY CHILTON, III, JAMES ANDERSON CHILTON, ROBERT WILSON CHILTON, JR. and MARY SANBORN CHILTON FOOTE Plaintiffs, vs. CRAIG CORPORATION, INC., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4939 CIVIL TERM ACTION IN QUIET TITLE MOTION FOR AMENDED FINAL ORDER QUIETING TITLE IN ACCORDANCE VWITH Pa.R.C.P. §1066 AND NOW come Plaintiffs and aver the following: 1. Plaintiffs filed an Action to Quiet Title to the above term and number on August 20, 2007. 2. The tract of land in question is a small remaining tract, which FLOWER ~ LINDSAY 26 West High Street Cazlisle, PA remains in the name of Craig Corporation, Inc., after the bulk of the land owned by the Craig Corporation, Inc., consisting of 38 lots, were sold to Hooke, Hooke & Lebo on January 21, 1986, by Deed recorded in Deed Book "I", Volume 31, Page 994. 3. The residual land is of sufficient size to consist of approximately three or four, building lots. 4. As Plaintiffs averred in their Complaint, after selling the bulk of their lots, Craig Corporation, Inc., made the decision to abandon any remaining property in Pennsylvania. 5. For a period in excess of 21 years, Robert W. Chilton, established an adverse, open, notorious, continuous and uninterrupted possession of the land in question, paying all real estate taxes since May 3, 1986, and paying for all mowing and maintenance since that time. 6. By Deed dated July 15, 2005, Robert W. Chilton and Virginia C. Chilton, conveyed all of their right, title and interest in the property in question to their five children, the Plaintiffs herein. They have maintained adverse, open, notorious, continuous and uninterrupted possession of the subject land, including payment for taxes and maintenance. 7. Having been unable to otherwise serve Craig Corporation, Inc. with a copy of the Complaint, Plaintiff s filed a Motion for Court Order permitting service by publication in accordance with Pa.R.C.P. §430. In that Motion, Plaintiffs detailed all of their efforts to serve Craig Corporation, Inc., or entities which may be interpreted to be related to Craig Corporation, Inc. 8. On January 23, 2008, this Honorable Court entered an Order ~ SAIDIS, FIAWER Sz LIlVDSAY 26 West High Street Cazlisle, PA authorizing service upon Defendant Craig Corporation of the Complaint of the action to Quiet Title, by publishing Notice of this action one time in the Cumberland Law Journal and one time in The Carlisle Evening Sentinel. 9. Proof of publication in the Cumberland Law Journal on March 7, 2008, is filed of record in this action. 10. Proof of publication in The Sentinel on March 5, 2008, is filed of record in this action. 2 1 i 11. Having accomplished the aforesaid Notice by Publication, Defendant Craig Corporation has been effectively served with this Action to Quiet Title. 12. A period in excess of 97 days having then passed since the latter of the two dates of notice by publication, and Defendant not having filed an Answer, Plaintiff requested that the Court enter a final Order forever barring Craig Corporation, Inc. from asserting any right, lien, title or interest in the land inconsistent with the interest or claim of Plaintiffs, and confirming that Plaintiffs have good and marketable title of said land through adverse possession, and the Court entered a Final Order to that effect on June 19, 2008. 13. The description attached to that Order was found to have a typographical error. In addition, since that Order was entered, a survey of the property was performed consistent with modern survey methods, and an Affidavit of the Registered Surveyor, William John Grow, is attached hereto, to which the legal description as generated by that survey is attached. 14. The owners of the real estate which is the subject of the Action to Quiet Title, have a preliminary Agreement of Sale with a prospective buyer. The typographical error on the legal description referred to in the Final Order of Court, and the variation of the legal description of the Deed from that of the modern scientific legal description attached to the Affidavit of the Surveyor, William John Grow, have become an SAIDIS, ~D RAyg ~ issue between buyer and seller, which both wish to have resolved. The Defendant in this 26 West High sneer Carlisle, PA action, CRAIG CORPORATION, INC., is in no way prejudiced by the proposed Amended Order of Court, having been served by publication in accordance with the Order of this Court, and having failed to file an Answer to the Complaint. The relief 3 requested will serve to benefit Plaintiffs, their prospective buyer, and to promote a cleaner title for any subsequent purchasers. WHEREFORE, Plaintiff requests that the Court enter the attached Amended Final Order in Accordance with Pa.R.C.P. §1066. SAIDIS, FLOWER & LINDSAY Attorneys for Plaintiffs By, James D. Flov/er, yf., Esquire f J 26 West High Street V Carlisle, PA 17013 Phone: (717) 243-6222 I.D. #27742 FLOWER ~ LINDSAY 26 West High Street Cazlisle, PA 4 VERIFICATION I, JAMES A. CHILTON, hereby verify that the facts set forth in the foregoing SAIDIS, RAWER Si LINDSAY 26 West High Street Carlisle, PA Motion are true and correct to the best of my knowledge, information and belief. understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Date: q~l ~ ~09 Ja s A. Chilton 5 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) ss. The undersigned is a Registered Surveyor and performed a survey for the SAIDIS, E~O~~VER Sz LINDSAY ~r~o~xs•,er•uw 26 West High Stree[ Carlisle, PA Preliminary/Final Subdivision Plan for the Chilton property, dated December 4, 2008. Attached is a true and correct copy of the accurate legal description generated from that subdivision plan. I am familiar with the real estate which is the subject of this action to quiet title and reviewed the description set forth in the Deed to the present owners from Robert W. Chilton, set forth in Deed Book 268, page 1643. The legal description as described by my survey is a legal description of the same land described in the aforesaid Deed, but is more accurate, having the benefit of modern scientific surveying technology. Date: ~~ ~, 2009 ,.~~~~~ ~~S Willia John Graw. ,~ Registered Su w,.._'.. r ts~~s~ ...owu. 41l1-1'1~l~ .ti~:3h G~i~tN Sworn and subscribed to before me this I ~ ~ •~'""~'''~~ ei)Onr,DE ~P. ~"'~,~ y f, v ~~' , :; day of 7~~~.~~ , 2009. -~~1 ~ ~ Q~ ~~ ~-~~~ A BARBARA E. STEEL, Notary Public Carlisle Boro, Cumberland County, PA My Commission Ex ices June 7, 20I 1 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land, situate in the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a pin in concrete in the eastern right of way line of Meeting SAIDIS, FIAWER ~ LINDSAY nn~ortr~vs•,v uw 26 West High Street Carlisle, PA House Springs Road and at the corner of lands now or formerly of Peter A. Biasucci; thence along the eastern right of way line of Meeting House Springs Road, North 15 degrees 1 minute 11 seconds West a distance of 389.73 feet to a bent pin at the corner of lands now or formerly of Thomas J. and Jan L. Arminio; thence along line of lands now or formerly of Thomas J. and Jan L. Arminio, North 74 degrees 54 minutes 49 seconds East, a distance of 116.64 feet to a pin in line of other lands now or formerly of Thomas J. and Jan L. Arminio; thence along line of lands now or formerly of Thomas J. and Jan L. Arminio, South 15 degrees 1 minute 11 seconds East, a distance or 100.00 feet to a point; thence along line of lands now or formerly of Thomas J. and Jan L. Arminio, North 74 degrees 58 minutes 49 seconds East, a distance of 131.58 feet to a point in the western right of way line of Douglas Court; thence along the right of way line of Douglas Court, South 15 degrees 1 minute 11 seconds East, a distance of 115.00 feet to a point at the intersection of the right of way lines of Douglas Court and Armstrong Road; thence along the right of way line of Armstrong Road, South 74 degrees 58 minutes 49 seconds West, a distance of 122.50 feet to a point; thence along the western end line of Armstrong Road, and lands now or formerly of Brigetta A. and Thomas A. Guyer, Jr., South 15 degrees 1 minute 11 seconds East a distance of 175.00 feet to a pin; thence along line of lands now or formerly of Peter A. Biasucci, South 75 degrees 19 minutes 49 seconds West, a distance of 125.72 feet to a pin in concrete in the eastern right of way line of Meeting House Springs Road, the place of BEGINNING. SAIDIS, FLOWER Sz LINDSAY ~:uw 26 West High Street Carlisle, PA 1. C,U(;' _ f~,_f , ._ ~'.. u ANN CLARK CHILTON FROEHLICH, JOHN FRY CHILTON, III, JAMES ANDERSON CHILTON, ROBERT WILSON CHILTON, JR. and MARY SANBORN CHILTON FOOTS Plaintiffs, -~~-~ CRAIG CORPORATION, INC., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLWANIA CIVIL ACTION -LAW NO. 07-4939 CIVIL TERM ACTION IN QUIET TITLE AMENDED ORDER OF COURT AND NOW, this SAIDIS, F7AWER SZ LjNDSAY 26 West High Street Carlisle, PA a s' day of .S'so i~c^- b~ 2009, 'I upon consideration of Plaintiffs' Motion for Final Order in this Action to Quiet Title in Accordance With Pa.R.C.P. §1066, IT IS HEREBY ORDERED that Defendant CRAIG ' CORPORATION, INC. is hereby forever barred from asserting any right, lien, title or ';, interest in the land in question, and that Plaintiffs ANN CLARK CHILTON FROEHLICH, JOHN FRY CHILTON, III, JAMES ANDERSON CHILTON, ROBERT WILSON CHILTON, JR., and MARY SANBORN CHILTON FOOTS, are Ordered and Decreed to have good and marketable title of the land in question situate in the Borough of Carlisle, Cumberland County, Pennsylvania, by virtue of the principle of adverse possession. Attached to this Order is the Affidavit of Registered Surveyor, William John Grow, and the legal description of the property in question as generated from his proposed but not approved Preliminary/Final Subdivision Plan for the Chilton property dated December 4, 2008, on which the boundaries of said land are marked. BY THE COURT: ~~ J. I ~~L~C.1_...:~ C I;. 2004 SEP 2~ C'1'~ ~ ~ ~~ `~;~~ Y 1.~' k:~ ti...l ir~~f"'~i q~:l~ 4~1~.S~vQ - ~o Y that ~~L R~ J. ~'1~~,Jz ~~