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IN RE: ESTATE OF T. A. ::
MILLER, LATE OF THE BOROUGH . .
OF CARLISLE, CUMBERLAND COUNTY::
PENNSYLVANIA ..
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
NO. 21-78-314
ORDER OF COURT
AND NOW, to wit, this ;??~ of ~ ,1980,
upon presentation of the foregoing petition, a rule is issued
upon Bethel A.M.E. Zion Church, Shiloh Baptist Church, West
Street A.M.E. Zion Church, and the Township of North Middleton
to show cause why said private sale of decedent's specifically
devised real estate should not be approved by the Court.
Service to be made upon counsel of record for Bethel A.M.E.
Zion Church, Shiloh Baptist Church, West Street A.M.E. Zion Church,
and the Township of North Middleton, returnable twenty (20) days
after the service hereof.
By the Court,
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IN RE: ESTATE OF T. A.
MILLER, LATE OF THE BOROUGH
OF CARLISLE, CUMBERLAND COUNTY::
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
NO. 21-78-314
PETITION TO CONFIRM PRIVATE SALE OF REAL ESTATE
TO THE HONORABLE, THE JUDGES OF SAID COURT:
The Petition of Beatrice M. Claus respectfully represents:
1. That she is the executrix of the estate of T. A. Miller
and also the surviving spouse electing to take against the will
of said T. A. Miller.
2. That by the terms of his will, T. A. Miller specifically
devised a parcel of real property in North Middleton Township con-
taining seven (7) acres more or less unto Bethel A.M.E. Zion Church,
Shiloh Baptist Church and West Street A.M.E. Zion Church as tenants
in common subject to certain conditions, and upon the failure
thereof, to the Township of North Middleton for certain purposes
and subject to certain conditions.
3. On October 11, 1978, pursuant to a petition by your
petitioner, a citation was directed to the devisees of said real
estate to appear for a hearing on the question of sale of said
premises divested of the conditions imposed by decedent's will.
4. On October 31, 1978, pursuant to petition by said
devisees averring that Beatrice M. Claus is not the surviving
widow of T. A. Miller the decedent, a rule was issued upon said
Beatrice M. Claus to show cause why her election to take against
the will of said T. A. Miller should not be vacated.
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s. After presentation of the evidence in support of
petitioner's position that she is in fact the widow of T. A. Miller,
the said specific devisees, by their attorneys, informally agreed
that Beatrice M. Claus was the surviving widow of T. A. Miller,
that her election against his will was valid and effective, that
said parcel of land could not be divided between the widow and
the specific devisees, that the conditions set forth in decedent's
will were impractical and that said parcel should be exposed to
public sale with the net proceeds divided in equal shares, one-half
to the surviving spouse and one-half to the specific devisees, but
although a stipulation of counsel to that effect was prepared in
August 1979, it has never been executed on behalf of the respective
parties.
6. That because said property had suffered fire damage of
approximately $1000, the fire insurance coverage was cancelled,
and the executrix was forced to obtain coverage under the assigned
risk plan of the Commonwealth of Pennsylvania.
7. That because of the insurance problems and the approaching
winter weather, said executrix offered said premises at a public
sale attended by attorneys for the specific devisees on October 20,
1979, at which time the only bid received was $20,000, which was
deemed insufficient.
8. The fire and extended insurance covered by the assigned
risk plan was cancelled effective December 19, 1979, for the
reason that said premises did not meet reasonable underwriting
standards.
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9. Because of the lack of insurance coverage, the onset
of freezing weather with possible damage to water system, supplying
water to mobile homes previously part of the estate, but sold at
public sale and renting space from the estate, and the possibility
of vandalism, your petitioner has entered into an agreement of sale
for said premises at the price of $25,000, a copy of said agreement
being attached hereto as Exhibit "A", and subject to the approval
of your Honorable Court.
10. That prior to execution of said agreement, your
petitioner had offered to sell to the specific devisees her
undivided one-half interest in said premises for one-half of the
best price bid at that time, but said offer was never accepted.
11. That your petitioner believes that all of the objections
to the sale of said premises have been satisfactorily removed, and
that it is in the best interests of all parties that said premises
be now sold under the terms and conditions set forth in the annexed
agreement of sale, and that your Honorable Court therefore approve
said sale.
WHEREFORE, your petitioner prays your Honorable Court for
the issuance of a rule upon Bethel A.M.E. Zion Church, Shiloh Baptist
Church, West Street A.M.E. Zion Church, and the Township of North
Middleton to show cause why said sale should not be approved by
your Honorable Court.
And she will ever pray, etc.
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ttorney or Petltloner
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COMMONWEAL TH OF PI:UNSY1YAU-fA
COQ.6~f\A.C
COUNTY OF CBHIHiiR1AN-D
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Beatrice M. Claus, being duly sworn according to law,
deposes and says that the facts set forth in the foregoing
Petition are true and correct to the best of her knowledgment,
information and belief.
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v Beatrice M. Claus
Sworn to and subscribed
be ore me this r:::1o day
o :-1980.
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AGREEMENT OF SALE
THIS AGREEMENT made and entered into this
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{ S day of
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( Jf the Estate of T. A. Miller, deceased,
, 19 P0, by and between BEATRICE M. CLAUS, Executrix
(whether singular or
plural hereinafter called SELLER)
A
N
D
KEITH T. M(~LEN and KEVIN L. WJLLEN, of R. D. 7, Box 203, Carlisle,
Pennsylvania (whether singular or plural hereinafter called BUYER)
WITNESSETH:
(1) The Seller agrees to sell and convey to the Buyer and
the Buyer agrees to purchase and accept the conveyance of all that
certain tract of land with any improvements thereon erected, situate
in North Middleton Township, Cumberland County, Pennsylvania,
containing seven (7) acres more or less, and being improved with a
framed dwelling house and other outbuildings known as Tamec Farm
and more particularly described in the Deed recorded in Deed Book "C",
Volume 19, Page 497.
(2) ,The Buyer agrees to pay to the Seller for the said real
estate the sum of twenty-five thousand ($25,000.00) payable as
follows: One hundred ($100.00) dollars on the signing of this
agreement, receipt of which is hereby acknowledged, and the
EXHIBIT "A"
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balance of twenty-four thousand nine hundred ($24,900.00) dollars
at the time of settlement. This agreement is contingent upon Buyer
obtaining financing.
(3) Settlement shall be made on or before the thirtieth (30)
day of March 1980 at which time the Seller shall tender to the
Buyer a properly drawn and executed deed of special warranty
conveying to the Buyer a good and marketable title in fee simple,
free and clear 'of all liens, charges, easements, and encumbrances,
except those visible and/or of record and Buyer shall pay to Seller
the balalnce of the purchase price.
(4) The terminal date-for obtaining approval of this sale
by the Court and/or the churches involved in said estate is March
30, 1980. If such approval is not obtained the hand money shall
be returned and Buyer may declare this agreement null and void at
his option.
(5) Mobile homes presently located on the premises have been
previously sold as personal property and are excluded from this
sale. Seller agrees to have said trailers removed from premises
at Seller's expense before settlement as herein above provided.
(6) Buyer shall be entitled to possession upon execution of
this agreement.
(7) Current real estate taxes shall be apportioned to the
date of settlement.
(8) All real estate transfer taxes shall be divided equally
between the Seller and the Buyer.
(9) Risk of loss by fire or other insurable hazard shall be
borne by the Buyer.
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(10) Water rent, sewage rent, rent, etc., shall be apportioned
to the date of settlement.
(11) Access to said premises is by road leading northwardly
from Creek Road 13 feet wide and 37.4 perches long as established
in deed recorded in Deed Book "B", Volume 4, Page 537, and referred
to in Deed Book "I", Volume 14, Page 442. Acpo:t.tion of the right
of -way extending from the bridge over Alexander Run to said premises
is established either by prescriptive user or grant of easement.
(12) Seller agrees to place Four thousand ($~,OOO.OO) dollars
in escrow with James Humer, Esquire to cover the cost of imp~ove-
ments to the premises by Buyer from the date of this. agreement until
settlement. Seller specifically agrees and hereby authorizes
James Humer, Esquire to reimburse Buyer for said improvements
including the cost of labor in the event that Buyer does not obtain
financing, Seller refuses to settle or Seller does not obtain
approval of the sale.
(13) .In the event that the Buyer shall fail ov refuse to
make settlement in accordance with the terms of this agreement,
the Seller, at his option, may declare this agreement null and void
and retain the hand money previously paid as liquidated damages
which shall not exceed ten (10%) percent of the purchase price;
bring suit for damages for breach of contract or bring suit for
specific performance.
(14) .Iri the event that the Seller shall fail Or refuse to
make settlement in accordance with the terms of this agreement,
the Buyer, at his option, may declare this agreement null and void
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and the hand money previously paid shall be returned forthwith
to the Buyer together with his costs of the title search, survey,
appraisal fees and costs of any improvements including labor; bring
suit against the Seller for breach of contract, or bring suit for
specific pe~formance.
(15) This agreement shall hot be assigned without the written
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consent of Seller.
(16) This agreement shall bind the parties hereto, their
heirs, executors and administrators.
IN WITNESS WHEREOF, the parties hereto have hereunto set their
hands and seals, the day and year
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first above written.
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Beatrice M. Claus, Executrix
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Kevin E. Mullen
(SEAL)
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Wi tness
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Keit T.Mullen
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STATE OF~ FLRIDA
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COUNTY OF .
On this the
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perSOnall:a:p::~~:::~E'
1981f, before
M. CLAUS, of the
me a Notary Public,
State of Florida, known to me or (satisfactorily proven) to be
the person described in the foregoing instrument, and acknowledged
that she executed the same in the capacity therein stated and for
the purposes therein contained.
IN WITHESS WHEREOF, I hereunto set my hand and seal.
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~t:'~ta . tiblic .
otary Public. State of Fl 'd ..
My Commission E' .Il a at Largl
baded ,xp"es <:A_t 27
. Iy Iomo,;.." fi,o & ;:;. . 1980
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CERTIFICATE OF SERVICE
I, James R. Humer, Esquire, Attorney for Petitioner,
certify that I served a copy of the within Petition and Order
of Court by mailing the same by ordinary mail, u.S. postage
3()
prepaid at Carlisle, Pennsylvania, on January ~, 1980,
addressed as follows:
Harold S. Irwin, Jr., Esquire
44 S. Hanover St.
Carlisle, PA 17013 and
John H. Broujos, Esq.
4 N. Hanover St.
Carlisle, PA 17013
Attorneys for Shiloh Baptist Church
West Street A.M.E. Zion Church
Bethel A.M.E. Zion Church and
James D. Bogar, Esq.
23 W. Main St.
Shiremanstown, PA 17011
Attorney for North Middleton Township
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s R. Humer
orney for Petitioner