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HomeMy WebLinkAbout08-2509Johnson, Duffle, Stewart & Weidner By: Mark C. Duffie, Esquire I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 mcd@jdsw.com Attorneys for Plaintiff SECURITY SAVINGS SYSTEMS, INC. IN THE COURT OF COMMON PLEAS Ninth and Market Streets CUMBERLAND COUNTY, PENNSYLVANIA New Cumberland, PA 17070, Plaintiff NO. V. : CIVIL ACTION - LAW EMMA E. LEIB, her heirs and assigns, : JURY TRIAL DEMANDED NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mcis adelante en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dfas despues de la notificaci6n de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aquf en contra suya. Se le advierte de que si usted falla de tomar acci6n como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamaci6n o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 I Johnson, Duffle, Stewart & Weidner By: Mark C. Duffie, Esquire I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 mcd@jdsw.com Attorneys for Plaintiff SECURITY SAVINGS SYSTEMS, INC. IN THE COURT OF COMMON PLEAS Ninth and Market Streets CUMBERLAND COUNTY, PENNSYLVANIA New Cumberland, PA 17070, Plaintiff NO. -4 cf*- v. CIVIL ACTION - LAW EMMA E. LEIB, her heirs and assigns, JURY TRIAL DEMANDED COMPLAINT TO QUIET TITLE AND NOW, comes the Plaintiff, Security Savings Systems, Inc., by and through its attorneys, Johnson Duffie, and hereby brings this action to Quiet Title against Defendant, Emma E. Leib, her heirs and assigns, and in support thereof avers as follows: 1. Plaintiff, Security Savings Systems, Inc., is a Pennsylvania corporation with a principal place of business and registered address at Ninth and Market Streets, New Cumberland, Pennsylvania 17070. 2. Defendant, Emma L. Leib, is now believed to be deceased. The identity and whereabouts of any heirs or assigns of Emma L. Leib are unknown. 3. Plaintiff is in actual possession of the following real estate situate in Cumberland County, Pennsylvania, and more fully described as follows: ALL THAT CERTAIN piece or parcel of land situate in the Borough of New Cumberland, Cumberland County, Commonwealth of Pennsylvania, and designated and known and numbered as Lot 248 in a certain plan of lots called "Elkwood" surveyed for the Wood, Harmon Real Estate Association by George Roberts, Civil Engineer, which is duly filed among the records in the office of the Clerk of Courts for the Recorder for Cumberland County aforesaid in Deed Book "M", Volume 5, Page 498. • Said property was transferred by Esther F. Leib to Frank R. Leib, by deed dated May 4, 1910 and recorded on May 6, 1910 in the Office of the Recorder of Deeds in the Court of Common Please of Cumberland County in Deed Book 7-P, Page 253. Frank R. Leib died on December 28, 1919 and devised said property to his wife, Defendant, Emma E. Leib by Deed recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 15-U, Page 3. 4. The Defendant, Emma E. Leib died on April 27, 1927 and directed her Co- Executrixes Esther F. Leib and Marion C. Leib, to sell and dispose of her real estate. The Last Will and Testament of Emma E. Leib is located in the Court of Common Pleas of Lancaster County in Will Book 34, Page 142. 5. The Last Will and Testament of Emma E. Leib directs her Co-Executrixes, ,Esther F. Leib and Marion C. Leib, to sell and divide said property in five (5) equal parts devising the same equally to her daughters, Esther F. Leib, Sarah Leib Ludinger, Helen Leib McCardless and Marion C. Leib. The fifth (5th) equal part was to be given to Helen Elizabeth Leib and Frank R. Leib, second children of her deceased son, Charles F. Leib. 6. The inventory with the estate of Emma E. Leib does not reference the subject property. 7. Plaintiff has been, by itself, in the actual, exclusive, continuous, visible, notorious, and adverse possession of the property above described continuously for in excess of twenty- one (21) years prior to the filing of this Complaint, claiming to his own the same in fee against the world. 8. The property is not taxed as it does not exist on the tax maps in the Cumberland County Tax Assessor's Office, and therefore, there has not been any tax paid on the property for many years. 9. The Tax Assessor's Office, in and for Cumberland County and the Borough of New Cumberland, indicate that this property is "no man's land" and neither has any record of an owner to the property. 10. The undersigned, on behalf of the Plaintiff, performed a title abstract to determine that the Defendant was the last known party of record in the Recorder of Deeds Office for said property. 11. The Plaintiff, by and through its undersigned counsel, has been unable to identify or locate the Defendant or any of the heirs or assigns of Defendant. WHEREFORE, Plaintiff requests that this Court order Defendant, his heirs or assigns, to bring an action in ejectment within thirty (30) days from the entry of the Order pursuant to Pa.R.C.P. 1066(b)(1), or be forever barred from asserting any right, claim, lien, title, or interest to said parcel, in consistent with the interest of Plaintiff. Respectfully submitted, JOHNSON DUFFIE STEWART & WEIDNER L By: Mark C. uffie 326745 VERIFICATION The undersigned confirms that the facts set forth in the foregoing Complaint are true and correct. This verification is made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsifications to authorities. SECURITY SAVINGS SYSTEMS, INC. Frank A. Mosher, President Dated: 'I I -/ 16 F 326745 CO lz> .. v ? . (.?1 ..? 1 ap ?- F? 1 C??r 1 Johnson, Duffle, Stewart & Weidner By: Mark C. Duffie, Esquire I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 mcd@jdsw.com Attorneys for Plaintiff SECURITY SAVINGS SYSTEMS, INC. IN THE COURT OF COMMON PLEAS Ninth and Market Streets CUMBERLAND COUNTY, PENNSYLVANIA New Cumberland, PA 17070, Plaintiff V. EMMA E. LEIB, her heirs and assigns, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED AFFIDAVIT PURSUANT TO Pa.R.C.P. 430 I, Mark C. Duffie, of Johnson, Duffie, Stewart & Weidner, counsel for Plaintiff, Security Savings Systems, Inc., being duly sworn do depose and say as follows: The following are measures taken by the undersigned to locate the Defendant, Emma L. Leib, her heirs and/or assigns. 1. Affiant has viewed the property which is an unimproved parcel referenced in the underlying Complaint and the Defendant, his heirs and assigns have evidenced no indica of ownership for a period of time exceeding twenty-one (21) years. 2. Affiant searched the Register of Wills Office in Cumberland County and found an estate filing for Emma E. Leib. 3. Affiant searched the telephone directory in the greater Harrisburg area and did not find a listing for a Emma E. Leib as in all likelihood she is deceased. 4. Affiant searched the Internet White Pages for a Emma E. Leib in the Commonwealth of Pennsylvania and discovered no listing for the same. 5. The husband of Emma E. Leib, Frank R. Leib, died on December 28, 1919. 6. Affiant has searched the internet and the white pages in South Central Pennsylvania for any of the heirs listed in the Complaint to Quiet Title and have found none. 7. The identities and addresses of any other heirs of Emma E. Leib are unknown. JOHNSON DUFFIE STEWART &WEIDNER Date: 71f ti? Mark C. :326721 ' r; C co i .- .tea'; Johnson, Duffle, Stewart & Weidner By: Mark C. Duffie, Esquire I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 mcd@jdsw.com Attorneys for Plaintiff SECURITY SAVINGS SYSTEMS, INC. IN THE COURT OF COMMON PLEAS Ninth and Market Streets CUMBERLAND COUNTY, PENNSYLVANIA New Cumberland, PA 17070, Plaintiff NO. 66'- ! h 5 30.? Cr V. CIVIL ACTION - LAW EMMA E. LEIB, her heirs and assigns, JURY TRIAL DEMANDED Defendant MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT / PUBLICATION AND NOW, this 13f day of ( , 2008, comes the Plaintiff, Security Savings Systems, Inc., by and through their undersigned counsel Johnson, Duffie, Stewart & Weidner, PC, and file the following Motion for Service Pursuant to Special Order of Court: 1. The undersigned counsel for the Plaintiff, immediately prior to filing this Motion filed an action to quiet title by complaint pertaining to a parcel of real estate therein described located in the borough of New Cumberland, Cumberland County, Pennsylvania. A true and correct copy of said Complaint is attached hereto and incorporated herein as Exhibit "A"). 2. The underlying action pertains to a parcel of real estate which has been unclaimed since 1927 and utilized for more than twenty-one (21) years by Plaintiff. 3. The undersigned, on behalf of the Plaintiff, has attempted to locate the Defendant, Emma E. Leib, her heirs or assigns and per Pa.R.C.P. 430, has filed an Affidavit outlining the scope of efforts utilized in locating the defendants. 4. The identity of any heirs or assigns of the Defendant, Emma E. Leib is unknown. WHEREFORE, the Plaintiff, respectfully requests this Honorable Court to permit service by publication pursuant to Pa.R.C.P. 430(b)(2) of a general nature addressed to the heirs or assigns of Emma E. Leib, deceased. JOHNSON DUFFIE STEM ART & WEIDNER Date: H (it be Mark C. Duffie :326744 t? ? ?- is , Y_ .,?, r :.sH -- :? ? ?? Y SECURITY SAVINGS IN THE COURT OF COMMON PLEAS OF SYSTEMS, INC., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. CIVIL ACTION - LAW EMMA E. LEIB, her heirs and assigns, Defendant NO. 08-2509 CIVIL TERM ORDER OF COURT AND NOW, this 29th day of April, 2008, upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of Court/Publication, the motion is granted to the extent that service upon Defendant may be made by publication once in the Cumberland Law Journal and a newspaper of general circulation in Cumberland County and posting of the property. PROOF OF SERVICE shall be filed of record. 'Mark C. Duffle, Esq. 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorney for Plaintiff 06F I rn ?1 I 6L y/24/os BY THE COURT, Vvesley Ole Jr., J. VINVAll 011 :Z WJ 6Z ?! V OOOZ A6 I C -:1 Hi ? -,:iia Johnson, Duffle, Stewart & Weidner By: Mark C. Duffie I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 SECURITY SAVINGS SYSTEMS, INC. Ninth and Market Streets New Cumberland, PA 17070, Plaintiff(s) V. EMMA E. LEIB, her heirs and assigns, Defendant(s) FILED-FFICE CIF THE POTHO TARY "II.Sf&-2 AM 8: 36 Attorneys for P am i CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2509 CIVIL ACTION - LAW STATEMENT OF INTENTION TO PROCEED TO THE HONORABLE JUDGES OF SAID COURT: It is the intention of the Plaintiffs in this case to proceed with the above-captioned case. JOHNSON, DUFFIE, STEWART & WEIDNER Dated: 30 '? By: a C. Duffi Attorney I. D. No. 75906 :457709 T PIP -17: Johnson, Duffie, Stewart & Wei¢,,MEERLAND Gt:iUN ' By: Mark C. Duffie, Esquire PENNSYLVAN IA I. D. No. 75906 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 mcd@jdsw.com SECURITY SAVINGS SYSTEMS, INC. Ninth and Market Streets New Cumberland, PA 17070, Plaintiff(s), EMMA E. LEIB, her heirs and assigns, Defendant(s) MOTION TO CONFIRM TITLE NO. 08-2509 CIVIL ACTION-LAW AND NOW, come this 0 - day of May, 2012, comes the Plaintiff, Security Savings Systems, Inc., by and through their undersigned counsel, Johnson, Duffie, Stewart & Weidner, P.C., and files the following Motion to Confirm Title. 1. On April 18, 2008, the Plaintiff, Security Savings Systems, Inc., filed a Complaint to Quiet Title with respect to the following property: All that certain piece or parcel of land situate in the Borough of New Cumberland, Cumberland County, Commonwealth of Pennsylvania, and designated and known and numbered as Lot 248 in a certain Plan of Lots called "Elkwood" surveyed for the Wood, Harmon Real Estate Association by George Roberts, Civil Engineer, which is duly filed among the records in the Office of the Clerk of Courts for the Recorder for Cumberland County aforesaid in Deed Book "M", Volume 5, Page 498. 2. Additionally, on April 18, 2008, Plaintiff filed a Motion for Service Pursuant to Special Order of Court in an Affidavit pursuant to P.A.R.C.P. 430 collectively requesting service Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA by publication. 3. On April 29, 2008, this Honorable Court entered an Order granting the Motion to serve Defendant by publication once in the Cumberland Law Journal and the newspaper of general circulation, as well as posting the property. 4. Publication was made in the Patriot News on June 4, 2008. The original Proof of Publication is attached hereto and incorporated herein as Exhibit "A". 5. A publication was also made in the Cumberland Law Journal on January 30, 2009. The original Proof of Publication is attached hereto and incorporated herein as Exhibit „B„ 6. The property was posted by the undersigned between the dates of May 15, 2008 for a period of six (6) months. 7. To date, filing publication and posting, no one has responded to the Complaint to Quiet Title and therefore, Title should be confirmed in the Plaintiff. WHEREFORE, the Plaintiff hereby request this Honorable Court to enter an Order Confirming title in the Plaintiff to the real property referenced herein. Respectfully submitted, JOHNSON, DUFFJ,Ix, STEV*RT & WEIDNER By: Mark C. Duffie, 41$quire Attorney I.D. No. 1,5906 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 mcd@jdsw.com 'The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 JOHNSON, DUFFIE, STEWART & WEIDNER DANA WIESEMAN 301 MARKET STREET P.O. BOX 109 LEMOYNE PA 17043 Z4ePatriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. IN THE COURT OFdiOMMONPLEAS This ad # 0001857933 ran on the dates shown below: C UMBf Y S NIA LVANIA PENNNSYLV NO.QSQM I June 04, 2008 CI VIL ACTION -LAW SECURITY SAVINGS SYSTEMS, C., Pialntlff V. EMMA E. LE 1 B, her heirs and as - D slgns, Detapidant COMPLAINT TO QUIET TITLE NOTICE to and subjcribed before me this 04 dray of jjun ,/2008 A.D. If YOU wish to deslud, you must enter a wrlThn aplpe Osrfonally Or by at- torney and file your dshlu s or obiec. tlons In writing with this court. You are warned that It you fall to do so, the case may Proceed may be -without ed a you MW Mdya, wm- ? Notary Public Out further notice fqr No nrfW request. ed by the PWdMMt. YQa may two money or property or otiler rlohts InwWtont to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION COMMONWEALTH OF PEN ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE NSYLVANIA Notariai Seal A LAWYER, THIS OFFICE MAY BE ABLE PROV Shefne L. Kisner Notary Pubk IDE YOU WITH ES IN- FORMATION ABOUT AGENCIES THAT c CitYOf Halnsburg,Dauphincou MY OFFER LEGAL SERVIC S TO ELIGIBLE PERSONS AT A MY CW E59ires Nov 26 2O1 DUCED FEE OR NO FEE. , Member, Pennsylvania A CUMBERLAND COUNTY BAR ssociation of Notaries ASSOCIATION 32S. B STREET CARL1?1? A t7 t 0 3 TELEPHO NE: ( 9lte 91l8 Exhibit "Ann W- 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 and 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__ January 30, 2009 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. sa arie Coyne, Ed/ or r SWORN TO AND SUBSCRIBED before me this 30 day of January, 2009 Notary _ s r ' F n ' I tsC U T " ;fVa ' S?hV71 Exhibit "B" CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas Cumberland County, Pennsylvania Civil Action-Law NO. 08-2509 SECURITY SAVINGS SYSTEMS, INC. Plaintiff V. EMMA E. LEIB, her heirs and assigns, Defendant COMPLAINT TO QUIET TITLE NOTICE If you wish to defend, you must enter a written appearance person- ally or by attorney and file your de- fenses or objections in writing with this court. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you without further notice for the 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 GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A RE- DUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 Telephone: (800) 990-9108 Jan. 30 12 Exhibit "B" (r) Johnson, Duffie, Stewart & Weidner By: Mark C. Duffie, Esquire I.D. No. 75906 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 mcd@jdsw.com SECURITY SAVINGS SYSTEMS, INC Ninth and Market Streets New Cumberland, PA 17070, Plaintiff(s), V. EMMA E. LEIB, her heirs and assigns, NO. 08-2509 CIVIL ACTION-LAW Defendant(s) ORDER OF COURT CONFIRMING TITLE AND NOW, this 211-tZ day of May, 2012, it is hereby ordered that the Defendant, his heirs and assigns or any third parties are forever barred from asserting a claim or interest in or to the following real property or any part thereof: All that certain piece or parcel of land situate in the Borough of New Cumberland, Cumberland County, Commonwealth of Pennsylvania, and designated and known and numbered as lot 248 in a certain Plan of Lots called "Elkwood" surveyed for the Wood Harmon Real Estate Association by George Roberts, Civil Engineer, which is duly filed among the records in the Office of the Clerk of Courts for the Recorder for Cumberland County aforesaid in Deed Book "M", Volume 5, Page 498. Title to the above property is confirmed in Plaintiff. :495371 0%rk e- zOC,e, - COPY .'?ed/,o?i a C, N ZIZMAY 10 PM 3: 7 CUMBERLAND CI)UNTy PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BY THE COURT: J 7