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Home My WebLink About04-0844 pd\jdg\ZIMMERMANESTconfess , ESTATE OF JOHN K. ZIMMERMAN, a/k/a JOHN KENNETH ZIMMERMAN, J. WILLIAM ZIMMERMAN, EXECUTOR Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. oL(-- ~W C'I v-i I LARRY E. GOSSARD and SHERI L. GOSSARD, husband and wife, Defendants CIVIL ACTION LAW CONFESSION OF JUDGMENT Pursuant to the authority contained in the warrant of attorney, a copy of which is attached to the Complaint filed in this action,'~ ~"..E for-t,he defendallLCi dJHl confess judgment Ll "j"c.Lmcnt in favor v[ the plaintiff and ~gd.~,,~t the dcfendo.nL5 [vr possession of the L"cll- prope~Ly u"scribed "" [orhJws: 48 Hurth Ea3t 3Lu,"L, BOLuuljL of - (;ld5 -'''''"l'sle, Cumbcrlallu County, jOennsyl\rafii~. I further appear for the defendants and confess judgment in favor of the plaintiff and against the defendants as follows: Principal balance due and owing $43,146.67 Interest from December 12, 2003 through February 20, 2004 70 days @ $9.46 662.20 Unpaid taxes Unpaid taxes Attorney's fees 683.28 291.58 6,717.56 TOTAL ,$51,501.29 STONE LaFAVER & SHEKLETSKI eyC:,~cnd"n" II I pd\jdg\ZIMMERMANESTcomplaint ESTATE OF JOHN K. ZIMMERMAN, a/k/a JOHN KENNETH ZIMMERMAN, J. WILLIAM ZIMMERMAN, EXECUTOR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA o'l-gl{</ ~ ~ NO. vs. LARRY E. GOSSARD and SHERI L. GOSSARD, husband and wife, Defendants CIVIL ACTION - LAW COMPLAINT PURSUANT TO PA. R.C.P. 2951 (b) (CONFESSION OF JUDGMENT) AND NOW comes the plaintiff, the Estate of John K. Zimmerman, a/k/a John Kenneth Zimmerman, J. William Zimmerman, Executor, by and through its attorneys, Stone LaFaver & Shekletski, and files this complaint pursuant to Pa. R.C.P. 2951(b) of judgment by confession and avers as follows: 1. The plaintiff is the Estate of John K. Zimmerman, a/k/a John Kenneth Zimmerman, J. William Zimmerman, Executor, 408 15th Street, New Cumberland, Cumberland County, Pennsylvania, 17070. 2. The defendants are Larry E. Gossard and Sheri L. Gossard, husband and wife, 2563 Veterans Way, Elliottsburg, Perry County, Pennsylvania, 17024. 3. A true and correct copy of the original instrument duly executed by the defendants is attached hereto, made a part hereof and marked Exhibit "A". 4. The aforesaid instrument has not been assigned. 5. Judgment on the aforesaid instrument has not been entered in any jurisdiction. 6. Contrary to the terms and provisions of the written Agreement for Sale of Real Estate, the defendants have failed to make monthly payments as required constituting a default whereby all remaining payments have become immediately due and payable under the terms of the written agreement, a copy of which is attached hereto as Exhibit "A". 7. As a consequence of the foregoing, the defendants are liable to the plaintiff as follows: Principal balance due and owing $43,146,67 Interest from December 12, 2003 through February 20, 2004 70 days @ $9.46 per day 662.20 Unpaid taxes Unpaid taxes 683.28 291.58 Attorney's collection fee (15%) 6,717.56 Total $51,501. 29 8. As a consequence of the foregoing, the plaintiff is entitled to a judgment in ejection in favor of the plaintiff and against the defendants. -2- WHEREFORE, plaintiff, the Estate of John K. Zimmerman, a/k/a John Kenneth Zimmerman, J. William Zimmerman, Executor, demands judgment in the sum of $51,501.29 against the defendants, Larry E. Gossard and Sheri L. Gossard, husband and wife, as authorized by the warrant of attorney in the instrument, a copy of which is attached hereto as Exhibit "A". STONE LaFAVER & SHEKLETSKI By CZV<JA . Da~jne, Esquire Supreme Court No. 39785 414 Bridge Street, P.O. Box E New Cumberland, PA 17070 (717) 774-7435 Attorneys for Plaintiff -3- pd\~is\l-verifi.aff VERIFICATION J. WILLIAM ZIMMERMAN, Executor of the ESTATE OF JOHN K. ZIMMERMAN, a/k/a JOHN KENNETH ZIMMERMAN, states that he is the Plaintiff named in the foregoing instrument and that he is ac- quainted with the facts set forth in the foregoing instrument; that the same are true and correct to the best of his knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.S.A. 54904 relating to unsworn falsification to authorities. ~~. - ...-~~ . W LLIAM ZIMME Date: 00~ c:\wpS I\w[)d~t~\ro~r\zimmerman.isa AGREEMENT OF SALE FOR REAL ESTATE THIS AGREEMENT is made this I L I (day of February, 1998, by and between JOHN K. ZIMMERMAN, of Carlisle, Cumberland County, Pennsylvania, hereinafter, whether one or more, called SEllER, and lARRY E. GOSSARD and SHERll. GOSSARD, husband and wife, of Carlisle, Cumberland County, Pennsylvania, hereinafter, whether one or more, called PURCHASER. 111/ - / WITNESSETH: 1. SEllER agrees to sell and convey to PURCHASER, and PURCHASER agrees to purchase and accept the conveyance of 48 North East Street, Borough of Carlisle, Cumberland County, Pennsylvania. 2. PURCHASER agrees to pay the sum of Fifty Five Thousand and 00/100 ($55,000.00) Dollars for said property as follows: Three Thousand and 00/100 ($3,000.00) Dollars at the time of the signing of this Agreement, receipt of which is hereby acknowledged by SELLER; and the balanca of Fifty Two Thousand and 00/100 ($52,000.00) Dollars in initial monthly installments of Four Hundred Fifty and 00/100 ($450.00) Dollars; all payments includa interest at the rate of eight (8%) percent per annum, with the first such installment due as of March 12, 1998, and continuing on the same day each month thereafter, for a total of Two Hundred Twenty Two (222). PURCHASER may prepay the principal balance due at any time, in whole or in part, without penalty. At the time that payment of all principal and accrued interest has been made in full, settlement as herein provided for shall be held. An amortization schedule containing the payment terms as herein set forth is attached hereto and made a part hereof, and the parties agree that principal and interest amounts as set forth in said schedule shall be used for tax calculation purposes as required for by either party. If any principal is prepaid by PURCHASER, the parties shall cooperate to adjust the interest amounts reportable for tax purposes with reference to said schedule. - 3. At final settlement, SEllER shall convey title in fee simple by special warranty deed, free and clear of all encumbrances except easements and restrictions visible or of record. 4. At settlement, all realty transfer taxes, if any, shall be divided equally between the parties; except that the obligation of the SEllER shall not exceed one (1 %) percent of the purchase price as stated in this Agreement, to wit: Five Hundred Fifty and 00/100 ($550.00) Dollars. 5. Possession of said property has been delivered to PURCHASER as of the time of the execution of this Agreement, and PURCHASER agrees that they have accepted the said property in its present condition; as is. B9fJK :':i8,'\ ;'M.t 910 , c;\wpSI\wpdalalrOler\zimrnerman.i$& 6. Real estate taxes shall be prorated to the date of delivery of possession to PURCHASER as follows: all subsequent taxes beginning with the 1998 County/Borough/Library taxes to be paid by PURCHASER. 7. As of the date of delivery of possession of said premises to PURCHASER, PURCHASER agrees to keep all improvements on the premises insured against fire with extended coverage, in a company reasonably agreeable to SELLER, for a sufficient sum to at all times cover the unpaid balance of the purchase price, said insurance to be carried in the names of the parties as their interests may appear, and to be further endorsed to protect any mortgagee of SELLER for said premises. In addition to such insurance, PURCHASER agrees to hold harmless and indemnify SELLER against any claims, suits or losses resulting from PURCHASER's occupancy or use of the said premises, including reasonable attorneys' fees for defense against such claims, suits or losses. 8. After delivery of possession of said premises to PURCHASER, PURCHASER agrees to keep the premises in a good state of repair, including the cutting of grass and other vegetation to a height at least as required by the regulations or ordinances of boro/township -, and to make no substantial alterations or construct any improvements on the said premises, without the prior written consent of the SELLER, which will not be unreasonably withheld, 9. Any municipal assessments or charges against said premises made subsequently to the date of this Agreement shall be the sole obligation of PURCHASER, who will hold SELLER harmless against the same. 10. On default in the payment of any installment of principal and/or interest for a period of thirty (30) days or more, or failure to correct the breach of any other obligation under this Agreement within thirty (30) days after written notice from the SELLER thereof, SELLER may declare this Agreement to be ended, retaining all payments made to that time as liquidated damages; and in such event, the Prothonotary or any attorney of any court of record in Cumberland County is hereby authorized to appear for and to confess judgment in an amicable action of ejectment against PURCHASER, their/his/her heirs, executors, administrators, successors, assigns or lessees, and in favor of SELLER, their/his/her heirs, executors, administrators, successors, or assigns, for the premises herein described, and to direct the immediate issuance'of a Writ of Possession with Writ of Execution for costs without notice and without asking leave of Court, and with One Thousand ($1,000.00) Dollars added as a reasonable attorney fee, or, at the option of SELLER, said Prothonotary or attorney is authorized to confess judgment against the PURCHASER and in favor of the SELLER for the unpaid balance of the purchase price and costs, interest, insurance, etc., with fifteen (15%) percent added as a collection fee. In addition, if this Agreement has been recorded in Cumberland County or elsewhere, said Prothonotary or attorney is authorized to appear for and to execute, acknowledge and record such documents as are deemed necessary by SELLER's counsel to void such Agreement as of record so that it shall not constitute an objection or cloud on the title of said premises. BOUK 5Fh i'M,[ :Jq J c:\wp.'ll\wpdala\roger\1.immerman.isa 11. The interest of the PURCHASER in this Agreement shall not be assignable in whole or in part without the prior written consent of the SELLER, and if such assignment is attempted, it shall constitute a default hereunder and the rights stipulated in the preceding paragraph shall accrue to the SELLER. 12. The PURCHASER has inspected the premises and, as set forth above, accepts this conveyance in an "as is" condition, including matters of survey and amount of acreage. and they have not relied upon any representations by either SELLER or SELLER's counsel as to the condition of the premises or the state of the title thereto. 13. If the subject property is a resident;,,1 dwelling, this contract is contingent upon a risk assessment or inspection of the property fur the presence of lead-based paint and/or lead- based paint hazards at the Purchaser's expense,:- until 9 p.m. on the tenth calendar day .der ratification (insert date 10 days after contract ratification or a date mutually agreed u;,on). (Intact lead-based paint that is in good condi.;'." is not necessarily a hazard. See the EPA pamphlet Protect Your Family From Lead in YOLo '. ,ne for more information). This continJLncy will terminate at the above predetermined dead::,,'J unless the Purchaser (or Purchaser's ""ent) delivers to the Seller (or Seller's agent) a written >,.ntract addendum listing the specific e;:'oting deficiencies and corrections needed. together with a. copy of the inspection and/or risk assessment report. The Seller may, at the Sell"r's option, within day" after delivery of the addendum, elect in writing whether to correct the condition(s) pr;"r to settlement. If the Seller will correct the condition, the Seller shall furnish the Purchaser with certification from a risk assessor or inspector demonstrating that the condition has been remedied before the date of the settlement. If the Seller does not elect to make the repairs, or if the Seller makes a counter-offer, the Purchaser shall have days to respond to the counter-offer or remove this contingency and take the property in "as is" condition or this contract shall become void. T~e urch~ser may remov;/his contingency at any time without cause. fL,.. /lr<.J1: f(dJ-<'i(v ,I '-? U 'J, J.<uf U \ Uu.i'~t.,,, /~i' "- IN WITNESS WHEREOF, the arties have hereunto set their hands and seals the day and date first above written. . ! Witness: / )'L.1 N/'l/,vA \ I ' ,'n1. )11 <'1j'-,-J-l T) )"1, /'1.1 I IjlL ~,1 -- \ '. -- ~";:Jf...~- l-'~/-"" ,6 /r ~~~...." ^ "JpJIN K. z, \~~ERMAN, ..peller >1Luo! f:Jt,'<-'-rojl lA~~Y, E, ',G,1&S, ARD, Purchaser II;' /1.( t;~ItL{,,\ll(. '7/~~?i7(.fL" . SHERI l. GOSSARD, Purch ll.[ (Seal) i- (Seal) ...., Seal) /... BOOK ~i(;ti f'^IoE :Jt-? '-,- ' c:\wpS I\wpdlll.a\roeer\zimmcrman.isa COMMONWEALTH OF PENNSYLVANIA :55. COUNTY OF CUMBERLAND ON this, the \ ~*:-k day of February, 1998, before me, a notary public, the undersigned officer, personally appeared JOHN K. ZIMMERMAN, known to me (or satisfactorily pi oven) to be the person whose name is subscribed to the within instrument, and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunt) set my hand and official seal. ." .....,.. '.' .:."~.,:'. .~, _. . : l. , . .if:,.:'o~ .:}~~);::.~i; " .(,'>';.~(~?':'.'" ..,<.~./( \;/p \~.. < .,...,......,. ~ (~G<-V C\) l 'xCL~J\:L Notary Public L) NOTARIAL SEAL U PATRICIA D. OlYARNIK, NoOvy PublIc Hampden Twp., CumIlo<Iand County, PA MyCOlIlIllIsIionExplres~s\'T7.2001 Co 0:> ..." FP j""\.~ COMMONWEALTH OF PENNSYLVANIA :::u ::a :55. , COUNTY OF CUMBERLAND ,~ ,..... '" to -, ON this, the \ ,)~.:k~., day of February, 1998, before me, a notary i;ublic, the undersigned officer, personally appeared LARRY E. GOSSARD and SHERI L. GOSSARD, husband and wife, known to me (or satisfactorily proven) to be the persons whose names are subscribed to the within instrument, and acknowledge that they executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. .:.;.,)X,::';:::<.... .>~ ~jr;f""':j:::\~;:,. . .t. ',. OF ..... . <:~?':',:.;.::'/:; ; ""..'i}. ("UO" \) L . \" 1("\ lC YCcu---<-<- ,) ~~(,'l~'A. Notary Publl.J r-'" NOTARIAL SEAL U ' ;'MRICIAD. Ol.YARNlK, NoIaryPul>'; Hampden Twp.. CumbllI18nd County, P ,\ t M!C.ommlsalonExp/m~1l27.:::~ BaOK 5(io iiM ~Jt:3 > -- c::) ~~ () /<:; o -:::s C) ::,-. ~ .~ -4- ~- ---- ~ ~ h.:. <:':., ~-~ ~'J ~ O<J 10.) 00 V, r D-'~ D r- "-> Z '0<" V) -;t-- :., ~ /"'-..,) c) C', 'II ._~ C;", :'.) C'. WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 IN RE: ESTATE OF JOHN K. ZIMMERW,N, also known as JOHN KENNETH ZIMMERMAN, J. WILLIAM ZIMMERMAN, Executor, Plaintiff v. LARRY E. GOSSARD and SHERI L. GOSSARD, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW : No. 04-814 DEFENDANTS' PETITION FOR SATISFACTION OF JUDGMENT BY CONFESSION AND NOW, come Defendant LARRY E. GOSSARD, by his attorney, Wayne F. Shade, Esquire, and respectfully represent, as follows: 1. Petitioner LARRY E. GOSSARD is an adult individual who resides at 2563 Veterans Way, Elliottsburg, Perry County, Pennsylvania 17024. 2. Respondent J. VdLLIAM ZIMMERMAN is an adult individual and the Executor of the Estate of John K. Zimmerman, also known as John Kenneth Zimmerman, and he may be served through the offices of his counsel of record, Stone, LaFaver & Sheklefski, 414 Bridge Street, P.O. Box E, New Cumberland, Pennsylvania 17070. WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 3. On February 12, 1998, Defendants entered into an Agreement of Sale for Real Estate in which Defendants agreed to purchase from Plaintiff the real estate premises known and numbered a'i 48 North East Street, Carlisle, Cumberland County, Pennsylvania. 4. On November 6~ 200 I, Defendant SHERI L. GOSSARD assigned her rights in the aforesaid Agreement of Sale to Defendant LARRY E. GOSSARD. A copy ofthe Assignment is attached hereto as Exhibit "A" and incorporated herein by reference as though fully set forth. 5. Plaintiff consented to the aforesaid Assignment from Defendant SHERI L. GOSSARD to Defendant LARRY E. GOSSARD and agreed to release Defendant SHERI L. GOSSARD completely from any responsibility under the aforesaid Agreement of Sale and from all other claims, if any, that Plaintiff had against Defendant SHERI L. GOSSARD at the time. 6. In spite of the aforesaid release of SHERI L. GOSSARD by Plaintiff, Plaintiff entered judgment by confession against both Defendants in the above-captioned matter on -2- WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle. Pennsylvania 17013 February 26, 2004, punuant to the terms of the Agreement of Sale in the amount of $51,501.29, and dockekd in this court to No. 04-844. 7. In spite of the af,)resaid release of SHERI L. GOSSARD by Plaintiff, Plaintiff entered judgment by confession in ejectment against both Defendants in the above- captioned matter on March 3, 2004, pursuant to the terms of the same Agreement of Sale and docketed in this court to No. 04-915. 8. On April 14, 2004, Plaintiff filed a Writ of Possession at No. 04-915 and retook possession of the premises at 48 North East Street, Carlisle, Cumberland County, Pennsylvania, pursuant thereto. 9. Defendant LARRY E. GOSSARD believes and therefore avers that, when Plaintiff took possession, of the real estate that was the subject of the Agreement of Sale, under the confession of judgment in ejectment, Plaintiff elected to extinguish the Agreement of Sale and thereby gave up the right to enforce any balance due as a result of the termination of the Agreement of Sale. -3- WAYNEF. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 10. The judgment that Plaintiff entered by confession against both Defendants on February 26,2004, in the above-captioned matter in the amount of$51,501.29 remains as a lien against Defendants and all of their assets. 11. On July 14, 2006, counsel for Defendant LARRY E. GOSSARD requested that counsel for Plaintiff satisfY the lien of the judgment in the above-captioned matter. 12. Plaintiff maintains that he has no obligation to satisfY the lien of the judgment. 13. No judge of this court has ruled upon any other issues in this or any related matter. WHEREFORE, Defendant LARRY E. GOSSARD respectfully requests that your Honorable Court issue a Rule upon Plaintiff to show cause why Plaintiff should not be required to satisfY the lien of the judgment at No. 04-844 in this Court. tV~ ;:-~ Wayne . Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Defendant Larry E. Gossard -4- WAYNEF.SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 The statements in the foregoing Petition are based upon information which has been assembled by my attorney in this litigation. The language of the statements is not my own. I have read the statements; and to the extent that they are based upon information which I have given to my counsel, they 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. ~4904 relating to unsworn falsification to authorities. Date: August J ( , 2006 ~1~e.~ Larry E. ossard P:\roger\real estate\agree. of sale\Zimmerman assign aos.doc \')51\ t ASSIGNMENT OF AGREEMENT OF SALE FOR REAL ESTATE This assignment is executed the 6tlt day of November, 2001, by LARRY E. GOSSARD and SHERI L. GOSSARD, formerly husband and wife; and it is consented to by JOHN K. ZIMMERMAN, as more particularly set forth below. WHEREAS, on February 12, 1998, the parties entered into an agreement of sale (a copy being attached hereto as Exhibit "A") for a certain property in the Borough of Carlisle, Cumberland County, Pennsylvania, known and numbered as 48 North East Street, Carlisle, PA 17013; and WHEREAS, by the terms of said agreement of sale, John K. Zimmerman agreed .. c, to sell said property to Larry E. Gossard and Sheri L. Gossard; and c::> N :::D -0 ::c WHEREAS, as a result of certain unhappy differences between them, Larry E. Gossard and Sheri L. Gossard have divorced. and they desire to provide for the disposition of the said agreement of sale as they had stipulated during their divorce proceedings. -0 ::3 NOW THEREFORE, with the intention to be bound legally hereby, the parties doc,:) agree as follows: ~ o 1. Sheri L. Gossard hereby assigns all her right, title and interest in the said agreement of sale and in the premises known as 48 North East Street, Carlisle, P A 17013. 2. Larry E. Gossard accepts the assignment of said agreement of sale, and in consideration thereof, he agrees to pay and perform all obligations of Purchaser under said agreement; and he will hold harmless Sheri L. Gossard against any and all claims arising out of said transaction. 3. John K. Zimmerman, Seller under said agreement of sale, hereby consents to the said assignment of the intere~t of Sheri L. Gossard; and he agrees that upon the execution of this assignment agreement, Sheri 1. Gossard shall be released completely from any responsibility under said agreement of sale and from all other claims, if any, that John K. Zimmerman may have against her. 4. John K. Zimmerman further agrees that Larry E. Gossard shall be deemed the sole responsible party for completion of the Purchasers' obligations under saici agreement of sale. BOOK 685 FACE 4915 EXHIBI-T "A". . ' c: '_ ?: ;.; ...~ co C) " ~ ~~~ : . r:: -- . N ~- r; -' U :.'J : g:~~:~ cc' :z rn I': -f f'T1 r~ -< 0.:: leI) ..J -u > P:\roger\real estate\agree. of sale \Zimmerman assign Dos.doc 5. This agreement shall be binding upon and inure to the benefit of the parties, their heirs, successors and assigns. 6. In all other respects, the parties ratify and reaffirm the agreement of sale dated February 12, 1998. IN WITNESS WHEREOF, the parties have set their hands and seals below on the date first above written. Witness: rR.~l~ L E. Gossard _'i~ ,--~ ~ .-<l~~ ~OOK 685 PAtE 4916 P:\roger\real estate\agree. of sale \Zimmerman assign 8os.doc COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) :ss ) ~~~ On this, the ~ day ofe;..' [1, ~before me, the undersigned officer, personally appeared LARRY E. GOSSARD, known to me (or satisfactorily proven) to be the persons whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. ~&~ On this, the ~y 0 ,01, be:tt me, the undersigned officer, personally appeared SHERI L. GOSSARD, known to me (or satisfactorily proven) to be the persons whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. :ss ) . '~'\;.:'t, . ',\.io,r, )i'~,,<,' ~,t.t~\~'~'~~'....~~~ r."<, \'. ':.~....~~....,. ~\;':i . ~.:^~j..".';~' "',...: "'Il".... ,~ t:':,,,,V~''''''',.... ~..~:"/..l~';' ~~..;'; ."""'-':.i'~~.~'-... ~.~ : 10- t'''' r." , ,,(..~.P-~~; 'C. z:~ ~~ ~,'~'~~.:~ ': . :& ~.rt.';.(?".f' ,.<~ _ "~~~'~~~":'\j<~ ~-\.;.~~~ ~t~'S-.~:.... ~~- '.. '." '''''0-:. 1:: ,\ :....k;..;:'. COMMONWEALTH OF PENNSYL VANIA Notary Public NOTARIAL SEAL . STEVEN J. FISHMAN. No=1C Carlisle ~!O. C~Se 1,2003 ; MvCQmm'JslQ!!~!!-.P! , ') ,,' . COUNTY OF C IN WITNESS WHEREOF, I have hereunto set my hand and official seal. " ,:~~,r,~~':ff\. .,.~~,jrF;l'S-r.,i\:";j,. ,!,.,,-~,J1tl.~"'~' ..j" ./'.... I...' ~~i7(3;;~1~'f#);1;~ '~:~';,_. ,~j;;G.:~; ,4PJ",:,./.!;t;fYt',' ~,:., ~ I\~;''''''~\?~';'';;;''' ,. ;.0>; ::-!~., ~", .' . Ft. .;~Z"~0 ;,~:,':.: \.<;p~,".' ':'~/~\.';"l.r!,.~~.-.t- -'-!. ' "~J':"'''~;'' ~j:Y-~ Notary Public Notarial Seal Nonna G. Burrs. =Pub!iC MSIJS<JUEhanna Twp.. Da n County y CommisSion Expires . 2, 2002 r, 0 O'nes BOOK 685 PACE 4917 P:\roger\real estate\agree. of sale \Zimmerman assign aos.doc COMMONWEALTH OF PENNSYL VANIA ) COUNTY OF CUMBERLAND :ss ) On this, the ~ "- day of ~ ~fore me, the undersigned officer, personally appeared JOHN K. ZIMMERMAN, known to me (or satisfactorily proven) to be the persons whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF. I have hereWlto set my hand and official seal. Notary Public i NOTARIAL SEAL STEVEN J. FISHMAN, Notary Public . ~arlisle Boro, Cumberland County : f}:l/ r.nmmission Ex es Sa 1,2003 'P.-...................- BOOK 685 rAGt4918 ~<) ,-'::...:.' 1...< . . ~ IN RE: ESTATE OF JOHN K. ZIMMERW,N, also known as JOHN KENNETH ZIN[MERMAN, J. WILLIAM ZIMMERMAN, Executor, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW SEP 1 9 200V' : No. 04-844 v. LARRY E. GOSSARD and SHERI L. GOSSARD, Defendants AND NOW, this ORDER OF COURT '" r " day of ~t,t"t,W\\c.r , 2006, upon consideration of the within Petition and upon motion of Wayne F. Shade, Esquire, attorney for Defendant Larry E. Gossard, a Rule is issued upon Plaintiff to show cause why the judgment in favor of Plaintiff and against Defendants in the above-captioned matter should not be marked satisfied. Rule returnable within 1 () days of date of service hereof. By the Court, WAYNEF. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 David H. Stone, Esquift.~ tone, LaFaver & Sheklefski Attorneys for Plaintiff ~ J. ayne F. Shade, Esqui:'e Attorney for De1t:mdant Larry E. Gossard , 'v1N'iAlASNN3d A1.NnCJ:) (1i',:'1lY38l^1nO Z i'J : 1 Wd 61 d3S 900Z Ab'VI0NOHIO!:id 3Hl :\0 381:1:10-0311:\ IN RE: ESTATE OF JOHN K. ZIMMERMAN, also known as JOHN KENNETH ZIMMERMAN, J. WILLIAM ZIMMERMAN, Executor, Plaintiff v. LARRY E. GOSSARD and SHERI L. GOSSARD, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW : No. 04-844 PRAECIPE TO SATISFY mDGMENT TO: Curtis R. Long, Prothonotary Please mark the judgment in the above-captioned matter satisfied as to the judgment and costs. Date: January b ,2007 ~ e ~ :'>- <-- ""tJ cr, ;:;: rr~ f !:-' ____ 2:, ":\'.-:. zr~.. (/'J: ,';- ::<:~ ~" ~C ~,.-C 'J>c: Z, :.2 c::> Sf>, ~:o -oh1 g~ :C:';'l C" :..u ~~ (5 -=-\ ~ -0 :s N .. (...) N