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HomeMy WebLinkAbout09-4090MARLIN K. ULSH AND CLARA A. ULSH, husband and wife, TRUSTEES OF THE MARLIN K. ULSH AND CLARA A. ULSH REVOCABLE TRUST DATED MAY 4,1998: Plaintiffs V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEAL E. WOOD, JR., ANTHONY J. SEBASTIAN AND JAMIE A. SEBASTIAN, NO. O 9- v A o;c T?.- husband and wife, JAMES B. TITZEL, TODD G. MATTSON AND HEATHER RAE: ACTION TO QUIET TITLE - AGREEMENT MATTSON, husband and wife, SHARON R. : PASTOR, JOHN F. SHUEY, KATHLEEN : SULLIVAN, JASON C. RICHARDS AND . TAMMY L. RICHARDS, husband and wife, : ELIZABETH M. BERRIER, DREHER L. . RICHARDS AND GWENDOLYN 1. RICHARDS, husband and wife, GERALD J. YANCISIN AND CHRISTINE M. YANCISIN, husband and wife, CARL T. PEIFFER AND : KATHLEEN M. PEIFFER, husband and wife: MILAN PERLICK AND JILT. L. PERLICK, : husband and wife, AARON C.= MILLS, JESSICA L. KARAFFA, . Defendants NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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, PA 17013 Telephone No. (717) 249-3166 MARLIN K. ULSH AND CLARA A. ULSH, : IN THE COURT OF COMMON PLEAS OF husband and wife, TRUSTEES OF THE : CUMBERLAND COUNTY, PENNSYLVANIA MARLIN K. ULSH AND CLARA A. ULSH : REVOCABLE TRUST DATED MAY 4,1998: Plaintiffs V. NEAL E. WOOD, JR., ANTHONY J. SEBASTIAN AND JAMIE A. SEBASTIAN, NO. D q - SaDQ o (,w ?u,-- husband and wife, JAMES B. TITZEL, TODD G. MATTSON AND HEATHER RAE: ACTION TO QUIET TITLE - AGREEMENT MATTSON, husband and wife, SHARON R. : PASTOR, JOHN F. SHUEY, KATHLEEN : SULLIVAN, JASON C. RICHARDS AND : TAMMY L. RICHARDS, husband and wife, : ELIZABETH M. BERRIER, DREHER L. . RICHARDS AND GWENDOLYN I. RICHARDS, husband and wife, GERALD J. YANCISIN AND CHRISTINE M. YANCISIN, husband and wife, CARL T. PEIFFER AND : KATHLEEN M. PEIFFER, husband and wife: MILAN PERLICK AND JILL L. PERLICK, : husband and wife, AARON C. MILLS, JESSICA L. KARAFFA, . Defendants COMPLAINT NOW, comes the Plaintiffs in the above-captioned matter by and through their counsel, SALZMANN HUGHES, P.C., and files this Complaint in an Action to Quiet Title against the above-designated defendants, and in support thereof set forth the following: 1. Plaintiffs, Marlin K. Ulsh and Clara A. Ulsh, husband and wife, are adult individuals residing at the property they own as Trustees of the Marlin K. Ulsh and Clara A. Ulsh Revocable Trust dated May 4, 1998, located at 2120 Milltown Road, Lower Allen Township, Cumberland County, Pennsylvania (hereinafter referred to as the "Ulsh Property") pursuant to the deed dated November 2, 2006 and recorded in Book 277, Page 2541 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania. 2. The Ulsh Property is described as Lot 3, Block C on the subdivision plan entitled Creekside Manor dated November 5, 1956, and recorded in Plan Book 9, Page 1, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, attached hereto and incorporated herein as Exhibit A. (hereinafter referred to as the "Creekside Manor Subdivision Plan"). 3. The named Defendants along with the Ulshes consist of all of the owners of property within the Creekside Manor Subdivision. 4. The Creekside Manor Subdvision Plan laid out a fifty (50) foot street between the Ulsh Property (Lot 3, Block C) and the property owned by Defendants Carl T. Peiffer and Kathleen M. Peiffer (Lot 18, Block D) which was later referred to by Lower Allen Township as Playground Drive. (Hereinafter referred to as "Playground Drive"). 5. By Ordinance dated December 22, 2008, Lower Allen Township formally vacated Playground Drive, thereby vesting ownership of Playground Drive to the centerline thereto in Plaintiffs, Marlin K. Ulsh and Clara A. Ulsh and Defendants Carl T. Peiffer and Kathleen M. Peiffer, as abutting landowners. (Ordinance attached hereto and incorporated herein as Exhibit B). 6. The one-half (1/2) of Playground Drive now owned by Plaintiffs Marlin K. Ulsh and Clara A. Ulsh, with Tax Parcel No. 13-24-0803-023 and is more particularly described as follows: ALL THAT CERTAIN tract or lot of ground situated in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING in the southwest corner of Lot No. 3, Block C, Section 1, Creekside Manor, which plan of lots is recorded in Plan Book 9, Page 1, Recorder of Deeds Office in and for Cumberland County, Pennsylvania, at the northeast intersection of Milltown Road and a proposed street having a width of fifty (50) foot; thence North eleven (11) degrees, thirty (30) minutes West along the western line of said Lot No. 3, Block C on the aforesaid plan of lots at a distance of one hundred twenty (120.00) feet to a point being the northwest corner of Lot No. 3, Block C; thence South seventy-eight (78) degrees thirty (30) minutes West, a distance of twenty-five (25) feet to a point, being the centerline of the fifty (50) foot wide street on the aforesaid plan of lots; thence South eleven (11) degrees thirty (30) minutes East along the centerline of the fifty (50) foot wide street, a distance of one hundred twenty (120) feet to the intersection of the centerline of the fifty (50) foot wide street and Milltown Road; thence North seventy-eight (78) thirty (30) minutes East, a distance of Twenty-Five (25) feet to a point, being the place of BEGINNING. 7. All of the owners of property within the Creekside Manor Subdivision (the named Defendants herein) have agreed to release, discharge and forever quit all claim, right, title, interest or easement in or to Playground Drive as stated in the Agreement and Release attached hereto and incorporated herein as Exhibit C. 8. None of the Defendants have ever made a claim for possession of, or for title to the property herein described, nor has any action of ejectment or other proceeding ever been instituted to obtain possession. However, Defendants, their heirs or successors in title, as property owners within the Creekside Manor Subdivision, may assert an interest or claim in the herein described property which may constitute a cloud upon the marketability of the title of Plaintiffs. WHEREFORE, Plaintiffs pray that a decree be entered forever barring the defendants and their heirs, personal representatives and assigns, from asserting any right, title or interest in or to the real estate described unless within twenty (20) days from the date of the service of the Complaint, the Defendants or their heirs, personal representatives or assigns commence an action in ejectment. Respectfully submitted, SALZMANN HUGHES, P.C By: A j /7 A I usann B. M rrison, Esquire Supreme Court No. 77041 354 Alexander Spring Road, Ste 1 Carlisle, PA 17015 (717) 249-6333 Attorney for Plaintiffs Date: 1U / VERIFICATION The foregoing document is based upon information that has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. § 4904, relating to unworn falsification to authorities. Marlin. Ulsh &e.,., a ae & Clara A. Ulsh `Date: a ?o _. _- ?- o o? r - o` ,9L• e:.Vj V?o'y-Z2 N ?. L91 1. it iT • e7 ?O - ? W al _ efl M v ticsl ?o co ?O `t mm T'ff 0 ?F69-? oc? t9 O• m f1 ;SS sl tt 1'x`3 •II 1 S OS n\'Oso I I t1 4LI m - to .OLI • Q :r .o .o r t7 r - OLf ' m o m f11, 0 . r ? .? 4 to ? O ozl a7 3 AN, o S. I Ti "p ?m•,OaI ? N ?. r a.`!? . .. __..• o eO yrn.DY?l1tt `- 0 Q 1 ?.. 'o.? ,4z1 1.3"1 S ,OS _ rn.osel I n a a .J O'L I o v-- ap O ,07.f O° I? S? If1 r , NQ N • rn.oo:. n I a O 1,.. Q O N 7-2 O_ O o r- 0 r O r n.. a 5- Sal??'? ORDINANCE NO. 2008 -06 i-a+-oEOa-?a(oxa YI?II??III?? )9N] AN ORDINANCE OF THE BOARD OF COA0flSSIONERS OF LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, VACATING A STREET KNOWN AS PLAYGROUND DRIVE AS FOLLOWS: BE IT ENACTED AND ORDAINED by the Board of Commissioners ("Board") of Lower Allen Township ("Township") Cumberland County, Pennsylvania, and it is hereby enacted and ordained by the same as follows: WHEREAS, Petitioners Carl T. and Kathleen M. Peiffer and Marlin K. and Clara A. Ulsh filed a Petition pursuant to the First Class Township Code 53 P.S. §57005, and WHEREAS, the Petitioners requested that Lower Allen Township, by appropriate Ordinance, vacate Playground Drive, which is more particularly described in Exhibit "A"; WHEREAS, Petitioners own 100% of the abutting property of the subject Playground Dive in compliance with the First Class Township Code, 53 P.S. §57005; and WHEREAS, the Board. of Commissioners of Lower Allen Township, find it to be in the interest of Lower Allen Township to vacate this Playground Drive. NOW THEREFORE BE IT ORDAINED, that all the above recitals are incorporated herein and the Board of Commissioners of the Township of Lower Allen, Cumberland County, Pennsylvania, by Motion duly made in the majority vote of Commissioners present, hereby vacate the portion of Playground Drive, more fully described in Exhibit "A". ENACTED AND ORDAINED this 22nd day of December, 2008. This vacation will be effective upon completion of a final report and upon filing , Office of Clerk of the Court of Quarter Sessions in the Court of Common Pleas of y11[ii County. Rai (Amist=t) Secretary LOWER ALLEN TOWNSHIP BO OF COMMISSIONERS l pT a President Exhibit B EXHIBIT "A" Beginning in the southwest corner of Lot No. 3, Block C, Section 1, Creekside Manor, which plan of lots if recorded in Plan Book 9, Page 1, Recorder of Deeds Office in and for Cumberland County, Pennsylvania, at the northeast intersection of Milltown Road and a proposed street having a width of fifty (50) foot; thence north eleven (11) degrees, thirty (30) minutes west along the western line of said Lot No. 3, Block C on the aforesaid plan of lots at a distance of one hundred twenty (120) feet to a point being the northwest corner of Lot No. 3, Block C; thence south seventy-eight (78) degrees thirty (30) minutes west, as distance of fifty (50) feet to a point, being the northeast corner of Lot No. 18, Block D on the aforesaid plan of lots thence south eleven (11) degrees, thirty (30) minutes east along the eastern line of said Lot No. 18, Block D, a distance of one hundred twenty (120) feet to the southeast comer of said Lot No. 18, Block D; thence north seventy-eight (78) thirty (30) minutes east, a distance of fifty (50) feet to a point, being the place of beginning. i =57MW*W Irm I ?/LOWERALLEN TO WNSHIP 2233 GETTYSBUHG ROAD - CAMP H11L L, PENNSYL VAN/A 17011 CERTIFICATION TOWNSHIP OF LOWER ALLEN Office of the Township Secretary I, Danna S. Lutes, Township Secretary of the Township of Lower Allen, Pennsylvania, hereby attest that the enclosed Ordinance 2008-06, an Ordinance of the Board of Commissioners of Lower Allen Township, Cumberland County, Pennsylvania, vacating a street known as Playground Drive is a true and correct copy. Given under my hand and the Seal of the Township of Lower Allen, 2233 Gettysbi County of Cumberland, Commonwealth of Pennsylvania, this 26th day of January s/Danna S. L Township Secretary Phone: (717) 975-7575 - www.lower-allen.pa.us AFFIDAVIT We, Carl T. Peiffer and Kathleen M. Peiffer, as owners 2124 Milltown Road, in Lower Allen Township, Cumberland County, Pennsylvania, and Marlin X Ulsh and Clara A. U19h, as owners 2120 Milltown Road, in Lower Allen Township, Cumberland County, Pennsylvania first having been duly affirmed according to law, depose and say that the foregoing Ordinance certified by the Secretary of Lower Allen Township is based upon information that is true and correct to the best of our knowledge, information and belief. -,-K, aolv?-' Carl -. Pe er - fu Kath1 -Peiffer Marlia Ulsh Affirmed and subscribed to before me this') day of 2009 NO ARY PUBLIC COMMONWEALTH OF PENNSYLVANIA Notarial Seal Kandy L Coyle, Notary Public South Middleton TWp., Ctxnbertand Courity My CommMlori Expires July 6, 2010 Member, Pennsylvania Association of Notaries -E'u,A'4 0' Clary A.- Uhh ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200905293 Recorded On 2/25/2009 At 1:32:57 PM * Instrument Type - MISCELLANEOUS INSTRUMENT Invoice Number - 37904 User ID - RZ * Grantor - LOWER ALLEN TOWNSHIP * Grantee - PEIFFER, CARL T * Customer - SALZMANN HUGHES PC * FEES STATE WRIT TAX $0.50 RECORDING FEES - $12.00 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $27.50 * Total Pages - 5 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA spa ?? ? Tf RECORDER O D DS * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 1111111111111111111111111 AGREEMENT AND RELEASE WHEREAS, Ernest H. Spoonhour and Blanche G. Spoonhour, his wife, were owners of a tract of land situate in Lower Allen Township, Cumberland County, Pennsylvania, for which they filed a subdivision plan entitled Creekside Manor dated November 5, 1956, and recorded in Plan Book 9, Page 1, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania; and WHEREAS, the recorded plan for Creekside Manor describes a fifty (50) foot street between Lot 18 of Block D and Lot 3 of Block C which has never been used by the public (hereinafter referred to as "Playground Drive") which is more particularly described as follows: Beginning in the southwest corner of Lot No. 3, Block C, Section 1, Creekside Manor, which plan of lots is recorded in Plan Book 9, Page 1, Recorder of Deeds Office in and for Cumberland County, Pennsylvania, at the northeast intersection of Milltown Road and a proposed street having a width of fifty (50) foot; thence north eleven (11) degrees, thirty (30) minutes west along the western line of said Lot No. 3, Block C on the aforesaid plan of lots at a distance of one hundred twenty (120) feet to a point being the northwest corner of Lot No.3, Block C; thence south seventy-eight (78) degrees thirty (30) minutes west, a distance of fifty (50) feet to a point, being the northeast comer of Lot No. 18, Block D on the aforesaid plan of lots thence south eleven (11) degrees, thirty (30) minutes east along the eastern line of said Lot No. 18, Block D, a distance of one hundred twenty (120) feet to the southeast comer of said Lot No. 18, Block D; thence north seventy-eight (78) thirty (30) minutes east, a distance of fifty (50) feet to a point, being the place of beginning. WHEREAS, the Board of Commissioners of Lower Allen Township enacted and ordained Ordinance 2008-06 on December 22, 2008, thereby officially vacating Playground Drive; and WHEREAS, Ernest H. Spoonhour and Blanch G. Spoonhour, his wife by their several Deeds, conveyed all of the lots described in the Plan for Creekside Manor; and WHEREAS, the undersigned, being individual owners of lots within the Creekside Manor subdivision, desire to release relinquish and otherwise waive all claims, rights, title and interest to the herein described fifty (50) foot street known as Playground Drive and agree to any vacation or abandonment thereof by any person or persons or any municipality waiving any and all claims, demands, damages, causes of action, which they may have or may ever have by reason thereof. NOW, THEREFORE, in consideration of One Dollar ($1.00) as well as the promises and the mutual benefits recited herein together with other good and valuable Exhibit C consideration, the receipt and sufficiency of which is hereby acknowledged by the parties for themselves, their assigns, heirs and successors, hereby agree as follows: 1. We, the undersigned individual owners of lots within the plan of Creekside Manor, which plan of lots was recorded in Plan Book 9, Page 1, Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, by our signatures hereby jointly and severally release, discharge and forever quit all claim, right, title, interest or easement in or to the herein described fifty (50) foot wide street known as Playground Drive and agree and consent to any vacation or abandonment thereof by any person or persons or any municipality waiving any and all claims, demands, damages and or causes of action which we may now have of may ever have in the future by reason thereof. 2. This agreement shall inure to the benefit of and shall be binding upon all parties hereto and upon their respective successors, purchasers, heirs and assigns and shall run with the land of the respective properties. 3. The parties agree to execute promptly any and all other documents that may be necessary to effectuate the terms of this Agreement. 4. The recitals above are incorporated herein by reference thereto and made part of this Agreement. 5. This Agreement shall be interpreted and governed in accordance with the laws of the Commonwealth of Pennsylvania. IN WITNESS WHEREOF, and intending to be legally bound hereby, the parties hereunto sets their hands and seals the day and year first above written. G,; f a Lot No. 1, Block A 2000 Milltown Road Neal E. Wood, Jr. Loretta V. Wood (deceased) Lot No. 2, Block A 2008 Milltown Road Anthony J. Sebastian Cser Amrkctho) Jamie A. Sebastian Lot No, 3, Block A 2014 Milltown Road J „ o B. Titzel ?f. Esther C. Titzel (deceased) Lot No. 4, Block A (SEE AUACEt-0) 2016 Milltown Road Todd G. Mattson ;?' 9 W 1 y Heather Rae Mattson Lot No. 5, Block A CXI9 2018 Milltown Road Sharon R. Pastor Lot No. 6, Block A 2020 Milltown Road Jo . Shuey Suzanne S. Shuey / Lot No. 1, Block B ° ?Py?ct"" 2100 Milltown Road thleen Sullivan Lot No. 2, Block B 2104 Milltown Road J so `Richards - , Tammy L. Lot No. 3, Block B AA µ AJY 2108 Milltown Road Elizabe . Berrier Lot No. 1, Block C - 2112 Milltown Road reher L. Richards y( ,p. Gwendol . Richards Lot No. 2, Block C 2116 Milltown Road Gerald J. cis n C1 C,( /? // / r Christine M. Yancisi Lot No. 3, Block C 2120 Milltown Road Marlin K. Ulsh, Trustee *Releasing rights only to the one-half of Playground Dr. note abutting Lot No. 3, Block C Clara A. Ulsh, Trustee Lot No. 17 & 18, Block D 2124 Milltown Road **Releasing rights only to one-half of Playground Dr. abutting Lot No-. 18, Block Lot No. 19, Block D 2128 Milltown Road Lot No. 20, Block D 925 Shetter Lane C, Carl T. Peiffer*-fV the not D Kathleen M. Peiffer "a, / .. /,,/ Milan Perlick Jill L. Perlick Aaron C. Mills L L ?-? J ssica L Karaffa f"' A ? Lot No. 4, Block A 1??d 3?1, 2016 Milltown Road Todd G. Mattson Lot No. 2, =lock A 2008 Milltown Road Anthony J. Sebastian Jamie A. S %in V Lot No. 19, Block D 2128 Milltown Road 1 L. Perlick 0 - T Ht- f r "NOTARY Ali 2C 09 JU;`4 16 r "i 12: 2 3 F r r - CA 3SYs" P.??G79j •'?? /77S?3y ?#- MARLIN K. ULSH AND CLARA A. ULSH, : IN THE COURT OF COMMON PLEAS OF husband and wife, TRUSTEES OF THE : CUMBERLAND COUNTY, PENNSYLVANIA MARLIN K. ULSH AND CLARA A. ULSH : REVOCABLE TRUST DATED MAY 4, 1998: Plaintiffs V. NEAL E. WOOD, JR., ANTHONY J. SEBASTIAN AND JAMIE A. SEBASTIAN, NO. O C1 - LJO 010 husband and wife, JAMES B. TITZEL, TODD G. MATTSON AND HEATHER RAE: ACTION TO QUIET TITLE - AGREEMENT MATTSON, husband and wife, SHARON R. : PASTOR, JOHN F. SHUEY, KATHLEEN : SULLIVAN, JASON C. RICHARDS AND . TAMMY L. RICHARDS, husband and wife, : ELIZABETH M. BERRIER, DREHER L. . RICHARDS AND GWENDOLYN I. RICHARDS, husband and wife, GERALD J. : YANCISIN AND CHRISTINE M. YANCISIN, husband and wife, CARL T. PEIFFER AND : KATHLEEN M. PEIFFER, husband and wife: MILAN PERLICK AND JILL L. PERLICK, : husband and wife, AARON C. MILLS, JESSICA L. KARAFFA, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: 6 '?2 Address: Lot No. 17 & 18, Block D 2124 Milltown Road d 0 Carl T. Peiffer K?aen M. Peiffer Camp Hill, PA 17011 OF 7 tT1' i:,n i ut T 2009 JU DTARY ?b 1Q: 08 MARLIN K. ULSH AND CLARA A. ULSH, : IN THE COURT OF COMMON PLEAS OF husband and wife, TRUSTEES OF THE : CUMBERLAND COUNTY, PENNSYLVANIA MARLIN K. ULSH AND CLARA A. ULSH : REVOCABLE TRUST DATED MAY 4, 1998: Plaintiffs V. NEAL E. WOOD, JR., ANTHONY J. SEBASTIAN AND JAMIE A. SEBASTIAN, NO. pq _ y Uo) O husband and wife, JAMES B. TITZEL, TODD G. MATTSON AND HEATHER RAE: ACTION TO QUIET TITLE - AGREEMENT MATTSON, husband and wife, SHARON R. : PASTOR, JOHN F. SHUEY, KATHLEEN : SULLIVAN, JASON C. RICHARDS AND . TAMMY L. RICHARDS, husband and wife, : ELIZABETH M. BERRIER, DREHER L. . RICHARDS AND GWENDOLYN I. RICHARDS, husband and wife, GERALD J. YANCISIN AND CHRISTINE M. YANCISIN, husband and wife, CARL T. PEIFFER AND KATHLEEN M. PEIFFER, husband and wife: MILAN PERLICK AND JILL L. PERLICK, : husband and wife, AARON C. MILLS, JESSICA L. KARAFFA, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date:-(/ -?- 3 - 09 Address: Lot No. 3, Block A 2014 Milltown Road Camp Hill, PA 17011 C=1? k Y TAP I "'9 JUL -6 Cumh, P , l 'r MARLIN K. ULSH AND CLARA A. ULSH, husband and wife, TRUSTEES OF THE MARLIN K. ULSH AND CLARA A. ULSH REVOCABLE TRUST DATED MAY 4, 1998: Plaintiffs V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEAL E. WOOD, JR., ANTHONY J. SEBASTIAN AND JAMIE A. SEBASTIAN, : NO. d Cl - y p cl D husband and wife, JAMES B. TITZEL, TODD G. MATTSON AND HEATHER RAE: ACTION TO QUIET TITLE - AGREEMENT MATTSON, husband and wife, SHARON R. : PASTOR, JOHN F. SHUEY, KATHLEEN : SULLIVAN, JASON C. RICHARDS AND . TAMMY L. RICHARDS, husband and wife, : ELIZABETH M. BERRIER, DREHER L. RICHARDS AND GWENDOLYN I. RICHARDS, husband and wife, GERALD J. YANCISIN AND CHRISTINE M. YANCISIN, husband and wife, CARL T. PEIFFER AND : KATHLEEN M. PEIFFER, husband and wife: MILAN PERLICK AND JILL L. PERLICK, : husband and wife, AARON C. MILLS, JESSICA L. KARAFFA, . Defendants . ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: b D 6 - A ? (XAP-? Sharon R. Pastor Address: Lot No. 5, Block A 2018 Milltown Road Camp Hill, PA 17011 He 1009 jUL _ Aar 10: QED Culv-- l MARLIN K. ULSH AND CLARA A. ULSH, husband and wife, TRUSTEES OF THE MARLIN K. ULSH AND CLARA A. ULSH REVOCABLE TRUST DATED MAY 4, 1998: Plaintiffs . V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEAL E. WOOD, JR., ANTHONY J. SEBASTIAN AND JAMIE A. SEBASTIAN, NO. C) C1 - ?I C) Cj O husband and wife, JAMES B. TITZEL, TODD G. MATTSON AND HEATHER RAE: ACTION TO QUIET TITLE - AGREEMENT MATTSON, husband and wife, SHARON R. : PASTOR, JOHN F. SHUEY, KATHLEEN : SULLIVAN, JASON C. RICHARDS AND . TAMMY L. RICHARDS, husband and wife, : ELIZABETH M. BERRIER, DREHER L. . RICHARDS AND GWENDOLYN I. RICHARDS, husband and wife, GERALD J. : YANCISIN AND CHRISTINE M. YANCISIN, husband and wife, CARL T. PEIFFER AND : KATHLEEN M. PEIFFER, husband and wife: MILAN PERLICK AND JILL L. PERLICK, : husband and wife, AARON C. MILLS, JESSICA L. KARAFFA, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: 61, k/o? Address: Lot No. 2, Block C 2116 Milltown Road Camp Hill, PA 17011 Gerald J Yan in Christine Yancisin ?? 1 F(LEU f f i He N- ? 2009 JU _ z r ?.; MARLIN K. ULSH AND CLARA A. ULSH, husband and wife, TRUSTEES OF THE MARLIN K. ULSH AND CLARA A. ULSH REVOCABLE TRUST DATED MAY 4, 1998: Plaintiffs V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEAL E. WOOD, JR., ANTHONY J. SEBASTIAN AND JAMIE A. SEBASTIAN, NO. C7 9 - y 0 °t O husband and wife, JAMES B. TITZEL, TODD G. MATTSON AND HEATHER RAE: ACTION TO QUIET TITLE - AGREEMENT MATTSON, husband and wife, SHARON R. : PASTOR, JOHN F. SHUEY, KATHLEEN : SULLIVAN, JASON C. RICHARDS AND . TAMMY L. RICHARDS, husband and wife, : ELIZABETH M. BERRIER, DREHER L. . RICHARDS AND GWENDOLYN I. RICHARDS, husband and wife, GERALD J. YANCISIN AND CHRISTINE M. YANCISIN, husband and wife, CARL T. PEIFFER AND : KATHLEEN M. PEIFFER, husband and wife: MILAN PERLICK AND JILL L. PERLICK, : husband and wife, AARON C. MILLS, JESSICA L. KARAFFA, . Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: 1 ! ?1_0 7 Address: Lot No. 1, Block C 2112 Milltown Road Camp Hill, PA 17011 01 771?p;':;`';t r ? ? ?+?y r IN r MARLIN K. ULSH AND CLARA A. ULSH, husband and wife, TRUSTEES OF THE MARLIN K. ULSH AND CLARA A. ULSH REVOCABLE TRUST DATED MAY 4, 1998: Plaintiffs V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEAL E. WOOD, JR., ANTHONY J. SEBASTIAN AND JAMIE A. SEBASTIAN, NO. C;) 9 - y 4 husband and wife, JAMES B. TITZEL, TODD G. MATTSON AND HEATHER RAE: ACTION TO QUIET TITLE - AGREEMENT MATTSON, husband and wife, SHARON R. : PASTOR, JOHN F. SHUEY, KATHLEEN : SULLIVAN, JASON C. RICHARDS AND . TAMMY L. RICHARDS, husband and wife, : ELIZABETH M. BERRIER, DREHER L. . RICHARDS AND GWENDOLYN I. RICHARDS, husband and wife, GERALD J. YANCISIN AND CHRISTINE M. YANCISIN, husband and wife, CARL T. PEIFFER AND : KATHLEEN M. PEIFFER, husband and wife: MILAN PERLICK AND JILL L. PERLICK, : husband and wife, AARON C. MILLS, JESSICA L. KARAFFA, . Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: ? A 0 Address: Lot No. 2, Block B 2104 Milltown Road Camp Hill, PA 17011 ?-; ?ppQ??1 ` 6 ,? `?i?'I L ;sr ?Fk;?? ?"?? 41?yr MARLIN K. ULSH AND CLARA A. ULSH, husband and wife, TRUSTEES OF THE MARLIN K. ULSH AND CLARA A. ULSH REVOCABLE TRUST DATED MAY 4, 1998: Plaintiffs V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEAL E. WOOD, JR., ANTHONY J. SEBASTIAN AND JAMIE A. SEBASTIAN, NO. 0 C t - y(:) C1 b husband and wife, JAMES B. TITZEL, TODD G. MATTSON AND HEATHER RAE: ACTION TO QUIET TITLE - AGREEMENT MATTSON, husband and wife, SHARON R. : PASTOR, JOHN F. SHUEY, KATHLEEN : SULLIVAN, JASON C. RICHARDS AND . TAMMY L. RICHARDS, husband and wife, : ELIZABETH M. BERRIER, DREHER L. . RICHARDS AND GWENDOLYN I. RICHARDS, husband and wife, GERALD J. YANCISIN AND CHRISTINE M. YANCISIN, husband and wife, CARL T. PEIFFER AND : KATHLEEN M. PEIFFER, husband and wife: MILAN PERLICK AND JILL L. PERLICK, : husband and wife, AARON C. MILLS, JESSICA L. KARAFFA, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: CQ-19 - n Elizabeth B er Address: Lot No. 3, Block B 2108 Milltown Road Camp Hill, PA 17011 Ffl ED-1 F OF THE P; ' h orb j i{ 1" 2009 JUL - 6 AN w 16: 0 7 MARLIN K. ULSH AND CLARA A. ULSH, : IN THE COURT OF COMMON PLEAS OF husband and wife, TRUSTEES OF THE MARLIN K. ULSH AND CLARA A. ULSH REVOCABLE TRUST DATED MAY 4, 1998: Plaintiffs V. CUMBERLAND COUNTY, PENNSYLVANIA NEAL E. WOOD, JR., ANTHONY J. SEBASTIAN AND JAMIE A. SEBASTIAN, NO. QGl _ L4 C)0(0 husband and wife, JAMES B. TITZEL, TODD G. MATTSON AND HEATHER RAE: ACTION TO QUIET TITLE - AGREEMENT MATTSON, husband and wife, SHARON R. : PASTOR, JOHN F. SHUEY, KATHLEEN : SULLIVAN, JASON C. RICHARDS AND . TAMMY L. RICHARDS, husband and wife, : ELIZABETH M. BERRIER, DREHER L. . RICHARDS AND GWENDOLYN I. RICHARDS, husband and wife, GERALD J. YANCISIN AND CHRISTINE M. YANCISIN, husband and wife, CARL T. PEIFFER AND : KATHLEEN M. PEIFFER, husband and wife: MILAN PERLICK AND JILL L. PERLICK, : husband and wife, AARON C. MILLS, JESSICA L. KARAFFA, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: 1?vt 1 ?) Za Kath een Sullivan Address: Lot No. 1, Block B 2100 Milltown Road Camp Hill, PA 17011 200$ JUL _6 Air 10: MARLIN K. ULSH AND CLARA A. ULSH, : IN THE COURT OF COMMON PLEAS OF husband and wife, TRUSTEES OF THE : CUMBERLAND COUNTY, PENNSYLVANIA MARLIN K. ULSH AND CLARA A. ULSH : REVOCABLE TRUST DATED MAY 4, 1998: Plaintiffs V. NEAL E. WOOD, JR., ANTHONY J. SEBASTIAN AND JAMIE A. SEBASTIAN, : NO. O q - Lj O 1-10 husband and wife, JAMES B. TITZEL, TODD G. MATTSON AND HEATHER RAE: ACTION TO QUIET TITLE - AGREEMENT MATTSON, husband and wife, SHARON R. : PASTOR, JOHN F. SHUEY, KATHLEEN : SULLIVAN, JASON C. RICHARDS AND . TAMMY L. RICHARDS, husband and wife, : ELIZABETH M. BERRIER, DREHER L. . RICHARDS AND GWENDOLYN I. RICHARDS, husband and wife, GERALD J. : YANCISIN AND CHRISTINE M. YANCISIN, husband and wife, CARL T. PEIFFER AND : KATHLEEN M. PEIFFER, husband and wife: MILAN PERLICK AND JILL L. PERLICK, : husband and wife, AARON C. MILLS, JESSICA L. KARAFFA, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: i al^ .,,2 , J tl-?. 11? H ather Rae Mattson Address: Lot No. 4, Block A 2016 Milltown Road Camp Hill, PA 17011 ?;. 20" .JUL -6 Ai'i fp: p ? ' d4. jy:/..1: Y 13 MARLIN K. ULSH AND CLARA A. ULSH, : IN THE COURT OF COMMON PLEAS OF husband and wife, TRUSTEES OF THE : CUMBERLAND COUNTY, PENNSYLVANIA MARLIN K. ULSH AND CLARA A. ULSH : REVOCABLE TRUST DATED MAY 4, 1998: Plaintiffs V. NEAL E. WOOD, JR., ANTHONY J. SEBASTIAN AND JAMIE A. SEBASTIAN, NO. Q 9- t Q 9 O husband and wife, JAMES B. TITZEL, TODD G. MATTSON AND HEATHER RAE: ACTION TO QUIET TITLE - AGREEMENT MATTSON, husband and wife, SHARON R. : PASTOR, JOHN F. SHUEY, KATHLEEN : SULLIVAN, JASON C. RICHARDS AND . TAMMY L. RICHARDS, husband and wife, : ELIZABETH M. BERRIER, DREHER L. . RICHARDS AND GWENDOLYN I. RICHARDS, husband and wife, GERALD J. YANCISIN AND CHRISTINE M. YANCISIN, husband and wife, CARL T. PEIFFER AND : KATHLEEN M. PEIFFER, husband and wife: MILAN PERLICK AND JILL L. PER 1ACK, : husband and wife, AARON C. MILLS, JESSICA L. KARAFFA, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: J y N? 11, Z Q a 1 V ' John huey Address: Lot No. 6, Block A 2020 Milltown Road Camp Hill, PA 17011 Oz DU9 JU -6 , r to Q e?lt?9J ?r ? r r ? r ?nY MARLIN K. ULSH AND CLARA A. ULSH, husband and wife, TRUSTEES OF THE MARLIN K. ULSH AND CLARA A. ULSH REVOCABLE TRUST DATED MAY 4, 1998: Plaintiffs V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEAL E. WOOD, JR., ANTHONY J. SEBASTIAN AND JAMIE A. SEBASTIAN, NO. c)cl _ L4 (n d husband and wife, JAMES B. TITZEL, TODD G. MATTSON AND HEATHER RAE: ACTION TO QUIET TITLE - AGREEMENT MATTSON, husband and wife, SHARON R. : PASTOR, JOHN F. SHUEY, KATHLEEN : SULLIVAN, JASON C. RICHARDS AND . TAMMY L. RICHARDS, husband and wife, : ELIZABETH M. BERRIER, DREHER L. . RICHARDS AND GWENDOLYN I. RICHARDS, husband and wife, GERALD J. YANCISIN AND CHRISTINE M. YANCISIN, husband and wife, CARL T. PEIFFER AND : KATHLEEN M. PEIFFER, husband and wife: MILAN PERLICK AND JILL L. PERLICK, : husband and wife, AARON C. MILLS, JESSICA L. KARAFFA, . Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: ?)", e 2-4?, `Z ooq 7)Az? Nea E. Wood Address: Lot No. 1, Block A 2000 Milltown Road Camp Hill, PA 17011 T1J-? r°!r'c Of. Z1?09 JUL ??: 0 7 t cv;?r MARLIN K. ULSH AND CLARA A. ULSH, : IN THE COURT OF COMMON PLEAS OF husband and wife, TRUSTEES OF THE MARLIN K. ULSH AND CLARA A. ULSH REVOCABLE TRUST DATED MAY 4, 1998: Plaintiffs V. CUMBERLAND COUNTY, PENNSYLVANIA NEAL E. WOOD, JR., ANTHONY J. SEBASTIAN AND JAMIE A. SEBASTIAN, NO. C) OC? O husband and wife, JAMES B. TITZEL, TODD G. MATTSON AND HEATHER RAE: ACTION TO QUIET TITLE - AGREEMENT MATTSON, husband and wife, SHARON R. : PASTOR, JOHN F. SHUEY, KATHLEEN : SULLIVAN, JASON C. RICHARDS AND . TAMMY L. RICHARDS, husband and wife, : ELIZABETH M. BERRIER, DREHER L. . RICHARDS AND GWENDOLYN I. RICHARDS, husband and wife, GERALD J. YANCISIN AND CHRISTINE M. YANCISIN, husband and wife, CARL T. PEIFFER AND : KATHLEEN M. PEIFFER, husband and wife: MILAN PERLICK AND JILL L. PERLICK, : husband and wife, AARON C. MILLS, JESSICA L. KARAFFA, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: tP /Z Z/o f Address: Lot No. 20, Block D 925 Shetter Lane Camp Hill, PA 17011 o-, Aaron C. Mills essica L. Karaffa t?(?;,D-.,-,14-:j ?A OF THE ??ARY 2DO9 JUL _6 ?? lo: MARLIN K. ULSH AND CLARA A. ULSH, : IN THE COURT OF COMMON PLEAS OF husband and wife, TRUSTEES OF THE : CUMBERLAND COUNTY, PENNSYLVANIA MARLIN K. ULSH AND CLARA A. ULSH : REVOCABLE TRUST DATED MAY 4,1998: Plaintiffs V. NEAL E. WOOD, JR., ANTHONY J. SEBASTIAN AND JAMIE A. SEBASTIAN, NO. c cl - 4 0C1 O husband and wife, JAMES B. TITZEL, TODD G. MATTSON AND HEATHER RAE: ACTION TO QUIET TITLE - AGREEMENT MATTSON, husband and wife, SHARON R. : PASTOR, JOHN F. SHUEY, KATHLEEN : SULLIVAN, JASON C. RICHARDS AND . TAMMY L. RICHARDS, husband and wife, : ELIZABETH M. BERRIER, DREHER L. . RICHARDS AND GWENDOLYN I. RICHARDS, husband and wife, GERALD J. YANCISIN AND CHRISTINE M. YANCISIN, husband and wife, CARL T. PEIFFER AND : KATHLEEN M. PEIFFER, husband and wife: MILAN PERLICK AND JILL L. PERLICK, : husband and wife, AARON C. MILLS, JESSICA L. KARAFFA, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: Milan Perlick Address: Lot No. 19, Block D 2128 Milltown Road Camp Hill, PA 17011 ?069 j6t -6 MARLIN K. ULSH AND CLARA A. ULSH, : IN THE COURT OF COMMON PLEAS OF husband and wife, TRUSTEES UY "brit: MARLIN K. ULSH AND CLARA A. ULSH REVOCABLE TRUST DATED MAY 4, 1998: Plaintiffs V. CUMBERLAND COUNTY, PENNSYLVANIA NEAL E. WOOD, JR., ANTHONY J. SEBASTIAN AND JAMIE A. SEBASTIAN, : NO. Oct -4CP10 husband and wife, JAMES B. TITZEL, TODD G. MATTSON AND HEATHER RAE: ACTION TO QUIET TITLE - AGREEMENT MATTSON, husband and wife, SHARON R. : PASTOR, JOHN F. SHUEY, KATHLEEN : SULLIVAN, JASON C. RICHARDS AND . TAMMY L. RICHARDS, husband and wife, : ELIZABETH M. BERRIER, DREHER L. . RICHARDS AND GWENDOLYN I. RICHARDS, husband and wife, GERALD J. YANCISIN AND CHRISTINE M. YANCISIN, husband and wife, CARL T. PEIFFER AND : KATHLEEN M. PEIFFER, husband and wife: MILAN PERLICK AND JILL L. PERLICK, : husband and wife, AARON C. MILLS, JESSICA L. KARAFFA, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: e " 20 - 0 T. Todd G. Mattson Address: Lot No. 4, Block A 2016 Milltown Road Camp Hill, PA 17011 cuu, © 7 2 MARLIN K. ULSH AND CLARA A. ULSH, husband and wife, TRUSTEES OF THE MARLIN K. ULSH AND CLARA A. ULSH REVOCABLE TRUST DATED MAY 4, 1998: Plaintiffs V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEAL E. WOOD, JR., ANTHONY J. SEBASTIAN AND JAMIE A. SEBASTIAN, NO. ©q - H OI 1 C) husband and wife, JAMES B. TITZEL, TODD G. MATTSON AND HEATHER RAE: ACTION TO QUIET TITLE - AGREEMENT MATTSON, husband and wife, SHARON R. : PASTOR, JOHN F. SHUEY, KATHLEEN : SULLIVAN, JASON C. RICHARDS AND . TAMMY L. RICHARDS, husband and wife, : ELIZABETH M. BERRIER, DREHER L. . RICHARDS AND GWENDOLYN I. RICHARDS, husband and wife, GERALD J. : YANCISIN AND CHRISTINE M. YANCISIN, husband and wife, CARL T. PEIFFER AND : KATHLEEN M. PEIFFER, husband and wife: MILAN PERLICK AND JILL L. PERLICK, : husband and wife, AARON C. MILLS, JESSICA L. KARAFFA, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: d d Address: Lot No. 19, Block D 2128 Milltown Road Camp Hill, PA 17011 (?Yv Jil . Perlick OF F]C?r._?..y y JUL /^1/ AEI to: Q 7 cbt i r? .. , MARLIN K. ULSH AND CLARA A. ULSH, husband and wife, TRUSTEES OF THE MARLIN K. ULSH AND CLARA A. ULSH REVOCABLE TRUST DATED MAY 4,1998: Plaintiffs V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEAL E. WOOD, JR., ANTHONY J. SEBASTIAN AND JAMIE A. SEBASTIAN, NO. 09-4090 Civil Term husband and wife, JAMES B. TITZEL, TODD G. MATTSON AND HEATHER RAE: ACTION TO QUIET TITLE - AGREEMENT MATTSON, husband and wife, SHARON R. : PASTOR, JOHN F. SHUEY, KATHLEEN : SULLIVAN, JASON C. RICHARDS AND . TAMMY L. RICHARDS, husband and wife, : ELIZABETH M. BERRIER, DREHER L. . RICHARDS AND GWENDOLYN I. RICHARDS, husband and wife, GERALD J. YANCISIN AND CHRISTINE M. YANCISIN, husband and wife, CARL T. PEIFFER AND : KATHLEEN M. PEIFFER, husband and wife: MILAN PERLICK AND JILL L. PERLICK, : husband and wife, AARON C. MILLS, JESSICA L. KARAFFA, Defendants PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint filed by Plaintiffs in the above captioned matter. Respectfully submitted, SALZMANN HUGHES, P.C. Date 2009 By: Lv(L dit4l Susann B. 91orrisdri, Esquire Supreme Court No. 77041 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 (717) 249-6333 Attorney for Plaintiffs IRLEMAKS OF THE 2R9 JUL 14 PH 2: 27 OJ 5:,12 ?e5 c le# ?(v71 2A a a-74% MARLIN K. ULSH AND CLARA A. ULSH, husband and wife, TRUSTEES OF THE MARLIN K. ULSH AND CLARA A. ULSH REVOCABLE TRUST DATED MAY 4,1998: Plaintiffs v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEAL E. WOOD, JR., ANTHONY J. SEBASTIAN AND JAMIE A. SEBASTIAN; NO. Q9-4090 Civil Term husband and wife, JAMES B. TITZEL, TODD G. MATTSON AND HEATHER RAE: ACTION T'O QUIET TITLE -AGREEMENT MATTSON, husband and wife, SHARON R. PASTOR, JOHN F. SHUEY, KATHLEEN SULLTVAN, JASON C. RICHARDS AND TAMMY L. RICHARDS, husband and wife, ELIZABETH M. BERRIER, DREHER L. RICHARD5 AND GWENDOLYN I. RICHARDS, husband and wife, GERALD J. YANCISIN AND CHRISTINE M. YANCISIN, husband and wife, CARL T. PEIFFER AND KATHLEEN M. PEIFFER, husband and wife: MILAN PERLICK AND JILL L. PERLICK, husband and wife, AARON C. MILLS, JESSICA L. KARAFFA, Defendants PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint filed by Plaintiffs in the above captioned matter. Respectfully submitted, SALZMANN HUGHES, P.C. Susann B. Morri on, Esquire Supreme Court No. 77041 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 (717) 249-6333 Attorney for Plaintiffs Date ~ ~ Z (~ °J 0 ,-~~ 7~,~r _ ~.~~~-r~,~~r F ~iili~i ,J;''J~ :~ , .l~ls ~ ~o • oo ~D AMY CI~~ `~1a.5 ~T~' aa9113