HomeMy WebLinkAbout09-4091CARL T. PEIFFER AND KATHLEEN M. : IN THE COURT OF COMMON PLEAS OF
PEIFFER, husband and wife, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V.
NEAL E. WOOD, JR., ANTHONY J.
SEBASTIAN AND JAMIE A. SEBASTIAN, : NO. 0 9 - 4 D ?tJ`?
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, MARLIN K. ULSH AND
CLARA A. ULSH, husband and wife,
MILAN PERLICK AND JILL 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 fe4lovAng 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
CARL T. PEIFFER AND KATHLEEN M. : IN THE COURT OF COMMON PLEAS OF
PEIFFER, husband and wife, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V.
NEAL E. WOOD, JR., ANTHONY J.
SEBASTIAN AND JAMIE A. SEBASTIAN, : NO. o R- ?l 0 4 I I:WzQ ??c 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, MARLIN K. ULSH AND
CLARA A. ULSH, 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, Carl T. Peiffer and Kathleen M. Peiffer, husband and wife, are adult
individuals residing at the property they own located at 2124 Milltown Road, Lower Allen
Township, Cumberland County, Pennsylvania (hereinafter referred to as the "Peiffer Property")
pursuant to the deed dated October 29, 1999 and recorded in Book 210, Page 1113 in the Office
of the Recorder of Deeds in and for Cumberland County, Pennsylvania.
2. The Peiffer Property is described as Lot 18, Block D 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 Peiffers 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
Peiffer Property (Lot 18, Block D) and the property owned by Defendants Marlin K. Ulsh and
Clara A.Ulsh (Lot 3, Block C) 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, Carl T. Peiffer and Kathleen M. Peiffer and Defendants Marlin K. Ulsh and Clara A.
Ulsh, as abutting landowners. (Ordinance attached hereto and incorporated herein as Exhibit B).
6. The one-half (1/2) of Playground Drive now owned by the Plaintiffs, Carl T.
Peiffer and Kathleen M. Peiffer, with Tax Parcel No. 13-24-0803-022 and is 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 southeast corner of Lot No. 18, Block D, 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 northwest intersection of Milltown Road and a proposed street having
a width of fifty (50) foot; thence North eleven (11) degrees, thirty (30)
minutes East along the eastern line of said Lot No. 18, Block D on the
aforesaid plan of lots at a distance of one hundred twenty (120.00) feet to
a point being the northeast corner of Lot No. 18, Block D; thence South
seventy-eight (78) degrees thirty (30) minutes East, 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 West, 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,
Date: T G
SALZMANN HUGHES, P.C
By:
Susann B. Morrison, E quire
Supreme Court No. 77041
354 Alexander Spring Road, Ste 1
Carlisle, PA 17015
(717) 249-6333
fill
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
unsworn falsification to authorities.
n s
Carl T. Peiffer
Kath M. Peiffer
Date: ro - I - &Cr
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ORDINANCE NO. 2008 -06
io- 'Iw?lu
? IIIN?9I?
oaisn7
AN ORDINANCE OF THE BOARD OF COMMISSIONERS OF
LOVER 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.
acation will be effective upon completion of a final report and upon filing
"lerk of the Court of Quarter Sessions in the Court of Common Pleas of
(A*4stant) Secretary
LOWER ALLEN TOWNSHIP
BOARD OF COMMISSIONERS
? 1.
e President
Exhibit B
EXHIBIT "A"
Beginning in the southwest comer 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 comer 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 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.
„YOWERALLEN TOWNSH/P
LEV-
2233 GETTYSBURG ROAD • CAMP MILL, PENNSYLVANIA 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,
County of Cumberland, Commonwealth of Pennsylvania, this 26th day of
Township Secretary
Phone: (717) 975-7575 • www.lower-allen.pa.us
AFFIDAVYT
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. Ulsh, 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.
Carl -.- Pe ffer-
Kathl Peiffer
`? ? 2Y&
Marimi U Ih.
Affirmed and subscribed to before me
thid'e'day of '2009
NOTARY "LIC
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Kandy L Coyle. Notary Public
South Middleton Twp., Cumberland County
My Commission Bores July 6, 2010
Member, Pennsylvania Association of Notaries
Clara-A.-Ulsh
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
RECORDER O D DS
1700
* - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
IIIIIIIIIIIIIIIII 11111111111
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 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 corner 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.
011
Lot No. 1, Block A 6'4
6tow 11?fq V
2000 Milltown Road Neal E. Wood, Jr.
Loretta V. Wood (deceased)
Lot No. 2, Block A L SIM A"ChJ-4
2008 Milltown Road Anthony J. Sebastian
CSC J4M*X'HEd)
Jamie A. Sebastian
Lot No, 3, Block A
2014 Milltown Road J o B. Titzel
`IV
Esther C. Titzel (deceased)
Lot No. 4, Block A GSM AnACtf1O)
2016 Milltown Road Todd G. Mattson
x
Heather Rae Mattson
Lot No. S, Block A
2018 Milltown Road Sharon R. Pastor
y ,
Lot No. 6, Block A
2020 Milltown Road Jo . Shuey
Suzanne S. Shuey 1
Lot No. 1, Block B
2100 Milltown Road
Lot No. 2, Block B
2104 Milltown Road
Lot No. 3, Block B
2108 Milltown Road
Elizabe . Berner
thleen Sullivan
Lot No. 1, Block C
2112 Milltown Road `-15reher L. Richards
Aq d, U,
Gwendol . Richards
f.
Lot No. 2, Block C
2116 Milltown Road Gerald J. cis n
C ? yn ,
Christine M. Yancisw
Lot No. 3, Block C
2120 Milltown Road Marlin K. Ulsh, Trustee
*Releasing rights only to the
one-half of Playground Dr. not
?ct? t .
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
i cCarl T. Peiffer
the
not
D
Kathleen M. Peiffer **
z
c
Milan Perlick
(sQ err ro)
Jill L. Perlick
i?
Lax
Aaron C. Mills
J ssica L Karaffa
Lot No. 4, Block A
2016 Milltown Road Todd G. Mattson
Lot No. 2, Block A---
2008 Milltown Road nthony I Sebastian
Jamie A. S astian
f:
Lot No. 19, Block D
2128 Milltown Road 1 L. Perlick
ALED-Dt_T: ire
C \F f
-19 ?, 5U
Ck_,_ 39 y
, C" J'I?U' a- r7 -7 9 311
"To
CARL T. PEIFFER AND KATHLEEN M. : IN THE COURT OF COMMON PLEAS OF
PEIFFER, husband and wife, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V.
NEAL E. WOOD, JR., ANTHONY J.
SEBASTIAN AND JAMIE A. SEBASTIAN, NO. O C? - Lt OR I
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, MARLIN K. ULSH AND
CLARA A. ULSH, 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: (v 69
Address: Lot No. 3, Block C
2120 Milltown Road
Camp Hill, PA 17011
Marlin K. Ulsh, Trustee
??a. 6r,'4?
Clara A. Ulsh, Trustee
TAR
?'l''A v4,',f;ei?i''
CARL T. PEIFFER AND KATHLEEN M. : IN THE COURT OF COMMON PLEAS OF
PEIFFER, husband and wife, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V.
NEAL E. WOOD, JR., ANTHONY J.
SEBASTIAN AND JAMIE A. SEBASTIAN, NO. CM - 409
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, MARLIN K. ULSH AND
CLARA A. ULSH, 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":5 Aj %0- ?3
a o'U q
/3. i
Ja a B. Titzel
Address: Lot No. 3, Block A
2014 Milltown Road
Camp Hill, PA 17011
1D?y Jut
` 6 /p: 05
CUAd<<:
CARL T. PEIFFER AND KATHLEEN M. : IN THE COURT OF COMMON PLEAS OF
PEIFFER, husband and wife, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V.
NEAL E. WOOD, JR., ANTHONY J.
SEBASTIAN AND JAMIE A. SEBASTIAN, NO. q - y Oq 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 I.
RICHARDS, husband and wife, GERALD J.
YANCISIN AND CHRISTINE M. YANCISIN,
husband and wife, MARLIN K. ULSH AND
CLARA A. ULSH, 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
Address: Lot No. 5, Block A
2018 Milltown Road
Sharon R. Pastor
Camp Hill, PA 17011
a^n .,
;/? hL LJ i ,',r
OF ? J
2009 jug ? 6 Q
Cl,??'?fi?•
CARL T. PEIFFER AND KATHLEEN M. : IN THE COURT OF COMMON PLEAS OF
PEIFFER, husband and wife, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V.
NEAL E. WOOD, JR., ANTHONY J.
SEBASTIAN AND JAMIE A. SEBASTIAN, NO. cl pq
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, MARLIN K. ULSH AND
CLARA A. ULSH, 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: (D1 ,5'1o
Address: Lot No. 2, Block C
2116 Milltown Road
Camp Hill, PA 17011
Gerald J Y c'si
Christine Yancisi
TAP.
2G?Q9 "UL -6 Ail 10: p
cull
ooll
CARL T. PEIFFER AND KATHLEEN M. : IN THE COURT OF COMMON PLEAS OF
PEIFFER, husband and wife, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V.
NEAL E. WOOD, JR., ANTHONY J.
SEBASTIAN AND JAMIE A. SEBASTIAN, NO.
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, MARLIN K. ULSH AND
CLARA A. ULSH, 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.
--/ 9- 4)
Date:
Address: Lot No. 1, Block C
2112 Milltown Road
Camp Hill, PA 17011
A104_-.--_0__(*1'4"4A01_?
OF Tpc
?. i7/1
1119 JuL - 6 6?. 0 a
CARL T. PEIFFER AND KATHLEEN M. : IN THE COURT OF COMMON PLEAS OF
PEIFFER, husband and wife, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V.
NEAL E. WOOD, JR., ANTHONY J.
SEBASTIAN AND JAMIE A. SEBASTIAN, NO. ypcj 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, MARLIN K. ULSH AND
CLARA A. ULSH, 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 • /$ .d 9
Address: Lot No. 2, Block B
2104 Milltown Road
Camp Hill, PA 17011
nT?IRY
2 Og jUL t-I lo: 0
CARL T. PEIFFER AND KATHLEEN M. : IN THE COURT OF COMMON PLEAS OF
PEIFFER, husband and wife, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V.
NEAL E. WOOD JR. ANTHONY J.
SEBASTIAN ANWIMME A. SEBASTIAN, NO. 0 C1 - Ll 09 ,
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, MARLIN K. ULSH AND
CLARA A. ULSH, 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: C-0 l°l - O} A
Elizabeth Beier
Address: Lot No. 3, Block B
2108 Milltown Road
Camp Hill, PA 17011
'.' ^I'"1Py 9'u
cUt?
CARL T. PEIFFER AND KATHLEEN M. : IN THE COURT OF COMMON PLEAS OF
PEIFFER, husband and wife, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V.
NEAL E. WOOD, JR., ANTHONY J.
SEBASTIAN AND JAMIE A. SEBASTIAN, NO. O R- 4 0 9 1
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, MARLIN K. ULSH AND
CLARA A. ULSH, 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:
u??
K ja"M1(j,AA'hleen Sullivan
Address: Lot No. 1, Block B
2100 Milltown Road
Camp Hill, PA 17011
Inc.
kliy
a..rt 41F?
CARL T. PEIFFER AND KATHLEEN M. : IN THE COURT OF COMMON PLEAS OF
PEIFFER, husband and wife, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V.
NEAL E. WOOD, JR., ANTHONY J.
SEBASTIAN AND JAMIE A. SEBASTIAN, NO. O Cj _ Lt O Cl
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, MARLIN K. ULSH AND
CLARA A. ULSH, 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: L .9a?2 9
H ather Rae Mattson
Address: Lot No. 4, Block A
2016 Milltown Road
Camp Hill, PA 17011
FILFD
?i 'fit:, ) i
2009 JUL -6 A? N !0.0
cLiVItji }
CARL T. PEIFFER AND KATHLEEN M.
PEIFFER, husband and wife,
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 °I - L409 1
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, MARLIN K. ULSH AND
CLARA A. ULSH, 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: J Uu t^ N I ZOO?
v'
- a4ln" I "I(?/z
John F huey
Address: Lot No. 6, Block A
2020 Milltown Road
Camp Hill, PA 17011
ALED I f .
IT Twf: { ''1 ray
2009 JUL -6 ht"r JIG: 05
? ? ??J???Tttr
PEi
CARL T. PEIFFER AND KATHLEEN M. : IN THE COURT OF COMMON PLEAS OF
PEIFFER, husband and wife, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V.
NEAL E. WOOD, JR., ANTHONY J.
SEBASTIAN AND JAMIE A. SEBASTIAN, NO. d c1 - y C7 Q j
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, MARLIN K. ULSH AND
CLARA A. ULSH, 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: `Lc o c'
Address: Lot No. 1, Block A
2000 Milltown Road
Camp Hill, PA 17011
Neal E. Wood
FLEA
2009 JUL -6 kIN 10: 0
CARL T. PEIFFER AND KATHLEEN M. : IN THE COURT OF COMMON PLEAS OF
PEIFFER, husband and wife, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V.
NEAL E. WOOD, JR., ANTHONY J.
SEBASTIAN AND JAMIE A. SEBASTIAN, NO. C7 C[ 4 OC?
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, MARLIN K. ULSH AND
CLARA A. ULSH, 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: ?Q/a /'9
Address: Lot No. 20, Block D
925 Shetter Lane
Camp Hill, PA 17011
Aaron C. Mills
4 Je ica 7? /9
L. Karaffa
4??4
FILE D-!t;E
(fir THE I'P ',,N Y
2009 JUL -6 X1`110: 04
?'L?.l v1?.,1w ??L?wrJ?p?•d?,
CARL T. PEIFFER AND KATHLEEN M. : IN THE COURT OF COMMON PLEAS OF
PEIFFER, husband and wife, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V.
NEAL E. WOOD, JR., ANTHONY J.
SEBASTIAN AND JAMIE A. SEBASTIAN, : NO. C) ot - Li c) 01I
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, MARLIN K. ULSH AND
CLARA A. ULSH, 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: /.-> 7? LZ
X Z"
ilan Perlick
Address: Lot No. 19, Block D
2128 Milltown Road
Camp Hill, PA 17011
71 ?Le?„is il??
2009 JUL -6 AM ia: 0
CARL T. PEIFFER AND KATHLEEN M. : IN THE COURT OF COMMON PLEAS OF
PEIFFER, husband and wife, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs ,
V.
NEAL E. WOOD, JR., ANTHONY J.
SEBASTIAN AND JAMIE A. SEBASTIAN, NO. ?q _ ypo?
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, MARLIN K. ULSH AND
CLARA A. ULSH, 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: L - 9D 0q-
Todd G. Mattson
Address: Lot No. 4, Block A
2016 Milltown Road
Camp Hill, PA 17011
"" JUL All 10: 0 ?
CARL T. PEIFFER AND KATHLEEN M. : IN THE COURT OF COMMON PLEAS OF
PEIFFER, husband and wife, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V.
NEAL E. WOOD, JR., ANTHONY J.
SEBASTIAN AND JAMIE A. SEBASTIAN, : NO. Qq _ L{ Ocl I
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, MARLIN K. ULSH AND :
CLARA A. ULSH, 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: /x-? /a0(01
,`
M v. Perlick
Address: Lot No. 19, Block D
2128 Milltown Road
Camp Hill, PA 17011
OFITHE
2009 JUL - 6 AM !J: 0 4
cufvit?
CARL T. PEIFFER AND KATHLEEN M. : IN THE COURT OF COMMON PLEAS OF
PEIFFER, husband and wife, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V.
NEAL E. WOOD, JR-, ANTHONY J.
SEBASTIAN AND JAMIE A. SEBASTIAN, NO. 09-4091 Civil Term
husband and wife, JAMES B. TITZEL,
TODD G. MATTSON AND HEATHER RAE: ACTION TO QUIET TITTLE - 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, MARLIN K. ULSH AND
CLARA A. ULSH, 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.
By: j IkL B. A4z??
Susann B. NMorrisod, Esquire
Supreme Court No. 77041
354 Alexander Spring Road, Ste 1
Carlisle, PA 17013
(717) 249-6333
Attorney for Plaintiffs
Date ftA-?J-?
2009 Jz UL 1 4 P "i 2: 31
iin,, i• _
ck /4 y6 -7b
p 14 a?- 7 X77
CARL T. PEIFFER AND KATHLEEN M. IN THE COURT OF COMMON PLEAS OF
PEIFFER, husband and wife, :CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
v.
HEAL E. WOOD, JR, ANTHONY J.
SEBASTIAN AND JAMIE A. SEBASTIAN, t NO. 09-4091 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, MARLIN K. ULSH AND
CLARA A. ULSH, 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.
e„ '~,~ f~
Date Q '~ ~
Susann B.'Morrisdn, Esquire
Supreme Court No. 77041
354 Alexander Spring Road, Ste 1
Carlisle, PA 17013
(717) 249-6333
Attorney for Plaintiffs
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