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HomeMy WebLinkAbout09-6044JOAN G. SEIDERS vs. IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA PAIGE L. DONOVAN, KATHY A. MYERS, DONN A. KECK, CHAD J KECK, JOEL M. KECK, DONALD R. KECK DEFENDANTS NO. (6)9 - CIVIL ACTION TO QUIET TITLE NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone: 717-249-3166 JOAN G. SEIDERS PLAINTIFF vs. PAIGE L. DONOVAN, KATHY A. MYERS, DONN A. KECK, CHAD J KECK, JOEL M. KECK, DONALD R. KECK DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. of- 66-0 CIVIL : ACTION TO QUIET TITLE COMPLAINT 1. Plaintiff, JOAN G. SEIDERS is an adult individual residing at 2218 James Buchanan Drive, Elizabethtown, Lancaster County, Pennsylvania 17022. 2. Defendant PAIGE L. DONOVAN is an adult individual residing at 2278 Pine Road, Newville, Cumberland County, Pennsylvania 17241. 3. Defendant KATHY A. MYERS is an adult individual residing at 1901 Pine Road, Newville, Cumberland County, Pennsylvania 17241. 4. Defendant DONN A. KECK is an adult individual residing at 2325 Ritner Highway, Carlisle, Cumberland County, Pennsylvania 17013. 5. Defendant CHAD J. KECK is an adult individual residing at 35 Leeds Road, Newville, Cumberland County, Pennsylvania 17241. 6. Defendant JOEL M. KECK is an adult individual residing at 262 Ridge Road, Shippensburg, Cumberland County, Pennsylvania 17257. 7. Defendant DONALD R. KECK is an adult individual residing at 2225 Pine Road, Newville, Cumberland County, Pennsylvania 17257. 8. Plaintiff is the owner of a tract of land situate in Penn Township, Cumberland County, Pennsylvania by virtue of a Deed to Paul Ronald Seiders and Joan G. Seiders, his wife, dated January 14, 1969, recorded in Cumberland County Record Book "B" Volume 23, Page 745, a copy of which is attached hereto, incorporated by reference and marked Exhibit "A". Paul Ronald Seiders died on March 27, 2009, thereby vesting full title in his widow, Joan G. Seiders. 9. The premises described in Deed Book "B" Volume 23, Page 745 were conveyed to Plaintiff and her now deceased husband from her husband's mother. 10. The Plaintiff believes and therefore avers that the premises as described in Deed Book "B" Volume 23, Page 745 failed to include in its description a strip of land approximately 16 feet in width and 510.05 feet in length. 11. The prior Grantor, Marjorie I. Seiders, held title to the aforementioned strip of land by virtue of Deed Book "C" Volume 15, Page 550, a copy of which is attached hereto, incorporated by reference and marked Exhibit "B". 12. The heirs of Paul R. Seiders, who are also the heirs of Marjorie I. Seiders Kornbau, have signed a Quit Claim Deed conveying any interest they may have in the property in question, a copy of which is attached hereto, incorporated by reference and marked Exhibit "C". 13. The Defendants herein named are the heirs at law of Barbara Ann Keck, sister of Paul R. Seiders and grandchildren of Marjorie I. Seiders Kornbau and are the only outstanding heirs who have failed to convey their interest through execution of a quit-claim deed. 14. Plaintiff avers that Marjorie I. Seiders Kornbau did not properly convey her interest in the aforesaid premises by recorded deed, up and until the date of the filing of this Complaint, thereby raising a title objection in the form of an outstanding interest in real estate in that the Deed attached hereto as Exhibit "A" omitted the premises which is the subject matter of this Action. 15. Plaintiffs aver that they and their predecessors in title have been in open. notorious, continuous and adverse possession of the premises set forth in Paragraph 9 herein for a period of time in excess of twenty-one (21) years which would be sufficient to establish adverse possession by the laws of the Commonwealth of Pennsylvania. 16. The Plaintiff desires and needs to have her ownership of said property as herein- above set forth confirmed, and her title to same quieted in order to obtain good and marketable title to same. WHEREFORE, the Plaintiff respectfully requests the Court to enter an order declaring Plaintiff, JOAN G. SEIDERS , the owner in fee simple of the premises described in Paragraph 10 of this Complaint, free and clear of any and all right, title, interest, claim or demand of the said Defendants,PAIGE L. DONOVAN, KATHY A. MYERS, DONN A. KECK, CHAD J. KECK, JOEL M. KECK, DONALD R. KECK and their heirs and assigns, and further barring the said Defendants from denying, impeaching or in any way attacking Plaintiff's title in and to the said premises described in Paragraph 10 above. Respectfully submitted DUNCAN & HARTMAN, P.C. . 11mly William A. Duncan, Esquire Attorney ID 22080 1 Irvine Row, Carlisle, PA 17013 717.249.7780 Dated: 9_ ?_ 0 9 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. AN G. SEIDERS Dated: ?J- - D 9 201-AT-Warranty Deed, Short Form, Act of 1909. Henry Hall, Inc., Indiana, Pa. izbt6s MADE THE I 0 -rb` of our Lord one thousand nine hundred sixty Y"?AF OF THE Ott l .;L. vii u:;crv5 2 ii f1i day of Qut,;: r ;. *.*UTyear 'a?, nine (69) BETWEEN MARJORIE 1. SEIDEHS, widow, of Penn Township, Cumberland County, Pennsylvania, hereinafter called Grantor and PAUL RONALD SEIDERS and JOAN G. SEIDERS, his wife, of Penn Township, Cumberland County, Pennsylvania, hereinafter called Grantee WITNESSETH, that in consideration of One and 00100 ($1.00) Dollars, in hand paid, the receipt whereof is hereby acknowledged, the said grantor do es hereby grant and convey to the said grantees , ALL THAT CERTAIN lot or tract of land situate in Penn Township, C umberl and County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point at a pin on the northern line of a 16 feet wide right-of-way; thence by lands now or formerly of J. S. Seiders, S. C. Griffey, H. F. Kelso, S. P. Bucher, J. S. Seiders, and P. R. Hutchinson, north 04 degrees 21 minutes west 519.34 feet to a point at an iron pin; thence by lands now or formerly of M. Dorosh north 88 degrees 30 minutes 40 seconds east 126.69 feet to a point at an iron pin; thence by lands now or formerly of J. Leer south 88 degrees 47 minutes 20 seconds east 127.41 feet to a point at a stake; thence by lands now or formerly of W. J. Alwood and Otha J. Hassinger south 11 degrees 18 minutes 40 seconds east 550.95 feet to a point on the northern line of said 16 feet wide right-of-way; thence by said north- ern line of said right-of-way north 88 degrees 58 seconds 20 minutes west 324.73 feet mare or less to a point, the place of BEGINNING. THE ABOVE description is taken from a survey made by Thomas Alvin Neff, Registered Surveyor, dated November 27, 1968, and intended to be recorded herewith. SUBJECT, nevertheless, to the restriction that no structure shall be erected on said lot costing less than $5,000.00. "SING part of the same premises which Paul C. Seiders and Dorothy F. Seiders, his wife, granted and conveyed unto Paul S. Seiders and Marjories I. Seiders, his wife, by their deed dated October 29, 1952, and recorded in Deed Book 15-C, page 550, Cumberland County Recorder Cumberland County, Pennsylvania, on October 29, 1952, whereupon title to the above described tract vested in fee simple to the Grantor, herein, as surviving tenant by the entirety. T=i conveyance is from mother to son and Daughter-in-law. 7 Bei 4B, AND the said grantor hereby covenants and agrees that she will warrant generally the property hereby conveyed. IN WITNESS WHEREOF, said grantor the day and year first above written. rsiontb, ozaleb snD Jeliuereb in the Presence of 10 JUSTICE OF THE Commission Expires January 7, :. State of Pennsylvania County of Cumberland On this, the has hereunto set her hand and seal - ---------J kar orie I. Seiders ss. u r day of -------------------- ----------------- SEAL ----------------- SEAL ----------------- • , 19 69 , before me, the undersigned officer, personally appeared Marjorie I. Seiders, a widow known to me (or satisfactorily proven) to be the person whose name is subscribed to the, .,. within instrument, and acknowledged that she has executed the same for the purposes t?a`oR ' contained. ?10" '•r In WITNESS WHEREOF, I hereunto set my hand and official seal. . d v. JUSTtG10 THE PEACE .; Title of Offeeeri? ?? ??• M M COTmissiOn Expires •""'-•••,'` Y January 7, 1974 ? B L1 n; sl '11 ??4. tad 740 State of County of On this, the / day of 19 before me, the undersigned officer, personally appeared /71 d r d w- r -9 known to me (or satisfactorily proven) to be the person whose name subscribed to the within instrument, and acknowledged that JW ?- executed the same for the purposes therein ' contained. In WITNESS WHEREOF, I hereunto set my hand and official seal. ; ]SAL T EE PE A n; -------------- Buz--s A. a. Title ©frQr.'._- My Commission Exz'ires .!emery 1,1 r1.7, ? vV 4 do hereby certify t t the recise reside e of the within named grantee is K P ' ,167- 2, 2-% 19 6 q Attorney for A 64 IQ 0 CH ,q 3 a? 71 to A b h-i 1 Cdtq 0 i-4 z '? G7 N Z 'Q" 0.4 04 0 O H Srq C ? 0 ? V COMMONW TH OF PENNSYLVANIA, County .n n 0 H 188. complete post office address 1 7 Z I-1 I/ r RECORDED on this day of ?__________ A. D. 19a, in the Recorder's Office of said County, in Deed Book' ?8 OC? -4-1 Z "w Vol. --,-,Z-j -------- Page ------ Given under my hand and the a of the said oree te a" ve written. -- --- ----- +?r Recorder. i IA >, 14 t 0 QW9 Ila ad ? ? V A. {i iI qJ'. ',BEGINNING AT AN IRON PIN IN THE NORTHEAST CORNER OF THE INTERSECTION OF SOUTH ENOLA DRI AND H?6HLAND AVENUE; THENCE EASTWARDLY ALONG THE NORTHERN LINE OF HIGHLAND AVENUE ONE HUNDRE TWEPJTY-,IVE (125) FEET TO THE NORTHWEST CORNER OF THE INTERSECTION OF A FI EEN (15) FEET WI ALLEY WITM..HIGHLAND AVENUE; THENCE NORTHWARDLY ALONG THE WESTERN LINE OF SAID FIFTEEN (15) F WIDE ALLEY T'W,ENTY FIVE (25) FEET, MORE OR LESS, TO A POINT AT OR OPP ITE THE CENTER OF THE PARTITION WALL'"DIVIDING PROPERTIES KNOWN AS NO. 112 AND NO. 114 SOH ENOLA DRIVE; THENCE WE WARDLY THROUGH TtiE, CENTER OF THE PARTITION WALL DIVIDING PROPERT S KNOWN AS NO. 112 AND NO. SOUTH ENOLA DRIV6,kAND BEYOND ONE HUNDRED TWENTY-FIVE (125) ^EET TO THE EASTERN LINE OF• SOUTH ENOLA DRIVE; THE`Kf SOUTHWARDLY ALONG THE EASTERN ,LIZING O SOUTH ENOLA DRIVE TWENTY-F IV (,25) FEET, MORE OR LESS, TO AN IRON PIN THE PLACE OF BELT , _ HAVING THEREON ERECTED THE SOUTHERN ONE-HALF OF A Tyfo STORY BRICK AND FRAM_ DWELLING KNOWN AS NO. 114 SOUTH ENOLA D44VE, SOUTH ENOLA, PA. BEING THE SAME PREMISES WHI ° C'H HELEN N. CONRAD, ET AL. BY THEIR DEED DATED APRIL 18, 194 ANDS RECORDED IN THE OFFICE FOR THE'WCORDING OF DEI6S IN AND FOR CUMBERLAND COUNTY IN DEED BOOK N. VOLUME 13, PAGE 32, GRANTED AND CONVEYED JNTO JOHN C. TAYLOR, JR. AND THELMA TAYLOR, HIS WIFE, GRANTORS HEREIN. AND THE SAID GRANTORS DO HEREBY COVEtV+AND AGREE TO AND WITH THE SAID r,RANTEES THAT THE SAID GRANTORS WILL WARRANT GENERALLY TOE IWOPERTY HEREBY CONVEYED. IN WITNESS WHEREOF, SAID GRANTORS HAVE HERI~UNTO SET THEIR HANDS AND SEALS, THE DAY AND YEAR FIRST ABOVE WRITTEN, SEALED AND DELIVERED IN THE PRESENCE OF RALPH A. SHEETZ J" N C. TAYLOR, JR. (SEAL; THEL TAYLOR (SEAL' STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND ON THIS 29TH DAY OF?"r OCTOBER. A.D. 1952, BEFORE ME, HARRY L, ITTLE THE UNDERSIGNED OFF IC PERSONALLY APPEARED JQ'IiN C. TAYLOR, JR., AND THELMA, TAYLOR, HIS WIf'''E, KNOWN TO ME (OR SATIS- FACTORILY PROVEN) T,6 BE THE PERSONS WHOSE NAMES ARE SUBSCRIBED TOT WITHIN INSTRUMENT AND ACKNOWLEDGED THAT;'THEY EXECUTED THE SAME FOR THE PURPOSES THEREIN COrJTA FJED. IN WITNESS" I HEREUNTO SET MY HAND AND OFFICIAL SEAL. SEAL. HARRY L. WITTLE NOTARY PUBLIC J MY COMMISSION EXPIRES SEC. 1\95? 1' HEREBY CERTIFY THAT THE PRECISE RESIDENCE OF 7 HE SAID GRANTEES IS OLA, PA. RALPH A. SHEET$ ATTORNEY FOR GRANTEE NO. 22042 U,jTf7 STATES DEED I10 2q5? THIS DEED, NTC?;?}.RL?tENUE 'M41)5- THE TWENTY-N I NTH'DAY OF OCTOBER PAUL C. SEIDERS ET UX X7.15 TU bOCL'Jl1E?TA?f IN THE YEAR OF OUR LORD ONE THOUSAND NINE HUNDRED AND FIFTY-TWO, JOHN S, & MARJORIE 1. SEIDERS BETWEEN PAUL C. SEIDERS AND DOROTHY F° CONS. $6.500.00 dt? 10'29-52 SEIDERS; HIS WIFE,OF HUNTSDALE, PENN TOWN- LOC. PENN TWP, SHIP, CUMBERLAND COUNTY, PENNSYLVANIA, DATED OCT. 29, 1952 STATE IAA Y HEREINAFTER CALLED GRANTORS, ENTO. OCT. 29, 1952 A N D 1'55 P.M. JOHN S. SEIDERS AND MARJORIE 1. SEIDERS, HIS WIFE, OF HUNTS GALE, PENN TOWNSHIF, CUMBERLAND COUNTY, PENNSYLVANIA, HEREINAFTER CALLED GRANTEES: WITNESSETH, THAT IN COWSIDERATION OF SIX THOUSAND FIVE HUNDRED (96,500) DOLLARS, IN HAND PAID, THE RECEIPT WHEREOF IS HEREBY ACKNOWLEDGED, THE SAIL) GRANTORS DO HEREBY GFIINT AND CONVEY I TO THE SAID GRANTEES, THEIR-HEIRS AND XSSIGNS, ALL THAT CERTAIN TRACT OF LAND SITUATED I COUNTY OF IN THE VILLAGE OF CUMBERLAND AND STATE OF PENN3 HUNTSDALE TO TD WIT:- YLVANIq, MORE PARTICULARLY ' D DE OF PENN, BOUNDED AND DESCRIBED AS Fa ? I BEGINNING AT A POINT IN THE PUBLIC ROAD LOWS, I LANDS OF H, SEIDERS LEADING FROM HUNTSDALE TO pJ NORTH Sg DEGREES GROVE; THEN L ONC LANDS OF p 30 MINUTES EAST A DISTANCE ALONG . BROUGH ESTATE (NOW OF 551 FEET TO A POST, • NORTH 12 DEGREES WEST A D 1 -""?---^- JACKSON) THENCE A- JACKSON), OF 1006.4 FEET • HAS NG AND J R oap; THENCE BY sqp TO A POINT IN A PUBLIC ROAD . LEAR, j , NORTH B2 DEGREES WEST A DISTA KNOWN AS THE ! Of MARY A. COCKLEY THE FOLLOWING POINT; CA SES AND DISTANCES ; THENCE ALONG LANDS OF'213,5 FEET TO A POST; THENCE SOUTH 8 ' SOUTH 3 DEGREES 1 I THENCE NORTH 7 DEGREES 4 MINUTES 5 MINUTES EAST A D POST E 4 DEGREES, 45 MINUTES 5 ` WEST A DISTANCE OF AS THE NONE ROAD WEST a DISTANCE OF 114 FEET TO a POST; THENCE BY SAME SOUTH g 213 FEET TO A POINT IN A THENCE ALONG LANDS OF THOMAS DEGREES 45 MINUTES PUBLIC ROAD KNOWN LEDANE (NOW C. WEIST WEST A DISTANCE OF 12 FEET TO A POIN ; 45 MINUTES ?, M. DORISH, Go HUTCHISON AND S 00TH 4 DEGREES DEGREES 45 MINUTES WEST A DISTANCE F CARRIE ROCM NORTH 85 WEST A, DI STANCE OF 545,5 FEET TO A CORNER; TigENCE ALONG LANDS OFEY CARR ING FROM HUNTSDALE TO PINE GROVE; THENCE 13Y SA ° 166 FEET TO A POINT IN THE PUBLIC ROAD LEA- ; GINNING , SOUTH A DISTANCE I OF 462 FEET TO THE PLACE OF BE CONTAINING 9.73 ACRES I i , MORE OR LESS. HAVING THEREON ERECTED A ? TWO STORY FRAME HOUSE AND I °UTHU THE ABOVE DESCRIPTION 15 TAKEN FROM A SURVEY MADE VEYOR, ON OCTOBER 8, 1945, BY To ELLIOTT MIDDLETON R BEING THE SAME PREMISES CONVEYED To PAUL C • REGISTERED SUR-R. OTTO OTTO, HIS WIFE, DATED FEBRUARY 26 . SEIDERS BY DEED OF ROBERT CUMBERLAND COUNTY . 1946, AND RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS EFOR , PENNSYLVANIA, IN DEED BOOK "0", IT BEING ALSO THE SAME PREMISES WHICH VARIOUS CONUME 13, PAGE 453 CONVEYANCES VOLUME CORDER F DEEDS FOR 0 CUMBERLAND COUNTY CORDED IN THE OFFICE OF THE•RE- ? ELIZABETH BECAME VESTED IN FEE SIMPLE IN MARY ELIZABETH OTT O, MARY I OTTO DIED TESTATE ON DECEMBER EL OF THE REGISTER F 11, 1920, HER WILL BEING DULY FILED FOR PROBATE IN THE OF FICE THE TERMS OF THE SAID WILL , A RECORDED I W. P. S. OTTO WAS APPOINTED N WILL BOOK 31, PAGE 278 By I OTTO. THE SAID WILL READS IN PART AS FOLLOWS:- EXECUTOR OF THE ESTATE OF 3. i HEREBY DIRECT MY SAID EXECUTOR TO SELL ALL OF 'MARY ELIZABETH I BE SITUATED EITHER AT PUBLIC OR PRIVATE ECU MY REAL ESTATE WHERESOEVER THE FO R SUCU PURPOSE ! HEREBY 'AUTHORIZE AND EMPOWER FI MMTO MAK??OR XECUTE THE BEST INTERESTEOF MY S ENE MAY ESTATE aNl? CIENT DEED OR DEEDS TO THE PURCHASER OR PURCHASERS THEREOF. AND DELIVER a GOOD AND SUFFI- I 4. 1 HEREBY GIVE AND BEQUEATH THE PROCEI_DS OF MY ENTIRE ESTATE BOTF' SAID EXECUTOR IN TRUST HOWEVER THAT HE SHALL FROM TIME TO PERSONAL AND'R TE TO MYi BEARING SECURITIES AND COLLECT THE INCOMES SAME AND INTERESTS-ACCRUING THEREON; AND I FURTHER HEkE ' DIRECT THAT MY SAID EXECUTOR SHALL HAVE THE RIGHT TO USE IN SUCH A WAY AND FIT ALL OF THE SAID INCOMES AND INTERESTS RECEIVED FROM SAID TRUST BY MANNER AS HE MAY SEE I ! THAT MY SAID EXECUTOR SHALL HAVE IN HIS DIECRETION TO USE ALL ORgNYFUNDS; I HEREBY ALSO DIRECT SAID TRUST AT SUCH TIME AS HE MAY 'SEE FIT AND F PORTION OF THE PRINCIPAL OF j S0, HE TU BE THE SOLE JUDGE AS OR SUCH PURPOSE AS HE MAY JUDGE IT NECESSARY TO DOI PRINCIPAL OF THE SAID TRUST FUNDSoTHE RIGHT AND NECESSITY TO USE SAID INTEREST AND INCOMES OR THE 5> IN CASE ANY OF THE SAID TRUST FUNDS SHALL REMAIN UNEXPENDE CUTOR THEN I HEREBY ORDER AND DIRECT THAT D AT THE DEATH EXE- 'THE BALANCE OF ANY INCOMES ARISING ON Sa/D TRUST(FUND EAND ANY BALANCE OF THE PRINCIPAL OF SAID FUNDS WHISH MAY R j THE DECEASE OF MY SAID EXECUTOR BE PAID TU BY GRAND-SON EMAIN UNEXPENDED SHALL AT THE RIVED AT , TIME OF I THE AGE OF- TWENTY-F I w ROBERT OTT O, PROVIDING HE S VE YEARSe HALL HAVE AR SAID EXECUTOR W,P.S I i ? . OTTO, DIED INTESTATE ON APRIL 30, i TATE AS DIRECTED BY PARAGRAPH 942, NEVER HAVING SOLO THE REAL ES- 3 OF THE WILL AS ABOVE SET FORTH. AT THE TIME OF SAID EXECUTOR'S oEaTH,`ROBERT OTTO I t_ - A THE FEE SIMPLE TITLE TO THE SAID REAL ESTATE THUS VESTED N PAST THE AGE OF T WENTY-FIVE YEARS AND M BY VIRTUE OF ruc ¦ a Greater Harrisburg Assam.,, fl IA\ ?f t .l'4:1 i 4.l/?..r:°?/?r'r- '., 0.216A ?'?•I't;? vti 7J'?•.? ? ,? .S ?,c•./A? fir.. f ?:?+ ,?i ' h/•?' !1.?0? o •? ? 1 ?j "*+y .41- 4, •,?,. 1. _ Z ,.,??;• / .;r-,;. '. Y!?', r+'* G r• i e1 tel.r ,1 . ? +,tIM r '1N ti ' Y:? 1 1?:. ' ? V µ/ }•,'??y ?s4 i11( ?•:? ,F T /) r( ?;, .. _ ,? it ^'r'•' :.? ? ..l r o r d.. +? br4, ?.,????.,ao??t??{k1h1?" ,M?.+? 1, x' ;?;!1 ?,• I ? ,rt/ ???r ? /, • "',: 1, ^`?' .'.t ? y . !"'/"A'rs .`F.. e I r r t ?, 3, r .."?' ., C,.. • ?? 1 Td I rr? . %` ?.; L! jI.1'? ..`. ,',?',. is !'' ? •7.'? : i/' . ,?? 1 ? 4N•a F.s , iN vr. 1"19A F• y r 126.f1Y .c• 9 I .'' :,,4!Fe S, r 4 p *p f 1 7 /J ?' 411 - •C•' 1 x , 1 / N , III/ •' I , 7 t• ,.:. r 41 114 ytv.r4? ' y. ` ,, ,N '?•1' a' 1 I.? •q? 1..,?, J .. w}* S?ti' yl?q`y ? plt ? t.? /f•?7.1?.. 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M• '' 'Lw+, ..t?`{ Y ?'? ?, ?,J r[??i+y??y. ? ?/ ? ?`t hf / ' „ ? ? ? ? ?5'y? .'., w .t >? , , x y , ? ; ?,? • t !: r: + t`?I• ar l? 'fi?" .:?? +r 1`11. +. • ,."?4 1 +1'I!' i'R ' 4 ,tr !'.a•'l, ?, atM w;• a r .Jy A?.• ?? +? 1 y? .-{ t ?a+r ?i`_,.?/?+? ir` . -ca ? 1182°p oo w 98.00 0 0 v '^ ?N v T ?11 n85°45'00"w 166.00 V i G y l to , l 1 o O ? A ° o o ... W s87°45'00"w 114.00 q ?3 551.00 '00"e ,A."' 7 1 r r a O ? C_ r S fi Date: 03- Title: Scale: 1 inch = 129 feet -7File: seiders.des -17' QUIT CLAIM DEED MADE the day of , 2009, Jl BETWEEN Joan G. Seiders, surviving spouse of Paul R. Seiders and Cynthia L. Barclay, Gladys K. Seiders, Dawn M. Grimes and Tracy I. Grimes, GRANTORS, AND Joan G. Seiders, widow, of Elizabethtown, Pennsylvania, GRANTEE, WHEREAS, Marjorie I. Kornbau died testate, seized of the hereinafter described tract of land on October 18, 1998; and WHEREAS, under the Last Will and Testament of Marjorie I. Kornbau dated March 7, 1994, in paragraph IV, she devised any and all real estate owned by her at the time of her death unto Paul R. Seiders and Barbara Ann Keck; and WHEREAS, Letters Testamentary were granted to Paul R. Seiders on January 19, 2000, and indexed in the Cumberland County Register of Wills Office to No. 21-00- 0066; and WHEREAS, Paul R. Seiders died March 27, 2009; and WITNESSETH that in consideration of One and 00/100 ($1.00) Dollar in hand paid, the receipt whereof is hereby acknowledged, the said Grantors do hereby remise, release and quitclaim to the said Grantee, party of the second part, her heirs and assigns forever, ALL THAT CERTAIN tract of land situate in Penn Township, Cumberland County, Pennsylvania, as depicted on a property survey for Paul Ronald Seiders & Joan G. Seiders, husband and wife, dated November 27, 1968 and attached hereto. Said tract of land is approximately 16 feet in width and 510.05 feet in length. BEING the remaining portion of the premises which Paul C. Seiders and Dorothy F. Seiders, his wife, granted and conveyed unto John S. Seiders and Marjorie I. Seiders, his wife, by their deed dated October 29, 1952, and recorded in Cumberland County Deed Book 15-C, Page 550. John S. Seiders died on January 12, 1968 whereupon title to the above described tract vested in fee simple to his surviving wife, Marjorie I. Seiders. Marjorie I. Seiders married Wilbert E. Kornbau on November 14, 1986, who survived her. r„r? , The marital interest of Wilbert E. Kornbau was waived by virtue of a post-nuptial agreement dated November 9, 1992 and attached hereto and incorporated by reference. IN WITNESS WHEREOF, the Grantors have hereunto set their hands and seals, the day and year first above written. Witness: Jo n G. Seiders HEIRS TO THE ESTATE OF MARJORIE I. KORNBAU Cy this L. Barclay Gladys . Seiders awn M. Grimes Au?? racy I. mes COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND :SS. On this the IS day of f'?\a, 2009, before me, the undersigned officer, personally appeared Cynthia L. -Barclay, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed same for the purposes therein contained. WITNESS my hand and official seal the day and year first above written. =Mummert. al Kathy Notary Pablic rland Coulj+, Ph ry Aug* Lt, 2011 1 P u b l c COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND :SS. On this the ?/ Sday of 2009, before me, the undersigned officer, personally appeared Gladys K. Seiders, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed same for the purposes therein contained. WITNESS my hand and official seal the day and year first above written. ONWEALTM OF PENNSYLVANIA NOTARIAL SEAL JOAN D. ADAMS, Notary.Public Carlisle Boro Cumberland Countf My Commission Expires March 7, 2011 Rotary Public COMMONWEALTH OF PENNSYLVANIA :SS. COUNTY OF CUMBERLAND .61 On this the day of 2009, before me, the undersigned officer, personally appeared Tracy I. Grimes, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed same for the purposes therein contained. WITNESS my hand and official seal the day and year first above written. P r Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL JAN D. ADAMS, Notary Public isle Dom- Cumberland County --I ssian Expires March 7, 2011. COMMONWEALTH OF PENNSYLVANIA :SS. COUNTY OF CUMBERLAND On this the 0 day of Vrton/ , 2009, before me, the undersigned officer, personally appeared Dawn M. Grimes, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed same for the purposes therein contained. WITNESS my hand and official seal the day and year first above written. C MPvlOfot° V MADAMS, LrH OF PENNSYLVANIA TARIAL SEAL JOAN Notary Public Carlisle Boro., Cumberland County M Commission Expires March 7, 2011 Notary Public COMMONWEALTH OF PENNSYLVANIA :SS. COUNTY OF CUMBERLAND On this the Y' day of L)6'?'p , 2009, before me, the undersigned officer, personally appeared Joan G. Seiders, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed same for the purposes therein contained. WITNESS my hand and official seal the day and year first above written. PLNNSYLVAN!A NOTARIAL SEAL JOAN D. ADAMS, Notary Public Carlisle Boro., Cumberland County My Commission Expires March 7, 2011 Notary Public I hereby certify that the precise mailing address of the Grantees is as follows: 45 Leeds Road, Newville, PA 17241 Attorney for Grantees, NTS ZOno S EP -3 PI) CU, ? 7SF? SD 1!ao?. atf Ax 2 3013P Sheriffs Office of Cumberland County R Thomas Kline F L) tr^:E Sheriff ytr ctiuhbrr? _ IT, T+ " i f`' ' ' Ronny Anderson Chi f D t ?? ? r •, : Q ? 20 L2 1,r1 io: o e epu y _ Jody S Smith ?ti OFFICE r s?.RiF ? ' Civil Process Sergeant Edward L Schorpp Solicitor Joan G. Seiders Case Number vs. Paige L. Donovan 2009-6044 SHERIFF'S RETURN OF SERVICE 09/04/2009 05:03 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on September 4, 2009 at 1703 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Paige L. Donovan, by making known unto herself personally, at 2278 Pine Road Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to hei personally the said true and correct copy of the same. 09/04/2009 04:00 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on September 4, 2009 at 1600 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Donn A. Keck, by making known unto herself personally, at 2325 Ritner Highway Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. 09/04/2009 04:49 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on September 4, 2009 at 1649 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Donald R. Keck, by making known unto himself personally, at 2225 Pine Road Newville, Cumberland ounty, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. 09/09/2009 06:30 PM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on August 9, 2009 at 1830 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Joel M. Keck, by making known unto himself personally, at 172 Chamberland Road Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to hirr personally the said true and correct copy of the same. 09/09/2009 05:20 PM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on August 9, 2009 at 1720 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kathy A. Myers, by making known unto herself personally, at 1901 Pine Road Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to her personally the said true and correct copy of the same. 09/18/2009 05:09 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 18, 2009 at 1709 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Paige L. Donovan, by making known unto herself personally, at 135 N. Hanover Street Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $203.84 SO ANSWERS- 04? September 21, 2009 R THOMAS KLINE, SHERIFF Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant CUP0i "I'14# 20, IF C lir' C' 1. Edward L Schorpp Solicitor OF; CE ::;= T-G ,-ERIFF Joan G. Seiders vs. Paige L. Donovan Case Number 2009-6044 SHERIFF'S RETURN OF SERVICE AMENDED 09/04/2009 05:03 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on September 4, 2009 at 1703 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Paige L. Donovan, by making known unto herself personally, at 2278 Pine Road Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to hei personally the said true and correct copy of the same. 09/04/2009 04:00 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on September 4, 2009 at 1600 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Donn A. Keck, by making known unto herself personally, at 2325 Ritner Highway Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. 09/04/2009 04:49 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on September 4, 2009 at 1649 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Donald R. Keck, by making known unto himself personally, at 2225 Pine Road Newville, Cumberland ounty, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. 09/09/2009 06:30 PM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on August 9, 2009 at 1830 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Joel M. Keck, by making known unto himself personally, at 172 Chamberland Road Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to hirr personally the said true and correct copy of the same. 09109/2009 05:20 PM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on August 9, 2009 at 1720 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kathy A. Myers, by making known unto herself personally, at 1901 Pine Road Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to her personally the said true and correct copy of the same. 09/18/2009 05:09 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 18, 2009 at 1709 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Chad J. Keck, by making known unto himself personally, at 135 N. Hanover Street Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $203.84 SO ANSWER September 21, 2009 R THOMAS KLINE, SHERIFF Page 2- AMENDED Joan G. Seiders VS Paige L. Donovan By- Deputy Sheriff 61 By - - ?? zf ? Deputy Sheriff B Deputy Sheriff JOAN G. SEIDERS : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO.2009-6044 CIVIL PAIGE L. DONOVAN, KATHY A. MYERS, DONN A. KECK, CHAD J KECK, JOEL M. KECK, DONALD R. KECK DEFENDANTS : ACTION TO QUIET TITLE PETITION FOR FINAL DECREE TO THE HONORABLE JUDGES OF SAID COURT NOW?r _.. NOW, this day of o?-z ? 009, comes William A. Duncan, Esquire, attorney for the above-named Plaintiff and respectfully represents that an Affidavit has been executed and is attached hereto deposing and saying that a Complaint in the above-captioned Action to Quiet Title, endorsed with Notice to Plead, has been served upon the Defendants by publication pursuant to prior Order dated September 5, 2006 of this Honorable Court and said Defendants have not answered said Complaint, entered an appearance or initiated an action in ejectment although the time to do so has expired. WHEREFORE, the Plaintiffs move this Honorable Court to enter judgment in their favor and against the Defendants and grant the Plaintiffs the relief prayed for in their Complaint in accordance with Pa. R.C.P. 1066(a) and (b)(1). Respectfully submitted, \ I ? n ?11A A (A A A William A. Duncan, Esquire Attorney ID 22080 1 Irvine Row, Carlisle, PA 17013 717.249.7780 4 JOAN G. SEIDERS vs. NO.2009-6044 CIVIL PAIGE L. DONOVAN, KATHY A. MYERS, DONN A. KECK, CHAD J KECK, JOEL M. KECK, DONALD R. KECK DEFENDANTS : ACTION TO QUIET TITLE AFFIDAVIT William A. Duncan, Esquire, being duly sworn according to law, deposes and says that: 1. Service on all Defendants was made by the Office of the Sheriff of Cumberland County with the last date of Service being September 18, 2009. 2. Twenty (20) days have elapsed since the last date of Service. 3. No responsive pleading has been filed by any party to the Complaint, no appearances have been entered and no action in ejectment has been initiated against Plaintiff. N 1 X l AAA Sworn and subscribed to before me this day of October, 2009. Nbt4y Public N000"Sal Kathy L. Mwq"K N OKY POlic Carlisle BotguSk !F!'• PA My Co lmmil a Ll, 2011 IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA William A. Duncan, Esquire Attorney ID 22080 1 Irvine Row, Carlisle, PA 17013 717.249.7780 (; ' `6'ils3iSt'X< tiF9iFi idYtt7? Sheriff s Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Joan G. Seiders vs. Paige L. Donovan Case Number 2009-6044 SHERIFF'S RETURN OF SERVICE AMENDED 09/04/2009 05:03 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on September 4, 2009 at 1703 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Paige L. Donovan, by making known unto herself personally, at 2278 Pine Road Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to hei personally the said true and correct copy of the same. 09/04/2009 04:00 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on September 4, 2009 at 1600 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Donn A. Keck, by making known unto herself personally, at 2325 Ritner Highway Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. 09/04/2009 04:49 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on September 4, 2009 at 1649 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Donald R. Keck, by making known unto himself personally, at 2225 Pine Road Newville, Cumberland ounty, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. 09/09/2009 06:30 PM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on August 9, 2009 at 1830 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Joel M. Keck, by making known unto himself personally, at 172 Chamberland Road Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to hirr personally the said true and correct copy of the same. 09/09/2009 05:20 PM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on August 9, 2009 at 1720 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kathy A. Myers, by making known unto herself personally, at 1901 Pine Road Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to her personally the said true and correct copy of the same. 09/18/2009 05:09 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 18, 2009 at 1709 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Chad J. Keck, by making known unto himself personally, at 135 N. Hanover Street Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $203.84 SO ANSWER September 21, 2009 R THOMAS KLINE, SHERIFF Page 2- AMENDED Joan G. Seiders VS Paige L. Donovan By Deputy Sheriff By_ Deputy Sheriff B Deputy Sheriff f i ' t 712E: 20 ?9 0C 1 Y 3 t' -1a1 4; 0 u i 4.5 1 ; .? I; A.? /1 OCT 14 20090 JOAN G. SEIDERS VS. PLAINTIFF PAIGE L. DONOVAN, KATHY A. MYERS, DONN A. KECK, CHAD J KECK, JOEL M. KECK, DONALD R. KECK DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO.2009-6044 CIVIL : ACTION TO QUIET TITLE DECREE OF COURT AND NOW, TO WIT, this _ day of QCA? , 2009, an Affidavit of Service of the Complaint with Notice to Plead being attached hereto and no Answer having been received from the Defendants, and upon cdnsideration of the foregoing Petition and upon motion of William A. Duncan, Esquire, Attorney for Plaintiff, IT IS HEREBY ORDERED, ADJUDGED AND DECREED that title to the premises that is the subject of this action is hereby vested in the Plaintiff, said tract more particularly described as follows: All that certain parcel of land situate in Penn Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to with: On the North by lands now or formerly of Joan Seiders; on the East by lands now or formerly of Hassinger; on the South by lands now or formerly of Ruth Niles and lands now or formerly of William Varner, et ux and on the West by Leeds Road. CONTAINING sixteen (16) feet in front on Leeds Road and extending 510.05 feet more or less, to the rear of the tract. BEING part of tax parcel Number 31-32-2313-023 IT IS FURTHER ORDERED AND DECREED that each of the Defendants are forever barred from asserting any right, lien, title or interest in the land inconsistent with the interest or claim of the Plaintiff s title to said land; from issuing maintaining any action attacking the same, or from encumbering, mortgaging or conveying the same, or any part thereof, unless an action of ejectment is filed against the Plaintiffs for recovery of the same within thirty (30) days. BY THE CWRT: J. FILED-f FFICE F THE F'1.1.0 P CC NOTARY 2009 OCT 15 AM 11: 4 1 1 -0 k??k j6E.L Keck, c1,. d-- J?S, c-_ 9-b? myee-s ?? E- -I w JOAN G. SEIDERS : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO.2009-6044 CIVIL PAIGE L. DONOVAN, KATHY A. MYERS, DONN A. KECK, CHAD J KECK, JOEL M. KECK, DONALD R. KECK : DEFENDANTS : ACTION TO QUIET TITLE PRAECIPE Sir, Enter on Appearance Docket and on Decree a notation that the Defendants failed to take action directed in the Decree of Court dated October 15, 2009 within the time therein limited; and transmit to the Recorder of Deeds a certified copy of the Decree containing the notation above described. DUNCAN & HARTMAN, P.C. r/ William ADunbW, squire Attorney ID 22080 1 Irvine Row, Carlisle, PA 17013 717.249.7780 JOAN G. SEIDERS and JANET F. KLIGGE, husband and wife PLAINTIFFS vs. DOROTHY A. COY, CHARLES R. COY JACKIE L. COY, SHIRLEY A. SHIELDS WILLIAM N. COY, PATSY L. COY, THEIR HEIRS, EXECUTORS AND ASSIGNS DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-4989 CIVIL : ACTION TO QUIET TITLE AFFIDAVIT William A. Duncan, Esquire, being duly sworn according to law, deposes and says that: 1. A Decree of Court was entered on the above-captioned matter on October 15, 2009 requiring the Defendants to file an action of ejectment. 2. A copy of the notice was served on each Defendant on by first-class, postage pre-paid mail, sent on October 16, 2009 to the last known address of each Defendant. Copies of the proof of mailing are attached hereto. 3. Thirty (30) days have elapsed since the notices were mailed to the Defendants. 5. No responsive pleading has been filed by any party to the Complaint, no appearances have been entered and no action in ejectment has been initiated against Plaintiffs. Sworn ands scribed to before me this / P'Tay of November, 2009. otary Public ONWEALTH OF PENNSYLVANIA ??c q't'? William A. Duncan, Esquire Attorney ID 22080 1 Irvine Row, Carlisle, PA 17013 717.249.7780 NOTARIAL SEAL JOAN D. ADAMS, Notary Public Carlisle Boro., Cumberland County My Commission Expires. March 7, 2011 a? DUNCAN & HARTMAN, P.C. malls Attorneys at Law Ian , 1 Irvine Row a= Carlisle, PA 17013 ` ?00, PS DD0 n C C1 X, crnocn••v z• •wrm 0 C)Z0 m pta 0 L N) 41 ps Furym 3817, April 2007 PSN 7530-02-000.9065 DUNCAN & HARTMAN, P.C. P b Attorneys at Law or maO 1 Irvine Row a' 16 ?009, Carlisle, PA 17013 ?t{ c o O n c: M n 00 NA T ? tD• D i VI CO7ofn.••? o: W • r O v?_ --I-I •WI m V I m p$ Fam W7, April 2007 PSN 7530-02-000-9065 a? ?o ? DUNCAN & HARTMAN, P.C. psolorm a i i, Attorneys at Law ?E 1 Irvine Row Carlisle, PA 17013 E.fln. 16 IpoN/VA ?- 1 sP PS Form .4817, April 2007 PSN 7530-02-000.9065 n c O D S O 9? ?mw ?? fA D DUNCAN & HARTMAN, P.C. Attorneys at Law 1 Irvine Row Carlisle, PA 17013 To: A 1 L, DnAI 0 V,4 j1 'A 7 1-3 piW1?-r Vr p!VWVI I , ?A 17,R 1-1I Wtj 16 S•? O C) C CD .fiff M-4mi4 I L31 EED D A m PS Form 3817, April 2007 PSN 7530-02-000-9065 DUNCAN & HARTMAN, P.C. 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