HomeMy WebLinkAbout09-6340COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS NOTICE OF APPEAL
Judicial District, County Of FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. ,3 Ill C ??NOTICE OF APPEAL
00L..GH erry
1 4'GvcrI VAle- Rd PA l70
DATE OF JUDGMENT IN THE CASE OF (Pbk&n ?••• • .• .,
(6 " Can*cX PA C ,? Hr?4Q( II.L.aiAetr ke.
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DOCKETWO. L ? ^ 0000 ? R? TuRE OFS4PPELLANT OR A OR AGENT
I
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2.2. r h. 1. ..
This block will be signed ONLY when this notation is required under Pa.
R.C.P.D.J. No. 10088.
This Notice of Appeal, when received by the District Justice, will operate as a
SUPERSEDEAS to the judgment for possession in this case.
If appellant WAS Claimant (Va 1'8. K.(:.Y.U.J. M. Mu](0) in acuvn
before a District Justice, A COMPLAINT MUST BE FILED within twenty
(20) days after filing the NOTICE of APPEAL.
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before District Justice. IF
NOT USED, detach from copy of nodde of appeal to be served upon appellee.
PRAECIPE: To Prothonotary
Enter rule upon C eve ty-c( Pk c ufA e e'ci Fow -Aciti,-T 0 v? appctlee(s), to file a complaint in this appeal
Nanw a apw"(S)
(Common Pleas No. _02- (03 gO ov .I ) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
of t orstbmsy ar sor RULE: To L'E.'M1'f'ftt PA Cot l° edGDGV?. . appellee(s)
Nana of appol"w
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service
of this rule upon you by personal service or by certified or registered mad.
(2) if you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU.
.'
IV
(3) The date of service of this rule if service was by mail is the date of the mailing.
Date: .200q
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTITRANSCRIPT FORM WITH 1114 21H OF PEAL.
AOPC 312-02
WHITE - COURT FILE TO BE FILED WITH PROTHONOTARY GREEN - COURT FILE YELLOW - APPELLANTS COPY
PINK -COPY TO BE SERVED ON APPELLEE GOLD -COPY TO BE SERVED ON DISTRICT JUSTICE
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on
the date and in the case referenced below.
PROOFi,0F S*$RV/ WAPA
8lEN®TJE YSF EAL ANDRULE tO FILE COiI LA111f9° ~ t m .
(This proof of service MUST BE FILED MTHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ; ss
AFFIDAVIT: I hereby (swear) (affirm) that I served
? a copy of the Notice of Appeal, Common Pleas , upon the District Justice designated therein on
(date of service) 20 , ? by personal service
? by (certified) (registered) mail,
sender's receipt attached hereto, and upon the appellee, (name) on
,20 ? by personal service ? by (certified) (registered) mail,
sender's receipt attached hereto.
(SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE,ME
THIS DAY OF , 20
Signature of official before whom affidavit was made
Signature of alFiant
Title of official
My commission expires on 20
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' . , COMMONWEALTH OF, PENNSYLVANIA
(:f)l INTV n;:• CUMBERLAMD
Mag. Dist. No.:
09-1-03
MDJ Name: Hon.
RICHARD S. DOUGHERTY
Address: 9 8 S IMLA DR STE' 1
RNO
_ LA, , PA
Telephone: (717 j 728-2805 17025
NOTICE OF JUDGMENT/TRANSCRIPT
RESIDENTIAL LEASE
PLAINTIFF: NAME and ADDRESS
rCZ3ITRAL PA COLLEGE EDUC FODPDATIO?
PO BOX 309
ATTN : MATTHEW LANZ
LSIU M[ERDALE, PA 17093 J
v5.
DEFENDANT: NAME and ADDRESS
rLAMARCHE, MICHAEL, ET AL.
119 WERTZVILLE ROAD
MWOLA, PA 17025
MICHAEL LAMARCHE L J
119 WZRTZVILLE ROAD Docket No.: LT-0000277-09
MIOLA, PA 17025 Date Filed: 9/02/09
THIS IS TO NOTIFY YOU THAT:
_-Judgment:_ ` FOR `INLAINTXrr'
® Judgment was entered for: (Name) CE>dPtR7?L PA COLLEGE EDUC. FO>QPD
Fil Judgment was entered against LAKA CHE, MICHAEL in a
Landlord/Tenant action in the amount of $ 121.50 on 9/16/09 (Date of Judgment)
The amount of rent per month, as established by the Magisterial District Judge, is $ 425.00.
' The total amount of the Security Deposit is $ .00
Total Amount Established by MDJ Less • Security Deposit Applied = Adjudicated Amount
Rent in Arrears $ .00-$ .00= $ .00
Physical Damages Leasehold Property $ .00-$ .00= $ .00
Damages/Unjust Detention $ -00-$ -00= $ 00
Less Amt Due Defendant from Cross Complaint - $ .00
Interest (if provided by lease) $
L/T Judgment Amount $ 00
? Attachment Prohibited/ Judgment Costs $ 121.50
42 Pa.C.S. § 8127 Attorney Fees $ -00
? This case dismissed without prejudice. Total Judgment $ 121.50
® Possession granted. Post Judgment Credits $
Post Judgment Costs, $
Certified Judgment Total $
Possession granted if money judgment is no satisfied by time o eviction.
? Possession not granted. ? Defendants are jointly and severally liable.
- - IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN
,TEN„DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERKOF COURTS
OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT, IF ANY. IN
ORDER TO: OBTAIN A .SUPERSEDEAS, THE APPELLANT MUST DEPOSIT;WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF
THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED. HOWEVER, LOW-INCOME AND/OR
SECTION 8 TENANTS SHOULD REFER TO Pa.R.C.P.M.D.J. No. 1008 OR 1013 FOR DIFFERENT PROCEDURES REGARDING THIS DEPOSIT.
IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE PARTY HAS
30 DAYS AFTER THE DATE OF ENTRYOFJ,UDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF
COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION.
THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITFITHE NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL,PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT
HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT. OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT
OF COMMON PLEAS AND NO FURTHER PROCESSIVIAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
SEP 16 2009 Date
Magisterial District Judge
certify that this is a true an o t copy t rec e r s containing the lu gment.
Date , Magisterial District Judge
My commission expires first Monday of January, 2012. SEAL
AO C3t5A-08
• COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: COI®ERLAW
Mag. Dist. No.:
09-1-03
MDJ Name: Hon.
RICHARD S. D017OHERTY
Address: 98 S I=r A DR STS 1
MOLA, PA
Telephone: (717 ) 728-2805 17025
NOTICE OF JUDGMENT/TRANSCRIPT
.PLAINTIFF: RESIDENTIAL LEASE
NAME and ADDRESS
O rt' MTRAL PA COLLEGE EDUC. irouwATIOi
PO BOX 309
ATTN : MATTHM LANE
LSDIO113RDALE, PA 17093 J
VS.
DEFENDANT: NAME and ADDRESS
FL- IIARCHE, MICHML, ET AL.
119 WERTZVILLE ROAD
KOLA, PA 17025
MICHAEL LANARCHE L J
119 NERTZVILLE ROAD Docket No.: LT-0000277-09
all
EAOLA, PA 17025 Date Filed: 9/02/09
THIS IS TO NOTIFY YOU THAT:
Judgment-- _
® Judgment was entered for: (Name) CZNTRAL PA COLLZOE EDUC. POURD
Judgment was entered against _ MISLYAN, KATHY in a
Landlord/Tenant action in the amount of $ 121.50 on 9116109 (Date of Judgment)
The amount of rent per month, as established by the Magisterial District Judge, is $ 425.00.
The total amount of the Security Deposit is $ .00
Total Amount Established by MDJ Less- Security Deposit Applieg=
Rent in Arrears $ . 00 - $ 0 =
Physical Damages Leasehold Property $ .00- .00=
Damages/Unjust Detention $ -00-1 _00=
Less Amt Due Defendant from Cross Complaint -
Interest (if provided by lease)
UT Judgment Amount
Attachment Prohibited/ Judgment Costs
42 Pa.C.S. § 8127 Attorney Fees
? This case dismissed without prejudice.
® Possession granted.
? Possession granted if money judgment
? Possession not granted.
Total Judgment
Post Judgment Credits
Post Judgment Costs
Certified Judgment Total
Adjudicated Amount
.00
$ .00
$ _00
$ _00
$ _00
$ .00
$ 121.50
$ _00
$ 121.50
? Defendants are jointly and severally liable.
IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN
TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS
OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT, IF ANY. IN
ORDER TO OBTAIN A SUPERSEDEAS, THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF
THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED. HOWEVER, LOW-INCOME AND/OR
SECTION 8 TENANTS SHOULD REFER TO Pa.R.C.P.M.D.J. No. 1008 OR 1013 FOR DIFFERENT PROCEDURES REGARDING THIS DEPOSIT.
IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE; PARTY HAS
30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY./CLERK OF
COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION.
THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THE NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT
HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT
OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
SEP 16 2009 Date , Magisterial District Judge
certify that this is a true an o t copy t rec e ro s containing the judgment.
Date , Magisterial District Judge
My commission expires first Monday of January, 2012. SEAL
AO PC 315A-O8
¦ Complete Items 1, 2, and 3. Also complete
Item 4 If Restricted Delivery Is desired.
¦ Print your name and address on the reverse
I so that we can return the card to you.
¦ Attach this card to the back of the mallpiece,
or on the front if space permits.
I. ArticleAddressed to:
Cep {-??z l PA ?dll etc !Ej„C-
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S, w VKeU D? l er I
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D. Is delivery adds d$fj9 t from Item.
If YES, enter deli44a=below.
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3. SqPKCe Type
Certified Mail ? Express Mall
? Registered ? Retum Receipt for Merchandise
E3 Insured Mail [3 C.O.D.
1709(3 4. Restricted Delivery? (F_xtra Fee) ? Yes
2. Article Number 7008 3230 0000 7648 3852
(Ransfer from service.
PS Form 3811, February 2004 Domestic Return Receipt 102595-02-WI540
(This proof 0
(Transfer from servk 7008 3230 0000 7648 3845 r/icabte boxes.)
PS Form 3811, February 2004 Domestic Return Receipt -102596-024&1540:
COMMONWE ------- -- - - - -
COUNTY OF Cu Atbe, ; ss
AFFIDAVIT: I hereby (swear) (affirm) that I served
? a copy of the Notice of Appeal, Common Pleas upon the District Justice designated therein on
(date of service) T- 20 (9q ? by personal service i by (certified) (registered) mail,
sender's receipt attached hereto, and upon the appellee, (name) Ce? j)rC ` PA co I (ed?Q; ofLn?
?C' e
,20 ? b ersonal service
p' f p 011 y p by (certifie tared) m
sender's receipt attached hereto. 1
(SWORN) (AFFIRMED) AND SU CRIBED BEFORE ME
THIS DAY OF 20M.
Signal le of ici before whom davit was made
Title of official
My commission expires on 41V 20-Q_.
NOTARIAL SEAL
PROTHONOTARY, NOTARY PUBLIC
CARLISLE CUMBERLAND COUNTY COURTHOUSE
MY COMMISSION EXPIRES JANUARY 4, 2010
G' rp
ate;
rC
afFant
CENTRAL PENN COLLEGE IN THE COURT OF COMMON PLEAS OF
EDUCATION FOUNDATION, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff :
NO. 2009-6340 CIVIL TERM
V.
CIVIL ACTION-LAW
MICHAEL H. LAMARCHE and
KATHRYN E. MISLYAN, EJECTMENT
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 an 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
CENTRAL PENN COLLEGE
EDUCATION FOUNDATION,
Plaintiff
V.
MICHAEL H. LAMARCHE and
KATHRYN E. MISLYAN,
Defendants.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2009-6340 CIVIL TERM
CIVIL ACTION-LAW
EJECTMENT
COMPLAINT IN EJECTMENT
NOW, comes Plaintiff, Central Penn College Education Foundation (hereinafter referred
to as "Central Penn"), by and through its attorneys, O'BRIEN, BARIC & SCHERER, and files
the within complaint and, in support thereof, sets forth the following:
1. Central Penn is a Pennsylvania trust with an address of College Hill Road,
Summerdale, Cumberland County, Pennsylvania 17093.
2. Plaintiff owns a residential building located at 119 Wertzville Road, Enola,
Cumberland County, Pennsylvania 17025.
3. Defendants, Michael H. LaMarche and Kathryn E. Mislyan are adult individuals
who reside at 119 Wertzville Road, Enola, Cumberland County, Pennsylvania 17025. And the
tenants are the Defendants herein.
4. No written lease exists between the parties and a month-to-month lease
relationship was in place.
5. Defendants took possession of the leased premises in approximately 1992.
6. The property at issue is the real property as described in the legal description
attached hereto as Exhibit "A" and incorporated by reference.
7. Plaintiff obtained title to the property referenced on Exhibit "A" on February 13,
2009 by deed recorded at Instrument No. 200910871, with the Recorder of Deeds of Cumberland
County.
8. On July 16, 2009, Plaintiff provided Defendants with a Notice To Quit requesting
the Defendants remove themselves from the property on or before August 31, 2009.
9. To the date hereof, Defendant's remain in possession of the premises.
10. Defendants failed to cure their default after notice.
WHEREFORE, Plaintiff requests judgment in ejectment be entered in its favor and
against Defendants together with costs and expenses of this action.
Respectfully submitted,
R
M O EN, BA zl.
/,) Davi
d A. Baric, Esquire
I.D. 44853
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
VERIFICATION
I verify that the statements made in the foregoing Complaint In Ejectment are true and
correct to the best of my knowledge, information and belief. This verification is signed by David
A. Baric, Esquire, Attorney for Plaintiff and is based upon the statements provided by Plaintiff,
as well as documents reviewed by the undersigned as attorney for Plaintiff. This verification will
be substituted and ratified by a verification signed by the Plaintiff who is presently unavailable to
sign said verification. I undersigned that false statements herein are made subject to penalties of
18 Pa.C.S. §4904, relating to unsworn falsificatio s to authorities.
1
David A. Baric, Esquire
Dated: October 14, 2009
? t
DEED OF DISTRIBUTION
C:(DFIY
Tax ID #09-15-1291-006
MADE this /0 day of Ft?br(.Lit.r? t 2?,
7
Between
THE SHIPPENSBURG UNIVERSITY FOUNDATION, INC. and JOEL R.
ZULLINGER, Co-Executors of the ESTATE OF GEORGE J. MILLER, JR.,
late of East Pennsboro Township, Cumberland County, Pennsylvania,
deceased, hereinafter whether one or more referred to as "GRANTOR, 11
And
CENTRAL PENNSYLVANIA COLLEGE EDUCATION FOUNDATION of
Summerdale, Pennsylvania, hereinafter whether one or more referred
to as "GRANTEE,"
WHEREAS, George J. Miller,
resident of East Pennsboro
Pennsylvania, having first made
5, 2007, with said will being
testamentary issued thereon to
Register of Wills of Cumberland
23, 2008, and
Jr. died on January 4, 2008, a
Township, Cumberland County,
last will and testament dated May
admitted to probate and letters
the above-named Grantor by the
County, Pennsylvania, on January
WHEREAS, at the time of death decedent died seized in fee of
the hereinafter described real estate and
WHEREAS, Paragraph V of the decedent's will, a copy of which
is filed with the Register of Wills, specifically devises the
hereinafter described real estate situate at 119 Wertzville Road,
East Pennsboro Township, Cumberland County, Pennsylvania, to
Grantee, and
WHEREAS, it is the intent of this deed to distribute to the
said Grantee, in full satisfaction of the specific devise under
Paragraph V of said will, real estate at 119 Wertzville Road, East
Pennsboro Township, Cumberland County, Pennsylvania.
NOW, THEREFORE, WITNESSETH that the Grantor herein does hereby
grant and convey in fee simple to said Grantee
ALL the following described real estate lying and being
situate in East Pennsboro Township, Cumberland County,
EXHIBIT "A"
Pennsylvania, more particularly described as follows:
BEGINNING at a point at the corner of the northerly edge
of Wertzville Road, SR 944, and a 40-foot unopened right
of way known as Grant Street, as shown on boundary survey
hereinafter mentioned; thence along the unopened Grant
Street, North 17 degrees 11 minutes 19 seconds West
372.36 feet to a point at a 15-foot unopened alley on
said boundary survey; thence along a 15-foot unopened
alley, North 72 degrees 37 minutes 31 seconds East 155.62
feet to a fence post found at a 10-foot unopened alley on
said boundary survey; thence along a 10-foot unopened
alley, South 13 degrees 59 minutes 41 seconds East 450.07
feet to the northerly edge of Wertzville Road, SR 944;
thence along Wertzville Road, SR 944, North 76 degrees 49
minutes 2 seconds West 151.3 feet to the place of
beginning, containing 1.36 acres or 59,262 square feet,
as shown on boundary survey prepared for George J.
Miller, Jr., 119 Wertzville Road, dated January 20, 2009,
and prepared by Alpha Consulting Engineers, Inc.,
attached hereto.
THE above-described real estate is intended to be the
same which Thelma A. Bretz, Administrator d.b.n. of the
Estate of Dessie S. Burris, by deed dated September 30,
1963, recorded in Cumberland County, Pa., Deed Book Z,
Volume 20, Page 719, conveyed to George J. Miller, Jr.,
Grantor decedent.
UNDER AND SUBJECT to existing covenants, agreements,
conditions, easements, restrictions and rights of record
to the extent valid and enforceable and still applicable
to the above-described premises.
AND the said Grantor does covenant, promise and agree to and
with said Grantee, the heirs, executors, administrators and
assigns, by these presents that Grantor has not heretofore done or
committed any act, matter or thing whatsoever whereby the premises
hereby granted or any part thereof is, are, or shall be or may be
impeached, charged, or encumbered in title, estate or otherwise
howsoever.
IN WITNESS WHEREOF, the said Grantor does hereby cause these
presents to be executed the day and year first above written.
Witness: THE SHIPPENSBURG UNIVERSITY
FOUNDATICW, INC.
STATE OF PENNSYLVANIA:
COUNTY OF
Z. (Seal)
-Executor
1 R. Zullttsler, Co-Exeqfdto
al)
Uv?
On this the day of 4&_\bef ore me
a notary public pers nally appe re who
acknowledged himself to be the of The
Shippensburg University Foundatio c., a corporation, Co-
Executor of the Estate of George J. Miller, Jr., being authorized
to do so, exe uted/??the foregoing instrument for the purposes
therein M'A b}?.gning the name of the corporation by himself
as such'' rz " .
seal.
In Witness Whereof, I have hereunto set my hand and official
iNSYLVA":
N6;:,ria! Seal
Jaoqueiine L. Dravlbaugh, Notary Public
South Middleton Twp., Cumberland County
My Commission Expires Aug. 14, 2011
Member, Pennsvh ? -lation of Notaries
STATE OF PENNSYLVANIA:
COUNTY OF
1,4,? 1 L?J
On this the K? day of 2047 ?, before me the
undersigned officer, personally appear Joel R. Zullinger, Co-
Executor of Estate of George J. Miller, Jr., known to me (or
satisfactorily proven) to be the person whose name is subscribed to
the within instrument, and acknowledged that he executed the
foregoing deed for the purposes therein contained and desired the
same to be recorded as such.
Witness my hand and official seal the day and year first above
written. 1
Notary Pub c
TWA L BNLNorC V SMVMNS$UH
CUMUN.COrt mWo
I hereby certify that Grantee's
office address is: 1
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Dated:
precise residence and post
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PL.A14JIN0r6NONEM9VN0*8UgVEYM `
?M LJMBKLN RD. P.O. BOX 'O'
i GEORGE J. MILLER, JR. NEW CUKAM LAND. PA f7O7O '
119 WERTZVILLE ROAD M-WA CONKLTM @IOMOq NC P te)!;1j726M f Gti PDIMM torso. OANSLA a WArf PD*1MVMA W W WALPHAC LCOM
?' AWy eawlM^a^S .
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number - 200910871
Recorded On 4/7/2009 At 2:46:17 PM * Total Pages - 7
* Instrument Type - DEED
Invoice Number - 40980 User ID - KW
* Grantor - MILLER, GEORGE J JR
* Grantee - CENTRAL PENNSYLVANIA COLLEGE EDUCATION FOUNDATION OF SUMMERDAL
* Customer - NAYLOR
*
FEES
STATE WRIT TAX $0.50
STATE JCS/ACCESS TO $10.00
JUSTICE
RECORDING FEES - $14.50
RECORDER OF DEEDS
PARCEL CERTIFICATION $10.00
FEES
AFFORDABLE HOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
EAST PENNSBORO SCHOOL $0.00
DISTRICT
EAST PENNSBORO TOWNSHIP $0.00
TOTAL PAID $51.50
I Certify this to be recorded
in Cumberland County PA
RECORDER O D EDS
?`f750
* - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
IIIXOR
1111111111111111111111111111111
CERTIFICATE OF SERVICE
I hereby certify that on October 13, 2009, I, David A. Baric, Esquire of O'Brien, Baric &
Scherer, did serve a copy of the Complaint In Ejectment, by first class U.S. mail, postage prepaid,
to the parties listed below, as follows:
Michael H. Lamarche
Kathryn E. Mislyan
119 Wertzville Road
Enola, Pennsy ania 17025
David A. Baric, Esquire
2009 OCT 13 All., !C: 5 3
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Respectfully submitted,
O'BRIEN, BARIC & SCH R
David A. Baric, Esquire
Date: October 20, 2009 I.D. #44853
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
CENTRAL PENN COLLEGE
EDUCATION FOUNDATION,
Plaintiff
V.
MICHAEL H. LAMARCHE and
KATHRYN E. MISLYAN,
Defendants.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2009-6340 CIVIL TERM
CIVIL ACTION-LAW
EJECTMENT
PRAECIPE TO ATTACH SUBSTITUTE VERIFICATION
Please attach the following Substitute Verification to the Complaint In Ejectment filed in
this matter on October 13, 2009.
VERIFICATION
I, Matthew G. Lane, verify that the statements made in the foregoing Complaint In Ej ectment
are true and correct to the best of my knowledge, information and belief.
I hereby ratify the verification previously supplied by my attorney, David A. Baric, Esquire
and execute this verification as a substituted verification.
I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
§4904 relating to unsworn falsifications to authorities.
Date: !d ?Y ' dr-c? 0 '00
?f ?-e--
Matthew G. Lane, Director
Central Pennsylvania College Education Foundation
F1Lr'--(J???•yLt? tµ`LI? pfi
OF THE
2109 OC # 20, Phi 3: 43
GUiiJ ?? 1 !? `? E !
CENTRAL PENN COLLEGE
EDUCATION FOUNDATION,
Plaintiff
V.
MICHAEL H. LAMARCHE and
KATHRYN E. MISLYAN,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2009-6340 CIVIL TERM
CIVIL ACTION-LAW
EJECTMENT
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance of JAMES W. KOLLAS, as counsel for Michael H.
Lamarche and Kathryn E. Mislyan, Defendants, in the above-captioned matter.
RESPECTFULLY SUBMITTED:
fames W. Kollas, Esquire
Supreme Court I.D. No. 81959
KOLLAS AND KENNEDY
1104 Fernwood Avenue
Camp Hill, PA 17011
(717) 731-1600
ATTORNEY FOR DEFENDANTS
Dated: 10-1,2'-o 7
y" I
,,)F THE
2409 NOV - 6 P 3: 07
tPC:%?1 ` to
11L-05-09 12:12 Pq: 2
CENTRAL PENN COLLEGE IN THE COURT OF COMMON PLEAS OF
EDUCATION FOUNDATION, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 2009-6340 CIVIL TERM
V.
CIVIL ACTION-LAW
MICHAEL H. LA.MARCHE and
KATHRYN E. MISLYAN, EJECTMENT
Defendants.
PRA,ECIPE TO DISCONTINUE
TO THE PROTHONOTARY:
Kindly mark the above-captioned action as having been settled and discontinued without
prejudice, Please release the escrowed funds to the Plaintiff.
7/41' RIEN, B C & SC.
r
David A. Baric, Esquire
19 West South Street
Carlisle, PA 17013
(717) 249-6873
KOLLAS AND KENNEDY
J es Kollas, Esquire
?i 1104 Fernwood Avenue
Camp Hill, Pennsylvania 17011
(717) 731-1600
Attorney for Plaintiff
on
Date: l? 0
Attorney for Defendants
Date: l1 ? ,90
20`3 ?'d t 0 P? 2' S?
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