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HomeMy WebLinkAbout09-7658 COYNE & COYNE, P.C. Henry F. Coyne, Esq. Pa. Supreme Ct. No. 06250 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorneys for Plaintiff David R. Bretz, by Susan Bretz, his attorney in fact, Plaintiff VS. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO. CA - %(v5B aiyi I )Erm Walter P. Little and Tara L. Little, his wife; Ray T. Harrigan and Mary D. Harrigan his Wife; Milton Renninger a/k/a Milton Reneker; Lillie Renninger; Jacob R. Renninger a/k/a/ J. R. Renninger: a/k/a J.R. Reneker; Jeremy Miller; Abraham Miller; a/k/a Abram Miller; Abram Miller heirs at law; Samuel Miller;: Thachous Miller; Martha Miller; Adeline : Miller; Francis Quigg; Sarah Jane Miller;: Jacob Hess; Catherine Miller; William Bady; John Gamber, Attorney-in-fact for Abraham Miller heirs; Frederick May CIVIL ACTION - LAW and Magdalona May, his wife;: : ACTION TO QUIET TITLE John Shoop, Administrator For Estate of Jacob Neidig ; Jacob Neidig; John Neidig and Mary Neidig, his wife 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 NOTICE IS 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 DEFENDANT. 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. Cumberland County Lawyer Referral Service 32 S. Bedford Street Carlisle, PA 17013 1-800-990-9108 (717) 249-3166 1. Plaintiff, David R. Bretz is an adult individual residing in the Sara A. Todd Memorial Home, 1000 West South Street, Carlisle, PA 17013. 2. Susan Bretz is an adult individual who resides at 101 Sharon Road, Enola, Pennsylvania 17025 and is Attorney-in-Fact for David R. Bretz. 3. Defendants, Walter P. Little and Tara L. Little, his wife, are adult individuals who reside at 8 Lockwood Drive, Enola, East Pennsboro Township, Cumberland County, Pennsylvania. 4. Defendants, Ray T. Harrigan and Mary D. Harrigan, his wife, are believed to have been deceased for many years and their heirs and possible assigns are unknown. 5. Defendant, Milton Renninger a/k/a Milton Reneker, is believed to have been deceased for many years and their heirs and possible assigns are unknown. 6. Defendant, Lillie Renninger, is believed to have been deceased for many years and their heirs and possible assigns are unknown. 7. Defendant, Jacob R. Renninger a/k/a/ J. R. Renninger a/k/a J. R. Reneker, is believed to have been deceased for many years and their heirs and possible assigns are unknown. 8. Defendant, Jeremy Miller, is believed to have been deceased for many years and their heirs and possible assigns are unknown. 9. Defendant, Abraham Miller; a/k/a Abram Miller, is believed to have been deceased for many years and their heirs and possible assigns are unknown. 10. Defendant, heirs in law of Abram Miller, are believed to have been deceased for many years and their heirs and possible assigns are unknown. 2 11. Defendant, Samuel Miller, is believed to have been deceased for many years and their heirs and possible assigns are unknown. 12. Defendant, Thachous Miller, is believed to have been deceased for many years and their heirs and possible assigns are unknown. 13. Defendant, Martha Miller, is believed to have been deceased for many years and their heirs and possible assigns are unknown. 14. Defendant, Adeline Miller, is believed to have been deceased for many years and their heirs and possible assigns are unknown. 15. Defendant, Francis Quigg, is believed to have been deceased for many years and their heirs and possible assigns are unknown. 16. Defendant, Sarah Jane Miller, is believed to have been deceased for many years and their heirs and possible assigns are unknown. 17. Defendant Jacob Hess is believed to have been deceased for many years and their heirs and possible assigns are unknown. 18. Defendant, Catherine Miller, is believed to have been deceased for many years and their heirs and possible assigns are unknown. 19. Defendant, William Bady, is believed to have been deceased for many years and their heirs and possible assigns are unknown. 20. Defendant, John Gamber Attorney-in-fact for Abraham Miller heirs, is believed to have been deceased for many years and their heirs and possible assigns are unknown. 21. Defendants, Frederick May and Magdalona May, his wife, are believed to have been deceased for many years and their heirs and possible assigns are unknown. 3 22. Defendant John Shoop, Administrator for Estate of Jacob Neidig, is believed to have been deceased for many years and their heirs and possible assigns are unknown. 23. Defendant, Jacob Neidig, is believed to have been deceased for many years and their heirs and possible assigns are unknown. 24. Defendants, John Neidig and Mary Neidig, his wife, are believed to have been deceased for many years and their heirs and possible assigns are unknown. ACTION TO QUIET TITLE 25. Paragraphs 1 through 24 are incorporated herein by reference. 26. Plaintiff possesses fee simple title to the premises known as Mountain Land, East Pennsboro Township, Cumberland County, Pennsylvania, having acquired title from Fanny Bretz by Deed dated May 5, 1959, and recorded in Deed Book D, Volume 19, Page 101, and listed as Tract No. 2, which is incorporated herein by reference. 27. The Plaintiff's property contains the metes and bounds description of a tract of land of an area of 7.077 acres further described in the Land Survey, dated April 17, 2008 conducted by Mark Romeo, P.L.S., to wit: All that certain tract of land known as Cumberland County Tax Parcel #09-11-3007-022 and being situate in the Township of East Pennsboro, Cumberland County, Pennsylvania and being more particularly described as follows: Beginning at a southwesterly corner of lands now or formerly of William & Evelyn Burkey, said point being on the northerly line of lands now or formerly of Helen & Robert Santo; Thence, along said lands of Helen & Robert Santo and along other lands of William & Evelyn Burkey and continuing along lands now or formerly of Ira & Anna Kauffman and beyond along lands of George Kauffman 4 South 61°30'55" West, a distance of 481.41 feet to a point; Thence, North 35°07'27" West, a distance of 525.11 feet to a point; Thence, along lands now or formerly of the Estate of Ruth V. Miller the following three (3) courses: l.) North 60°00'00" East, a distance of 379.50 feet to a point; 2.) North 24°29'38" West, a distance of 263.78 feet to a point; 3.) North 60°02'35" East, a distance of 137.26 feet to a point on the westerly line of lands now or formerly of Joseph C. Franczak; Thence along said lands of Joseph C. Franczak and along lands now or formerly of Sharon L. Foster and beyond along lands now or formerly of William & Evelyn Burkey South 29°00'00" East, a distance of 798.33 feet to a point, the place of beginning. CONTAINING 7.07 acres of land, more or less. 28. The said Plaintiff has paid property taxes on the said premises for a period in excess of 21 years. 29. Ray T. Harrigan and Mary D. Harrigan, his wife by Deed dated April 26, 1948 and recorded in Book T, Volume 13, Page 525 conveyed the same premises to Fanny Bretz. 30. The Commissioners of Cumberland County, by deed dated January 19, 1946 and recorded in Deed Book T, Volume 13, Page 524 which is incorporated by reference, conveyed the same premises to Ray T. Harrigan. 31. The Treasurer of Cumberland County seized the real estate from Milton Reneker (sic-Renninger) due to unpaid taxes and by deed dated December 31, 1940 and recorded in Deed Book T, Volume 13, Page 523 which is incorporated by reference, conveyed the same premises to the Commissioners of Cumberland County, Pennsylvania. 32. The said Jacob R. Renninger died on October 28, 1903 being seized of the said parcel of land and he was survived by his heirs at law, namely son, Milton R. Renninger and daughter, Lillie Renninger. The said Lillie Renninger died intestate on December 1, 1937, being seized of one-half (1/2) interest in the said parcel of land and was survived by her brother, Milton R. Renninger, who became seized in fee simple of the said parcel of land. 5 33. Jacob R. Renninger by his deed, recorded on August 21, 1883 in Deed Book 3, Volume V, Page 191 which is incorporated be reference, conveyed the premises to Jeremiah Miller. Further, the recitals in said Deed on Page 192 of the Deed Book to include the following: a. It being a part of a piece of land (10 acres) which John Shoop, administrator of Jacob Neidig deceased, sold and conveyed to Frederick May (now deceased) and Frederick May & wife by deed dated March 31, 1848 sold and conveyed. the same to Abram Miller there is also included in this sale and conveyance Tract No. 2; b. It being a part of a piece of land (2 acres and on hundred and 116 perches) which Frederick May and Magdalona, his wife, by deed dated November 26, 1845, sold and conveyed to Abram Miller, C. The said Abram Miller being thereof seized died intestate and left as his heir in law, Abram Miller, Jr., Samuel Miller, Jeremiah Miller, Thachous Miller, Martha Miller, Adeline Miller intermarried with Francis Quigg, Sarah Jane Miller, intermarried to Jacob Hess and Catherine Miller intermarried with William Bady and the above mentioned heirs by an instrument of writing did make John Gamber their attorney in fact for Abraham Miller heirs, did by this deed dated April 7, 1877 sale and convey the same to Jacob R. Renninger, party hereto by reference being had the different recited Indenture. 6 34. John Neidig and Mary Neidig, his wife, by their deed, dated March 27, 1838 and entered in Deed Book I, Volume TT, Page 351, granted and conveyed 93 acres which contained the parcel of land owned by the Plaintiff to Frederick May. 35. On August 23, 2007, Walter P. Little and Tara L. Little, his wife, recorded a Quit Claim Deed unto themselves as Grantees and recorded in Deed Book 33021. 36. The recording of said Quit Claim Deed by Walter P. Little and Tara L. Little, his wife, has caused a cloud to be raised on the title of a parcel of land David R. Bretz has owned and possessed since May 5, 1959. 37. The said cloud renders the title to the said premises unmarketable in that it exposes the holders, the said David R. Bretz, or any assignee, grantee, devisee, or the like to the hazards of litigation. 38. The Defendants are the only persons known to the Plaintiff who have an unsupported claim to land owned and possessed by the Plaintiff. WHEREFORE, plaintiff requests the Court to enter an order decreeing the plaintiff is the legal owner of the premises, by virtue of a deed from Fannie Bretz, dated May 5, 1959, of and entered of record in Deed Book D, Volume 19, page 101, Tract No. 2; that these proceedings shall at all times hereafter be taken as evidence of the facts decreed and established by your Honorable Court that Plaintiff is the legal owner of record of the subject property and declare the Quit Claim Deed filed by the Defendants, Littles, null and void. That a Rule be granted on Defendants to show cause they be forever barred from asserting any right, title or interest in said 7 land. That this Honorable Court award Plaintiffs Attorneys Fees, survey costs and all other expenses Plaintiffs have suffered due to the vexatious and unwarranted actions on the part of the Defendants in filing said Quit Claim Deed and any other remedies which this Honorable Court deems appropriate. Dated: 1 (Inr aQ Respectfully submitted, COYNE & COYNE, P.C. HENRY F. CO E, E QUIRE 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 0625 Attorney for Plaintiff 8 VERIFICATION I, Susan Bretz certify that the statements made in the foregoing document are true and correct to the best of my knowledge, information, and belief and that this verification is subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. Date Q ??rz 7- 00,? Susan Bretz, Attorney-in-Wet for David & Bretz 0 THE 1 1J'' 2009I` OV -E, 8: 35 *'18. bo po ATr%j c r-* µ5oto e 43308 COYNE & COYNE, P.C. Henry F. Coyne, Esq. Pa. Supreme Ct. No. 06250 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorneys for Plaintiff David R. Bretz, by Susan Bretz, his attorney in fact, Plaintiff VS. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Walter P. Little and Tara L. Little, his wife; Ray T. Harrigan and Mary D. Harrigan his Wife; Milton Renninger a/k/a Milton Reneker; Lillie Renninger; Jacob R. Renninger a/k/a/ J. R. Renninger: a/k/a J.R. Reneker; Jeremy Miller; Abraham Miller; a/k/a Abram Miller; Abram Miller heirs at law; Samuel Miller;: Thachous Miller; Martha Miller; Adeline : Miller; Francis Quigg; Sarah Jane Miller;: Jacob Hess; Catherine Miller; William Bady; John Gamber, Attorney-in-fact for Abraham Miller heirs; Frederick May and Magdalona May, his wife; John Shoop, Administrator For Estate of Jacob Neidig ; Jacob Neidig; John Neidig and Mary Neidig, his wife Defendants CIVIL ACTION - LAW ACTION TO QUIET TITLE MOTION FOR A SPECIAL ORDER DIRECTING THE METHOD OF SERVICE AND NOW comes the Petitioner, David R. Bretz by Susan Bretz his Attorney-In-Fact, by and through their attorney, Henry F. Coyne, Esquire, of Coyne & Coyne, P.C., and avers the following: 1. Petitioner is the Plaintiff in the above captioned matter. 2. The complaint in the above-captioned matter sets forth that with the exception of Walter P. Little and Tara L. Little, his wife, all of the Defendants are believed to be dead for many years and their heirs and possible assigns are unknown. 3. Both the Petitioner, Susan Bretz and her counsel, Henry F. Coyne, Esquire, have taken various steps to locate heirs and assigns of the various Defendants. Such steps are outlined in more detail in the affidavit attached hereto. WHEREFORE, Petitioner respectfully moves your Honorable Court to enter a special order authorizing the Petitioner make service by publication one (1) time in the Cumberland County Law Journal and the Patriot News. e-s ? g Date Henry F. Coyne,f-*ire 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 0625 Attorney for Plaintiff 2 Respectfully submitted, COYNE & COYNE, P.C. Henry F. Coyne, Esq. Pa. Supreme Ct. No. 06250 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorneys for Plaintiff David R. Bretz, by Susan Bretz, his attorney in fact, Plaintiff VS. Walter P. Little and Tara L. Little, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . NO. eq- CJ765&- G V i L (b?zw. CIVIL ACTION - LAW his wife; Ray T. Harrigan and Mary D. Harrigan his Wife; Milton Renninger a/k/a Milton Reneker; Lillie Renninger; Jacob R. Renninger a/k/a/ J. R. Renninger: a/k/a J.R. Reneker; Jeremy Miller; Abraham Miller; a/k/a Abram Miller; Abram Miller heirs at law; Samuel Miller;: Thachous Miller; Martha Miller; Adeline : Miller; Francis Quigg; Sarah Jane Miller;: Jacob Hess; Catherine Miller; William . Bady; John Gamber, Attorney-in-fact for : Abraham Miller heirs; Frederick May and Magdalona May, his wife; John Shoop, Administrator For Estate of Jacob Neidig ; Jacob Neidig; John Neidig and Mary Neidig, his wife Defendants ACTION TO QUIET TITLE AFFIDAVIT OF HENRY F. COYNE, ESQUIRE REGARDING EFFORTS TO LOCATE HEIRS AND/OR ASSIGNS OF THE DEFENDANTS, WITH THE EXCEPTION OF WALTER P. LITTLE AND TARA L. LITTLE, HIS WIFE, NAMED IN THE SAID ACTION TO QUIET TITLE HENRY F. COYNE, ESQUIRE, being duly sworn according to law, deposes and states the facts set forth below regarding his efforts to locate heirs and/or assigns of the Defendants named in the said Action To Quiet Title, docketed to bq - o 7 65° r( v ` T? r r.- Affiant has taken the following with reference thereto: 1. A search has been made in the telephone directory. 2. With the exception of Walter P. Little and Tara L. Little, his wife, none of the Defendants could be alive or could any of the Defendants be located. Your Petitioner and her counsel researched the records in the Register of Wills Office and the Recorder of Deeds Office to locate the Defendants, with the exception of Walter P. Little and Tara L. Little, his wife, as well as their heirs and assigns and were unable to locate the said Defendants, their heirs and assigns. 4. Further, your Petitioner and Henry F. Coyne, Esquire have no personal knowledge of any of the Defendants, with the exception of Walter P. Little and Tara L. Little, his wife, and their heirs and do not believe any of them are in the area and believe no further action to locate the Defendants and their heirs would be productive. 4 H NRY F.- AA . CO E, ESQUIRE Sworn and subscribed to before me this fs day of Kan/ , 2009. of W(?TAl11AL SEAL 6isa Marie Coyne. Notary puplic Ham TownahuznbartllMlnt?? SAY ?ry l jf ; f r -i )TARY 1009 NOY -6 PI 8: 38 C?Ip,ti. INFY ?fvtAVyrgNN3p 40 -TJA.3WNOMMr,:) A! P A! StQt,Qt?nu?.te??q???o;sx?rnr+?3vk1 ? 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 David R. Bretz vs. Tara L. Little 4 -,7 T t :' ! -AqV ?0"91;0' 10 i. C. 0, 1 Case Number 2009-7658 SHERIFF'S RETURN OF SERVICE 11/06/2009 06:16 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on November 6, 2009 at 1816 hours, he served a true copy of the within Complaint to Quiet Title, upon the within named defendant, to wit: Tara L. Little, by making known unto herself personally, at 8 Lockwood Drive Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. 11/06/2009 06:16 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on November 6, 2009 at 1816 hours, he served a true copy of the within Complaint to Quiet Title, upon the within named defendant, to wit: Walter P. Little, by making known unto himself personally, at 8 Lockwood Drive Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $57.94 November 09, 2009 SO ANSWERS, ?-?4 R THOMAS KLINE, SHERIFF Deputy Sheri f NOV 0 9 2009 q David R. Bretz, by : IN THE COURT OF COMMON PLEAS OF Susan Bretz, his attorney in fact, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. NO. oct- "7658 CIV)!_ r-egA Walter P. Little and Tara L. Little, his wife; Ray T. Harrigan and Mary D. Harrigan his Wife; Milton Renninger : CIVIL ACTION - LAW a/k/a Milton Reneker; Lillie Renninger; . Jacob R. Renninger a/k/a/ J. R. Renninger: a/k/a J.R. Reneker; Jeremy Miller; Abraham Miller; a/k/a Abram Miller; Abram Miller heirs at law; Samuel Miller;: Thachous Miller; Martha Miller; Adeline : Miller; Francis Quigg; Sarah Jane Miller;: Jacob Hess; Catherine Miller; William Bady; John Gamber, Attorney-in-fact for Abraham Miller heirs; Frederick May and Magdalona May, his wife;: ACTION TO QUIET TITLE John Shoop, Administrator For Estate of Jacob Neidig ; Jacob Neidig; John Neidig and Mary Neidig, his wife Defendants ORDER AND NOW, this &L. day of k)oz&44r- , 2009, Petitioner David R. Bretz by Susan Bretz, His Attorney-in-Fact, Plaintiff in the above captioned case, is hereby directed to make service upon the above-named Defendants with the exception of Walter P. Little and Tara L. Little, his wife by publication one (1) time in both the Cumberland County Law Journal and the Patriot News. I:: '_Ei ,r "It 44. REAGER & ADLER, PC Linus E. Fenicle, Esquire Atty. I.D. #20944 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Defendants Walter P. Little and Tara L. Little David R. Bretz, by Susan Bretz, his attorney in fact, Plaintiff VS. Walter P. Little and Tara L. Little, his wife; Ray T. Harrigan and Mary D. Harrigan, his wife; Milton Renninger a/k/a Milton Reneker; Lillie Renninger; Jacob R. Renninger a/k/a J. R. Renninger a/k/a J.R. Reneker; Jeremy Miller; Abraham Miller a/k/a Abram Miller; Abram Miller heirs at law; Samuel Miller; Thachous Miller; Martha Miller; Adeline Miller; Francis Quigg; Sarah Jane Miller; Jacob Hess; Catherine Miller; William Bady; John Gamber, Attorney-in-fact for Abraham Miller heirs; Frederick May and Magdalona May, his wife; John Shoop, Administrator for Estate of Jacob Neidig; Jacob Neidig; John Neidig and Mary Neidig, his wife, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-7658 Civil Term : CIVIL ACTION -LAW ACTION TO QUIET TITLE NOTICE TO PLEAD To: David R. Bretz, by Susan Bretz, his attorney in fact c/o Henry F. Coyne, Esquire 3901 Market Street Camp Hill, PA 17011-4227 YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED NEW MATTER AND COUNTERCLAIM WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU. Respectfully submitted, Date: November 25, 2009 REAG R ADLER, P.C. By: Linus E. Fenicle, squire Atty. I.D. #20944 2331 Market Street Camp Hill, PA 17011 (717) 763-1383 Attorneys for Defendants, Walter P. Little and Tara L. Little REAGER & ADLER, PC Linus E. Fenicle, Esquire Atty. I.D. #20944 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys.for Defendants Walter P. Little and Tara L. Little David R. Bretz, by Susan Bretz, his attorney in fact, Plaintiff vs. Walter P. Little and Tara L. Little, his wife; Ray T. Harrigan and Mary D. Harrigan, his wife; Milton Renninger a/k/a Milton Reneker; Lillie Renninger; Jacob R. Renninger a/k/a J. R. Renninger a/k/a J.R. Reneker; Jeremy Miller; Abraham Miller a/k/a Abram Miller; Abram Miller heirs at law; Samuel Miller; Thachous Miller; Martha Miller; Adeline Miller; Francis Quigg; Sarah Jane Miller; Jacob Hess; Catherine Miller; William Bady; John Gamber, Attorney-in-fact for Abraham Miller heirs; Frederick May and Magdalona May, his wife; John Shoop, Administrator for Estate of Jacob Neidig; Jacob Neidig; John Neidig and Mary Neidig, his wife, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-7658 Civil Term : CIVIL ACTION -LAW : ACTION TO QUIET TITLE DEFENDANTS', WALTER P. LITTLE AND TARA L LITTLE, HIS WIFE, ANSWER, NEW MATTER AND COUNTERCLAIM TO COMPLAINT FOR QUIET TITLE AND NOW comes, WALTER P. LITTLE and TARA L. LITTLE, his wife, Defendants herein, by and through their attorneys, Reager & Adler, PC, and Answers Plaintiff's Complaint as follows: 1. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 2. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 3. Admitted. 4. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 5. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 6. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 7. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 8. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 2 9. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 10. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 11. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 12. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 13. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 14. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 15. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 3 16. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 17. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 18. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 19. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 20. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 21. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 22. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 4 23. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 24. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 25. Denied. See responses to responses 1 through 24. 26. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. It is further denied on the basis that it is a legal conclusion to which no response is required. 27. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 28. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 29. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 30. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 5 31. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 32. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 33. and 33. a-c Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 34. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of this averment, and proof thereof is demanded at trial. 35. Admitted in part, denied in part. The Quit Claim Deed is admitted. The said Quit Claim Deed was recorded on August 23, 2007, to Instrument No. 200733021, not Deed Book 33021. 36. Denied. It is specifically denied that David R. Bretz has owned and possessed said property since May 5, 1959, and proof is demanded. Defendants, Walter P. Little and Tara L. Little, have had possession of the said parcel of property as set forth in their Quit Claim Deed in excess of 21 years, and own said property by the doctrine of adverse possession. It is further denied on the basis that it is a legal conclusion to which no response is required. 37. Denied. This is a legal conclusion to which no response is required. It is further denied that David R. Bretz owns said property on the basis of ownership by adverse possession of Walter P. Little and Tara L. Little, pursuant to said Quit Claim Deed. 6 38. Denied. It is specifically denied that Defendants, Walter P. Little and Tara L. Little, have an unsupported claim to any land owned and/or possessed by Plaintiffs. Rather, Walter P. Little and Tara L. Little have possessed the said property set forth in the Quit Claim Deed in excess of 21 years, and own said property by the doctrine of adverse possession. WHEREFORE, Defendants, WALTER P. LITTLE and TARA L. LITTLE, request that Plaintiffs claim be dismissed, and the Defendants, WALTER P. LITTLE and TARA L. LITTLE, be declared owners of said property set forth in the Quit Claim Deed by adverse possession. NEW MATTER 39. Defendants, Walter P. Little and Tara L. Little, have used the said property that is set forth in their Quit Claim Deed in excess of 21 years. 40. Defendants, Walter P. Little and Tara L. Little, started using the said property that is the subject of the Quit Claim Deed in the summer of 1986. 41. Defendants, Walter P. Little and Tara L. Little, have used said property set forth in the Quit Claim Deed by a walking trail over said property, for feeding the deer, planting a garden and shrubs, cleaning up the said property, for four wheeling, spraying said property for gypsy moth, and having part of a garage on said property. Their use has been open, continuous, and notorious in excess of 21 years. 42. By the doctrine of adverse possession, Defendants, Walter P. Little and Tara L. Little, own said property that is the subject of their Quit Claim Deed. WHEREFORE, Defendants, WALTER P. LITTLE and TARA L. LITTLE, ask that Plaintiffs claim be dismissed and judgment entered for Defendants on the basis that 7 Defendants own said land set forth in their Quit Claim Deed by the doctrine of adverse possession. COUNTERCLAIM 43. Paragraphs 39 through 42 are incorporated herein by reference as if fully set forth at length. 44. By the doctrine of adverse possession, Defendants, Walter P. Little and Tara L. Little, own said property set forth within their Quit Claim Deed. WHEREFORE, Defendants, WALTER P. LITTLE and TARA L. LITTLE, request Judgment against Plaintiff and in favor of Defendants, and that Plaintiff be forever barred from making any claim to the property that is the subject of the Quit Claim Deed set forth herein, and for such other relief and damages as are related thereto. Respectfully submitted, REAGE & ADLER, P.C. By: Linus E. Fenicle, Esquire Atty. I.D. #20944 2331 Market Street Camp Hill, PA 17011 (717) 763-1383 Attorneys for Defendants, Walter P. Little and Tara L. Little 8 VERIFICATION I, WALTER P. LITTLE, hereby certify and state that the facts set forth in the foregoing Complaint are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. ALTER P. LIT ME DATE: ZZ- 2 e- p It CERTIFICATE OF SERVICE AND NOW, this ;?J day of /i'yv , 2009, I hereby verify that I have caused a true and correct copy of the foregoing Defendants' Answer, New Matter and Counterclaim to Complaint for Quiet Title to be placed in the U.S. mail, First Class, postage prepaid and addressed as follows: Henry F. Coyne, Esquire 3901 Market Street Camp Hill, PA 17011-4227 (Attorney for Plaintiff) REAGER V, TH1/ ' { f iC } ei+ J I"i'u?31._f tt ti 12 5 F 1h F;i r... _ _ l,. REAGER & ADLER, PC Linus E. Fenicle, Esquire Atty. LD. #20944 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Defendants Walter P. Little and Tara L. Little ~~10 .~!~. -~ r ~°~ ~~ 33 c:;~~~~._ v _ ~ ~. _ ~ti;~ a- ~~~ `~' . , ~, David R. Bretz, by Susan Bretz, his attorney in fact, Plaintiff vs. Walter P. Little and Tara L. Little, his wife; Ray T. Harrigan and Mary D. Harrigan, his wife; Milton Renninger a/k/a Milton Reneker; Lillie Renninger; Jacob R. Renninger a/k/a J. R. Renninger a/k/a J.R. Reneker; Jeremy Miller; Abraham Miller a/k/a Abram Miller; Abram Miller heirs at law; Samuel Miller; Thachous Miller; Martha Miller; Adeline Miller; Francis Quigg; Sarah Jane Miller; Jacob Hess; Catherine Miller; William Bady; John Gamber, Attorney-in-fact for Abraham Miller heirs; Frederick May and Magdalona May, his wife; John Shoop, Administrator for Estate of Jacob Neidig; Jacob Neidig; John Neidig and Mary Neidig, his wife, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-7658 Civil Term CIVIL ACTION -LAW ACTION TO QUIET TITLE AFFIDAVIT OF SERVICE On this, the 7`~' day of July, 2010, I hereby certify that: 1. I am the attorney for Walter and Tara Little, Defendants in the above-captioned case. On June 30, 2010, I caused to be transmitted, by a form of mail requiring a signed receipt, a copy of the attached Subpoena addressed to Mark Romeo, 700 Ohio Avenue, Lemoyne, PA 17043. (Exhibit "A") 2. I further depose and say that I thereafter received a Certificate of Mailing receipt bearing the post mark date of delivery of July 1, 2010 accepted by Joanne J. Romeo. (Exhibit "B") Respectfully submitted, REA~ & ADLER, P. L nus E. Fenicle, Esquire Atty. I.D. #20944 2331 Market Street Camp Hill, PA 17011 (717)763-1383 Attorneys for Defendants, Walter P. Little and Tara L. Little Sworn to and subscribed before me this day of 2010. Notary Public COMMONWEALTH OF PENNSYLVANIA COUNTY, OF CUMBERLAND David R. Bretz, by Susan Bretz, his attorney in fact, , Plaintiff File No. 09-7658 vs. Walter P. and Tara Little, et al. . Defendant SUBPOENA TO ATTEND AND TESTIFY TO: Mark Romeo, 700 Ohio Avenue, Lemoyne, PA 17043 You are ordered by the court to come to the offices of Reaper & Adler, P.C., 2331 Mazket Street (Specify Cournoom or other place) at Camp Hill ,Cumberland County, Pennsylvania, on July 22, 2010 at 10:00 o'clock, A. M,. to testify on behalf of Defendants in the above case, and to remain until excused. 2. And bring with you the following: All surveys, plot plan's and/or other documents in your possession regarding the parcel owved by David R. Bretz, wbicb property is referenced in dad book D page 101 of the Cumberland County Recprds and which was the subject of an exhibit sketch for the lands of David R. Bretz prepared by you. If you ~ fail to attend ' or to produce the documents or things required by this subpoena, you may be subject to the sanctions authorized by Rule 234.5 of the Pennsylvania Rules of Civil Procedure, including but not limited to costs, attorney fees and imprisonment. REQUESTED BY A PARTY/ATTORNEY IN COMPLIANCE WITH Pa.R.C.P.No.234.2(a): Natpe; Linus E. Fenicle, Esquire Address: Reaper & Adler, P.C. 2331 Market Strut, Camp Hill, PA 17011 Telephone: 717-763-1383 Supreme Court ID # 2o9aa BY COURT: ono /Clerk, Civil Division Date: a- ~, ~~~6 sal of'the Court Deputy Official Not;;: Tris form of s>.lbpoena shall be used whenever a subpoena is issuable, including hearings in connectifln yritl` ~epasitions and before arbitrators, masters, commissioners, etc. in compliance wi±h I'a. R.C]'.l~l0~3~:1. If a subpoena for a production of documents, records or things is desired, complete paragraph 2. (Eff. 7/97) EXHIBIT A ~- ~~.. . ' (Domestic Mail G ~ For delivery inform. O 0 M1 RJ O ~ Postage $ ~ ~ Certified Fee rl D Return Receipt Fee !~ p (Endorsement Required) (~ ~ Restricted Delivery Fee (Endorsement Required) O T col Dnclnno R Fccc ~ i ;~c% _ . \1;~ i~ostmarR~~~, Here. Q ~ \ Q~ ~ ~~~ _..i `L 1 ~~' ^' ~' SB o Street, !'~ or ~\_L,1_ T ?~ `w_ City, te, ZlP+4 ^ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to-you. ^ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: ~~~~ (Z~rre~ W ~, O ~a~ ~ p~ 1~-10~t3 A. Received by (Please not Clearly) B°rD e f Delivery ,U4hr~ S • ~5ya-Q a / ~J,f ~ X Si nature ^ Agent ^ Addressee D. Is livery address dkferent from item 1? ^ Yes If ES, enter delivery address below: ^ No 3. Service Type e~Certified Mail ^ Express Mail ^ Registered ^ Return Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Fee) ^ Yes 2. Article Number (Transfer from service label) 7 D D 9 D D 8 D D D 01 17 D 2 9 D 0 6 PS Form 3811, March 2001 Domestic Return Receipt 102595-01-M-1424 EXHIBIT ~_ CERTIFICATE OF SERVICE AND NOW, this 7th day of July, 2010, I hereby verify that I have caused a true and correct copy of the foregoing document to be placed in the U.S. mail, First Class, postage prepaid and addressed as follows: Henry F. Coyne, Esquire 3901 Market Street Camp Hill, PA 1 70 1 1-4227 (Attorney for Plaintiff) ~11~~_i COYNE & COYNE, P. '^ 7r ~- • } ~'~`~ Henry F. Coyne, Esq. Pa. Supreme Ct. No. 0 250 10 i 0 -~ ~ ~-~ l y ~; ,:' `~ ~ ~ ~ 3901 Market Street Camp Hill, PA 17011- 227 C~~w , ~ '~~tiT1` (717) 737-0464 i [' ' ~ ~~ Attorneys for Plaintiff David R Bretz, by : I-N THE COURT OF COMMON PLEAS OF Susan Bretz, his attorn yin fact, :CUMBERLAND COUNTY, PENNSYLVANIA Peti Toner/Plaintiff vs. NO. 09-7658 Civil Term Walter P. Little and T ra L. Little, his wife; Ray T. Harri nand Mary D. ' Harrigan his Wife; Mil on Renninger :CIVIL ACTION -LAW a/k/a Milton Reneker; illie Renninger; Jacob R. Renninger a/ a/ J. R Renninger: a/k/a J.R Reneker; Je my Miller; Abraham Miller; a/k/a bram Miller; Abram Miller heirs at w; Samuel Miller;: Thachous Miller; Mart a Miller; Adeline Miller; Francis Quigg; arah Jane Miller; Jacob Hess; Catherine filler; William Bady; John Gamber, orney-in-fact for Abraham Miller heirs; rederick May and Magdalona May, h 's wife;: :ACTION TO QUIET TITLE John Shoop, Administr for For Estate of Jacob Neidig ;Jacob Neidig; John Neidig and Mary eidig, his wife, Respond nt/Defendants TO THE HONORABLE, JXJDGES OF SAID COURT: AND NOW COM S the Petitioner, David Bretz, by Susan Bretz, his attorney in fact, by and through his legal counsel, enry F. Coyne, Esquire of. Coyne & Coyne, P.C. and avers the following in support of its Petition for a~ Emergency Protective Order: 1. On Dece ber 6, 2009, Plaintiff commenced this action to seek quiet title concerning mountain land located in E st Pennsboro Township, Cumberland County, Pennsylvania. 2. On Marc 12, 2010, Default Judgment was granted to Plaintiff as to all Defendants, excepting Defendants Littl s. 3. Beginning Apri12010, the Plaintiff and the Defendants Littles began exchanging requests for discovery pursuant tot a Rules of Civil Procedure. 4. In particu ar, in response to discovery request from Defendants, Plaintiff identified Mark Romeo, Professional Land Surveyor as Plaintiff's expert having also previously identified Mr. Romeo as Plaintiff's expert in the co plaint filed in this matter. (See Paragraph 27 of Complaint) 5. Despite i entifying Mr. Romeo as Plaintiff's expert witness, on June 30, 2010, Defendants Littles' Attorn y served upon Mark Romeo, P.L.S. (a professional land surveyor), anon-party to this action, a Subpoena o Attend and Testify at a Deposition pursuant to Pa. R.C.P. 4007.1. (Copy of Subpoena is attached as E ibit "A" and a copy of Plaintiff's Supplemental Answers to Interrogatories is attached as Exhibit "B"). 6. On July 6, 2010, the undersigned counsel again advised Attorney Fenicle that Mr. Romeo was Plaintiff's expert witn ss and that, as such, Mr. Romeo could not be deposed without leave of court (Pa.R.C.P. No. 4003.5) w ich Attorney Fenicle had not obtained; however, despite the undersigned's request for the withdrawal f the subpoena and Notice of Deposition, Attorney Fenicle refuses to do so. 7. The under igned having previously communicated to Attorney Fenicle and Attorney Fenicle indicating that he ould not withdraw the Subpeoan as to Plaintiffs expert, the undersigned has a good faith belief that Atto ey Fenicle is opposed to this Petition for a Protective Order 8. Judge Hes has been previously been assigned to this case having entered the Default Judgment in this matter. WHEREFORE, t e Plaintiff, David R. Bretz, respectfully requests your Honorable Court enter an Emergency Protective rder and direct that Mark Romeo, P.L.S., Plaintiff's expert witness, shall not be required to respond to Defendants' subpoena and _ Mr. Romeo shall not be required to attend the deposition noticed per the ubpoena served upon Mr. Romeo; and all other applicable relief. Respectfully submitted, COYNE & COYNE, P.C. Dated: By: Henry F. Co squire Pa. S. Ct. No. 06250 3901 Market Street Camp Hill, PA 1 70 1 1-4227 (717) 737-0464 Attorney for Plaintiff/Petitioner XHIBIT A REAGER & ADLEF Linus E. Fenicle, Es9 Atty. I.D.#20944 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763- Attorneys for Defends Walter P. Little and Ti PC 383 L. Little II~~~~ ~~I~I ~u~ _ i 2oio ~u David R. Bretz, by Susan Bretz, his attorn y in fact, Plaintiff vs. Walter P. Little and T a L. Little, his wife; Ray T. Harrigan d Mary D. Harrigan, his wife; Mil on Renninger a/k/a Milton Reneker; illie Renninger; Jacob R. Renninger a J. R. Renninger a/k/a J.R. Reneker; Jer y Miller; Abraham Miller a/k/a bram Miller; Abram Miller heirs at 1 w; Samuel Miller; Thachous Mille ;Martha Miller; Adeline Miller; Francis Quigg; Sarah Jane Miller; Jacob Hess Catherine Miller; William Bady; hn Gamber, Attorney-in-fact for Ab sham Miller heirs; Frederick Mayan Magdalona May, his wife; John Sh op, Administrator for Estate of Jacob Neidig; Jacob Neidig; John Nei 'g and Mary Neidig, his wife, IN THE COURT OF COMMON PLEAS QF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-7658 Civil Term CIVIL ACTION -LAW ACTION TO QUIET TITLE Defendants NOTICE OF DEPOSITION To: Mark Romeo 700 Ohio Aven Lemoyne, PA 1 Please take noti Walter P. Little and T~ that, pursuant to Pennsylvania Rules of Civil Procedure, Defendants, L. Little, through their attorneys, Reager & Adler, P.C. will take the deposition of Mark 2331 Market Street, Public or other offic until completed. Deponent is possession regarding book D, volume 19, subject of an exhibit meo, by oral examination at the law offices of Reager & Adler, P.C., amp Hill, PA 17011 on July 22, 2010 at 10:00 a.m., before a Notary authorized by law to administer oaths, and continuing from day to day cted to bring all surveys, plot plans and/or other documents in his parcel owned by David R. Bretz, which property is referenced in deed 101 of the Cumberland County Records and which property was the ch for the lands of David R. Bretz prepared by him. Respectfully submitted, REAGE ADLER, Pte. By: Linus E. Fenicle, Esquire Atty. I.D. #20944 2331 Market Street Camp Hill, PA 17011 {717) 763-1383 Attorneys for Defendants, Walter P. Little and Tara L. Little CERTIFICATE OF SERVICE AND NOW, this ~ 0th day of June, 2010, I hereby verify that I have caused a true and correct copy of the foregoing document to be placed in the U.S. mail, First Class, postage prepaid and addressed as follows: Henry F. Coyne, Esquire 3901 Market Street Camp Hill, PA 17011-4227 (Attorney for Plaintiff) REAGER ADLER, PC Linus E. Fenicle, Esquire ,,. t• y S ' BY COURT: ono /Clerk, Civil Division COMMONWEALTH OF' PENNSYLVANIA COUNTY, OF CUMBERLAND David R. Bretz, by Sus Bretz, his attorney in fact, . ' 09-7658 Plaintiff.'- File No. 5. Walter P. and Tara ittle, et al. Defendant SUBPOENA TO ATTEND ANJa TESTIFY TO: Mark Romeo, 70 Ohio Avenue, Lemoyne, PA 17043 1. You aze order d by the court to come to the offices of Re ger & Adler, P.C., 233'1 Mar)aet Street (Specify Courtroom or other place) at Camp Hill ,Cumberland County, Pennsylvania, on July 22, 2010 at 10:00 o'clock, A. NI,. to testify on behalf of Defendants p in the above c e, and to remain until excused. 2. And bring wi you. the following: All surveys, Plat planb ~ ~ ethb~ docwneats ia.your possession regarding the parcel owned by David R Bretz, which property ie referenced in dad book D page 101 of thQ C . County Recprds aad which was the subject of an wrhibit sketch for the lands of David R Bretz prepared by you. If you fail" to atCend'~ or to produce the documents or things required by this subpoena, yotx ~ma ; be . subject' to the sanctions authorized by Rule 234.5 of the Pennsylvar%a Rules of Givi•1 Procedure, including but not limited to costs, attorney fees and imprisonment. REQUESTED BY A)~ARTY/ATTORNEY IN COMPLIANCE WITH Pa.R.C.P.No.234.2(a): Name; Linus E. Fenicle, Esc Address: Reager at Adler, P. 2331 Market Strut, Camp Hill, PA Telephone: 1.17-763-13R3 Supreme Court ID # ? - Date: '~' Official Note: T'lis foi• hearings in ct3nnectign compliance with 1?a. R. things is desired; comp. 8, ~.a/6 ~urt_ DeP~Y 1. ~ subpoena shall be used whenever a subpoena is issuable, including ntn:~ciepasitions and before arbitrators, masters, commissioners, etc. in '~'.No~3~:1. If a subpoena for a production of documents, records or to g2ragiaph 2. ~ (Eff. 7/97) XHIBIT B COYNE & COYNE, P. Henry F. Coyne, Esq. Pa. Supreme Ct. No. 06 3901 Market Street Camp Hill, PA 17011-~ (717) 737-0464 David R Bretz, by Susan Bretz, his attorn~ 7 vs. IN THE COURT OF COMMON PLEAS OF in fact, :CUMBERLAND COUNTY, PENNSYLVANIA ff NO. 09-7658 Civil Term Walter P. Little and Ta a L. Little, his wife; Ray T. Harrig and Mary D. Harrigan his Wife; Milt n Benninger .:CIVIL ACTION -LAW a/k!a Milton Reneker; L 'e Benninger; Jacob R Benninger a/k! J. R Benninger: a/k/a J.R Reneker; Jere y Miller; Abraham Miller; a/k/a bram Miller; Abram Miller heirs at la ;Samuel Miller;: Thachous Miller; Marth Miller; Adeline : . Miller; Francis Qugg; S rah Jane Miller; Jacob Hess; Catherine 'ller; William Bady; John Ga~nber, A rne~-in-fact for Abraham Miller heirs; F ederick May and Magdalona May, his wife;: :ACTION TO QUIET TITLE John Shoop, Administra or For Estate of Jacob Neidig ;Jacob eidig; John Neidig and Mary N idig, his wife Def ndants 1. Expert Witness - Ides for each expert, state: a. The subject r, b. The substanc summary of t each expert you intend to call as a witness at the trial of this matter, and after about which the expert is expected to testify; and of the facts and opinions to which the expert is expected to testify and a e grounds for each opinion. 1 ANSWER: Mark .Romeo, P.L.S. 700 O 'o Avenue Lemo e, PA 17043 Mr. Romeo testimo y will concern the chain of title with regard to the real estate at dispute in the litigation. His to ony will be based information received from the following sources which the Plaintiff reserv the right to amend: deeds for the predecessors in title and the adjoining tracts of real estate, corroboration with other surveyors, past surveys done on the real estate in question and adjo' g tracts of real estate, tax maps, and conversations with adjacent land owners. Plaintiffs reserve a right to amend, supplement and/or clarify the Answers to ,this set of interrogatories pursuant to a rules of civil procedure. Respectfully submitted: CO O Dated: ~ By; Henry F. C e, .squire 3 901 Market Street Camp Hill, PA 1 70 1 1-4227 (717) 73 7-0464 Pa. S. Ct. No. 06250 2 CERTIFICATE OF SERVICE I, Henry F. Coyn ,Esquire, do hereby certify that I have this date served an original of the foregoing Plaintiffs' Resp nses to Defendants' Littles First Set of Interrogatories on the following individual, by depositing a same in the United States mail, postage prepaid and addressed to the following: Linos E. Fenicle, E quire Reager & Adler, P 2331 Market Street Camp Hill, PA 170 1-4642 Date: Henry F. Coyne, squire Attorney for Plai t 3 CERTIFICATE OF SERVICE I, Henry F. Coyn ,Esquire, do hereby certify that I have this date served an original of the foregoing Plaintiff's Petiti n for Protective Order on the following individual, by depositing the same in the United States mail, post ge prepaid and addressed to the following: Linus E. Fenicle, E quire Reager & Adler, P 2331 Market Street Camp Hill, PA 170 1-4642 Date: Henry F. Coyne, Es ire Attorney for Plaintiff MARIA D. Wl CALVIN E. WIS Petitioner's Exhibit IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC KELATIONS SECTION PACSES NO. 546111545 ent :DOCKET NO. 10-421 CIVIL TERM INDEX OF EXHIBITS 1 -Earnings statement Petitioner's Exhibit I~1o. 2 -Correspondence from employer Petitioner's Exhibit o. 3 - Dance studio income/loss statement c~ ~ "~ ~ `~3 Petitioner's Exhibit o. 4 - Dance studio spreadsheet t7 i _.-" ,: ~-~ _ `~~ ' "~~ -- -~; , ~., _ .,, Petitioner's Exhibit o. 5 - Income and expense statement ~ ~~ ~ ~- Petitioner's Exhibit o. 6 - Earnings report for Husband - a ...... ~~ ~ .~ Respondent's Exhibi No. I -Mortgage statement ~ Respondent's Exhibit No. 2 - 2009 joint tax return Respondent's Exhibi No. 3 -Income checks Respondent's Exhibi No. 4 & 5 -Income and expense statements Respondent's Exhibi No. 6 -Dance studio 2009 income and expenses BOILING SPRINGS CARLISLE CHAMBERSBURG MARION MONT ALTO NEWVILLE SHIPPENSBURG WAYNESBORO CALVI S WISER MARIA D WISER 402 S PENN ST LJR SHIPP SBURG PA 17257-8702 10 UST 3 x:502 2~~~6200~: •~~ ~ ~~r ~roR YOUR R~ccro ~: Ef2~~OSlt~l-?~t1 $~~g IYlkTlt Yl~.''IE~3Q -- .1Z <O i ~p~ ~ ;2..?-13- ~2~25~g9 3~T ~-al-1o ~: 71a~OVAT D'[~'!i~' $1, 054.64 'E~i2`A '~FTSR: AMT DUE: $1,054.64 LATE CHARGE AFTER: 1-16-10 $63.28 ENTER AMOUNT PAID ACCOUNT NU1~ER 022-0001-7208974-9001 cTlo~ o~ THIS sTA'P s Y SAX'. RBTA~ TSIs 974-90411 PAt~ 1 O]E' 1 '. *** StLL N?~'IC~ *~r* pAXT DU3 ~'~E PA'~lH~TP 1-Q1-20];p ~,3r tt35!Il'~i4 ~~~ R11TE A 2'IAt+A'~C~ 23AT]~38Y" D . B.O~~S 1~.6.,'S~Q,$3 777.4fi a.OQ$ li, 5~~t.ei 14 #f-Z.51 5.00$ 3~~.6, 6;30.51 527.32- S..ov~ '11~,5~o.a1 250.1s- S:G{1~$ $27'7.1.7- 116,243.54 8.aa~ lx6,a~~.6a I7 ~s39.15 I16,143.b; PRINCIPAL: $252.98 1-16-10 $63.28 > ~ 8 $T's TCt: ~o BOX 6 8~ T$~"i~lt: t71~7) 26 ~ i~A4'R1124T8 TRUST #PAN3[ ~~ URA, PA I7201-6010 -.6216- Q?A 1-888-~64-6116 0022 0520 268 A *** BILLING NOTICE *** PAYMENT DUE DATE: 1-O1-10 PRINCIPAL: $252.98 INTEREST: $801.66 INTEREST: $801.66 . ,. 7-6 ~(o VLr ~ s Department of the Treasury Internal Revenue Service Form 1040 U.S. Individu I Income Tax Return 2009 (ss> IRS Use Only-Do notwritewstapleinthisapace. Label For the year Jan. 1-Dec. 31, 2009, r other tax year beginning , 2009, ending , 20 OMB No. 1545.0074 L Your first name and initial Last name strucfions B Calvin E Wiser Yarn aooar seraarty 190-42-9436 on page 14.) i If a joint return, spouse's first name nd initial Last name t>:e>netRS Maria D Wiser s soul Y ~~ 142-46-4052 ~~ H Home address (number and street). If you have a P.O. box, see a e 14. P 9 Apt. no. You must enter otherwise, E please print R 402 S Penn Str et ~ ourSSN s above. y () or type. E City, town or post office, state, and IP code. If you have a foreign address, see page 14. Checking a bOX beltwv WIII nOt Presidential Shi ensbur PA 17257 change your tax or refund. Election Cam I n Check here if you, or your spouse if filing jointly, want $3 to go to this fund (see page 14) You Spouse 1 Single Filing 4 Head of househdd (with qualifying person). (See page 15.) If the li i 2 X Married filing jointly (eve ty ng person is a child but not your dependent, enter tnla if only one had income) qua ' StatUS child s name here. Check only 3 ~_ Manied filing separately. Enters Ouse's SSN above - one box. and full name here. - 5 Qualifying widow(er) with dependent child (s 16 ee page ) 8a Exem tions }{ Yourself. If so eone can claim you as a dependent, do not check box 6a eoooesdrerJred p b XSpouse .. } oneeandeb 2 ........................ ............... C Depend@nts: I (2) Dependents (~ Dependents Nto. dctridran (4) Check H pr goyMq- qual' ng child (1) First name Lasi na a social security number relationshi ro P for 'Id tax ~ ~ ~ I'~ 1 Britne Wise If more than four 021-68-6938 ou Dau hter t see 17) • did not ire rN7r t'°'~d~e~• ^ or aa aafan p a 8 ~ (~ dependents, see P 0 ^ ~ page 17 and ^ b ~ check here ~ I nota or e ^ d Total number of a emptions claimed ..................... ndd ' °n ~~ - 3 7 Wages, salaries, ti Income s, etc. Attach Form(s) W-2 7 5 3 0 62 ga Taxable interest. ach Schedule B if required ........... 8a Attach Form(s) b Tax-exempt intere t. Do not include on line 8a - 8b W-2 here. Also 9a Ordinary dividend .Attach Schedule B if required ....... ga attach Forms b Qualified dividend (see page 22) - .... 9b W-2G and 10 Taxable refunds, c edits, or offsets of state and local income taxes (see page 23) 10 1099-R if tax 11 Alimony received was withheld. • ' ' ' ' ' ' ' ' ' ' ' ' ' ' ' 11 12 Business income r (loss). Attach Schedule C or C-EZ - - ......... 12 1 193 13 Capital gain or (los If you did not ). Attach Schedule D if required. If not required, check here - ^ 13 get a W-2, 14 Other gains or (los es). Attach Form 4797 - - • ............... 14 see page 22. 15a IRA distributions 15a b Taxable amount (see page 2a) 15b 16a Pensions and ann 7 ities 18a b Taxable amount (See page 25) 16b Enclose, but do 7 Rental real estate, oyalties, partnerships, S corporations, trusts, etc. Attach Schedule E 77 7 94 3 not attach an , y 18 Farm income or (I payment. Also, 19 s). Attach Schedule F - . .............. 18 Unemployment co please use 20 pensation in excess of $2,400 er reci lent see a e 27 - - P P ( P 9 ) 19 a Social security ben Form 1040-v. 21 fits • 120a I I b Taxable amount (See page 27) 20b Other income 21 22 Add the amounts i the far right column for lines 7 through 21. T his is your total Income - • - 22 4 3 92 6 23 Educator expenses Adjusted (see page 29) ...... Y3 ~ Certain business expen Gross s of reservists, pertorming artists, and fee-basis government o Income vials. Attach Form 2106 or 2106EZ 24 25 Health savings ac unt deduction. Attach Form 8889 • • • 25 26 Moving expenses. ttach Form 3903 ... 26 27 One-half of self-em foyment tax. Attach Schedule SE 27 2 7 5 28 Self-employed SEP SIMPLE, and qualified plans 28 29 Self-employed heal h insurance deduction (see page 30) 29 30 Penalty on early wit drawal of savings - - - - 30 31a Alimony paid b Re ipient's SSN - 31a 32 IRA deduction (see age 31) .. - g2 33 Student loan intere t deduction (see page 34) - - - - 33 7 2 8 34 Tuition and fees de uction. Attach Form 8917 - 34 5 Domestic productio activities deduction. Attach Form 8903 35 • • t Add lines 23 throng S bt t li 3 f 31 a and 32 through 35 - . ....... ...... 36 1 0 0 3 u rac ne 6 ro line 22. This is your adjusted gross income .....- 37 4 2 9 2 3 :y Act, and Paperwork eduction Act Notice, see page 97. EEA Form 1040 (2009) 1,~ i_ Folmloao(zoo9>Calvin E & aria D Wiser 190-42-9436 Paget 38 Amount from line j37 (adjusted gross income) • , - - 38 q 2 _ g ~ 3 Tax ana Credits 39a Check ~~ You w ~ ere born before January 2, 1945, Blind. Total boxes ~ ~ ~, ~I Spo s if: checked -39a Blind. e was born before January 2; 1945, Standard b If your spouse itemize o n a separate return or you were actual-status alien, see pg 35 and check here - 39b +';~' , Deduction for- 40a Itemized deducti n s (from Schedule A) or your standard deduction (see left margin) 40a 2 4 2 21 • People who b If you are increasing y u r standard deduction by certain real estate taxes, new motor check any box on line vehide taxes, or a net i saster loss, attach Schedule L and check here (see page 35) - - 40b 39b or 39a 41 Subtract line 40a r om line 38 - - - 41 18 7 0 2 , 40b orw~to can be 42 Exemptions. If lint; 38 is $15,100 or less and you did not provide housing to a Midwestern claimed as a displaced individua l, multiply $3,650 by the number on line 6d. Otherwise, see page 37 42 10 9 5 0 dependent, see page 35. 43 Taxable income. ubtract line 42 from line 41. If line 42 is more than line 41, enter -0- 43 7 7 5 2 • Ali others: ~ Tax (see page 37 . Check if any tax is from: a ~] Form(s) 8814 b ~ Form 4972 • • 44 7 7 8 Single or 45 Alternative mini m tax (see page 40). Attach Form 6251 45 Married filing 48 Add lines 44 and ~ 5 - - - - - - • - 48 7 7 8 - separately, $5,700 ~ 47 Foreign tax credit.l Attach Form 1116 if required 47 Married filing or jointl ~ Credit for child and de dit 49 Ed ti ~ ndent care expenses. Attach Fonn 2441 • ' - ~ line 29 49 'J 7 8 F rm 8863 o y uca on cre s r m o , Wldayy e~}q, 50 Retirement savin contributions credit. Attach Form 8880 50 $11,4 0 g 51 Child tax credit (s a page 42) - - - - 51 0 Head of household, 52 Credits from Form; a ^ a39s b e es39 e ~ ss9s 52 3 $8,350 53 other creditstromF a 3800 b 8801 c 5 ~ Add li 47 thr ur total credits - - - 54 ']'] 8 h 53 Th e are ou~ nes . es yo 55 Subtract line 54 fr m line 46. If line 54 is more than line 46, enter -0- - Sb Q 56 Self-employment t x. Attach Schedule SE • • • - • • • • • • • • • • • • • • • • • • • • • 5s 5 5 0 Other 57 Unreported social ecurity and Medicare tax from Form: a ~ 4137 b ~ 8919 • • • • 57 Taxes 58 Additional tax on I s, other qualified retirement plans, etc. Attach Form 5329 if required 58 • 59 Additional taxes: a 59 ~J AE1C payments b ~ Household employment taxes. Attach Sch. H 60 Add lines 55 throu h 59. This is your total tax - - • - 60 5 5 0 81 Federal income to t P withheld from Forms W-2 and 1099 • • - • 61 4 2 9 8 ' aymen s ~ I ' 62 2009 estimated tax pay ments and amount applied from 2008 return 62 il~ 53 Making work pay and g vemment retlree credits. Attach Schedule M 63 8 0 0 If you have a 64a Earned income crr~ in ualif dit EIC) ( ------'- 64a g y q Child, attach b Nontaxable combat pay ~elecfion 54b Schedule EIC. 65 Additional child tax ', credit. Attach Form 8812 - 85 86 Refundable educa ~ion credit from Form 8863, line 16 88 1 0 0 0 67 First-time homebu er credit. Attach Form 5405 87 68 Amount paid with r ~quest for extension to file (see page 72) 68 89 Excess soda) security a ~d tier 1 RRTA tax withheld (see page 72) 59 70 CredltS from Form: ~ a ~ 2439 b ~ 4136 c ~ 8801 d ~ 8885 7l1 71 Add lines 61, 62, 6 , 64a, and 65 through 70. These are your tota l paym ents • - 71 6 0 9 8 72 If line 71 is more th n line 60, subtract line 60 from line 71. This is the amount you overpaid 72 5 5 4 8 Refund 73a Amount of line 72 u want refunded to you. If Form 8888 is attached, check here • • - ~ 73a 5 5 4 8 Direct deposit? See page 73 - b Routing number X X X X X X X X X k Type: Checking Savings and flit in 73b, - d Account number X X X X X X X X X X X X X X X X X 73c, and 73d, or Form 8888. 74 Amount of line 72 you w nt apptied b yorr 2010 eatinabd fate •- 74 Amount 75 Amount you owe. ubtract line 71 from line 60. For details on how to pay, see page 74 • - 75 YOU We 76 Estimated tax pen a ty (see page 74) - - - - - 76 Do you want to allow ano er person to discuss this return with the IRS (see page 75)? Yes. Complete the following. X No Third Party ' Designee Designee's - Pho~ Personal identification - name no. number (PIN) Sign Under penalties of perjury, I ded re that 1 have examined this return and accompanying schedules and statements, and to the best or my knowledge and belief, Here they are true, coned, and comp ) te. Dedarefion of preparer (other than taxpayer) is based on all information of which preparer has any knowledge. Joint return? Your signature Date Your occupation Dayflme phone number See page 15. Keep a Copy ' ' labor ' s signature. if a joint ret Spouse for your u boor must sign. Date Spouse s occupation records. s e l f em t o e d Paid Preparers Date Check tt Preparers SSN or PTIN signature ' 0 6- 3 0- 2 010 ~tt~mp'°y~ X 17 6- 4 4- 2 2 51 Preparer s Firtn'sname(or oone s Tax Service EIN 25-1756329 Use On{y yur,rs;fselaemp,oyed), , 223 East Kin Street address, andZlPcoda hi ensbur PA 17257 Phone no. 717-532-3446 EEA ! FOr11 7040 (2009) SCHEDULE A Itemized ©eductions OMB No. 1545-0074 (Form 1040) 2009 Departrnent of the Treasury - Atta h to Form 1040. - See Instructions for Schedule A (Form 1040). Attachment Internal Revenue Service (99) Sequence No. 07 Name(s) shown on Fortn 1040 Yaursoud ~~ ~~ Calvin E & Maria D Wi er 190-42-9436 Medical Caution. Do not inclu expenses reimbursed or paid by others. and 1 Medical and dental a nses (see page A-1) - - • .... 1 Dental 2 Enter amount from Fo 1040, line 38 2 Expenses 3 Multiply line 2 by 7.5% (.075) - - - ......... 3 4 Subtract line 3 from lin 1. If line 3 is more than line 1, enter -0- - - - • ....... 4 Taxes You 5 State and local (check only one box): Paid a }{ Income taxes, or 1- ......... 5 1 6 5 6 (See b General sales taxes I page A-2.) 8 Real estate taxes (se page A-5) - - - • ....... g 7 New motor vehicle tax s from line 11 of the worksheet on page 2. Skip this line i you checked box 5b ..... 7 8 Other taxes. List type nd amount - 8 9 Add lines 5 through 8 • . • . • .. ........ ... .......... 9 1 65 6 Interest 10 Home mortgage intere t and points reported to you on Form 1098 10 10 164 You Paid 11 Home mortgage intere t not reported to you on Form 1098. If (See paid to the person fro whom you bought the home, see page page A-G.) A-7 and show that per on's name, identifying no., and address - Note. Personal 11 interest is 12 Points not reported toy ou on Form 1098. See page A-7 for not deductible. special rules - ................. 1Y 13 Qualified mortgage ins rance premiums (see page A-7) - 13 14 Investment interest. A ach Form 4952 if required. (See page A-8.) 14 15 Add lines 10 through 1 - - .......................... 15 10 16 4 Gifts to 18 Gifts by cash or check. If you made any gift of $250 or Charity more, see page A-8 .............. 18 17 Other than by cash or eck. If any gift of $250 or more see If you made a , gift and got a page A-8. You must a ach Folm 8283 if over $500 17 benefit for it, 18 Carryover from prior ye r - 18 see page A-8. 19 Add lines 16 through 1 - • ........................... . 18 Casualty and Theft Losses 20 Casualty or theft loss(e ). Attach Form 4684. (See page A-10.) - . .. ..... Y0 Job Expenses 21 Unreimbursed employ expenses -job travel, union dues, job and Certain education, etc. Attach orm 2106 or 2106-EZ if required. (See Miscellaneous page A-10.) 1!~'ORM 210 6 -E Z 13 2 5 9 21 13 2 5 9 Deductions Y4 Tax preparation fees . ............... 22 (See 23 Other expenses - inves ment, safe deposit box, etc. List type page A-10.) and amount - 23 24 Add lines 21 through 2 - - - - . . . .......... 24 13 2 5 9 25 Enter amount from For 1040, line 38 25 4 2 9 2 3 28 Multiply line 25 by 2% (. 2) - - - ...... ..... 26 8 5 8 27 Subtract line 26 from lin 24. If line 26 is more than line 24, enter -0- 27 12 4 O 1 Other 28 Other -from list on pag A-11. List type and amount - Miscellaneous Deductions 28 Total 28 Is Folm 1040, line 38, o er $166,800 (over $83,400 if married filing separately)? Itemized Deductions [X ~~ No. Your deducti lines 4 throug is not limited. Add the amounts in the far right column for 28. Also, enter this amount on Form 1040, line 40a. - 29 2 4 2 21 ~ ~ ~ Yes. Your deducti may be limited. See page A-11 for the amount to enter. For Papervvork Reduction Act Notice, see su IT you erect to Itemized uctions even though they are less than your standard deduction, check here ............................ - 1040 instructions. EEA Schedule A (Form 1040) 2008 SCHEDULE C Profit or~Loss from Business °"'a"°~'~~-0°74 (Form 1040) . (Sole Proprietorship) Department of the Treasury - P 209 rtnerships, joint ventures, etc., generally must file Form 1065 or 1065-B. Internal Revenue Service (s9) - Attach t Form 7040, 1040NR, or 1041. - See Instructions for Schedule C (Form 1040). Seq~uenc~e No. 09 Name of proprietor Maria D Wiser ~~~~~ 142-46-4052 A Principal business or profession, incl ding product or service (seepage C-2 of the instructions) B ~~~,,, Pis r-s ~o a ~~ STUDIO - C Business name. If no separate busin ss name, leave blank. p Fst~loysrpnunber(ErM rant' CENTER STAGE STUDIO E Business address (including suite or oom no.) - 62 East King Street City, town or post office, state, and ZI code Sh1 ensbur PA ' 17257 F Accounting method: (1) ash (2) X Accrual (3) Other (specify) - G Did you "materially participate" in the operation of this business during 2009? If "No," see page C-3 for limit on losses X Yes No H If you started or acquired this busine s during 2009, check here • ...................... - Income 1 Gross receipts or sales. Caution. Se page C-4 and check the box if: ~ This income was reported to you n Form W-2 and the "Statutory employee" box on that form was checked, or • - ~ 1 3 4 7 4 2 ~ You are a member of a qualified j int venture reporting only rental real estate income not subject to self-employme t tax. Also see page C-3 for limit on losses. 2 Returns and allowances . ......................... 2 3 Subtract line 2 from Tine 1 - .................... 3 3 4 7 4 2 4 Cost of goods sold (from line 42 on p ge 2) - .. ................... 4 12 8 8 8 5 Gross profit. Subtract line 4 from line 3 - . ............... 5 21 8 5 4 6 Other income, including federal and ate gasoline or fuel tax credit or refund (see page C-4) 6 3 02 0 7 Gross income. Add lines 5 and 6 • . . ...................... - 7 2 4 $ 7 4 EX enses. Enter expe ses for business use of your home only on line 30. 8 Advertising - .. 1 562 i8 Office expense • is 3 693 9 Car and truck expenses (see 19 Pension and profit-sharing plans 19 page C-4) - .. 20 Rent or lease (see page C-8): 10 Commissions and fees 0 a veniGes, machinery, and equipment ., 20a 11 Contract labor (see page C-4) 1 b Other business property 20b 6 4 2 2 12 Depletion - - 2 21 Repairs and maintenance 21 2 5 0 13 Depreciation and section 179 22 Supplies (not inGuded in Part III) 22 9 5 3 expense deduction (not 23 Taxes and licenses 23 included in Part III) (see page 24 travel, meals, and entertainment: C_5) .............. 3 6 5 6 0 a Travel ............. 24a 1 5 2 7 14 Employee benefit programs b Deductible meals and (other than on line 19) 1 entertainment (see page C-6) 24b 15 Insurance (other than health) 1 5 1 14 6 25 Utilities ... 25 3 121 16 Interest: M 26 Wages pass employment credits) 26 a ortgage (paid to banks, etc.) 1 a 27 Other expenses (from line 48 on b Other ............. 1 b page 2) ......... 27 18 411 17 Legal and professional services ........... 1 28 Total expenses before expenses for siness use of home. Add lines 8 through 27 - - - 28 4 3 6 4 5 29 Tentative profit or (loss). Subtract line 8 from line 7 - - - • ................. 29 18 7 71 30 Expenses for business use of your ho e. Attach Form 8829 ................ 30 31 Net profit or (loss). Subtract line 30 fr m line 29. ~ If a profit, enter on both Form 1040 line 13 (If you checked the box on line line 12, and Schedule SE, line 2, or on Form 1040NR, 1, see page C-7). Estates and trusts, enter on Form 1041, 31 (18 7 71 ) line 3. ~ If a loss, you must go to line 32. 32 If you have a loss, check the box that ascribes your investment in this activity (see page C-7). ~ If you checked 32a, enter the loss Form 1040NR, line 13 (if you checked n both Form 1040, line 12, and Schedule SE, line 2, or on 32a ~ All investment is at risk. he box on line 1, see the fine 31 instructions on page C-7). 32b Some investment is not Estates and trusts, enter on Form 104 ~~.._.. _ ,line 3. at risk. ~carncu JLY, you nms~ attacp roan o7ya. tour loss may be IIttllted. For Paperwork Reduction Act Notice, page C-9 of the instructions. EEA Schedule C (Form 1040) 2009 ScheduleC(Form104o)2009 STUD~O 999999 Page 2 Name(s) SSN Maria D Wiser 142-46-4052 Cost of Goo s Sold (s ee page c-8) 33 Method(s) used to value closing inventory: a ~ C s t b ~ Lower of cost or market c ~ Other (attach explanation) 34 Was there any change in determin' If "Yes," attach explanation g quantities, costs, or valuations between opening and closing inventory? - - - - - - - ~ Yes ~ No 35 Inventory at beginning of year. If d Brent from last year's closing inventory, attach explanation 35 38 Purchases less cost of items withd wn for personal use - - - 36 37 Cost of labor. Do not include any a ounts paid to yourself - 37 12 8 8 8 38 Materials and supplies ------ 38 39 Other costs .......... ................................. 39 40 Add lines 35 through 39 - - - - 40 12 8 8 8 41 Inventory at end of year - - - - 41 42 Cost of goods sold. Subtract line 1 from line 40. Enter the result here and on page 1, line 4 - - - 42 12 8 8 8 Information on Your Vehicle. Complete this part only if you are claiming car or truck expenses on line 9 and are not required to file omt 4562 for this business. See the instructions for line 13 on page C-5 to find out if you must file Form 4 2. 43 When did you place your vehicle in ervice for business purposes? (year, month, day) - 44 Of the total number of miles you dro a your vehicle during 2009, enter the number of miles you used your vehicle for: a Business b Commuting (see instructions) c Other 45 Was your vehicle available for pens al use during off-duty hours? - - - ~ ~ Yes ~~ No 48 Do you (or your spouse) have anoth r vehicle available for personal use? - - ~ Yes ~ No 47 a Do you have evidence to support yo r deduction? - - - - - CJ Yes ~ No b If "Yes," is the evidence written? - - - Yes No Other Ex enses. List b low business expenses not included on lines 8-26 or line 30. MERCHANDISE 5 804 COSTUMES 4 991 VIDEO 1 220 STUDIO EXTRAS 2 994 AUTO 2 127 PHONE 1 275 48 Total other expenses. Enter here an d on page 1, line 27 • • • • • • • • • • • • • • • • • • • • • - • 48 18 411 eEA ~ Schedule C (Form 1040) 2009 ()Mtl NO. 'IOao-W/4 Profit or doss From Business SCHEDULE C (Form 1040) (Sole Proprietorship) 2009 - Pa erships, joint ventures, etc., generally must file Form 1065 or 1065-B. Department of the Treasury - Attach to or 1041. - See Instructions for Schedule C (Form 1040). 1040NR orm 1040 Attachment Sequence No. O9 Internal Revenue Service (ss) , , Name of proprietor ~'BQ1~rniieef (SSM Calvin E Wiser 190-42-9436 A Principal business or profession, inclu ing product or service (see page C-2 of the instructions) B ryrerooast~ampapesc-e. to, a» ICECREAM TRUCK - C Business name. If no separate busine s name, leave blank. D ~4kyar~~~O~M.~~Y CALVIN WISER E Business address (including suite or r om no.) - 402 S . Penn Street City, town or post office, state, and ZIP code Shi ensbur PA 17 2 57 F Accounting method: (1) X C sh (2- Accrual (3) Other (specify) - G Did you "materially participate" in the Aeration of this business during 2009? If "No," see page C-3 for limit on losses X Yes No H If you started or acquired this busines during 2009, check here - - - Inc me 1 Gross receipts or sales. Caution. See age C-4 and check the box if: ~ This income was reported to you o on that form was checked, or Form W-2 and the "Statutory employee" box • - 1 7 200 ~ You are a member of a qualified jo' t venture reporting only rental real estate income not subject to self-employmen tax. Also see page C-3 for limit on losses. 2 Returns and allowances - 2 3 Subtract line 2 from line 1 - - - - - - 3 7 2 0 0 4 Cost of goods sold (from line 42 on p ge 2) 4 5 Gross profit. Subtract line 4 from line 5 7 2 0 0 6 Other income, including federal and s ate gasoline or fuel tax credit or refund (see page C-4) - 6 7 Gross income. Add lines 5 and 6 •- 7 7 2 0 0 EX en3eS. Enter expen es for business use of your home only on line 30. 8 Advertising 18 Office expense - - 18 2 5 0 0 9 Car and truck expenses (see 19 Pension and profit-sharing plans 19 page C-4) - - 20 Rent or lease (see page C-6): 10 Commissions and fees 0 a vehicles, machinery, and equipment 20a 11 Contract labor (see page C-4) 1 b Other business property 20b 4 0 0 12 Depletion - 2 21 Repairs and maintenance - - 21 13 Depreciation and section 179 22 Supplies (not induded in Part III) 22 expense deduction (not 23 Taxes and licenses - 23 included in Part III) (see page 24 Travel, meals, and entertainment: C-5) ............. 3 a Travel ............ 24a 14 Employee benefit programs b Deductible meals and (other than on line 19) 4 entertainment (see page C-li) 24b 15 Insurance (other than health) 5 25 Utilities - 25 16 Interest: 26 Wages Qess employment credits) 26 a Mortgage (paid to banks, etc.) 1 27 Other expenses (from line 48 on b Other • - 1 b page 2) • - 27 3 5 5 17 Legal and professional services • • • - • • • • • • • 7 5 5 28 Total expenses before expenses for usiness use of home. Add lines 8 through 27 - - - - - - • - 28 ____ _ 3 L 310 29 Tentative profit or (loss). Subtract lin 28 from line 7 - - - - - - 29 3 8 9 0 30 Expenses for business use of your h me. Attach Form 8829 - 30 31 Net profit or (loss). Subtract line 30 om line 29. ~ If a profit, enter on both Form 1 line 13 (If you checked the box on lin ,line 12, and Schedule SE, line 2, or on Form 1040NR, 1, see page C-7). Estates and trusts, enter on Form 1041, 31 3 8 9 0 line 3. ~ If a loss, you must go to line 32. 32 If you have a loss, check the box that describes your investment in this activity (see page C-7). ~ If you checked 32a, enter the loss on both Form 1040, Ilne 12, and Schedule SE, Ilne 2, or on 32a All investment is at risk. Form 1040NR, line 13 (rf you check the box on line 1, see the line 31 instructions on page C-7). 32b Some investment is not Estates and trusts, enter on Form 1 1, line 3. at risk. ~ If you checked 32b, you must atta~h Form 6198. Your loss may be limited. For Paperwork Reduction Act Notice, see page C-9 of the Instructions. EEa, Schedule C (Form 1040) 2009 ScheduleClForm104012009 TCFCRFTAM TRIICK 99999 Page Q Name(s) SSN Calvin E Wiser 190-42-9436 Cost of Goods Sold ( e page C-8) 33 Method(s) used to value closing inventory: a ~ Cos b ~ Lower of cost or market c ~ Other (attach explanation) 34 Was there any change in determinin If "Yes," attach explanation quantities, costs, or valuations between opening and closing inventory? - ~ Yes ~ No 35 Inventory at beginning of year. If dill rent from last years closing inventory, attach explanation - 35 36 Purchases less cost of items withdra n for personal use - - 38 37 Cost of labor. Do not include any a ounts paid to yourself - - - - - 37 38 Materials and supplies -- 38 39 Other costs ........... ~ ................................. 39 40 Add lines 35 through 39 ~ - 40 41 Inventory at end of year ~ 41 42 Cost of goods sold. Subtract line 4 from line 40. Enter the result here and on page 1, line 4 42 Information on Your ehiCle. Complete this part only if you are claiming car or truck expenses on line 9 and are not required to file rm 4562 for this business. See the instructions for line 13 on page C-5 to find out if you must file Form 45 2. 43 When did you place your vehicle in ervice for business purposes? (year, month, day) - 44 Of the total number of miles you dro a your vehicle during 2009, enter the number of miles you used your vehicle for: a 45 Business ~ Was your vehicle available for pens b Commuting (see instructions) c Other al use during off-duty hours? - - ~ Yes ~ No 48 Do you (or your spouse) have anoth $r vehicle available for personal use? - - - C~ Yes U No 47 a Do you have evidence to support yo ~r deduction? - - - ~ Yes ~~ No b If "Yes," is the evidence written? - - - - - - 'Yes No Other Ex eases. List low business expenses not included on lines 8-26 or line 30. PHONE 355 48 Total other expenses. Enter here a on page 1, line 27 - - 48 3 5 5 EEA ~ Schedule C (Form 104012009 Profit or•Loss•From Business OM8NO.1545-0074 SCHEDULE C (Form 1040) (Sole Proprietorship) 2~~9 - P rtnerehips, joint ventures, etc., generally must Tile Form 1065 or 1085-B. Department of the Treasury intemai Revenue Service (ss) - Attach to Form 1040, 1040NR, or 1041. -See Instructions for Schedule C Form 1040. ( ) Attachment Sequence No. Q9 Name of proprietor soaetsea.ityrnmbertSSN) Maria D Wiser 142-46-4052 A Principal business or profession, incl ding product or service (see page C-2 of the instructions) B ~~yo,,, ~~. ~o.a ~~ ICECREAM TRUCK - C Business name. If no separate busin ss name, leave blank. D E„rpwyarsfl,,,.,,eer~,aa„y MARIA WISER E Business address (including suite or oom no.) - 4 02 S Penn Street City, town or post office, state, and ZI code Shi ensbur PA 17257 F Accounting method: (1) X ash (2) Accrual (3) Other (specify) - G Did you "materially participate" in the Aeration of this business during 2009? If "No," see page C-3 for limit on losses X Yes No H If you started or acquired this busine during 2009, check here - - - - - • - Income 1 Gross receipts or sales. Caution. Se page C-4 and check the box if: ~ This income was reported to you n Form W-2 and the "Statutory employee" box on that form was checked, or • - ~ 1 3 0 6 0 0 ~ You are a member of a qualified j int venture reporting only rental real estate income not subject to self-employme t tax. Also see page C-3 for limit on losses. 2 Retumsandallowances --- 2 3 Subtract line 2 from line 1 - - - - - - - 3 3 0 6 0 0 4 Cost of goods sold (from line 42 on p ge 2) - - - - 4 S Gross profit. Subtract line 4 from lin 3 - - - - - - - 5 3 0 6 0 0 6 Other income, including federal and fate gasoline or fuel tax credit or refund (see page C-4) - - 6 7 Gross income. Add lines 5 and 6 - - - - - - - - • - 7 3 0 6 0 0 EX enses. Enter expe ses for business use of your home only on line 30. 8 Advertising - - - - - 8 18 Office expense 18 9 Car and truck expenses (see 19 Pension and profit-sharing plans 19 page C-4) 9 5 7 5 20 Rent or lease (see page C-6): 10 Commissions and fees 0 a veniGes, machinery, and equipment 20a 11 Contract labor (see page C-4) 1 b Other business property 20b 8 0 0 0 12 Depletion 2 21 Repairs and maintenance 27 13 Depreciation and section 179 22 Supplies (not induded in Part III) - 22 expense deduction (not 23 Taxes and licenses - 23 included in Part III) (see page 24 Travel, meals, and entertainment: C-5) - 3 aTravel -- 24a 14 Employee benefit programs b Deductible meals and (other than on line 19) 4 entertainment (see page C-6) 24b 15 Insurance (other than health) 5 25 Utilities - - - 25 18 Interest: 26 Wages (less employment credits) 26 a Mortgage (paid to banks, etc.) - 1 a 27 Other expenses (from line 48 on b Other ... 1 b page 2) ........ 27 8 3 3 7 17 Legal and professional services 7 28 Total expenses before expenses for usiness use of home. Add lines 8 through 27 - - - 28 16 , 912 29 Tentative profit or (loss). Subtract lin 28 from line 7 - - - - - - - - - - ..... 2g 13 6 8 8 30 Expenses for business use of your h me. Attach Form 8829 - - - - - - ..... 30 31 Net profit or (loss). Subtract line 30 f om line 29. ~ If a profit, enter on both Form 104 ,line 12, and Schedule SE, line 2, or on Form 1040NR, line 13 (If you checked the box on lin 1, see page C-7). Estates and trusts, enter on Form 1041, 31 13 6 8 8 line 3. ~ If a loss, you must go to line 32. 32 If you have a loss, check the box that escribes your investment in this activity (see page C-7). ~ If you checked 32a, enter the loss n both Form 1040, line 12, and Schedule SE, line 2, or on 32a r~ All investment is at risk. Form 1040NR, line 13 (if you check the box on line 1,'see the line 31 instructions on page C-7). 32b ~ Some investment is not Estates and trusts, enter on Form 1 1, line 3. at risk. checked 32b, you must attach Form 6198. Your loss may be limited. For Paperwork Reduction Act Notice, se~ page C-9 of the instructions. EEA Schedule C (Form 1040) 2009 ScheduleC(Form1040)2009 TCECR~AM TRUCK 562000 • Page Q Name(s) SSN Maria D Wiser 142-46-4052 f ` Cost of Goods Sold ( ee page C-8) 33 Method(s) used to n value closing inventory: a ` J Co t b ~ Lower of cost or market c ~ Other (attach explanation) 34 Was there any change in detemtinin If "Yes," attach explanation quantities, costs, or valuations between opening and closing inventory? - - - - - ~~ Yes ~J No 35 Inventory at beginning of year. If di rent from last year's closing inventory, attach explanation 35 38 Purchases less cost of items withdr n for personal use - 38 37 Cost of labor. Do not include any a ounts paid to yourself - 37 38 Materials and supplies ~----- 38 39 Other costs ........... ~ ................................. 39 40 Add lines 35 through 39 - - - - 40 41 Inventory at end of year 41 42 Cost of goods sold. Subtract line 4 from line 40. Enter the result here and on page 1, line 4 42 Information on Your ehicle. Complete this part only if you are claiming car or truck expenses on line 9 and are not required to file orm 4562 for this business. See the instructions for line 13 on page C-5 to find out if you must file Form 45 2. 43 When did you place your vehicle in ervice for business purposes? (year, month, day) 44 Of the total number of miles you dro a your vehicle during 2009, enter the number of miles you used your vehicle for: a Business b Commuting (see instructions) c Other 45 Was your vehicle available for pens nal use during off-duty hours? - - - - - - ~ Yes ~ No 48 Do you (or your spouse) have anoth r vehicle available for personal use? - - - ~ ~ Yes ~l No 47 a Do you have evidence to support yo r deduction? - - - - - ~~ Yes ~~ No b If"Yes,"is the evidence written? --•..-.. Yes No Other Ex enses. List elow business expenses not included on lines 8-26 or line 30. DUMPING 6 700 WEIGHING LOADS 189 PERMITS 150 PHONE 1 298 4s Total other expenses. Enter here a don page 1, line 27 - • • • • • • • • • • • • - • - • • • - - • • 48 8 3 3 7 eea j Schedule C (Form 1040) 2009 CHEDULE E Supplemental Income and Loss oMBNo.1545-0074 S (Form 1040) Department of the Treasury Internal Revenue Service (89) MiarJr b (From rental real estate, royalties, partnerships, S corporations, estates, trusts, REMICs, etc.) arm 7010.1040PR, aFarm 1041. - See bs6rwia~e for Sohsdaule E (Farm 70~. 2009 Attachment Sequence No. ~ 3 Name(s) shown on return Calvin E & Maria D Wi ser Ya~sarial ~~ ry°~ 190-42-9436 Income or Loss From Renta Schedule C or C-EZ (see pa Real Estate and Royalties Note. If you are in the business of renting personal property, use a E-3). If you are an individual, report farm rental income or loss from Form 4835 on page 2, line 40. 1 List the type and address of each re tai real estate property: 2 For each rental real estate property Yes No A rental ro eert listed on line 1, did you or your family l i h f 25-27 LinCOln Wa est or persona ng t e tax year use it dur reater of: oses for more than the ur A X g p p g 14 days or ~ ~ 10% of the total days rented at fair B C rental value? (See page E-3.) C Income: Pro ernes Totals A B C (Add columns A, B, and C.) 3 Rents received - 3 2 5 9 8 8 3 2 5 9 8 8 4 Royalties received 4 4 Expenses: 5 Advertising 5 6 Auto and travel (see page E-4) - - 6 1 7 51 7 Cleaning and maintenance 7 8 Commissions - 8 e Insurance •--•••••••-- - 9 960 10 Legal and other professional fees • 10 11 Management fees - 11 12 Mortgage interest paid to banks, etc. (see page E-5) - - 12 11 8 8 5 12 11 8 8 5 13 Other interest - - - 13 14 Repairs - 14 5 662 15 Supplies- - 15 16 Taxes •--•••••••••• is 3 117 17 Utilities -- - 17 5 522 18 Other (list) - 18 19 Add lines 5 through 18 19 2 $ $ 97 19 2 $ $ 97 20 Depreciation expense or depletion (see page E-5) 20 5 0 3 4 2u 5 0 3 4 21 Total expenses. Add lines 19 and 2 21 3 3 931 22 Income or (loss) from rental real estate or royalty properties. Subtract line 21 from line 3 (rents) o line 4 (royalties). If the result is a (loss), see page E-5 to find out if you must file Form 8198• - 2 9 4 3 23 Deductible rental real estate loss. Caution. Your rental real estate loss on line 22 may be limited. See page E-5 to find out if you must file Form 8582. Real estate professionals mu complete line 43 on page 2 .. 3 7 9 4 3 ) ) ) 24 Income. Add positive amounts sho on l ine 22 . Do not include anv lo sses - - - 24 25 Losses. Add royalty losses from line 22 and rental real estate losses from line 23. Enter total losses here 28 Total rental real estate and royalty ncorrre or (loss-. Combine lines 24 and 25. Enter the result here. If Parts II, III, IV, and line 40 on pag 2 do not apply to you, also enter this amount on Form 1040, line 17, or Form 1040NR, line 18. Othe ise, include this amount in the total on line 41 on page 2 For Paperwork Reduction Act Notice, see page E-8 of the instructions. EEA 12s I( 7, 943) ..... 128 I (7, 943) Schedule E (Forth 1040) 2009 SCHEDULE SE OMB No. 1545-0074 (Form 1040) Self-Employment Tax 2009 Department of the Treasury Internal Revenue Service (ag) - ttach to Form 1040. - See Instructions for Schedule SE (Form 1040). Attachment Sequence No. Name of person with self~mployment in ome (as shown on Form 1040) Social security number of person Calvin E Wiser wtthself~rrtploymentincome - 190-42-9436 Who Must File Schedule SE You must file Schedule SE if: ~ You had net eamings from self-emplo ant from other than church employee income (line 4 of Short Schedule SE or line 4c of Long Schedule SE) of $400 or more, r , ~ You had church employee income of 108.28 or more. Income from services you performed as a minister or a member of a religious order is not church employe income (see page SE-1). Note. Even if you had a loss or a small a ount of income from self-employment, it may be to your benefit to file Schedule SE and use either "optional method" in Part II of Long Schedule SE (see page SE-4). Exception. If your only self-employment ncome was from earnings as a minister, member of a religious order, or Christian Science practitioner and you filed Form 4361 and received IRS approval not to be taxed on those eamings, do not file Schedule SE. Instead, write "Exempt-Form 4361" on Form 1040 line 56. May I Use Short Schedule SE r Must I Use Long Schedule SE? Note. Use this flowchart only if you must Ile Schedule SE. If unsure, see Who Must File Schedule SE, above. Did you receive weees ar lips in 20087 No Yas Are you a minister, member of a religious order, o Christian Saence practitioner who received IRS approval nd to be taxed YeS Was the total of your wages and tips subject to aoaal security Yes on eamings from these sources, but you owe elf-employment or railroad retirement (tier 1) fax plus your net eamings from tax on other eamings? self-employment more than $106 800? , No Are you using one of the optional methods to figu your net Yes No eamings (see page SE-4)? Did you receive tips subject to soaal security or Medicare tax Y6S that you did not report to your employer? No No Did you receive church employee income repo ed on Forrn Yes No Did you report any wages on Fonn 8919, Uncollected Social YeS W-2 of $108.28 or more? Security and Medicare Tax on Wages? O You may use ShoR Sdtedrre SE You moat use Larry Sdradde SE an papa 2 Section A -Short Schedule SE. Caution. Read above to see if you can use Short Schedule SE. 1 a Net farm profit or (loss) from Sche ule F, line 36, and farm partnerships, Schedule K-1 (Form 1065), box 14, code A .... ..................................... 1a b If you received social security retire ant or disability benefits, enter the amount of Conservation Reserve Program payments included on Sc edule F, line 6b, or listed on Schedule K-1 (Form 1065), box 20, code Y 1b 2 Net profit or (loss) from Schedule ,line 31; Schedule C-EZ, line 3; Schedule K-1 (Form 1065), box 14, code A (other than farming ;and Schedule K-1 (Form 1065-B), box 9, code J1. Ministers and members of religious orders, see page SE-1 for types of jncome to report on this line. See page SE-3 for other into a to report ............. 2 3 8 9 0 3 Combine lines 1 a, 1 b, and 2 ......................... 3 3 8 9 0 4 Net earnings from self-employme t. Multiply line 3 by 92.35% (.9235). If less than $400, do not file this schedule; you do not o self-employment tax - ......... - 4 3 5 92 S Self-employment tax. If the amou on line 4 is: ~ $106,800 or less, multiply line 4 y 15.3% (.153). Enter the result here and on Form 1040, Ilne 56. ~ More than $106,800, multiply lin 4 by 2.9% (.029). Then, add $13,243.20 to the result. Enter the total here and on Form 1 40, line 56 ......... 5 5 5 0 6 Deduction for one-half of self-amp oyment tax. Multiply line 5 by 50% (.5). Enter the result here nd on Fofrn 1040, line 27 6 2 7 5 For Paperwork Reduction Act Notice, s Form 1040 instructions. EEA Schedule SE (Form 104012009 Educa ion Credits (American Opportunity, Hope, and OMB No. 1545-0074 Forrn 8863 Lifetime Learning Credits) 2009 - See eparete Instructions to find out if you are eligible to take the credits. Attachment Department of the Treasury Internal Revenue Service (99) - Attach t0 FOrm 1040 or Form 1040A. Sequence No. 50 Name(s) shown on return Yam aoaal ~ ^1°~ Calvin E & Maria D Wis er 190-42-9436 Caution: You cannot take both an educatio credit and the tuition and fees deduction (see Form 8917) for the same student for the same year. American Opportunity Credit Use Part II if you are claiming a Hope credit for a student attending school in a Midwestern disaster area. If you use Part II, you cannot use Part I f r any student. Caution: You cannot take the merican opportunity credit for more than 4 tax years for the same student 1 (a) Student's name (b Student's (c) Qualified (d) Subtract $2,000 (e) Multiply the (~ It column (d) is zero, (as shown on page 1 so ial security expenses (see from the amount in amount in column enter theamounttrom of your tax return) n mber (as instructions). Do column (c). If zero (d) by 25% (.25) column (c). Otherwise, First name sho non page 1 not enter more or less, enter -0-. add 52,000 ro the Last Warne of y ur tax return) than $4,000 for each student. amount in column (e). Britney________ Wiser 021 68-6938 4 000 2 000 500 2 500 --------------- 2 Tentative American opportunity cre it Add the amounts on line 1, column (f). Skip Part II if line 2 is more than zero. If you are taking the I fetime learning credit for a different student, go to Part III; otherwise, go to Part IV - - - - - 2 2 5 0 0 Hope Credit Use this part if you are claimi g the Hope credit for a student attending school in a Midwestern disaster area and elect to waive the computation meth in Part I for all students. Caution: You cannot take th Hope credit for more than 2 tax years for the same student 3 (a) Student's name ( )Student's (c) Qualified (d) Enter the smaller (e) Add (f) Enter one-half (as shown on page 1 so ial security expenses (see of the amount in column (c) and of the amount in of your tax return) n mber (as instructions). Do column (c) or column (d) column (e) First name sho on page 1 of not enter more $1,200'" Last name yo r tax return) than $2,400* for each student. --------------- --------------- --------------- 'For each student who attended an eligible ed cagonal institution in a Midwestern disaster area, do rqt enter more than $4,800. "For each student who attended an eligible rational insfttution in a Midwestern disaster area, enter fhe ama~er of the amount in column (c) or 52,400. 4 Tentative Hope credit Add the amo nts on line 3, column (f). If you are taking the lifetime learning credit for another student, go to Part II; otherwise, go to Part V - - - - - - • - 4 Lifetime Learning C dlt. Caution: You cannot take the American opportunity credit or the Hope credit and the lifetime learning credit fort same student in the same year. 5 (a) Student's name ( s shown on page 1 of your tax return) (b) Student's social security (c) Qualified number (as shown on page expenses (see First name Last name 1 of your tax return) instructions) 8 Add the amounts on line 5, column ( ), and enter the total - - - 8 7a Enter the smaller of line 6 or $10,00 - - - - 7a b For students who attended an eligibl educational institution in a Midwestern disaster area, enter the smaller of $10,000 or their qualified expense included on line 6 (see special rules on page 3 of the instructions) - 7b c Subtract line 7b from line 7a - - - - - - - - 7c 8a Multiply line 7b by 40% (.40) - - - - - 8a b Multiply line 7c by 20% (.20) - - 8b C Tentative lifetime learning Credit dd lines Sa and 8b. If you have an entry on line 2, go to Part IV; otherwise go to Part V 13C For Paperwork Reduction Act Notice, see age 5 of separate instructions. EEA Form 8883 (2009) Form 8863 (2009) Page 2 s Enter the amount from line 2 ~ - I 9 I ~ _ 5 () () 10 Enter: $180,000 if married filing joint y; $90,000 if single, head of household, or qualifying widow(er) 10 18 0 0 0 0 11 Enter the amount from Form 1040, li a 38,' or Form 1040A, line 22 11 4 2 92 3 12 Subtract line 11 from line 10. If zero r less, stop; you cannot take any education credit • • • • • • • • • • - • • • • • • • • 12 13 7 0 7 7 13 Enter: $20,000 if married filing joint ; $10,000 if single, head of household, or qualifying widow(er) -- 13 2 0 0 0 0 14 If line 12 is: ~ Equal to or more than line 13, en r 1.000 on line 14 - - - - - - - ~ Less than line 13, divide line 12 line 13. Enter the result as a decimal (rounded to 14 1 . 0 0 0 at least three places) - 15 Multiply line 9 by line 14. Caution: If ou were under age 24 at the end of the year and meet the conditions on page 5 of the instr coons, you cannot take the refundable American opportunity credit. Skip line 16, enter the amoun from line 15 on line 17, and check this box - • - ~ 15 2 5 0 0 18 Refundable American opportunity redit. Multiply line 15 by 40% (.40). Enter the amount here and on Form 1040, line 66, or Form 104 A, line 43. Then go to line 17 below 18 1 0 0 0 Nonrefundable Educ tion Credits 17 Subtract line 16 from line 15 - 17 1 5 0 0 18 Add line 4 and line 8c. If you haven entry on these lines, skip lines 19 through 24, and enter the amount from line 17 on line 25 - - - 18 19 Enter: $120,000 if married filing join y; $60,000 if single, head of household, or qualifying widow(er) 19 20 Enter the amount from Form 1040, I' a 38,' or Form 1040A, line 22 20 21 Subtract line 20 from line 19. If zero r less, skip lines 22 and 23, and enter zero on line 24 • 21 22 Enter: $20,000 if married filing joint) ; $10,000 if single, head of household, or qualifying widow(er) - 22 23 If line 21 is: ~ Equal to or more than line 22, en er the amount from line 18 on line 24 and go to line 25 ~ Less than line 22, divide line 21 y line 22. Enter the result as a decimal (rounded to at least three places) .......... ..................................... 23 24 Multipy line 18 by line 23 - • - 24 26 Add line 17 and line 24. If zero, sto ;you cannot take any nonrefundable education credit 25 1 5 0 0 28 Enter the amount from Form 1040, I ne 46, or Form 1040A, line 28 - 26 '7'7 8 27 Enter the total, if any, of your credits from: ~ Form 1040, lines 47, 48, and the ~ Form 1040A, lines 29 and 30 mount from Schedule R entered on line 53 - - - - ~ • - 27 28 Subtract line 27 from line 26. If zero r less, stop; you cannot take any nonrefundable education credit ............. ..................................... 2g 778 29 Nonrefundable education credits. nter the smaller of line 25 or line 28 here and on Form 1040, line 49, or Form 1040A, line 31 - .. 29 7'7 8 "If you are filing Form 2555, 2555-E , or 4563, or you are excluding income from Puerto Rico, see Pub. 970 for the amount to enter. EEA Form 8883(2009) EZ 2106 OMB No. 154rr0074 - Forrn Un eimbursed Employee Business Expenses 2009 Attachment Department of the Treasury Internal Revenue Service 99 ~ Attach to Form 1040 or Form 1040NR. Sequence No. 129A Your name Occupation in which you incurted expenses Solid ssouriq nunf~ You May Use This Form Only ff All of the F Ilowing Apply. ~ You are an employee deducting ordinary and necessary expenses attributable to yourjob. An ordinary expense is one that is common and accepted in your field of trade business, or profession. A necessary expense is one that is helpful and appropriate for your business. An expense does not ha to be required to be considered necessary. ~ You do not get reimbursed by your empl yer for any expenses (amounts your employer included in box 1 of your Form W-2 are not considered reimbursements for this pur ose). ~ If you are claiming vehicle expense, you re using the standard mileage rate for 2009. Caution: You can use the standard mileag rate for 2009 only If: (a) you owned the vehicle and used the standard mileage rate for the first year you placed the vehicle in service, or (b) you leased the vehicle and used the standard mileage rate for the portion of the lease period after 1997. ""'` Figure Your Expens s 1 Vehicle expense using the standard ileage rate. Complete Part II and multiply line 8a by 55 cents (.55) ............... ................................. 1 13 259 2 Parking fees, tolls, and transportation including train, bus, etc., that did not involve overnight travel or commuting to and from work - 2 3 Travel expense while away from horn overnight, including lodging, airplane, car rental, etc. Do not include meals andentertaimm ~t -- 3 4 Business expenses not included on li es 1 through 3. Do not include meals and entertainment ........... ................................. 4 5 Meals and entertainment expenses: x 50% (.50). (Employees subject to Department of Transportation (DOT) ours of service limits: Multiply meal expenses incurred while away from home on business b 80% (.80) instead of 50%. For details, see instructions.) 5 6 Total expenses. Add lines 1 through .Enter here and on Schedule A (Form 1040), Tine 21 (or on Schedule A (Form 1040NR), II a 9). (Armed Forces reservists, fee-basis state or local government officials, qualified perfo ing artists, and individuals with disabilities: See the instructions for special rules on whey to enter this amount.) 6 13 2 5 9 InfOrlYtBtlon On YOU+ Vehicle. Complete this part only if you are claiming vehicle expense on line 1. 7 When did you place your vehicle in se ice for business use? (year, month, day) ~ 2 0 0 8 - O 1- 01 8 Of the total number of miles you drove your vehicle during 2009, enter the number of miles you used your vehicle for: a Business 2 4 , 10 8 ¢ Commuting (see instructions) c Other 9 Was your vehicle available for person~l use during off-duty hours? - []Yes ~ ] No -- 10 Do you (or your spouse) have another vehicle available for personal use? ~ Yes ~ No 11a Do you have evidence to support yourdeduction? - • ~ Yes [] No b If "Yes," is the evidence written? - - - ~ Yes ~ No For Paperwork Reduction Act Notice, see page 4. EEA Form 2106-F1(2009) SCHEDULE M Making Work Pay and Government OMB No. 1545-0074 (Form 1oa0A or 1040) Retiree Credits 2009 Department of the Treasury Attachment Internal Revenue Service (ss) - A ch to Form 1040A, 1040, or 1040NR. ~ See separate instructions. Sequence No. 166 Name(s) shown on return Your a0del sewily mnber Calvin E & Maria D W ser 190-42-9436 1a Important: See the instructions if you can be claimed as someone else's dependent or are filing Form 1040NR. Check the "No" box below and see t instructions if (a) you have a net loss from a business, (b) you received a taxable scholarship or fellowship g nt not reported on a Form W-2, (c) your wages include pay for work performed while an inmate in a penal institution, (d) you received a pension or annuity from a nonqual~ed de- ferred compensation plan or a nongo ernmental section 457 plan, or (e) you are filing Form 2555 or 2555-EZ. Do you (and your spouse if filing joint y) have 2009 wages of more than $6,451 ($12,903 if married filing jointly)? Yes. Skip lines 1a through 3. E ter $400 ($800 if married filing jointly) on line 4 and go to line 5. ~X 1 No. Enter your earned income (ee instructions) • ~ 1a I 51, 5 9 4 b Nontaxable combat pay included on line 1a (see instructions) 1b 2 Multiply line 1a by 6.2% (.062) - 2 3 Enter $400 ($800 if married filing jointly) • ~ 3 99 800 4 Enter the smaller of line 2 or line 3 ( nless you checked "Yes" on line 1a) 4 5 Enter the amount from Form 1040, li a 38*, or Forrn 1040A, line 22 • ~ 5 ~ 4 2 , 9 2 3 e Enter $75,000 ($150,000 if married fi ing jointly) 6 7 Is the amount on line 5 more than th amount on line 6? [] No. Skip line 8. Enter the amou from line 4 on line 9 below. [ ~ Yes. Subtract line 6 from line 5 - 7 8 Multiply line 7 by 2% (.02) .... ~ ..................................... ~ 8 9 Subtract line 8 from line 4. If zero or less, enter -0- • I 9 10 Did you (or your spouse, if filing jointl) receive an economic recovery payment in 2009? You may have received this payment if yo received social security benefits, supplemental security income, railroad retirement benefits, r veterans disability compensation or pension benefits (see instructions). IXl No. Enter -0- on line 10 and go to line 11. Yes. Enter the total of the a m nts received b ou and ours ouse, if filin ....... 10 ~__ P Y YY ( Y P 9 jointly). Do not enter more han $250 ($500 if marcied filing jointly) 17 Did you (or your spouse, if filing jointl) receive a pension or annuity in 2009 for services performed as an employee of the U.S. Governm nt or any U.S. state or local government from work not covered by social security? Do not in Jude any pension or annuity reported on Form W-2. LX~ No. Enter -0- on line 11 and go to line 12. Yes. ~ If you checked "No" on line 10, enter $250 ($500 if married filing jointly and the answer on line 11 is "Yes" for both spouses) ~ If you checked "Yes" o line 10, enter -0- (exception: enter $250 if filing 11 jointly and the spouse ho received the pension or annuity did not receive an economic recovery ayment described on line 10) 12 Add lines l0 and 11 - -......... 12 13 Subtract line 12 from line 9. If zero o less, enter -0- .... ....... 13 14 Making work pay and government tires credits. Add lines 11 and 13. Enter the result here and on Form 1040, line 63; Form 104 A, line 40; or Form 1040NR, line 60 14 *If you are filing Form 2555, 255! For Paperwork Reduction Act Notice, see 1040NR Instructions. or 4563 or you are excluding income from Puerto Rico, see instructions. 00 800 1040A, 1040, or EEA Schedule M (Form 1040A or 1040) 2009 800 0 0 c ~ ,~ U W w N 0 ~ ~ `~ m o ~ m ~ ~ a I m N ~ C O '-I O a m o a W N N Q ~ O p ~ 9 ~ U m ~ N J ~ b r 'c~ o e ~ ~3 " o ~ a ~ ~ E o' o yy ~ ~ J N N ~ u7 y C ~ N ~ ~ ~ ~ ~ 01 ~ ~ ~ U LL L ~ a m m m ~ Q O o ~ M d ~ O C .7 ~ O ~ ao n m m m m b ~"~ o m U .-~ 0 m y W O o ~ O ~ ~ o N W .~ S A . ro E ~ ~ ~p N j L" ~ o ~ p c rfi w . ~ N ~ ~ W O N U m C O `~ f0 ~ 3 c ul 10 ~ +o-+ ~' E ~ ~ v ~ O ti • O Z 0 h F N N O N O~ ti ~ ~ rn rn ~ ~ r-1 '-I m m ~ ~ 1~ bl O U v A N ~ 'I G U 7 N O 4 y ~ N m b Ga u C a~ O b N F .7 'L 0 W N w ~_ ~~ H J ~r " o ~ w 1A ~ ~°, o C °' ~ 0 N V ~ C ~ ,~ N ~ •A ~ w~ W ~ l0 N j~ O C y y U f0 3 c E ~ _N 'p x O r r N O r M U W m ra •~ c m rn n i y N o V' O Ol N m C C d a `,~' m r r ~ W h O E ~~ c tv r r ,, N O C ` r M CW7 V [I' U m ~ ~ m o ~ M .--1 fr7 O H y M V' O x 8 d a a m m J r O N .-1 O N O r O o ~ c r y ~ O M ° . ~ ~ m M d . -1 C ~ ~ M d O O C ~ O O ~_ ~ ~ .--I m n m a to W o r 0 0 n o m o m U ~ ~ m 0 0 ~ rn d o 0 jp aD N ~ O O ~ O O ~ N N N A ro ~. ~~ ~ ~ ~ a a w ~ U C m a v w O rl N C ro rl .~ N 1~ C a~ f+ v v ro a ~ U ~ N M Z ti ti r r 0 0 m ~i m m ~ ~ 1~ ffi O U N A a~ C U ~ O1 O H m ~ U1 r-I q ro b ,~ C +~ o ro v F az J 190429436 WISER CALVIN MARIA WISER 0900112095 PA-40 - 2009 Pennsylvania Income Tax Return ENTER ONE LETTER OR NUMBER IN EACH BOX. Do Not Use Your Preprinted Label 142464052 E D 402 S PENN STREET SHIPPENSBURG ocwpation LAB 0 R Occupation SELFEMPLOY PA 17257 21800 1 a Gross Compensation. Do not includ exempt income, such as combat zone pay and qualifying retirement benefits. See th instructions. 1 b Unreimbursed Employee Business penses. 1c Net Compensation. Subtract Line 1b from Line 1a. 2 Interest Income. Complete PA Sche ule A if required. 3 Dividend and Capital Gains Distribut' ns Income. Complete PA Schedule B if required 4 Net Income or Loss from the Operati n of a Business, Profession or Farm. 5 Net Gain or Loss from the Sale, Exc ange or Disposition of Property. 6 Net Income or Loss from Rents, Roy Ities, Patents or Copyrights. 7 Estate or Trust Income. Complete a d submit PA Schedule J. 8 Gambling and Lottery Winnings. Co plete and submit PA Schedule T. 9 Total PA Taxable Income. Add only a positive income amounts from Lines 1 c, 2, 3, 4, 5, 6, 7 and 8. DO NOT ADD ny losses reported on Lines 4, 5 or 6. 10 Other Deductions. Enter the approp late code for the type of deduction. See the instructions for additional inf rmation. 11 Adjusted PA Taxable Income. Subtr ct Line 10 from Line 9. N EC Page 1 of 2 FC N Extension. N Amended Retum. R Residency Status. PA Resident/ Nonresident/ Part-Year Resident ~^ to J Single/ Martied, Filing Jointly/ Manied, Filing Separately/ Final Retum/ Deceased Date of death N Farmers. School District Name S H I P P E N S B U R G 1a 53062 1b 14479 1c 38583 2 0 3 0 4 3890 5 0 6 -7943 7 0 8 0 9 42473 10 0 11 42473 L 0900112095 ~ ~ 0900112095 J 0900212101 PA-40 - 2009 Social Security N tuber 19042943 Name(s) CALVIN WISER 12 PA Tax Liability. Multiply Line 11 y 3.07 percent (0.0307). 13 Total PA Tax Withheld. See the ins ructions. 14 Credit from your 2008 PA Income T x return. 15 2009 Estimated Installment Payme ts. 16 2009 Extension Payment. 17 Nonresident Tax Withheld from you PA Schedule(s) NRK-1. (Nonresidents only) 18 Total Estimated Payments and Cre its. Add Lines 14, 15, 16 and 17. Tax Forgiveness Credit. Submit PA Sch dule SP. 19a Filing Status: 01 Unmarried or petaled 02 Married 03 Deceased 19b Dependents, Part B, Line 2, PA Sch dule SP 20 Total Eligibility Income from Part C, ine 11, PA Schedule SP. 21 Tax Forgiveness Credit from Part D Line 16, PA Schedule 3P. 22 Resident Credit. Submit your PA Sc PA Schedule(s) GS, G-L and/or RK 23 Total C1her Credits. Submit your PA 24 TOTAL PAYMENTS and CREDITS. 25 TAX DUE. If Line 12 is more than Li 26 Penalties and Interest. See the instri If it G-R with your hedule OC. d Lines 13, 18, 21, 22 and 23. 24, enter the difference here. Ions. Enter Code: (ding form REV-1630, mark the box. N 27 TOTAL PAYMENT DUE. See the ins ructions. 28 OVERPAYMENT. If Line 24 is more an the total of Line 12 and Line 26, enter the difference here. The total of Lines 29 through 35 mu t equal Llne 28. 29 Refund -Amount of Line 28 you wan as a check mailed to you. Refund 30 Credit -Amount of Line 28 you want s a credit to your 2010 estimated account. 31 Amount of Line 28 you want to donat to the Wlld Resource Conservation Fund. 32 Amount of Line 28 you want to donat to the MIIItary Family Relief Assistance Program. 33 Amount of Line 28 you want to donat to the Governor Robert P. Casey Memorial Organ and Tissue Donation Awaren Trust Fund. 34 Amount of Line 28 you want to donat to the Juvenile (Type 1) Diabetes Cure Research Fund. 35 Amount of Line 28 you want to donat to the PA Breast Cancer Coalition's Breast and Cervical Cancer Research und. SignatUre(S). Under penalties of pery'ury, I (we)d are that I (we) have examined this return, inGuding all accompanying schedules and statements, and to the b st of my (our) belief, they are true, correct, and complete. Preparers Name and Telephone Number RUTH ANN MOONEY 12 1304 13 1629 14 0 15 0 16 0 17 0 18 0 19a 00 19b 00 20 0 21 0 22 0 23 0 24 1629 25 0 26 0 27 0 28 325 29 325 30 0 31 0 32 0 33 0 34 0 35 0 Firm FEIN Preparers SSN/PTIN Date 06-30-2010 251756329 176442251 717-532-3446 Page 2 of 2 L 0900212101 0900212101 J J 142464052 STUDIO 0903114577 PA-40 Schedu~e C - 2009 (09-09) Profit or L ss From Business or Profession (sole Proprietorsnip> MARIA D WISER CENTER STAGE STUDIO 62 EAST KING STREET SHIPPENSBURG 1 a. Gross receipts or sales 1 A 1 b. Returns and allowances 1 B 1 c. Balance 1 6. Advertising 6 7. Amortization '7 8. Bad debts from sales or services 8 9. Bank charges 9 10. Car and Wck expenses 10 11. Commissions ]r ]~ 12. Cost depletion not % depletion 12 13a.Regular depreciation 13 A 13b. Section 179 expense 13 B 14. Dues and publications 1 y 15. Other employee benefit programs 15 16. Freight (not on Schedule C-1) 16 17. Insurance 1 7 18. Interest on business indebtedness 18 19. Laundry and Leaning 19 20. Legal and professional services 2 0 21. Management fees 21 22. Office supplies 2 2 23. Pension and profit-sharing plans 2 3 24. Postage 2 4 25. Rent on business properly 2 5 28. Repairs 2 6 27. Subcontractor fees 2 7 L Method of Inventory: C=Cost, L=Lower ~ of cost or market, O=Other Accounting Method: A=Accrual, C=Cash, O=Other A Home office N expenses deducted 9 9 9 9 9 9 Business out of existence N Any change in determining N quantities, costs or valuations 3 4 7 4 2 I ~• cost of goods sold/operedons Q ~. Gross profit 3 4 7 4 2 d• Other Income (submit statement) S. Tolal income 15 6 2 ~8. Supplies (not inGuded on sdredde trt) 0 29. Taxes 0 30. Telephone Q 31. Travel and entertainment 0 32. UGIiGea 0 33. Wages 0 34. Other expenses (specify): 6560 0 A MERCHANDISE 0 B COSTUMES 0 C VIDEO 0 D STUDIO EXTRAS 1146 E AUTO 0 F G H 0 I 0 J 0 K 3693 0 ' 0 34. Total other expenses 6 4 2 2 35. Total expenses 2 5 0 38. Reduce expenses by total business credits 0 37. Total adjusted expenses 38. Net profit or loss 2 3 4 5 28 29 30 31 32 33 A B C D E F G H I J K 34 35 36 37 38 Page 1 of 2 0903114577 0903114577 PA 17257 12888 21854 3020 24874 953 0 1275 1527 3121 0 5804 4991 1220 2994 2127 0 D 0 0 0 0 17136 43645 0 43645 -18771 J 0903214583 PA-40 Schedule C - 2009 Social Security Number 14 2 4 6 4 0 5 2 Name of owner MARIA D WISER SCHEDULE C-1 -Cost of Goods Sold and/or Operations 1. Inventory at beginning of year (if differe t from last year's closing inventory, include explanation) 2a. Purchases 2b. Cost of items withdrawn for personal u e 2c. Balance (subtract Line 2b from Line 2a 3. Cost of labor (do not include salary pai to yourself or subcontractor fees) 4. Materials and supplies 5. Other costs (include schedule) 6. Add Lines 1, 2c, 3, 4, and 5 7. Inventory at end of year 8. Cost of goods sold and/or operations ( ubtract Line 7 from Line 6) Enter here and on Part I, Line 2 SCHEDULE C-2 -Depreciation ( ee Instructions) 1. Total Section 179 depreciation (do not nclude in items below) 2. Less: Section 179 depreciation includ in Schedule C-1 3. Balance (subtract Line 2 from Line 1). nter here and on Part II, Line 13b 4. Other depreciation: L 1 0 2A 0 2B 0 2C p 3 12888 4 0 5 0 6 12888 ~ Q 8 12888 1 0 2 0 3 0 Description of properly Dete acquired Cost or other basis Depreciation allowed or Method of computing L'rfe or rate Depreciation for (a) (b) (C) allowable in prior years depreaafion (~ this year Buildings 4 A 0 0 Fumiture/fixtures 4 B 0 0 Trans. equipment 4 C Q Q Machinery 4 D 0 0 Omer STUDIO 4E 8012006 131195 19680 SL 4F 0 0 4G 0 0 4H 0 0 4I 0 0 4J 0 0 4K 4L 4M 4N 40 4P 0 0 0 0 0 0 0 0 0 0 0 0 5. Totals 6. Depreciation included in Schedule C-1 7. Balance (subtract Line 6 from Line 5). I 131195 here and on Part 11, Line 13a 20 5 6 7 Page 2 of 2 0903214583 0903214583 0 0 Q 0 6560 0 0 0 0 0 0 0 0 0 0 0 6560 0 6560 0903114577 PA-40 Sched le C - 2009 (09-09) Profit or oss From Business or Profession (sole Proprietorship) 190429436 CALVIN E ISER ICECREAM TRUCK CALVIN WI ER 402S• PENN STREET SHIPPENSBURG 1a. Gross receipts or sales 1 A 1 b. Returns and allowances 1 p 1 c. Balance 1 C 8. Advertising 6 7. Amortization '7 8. Bad debts from sales or services 8 9. Bank charges 9 10. Car and truck expenses ]~ Q 11. Commissions 11 12. Cost depletion not % depletion ]~ 2 13a.Regular depreciation 13 A 13b. Section 179 expense 13 B 14. Dues and publications 14 15. Other employee benefit programs 15 18. Freight (not on Schedule C-1) 1 6 17. Insurance ]r 7 18. Interest on business indebtedness 18 19. Laundry and Gearing 19 20. Legal and professional services 2 0 21. Management fees 21 22. Office supplies 2 2 23. Pension and profit-sharing plans 2 3 24. Postage 2 4 25. Rent on business property 2 5 28. Repairs 2 6 27. Subcontradorfees 2 7 L 0903114577 PA 17257 Method of Inventory: C=Cost, L=Lower ~ of cost or market, O=Other Accounting Method: A=Accrual, C=Cash, O=Other ~ Home office N expenses deducted 9 9 9 9 9 9 Business out of existence N Any change in determining N quantities, costs or valuationis 7 2 0 0 2. Cost of goods sold/operafions 2 0 0 3. Gross Profit 3 7 2 0 0 "~ 7L 0 0 4. Other Income (submit statement) 4 0 5. Total income 5 •~ 2 0 0 Q 28. Supplies (not inGuded on srLedde G-1) 2 8 0 0 29. Taxes 2 9 0 Q 30. Telephone 3 0 3 5 5 Q 31. Travel and entertainment 31 0 0 3z. Ufilides 3 2 0 Q 33. Wages 3 3 0 0 34. Other expenses (specifyi: 0 0 A A 0 0 B g 0 0 C C 0 0 D D 0 0 E E 0 0 F F 0 G G 0 H H 0 0 I I 0 55 ~ ~ 0 0 K K 0 2500 0 0 34. Total other expenses 3 4 0 4 0 0 3s. rocal expenses 3 5 3 310 0 38. Reduce expenses by total business credits 3 (~ 0 0 37. Total adjusted expenses 3 7 3 310 38. Net profit or loss 3 8 3 8 9 0 Page 1 of 2 0903114577 0903214'583 PA-40 Schedule - 2009 Social Security Number 190429436 Name of owner CALVIN E WISER SCHEDULE C-1 -Cost of Good Sold and/or Operations 1. Inventory at beginning of year (ff differ nt from last year's closing inventory, include explanation) 2a. Purchases 2b. Cost of items withdrawn for personal u 2c. Balance (subtract Line 2b from Line 2 ) 3. Cost of labor (do not include salary pa' to yourself or subcontractor fees) 4. Materials and supplies 5. Other costs (include schedule) 6. Add Lines 1, 2c, 3, 4, and 5 7. Inventory at end of year 8. Cost of goods sold and/or operations (ubtract Line 7 from line 6) Enter here and on Part I, Line 2 SCHEDULE C-2 -Depreciation ee Instructions) 1. Total Section 179 depreciation (do not nclude in items below) 2. Less: Section 179 depreciation includ in Schedule C-1 3. Balance (subtract Line 2 from Line 1). nter here and on Part II, Line 13b 4. Other depreciation: L 1 0 2A 0 2B 0 2C 0 3 0 4 0 5 0 6 0 ? D 8 0 1 0 2 0 3 0 Descnphon of properly uare acgwrec (a) (t)) Cost or other basis (D) Depreciation allowed or allowable in (~nj years Method of computing Lrfe or rate deg e)'on (~ Depreciation 1br this year (g) Buildings 4 A Fumiture/fixtures 4 B Trans. equipment 4 C Machinery 4 D Omar ~ 0 ~ 0 O 0 0 0 0 0 0 0 (sP~Y) 4E 4F 4G 4H 4I 4J 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 4K 4L 4M 4N 40 4P 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 5. Totals 6. Depreciation included in Schedule C-1 7. Balance (subtract Line 6 from Line 5). E. L 0903214583 0 5 0 6 p Iter here and on Part II, Line 13a '7 ~ Page 2 of 2 0903214583 0903114577 PA-40 Schedu e C - 2009 (09-09) Profit or L ss From Business or Profession (sole Froprietorsnip) 142464052 MARIA D W SER ICECREAM TRUCK MARIA WIS R 402 S PENN STREET SHIPPENSBURG 1a. Gross receipts or sales 1 A 1 b. Returns and allowances 1 B 1 c. Balance 1 6. Advertising 6 7. Amortization '7 8. Bad debts from sales or services 8 9. Bank charges 9 10. Car and truck expenses ]r 0 11. Commissions ]t ]r 12. Cost depletion not % depletion 12 13a.Regular depreciation 13 A 13b . Section 179 expense 13 B 14. Dues and publications 14 15. Other employee benefit programs 15 16. Freight (not on Schedule C-1) 16 17. Insurance 1 7 18. Interest on business indebtedness 18 19. Laundry and Leaning 19 20. Legal and professional services 2 0 21. Management fees 21 22. Ofice supplies 2 2 23. Pension and profit-sharing plans 2 3 24. Postage 2 4 25. Rent on business progeny 2 5 26. Repairs 2 6 27. Subcontractor fees 2 7 Q 28. Supplies (not inGuded on Sdredule F1) 0 29. Taxes 30. Telephone 31. Travel and entertainment 5 7 5 32. Utilities 0 33. Wages 0 34. Other expenses rspecify~: 0 0 A DUMPING 0 B WEIGHING LOADS 0 C PERMITS 0 D 0 E 0 F G H 0 I 0 ~ 0 K 0 0 0 34. Total other expenses 8 0 0 0 35. Total expenses 0 38, Reduce expenses by total business credits 0 37. Total adjusted expenses 38. Net profit or loss 2 3 4 5 28 29 30 31 32 33 A B C D E F G H I J K 34 35 36 37 38 Page 1 of 2 0903114577 0903114577 L Method of Inventory: C=Cost, L=Lower ~ of cost or market, O=Other Accounting Method: A=Accrual, C=Cash, O=Other ~ Home office N expenses deducted 5 6 2 0 0 0 Business out of existence Y Any change in determining N quantities, costs or valuations PA 1725? 3 0 6 0 0 2. Cost of goods sold/operations 0 3. Gross profit 3 0 6 0 0 4.Other Income (submit statement) 5. Total income 0 30600 0 30600 0 0 1298 0 0 0 6700 189 150 0 0 0 0 0 0 0 0 7039 16912 0 16912 13688 J i J 0903214583 PA-40 Schedule - 2009 Social Security Number 14 2 4 6 4 0 5 2 Name of owner MARIA D WISER SCHEDULE C-1 -Cost of Good Sold and/or Operations 1. Inventory at beginning of year (if diffe nt from last year's closing inventory, include explanation) 2a. Purchases 2b. Cost of items withdrawn for personal u e 2c. Balance (subtract Line 2b from Line 2 3. Cost of labor (do not include salary pai to yourself or subcontractor fees) 4. Materials and supplies 5. Other costs (include schedule) 6. Add Lines 1, 2c, 3, 4, and 5 7. Inventory at end of year 8. Cost of goods sold and/or operations ( ubtract Line 7 from Line 6) Enter here and on Part I, Line 2 SCHEDULE C-2 -Depreciation ( ee Instructions) 1. Total Section 179 depreciation (do not nclude in items below) 2. Less: Section 179 depreciation includ in Schedule C-1 3. Balance (subtract Line 2 from Line 1). nter here and on Part II, Line 13b 4. Other depreciation L 1 0 2A 0 26 0 2C 0 3 0 4 0 5 0 6 0 7 0 8 0 1 0 2 0 3 0 DescnpUon of property Date acquired Cost or other basis Depredation allowed or Method of computing Life or rate Depreciation for (a) (b) ~ O allowable in prior years depredation (~ this year (d) (e) (g) Buildings 4 A 0 0 Fumiture/flxtures 4 B 0 0 Trans. equipment 4 C 0 0 Machinery 4 D Otl~er 0 0 ~> 4E 0 p 4F 0 0 4G 0 0 4H 0 0 4I 0 0 4J 0 0 4K 0 0 4L 0 0 4M 0 0 4N 0 0 40 0 0 4P 0 0 5. Totals 6. Depreciation included in Schedule C-1 7. Balance (subtract Line 6 from Line 5). E 0 5 6 here and on Part II, Line 13a 7 Page 2 of 2 0903214583 0903214583 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 J PA SCHEDU Rents and Royalty Income (Loss) PASO Schedule E 0906817952 2009 If you (have more than three orooerties. you may ohotocoov this schedule. Name of the taxpayer filing this schedule CALVIN E WISER Social Security Number (shown first) 190-42-9436 Sea the ialrrrdons. Report the income and expenses ~as, ar~d ~tiier minerals from~rou~rooerty, and th use meta s m your property p u ng Proaudspfrom y for the use of your personal property by others. Also, report the income you received for the extraction of oil, our~pai~ents~nd co ~hts. ~~ If yyou are in the business of renting your property, extracting r p en s an copyrP~ti' -use PA Schedule C. hart A. Kind or Property For Profit Property Address A YES ~ 25-27 LINCOLN WAY WEST RENTAL PROPEERTY NO ^ SHIPPENSBURG PA 17257 B YES ^ NO C YES NO ^ Part B. Identify the property from Part A and i jointly owned (J) Important: Spouses may not offset income a Income dicate if the owner is the taxpayer (T =the name shown first on the PA-40) or the spouse (S) or if d losses. Property A Property B Property C X T S J T S J T S J 1. Rent received 1. 2 5 9 8 8 2. Royalties received --- 2. Expenses 3. Advertising - 3. 4. Automobile and travel - 4. 17 51 S. Cleaning and maintenance --- 5. 6. Commissions -- 6. 7. Insurance ............. ............... 7. 9 6 0 8. Legal and professional fees - 8. 9. Management fees - - - 9. 10. Mortgage interest - 10 118 8 5 11. Other interest - - - - 11 12. Repairs . .............. ............... 12 5 6 62 13. Supplies .............. ............... 13 14. Taxes -not based on net income - - - 14 3117 15. Utilities 15 5 5 2 2 18. Depreciation expense 16 5 0 3 4 Important: PA law does not permit any feder I bonus depreciation. PA law limits the IRC section 179 expensing to $25,000. See the instructions. 17. Other expenses (itemize): - - - - 17 ................... ............... ................... ............... 18. Total Expenses -Add Lines 3 through 1 - 18 3 3 9 31 Income or Loss 19. Income -Subtract Line 18 from Line 1 0 2 - - - 19 20. Loss -Subtract Line 1 or 2 from Line 18. (check the box, if a net loss) 20 ^X - 7 9 4 3 ^ ^ c r. nec income yr moss Total Lines 19 and 20 22. Rent or royalty income (loss) from PAS PA Schedule(s) RK-1 or NRK-1 23. Net Rent and Royalty Income (Loss). Ac include on Line 6 of your PA-40 - 09D6817952 • {check the box, if a net loss) [] 21 ~ - 7 9 4 3 ~rporation(s) and partnerships from your •--{check the box,ifanetloss)^] 22 i Lines 21 and 22. If submitting more than one schedule, total all amounts, and • {check the box, if a net loss) ~ 23 -'7 g 4 0906817952 J PA SCHEDULE UE Allowable Employee Business Expenses PA Sdredule UE (01}09) (~) PADEPARTMENiOF ZOOS 0901710020 OFFICIAL USE ONLY Name of taxpayer claiming expenses Social Security Number (shown first) CALVIN E WISER 190-42-9436 Employer's Name Employer's address 982'7 DOWNSVILLE Employer's Identification Number MG & G CONSTRUCTION AGERSTOWN MD 21741 522292142 Describe the duties of the job in which you ncurred these expenses Employer's Telephone Number LABOR Caution: You must complete a separate schedule for each job or position. Spouses may not file joint PA Schedule(s) UE. PaR A. Direct Employes Business Expen 1. Union dues. List union name(s) and a ount(s) paid. Enter the total. Submit additional sheets, if needed. Name of union(s) and amount(s). 1. ~ ~1 2. Work clothes and uniforms. Needed f r your employment and not suitable for everyday use. Description: 2. 3. Small tools and supplies. Needed for our employment and not provided by your employer. Description: RE UIRED PHO E AND TOOLS 3. 122 4. Professional license fees, malpractice Insurance and fldellty bond premiums. Required as a condition of your employment. Description: q 5. Total Direct Employee Business Expe ses. Add Lines 1 through 4 - - ... 5. 12 2 Part B. Business Travel Expenses. You m y use appropriate amounts from Lines 1, 2, 3 and 5 of your Federal Forth 2106 or Federal Form 2106-EZ. CAUTION: You may not us Line 4 of Form 2106. You must itemize these expenses in Part C of this schedule. Vehicle Expenses: Standard Mllsage Rate. 6. Enter the amount from your Form 2106 or 2106-EZ, OR Enter your total business miles 2 4 0 $ and multiply by the federal standard mileage rate. 6. 13 2 5 Vehicle Expenses: Actual Travel and Mile ge Expenses. 7. Enter the amount from your Form 2106 Make the following adjustments: - - ... 7. 8. Add back the "Inclusion Amount" from orm 2106. This adjustment does not apply for PA purposes 8. 9. Optional Depreciation. You may use a y generally accepted method. If not using your Forth 2106, enter your allowable depreciation expenses d the method you use g, 10. Actual Travel and Mileage Expenses f r PA Purposes. Total Lines 7 through 9 - • 10. Other Business Travel Expenses. 11. Parking fees, tolls and transportation. Enter the amount from your Form 2106 or 2106-EZ - - • 11. 12. Travel expenses while away from ho overnight Enter the amount from your Form 2106 or 2106-EZ • 12. 13. Meals and entertainment expenses. E ter the amount from your Form 2106 or 2106-EZ .. 13. 14. Total Business Travel Expenses. Add Ines 6 or 10 and Lines 11,'12 and 13 - .. 1a. 132 5 Part C. MisC@Ilaneous Expenses. Itemize ur additional expenses, induding those PA allowable Business 6cpensea not itemized on your Foam 2106 or 2106-EZ. 15. Total Miscellaneous Expenses - - - - - - .................. 15. Total Allowable PA Employee Business penses. You must account for reimbursements, if any. A. Direct Expenses from Line 5 ................... q, 12 2 B. Business Travel Expenses from Line 1 - - - - ............ B. 13 2 5 C. Miscellaneous Expenses from Line 15 - .............. C . D. Office or Work Area Expenses from Li a 16, on Side 2 - ............. p . E. Moving Expenses from Line 19, on Sid 2 - ................... E . F. Education Expenses from line 23, on ide 2 - ............... F. G. Total Depreciation Expenses from LIn 24, on Side 2 - ............... G . H. Total Allowable Employee Business E penses. Add Lines A through G - - - .... H. 14 4 7 I. Reimbursements. Enter payments that our employer DID NOT include in box 16 of your Form W-2 - I. J. Net expense or relmbureement. Subtra f -~ Line I from Line H. Enter the difference, and: - - - .. J. - 14 4 7 I Lrne H rs MORE than Lrne I, rr If Line I is MORE than Line H, it Nonresidents and part-year res on Lrne 1 b, on your PA-40. the excess on Line 1a, on your PA-40. also need to complete PA Schedule NRH. See instructions. ti7r rs i 0901710020 0901710020 0901810028 PA SCH~D~ILE UE Allowable mp oyes Business Expenses ~ PA Sdtedrb ~ (09-09) (I) Q PA DEPAR71ENi OF ~oOv OFFICIAL USE ONLY Name of taxpayer claiming expenses CALVIN E WISER Social Security Number (shown first) 190-42-9436 Part D. Office or Work Area Expenses. Yo must answer ALL three questions or the Department will disallow your expenses. D1. Does your employer require you tom D2. Is this work area the principal place D3. Do you use this work area regularly a If you answer YES to ALL three questions, intain a suitable work area away from the employer's premises? ~ YES ~ NO ere you perform the duties of your employment? ~ YES ~ NO d exclusivety to perform the duties of your employment? ~ YES ~ NO ntinue. If you answer NO to ANY question, you may not claim office or work area expenses. Actual Office or Work Area Expenses. Ent r expenses for the entire year and then calculate the business portion. a. Depreciation expense (homeowners nty) --- a. b. Real estate taxes - - - - - - b. c. Mortgage interest (homeowners only) - c. d. Utilities ............. ...................................... d. e. Property insurance ........ ...................................... e. f. Property maintenance expenses fro statement. See the instructions - f. g. Other apportionable expenses from s atement. See the instructions • - g. h. Rent (renters onty) ........ ...................................... h. i. Total. Add Lines a through h. Enter t e total here - i. j. Business percentage of property. Di of your entire property. Round to 2 d ide the total square footage of your work area by the total square footage imal places - - j. k. Apportioned expenses. Multiply Line i by the percentage on Line j - - - k. I. Total office supplies from statement. ee the instructions - - I. 16. Total Office or Work Area Expenses Add Lines k and I - - - • 16. Part E. Moving Expenses. Distance Test. E1. Enter the number of miles from your E2. Enter the number of miles from your E3. Subtract Line E2 from Line E1 and a If Line E3 is 35 miles or more, contin 17. Transportation expenses in moving h 18. Travel, meals, and lodging expenses 19. Total Moving Expenses. AddLinesl Id home to your new workplace - - - miles Id home to your old workplace - - - miles ter the difference - - miles e. If it is not at least 35 miles, you may not claim any moving expenses. usehold goods and personal effects - - • 17. wring the actual move from your old home to your new home • 18. and 18 ---------•19. Part F. Education Expenses. You must an er ALL three questions or the Department will disallow your expenses. F1. Did your employer (or law) require th If you answer YES, continue. If you a F2. Did you need this education to meet F3. Will this education, program or tours If you answer NO to questions F2 and F3, Name of college, university, or educa 20. Tuition or fees ......... 21. Course materials ........ 22. Travel expenses ....... 23. Total Education Expenses. Add Line t you obtain this education to retain your present position or job? [] YES [] NO saver NO, you may not claim education expenses. a entry level or minimum requirements to obtain your job? [~ YES ~ NO of study qualify you for a new business or profession? [] YES C] NO ntinue. If you answer YES to either question, you may not claim education expenses. Tonal institution: Course of study: ....................................... 20. ....................................... 21. ....................................... 22. 20 through 22 - - - - - - - - - - - . 23. Part G. Depreciation Expenses. PA law do snot allow any federal bonus depreciation and limits IRC Section 179 expensing to $25,000. (a) Description of properly (b) Dat acquired (c) Cost or other basis (d) Depreciation method (e) Section 178 a nse xpe (f) Depreciation expenses 24, Total Depreciation Expenses. Add t amounts from columns (e) and (f) - - • 24. Side 2 0901810028 0901810028 RETURN BY APRIL 15, 2010 T0: 2009 TAX OFFICE USE ONLY - DO NOT WRITE IN THIS ARE! CAPITAL TAX COLLECTION BUREAU LOCAL EARNED INCOME TAX RETURN (FORM 531) TO CONSTITUTE PROOF OF FILING, THE TARP YER'S COPY MUST BE VALIDATED BY THE BUREAU. TO HAVE YO R COPY VALIDATED BY MAIL, RETURN BOTH THE BUREAU'S AND PAYER'S COPIES ALONG WITH A SELF ADDRESSED STAMPED NVELOPE. www.c tax.com 5 SOG G.,NO. A 90C. 3EC. N4•' (3 v ~w y,.fi"Y.... °t' ~' ~- 1190-42-943 6 142-4 6-4 05 1 W-2 EARNINGS (From attached -2's) 1 5116 2. 0 0 19 0 0. 0 0 2 EMPLOYEE BUSINESS EXPENS S (EBEs) (Attached Federal Form 2106 8~ State Schedule UE) 2 14 4 7 9 . 0 0 ~ 3 TAXABLE W-2 EARNINGS LESS (EBEs) (Subtract Line 2 from Line 1) 3 3 6 6 8 3. 0 0 19 0 0. 0 0 4 OTHER TAXABLE EARNED INC ME (NO INTEREST OR DIVIDENDS) LIST TYPE: 4 5 TOTAL TAXABLE EARNED INC ME ( d Lines 3 and 4) 5 3 6 6 8 3. 0 0 19 0 0. 0 0 6 NET PROFIT FROM BUSINESS, ROFESSION, OR FARM ~A~~ur K ad~ral nd State Schedules C, F 6 ?Oq0 I ~ O ~ (~ 7 NET LOSS(ES) from Business, P fession or Farm S~~io ~~der~pnd State Schedules C, F 7 ~ 18 7 71.0 0 8 Subtract Line 7 from Line 6 (IF LE S THAN ZERO, ENTER ZERO) g ~ ~ g e Efeu°hed nO ouNPA-40 retumN PURPO - ES ONLY: Enter Net, Subchapter S Corporation pass-thru Net Profit(s)/Loss(es) 9 ' I 10 TOTAL TAXABLE EARNED INC ME AND NET PROFITS (Add Lines 5 and 8) 10 ~ 19 0 0 . 0 0 11 ENTER TAX RATE AS A DECIM L(trom the -rAx RATE TABLE" found on the last page of this forth packet) 11 0 , 014 0 0.014 12 TAX (ABILITY: Multiply Line 10 b Line 11 12 . 2 6 . 6 13 TOT LOCAL INCOME TAXES WITHHE D EXCEPT PHILADELPHIA INCOME TAX (From attached W-2's, Box 19) 13 2 -] 14 QU R TE R LY P A Y M E N T A S N D/ R L AS T Y E A R' S O V E R P AY M E N T C R E D I TED T O THIS YEAR 14 15 g Fp Tg ~E p R g P T p p P HI Lp ~~~ ~TS FOR CERTIFIED RESIDENT ~ ~g /p N D g g g R o 7 T H E T~ p g N q q7 T q ~ H G q ~I THEAHARRISt3TRG KEYSTONE OPPORTUNITY Z E KaZ ND/OR 15 16 TOTAL WITHHOLDINGS 8 PAY ENTS (Add Line 13, 14 and 15) 16 2 7 0 17 TAX BALANCE DUE (Subtract Line 1 from Line 12) PAYMENT NOT NECESSARY IF LESS THAN $1.00 17 ~ Q 18 INTEREST & PENALTY (See Inst uctions) 18 19 TOTAL BALANCE DUE (Add Line 17 and 18) Make check payable to "CTCB" ~um~ie°o ac~,ec`~r~ry 19 ~~ 20 OVERPAYMENT (Subtract Line 1 from Line 16) IF LESS THAN ZERO, ENTER ZERO 20 0 . 4 21 OVERPAYMENT TO BE REFUN ED 21 0 . 4 Ta~ayer A', ~' ar'BOTI-r Sarigs a Cheddrq AaY- ROl1T1NG NO. ACCOUNT NO. 22 OVERPAYMENT TO BE CREDIT D TO NEXT YEAR'S TAX 22 ---- 23 OVERPAYMENT TO BE CREDIT D TO SPOUSE'S BALANCE DUE FOR T HIS FILING YEAR 23 f . A YOUR CTCB ACCOUNT NUMBER (IF YOUR PIN NUMBER FOR YOUR NAME _ ONLINE FILING (LAST, FIRST, M) Enter at right WISER, CALVIN E B SPOUSE'S CTCB ACCOUNT NUMBER QF SPOUSE'S PIN NUMBER FOR KNOWN) SPOUSE'S NAME ONLINE FILING (LAST. FIRST, M) Enter at right » WISER, MARIA D HAVE YOU MOVED FROM THE ~ BEGINNING OF THE TAX FILING ES IF YES, COMPLETE SCHEDULE P ON PAGE 2 OF "BUREAU'S" COPY HOME 4 O 2 S PENN STREET YEAR TO PRESENT? }{ O OF RETURN ADDRESS » SHIPPENSBURG, PA 17257 YOUR RESIDENT UNICIPALITY DAYTIME PHONE I (TOWNSHIP, BOR UGH OR CITY) NUMBER ~~ n ~~ YOUR SIGNATURE DA T~ YOUR OCCUPATIO N x C, / ~~~~~~ LABOR SPOUSE'S SIGNATURE (ONLY IF ALSO FILING ON THIS FORM) D~ j~ j~ SPQUSE'S OCCUPATION (ONLY IF ALSO FILING ON THIS FORM): X SELFEMPLOYED PAID PREPARER'S NAME (PLEASE PRINT) FIRM'S NAME (OR ENTER "S.E" IF SELF EMPLOYED) PAID PREPARER'S PHONE NUMBER RUTH ANN MOONEY S.E. 717-532-3446 1 A/ Wage and T8X Department of the Treasury-Internal Revenue Service Form W-2 Statement 2 0 0 9 Copy B-To Be Filed With Employee's F DERAL Tax Return. This information is being furnished to the I emal Revenue Service. a Emp oyee's social security number Safe, accurate, Visit the IRS website 19 0 4 2 - 9 4 3 6 oMB No. 1545-oooe FASTI Use at www.irs.gov/efrle. b Employer identification number (EIN) 1 Wages, tips, other compensation 2 Federal income tax withheld 52-2292142 48005.11 4104.00 c Employer's name, address, and ZIP code 3 Social security wages 4 Social security tax withheld MG & G CONSTRUCTION 48005.11 2976.32 5 Medicare wages and tips 6 Medicare tax withheld P.O. BOX 1700 48005.11 696.07 9 8 2 7 DOWN S V I LL E P I K 7 Social security tips 8 Allocated tips HAGERSTOWN MD 21741 d Control number 9 Advance EIC payment 10 Dependent care benefits e Employee's name, address, and ZIP cod 11 Nonqualified plans ~ 2a See instructions for box 12 CALVIN E ISER e 4 02 S . PENN STREET ~~ p erty an~ment ac P 13 s`H w° « p C 2b SHIPPENSBURG PA 17257 e y l y d 14 Other 12c e 12d c a e 15 State Employer's state ID number 16 State wages, tips, etc. 17 State income tax 18 Local wages, tips, etc. 19 Local income tax 20 Locality name PA~ 9046 6470 48005.11 1473.65 q ~ oy~s agFi$I ~egyrity number Safe, accurate, Visit the IRS website 1 y 4 b OMB No. 1545-0008 FASTI Uas at www.irs.gov/elite. ~~mp~y;Qr~~fisayon number (EIN) 1 Wages, tips, otF~1~RensAtiQn ,. 2 Federal income t~x~N~hejdo. ~~rpp~er„g ~ U g, ~ddrg N ~ C, tt~ V tC ' I NC . 3 Social security w,ggss6 8 9 4 Social security tic y~it~hel~j 3 y L r . 9 8 2 7 DOWN S V I LL E P I K P. 0. BOX 1 s Medicare wagas~~ jjps 8 9 33 b ~~ s Medicare tax with h~ 7 7 , . HAGERSTOWN MD 21741-1740 7 Social security tips 8 Allocated tips d Control number 9 Advance EIC payment 10 Dependent care benefits n e, address, and ZIP cod I 11 Nonqualified plans 12a See instructions for box 12 E CA~ V I N ISER c e 4 02 S . PENN STREET s SHIPPENSBURG PA 17257 4 ~ ~,,,~,~, ~;roep~m 1s ~ 2b d 14 Other 12c c c e ~ 12d a ' 15 State Employer's state ID number 16 State wa ti ,etc. 17 State income tak 18 Local wages, tips, etc. 19 Local income tax' 20 locality name PA ~ 93472470 ___ ..._....3~5~ 89_ _.._.___...96.92 Wage and Tax Form W'2 Statement Copy B-To Be Filed With Employee's F This information is being furnished to the li 2009 AL Tax Return. Revenue Service. Department of the Treasury-Internal Revenue Service Form 11W2 Wap~ and Tax 2009 ~ 0027 -0827A041 c oye s name, roes, an c e Department of the Treasury -Internal Revenus Service 000014-000100 TORRES CREDIT SERVICES INC OMB No. 1545-0008 p PO BO% 189 80-0066026 142-46 4052 CARLISLE PA 17013 gas, s, ercmpnaapon moomeSaxm icon nn ~a ne ~'~ ~ ~ 1900.00 117.80 e nstrs. or x t er a mployee's name, addrosa, and IP code icaro vrapas an iDS scare x vn PASUI 1.14 MARIA D WISER 0 27.55 402 S PENN ST T Sodal security tips a Allocated flips SHIPPENSBURG PA 17257 9 Vance IC payment span ant caro a is eve ens 188tate Employer's able ID No. 18 State vragee, tips, etc. 17 State income tax 18 toeal tepee, tips, etc. 19 Local income tax 20 Locality name PA 191696356 1900.00 58.33 1900.00 26.60 PA SMIDD ThN YdsmaMan M haYb tlallialled b itN MIb11o1 RasenM~SelMae Notiee to Employee Refond. Even if you do not have to file a tax return, you should file to get a refund rf hex 2 shows federal income tax w8htiekl or'rf you ran take the earned income credit. Earned Income erodN (EIC). You must file a tax return a any amount le shown in box 9. You may be able to take the EIC for 2009 tt (a) you tlo not have a qualirying child and you earned less than $13,440 ($18,440 8 married filing )ointry), (b) you have one qualifying child and you earned less than $35,463 ($40,463 tt monied filing jointy), or (c) you have more than one qualifying child and you earned less than 540,295 ($45,295 tt married filing jomtry), or d) you have three or mare qualifying children and earned less than 543,279 ($48,279 if monied filing jointly). You and any qualirying children must have valid social securry numbers (SSNs). You cannot take me EIC'rf your investment income rs more tnan 53,100. Arty EIC mat Is more than your tax Ihhllily le refunded to You, hW anry if Yoe Nle a hx roNre. If you have at least one qualirying ch8d, you may get as much as $1,826 b the EIC in advance by completing Form W-5, Earned Income Cretld Advance Payment Certificate, and giving K to your employer. Clergy and religious rorhers. tt you are not subject to social security and Medicare taxes, see Publication 517,Sacial Security and Other Information for Members of the Clergy and Religious Workers. Corrections. If your name, SSN, or address is incorrect, correct Copies B, C, and 2 and ask your employer to correct your employment mcord. Re sure to ask the employer to file Form W-2c, Corrected Wage and Tax Statemem, with the Social Security Administration (SSA) to correct any name, SSN, or mbney amount error reported to the SSA on Form W-2. tt your name and SSN are correct but are not the same as shown on your social security card, you should ask for a new card that displays your correct name at any SSA office or by calling 1-800-772-1213. Credit for excess taxes. If you had more than one employer in 2009 and more than $6,621.00 in social security arMlor Tier I railroad rmirement (RRTA) taxes were whhheld, you may be able to claim a credn for the excess against your federal income tax. If you nod more than one railroad employer and more than 53,088.80 in Tier II RRTA tax was withheld, you also may he able to claim a credit. See your Form 1090 or Form 1040A instructions and Publication 505, Tax Withholding and Estimated Tax. Instructions for Employee Box 1. Enter Wis a oun On the wages line of your tax return. Box 2. En~Ie~he federal income rax whhheld line of your tax return. Bax 8. This a utletl in boxes 1, 3, S, or 7. For information on now fo report tips on your tau return, see your Form 1040 instruc8ons. Box 9. Enter this amount on the advance earned income credit paymems line of your Form 1040 ar Form 1040A. Box 18. This amount is the total dependent cam benefits that your employer paid to you or incurred on your behalf (including amounts from a section 125 (cafeteria) plan). Any amount over $5,000 is also included in box 1. You mull complete Schedule 2 (Form 1040A) or Fonn 2441, Child and Dependent Care Expenses, to compute any taxable and nontaxable amounts. Bos 11. This amount is (a) reported in box t rf d is a distribution made to you from a nonqualified deferred compensadon or nangovemmerrtal section 457(b) glen or (b) included In box 3 and/or 5'rf it is a prior year dekrrel under a nonqualttied or section 457th) plan that became kxable for social security and Medicare taxes this year because (here is no longer a substantial risk of fortetture of your right to me deferred am0um. Box 12. The fallowing list ezpkins the codes shown in box 12. You may need this information to complete your kx return. Elective deierrals (codes D, E, F, and S) and designated Roth contributions (codes AA and BB) under all plans are generelry limbed to a taWl of 578,500 ($11,500 4 you only have SIMPLE Dlens; 579,500 for section 403(6) plans tt you qualify for the 15-year rule explained in Pub. 571). Oeferrels under code G are limned to $16,500. Deferrals under code H are limned to 57,000. However, d you were at least age 50 in 2009, your employer may nave allowed an additional deferml of up to $5,500 ($2,500 for section 40i(k)(11) and 408(p) SIMPLE plans). This additional deferral amount rs not subject to the overall IimA do elective deferrals. f-or cbde G, the limit on elective deferrals may be higher for the last 3 years before you reach retirement age. GonlaCt your plan administrator far more information. Amounts h1 excess of the overall electve deferral IimB must tae included in income. See the "Wages, Salaries, Tips, elc." line Instructions for Form 1040. Note. It a year follows code D through H, S, Y, AA or BB, you made amake-up pension contribution for a prior year(s) when you were in military service. To figure whether you made excess deferrals, consider these amounts for the year shown, not the cunent year. If no year is shown, the contributions are for the current year. A-Uncollected social security or RRTA tax on tips. Include this tax on Form 1040. See "Total Tax" in the Form 1040 instructions. B-Uncolleced Medicare tax on tips. Include this tax on Form 1040. See "Total Tax" in the Form 1040 instructions. C-Tazabk cost of group-term lice insumnce over $50,000 (included in hazes 1, 3 (up to social security wage base), and 5) D--Elective deferrals to a section 401(k) cash or deferred arrangement. Also includes deferrals ~Ider a SIMPLE retirement account that is part of a section 401(k) arrangement. ~'E-Elective dekrrals under a seclian 403(b) wary reduc0on agreemerd F---Elective dekrrals under a section 408(k)(6) salary reduction SEP G-Elective dekrmis and employer comdhutions (including nonelective deferrals) to a section 457th) deferred compensation Dkn R-Elective defermis to a section 501(c)(18)(D) tax-exempt organiza0on plan. See "Adjusted Gross Income" in the Form 1040 instmctians for how to deduct. J-Nontaxable sick pay (information ony, not included in boxes 1, 3, or 5) K-20% excise tax on excess golden parechme payments. See ?otal TaY in the Form 1040 instructions. L-Substantiated employee business expense reimbursements (nontaxable) M-Uncollected social secunry or RRTA tax on taxable cost of group-krm INe insurance over $50,000 (former employees onry). See'TOtal Tax" in the Form 1040 irawctions. N~Jncollemed Medicare tax on hxabk cost of group•term life ir5urarice over $50,000 (former employees onry). See "Total Tax" in the Form 1040 instmc8ons. P-Excludable moving expense reimbursements paid directly tp employee (not included in':oxes 1, 3, or 5) D-Nontaxable combat pay. See the instructions for Fonn 1040 or Form 1040A for details on reporting this amount. R~mployer contributions to your Archer MSA. Report on form 8853, Amber MSAS and Long-Term Care Insurance Cbntmcts. S-Employee salary reduction con[ribugons under a section 408{p) SIMPII: (not included in box 1) T-Adoption benefits (not included in box 1). You muri complete Form 8839, Oualiried Adoption Expenses, to compute any taxable and nontaxable amounts. V-Income from exemise of nonstatutory stock option(s) (included in poxes 1, 3 (up to social security wage base),and 5) W-Employer contributions to your Health Savings Account. Report on Form 8889, Health Savings Accounts (HSAs). Y-Deferrals under a section 409A nonqualitied deferred compensation Dlan. 2-Income under section 409A on a nonqualified deferred compensation plan. This amount is also included in box 1. It is subject to an additional 2D% tax Dlus irderest. See "Total Tax" in the Form 1040 instructions. AA--0esignated Roth contributions antler a section 401(k) plan. BB--Designated Roth contributions under a section 403(b) Dlan. Box 13. Ii the "Retirement Dlan" box is checked, special limits may apPN to the amount of reditipnal IRA contributions that you may deduct. ' .Kee Copy C pf FOmi W-2 for at least 3 years after the due dale for hit tax r, to help Droterd your social security benefits, kee0 Copy cial security benefds, lust in case there is a question about your nNOr earnings in a particular year. Compare me Social Security wages and me Medicare wages to the informaton shown on your annual par workers over 25) Social Security Statement r COLANDREA PO 90X 1754 INWOOD, WV 254 ~Yto the_ ``""--~~order ow For ~: 0 5 L 5 0 ~~ ~~ Av~ . 1 ~~ /~.s hay JAGEMENT LLC ~ S.OZ ~ 69-462/5t5 { 0 BRANCH 14 ~8t8 /9 ~UfiV Gv r s'c /Z ~ $ 6~oeo -~ PL ~ ~ ~~ c _ Ilotlers ~ '° :: ~.~w. 1 E. ;OFF~~ l25~28 ~•%~ 11P 3t 0 L 400 30 17 4«'O_L 50 2 .. ~..,.: • COLONIAL G.ASSIC® d ., ~ ~ r ~~-I wx. ,,r,~.,. ,~ ~ ~~- L~1or~CP.c`s CowtP• .Y/--S, RESPONDENT'S EXHIBIT . ~ COLANDREA M GEMENT LLC 'I 5O1 PO BOX 1754 69-x62/515 INWOOD, WV 25428-t 54 f ~ ~a /~rj~'r Date ~Yto the C L (/ ! N tw ~ SCR ~ : ~'~} `'-corder o _. r~ ~C ~ ~! k~ ee~ Dollars ~ ~ ;,~,; o~ ~.<.. ~ ° CIt1~p Bak _,_._.- -~-- INW000 2b428 For - "" ~:0 5 L 5046 3~: 0 1400 30 174a'0 L SO L ,., COLONIAL CIASSIG n- p ~fi/9 - o~~/s ~aa~Y ~;~,~, ~ o~ B ~ SAM ~~a~~ ~'~ ~~ o.~ // 5 ~l ~ w. In the Court o~ Common Pleas of County, Pennsylvania Phone: Fax: . ~ ~ )Docket Number PI intiff vs. ) PACSES Case Number 7 t~ ~0 j~ De endant ) Other State ID Number Pleas note: All correspondence must include the PACSES Case Number. Income Statement THIS FORM MUST BE ~LLED OUT AND YOU MUST PROVIDE DOCUMENTS TO SUPPORT ALL A OUNTS PROVIDED IN THIS INCOME STATEMENT (1f you are self-employed or~if you are salaried by a business of which you are owner in whole or in part, you must also fi11 out the Su plemental Income Statement which appears below.) INCOME STATEMENT OF -~o~v~h l~<s (Name) (Pacses Number) I verify that the statements ade in this Income Statement are true and correct. I understand that false statements herein are mad subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. "~ , ./`~ ~ Date: 17 /6 " ` ~s%~! ~ ~.a~-~. INCOME ~'G"~ P aintiff r~ ~~f ~~~~~ or D nd t c~ ~@ ~/3/,~/U Employer: Address: Type of Work: ~ k e Payroll Number: Pay Period (weekly, biweek Gross Pay per Pay I Itemized Payroll Dec Federal Withholding FICA Local Wage Tax State Income Tax Mandatory Retireme Union Dues Health Insurance Other (specify) Net Pay per Pay Period: Service Type etc): $ ~e s: ~__ Fh . '~/&'©O fL~cl Truck i~en~.~ '~oo`Lpad u ~ p0 adD f,."°r ~c axes ~ jw ~~ti ~ 333+00 ~ ~- $ ~ Form IN-008 Rev. 3 Worker ID Income Statement (Continued) PACSES Case Number Other Income: Week Month Year (Fill in Appropriate Column) Interest $ $ $ Dividends Pension Distributions Annuity Social Security Rents Royalties Unemployment Comp. Workers Comp. Employer Fringe Benefits Other $ $ TOTAL INCOME $ PROPERTY OWNED Ownership" Description Value ~ W J Checking accounts $ /C10c~ ,.¢~o~.,;,~, Savings accounts Credit Union Stocks/bonds ~~~7 U 0 Real Estate Other Total $ INSURANCE Coverage" Company Policy No. H W C Hospital Blue Cross Other Medical Blue Shield Other Health/Accident Disability Income Dental Other *H=Husband; W=Wife; J=Joint; C=Child Form IN-008 Rev. 3 Page 2 of 3 Worker -D Service Type v Expense Statement EXPENSE STATEMENT OF (Name) (Pacses Number) I verify that the statement made in this Expense Statement are true and correct. 1 understand. that false statements herein are ma e subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. =A~ / t Date: i ~ /6 /.~~/~^ - aln t or ndant EXPENSES MONT TOTA LY MONTHLY G ILDREN MONTHLY PARENT EXPENSES MONTHLY TOTAL MONTHLY CHILDREN MONTHLY PARENT HOME Medical Mort a e or Rent ~ Medical Insurance Maintenance Doctor Lawn Care Dentist 2nd Mort a e Ho s ital Medication UTILITIES Counseting(Therapy Electric Orthodontist Gas Special Needs (glasses, Oil etc.) Tele hone 9 Cell- Phone EDUCATION Water d. d Tuition Sewer Tutcrin Cable TV `p Lessons Internet Other Trash/Rec clin EXPENSES MONT TOTA LY MONTHLY CHILDREN MONTHLY PARENT EXPENSES MONTHLY TOTAL MONTHLY CHILDREN MONTHLY PARENT TAXES PERSONAL _ Real Estate ~/p - Debt Service Personal Pro ert Clothin Groceries ~/O INSURANCE Haircare HomeownerslRenters Memberships Automobile Life S2 MISCELLANEOUS AccidenUDisabili Ghild Care Excess Covera a Household Hel Lon -Term Care Summer Cam Pa ers/BookslMa alines AUTOMOBILE Entertainment Lease or Loan Pa ments 8S Pet Ex enses - Fuel Vacations Re airs Gifts Membershi s Le al Fees/Prof. Fees Charitable Goniributions Children's Parties Children's Allowances Other Child Su ort Alimon Pa ments TOTAL MONTHLY EXPENSES ~~~~ ~ sQl l: e '~ ,~ . f Income Statement (Continued) PACSES Case Number SUPPLEMENTAL INCOME STATEMENT (You only need to complete the below portion if you are self-employed or if you are salaried by a business of which you are owner in whole or in part) (a) This form is to be filled out by a person (check one): ^ who operates a busines act' es fes 'on, or (2) who is a member o partnershi e-ai;~ r ^ (3) who is a shareholder m an is salane by a closed corporation or similar entity. (b) Attach to this statement a copy of the following documents relating to the partnership, joint ture, business, profession, corporation or similar entity: 1 e most recent Federal Income Tax Return, and the most recent Profit and Loss Statement. (c) Name of business: ~ Address and telephone number: (d) Nature of business ( k one) partnership ^ (2) joint venture ^ (3) profession ^ (4) closed corporation ^ (5) other (e) Name of accountant, controller or other person in charge of financial records: (f) Annual income from business: (1) How often is income received? (2) Gross income per pay period: ' (3) Net income per pay period: (4) Specific deductions, if any: - ~o,ru~,2 ~1a9'9.33 ~Y o • ~ ..__.. ..-.--~- --ra x e s , /Y,~ J~r-, a ~ zao9 -'.~ S eG'+'i ~. ^ f ~ w.ortk /f~OroX. '~S~l0 /, 9 ~/~ 1 p ~~ ~ ~ /~ fk ~ ~ ~/9 yG • ~ 6/,ti,ay~~h Service Type r Page 3 of 3 __/ yoa9 ~~ ~ G~ Form IN-008 Rev. 3 Worker ID .~ ;rs X I In the Court of Phone: • Fax: Plaintiff Name: Defendant Name: Docket Number: PACSES Case Number: $5/ ~ ~ / /S `1S Other State ID Number: Please note: All correspondence must include the PACSES Case Number. Income and Expense Statement THIS FORM MUST BE FILLED OUT (If you are self-employed or i you are salaried by a business of which you are owner in whole or part, you must also fill out the Supplemental ncome Statement which appears on page two of this income and expense statement. ) INCOME STATEMENT OF ~ IV ! 1 /~ ~ - ~' S e r Section I: Income and Insurance Employer C.a/ Q v- Address ~ (~, ~ Type of Work ~iP~r. A Payroll No. syb• Gross Pay per Itemized Payroll Deductions: in Pleas of County, Pennsylvania Period $ "~/d~~,ad Pay Perio~(wkly. bi-wkly., etc.) Fed Social Security $ Local Wa a Tax $ State Income Tax $ Retire $ Savin s Bonds Credit Union $ Life Insurance rance $ Other Deductions s ec' $ $ _. $ Net Pay per Pay Period $ INCOME: OTHER (Fill in A ropriate Column) INCOME WEEK ONTH YEAR Interest $ $ ~ Dividends Pension Annuit Social Securit Rents Ro allies E ense Account Gigs Unem to ment Workmen's Com ensation Other Other TOTAL $ TOTAL INCOME $ Service Type PROPERTY Ownership OWNED DESCRIPTION VALUE H W J Checking Accounts f'~'So~ t $ Savin s Accounts g Credit Union Stocks/Bonds ~ 2j Real Estate / ~e S/4.cclio Other ~ nr ,h4v~'~^ JCS?7 dOV I TOTAL I$ * H=Husband; W=Wife; J=Joint ~ , Form IN-008 Worker ID ~ 6-~0 ~ ~ ~ t { Income and Expense Stateme PACSES Case Number INSURA CE Coverage N COMPANY POLICY # H W C Hosvital Blue Cross Other Medical Blue Shield Other Health/Accident Disability Income Dental Other a. b. c d. e. f. * H =Husband; W =Wife; C =Child Section II: Sunalemental Income Statement This form is to be filled ou by a person ^ 1) who operates business or practices a profession, or ~2) who is a me er of a partnership or joint venture, or ^ (3) who is a sha older in and is salaried by a closed corporation or similar entity. Attach to this statement a c py of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entit (1) the most recent Federal Income Tax Return, and (2) the most recent Profit a d Loss Statement Name of business: ~' /~, 1^cN ef- ~ QS' Address and telephone nu er: ~ (1) partnership ^ (2) joint venture ^ (3) profession ^ (4) closed cotpor lion ^ (5) other Name of accountant, contr ller or oth^er^person in charge of financial records: Y1 /' LCOy1 C . Annual income from bus' ss: (1) How often is in me received? /hoN fti / ,'nco,.r, (2) Gross income r pay period: (3) Net income per ay period: /vIo ti f k/ ~oSe (4) Specified deduct ons, if any: Service Type Page 2 of 3 Form IN-008 Worker 1D Income and Expense Section III: Expenses Instructions: Only show extrao in BOLD FONT are especially you assert your case cannot be PACSES Case Number expenses in this section unless you filled out Section II on page two. The categories .nt for calculating child support. If you are requesting Spousal Support/APL or if ned according to the guideline grids or formula, this section must be fully completed. (Fill in ppropriate Column) EXPENSES WEEK MONTH YEAR Home Mortgage/Rent $ $ Maintenance Utilities Electric $ $ Gas Oil •~ Telephone 8 Water Sewer Em to ment Public Transport. $ $ Lunch Taxes Real estate $ 6 $ Personal Property Insurance Homeowner's $ ~ $ Automobile Life Accident Health Other Automobile Payments $ $ Fuel Repairs Medical Doctor $ $ Dentist Orthodontist Hospital Medicine n (glasses, braces, o e9ic I verify that the statements made statements herein are subject to t Date Service Type EXPENSES ~~ m Appropriate Column) (continued) WEEK MONTH PEAR Education Pri98te SCh001 $ $ $ Parochial School College zy`p }e 3 Religious Personal Clothing $ $ 75 ~ $ Food r»o a. Barber/ i' Credit Payments Credit Card Charge Memberships Loans Credit Union $ $ $ Miscellaneous Household Help $ $ $ Child care Papers books Ma azines Entertainment Pay TV Vacation Gigs Legal fees Charitable Co ufo er hdd Alimony Other $ $ $ T tal WEEK MONTH YEAR E menses: $ ~ ~/YX~ $ this Iticome and Expense Statement are true and correct. I understand that false criminal penalties of 18 Pa. C.S. § 49 lating to unsworn falsification to authorities. i ~~^ Plaintiff or Defendant Page 3 of 3 Form IN-008 Worker ID Center Stage Studio 2009 Income and Expenses Income Tuition ................... $27987.00 Registration ............... $730.00 Recital Tickets ........... $600.00 Video ...................... $1220.00 Costumes ................ $2195.00 Fundraiser ................. 1339.50 Merchandise .............. $670.30 Total $3,741.80 Expenses Rent ....................... 6422.34 Insurance ................ 1146.00 Utilities .................. $ 121.20 Repairs ...................$ 50.00 Studio Extras ............ 2994.40 Supplies ................. 952.60 Office Supplies .......... 3692.30 Advertisements .......... 1561.84 Payroll ..................... 14927.21 Training .................. 0.00 Video .................... 1220.00 Costume .................. 990.88 Fundraiser ............... $ .00 ~ ~~ ~ _ .~~e_a_-1~-~<~ ~lt~ilr.~, !~t_ !~.~ Travel ~-' ~ f/ ....................$ 527.16 Merchandise ............ $ 803.71 Total TOTAL - • '• 7 ~yU ~ ~ ~ _.___ _ l Q ~ ~ 0 0 ~ 0 0 Gp0000 0 V U 01 a+ t~~ l~Nl( ~}' CO C ~~r-.-~~ v ~ O ~~ Q O N_ V' M O v O O O O O N v N V' C N w N m n. J N C O O U v m N 0 7 O L O r O CO O CO N +' C d m E O U 0 L O N 0 L 0 N a~ _N f0 'C (6 0 0 N O O (D O .a ~OD~O O N_ N_ O O M N O O O ~ O m m m 0 0 C C_ C C _C C_ C C C C C C mmmmmm N N N N N N UUUUUU ~ ~1 ~ V C'7 0 0 0 0 0 0 M M M M M M ~ ~ ~ ~ ~ ~ O N O O O N ~ N N O .-- O M M O O _ ~ C N r ~ r 0 ~ ~ r a ~ rn N_ N O O Q N v r N C N w N m y 7 O L r O N C N L L O t O N 0 L 0 N w+ C O V V a ~ Q J N C (0 O 'C ~ ~ U O ~ o Q7 N N O N D O .n I~OON~ N~00.N- ~~TVV O O m C C_ C C C C m m m a~ m a~ U U U M c'07 cO) ~ to t1') N W r Zm O ~"~ K ~ W W a ~~~~~~~ ~_ ~ ~~~~ ~~_ _o N s W W W.DEERFIELD-COMMOtiS.COM April 17, 2010 To Wixom It May Maria Wiser is a sub-col times, may reflect a pay nature of our bilt"ing cyc nor reflect invoices rece Deerfield Commons anc they are processed and Deerfield Commons bui implications for paymef you may contact Rebea Regards, kes Le~asiog~l3i#ing Agera*_ Deerfield Commons loo D tractor at the property of Deerfield Commons. Maria's paystubs. at Went of invoices submitted over a period of 46 weeks. Due to the. es, wb-contractor payments may not always be made every 5.S gay ivied within that 15 day period. Invoices are submitted to the office at then forwarded to our billing department at our Home Offiice where :heckscutforpayment. f~FariaVl~iser-'ssnatapagnatt-emptayee-of a sub-contractor and as such is responsible for any and att tax is received by her. if you have any additional questions or concerns a Lee, our Residential Manager, at our office. 7-S -~ o r~ ERFIELD COMMONS, SHIPPENSBURG, PA r7z57 PHONE 7i7.53o.grit ~ FAX 7i7.53o.47ob EMAIL INFO@DEERFIELD-GOMMONS.COM STUDIO January through June, Net Income: January 780.51 February 136.50 March (2,630.45) April 2,013.01 May (71.96) June (934.75) Total ($707.14) 0 6-~0 ~3~ L 0 • T 177 ~ _= O ~ Z ~ T V1 ~ ~ CJ7 ~ ~ J V • ~- C N W N N N ~ ~ ~ A C ~ O ~ O .fl O N ~ ~ ffl O W 64 .P {f} CD C N O O N .A ~ N W ~l t0 O ~ ~ O ~ ~ y C ~ ~ j ~ _~ 0 V, ~ ~l ~ x ~ O ~ O I ui I ~~ 1 ~ ff3 Efl ffl - ~ p N ~ ~ ~ ~ ~ N C J1 p 0 ~ ~ CO Q O O O ~ ~P O N ~ 0 0 A ..i ~ ~ ~ V ~ O C ~ 69 ~ ~; ~ ~ A O fJt O ~ ~ V N N ~j p - N V ~ V ~ ~ ~ O O c~ {~ < O O ~ n '~ y O = O ~ O ~p ~ ~ O ~ ~ O O ~ O W N N W ~ W CJ~ N CO fn CO N p < W ~ f.Jl N O ~ ~ N N O cP i Cn O (T1 O N W A O m 3 O O: O N O ~ ~ O m O ~ ~ O N rn ~ ~ C7t N N N tp W N N j ~ N W ~ EA Cn CA Cn 0 A 3 m fA N ~ fJ1 CEO UNi V W O O N O ~ GAD ~ EA 7 ~ O .,. ~ C~1 ~ j ~r C1 ~ C V ~ ~ V ~ ~ c~ = ~R O . r a~ ~ O y O ~ A ~ o ° O ~ {~ ~ N c~ O O c 3 w Ei? 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N C> S a1 7 a 3 A ~ 3 ~ - ~ ~ 0 rn k N "` ~ V (n N ~ C m A m t~ a ' 0 ~ m ~ j Q m ~_ ~ Efl ffl V ~ ~ OD CD ~ p ~ ~ W d 3 Q a'V N C O O O m 3 fQ G a `~ ~1 A~ ,~ E~ O C O O G O O O O O O O O O O W N O O O t!3 W d! O W {,H N {~ N O W W CJ1 f '~ N Q 0 '~ ~ ~ e cNi~vv~ ~icio N CD ? C 3 Q. pm N Eflffl{-Rfnfflffl{~?Efl{-f) p~ 1 N N 1 0~ N W N < 00 O V ~1 A OU7OU7AOCpODUt OCOOGJOO W 00 O ~P OD aD W ~ z O m CO O. O O .r. O Z 3 ~° N O ~11~ V N 1~9 O i~H O C O CFl c n ~ w ' ~D 1 •i m _~ rF N C C. N O C') O w C N N ~ O ~ ~ O O 3 C 3 C. m y N N Cf 3' N 3 _Q. ~ ~ ~ ~ V .~- ~ iw to N (D C m 7 ffl ~ ~ ~ N 0 0 c O Cp V ~ ~ ~ OD O 'a m W rt C d ~ O ~ m W A O V V O W W ~ W C J1 i U ~A C OD W .a 'Q O ~ ~ a 3 3 .~ ~ m CD ' O W O O m 3 < Q C a ~. ..L V W !~ J 0 Q 0 '~ Q V W j W N '~ 0 N Q V {~ N N O O O ~69 W O O O O {~ O n 0 w .. c 3 c a m ~ ~ ~ ~ m W W W N g O CT1 N Cti • e o _ .1 (~ J O .P N V O n m a 0 m 3 o Z ~ ~. O O O 6R O C 0 N N CO W 1A O C O .i ~ j W j n W ~ W .=i 0 ~ 3 V j (~ m n rt fA _C N O A 0 c B m N C 7 Q 01 N !~i S O1 3 d y N ~ „~ A O ~ ~ ~ ~D K N ~ 3 N ~ C m 7 A N .Ci ~ ~ A ~ CO M -+ N O ~ m N d 0 O V v N ~ 1 ~ O N ~ N N C ~ ~ ffl ffl ' O 1 W Ch N 1 00 ~ O 1 O V U7 ~ 4 W N Ef) _ V ~ ~ O O a D O r. <~ m O 1 O ~ _ 1 m 3 v '~ 0 0 0 0 '~ ~I17 N V CW N E,9 O O O OD Cif W 0 V W V W {~ O O O j {fj ...- C~7 C!1 C fl: n O C N C 7 d qm A 1 m A A C'! m _a ~'o O ..« A Z O ~p ~ .. 0 O O t~ O O O co C~ '~ t/? "~~ Cp In the Court of ommon Pleas of ~~gE~,~ County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 Phone: (717) 240-6225 DECEMBER 15 , 2 0 0 9 Fax: (71'n 240-6248 MARIA D. WISER ) Docket Number 01076 S 2009 P aintiff ) vs. PACSES Case Number 54 61113 5 3 CALVIN E. WISER ) fendant ) Other State ID Number Please note: All correspondence must include the PACSES Case Number. Income Statement THIS FORM MUST BE ILLED OUT AND YOU MUST PROVIDE DOCUMENTS TO SUPPORT ALL MOUNTS PROVIDED IN THIS INCOME STATEMENT (If you are self-employed orif you are salaried by a business of which you are owner in whole or in part, you must also fill out the Supple ental Income Statement which appears below.) INCOME STATEMENT (Name) (PACSES Number) I verify that the statements de in this Income Statement are true and correct. I understand that false statements herein are made s bject to penalties of 18 Pa. C.S.A. § 4904 rela/thing to unsworn falsification to authorities. Date: +~/ ~i~- - ~ , ~//..~ x ,, Plaintiff or Defendant INCOME Employer: Address: Type of Work: Payroll Number: Pay Period (weekly biweekl Gross Pay per Pay P Itemized Payroll Dec Federal V~ithholding FICA Local Wage Tax State Income Tax Mandatory Retireme~ Union D,ure~s Health Iris f:~°ce~' Other (specify) Net Pay per Pay Period: Service Type M $~~ . CSV ~bcf~, $ rT, dpi ~~9~ '',3 _~~z ~~_ - _/G ~~ ~~ Form IN-0O8 Rev. 3 Worker ID 21502 7~~0 ~ S~ Income Statement Other Income: Interest Dividends Pension Distributions Annuity Social Security Rents Royalties Unemployment Comp. Workers Comp. Employer Fringe Benefits Other TOTAL INCOME PROPERTY OWNED Checking accounts Savings accounts Credit Union Stocks/bonds Real Estate Other INSURANCE Hospital Blue Cross Other Medical Blue Shield Other Health/Accident Disability Income Dental Other *H=Husband; W=Wife; J= ~) PACSES Case Number 546111353 Week Month yeaz (Fill in Appropriate Column) $ $ $ $ $ Ownership* Description Value H W J Total $ Coverage* Company Policy No. H W C Joint; C=Child Page 2 of 3 Form IN-008 Rev. 3 Service Type M Worker ID 21502 Income Statement PACSES Case Number 5 4 61113 5 3 SUPPLEMENTAL INCOME STATEMENT (You only need to complete the below portion if you aze self-employed or if you aze alaried by a business of which you aze owner in whole or in part) (a) This form is to be filled out by a person (check one): ^ (1) who operat a business or practices a profession, or ^ (2) who is a me ber of a paztnership or joint venture, or ^ (3) who is a sh eholder in and is salazied by a closed corporation or similar entity. (b) Attach to this stat ment a copy of the following documents relating to the partnership, joint venture, business, professi n, corporation or similaz entity: (1) the most r nt Federal Income Tax Return, and (2) the most rec nt Profit and Loss Statement. (c) Name of business: Address and telenl (d) Nature of busine: (check one) ^ (1) partnership ^ (2) joint ventu~ ^ (3) profession ^ (4) closed core ^ (5) other (e) Name of (f) Annual income (1) How often is i~ (2) Gross income 1 (3) Net income peg (4) Specific deduce number: controller or other person in chazge of financial records: n business: some received? ~r pay period: pay period: ons, if any: Page 3 of 3 Form IN-008 Rev. 3 Service Type M Worker ID 21502 In the Court of ommon Pleas of CuMBEIU.ANn County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 Phone: (717) 240-6225 DECEMBER 15 , 2 0 0 9 Fax: (717) 240-6248 MARIA D. WISER ) Docket Number 01076 S 2009 P aintiff ) vs. PACSES Case Number 546111353 CALVIN E. WISER ) fendant ) Other State ID Number Please note: All correspondence must include the PACSES Case Number. Guidelines Exuense Statement EXPENSE STATEMENT OF (Name) (Pacses Number) I verify that the statements de in this Expense Statement are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. A n Date: ~ ~ •~~/ Q.~.e.,t, ~~~?.Y~~ Plaintiff or Defendant Instructions: Guidelines E~pense Statement -This fonm should only be completed when: 1) You aze requestin an adjustment to the amount of support pursuant to Rule 1910.16-5 because of unusual needs and un sual fixed obligations, other support obligations, medical expenses not covered by insurance, or any oth r relevant factors, or 2) You are requestin that the other party share in the following expenses pursuant to Rule 1910.16-6: child caze expenses, ealth insurance premiums, unreimbursed medical expenses, private school tuition, summer camp, or oth r needs, or mortgage payment. You must provide documents to support all amnnntc nrnvirlFrl in this Frrs+nco Cr~ro.,,o.,r Weekly Monthly Yearly ( Fill in Appropriate Column ) Mortgage (including real esta taxes and homeowner's insurance) or Rent e $ $ ~ , $ Health Insurance Premiums Unreimbursed Medical Ex enses: _. Doctor ~..~- Dentist ..-- Orthodontist ~..- Hos ital ._._.- Medicine ,.~, Special Needs (glasses, braces, orthopedic devices, therapy) Jam. Form IN-008 Rev. 3 Service Type M Worker ID 21502 Guidelines Expense Statem nt (Continued) PACSES Case Number 546111353 Weekly Monthly Yearly Child Care .~_.., Private School ,~ Parochial school ,..._._, Loans/Debts „~ Support of Other Dependents: -- Other child support Alimony payments ..~- Other: (Specify) .~ Total $ $ ,} ()'©. ~ $ ~ ~~~~~ Page 2 of 2 Form IN-008 Rev. 3 Service Type M Worker ID 21502 Expense Statement EXPENSE STATEMENT OF (Name) (Pacses Number) I verify that the stateme is made in this Expense Statement are true and correct. I understand that false statements herein are de subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authoritie . Date: ~ ~''l~ Plaintiff or Defendant EXPENSES MO TO THLY L MONTHLY CHI DREN MONTHLY PARENT HOME Mort a e or Rent ~ ~ --^ Maintenance -"'~"~ ----. Lawn Care ^ 2nd Mort a e ---•-'~ UTILITIES Electric Gas Oil Tele hone Cell Phone Water Sewer Cable TV Internet Trash/Rec clin EXPENSES MONTHLY TOTAL MONTHLY CHIL N MONTHLY P Medical Medicallnsurance tom' Doctor ~'~' Dentist ~ Ho s ital -''~ Medication r~ Counseling/Therapy Orthodontist Special Needs (glasses, etc.) ~~ EDUCATION Tuition ~^"~ Tutorin +"" Lessons .+~ Other EXPENSES ~ MONTHLY ~ MONTHLY ~ MONTHLY Real Estate INSURANCE Homeowners/Renters Automobile EXPENSES MONTHLY OT L MONTHLY CHI DRE MONTHLY A PERSONAL Debt Service Clothi Groceries Haircare Membershi s MISCELLANEOUS Child Care -" Household Hel Summer Cam Pa ers/Books/Ma azines Entertainment Pet Ex enses --- Vacations ~.,. Gifts Le al FeeslProf. Fees Charitable Contributions Children's Parties "' Children's Allowances '°'°` Other Child Su ort --~ Alimon Pa ments ,.~ TOTAL MONTHLY EXPENSES ExEense Statement EXPENSE STATEMENT OF (Name) (Pacses Number) I verify that the stateme is made in this Expense Statement are true and correct. I understand that false statements herein are ade subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authoritie , , Date: / •-~cia-~`'7/c Plaintiff or Defendant EXPENSES ' MO TO THLY L MONTHLY CHI DREN MONTHLY PARENT HOME Mort a e or Rent gy -'" .----- Maintenance -"''~""° Lawn Care --"" 2nd Mort a e -~ - _ ... . UTILITIES Electric Gas Oil Tele hone Cell Phone Water Sewer Cable TV Internet Trash/R.ec clin EXPENSES MONTHLY TOTAL MONTHLY CH LD EN MONTHLY PARENT Medical Medicallnsurance r'~ Doctor ~"' Dentist e~ Ho s ital -~" Medication t'` Counseling/Therapy Orthodontist Special Needs (glasses, etc.) EDUCATION Tuition ~' Tutorin -y"r" Lessons ~' Other ~ EXPENSES ~MON~'HLY MONTHLY ~MONTHLY~ Automobile EXPENSES MONTHLY TOTAL MONTHLY CHILDREN MONTHLY ARE T PERSONAL Debt Service Ciothin Groceries Haircare Membershi s MISCELLANEOUS Child Care -" Household Hel -- Summer Cam Pa erslBooks/Ma azines Entertainment Pet Ex enses ~- Vacations Gifts Le al Fees/Prof. Fees Charitable Contribut(ons Children's Parties Children's Allowances "'' Other Child Su ort -~ Allmon Pa ments :~- TOTAL MONTHLY EXPENSES Expense Statement EXPENSE STATEMENT OF (Name) (Passes Number) I verify that the stateme is made in this Expense Statement are true and correct. I understand that false statements herein are ade subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authoritie . ,,, Date: / %••~~-'a-'"'zi~ Plaintiff or Defendant EXPENSES MO TO THLY L MONTHLY CHILDREN MONTHLY PARENT HOME Mort a e or Rent ~' '-' ------^ Maintenance -~"'•'•~` Lawn Care ^~" 2nd Mort a e UTILITIES Electric Gas Oil Tele hone Cell Phone Water Sewer Cable TV Internet Trash/Rec clin EXPENSES TAXES Real Estate Personal Prol INSURANCE Homeowners Automobile Y (MONTHLY (MONTHLY EXPENSES MONTHLY TOTAL MONTHLY CHILD N MONTHLY PAR Medical Medicallnsurance r'te'' Doctor +/-" Dentist e~ Ho s ital -~"~' Medication rte' CounselinglTherapy Orthodontist Special Needs (glasses, etc.) •~~ EDUCATION Tuition ~" Tutorin yr" Lessons ~ Other EXPENSES MONTHLY OTAL MONTHLY CHILDREN MONTHLY ARENT PERSONAL Debt Service Clothin Groceries Haircare Membershi s MISCELLANEOUS Child Care -" Household Hel -- Summer Cam Pa erslBookslMa azines Entertainment Pet Ex enses Vacations Gifts Le al Fees/Prof. Fees Charitable Contributions Children's Parties ~• Children's Allowances '°" Other Child Su ort .y Alimon Pa ments TOTAL MONTHLY EXPENSES Expense Statement EXPENSE STATEMENT OF {Name) {Pacses Number) I verify that the statem nts made in this Expense Statement are true and correct. I understand that false statements herein are ade subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authoriti s. Date: / •~~-n.iL Plaintiff or Defendant EXPENSES M N TO THLY AL MONTHLY C LDREN MONTHLY P RENT HOME Mort a e or Rent g'y -'~ ,..-.----. Maintenance -~-~~'""` Lawn Care -~ 2nd Mort a e - - _...,~,. UTILITIES Electric Gas Oil Tele hone Cell Phone Water Sewer ~!~ Cable TV Internet Trash/Rec clip EXPENSES T Automobile .Y I MONTHLY l MONTHLY EXPENSES MONTHLY TOTAL MONTHLY C i D E MONTHLY P Medical Medicallnsurance r~ Doctor ~"' Dentist e~ Ho s ital --~- Medication r"' Counseling/Therapy Orthodontist Special Needs (glasses, etc.) ,~.~~ EDUCATION Tuition a*+~' Tutorin ~~• Lessons r~ Other EXPENSES MONTHLY TOT L MONTHLY CHILDREN MONTHLY A E T PERSONAL Debt Service Clothin Groceries Haircare Membershi s MISCELLANEOUS Child Care -^ Household Hel -- Summer Cam Pa erslSooks/Ma azines Entertainment Pet Ex enses Vacations Gifts to al Fees/Prof. Fees Charitable Contributions Children's Parties ~^ Children's Allowances `"'° Other Child Su ort .•-~ Afimon Pa ments ;,,,, TOTAL MONTHLY EXPENSES i 08 2010 2:31PM ~ MG#G#COSTRUCTIO 9015829402 p.S Employer: MG & G C NTRUCTION LLC /~ Check if address supplied is: ( )Employment Location ( ) Paym{I Address ~'"} Bmpbyment attd Payro{t locations are tfie same. Pleasc suppty your Federal Emp oyer Identification Number: -` It e5 2 - `L2 ~ 2 ! y ~- Re: ~,~~ ~_ y,~g PACSES Case No.: 546111545 $$N: 190-~k2-9436 Furnish Earnings informs It is preferred that you att a copy of the employee's Paynollild Number: ~, Employee Address: Date of Hire: ~o Reason: ~ Cali back date: ~ ~ l Pay cycle: ( ) j~~B; 10/28/50 EARMNGS REPORT for the above-named employee for each pay period during the last six (~ months. a photocopy of your records containing the earnungs information requested. Attach t t w-2 Fort. C7 C7 C .C._ G Nature of Employment: f'be~t:t'K,cen Last day worked/terminated: v ~~ ~~ Full-time: ~ Part-time: Gross hourly rate: $ 2 Y - 3 s y ( )Semi-Monthly < )13i-Wcekty (,,{~) Weekly Payroll Period Ending ~ .~? L' 2 Z f t J ~ ~ t ~ ~ ~ ~ ~ i~, ~o Date of Pay ~ ~ L7 f to t fc~~ j1 / 71 n Gross Pay ~, C1 Z Y ,.., Deductions Federal Withholding ~Z.. u Z -^ 2 -~ $Zs.._. - ~ Z --' Social Security Gc7, . 3 .. _ _ _ ' ~ 3 ~ __ bd9 ~ ~,~~t~ lY_r~ fY.t i`i~ t 3 f~~ yet State L~come Tax L9 q v 24 - d ~ . ~- Z°I 9 a 2`fi.'`t~ Retirement ,~~ ,r , ~ ..... ~ ~ Ca , ~ ,., ,_ V ~.. 58V1ng913onds ~ ~~ ... Credit Union ~ _. r-- ~ .~ ~ ~,,,~ ,.- O ~ -- o _ Life Insurance r--- ._. c, .~ ,~ ~, ~ ~ m .,, l~gltl~alptsnice .._ O ~ b - ~- O -~ ~ O O - -- t? .._ other (Specify)~'l~j w- ~. ~., v "..~ ~ 3 ~ Other ti!'/a,G 2a ~- 71J - 2J -- ?s~ --~ Net Pay . ~ ~$ ~, 7~, (S ~ Hours Worked ~ ,4 ~ LE V ~ ~ I verify that the statements ade in this Earnings Report are true and correct. I understand that false statements het~ein are subject to the cri nal penalties of 18 Pa. C.5. ~ 4904, relating to unsworn falsification to authorities. Signed by: -_._~ Date: / V Position: Page 2 of 4 Farm IN-015 Rev.2 Service 'I~pe M Worker ID 212 0 5 ~r "~ ~~ - 9 200 ~ ~.:. David R. Bretz, by : IN THE COURT OF COMMON PLEAS OF Susan Bretz, his attorn e in fact, :CUMBERLAND COUNTY, PE NNSYLVANIA Petit i ner/Plaintiff vs. NO. 09-7658 Civil Term Walter P. Little and Ta a L. Little, his wife; Ray T. Harrig nand Mary D. Harrigan his Wife; Mil on Renninger :CIVIL ACTION -LAW a/k/a Milton Reneker; illie Renninger; Jacob R Renninger a/ J. R Renninger: _ a/k/a J.R Reneker; Jer my Miller; Abraham Miller; a/k/a bram Miller; -~:~ ~- c_,_ ~.+ Abram Miller heirs at w; Samuel Miller;: ~_~ -- ~' ~ ~~ i= m Thachous Miller; Mart a Miller; Adeline : _,~ _ "" -:, "=' cs~ `; ~ Miller; Francis Quigg; Sarah Jane Miller;: " ~'~-- ~ =~;~: Jacob Hess; Catherine filler; William - -~ '- ~-`= Bady; John Gamber, ttorney-in-fact for : ~' ~ ~? ~ ~.~ Abraham Miller heirs; Frederick May .:~ -~ -~c ~ and Magdalona May, is wife;: :ACTION TO QUIET TITLE John Shoop, Administ ator For Estate of Jacob Neidig ; Jaco Neidig; John Neidig and Mary Neidig, his wife, Resnon ent/Defendants RULE TO SHOW CAUSE AND NOW, Protective Order, it is Littles to show why the /q~ day of July, 2010, upon consideration of Plaintiff's Petition for ORDERED that a Rule is hereby entered upon the Respondents/Defendants intiff s Petition for Protective Order should not be granted and the Deposition for Mark Romeo, P.L.S. ~s hereby stayed until further Order of this Court. This Rule is for Zo days after service of this Rule To Show Cause upon counsel Littles. BY THE COURT: President Judge C£ "Henry F. Coyne, For Plan '~ Linus Fenicle, E For Defi t.ro 'J t~~S ~ 1~ y~~ 4 ~~v ~~ ' .'- Prwa:~s~ ZOfO JJ 2S fJ ~~ ~ r COYNE & COYNE, P.C. Henry F. Coyne, Esq. Pa. Supreme Ct. No. 06250 3901 Market Street Camp Hill, PA 17011-4227 CUP~~~ ~ _ ~~y t~~ i ~ `r~L.~' ~"~ (717) 737-0464 Attorneys for Plaintiffs David R Bretz, by : IN THE COURT OF COMMON PLEAS OF Susan Bretz, his attorney in fact, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. Walter P. Little and Tara L. Little, his wife; Ray T. Harrigan and Mary D. . Harrigan his Wife; Milton Renninger a/k/a Milton Reneker; Lillie Renninger; Jacob R Renninger a/kla! J. R. Renninger: a/k/a J.R Reneker; Jeremy Miller; Abraham Miller; a/k/a Abram Miller; Abram Miller heirs at law; Samuel Miller;: Thachous Miller; Martha Miller; Adeline Miller; Francis Quigg; Sarah Jane Miller;: Jacob Hess; Catherine Miller; William Bady; John Gamber, Attorney-in-fact for Abraham Miller heirs; Frederick May and Magdalona May, his wife; . John Shoop, Administrator For Estate of Jacob Neidig ;Jacob Neidig; . John Neidig and Mary Neidig, his wife . Defendants NO. 09-7658 Civil Term CIVIL ACTION -LAW ACTION TO QUIET TITLE CERTIFICATE OF SERVICE I, Henry F. Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the Rule to Show Cause, dated July 19, 2010 was served this date upon the below-referenced individuals at the below listed address by way of first class mail, postage pre-paid on Jul 27 2010: y ' Linus E. Fenicle, Esquire Reager & Adler, PC 2331 Market Street Camp Hill, PA 1 70 1 1-4642 Dated: ~ l ~ v COYNE & COYNE, PC By: eery F. oyne, Esquir 3901 M et Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorney for Plaintiffs 1 r,_::. COYNE & COYNE, P.C. ',` ~ ~ - ~' Henry F. Coyne, Esq. Pa. Supreme Ct. No. 06250 EG~~ ~~.i~~.; 3 ~ ~~.~~~ -~~ `rte 3901 Market Street p'(I(f' ~~ ~}'lh ~~ ~ Camp Hill, PA 17011-4227 ~~~`~~ = - - ~''` 71 737-0464 `: ~- '` . , "`' ~ '~ '`A~torneys for Plaintiff David R Bretz, by : IN THE COURT OF COMMON PLEAS OF Susan Bretz, his attorney in fact, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff _ vs. NO. 09-7658 Civil Term Walter P. Little and Tara L. Little, . his wife; Ray T. Harrigan and Mary D. Harrigan his Wife; Milton Renninger a/k/a Milton Reneker; Lillie Renninger; Jacob R Renninger a/k/a/ J. R Renninger: a/k/a J.R Reneker; Jeremy Miller; . Abraham Miller; a/k/a Abram Miller; . Abram Miller heirs at law; Samuel Miller;: Thachous Miller; Martha Miller; Adeline Miller; Francis Quigg; Sarah Jane Miller;: Jacob Hess; Catherine Miller; William Bady; John Gamber, Attorney-in-fact for Abraham Miller heirs; Frederick May and Magdalona May, his wife;: . John Shoop, Administrator For Estate of Jacob Neidig ;Jacob Neidig; . John Neidig and Mary Neidig, his wife Defendants CIVIL ACTION -LAW ACTION TO QUIET TITLE CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things, pursuant to Rule 4009.22, Plaintiff David R. Bretz certifies that: (1) a notice of intent to serve subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) no objection to the subpoena has been received, and (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date: Henry F. Coyne, squire 3901 Market Street Camp Hill, PA 17011-4227 (717} 737-0464 Pa. S. Ct. No. 06250 Attorney for Plaintiff COYNE & COYNE, P.C. Henry F. Coyne, Esq. Pa. Supreme Ct. No. 06250 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorneys for Plaintiff David R Bretz, by : IN THE COURT OF COMMON PLEAS OF Susan Bretz, his attorney in fact, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. Walter P. Little and Tara L. Little, his wife; Ray T. Harrigan and Mary D. Harrigan his Wife; Milton Benninger alkJa Milton Reneker; Lillie Benninger; : Jacob R Benninger a/k/a/ J. R I2enninger: a/k/a J.R Reneker; Jeremy Miller; Abraham Miller; a/k/a Abram Miller; Abram Miller heirs at law; Samuel Miller;: Thachous Miller; Martha Miller; Adeline Miller; Francis Quigg; Sarah Jane Miller;: Jacob Hess; Catherine Miller; William Bady; John Gamber, Attorney-in-fact for Abraham Mi71er heirs; Frederick May and Magdalona May, his wife;: John Shoop, Administrator For Estate of Jacob Neidig ; Jacob l~eidig; John Neidig and Mary Neidig, his wife Defendants NO. 09-7658 Civil Term CNIL ACTION -LAW ACTION TO QITIET TITLE NOTICE OF INTENT TO SERVE SUBPOENA To: Walter P. Little and Tara. L. Little c/o Linus E. Fenicle, Esquire - Reager & Adler, P.C. 2331 Market Street Camp Hill, PA 17011 Plaintiff David R. Bretz intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena, If no objection is made the subpoena maybe served. Date: ~ .~ Henry ~'. Co ,Esquire 3901 Market Street Camp Hill; PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 06250 Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND David R Bretz, by Susan Bretz, his attorney in fact • P~~' File No. 09'658 VS. Walter P. Little and Tara L. Little, his wife; et al. Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: john B. Owen, Code Enforcement Office for East Pennsboro Twp;, 98 South Enola Drive,Enola, PA 17025 (Name of Person or Entity) Within twenty (2Q?) days after service of this subpoena, you are ordered by the court to produce the following documents or things: A.11 documents concerning and relating to the construction of a residence on the land owned by Walter P. Little and Tara L. Little. All documents concerning the construction of a garage on the land owned by Walter P. Little and Tara L. Little. at Coyne & Coyne, P.C., 3901 Market Street, Camp Hill, PA 17011 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making ties request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Hoary F. Coyne, Esq. ADDRESS: coyme & coke, P.c. 3901 Market Stmt Camp Hill, PA 17011 TELEPHONE: 717-737.0464 SUPREME COURT ID # o6zso ATTORNEY FOR: naha x. area, PlaiatifF BY THE COURT: Date: Seal of the Court Prothonotary, Civil Division Deputy CERTIFICATE OF SERVICE I, Henry F. Coyne, Esq., of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Certificate Prerequisite to Service of Subpoena was served this date upon the below- referenced individuals at the below listed address by way of first class mail, postage pre-paid: Linus E. Fenicle, Esquire Reager & Adler, P.C. 2331 Market Street Camp Hill, PA 17011 Dated: Henry F. Coyne, squire 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 06250 Attorney for Plaintiffs 2 • v DAVID R. BRETZ, by SUSAN BRETZ, his attorney in fact, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLANIA CIVIL ACTION - LAW NO. 09-7658 CIVIL WALTER P. LITTLE and TARA L. LITTLE, his wife; RAY T. HARRIGAN and MARY D. HARRIGAN, his wife; MILTON RENNINGER a/k/a MILTON RENEKER; JEREMY MILLER; ABRAHAM MILLER a/k/a ABRAM MILLER; ABRAM MILLER HEIRS AT LAW; SAMUEL MILLER; THACHOUS MILLER; MARTHA MILLER; ADELINE MILLER; FRANCIS QUIGG; SARAH JANE MILLER; JACOB HESS; CATHERINE MILLER; WILLIAM BADY; JOHN : GAMBER, attorney-in-fact for ABRAHAM MILLER HEIRS; FREDERICK MAY and : MAGDALONA MAY, his wife; JOHN SHOOP, Administrator for Estate of Jacob Neidig; JACOB NEIDIG; JOHN NEIDIG and MARY NEIDIG, his wife, : Defendants : MOTION TO QUIET TITLE r' o. o? w U 6 IN RE: PLAINTIFF'S PETITION FOR PROTECTIVE ORDER ORDER AND NOW, this day of August, 2010, argument on the plaintiff's petition for protective order is set for Friday, September 10, 2010, at 1:30 p.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. Henry F. Coyne, Esquire For the Plaintiff Linus Fenicle, Esquire For Defendants Walter Little and Tara L. Little :rlm l:l3? tgS MatLet, ?llQ?rd BY THE COURT, 'X' . A'd, Kevin A. Hess, P. J. DAVID R. BRETZ, by SUSAN BRETZ, his attorney in fact, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLANIA CIVIL ACTION - LAW NO. 09-7658 CIVIL WALTER P. LITTLE and TARA L. LITTLE, his wife; RAY T. HARRIGAN and MARY D. HARRIGAN, his wife; MILTON RENNINGER a/k/a MILTON RENEKER; JEREMY MILLER; ABRAHAM MILLER a/k/a ABRAM MILLER; ABRAM MILLER HEIRS AT LAW; SAMUEL MILLER; THACHOUS MILLER; MARTHA MILLER; : ADELINE MILLER; FRANCIS QUIGG; SARAH JANE MILLER; JACOB HESS; CATHERINE MILLER; WILLIAM BADY; JOHN : GAMBER, attorney-in-fact for ABRAHAM MILLER HEIRS; FREDERICK MAY and MAGDALONA MAY, his wife; JOHN SHOOP, Administrator for Estate of Jacob Neidig; JACOB NEIDIG; JOHN NEIDIG and MARY NEIDIG, his wife, Defendants : MOTION TO QUIET TITLE IN RE: PLAINTIFF'S PETITION FOR PROTECTIVE ORDER ORDER AND NOW, this aO" day of September, 2010, following argument, the deposition of Mark Romeo, PLS, is STAYED pending agreement by the defendants to pay any fee of Mr. Romeo occasioned by the deposition. ? Henry F. Coyne, Esquire For the Plaintiff ./Linus Fenicle, Esquire For Defendants Walter Little and Tara L. Little Am Q/a ofro BY THE COURT, ?'? '4 1 Kevin A ess, P. J. FILED-OFFICE IN THE COURT OF COMMON PLEAS OF THE PROTHONOTARY COUNTY OF CUMBERLAND, PENNSYLVANIA 2010 DEC 30 AM $: 09 CUMBERLAND COUNTY DAVID R. BRETZ, by PENNSYLVANIA SUSAN BRETZ, his attorney in fact, Plaintiff No. 09-7658 Civil Term WALTER P. LITTLE and TARA L. LITTLE, et al. Defendants PRAECIPE FOR WITHDRAWAL/ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of Linus E. Fenicle on behalf of Defendants Walter P. Little and Tara L. Little. ?' Dated: REAGER & LER, P.C. By. Z(7 LLin-us E. Feni e I.D. No. 20944 2331 Market St. Camp Hill, PA 17011 (717) 763-1383 Please enter the appearance of Helen L. Gemmill on behalf of Defendants Walter P. Little and Tara L. Little. McNEES WALLACE & NURICK LLC Dated: / z.1 t r jr o By l? L. G?n? Helen L. Gemmill I.D. No. 60661 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 237-5273 it CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document was served by first-class mail, postage prepaid, upon the following, upon the date indicated below: Henry F. Coyne, Esq. Coyne & Coyne, P.C. 3901 Market St. Camp Hill, PA 17011 Dated: I.%. I 2!r It v &.?' L. rr4. ?r He en L. Gemmi 1 e r-7 C IN THE COURT OF COMMON PLEAS COUNTY OF CUMBERLAND, PENNSYLVANIA DAVID R. BRETZ, by SUSAN BRETZ, his attorney in fact, Plaintiff WALTER P. LITTLE and TARA L. LITTLE, et al. Defendants No. 09-7658 Civil Term DEFENDANTS' MOTION FOR SUMMARY JUDGMENT n? C-n tea Pursuant to Pa. R. Civ. P. 1035.2(1), Defendants Walter P. Little and Tara L. Little C? r -q c: CD °e (collectively, "the Littles" or "Defendants"), by and through their counsel, McNees Wallace & Nurick LLC, move for the entry of summary judgment in their favor and against Plaintiff David R. Bretz ("Bretz" or "Plaintiff'). In support of their Motion, the Littles state as follows: Procedural History 1. On November 6, 2009, Plaintiff instituted this action by filing a Complaint For Quiet Title ("Complaint"). Complaint. 2. In the Complaint, Plaintiff asserted that he possessed fee simple title to approximately 7 acres of property (the "Property") described as "Mountain Land" located in East Pennsboro Township, Cumberland County, Pennsylvania. Complaint at ¶¶ 26 and 27. 3. The Property claimed by Plaintiff adjoins real estate owned by the Littles where the Littles reside. 4. The Complaint named the Littles as defendants, and also named as defendants numerous deceased individuals. Complaint at ¶T 4-24. 5. On November 25, 2009, the Littles filed their Answer, New Matter and Counterclaim to Complaint For Quiet Title ("Answer, New Matter and Counterclaim"). 6. In the Answer, New Matter and Counterclaim, the Littles denied that Bretz owned the Property and asserted that the Property was owned by the Littles by adverse possession in accordance with the Littles' quit claim deed recorded on August 23, 2007. Answer. New Matter and Counterclaim at ¶¶ 36-38, 40-42, 44. 7. Plaintiff filed Preliminary Objections to Defendants' New Matter on December 18, 2009, and the Littles filed a Reply to Preliminary Objections of Plaintiff on January 6, 2010. 8. Plaintiff then withdrew the Preliminary Objections by Praecipe filed on January 29, 2010. 9. Plaintiff filed an Answer to Defendants' New Matter and Counterclaim on January 29, 2010, thereby closing the pleadings. 10. On March 8, 2010, Plaintiff moved for default judgment against the deceased defendants. 11. By order dated March 12, 2010, the Honorable Judge Hess entered default judgment against the deceased defendants. 12. On September 20, 2010, Judge Hess issued an order in this case in connection with a discovery dispute. 13. No other judges of this Court have had prior involvement with this action. 14. The Littles submit this motion for the entry of summary judgment under Pa. R. Civ. P. 1035.2(1) and assert that there is no genuine issue of any material fact as to a necessary element of the claims in this action which could be established by additional discovery or expert report. 2 15. Accordingly, based upon the undisputed facts, the Littles seeks summary judgment in their favor and against Bretz on all claims in Bretz's Complaint and all claims in the Littles' Counterclaim. Statement of Undisputed Facts 16. The Property claimed by Plaintiff in this case is the southernmost 7-acre op rtion of a 20-acre parcel of mountain land that Frederick May acquired from John Shopp as administrator of the estate of Jacob Neidig. See Deed Book I, Volume TT, page 353, May 1, 1838, entered April 7, 1842, attached hereto as Exhibit A.1 17. The Property is marked by the symbol (D on a surveyor's sketch produced by Plaintiff as an attachment to Plaintiff s Answer To Defendants' Request For Production Of Documents. A copy of Plaintiffs discovery response containing the surveyor's sketch is attached hereto as Exhibit C. 18. There is no known deed, recorded or unrecorded, from Frederick May as grantor showing any conveyance by Frederick May of the Property comprising the southernmost 7-acre portion of the 20-acre mountain land parcel. ' In the Complaint, Plaintiff Bretz mistakenly references as the source of Frederick May's ownership of the 20-acre parcel a deed from John Neidig and Mary Neidig dated March 27, 1838 and recorded in Deed Book 1, Volume TT, Page 351 (Exhibit B hereto). Complaint at ¶ 34. The actual deed into Frederick May for the 20-acre parcel is the deed from John Shopp as administrator of the estate of Jacob Neidig attached hereto as Exhibit A. The mistake in the Complaint is evidenced by the fact that: (a) The deed from John and Mary Neidig (Exhibit B hereto) describes the conveyance of 91 acres of farm land near Fairview bordering the Susquehanna River. The Property at issue here, however, is 20 acres of mountain land, not 91 acres of farm land, and the River is located miles away from the Property; and (b) In ¶ 33 of Plaintiffs Complaint, Plaintiff incorporates by reference a deed from Jacob Renninger and asserts that the Jacob Renninger deed reflects the chain of title for the Property. Complaint at ¶ 33. The Jacob Renninger deed identifies the deed from Shopp on behalf of the estate of Jacob Neidig (Exhibit A hereto) as the source deed. 19. There is, however, a recorded deed from Jacob R. Renninger to Jeremiah Miller that recites the conveyance history of the central and northern portions of the 20-acre mountain land parcel by Frederick May. See Deed Book 3, Volume V, page 191, November 7, 1882, recorded August 21, 1883 (the "Jacob Renninger Deed"), attached hereto as Exhibit D. See also Complaint at ¶ 33 (incorporating the Jacob Renninger Deed into the Complaint by reference). 20. Attached as Exhibit E hereto is a typed version of the description of the two tracts conveyed in the handwritten Jacob Renninger Deed. 21. The northernmost portion of the 20-acre mountain land parcel is described in the Jacob Renninger Deed as a tract of land slightly larger than 10 acres and identified by metes and bounds. The description of this 10-acre tract is shown in blue type on Exhibit E hereto. 22. The Jacob Renninger Deed states that this 10-acre parcel was "RgA of a piece of land" that Frederick May acquired from John Shoop [sic] as administrator for Jacob Neidig and that Frederick May and his wife sold and conveyed to Abram Miller by deed dated March 31, 1848. Exhibits D & E. (Emphasis added). 23. The metes and bounds description of the 10-acre parcel when plotted matches the tract marked on Plaintiffs surveyors sketch as O. See Exhibit C hereto. 24. The central portion of the 20-acre mountain land parcel is described in the Jacob Renninger Deed as a tract slightly larger than 2 acres near or adjacent to the 10-acre tract and identified by metes and bounds. The description of this 2-acre tract is shown in red type on Exhibit E hereto. 25. The Jacob Renninger Deed states that this 2-acre parcel was land that Frederick May and his wife sold and conveyed to Abram Miller by deed dated November 26, 1845. 4 26. The metes and bounds description of the 2-acre parcel when plotted matches the tract marked on Plaintiffs surveyor's sketch as O . 27. Thus, the 20-acre mountain land parcel acquired by Frederick May in the deed attached as Exhibit A is comprised of the three tracts marked 01O and O on the surveyor's sketch in Exhibit C. 28. The Jacob Renninger Deed goes on to state that Abram Miller died intestate and that Jacob Renninger acquired the 10-acre parcel and the 2-acre parcel in an apparently unrecorded deed dated April 7, 1877 from John Gamber as the attorney-in-fact for Abram Miller's heirs. Exhibits D and E. 29. The Jacob Renninger Deed conveys the 10-acre parcel and the 2-acre parcel to Jeremiah Miller. Exhibit D. 30. The 10-acre parcel and the 2-acre parcel thereafter became the lands of Ruth V. Miller, which were subsequently distributed to Dickson R. Miller and Helen K. Weist from the Estate of Ruth V. Miller under a decree entered October 8, 1968 by the Honorable Dale F. Shughart and recorded in Deed Book Y22, Page 799. See Notes on surveyor's sketch in Exhibit C hereto. 31. Significantly, while the Jacob Renninger Deed shows that Frederick May conveyed the northernmost 10-acre tract in 1848 and conveyed the central 2-acre tract in 1845, the Jacob Renninger Deed is completely silent as to any conveyance by Frederick May of the southernmost 7-acre tract. See Exhibit D hereto. 32. In particular, the Jacob Renninger Deed does not contain any language reflecting any conveyance from Frederick May to Abram Miller, or from Frederick May to Jacob 5 Renninger, or from Frederick May to anyone else, of the residual southernmost 7-acre portion of the original 20-acre tract of mountain land. 33. Historical records show that Frederick May died in 1856, six years after the 1848 conveyance of the 10-acre parcel to Abram Miller and nine years after the 1845 conveyance of the 2-acre parcel to Abram Miller. See Excerpt of History of Cumberland County, Pennsylvania, attached hereto as Exhibit F. 34. There is no evidence, either recorded or unrecorded, of any transfer of the Property (the 7-acre tract marked as O on the surveyor's sketch) by Frederick May to Jacob Renninger or to anyone else prior to Frederick May's death over 150 years ago in 1856. 35. The heirs of Frederick May are unknown. 36. In this action, Bretz claims that he acquired title to the Property by a chain of deeds leading back to a 1940 tax sale of lands of Milton Reneker. Complaint at ¶¶ 26-31. 37. Bretz asserts that Milton Reneker is also known as Milton Renninger, and was the sole surviving heir of Jacob Renninger. Complaint at ¶¶ 31-32. 38. Lands of Milton Reneker were seized by the Treasurer of Cumberland County due to unpaid taxes and sold to the Commissioners of Cumberland County by deed dated December 31, 1940 and recorded in Book T, Volume 13, Page 523 (the "Tax Sale Deed"). Complaint at ¶ 31. A copy of the Tax Sale Deed is attached hereto as Exhibit G. 39. The Tax Sale Deed describes the lands seized and sold only as follows: A certain tract of seated land consisting of lot of ground situate in the Township of E. Pennsboro, Cumberland Co., Pennsylvania, purporting to be owned by and assessed in the name of Milton Reneker, described as follows: Lot of ground situate in said E. Pennsboro Twp. 40. There is no metes and bounds description or any other description of the lands sold by the Tax Sale Deed. 6 41. The Tax Sale Deed does not specify the location of the lands sold, other than being in East Pennsboro Township. 42. The Tax Sale Deed does not state that the lands sold were lands that Milton Reneker had inherited from Jacob Renninger. 43. There is no evidence that there were other lands in the vicinity owned by anyone known as Milton Reneker or Milton Renninger. 44. There is no evidence that the lands referenced in the Tax Sale Deed were lands known and indentified in the community as being owned by Milton Reneker or Milton Renninger. 45. Importantly, there is no evidence that the land sold by the Tax Sale Deed was land that was ever owned by Frederick May. 46. None of the deeds in the chain between the Tax Sale Deed and the deed into David Bretz contain a metes and bounds description or identify the land conveyed in any greater detail. 47. The deed from the Cumberland County Commissioners to Ray T. Harrigan dated January 19, 1946 and recorded in Deed Book T, Volume 13, Page 524 (the "Harrigan Deed") describes the land conveyed only as "a tract of land containing lot of ground in East Pennsboro Township, sold as the property of Milton Reneker situate in the Township of East Pennsboro in the County of Cumberland and State of Pennsylvania." A copy of the Harrigan Deed is attached hereto as Exhibit H and the Harrigan Deed is incorporated by reference in Plaintiffs Complaint at ¶ 30. 7 48. The deed from Ray T. Harrigan and Mary D. Harrigan to Fannie S. Bretz dated April 26, 1948 and recorded in Deed Book T, Vol. 13, page 525 (the "Fannie Bretz Deed") describes the land conveyed only as: All that certain lot of ground situate in East Pennsboro Township, Cumberland County, Pennsylvania, known and described as the property of Milton Renecker. And being the same premises conveyed to Ray T. Harrigan, one of the grantors herein, by deed of the Commissioners of Cumberland County, Pennsylvania, dated January 19, 1946, and being the same property sold to said County Commissioners by John H Hobart, Treasurer of Cumberland County, Pennsylvania, on July 29, 1939 and conveyed to them by deed dated December 3Is' 1940. A copy of the Fannie Bretz Deed is attached hereto as Exhibit I and the Fannie Bretz Deed is referenced in Plaintiff s Complaint at ¶ 29. 49. The deed from Fanny Bretz dated May 5, 1959 and recorded in Deed Book D, Volume 19, Page 101 (the "David Bretz Deed") describes the lands conveyed as: Tract No. 2. Being all that certain tract of Mountain Land situate in East Pennsboro Township which Ray T. Harrigan and Mary D. Harrigan, his wife, by their deed dated April 25, 1948, granted and conveyed unto Fannie S. Bretz, Grantor herein; said Deed being recorded in the Office for the Recording of Deeds aforesaid in Deed Book "T", Volume 13, page 525. A copy of the David Bretz Deed is attached hereto as Exhibit J and is incorporated by reference in Plaintiffs Complaint at ¶ 26. 50. On August 23, 2007, the Littles recorded a quit claim deed to the Property, claiming the Property by adverse possession. A copy of the Littles' August 23, 2007 deed is attached hereto as Exhibit K. 51. The Littles reside on other property that they own that adjoins the Property. The Littles residential property is marked as O on the Plaintiffs surveyor sketch. Exhibit C hereto. 8 Grounds For Motion for Summary Judgment A. There Is No Chain Of Title That Establishes That Bretz Owns The Property 52. Plaintiffs entire claim to the Property at issue in this case is based upon Plaintiffs belief that the land conveyed to Bretz in the David Bretz Deed is the same land as the Property. 53. None of the deeds referenced and incorporated in Plaintiffs Complaint provide any evidence that the land conveyed in the David Bretz Deed is the Property that adjoins the Littles' residential property. 54. Plaintiffs claim to the Property fails because it rests upon the following legally insufficient, speculative assumptions, which are not supported by any evidence. Bretz improperly assumes that: a. Because Frederick May conveyed by deed part of his land to Abram Miller in 1845 and conveyed by deed another part of his land to Abram Miller in 1848, Frederick May also must have conveyed the remaining part of his land (the Property) to Abram Miller before Frederick May's death in 1856; and b. Because Jacob Renninger acquired the tracts conveyed in 1845 and 1848 from the heirs of Abram Miller, Jacob Renninger also must have acquired the remaining land (the Property) that Plaintiff speculatively assumes Abram Miller acquired from Frederick May; and Jacob Renninger died still possessed of the Property that Plaintiff assumes Jacob Renninger acquired, even though prior to his death Jacob Renninger disposed of the other two tracts that he is known to have acquired; and d. The person identified in the Tax Sale Deed as Milton Reneker was the son of Jacob Renninger; and The undescribed and unidentified land seized at the Tax Sale was the Property. 55. Plaintiff s speculative assumptions set forth in the preceding paragraph are insufficient for Plaintiff to meet his burden of proving that he owns the Property at issue in this case. 9 56. There is no evidence that Frederick May, or his unknown heirs, ever conveyed title to the 7-acre Property to anyone, let alone any evidence of the three necessary conveyances - (1) Frederick May to Abram Miller; (2) Abram Miller heirs to Jacob Renninger; and (3) Jacob Renninger to Milton Reneker - that would have to be proven by competent evidence in order to show that Frederick May's remaining land ended up in the hands of Milton Reneker. 57. Even if these three necessary conveyances of the Property were made (conveyances that are not described in Plaintiffs Complaint, not reflected in the deeds referenced in Bretz's Complaint, and not reflected in any other known deeds), under the Statute of Frauds the absence of any writing signed by the grantor and containing an adequate description of the property and a recital of the consideration would bar Bretz from enforcing such conveyances that would have to be assumed for Plaintiff to possess title. 58. Because Plaintiff cannot meet his burden of proving that he possesses title to the Property under any chain of title, the Littles are entitled to judgment as a matter of law on all claims in this action. 59. Because Plaintiff lacks any interest in the Property, Plaintiff cannot challenge the Littles' claim to the Property by adverse possession. B. The Tax Sale Deed Through Which Bretz Claims Title Is Void 60. Moreover, even if somehow Milton Reneker did own the Property, the Tax Sale Deed through which Bretz claims title (Exhibit G hereto) is void as a matter of law. 61. The Supreme Court of Pennsylvania has consistently held that "no tax sale of land is valid unless both the assessment and the conveyance by the treasurer contain sufficient descriptions to identify and disclose the property taxed and sold." Hunter v. McKlveen, 65 A.2d 366, 367 (Pa. 1949) citing Fisk v. Corey, 21 A. 594 (Pa. 1891). 10 62. In Hunter v. McKlveen, the descriptions in the tax deeds referred to the property solely by the name of the township (and sometimes included the amount of acreage), but contained nothing further to identify the land. 65 A.2d at 368 (deed descriptions were such as "420 acres in Cook Township" and "a tract containing timber in Donegal Township"). The Supreme Court held that "[s]uch deeds describe nothing and convey nothing" and thus the "attempted tax sale was of no effect" as the "deeds which the county commissioners received were worthless and could not serve to divest the [owner's] title." Id. 63. Similarly here, the Tax Sale Deed lacks the necessary description to identify the land being conveyed, and therefore is void. 64. Because the Tax Sale Deed is void, Plaintiff cannot meet his burden of proving that he acquired and possesses title to the Property, and the Littles are entitled to judgment as a matter of law. 65. Because Plaintiff lacks any interest in the Property, Plaintiff cannot challenge the Littles' claim to the Property by adverse possession. WHEREFORE, Defendants Walter P. Little and Tara L. Little request that summary judgment be entered in their favor and against Plaintiff David R. Bretz on all claims in this action. McNEES WALLACE & NURICK LLC By ne elel L. Gemmill (PA 60661) 100 Pine Street, P.O. Box 1166 Harrisburg, PA 17108-1166 Tel. (717) 237-5273 Fax. (717) 260-1697 Dated: November 14, 2011 Attorneys for Defendants Walter P. Little and Tara L. Little 11 CERTIFICATE OF SERVICE I hereby certify that I have this date served a copy of the foregoing document upon the following, by hand delivery: Henry F. Coyne Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011-4227 Helen L. Gemmill Dates: November 14, 2011 ?x ti'1 +?dG•r4 i,- / // 7-FL?C' rri fc%G•P,G7l..side rlr7 07! /.70` !?' r F / i u+r?r?c?<rzY s?`?5lrar .yl E - -------------- f t I z r? ?r.r rr ??rr C., 'f, pL orr /? .7 c<ir sra,,,, c n? 7//,7 7-11i r?r < ?aar 4 771 , ra,?r<..C?tl>>n???f'-rrir ?.ie4, G.C-//r R/r C</"D7"S!/[CC rCl'Cnli//(j /r r/r1 G71? 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Bretz, by Susan Bretz, his attorney in fact, Plaintiff VS. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-7658 Civil Term Walter P. Little and Tara L. Little, his wife; Ray T. Harrigan and Mary D. Harrigan his Wife; Milton Renninger a/k/a Milton Reneker; Lillie Renninger; Jacob R. Renninger a/k/a/ J. R. Renninger: a/k/a J.R. Reneker; Jeremy Miller; Abraham Miller; a/k/a Abram Miller; Abram Miller heirs at law; Samuel Miller;: Thachous Miller; Martha Miller; Adeline : Miller; Francis Quigg; Sarah Jane Miller;: Jacob Hess; Catherine Miller; William Bady; John Gamber, Attorney-in-fact for : Abraham Miller heirs; Frederick May CIVIL ACTION - LAW and Magdalona May, his wife; ACTION TO QUIET TITLE John Shoop, Administrator For Estate of Jacob Neidig ; Jacob Neidig; John Neidig and Mary Neidig, his wife Defendants PLAINTIFF'S ANSWERS TO DEFENDANTS' REQUEST FOR PRODUCTION OF DOCUMENTS TO: Linus E. Fenicle, Esquire Reager & Adler, PC 2331 Market Street Camp Hill, PA 17011-4642 Attorney for Defendant 1 Attached hereto is a copy of a survey conducted by Mark Romeo, P.L.S. 2. At the present time, Plaintiff has not compiled a list of documents that may be presented or introduced into evidence at trial. Plaintiff reserves the right to supplement and/or clarify the Documents provided to this set of Responses to Defendant's Request for Production of Documents. Respectfully submitted: COYNE & COYNE, P.C. By: XHe Dated: 12 F. Co e, Esquire Pa. Supreme Ct. No. 06250 3901 Market Street Camp Hill, PA 17011 (717) 737-0464 Attorneys for Plaintiff N O O y N 3 U Z O ? II Z '?' 3 m n N m UI H \ O O r N m O >w? 9 y 770 zl ,, 0 N ? l M?f 4D5` 0 y6 tea. ? ° 0 Mid ??N sYr? \ Ys? A?° ?Q66tsa ?N 3'. 0 ml= A^ v'q,,?IJU R M CC) o io io?3 i3?ifinyi °'lo In 3 t ?pgo pl I?NIg 13 I I I;.B ° ° I ?1 1 I J j I; N b D l .l° 1? ? n l? g l& I I O .?tii 0 ^? Q I e l n' 1? I a 4 I l I 1? 1 ?, ? j IH I to?I?? I wyl3 I l I;. ..? I I I I ° 1 >' I 1 V O~N b l b l ,° I ?. Q I I b I 1 ?? ti bl?l I I IE Ia4a1<N `I?-I 1 I I-? I q l I I I I I C I I IS N°. ? ? i i REVISION DATE a EMIBR?SKETCH MARK G. ROMEO, P.L. S. ; i LANDS OF DAVID R. BRETZ awvNa .. sw c . c ` " a s I?.*m a Imu wr rods mnmv, culseuw muwrr, rd <*+1 w-.w o 0 0 0 0 0 0 0 0 0 R R R R R \I N °"? w til N °'' Olpfr& ??m ;aC o C & bh ?g ?? a p PN ° .6}??,?8] 8` ° 0 o pop ? M I??A=J c B b QOM I'}??] ° o a °s?'v lo??o'nl ? pC ey?pc ?h T?o °u b?00M ?.i ??a te u° b °R ¢ lo? ?n a`I c. ap'b Op J$i Ik!ut?? R ? Agi o f a^I pg Jyl .`.T?? R g y I ey!?? wE• AA E n e 8a e?l ? rev rE ? ?an ie? 3 ?i t w E s?? 8?? ? le??s? wE <? E n stn 8a? GG 3 -•e0 i~E c .,E n n 8a?' m-. ° e. m E i wE o o4Rxg ' je.??y 0. a <? e, i E ?a ? le???t E ?eE ?2 ? QI IL < '? ° I wE ?cv° 1 aR x• ° el b't ? R ?, I u<v° , _. E ? ° ] e ? Q a ?S? r£? 3 V p a "y ?\ p bs o^ i ?d aHy??? $\.a ,? gg b °ti V ,° ] ab °3 \• ?? ? a 3 V ,m;° atw? 3 i• ?t° ? ° > V n\? at+:?? $\a3`$ U i V N` lab. $\' 3 l I w o?4S? ?.,i a n3 b I w?? p.?2? o? ti\' q a CII ?4?? Ipa'b ??, \"1.,3 18 ,°p# I y . i ;'AN`C ? a 3' I a ?$ `< ti t bet t e n t v e et < be3 t Al No ° ? t ?' n ? ?41 o g ,o ? ' ` ? EbI N I Ebl M ?I VERIFICATION I, Susan Bretz certify that the statements made in the foregoing document are true and correct to the best of my knowledge, information, and belief and that this verification is subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. Date l a 3 Susan Bretz, Attorney-in- act for David R. Bretz 8 CERTIFICATE OF SERVICE I, Henry F. Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Answer to Defendants' Request for Production of Documents was served this date upon the below-referenced individuals at the below listed address by way of first class mail, postage pre-paid: Linus E. Fenicle, Esquire Reager & Adler, PC 2331 Market Street Camp Hill, PA 17011-4642 Dated: 2_3 (OAR f 0--' Henry F. Coyne 3 ??;6;+ D 3J\ql prC7lr G/G ?airrc jh'MluOra ? /Ln•:? .?Qlr!/. ,CG/%LO- l?rc4 .CPFIii(r. (Crrerur•(!. Urr<d/relic .? a7ulr.7l//rc /irri rrrL r!a(? /t/zt; lreY,7;?/_ FL .a /lltlrr r? //jRrG 1. !l. ?. /I rr ljcrrrrA. to rr/. ri%/tG ?rrar</rL•!! l>rLIL<9/r/? l.7cG• rcr/? C!7zJCllyq/rCSe//%>croo .p7n <r'c r!d ?ll. l?! TY?. nI- F?zrFL [<7?rnru l /? dvrlr. f r. fdel?e ? (l?u>rrrl(/?? /zc hizlo/ lic6 /rrcce aarre aoscq>rd, /? rrcetrr ; e c?c Flnrd lr/ f?a dlecrG v7? iurl. /CaGrl. ?izdon/ve'e, rcr? r! oar, //u / ? j? O / ?iau ?a-lrerar!/re,g L?r!/rrr/s rrf lre ire, !iz avr!/? 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' t/ra!/ CO. ?ld/«<l<L F ?f ?% ?./sr ?ilrEi .lip <i /,? ??Gly_.%r/uyiC tY<rJr ? ?? yc / > < / ? ?l ?<rEr.C<ars cl<r ifrzr,,z»rr/. ----- Alvf«<vr!/7e/G. __ r?n?/ ? cr<d ..?? earcY reo?! _!fr- v' d? l vi,-rrfir_, +S ,- ri ?.r/-<r>r r .»o /s /E r>?isJ Al r/? ? ? >i /rrr-«yf?r /N/i r1r<r>rrrdl rrrr !' ? PX. eL'r/Lfsm>r<rC? ? i? ?«. G/<nc/ %?Cr/r?r•<G? flee<mC ??r<vE .<2 /d63. '" s e , OO >rn' f ?irrfl qrT r r! COdC n?/.nrssfr< > 9 .41 -- -?` -_-_---- OCri/Ofa/ a?<'>-rva ?; <?•i?se r?vr? O i Jo<rYy? // ?<i?f/?tiC /:<yn>uYC z! »?.//nm(ir:?/? Jiiv?rrr? ' ?f Jacob R. Renninger to Jeremiah Miller Deed Book 3, Volume V, Page 191, November 7, 1882 (recorded August 21, 1883) Typed description of land conveyed in deed All that messime or tract of land Situate or lying at the Mountain in East Pennsboro Township, Cumberland County and State of Pennsylvania, adjoining lands formerly owned by Fredk. May, Jacob Neidig, Samuel Mumma deceased, bounded and described as follows, to wit: -- Beginning at a corner of said May's land; thence by land of George Bowers North 29 degrees, West fifty-seven (57) perches and six tenths: thence eighty-five and one half (85 %2) degrees, East three perches to a black oak: thence North seventy two and one half (72 %2) degrees, East thirty-one (31) perches to a hickory grub, thence by land of Jacob Neidig heirs (or formerly so) South twenty-nine (29) degrees, East forty-six and five tenths (46 5110) to a stake; thence by land of said May's, South sixty (60) degrees, West thirty (34) perches to the place of beginning. Containing Ten (10) acres & one hundred and sixteen (116) perches strict measure. It being part of a piece of land which John Shoop, administrator of Jacob Neidig deceased, sold and conveyed by Order of Orphans Court to Frederick May (now deceased) and Frederick May & Wife by deed dated March 31" A.D. 1848 sold and conveyed the same to Abram Miller. There is included also in the within sale and conveyance tract No. 2, as follows. Situate in Township, County and State aforesaid, lying near or adjacent to aforesaid described tract, joining lands of Geo. Boyer and Fred. Mays (former owners) bounded and described as follows: Beginning at a stake: thence by land formerly of said May five (5) degrees, West twenty-six (26) perches to a white oak stump: thence by land formerly Geo. Boyer South twenty-nine and three quarters (29 %) degrees, East sixteen (16) perches to a stake: thence by land of said May's North (60) sixty degrees, East twenty-three per- ches to a hickory tree: thence North nineteen and one-half (19 '/2) degrees West twenty and one-tenth (20.1) perches to the place of beginning. Containing (2) Two acres and one hundred and sixteen 016) perches strict measure. It being the same tract of land that Frederick May and Magdalene his wife by their deed of Indenture dated November 26`h A.D. 1845 sold and conveyed to Abram Miller, and the said Abram Miller, being thereof seized died intestate and left as his heirs at law Abram Miller, Jr. Samuel Miller, Jeremiah Miller, Zacheus Miller, Martha E. Miller, Adeline Miller, intermarried with Francis Quigg, Sarah Jane Miller, inter- married to Jacob Hess, and Catherine Miller, intermarried with William Baily, and the above-mentioned heirs by an instrument of writing did make John Gamber their attorney in fact for Abraham Millers heirs, did by his deed dated April 71h A.D. 1877, sale and convey the same to Jacob R. Renninger, party hereto, by reference being had to the different recited Indentures will more fully and at large appear. E?J BIO: Daniel G. May, Cumberland County, PA Contributed for use in the USGenWeb Archives by Judy Bookwalter Copyright 2010. All rights reserved. http://www.usgwarchives.net/copyright.htm http://www.usgwarchives.net/pa/cumberland/ History of Cumberland and Adams Counties, Pennsylvania. Containing History of the Counties, Their Townships, Towns, Villages, Schools, Churches, Industries, Etc.; Portraits of Early Settlers and Prominent Men; Biographies; History of Pennsylvania; Statistical and Miscellaneous Matter, Etc., Etc. Illustrated. Chicago: Warner, Beers & Co., 1886. http://www.usgwarchives.net/pa/cumberland/beers/beers.htm PART II. HISTORY OF CUMBERLAND COUNTY. PENNSYLVANIA. CHAPTER XLV. EAST PENNSBOROUGH TOWNSHIP AND BOROUGH OF CAMP HILL. 471 EAST PENNSBOROUGH TOWNSHIP. DANIEL G. MAY, contractor, West Fairview, is a grandson of Joseph Gingrich, who lived near Middletown, Dauphin Co., Penn., in the latter part of the eighteenth century, and later removed to near Mifflin, in Juniata County, Penn. Joseph Gingrich was twice married, having four children by his first wife and six by his second. One of the first wife's daughters, Magdalena, married, in 1820, Frederick May, of Middletown, Dauphin Co. Penn., a farmer, born in that county. They had nine children: Joseph, Daniel G., Catharine, Elizabeth, John, Jacob, Frederick, David and Barbara. They removed to Lancaster County, and later to West Fairview, this county, where Mr. May built the house in which our subject now lives, buying a farm of nearly one hundred acres, a large part of which is now occupied as town lots. Besides farming he engaged in cabinet-making, following these occupations until his death in 1856. His widow died in 1870, aged seventy-three years. At this time but four of their children were living: Joseph, in Philadelphia, Penn; Catharine, wife of Samuel Butner, of East Pennsborough Township, this county; Jacob, in West Fairview, and Daniel G. The latter was born, February 2, 1825, in Lancaster County, Penn. John Frederick, Barbara and Elizabeth are' dead. Another son, David, was captain of Company K, Seventh Pennsylvania Cavalry, and was killed while leading a charge at the battle of Chickamauga, in October, 1863. His men were greatly attached to him, and, making three successive charges, recovered his body, which is interred in the National Cemetery, at Chattanooga. Daniel G. worked for his father until he was twenty-one, when he married Mary, daughter of John Rupley, of East Pennsborough Township, this county. To this union five children were born: Luther, accidentally killed in his twelfth year; Joseph, Harry, Susan and Rebecca, who died in infancy. In 1858 Mr. May married Eshelman, by whom he has two daughters, Ellen E. and Fanny, living in Fairview, Penn. After his first marriage he moved to a farm owned by his wife, but in 1863 came back to the homestead, which he took at the appraisement, and has lived there since. At various times he was engaged in brick-making, lumber-dealing, and in grocery business, but subsequently adopted carpentering, which he now follows exclusively. He is a self-made man. Without the advantages of school education he has raised himself to an honorable position, and is high-minded and honorable - a man who was ?x?>d,+? ' IN WITNESS.WHEREOF, I HEREUNTO.-SET MY HAND AND,OFFlICIAL SEAL. •: LOI S D HELSEL NOTARY PUBLIC i MY .COMMISSION EXPIRES END OF j , SESSION' OF SENAT I DO HEREBY CERTIFY THAT THE PRECISE RESIDENCE Of THE WITHIN N DEE S CARLISLE, STAR ROUTE, PA. ROBERT LEE JACOBS ATTORNEY FOR GRANTEES --------------------------------------------- -- ---------------------------------- ------- No 16466 4 , DEED JOHN H HOBART TREASURER 4 KNOW-'iALL MEW'BY' THESE PRESENTS,, TO 6 THAT WHEFE AS, BY THE RETURNS MADE TO THE BOARD OF i COMMISSIONERS OF CUMB. CO. 6 COMMISSIONERS OF CUMBERLAND COUNTY, A CERTAIN TRACT OF CONS. $37.12 SEATED LAND CONSISTING OF LOT-OF GROUND SITUATE IN THE LOC. E. PENNSBORO TWP. TOWNSHIP OF E. PENNSBORO, CUMBERLAND CO., PENNSYLVANIA, DATED DECEMBER 31, 1940 PURPORTING TO BE OWNED BY AND ASSESSED IN THE NAME OF ENT. APRIL 27, 1946 MIL TON: RENEKERmDESCRIBED AS FOLLOWS; LOT OF GRJIIND -------------------------------- ---- SITUATE IN SAID E. PENNSBORO TWP., WAS RETURNED BY THE COLLECTOR OF SAID, E.. PENNSBORO. TWP...,. THE OWNER OK OWNERS THEREOF-HAVING NEGLECTED OR REFUSED TO PAY THE TAXES HEREINAFTER. SPECIFIED; WHICH SAID PROPERTY WAS RATED, CHARGED AND ASSESSED, ACCOr ING TO THE LAWS OF THIS COMMONWEALTH, WITK. THE PAYMENT OF TAXES FORTHE YEARS ONE THOUSAND NINE HUNDRED TWENTY FIVE TO 1934 INCL., AND AMOUNTING IN THE WHOLE TO THE--SUM OF THIRTY SEVEN DOLLAR AND TWELVE CENTS FOR ALL TAXES AND INTEREST LEGALLY DUE, AND UNPAID FOR THE YEARS ABOVE MENT;ONE AND WHEREAS, IN PURSUANCE OF THE SEVERAL ACTS OF ASSEMBLY IN SUCH CASE MADE AND PROVIDED, HAVING GIVEN DUE PUBLIC NOTICE OF THE PURPOSE, TIME, PLACE AND TERMS OF SUCH SALE, AND THE AMU OF TAXES AND INTEREST DUE ON SAID TRACT OF LAID, BY PUBLISHING THL SANE IN AT LEASTTWO NEWSPAPE OF GENERAL CIRCULATION IN THE SAID COUNTY OF.,CUMBERLAND, ONCE A WEEK FOR THREE SUCCESSIVE WEEKS PRIOR TO THE HOLDING OF SUCH SALE, AND ALSO BY NOTICE SERVED UPON THE OWNERS OR TERRE TENANTS C SAID LAND , AS PROVIDED BY LAW, AND NO PERSON HAVING PAID THE TAXES, CHARGED AND ASSESSED UPON THE SAID TRACT OF LAND, AND THE INTERESTS AND COSTS ACCRUtD THERE6N, I, THE SAID TREASURER, CON MENCED THE SALE OF SAID TRACT OF LAND AMONG OTHERS, ON THE 29TH DAY OF JULY LAST PAST, AT THE COURT HOUSE IN THE BOR ,UGH OFD CARLISLE, IN THE COUNTY OF CUMBERLAND, BY PUBLIC VENDUE AND OUT- CRY AND ON THE 29TH DAY OF JULY LAST PAST SOLD THE SAID TRACT OF LAND TO THE COMMISSIONERS OF CUMBERLAND COUNTY FOR THE PRICE OR SUM OF THIRTY SEVEN AND 12 100 DOLLARS, NO PERSON HAVING BID AN AMOUNT SUFFICIENT TO PAY TAXES, INTERESTS AND COSTS, AND IT THEREUPON BECAME THE DUTY 01 SAID, COUNTY COMMISSIONERS TO BUY THE SANE. NOW THIS INDENTURE WITNESSETH, THAT 1, JOHN H HOBART,.TREASURER OF SAID COUNTY, FOR AND Il? CONSIDERATION OF THE SAID SUM, DO GRANT, BARGAIN AND SELL THE SAID TRACT OF LAND TO EARL L. BRENNEMAN, RAYMOND W. LEMASTER AND JAMES C.•LINDSEY, COMMISSIONERS OF SAID COUNTY, TO HOLD TO THEM AND THEIR SUCCESSORS IN OFFICE FOREVER, SUBJECT TO THE REDEMPTION ALLOWED BY LAW. IN WITNESS WHEREOF, I THE SAID JOHN .H HOBART, TREASURER, HAVE HEREUNTO SET MY HAND AND SEAL, THE 31ST.DAY OF DECEMBER, IN THE YEAR OF OUR LORD ONE THOUSAND NINE HUNDRED FORTY. SIGNED, SEALED AND DELIVERED JOMNIH HOBART (SEAL) IN THE PRESENCE OF TREASURER OF CUMBERLAND COUNTY. ' COMMONWEALTH OF PENNSYLVANIA') r.Sa?L COUNTY, ON THE DAY OF. DECEMBER 'IN'THE YEAR OF'OUR LORD'ONE jFOUSAND NINE HUNDRtD FORTY BEFORE THE PRESIDENT JUDGE OF THE SAID COURT, JOHN H. HOBART TREASURER OF CUMBERLAND COUNTY, APPEARtD IN HIS PROPER PERSON IN OPEN COURT, AND ACKNOWLEDGED THE FOREGOING DEED TO BE HIS ACT AND DEED, PURSUANT TO THE SEVERAL ACTS OF ASSEMBLY IN'SUCH CASE MADE AND PROVIDED. IN WITNESS WHEREOF, I WATSON R. DAVISON, 39TH JUD. 01ST. SPECIALLY PRESIDING. PRESIDENT JUDC,E OF THE SAID COURT OF COMMON PLEAS, HAVE HEREUNTO SET MY HAND AND SEAL-THE DAY AND Y E;AR AFORESAID. WATSON R DAVISON (SEAL) PRESIDENT JUDGE IN TESTIMONY WHEREOF, I HAVE HEREUNTO SET MY HAND AND AFFIXED THE SEAL OF SAID ........ _..--- COURT, THE DAY AND YEAR AFORESAID. GEORGE W KUNK&; PROTHOr OTfAFY REC_RDED IN TREASURER'S DEED BOOK NO 3, PAGE 248. I DO HEREBY CERTIFY THAT THE PRECISE RESIDENCE OF THE WITHIN NAKED GRANTEE IS COURT (OUSE, CARLISLE, PA. APRIL 27, 1946 RAY T, HARRIGAN ATTORNEY FOR GRANIE E .• ---------------------------------- ------------- No 16467 DEED POLL EARL L BRENNEMAN,ET AL 4 COUNTY COMMISSIONERS 4 WHEREAS, A TRACT OFLAND CONTAINING LOT OF GROUND IN TO ¢ EAST PENNSBORO TOWNSHIP, SOLD AS THE PROPERTY OF MILTON RAY T HARRIGANy RENEKER SITUATE IN THE TOWNSHIP OF EAST PENNSBORO IN THE CONS. '3.00 Q COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, WAS RATED LOC. EAST PENNSBORO T4tP. 4 AND-ASSESSED WITH DIVERS TAXES WHICH. REMAINED UNPAID, AND DATED JANUARY 19, 1946 THE TREASURER OF U AID COUNTY HAVING GIVEN DUE AND PUBLIC ENT. APRIL 27, 1948 NOTICE OF THE TIME AND PLACE OF SALE, DID ON THE 29TH DAY -------------- -JULY 1940, EXPOSE THE SANE TO SALE BY PUBLIC VENDUE OK OUTCRY, AND NO PERSON BIDDING THEREFOR A SUM EQUAL TO THE AMOUNT OF TAXES DUE AND THE COST OF ADVERTISING AND SALE, IT THEREFORE BECAME THE DUTY OF THE COMMISSIONERS OF THE COUNTY OF CUMBERLAND TO BUY THE SAME, WHICH THEY ACCORDINGLY DID; AND WHEREAS , THE TREASURER OF SAID COUNTY, IN PURSUANCE THEREOF, BY DEED BEARING DATE THE 31ST DAY OF DECEMBER, 1940, DULY 'ACKNOWLEDGED, DID GRANT AND CONVEY THE SAID DESCRIBED TRACT OF LAND TO THE COMMISSIONERS OF THE COUNTY OF CUMBERLAND, AND THEIR SUCCESSORS IN OFFICE AND WHEREAS, THE SAID DESCRIBED TRACT OF LAND NOT HAVING BEEN REDEEMED IN DUE TIME BY THE ORIGINAL OWNERS, THE COMMISSIONERS OF THE COUNTY OF CUMBERLAND, IN PURSUANCE OF THE VARIOL ACTS OF ASSEMBLY IN SUCH CASE MADE AND' PROVIDED, DID, AFTER GIVING DUE AND LEGAL NOTICE OF THE TIME AND PLACE OF SALE, EXPOSE THE SAID DESCRIBED TRACT OF LAND TO PUBLIC SALE ON THE 28TH DAY OF DECEMBER, 1945, AND SOLD THE SANE TO RAY T. HARRIGAN, IuECHANICSBURG, R. D. 2, MONPOE TOWNSHIP, CUMBERLAND COUNTY PENNSYLVANIA, FOR THE SUM OF FIFTY THREE ($53.00) DOLLARS, HE BEING THE HIGHEST AND BEST BIDDER AND THAT THE HIGHEST AND BEST PRICE BIDDEN FOR THE SOME. NOW KNOW YE, THAT WE, EARL L. BR:NNEMAN, R. W . LEMASTER AND J. C. LINDSEY COMMISSIONERSi OF THE COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BY VIRTUE OF THE POWER AND AUTHORITY VESTED IN US AS AFORESAID, FOR AND IN CONSIDERATION OF THE SUM OF FIFTY THREE ($53.00) DOLLAR: LAWFUL MONEY OF THE UNITED STATES OF AMERICA, TO US IN HAND PAID, AT AND BEFORE THE ENSEALING AND DELIVERY HEREOF, THE RECEIPT WHEREOF IS HEREBY ACKNOWLEDGED, HAVE GRANTED, BARGAINED AND I tI SOLD ONTO THE SAID RAY T. HARRIGAN, MECHANICSBURG, R. D.# 2 MONROE TOWNSHIP,. CUMBERLAND COUNTY, PENNSYLVANIA, HIS HEIRS AND ASSIGNS, ALL THE RIGHT, TITLE ANDINTEREST OF THE SAID COUNTY OF CUMBERLAND, OF, IN AND TO THE HEREINBEFORE MENTIONED AND DESCRIBED TRACT OF LAND KNOWN AS LOT OF GROUND IN EAST PENNSBORO TOWNSHIP, SOLD AS THE PROPERTY OF MILTON RENEKER TOGETHER WITH ALL THE PRIVILEGES AND APPURTENANCES THEREUNTO BELONGING, OR.IN AM'PIISE AiPERTAINING.. TO HAVE AND TO HOLD THE SAID DESCRIBED TRACT OF LAND, TOGETHER WITH ALL THE PRIVILEGES AND APPURTENANCES THEREUNTO BELONGING, OR IN ANYWISE APPERTAINING, UNTO THE SAID RAY T. HARRIGAN, MECHANICSBURG, R. D- # 2, MONROE TOWNSHIP, CUMBERLAND COUNTY, PA. HIS HEIRS AND ASSIGNS, TO THE ONLY PROPER USE AND BEHQQF OF THE SAID RAY T. HARRIGAN,,MECHANICSBURG, R. D. # 2, MONP.OE-iTWP,. CLIMB. CO., PA. HIS HEIRS AND ASSIGNS FOREVER. IN WITNESS WHEREOF, WE HAVE HEREUNTO SET OUR HANDS AND.THE SEAL OF'THE SAID COUNTY OF CUMBERLAND, THIS :19TH DAY OF JANUARY 1946. EARL 'L BRENNEMAN R. W. LEMASTER J C LINDSEY COUNTY COMMISSIONERS RECEIVtD ON THE DAY OF THE DATE OF THE FOREGOING DEED POLL, THE FULL CONSIDERATION MONEY THEREIN MENTIONED. J. W. DOUGHE HTY TREASURER'OF CUMBERLAND COUNTY. COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND )SS BEFORE ME, THE SUBSCRIBER, A DEPUTY RECORDER OF DEEDS PERSONALLY CPME EARL L. BRENNEMAI4, R. W. LEMASTER, AND J. C. LINDSEY COMMISSIONERS OF THE COUNTY OF CUMBERLAND,.,AND DULY ACKNOWLEDGED THE FOREGOING TO BE THEIR ACT AND DEED FOR THE PURPOSES THEREIN MENTIONEQ, AND DESIRJ) THAT THE S MIE MIGHT BE RECORDED AS SUCH ACCORDING TO LAW. WITNESS MM HAND AND SEAL, THIS 21ST DAY OF JANUARY A. D.• 1946 CHESTER,A BRENNEMAN. DEPUTY RECORDER OF DEEDl , CUMBERLD COUNTY, PA. MY COMM I,SS I ON E XP.I RES T >ki0 ND AY OF JAN. 1950 DO HEREBY CERTIFY THAT THE PRECISE RESIDENCE OF THE WITHIN N GRANTEE IS MECHANICSBURG, PA. R. D. 2 - .__.ARR1L.-27.,. 1948.. I RAY T. HARRIGAN. ATTORNEY FOR GRANTEE -----------------------------4------------------- ----------------------------------- --------- NO. 16469 DEED: 4 THIS DEED, RAY T,HARRIGAN ET UX 6 TO 4 MADE THIS 26TH DAY OF APRIL IN THE YEAR;NINETEEN HUNDRED AND FANNIE' S BRETZ FORTY EIGHT. 4 BETWEEN RAY T. HARRIGAN AND MARY D. HARRIGAN' ri IS- Wi FE 0 'OF CONS. X1.00 LOC. EAST PENNSBORO TWP. 4 MECHANICSBURG, R. D. 2, PENNSYLVANIA( HEREIN AFTq CALLED THE •, DATED APRIL 26, 1945 GRANTORS) 4 AN D ENT. APRIL 27, 1948 ( PENNSYLVANIA, HEREIN- -----------------------------? FANNIE S. BRETZ,OF MECHANICSBURG; R- D.:4, AFTER`CALLED THE GRANTEE) WITNESSETH,?THAT IN CONSIDERATION OF ONE DOLLAR (31.00)1 IN HAND PAID, THE RECEIPT AMEREOF IS 11--v ArvunwlGnr.Fn_ THE SAID GRANTORS DO HEREBY GRANT-AND CONVEY TO THE SAID:GRANTEE, HER HEIRS ?x?b?f • 13T 5a L4 COUNTY, ON THE DAY OF. DECEMBER IN THE YEAR OF OUR LORD ONE T40USAND NINE HUNDRtO FORTY BEFORE THE PRESIDE JUDGE OF THE SAID COURT, JOHN H. HOB ART TREASURER OF CUMBERLAND COUNTY, APPEARrD IN HIS PROP PERSON IN OPEN COURT, AND ACKNOWLEDGED THE FOREGOING DEED TO B`_ HIS ACT AND DEED, PURSUANT TO TH SSEVERAL ACTS OF ASSEMBLY IN SUCH CASE MADE AND PROVIDED, IN WITNESS WHEREOF, I W TSON R. DAVISON, 39TH JUD, DIST SPECIALLY PRESIDING PRESIDENT JUOCE OF THE SAID COUhcT OF CO ON PLEAS, HAVE HEREUNTO S MY HAND AND SEAL THE DAY AND YEAR AFORESAID. WATSON ?XAVISON (SEAL) PRESIDENT JUDGE IN TESTIMONY WHEREOF, I HAVE HEREUN \KNK XED THE SEAL OF SAID COURT, THE DAY AND YEAR AFORESAID . t Y REC-RDED IN TREASURER' DEED BOOK NO 3I DO HEREBY CER?FY THAT THE PRECISE RENAMED GRANTEE IS COURT F OUSE V LISLE, PA. APRIL 27, 1947 RAY T HARR IGAN ATTORNEY FOR GRANTEE ---------------------------------- ------------------------------------- ---------------------- NO 16467 DEED POLL 6 EARL L BRENNEMAN ET AL COUNT COMMISSIONERS 4 WHEREAS, A TRACT OFLAND CONTAINING LOT OF GROUND IN TO EAST PENNSBORO TOWNSHIP, SOLD AS THE PROPERTY OF MILTON RAY T HARRIGAN RENEKER SITUATE IN THE TOWNSHIP OF EAST PENNSBORO IN THE CONS, W-00 COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, WAS RATED LOC. EAST PENNSBORO TWP, AND ASSESSED WITH DIVERS TAXES WHICH REMAINED UNPAID, AND DATED JANUARY 19, 1946 4 THE TREASURER OF SAID COUNTY HAVING GIVEN DUE AND PUBLIC ENT. APRIL 27. 1948 O NOTICE OF THE TILE AND PLACE OF SALE, DID ON THE 29TH DAY ---------------------------------- JULY 1940, EXPOSE THE SANE TO SALE BY PUBLIC VENDUE OH OUTCRY, AND NO PERSON BIDDING THEREFOR A SUM EQUAL TO THE AMOUNT OF TAXES DUE AND THE COST OF ADVERTISING AND SALE, IT THEREFORE BECAME THE DUTY OF THE COMMISSIONERS OF THE COUNTY OF CUMBERLAND TO BUY THE SAME, WHICH THEY ACCORDINGLY DID; AND WHEREAS , THE TREASURER OF SAID COUNTY, IN PURSUANCE THEREOF, BY DEED BEARING DATE THE 315T DAY OF DECEMBER, 1940, DULY ACKNOWLEDGED, DID GRANT AND CONVEY THE SAID DESCRIBED TRACT OF LAND TO THE COMMISSIONERS OF THE CO WTY OF CUMBERLAND, AND THEIR SUCCESSORS IN OFFICE; AND WHEREAS, THE SAID DESCRIBED TRACT OF LAND NOT HAVING BEEN REDEEMED IN DUE TIME BY THE ORIGINAL OWNERS, THE COMMISSIONERS OF THE COUNTY OF CUMBERLAND, IN PURSUANCE OF THE VARIOUS ACTS OF ASSEMBLY IN SUCH CASE MADE AND PROVIDED, DID, AFTER GIVING DUE AND LEGAL NOTICE OF THE TIME AND PLACE OF SALE, EXPOSE THE SAID DESCRIBED TRACT OF LAND TO PUBLIC SALE ON THE P 28TH DAY OF DECEMBER, 1945, AND SOLD THE SAME TO RAY T. HARRIGAN, MECHANICSBURG, R. D. # 2, MONROE TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, FOR THE SUM OF FIFTY THREE'($53.00) DOLLARS, HE BEING THE HIGHEST AND BEST BIDDER AND THAT THE HIGHEST AND BEST PRICE BIDDEN FOR THE SAME. NOW KNOW YE, THAT WE, EARL L. BR NNEMAN, R. W . LEMASTER AND J. C. LINDSEY COMMISSIONERSt OF THE COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BY VIRTUE OF THE POWER AND AUTHORITY VESTED IN US AS AFORESAID, FOR AND IN CONSIDERATION OF THE SUM OF FIFTY THREE ($53.00) DOLLARS LAWFUL MONEY OF THE UNITED STATES OF AMERICA, TO US IN HAND PAID, AT AND BEFORE THE ENSEALING AND DELIVERY HEREOF, THE RECEIPT WHEREOF IS HEREBY ACKNOWLEDGED, HAVE GRANTED, BARGAINED AND SOLD UNTO THE SAID RAY T. HARRIGAN, MECHAN I CSSURG, R. D.# 2 MONROE TOWNSHIP, CUM 13ERLAND COUNTY, PENNSYLVANIA, HIS HEIRS AND ASSIGNS, ALL THE RIGHT, TITLE ANDINTEREST OF THE SAID COUNTY OF CUMBERLAND, OF, IN AND TO THE HEREINBEFORE MENTIONED AND DESCRIBED TRACT OF LAND KNOWN AS LOT OF GROUND IN EAST PENNSBORO TOWNSHIP, SOLD AS THE PROPERTY OF MILTON RENEKER TOGETHER WITH ALL THE PRIVILEGES AND APPURTENANCES THEREUNTO BELONGING, OR IN ANYWISE A ,PERTAINING. TO HAVE AND TO HOLD THE SAID DESCRIBED TRACT OF LAND, TOGETHER WITH ALL THE PRIVILEGES AND APPURTENANCES THEREUNTO BELONGING, OR IN ANYWISE APPERTAINING, UNTO THE SAID RAY T. HARRIGAN, MECHANICSBURG, R. D. # 2, MONROE TOWNSHIP, CUMBERLAND COUNTY, PA. HIS HEIRS AND ASS ICNS, TO THE ONLY PROPER USE AND BEHQOF OF THE SAID RAY T. HARRIGAN, MECHANICSBURG, R. D. # 2, kIOPJR0E7TWP,. CUMB. CO., PA. HIS HEIRS AND ASSIGNS FOFE VER. IN WITNESS WHEREOF, WE HAVE HEREUNTO SET OUR HANDS AND THE SEAL OF THE SAID COUNTY OF CUMBERLAND, THIS 19TH DAY OF JANUARY 1946. EARL L BRENNEAIAN R. W. LEMASTER J C LINDSEY COUNTY COMMISSIONERS RECEIVrD ON THE DAY OF THE DATE OF THE FOREGOING DEED POLL, THE FULL CONSIDERATION MONEY THEREIN MENTIONED. J. W. DOUGHE IdY TREASURER OF CUMBERLAND COUNTY. COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND )SS BEFORE 1.E, THE SUBSCRIBER, A DEPUTY RECORDER OF DEEDS PERSONALLY CAME EARL L. BRENNEMAN, R. W. LEMASTER, AND J. C. LINDSEY COMMISSIONERS OF THE COUNTY OF CUMBERLAND, AND DULY ACKNOWLEDGED THE FOREGOING TO BE THEIR ACT AND DEED FOR THE PURPOSES THEREIN MENTIONEQ, AND DESIR D THAT THE S 44E MIGHT BE RECORDED AS SUCH ACCORDING TO LAW. WITNESS MY HAND AND SEAL, THIS 21ST DAY OF JANUARY A. D. 1946 CHESTERiA BRENNEMAN DEPUTY RECORDER OF OEED , CUMBERLAND COUNTY, PA. MY COMMISSION EXPIRES k1GROITEE Riij?ulONDAY OF JAN. 1950 1 00 HEREBY CERTIFY THAT THE PRECISE RESIDENCE OF THE WITHIN IS MECHANICSBURG, PA. R. D. 2 ARRIL 27, 1948 RAY T. HARRIGAN ATTORNEY FOR GRANTEE -----------------------------4-------------------------------------------------------------- NO 1646a 4 DEED 4 RAY T .HARR IGAN ET UX 6 THIS DEED, TO MADE THIS 26TH DAY OF APRIL IN YEAR,NINETEEN HUNDRED AND FANNIE S BRETZ F Y EIGHT. CONS. #1.00 4 BETWEE Y T. HARRI AND MARY D. HARRIGAN, rilS WIFE, OF LOC. EAST PENNSBORO TWP. ¢ MECHANICSBU D. 2, PENNSYLVANIA ( HEREINAFTEq CALLED THE DATED APRIL 26, 1948 ¢ GRANTORS) ENT. APRIL 27, 1948 4 AND __________________________ _ ANNIE S. BRETZ OF MECHAN SBURG, R. D. 4, PENNSYLVANIA, ( HEREIN- AFTER CALLED THE GRANTE I WITNESSETH, THAT I ONSIDERATION OF ONE DOLLAR ($1.00) IN HAND ID, THE RECEIPT WHEREOF IS HEREBY ACKNO EDGED, THE SAID GRANTORS 00 HEREBY GRANT.,AND CONVEY TO THE SAID GRANTEE, HER HEIRS atdn Accirhic ?X- 10, SOLD UNTO THE SAID RAY T. HARRIGAN, MECHANICSBURG, R. D.# 2 MONROE TOWNSHIP,. CUMBERLAND COUNTY, PENNSYLVANIA, HIS HEIRS AND ASSIGNS, ALL THE RIGHT, TITLE ANDINTEREST OF THE SAID COUNTY OF CUMBERLAND, OF, IN AND TO THE HEREINBEFORE MENTIONED AND DESCRIBED TRACT OF LAND KNOWN AS LOT OF GROUND IN EAST PENNSBORO TOWNSHIP, SOLD AS THE PROPERTY OF MILTON RENEKER TOGETHE R WITH ALL THE PRIVILEGES AND APPURTENANCES THEREUNTO BELONGING, OR IN ANfWISE APPERTAINING.. TO HAVE AND TO HOLD THE SAID DESCRIBED TRACT OF LAND, TOGETHER WITH ALL THE PRIVILEGES AND APPURTENANCES THEREUNTO BELONGING, OR IN ANYWISE APPERTAINING, UNTO THE SAID RAY T. HARRIGAN, MECHANICSBURG, R. D. r-2, MONROE TOWNSHIP, CUMBERLAND COUNTY, PA. HIS HEIRS AND ASSIGNS, TO THE ONLY PROPER USE AND BEHOOF OF THE SAID RAY T. HARRIGAN,.MECHANICSBURG, R. D. # 2, MOtMETT7W,,. CLIMB. CO., PA. HIS HEIRS AND ASSIGNS FOREVER. IN WITNESS WHEREOF, I';E HAVE HEREUNTO SET OUR HANDS AND THE SEAL OF THE SAID COUNTY OF CUMBERLAND, THIS 19TH DAY OF JANUARY 1946. EARL L BRENNEMAN R. W. LEMASTER J C LINDSEY COUNTY COMMISSIONERS RECEIVtD ON THE DAY OF THE DATE OF THE FOREGOING DEED POLL, THE FALL CONSIDERATION MONEY THEREIN MENTIONED. J. W. DOUGHE RFY TREASURER OF CUMBERLAND COUNTY. COM%IONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND )SS BEFORE MEE, THE SUBSCRIBER, A DEPUTY RECOFOER OF DEEDS PERSONALLY CANE EARL L. BRENNEMAN, R. W. LEMASTER, AND J. C. LINDSEY COMMISSIONERS OF THE COUNTY OF CUMBERL AND,,,AND DULY ACKNOWLEDGED THE FOREGOING TO BE THEIR ACT AND DEED FOR THE PURPOSES THEREIN MENTIONEQ, AND DESIRED THAT THE SAVE MIGHT BE RECORDED AS SUCH ACCORDING TO LAW. WITNESS MY HAND AND SEAL, THIS 21ST DAY,OF JANUARY A. D. 1946 CHESTER A BRE'NNEMAN? s. DEPUTY RECORDER OF DEED?O, CUMBERLA41) COUNTY, PA. MY COMMISSION EXPIRES TAE?EI.R"' AIU?DAY OF JAN, 1450 I DO HEREBY CERTIFY THAT THE PRECISE RESIDENCE OF THE WITHIN NA C GRVTEE IS MECHANICSBURG, PA. R. D. 2 _.ARRIL 27, 1948 RAY T. HARRIGAN ATTORNEY FOR GRANTEE ----------------------------- ------------------------ -------------------------------------- NO 1646a DEED b RAY T HARRIGAN ET UX 6 THIS DEED, TO 6 MADE THIS 26TH DAY OF APRIL IN THE YEAR.NINETEEN HUNDRED AND FANNIE' S BRETZ FORTY EIGHT. CONS. ff.00 V BETWEEN RAY T. HARRIGAN AND MARY D. HARRIGAN' ri1S WIFE, OF- LOC. EAST PENNSBORO TWP. 4 MECHANICSBURG, R. D. 2, PENNSYLVANIA ( HEREINAFTE(ZI CALLED THE DATED APRIL 26, 1948 G GRANTORS) ENT_ APRIL 27, 1946 6 AND -----------------------------0 FANNIE S. BRETZ OF MECHANICSBURG, R. D. 1,, PENNSYLVANIA, ( HEREIN AFTER'CALLED THE GRANTEE) WITNESSETH,`THAT IN CONSIDERATION OF ONE DOLLAR ($1.00) IN HAND PAID, THE RECEIPT WHEREOF IS HEREBY ACKNOWLEDGED, THE SAID GRANTORS DO HEREBY GRANT AND CONVEY TO THE SAID GRANTEE, HER HjEf AND ASSIGNS, ALL THAT CERTAIN LOT OF GROUND SITUATE'IN EAST PENNSBURO TOWNSHIP,' CUMBERLAND COUNTY, PENNSYLVANIA, KNOWN AND DESCRIBED AS THE PROPERTY OF MILTON RENEKER, AND BEING THE SAME PREMISES CONVEYED TO RAY T. HARRIGAN, ONE OF THE GRANTORS HEREIN, i BY DEED OF THE COMMISSIONERS OF CUMBERLAND COUNTY, PENNSYLANIA, DATED JANUARY 19, 1946, AND BEING THE SAME PROPERTY SOLD TO SAID COUNTY COMM I SS IONEPS BY JOHN H HOBART, TREASURER OF CUM- ERLAND COUNTY, PENNSYLVANIA, ON JULY 29, 1939 AND CONVEYED TO THEM BY DEED DATED DECEMBER 31ST, 1940 AND THE SAID GRANTORS DO HEREBY COVENANT AND AGREE TO AND WITH THE SAID.GRANTEE THAT THE GR RJTORS, THEIR HEIRS, EXECUTORS AND ADMINISTRATORS; SHALL AND WILL SPECIALLY WARRANT AND FOR- EVER DEFEND THE HEREIN ABOVE DEtiCRIBED PREMISES, WITH THE HEREDITAMENTS AND APPURTt°ANCES , UNTO THE SAID GRANTEE, HER HEIRS AND ASSIGNS, AGAINST THE SAID GRANTORS AND AGAINST EVERY OTHER' PERSON LAWFULLY CLAIMING OR WHO SHALL HEREAFTER CLAIM THE SAW OR ANY PART THEREOF. IN WITNESS WHEREOF, SAID GRANTORS HAVE HEREUNTO SET THEIR HANDS AND SEAL THE DAY AND YEAR FIRST ABOVE WRITTEN. SEALED AND DELIVERED IN THE PRESENCE OF RAY T HARRIGAN (SEAL) ?. MARY D HARRIGAN (SEAL) STATE OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) ON THE 27TH DAY OF APRIL 1948, BEFORE NE A DEPUTY RECORDER OF DEEDS.THE UNDERS1040 OFFICER, PERSONALLY APPEARED RAY T. HARRIGAN AND MARY D. HARRIGAN, HIS WIFE, KNOWN TO AE ( OR SATISFACTORILY PROVEN) TO BE THE PERSONS WHOSE NAAE S ARE SUBSCRIBED TO THE WITHIN INSTRUMENT, AND ACKNOWLEDGED THAT THEY EXECUTED,THE SANE FOR THE PURPOSES THEREIN CONTAINED, AND DESIRED THE SAME MIGHT BE RECORDED AS SUCH. IN WITNESS WHEREOF, I HEREUNTO SET MY HAND AND OFFICIAL SEAL. CHESTER A BRENNEMAN DEPUTY REC :RDER OF DEEDS, CUB ERLAND_VUNTY, PA. FAY COMMISSION EXPIRES THE FI NMOryD YAOF JAN. 1950 THE ADDRESS OF THE WITHIN NAMED GRANTEE IS MECHANICSBURG, R. D. 4. PENNA. RAY T HARRIGAN ATTY. ON BEHALF OF THE GRANTEE -------------- --------------------------- NO 16504 DEED THIS INDENTURE, . WILLIAM J TURPIN TO MADE THE 27TH DAY OF APRIL IN THE YEAR OF OUR LORD ONE ... WILLIAM J TURPIN ET UX THOUSAND NINE HUNDRED AND FORTY EIGHT. CONS. $1.00 BETWEEN WILLIAM J TURPIN, OF THE BOROUGH OF NEST FAIRVIEW, LOC. WEST FAIRVIEW, PA. COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, PARTY OF , DATED APRIL 27, 1948 THE FIRST PART, ENT. APRIL 29, 1948 AND ____________ _ ____ _ ___ --WILLIAM J TURPIN 'AND MILDRED T. TURPIN, HUSBAND AND WIFE, )F THE SANE PLACE, PARTIES OF THE SECOND PART, WITNESSEIH, THAT THE SAID PARTY OF THE FIRST.PAR[ 'OR AND IN CONSIDERATION OF THE SUM OF ONE DOLLAR AND OTHER VALUABLE CONSIDERATIONS LAWFUL IONEY OF THE UNITED STATES OF AMERICA, WELL AND TRULY PAID BY THE SAID PARTIES OF THE SECOND 'ART TO THE SAID PARTY OF THE FIRST PART, AT AND BEFORE THE SEALING AND DELIVERY OF THESE PRE- LENTS, THE RECEIPT NHEREOF IS.HEREBY ACKNOWLEDGED, HAS GRANTED, BARGAINED, SOLD, ALIENED, EN- "EOFFED, RELEASED, CONVEYED AND CONFIRMED, AND BY THESE PRESENTS DOES GRANT, BARGAIN, SELL, ALIEN; ENFEOFF, RELEASE, CONVEY AND CONFIRM UNTO THE SAID PARTIES OF THE SECOND PART, THEIR 'EIRS AND ASSIGNS, ?n? BOOK ?' c7 F?uC.7.U1. FMEMMPLF DEED-Typewriter C k,hm Press, Hurisbutg. Pa. Tj4io Jinbruturp, babe tide 5th. day of May in the year of our Lord One Thousand Nine Hundred and Fifty Nine/ V J5etbxrn F'snny Bretz, also known as Fannie S. Bretz, single woman, of East Pennsboro Township, Cumberland County, Pennsylvania, party of the first part, *AND* David H. Bretz and Bertha D. Bretz, his wife, of tl,e'same place, parties of the second part. ttttCS??etij, That the .aid part v of the first part, for and inconsidenMmt of the sum of Ten (10.00 ) Dollars, lawful money of the United Stasis of America, well and trtdy paid by the said part ies of the second part to the said party of the first part, at and before the sealing and defirery of these preserttf, fihs_teeapt whereof is hereby acknowledged, has granted, 'bargained, sold, aliened, enfeoffed, released, conveyed, and confirmed and by these presents do es grant, bargain, sell, alien, enfeoff, release, convey, and confirm unto the said part i83 of the second pan their ttti heirs and assigns, Su those two certain tracts or parcels of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit:_ Tract No, L, BEGINNING at a point in the eastern line of the Pine Hill Road at the northern line of land of Edward W. Haegele; thence northwardly along the western line of land of Clinton Orris nine hundred seventy (970) feet, more or less, to a point; thence westwardly along land of Charles *X. & Linda M. Linder, formerly Wen- zel Rohr, three hundred seventy five (375) feet, more or less, to a point; thence southwardly along land of William 87 Esther Hazzard, formerly Slacker, five hundred fifty (550) feet to a point; thence eastwardly fifty (50) feet to a point; thence southwardly four hund- red (400) feet to Hoffman's Corner; thence eastwardly, across the Pine Hill Road, three hundred twenty (320) feet to a point, the place of BEGINNING. t a' i r c } i x a s 1 BEING the same premises which J. R. Henninger, single man, by. { his deed dated October 10, 1939 and recorded in the'Office for-the recording of Deeds in and for Cumberland County in Deed'.Book "J", Volume 12, page 585, granted and conveyed unto F'arviy Bretz, grantor herein. TRACT No. 2.,BBING'all that certain tract of ;fountain Land ' situate in East fennsboro Township which hay T. Harrigan and Mary ° D. Harrigan, his wife, by their deed dated April 26, 1948, granted and conveyed unto Fannie S. Bretz, grantor herein; said Deed being I recorded in the Office for the Recording of Deeds aforesaid -iii Deed Book "T", Volume 13, Page 525. Wwtijer with all and singular, the tenement s, hereditaments and appurtenances to the saute belong- ing or in anywise appertaining, and the reversion and..reversions, remainder and remainders. rents, issues and profits thereof: ginb AW all the estate, right, title, interest, property, claim and demand whatsoever, both in law and equity, of the said pmt y of the first part, of, in, to or out of the said premises, and every part and parr, I thereof ?prY Pabt Imb to *Qib the said premises, with all and singular the appurtenances, unto the said part ie:: of slu second part their heirs and assigns, to and for the only proper use and behoof of the said part ie s of the second part, their heirs and assigns forever, i STIb THE SAID party of the first part, for herself, her heirs, ext-cuton and administrators, do e s by these presents, covenant, grant and agree to and with the said pan L e s of the swand part their heirs and assigns, that she thesaid party of the first part, her heirs all and singular else heredita meats and premises hereinabave described and granted or mentioned, and in- j tended so to be, with the appurtenance,, unto the said pmt le s of the second part, their heirs and assigns, against the said pmt y of the first part and her heirs and against all and every other person or persons whomsoever, lawfttuy claiming or to claim the same or any part thereof, shall and will, by these presents, WARRANT AND FOREVER DEFEND In Witnea Mijereof a. said part y of the first part ha s hereunto set her hand and seal the day and year first above written. i t _7 4- s' .... ...... (SEAL) Signed, Sealed and Delivered ...................................... ......... (SEAL) ' 3 s 8aOJ A PAGEI03 COMMONWEALTH OF PANNSYLVANIA SS: COUNTY OF ..CU>1?EktIrAND .................. OF qtt i i GUMEERtAMD bi7Uritr', ?' f?E"SYLVANP ?i On this„the 5th.... day of ................. Msy........... t 19. before meg j:. Jerome E, yN i t tl a the undersigned officer, pcrsottoRy ePPe°red ..F$4i??9..$F.etas..?a,?o..kt3o9eu..as..Fanny..S...Bretz, s},l,,e,t woman r ......... . .................................................................................................. m known to e (or satisfactorily proven) to be the person ...... whose name ..... S S ......'subscribed to the j within instrument, and acknowledged that .....8 he ...... executed the same for the purpose therein j In WITNESS WHEREOF, I hereunto set my 6ndand lseal. •°'L '?`+,: uit ce of tHe'.' ea r ; My Comm' si expires: Pirsl:. Afondag. i.n.. I hereby certify that the Precise Residence of th rantee, in the within Deed, is ......... ... r / ..Mounted. Route.,. Ennis, . Pa.. ..................... 'i •. .; ?o Attorney for ntee. 02 of p Ol. 0. 0 r-4 o m e+ .„fit : , '- L a1 . ? . ?• u f?` F ss. 43 -4 V AIM 4J 7a at 9 e D tq : vt: VP 1 1 f, o ?' 2 f+ x m: O' ('rbh i ry A pa , g ttt p E cg , COMMONWEALTH Opy/p/ENMYLVAMA ss: COUNTY, Att ea In the Office Recviding of S, Mortgages', etc., in end 'for the Cotity of . to l7eed!Book .. Vol. If P Witntoo My Hand and Seal"o(Office this .. ? ,,,,,......??. ."...,..... Ann,? f)nrnini ]9.? Y J?=??-..?..?s,ri.?.w)i..w./ f,?i., ;.,?.:y.,?strrs:J/,? EK{„bif K 7f I QUIT CLAIM DEED MADE the V J'T day of t¢ j!6 zrr in the year two thousand and seven (2007) BETWEEN WALTER P. LITTLE and TARA L. LITTLE, his wife, Grantors AND WALTER P. LITTLE and TARA L. LITTLE, his wife, Grantees WITNESSETH, that in consideration of ONE AND NO/100 ($1.00) DOLLAR, in hand paid, the receipt whereof is hereby acknowledged, the said grantor does hereby release and quit claim to the said grantee, ALL THAT CERTAIN piece. or parcel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a pin on the property line of Walter P. Little and Tara L. Little, thence Northwest 29 degrees, a distance of 445.5 feet to a pin; thence Northeast 66 degrees, a distance of 379.5 feet to a pin; thence Northwest 19.5 degrees, a distance of 331.65 feet to a pin; thence Northeast 60 degrees, a distance of 132 feet to a pin; thence Southeast 29 degrees 750.75 feet to a pin; thence Southwest 62 degrees, a distance of 561 feet to a pin, being the PLACE OF BEGINNING. BEING part of property formerly owned by Frederick May in a deed recorded in Deed Book 1, Volume TT, Page 353 but having no owner identified presently in the Cumberland County records. Being adjacent to property owned by Walter P. Little and Tara L. Little, his wife, Grantors and Grantees herein, said property more particularly described in a Deed dated January 13, 1986 and recorded in Deed Book S31, Page 122 of the Cumberland County Records. The said Walter P. Little and Tara L. Little have utilized part of the above-described property in excess of 21 years for a garage and hereby execute this Quit Claim Deed to assert their interest in the property. TOGETHER with all and singular, the tenements, hereditments and appurtenances thereunto belonging or in any wise appertaining, and the reversions, remainders, rents, issues, profits thereof: AND also, all the estate, right, title, interest, property, claim and demand whatsoever, as well in law COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OFD, On this, the ?Aslday of 2007, before me, the undersigned officer, personally appeared WALTER P. LITTLE and TARA L. LITTLE, known to me (or satisfactorily proven) to be the persons whose names are subscribed to the within instrument, and acknowledged that they executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL V4" - ` LINDA H MILLER Notary Public Notary PUbIiC CITY OF HARRISBURG, DAUPHIN COUNTY MY ConvnIsslon Expires May 9, 2009 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF SS. RECORDED in the Office for Recording of Deeds, etc., in and for said County, in Deed Book No. Vol. Page WITNESS my Hand and Official Seal this day of 2007. Recorder of Deeds V as in equity, of the said party of the first part, of, in, or to the above-described premises, and every part and parcel thereof, with the appurtenances. TO HAVE AND TO HOLD all and singular the above-mentioned and described premises, together with the appurtenances, unto the said party of the second part, his heirs and assigns forever. IN WITNESS WHEREOF, said Grantors have hereunto set their hands and seals, the day and year first above-written. WALTE P. LI TLE TARA L. LITTLE CERTIFICATE OF RESIDENCE I hereby certify, that the precise residence of the grantee is herein as follows: a'?!U DOQ O,P• ???ti q /dip /7 2S Attorney or Agent for Grantee PRAECIPE FOR LISTING CASE FOR ARGUMENT -i t .-6, p;f?GTHONOTAh (Must be typewritten and submitted in triplicate) Ut' 15 1L. )?FEB -3 AM 10 02 TO THE PROTHONOTARY OF CUMBERLAND COUNTY: (List the within matt the next Argument Court.) CUMBERLAND COUNTY COURT OF COMMON PLEAS ^?}?R$ERi.AND CQUNI1? ------------- ------------------- ------- -------------------------------------------------------------------E??iSYLYANtA CAPTION OF CASE (entire caption must be stated in full) David R. Bretz, by Susan Bretz, his attorney in fact vs. Walter P. Little and Tara L. Little, et al. No. 09-7658 Civil Term 1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's demurrer to complaint, etc.): Defendants' Motion For Summary Judgment 2. Identify all counsel who will argue cases: (a) for plaintiffs: Henry F. Coyne, Coyne & Coyne, P.C. (Name and Address) 3901 Market Street, Camp Hill, PA 17011 (b) for defendants: Helen L. Gemmill, McNees Wallace & Nurick LLC (Name and Address) 100 Pine Street, Harrisburg, PA 17101 3. 1 will notify all parties in writing within two days that this case has been listed for argument. 4. Argument Court Date: February 24, 2012 Signature _Helen L. Gemmill Print your name Date: February 1, 2012 Attorney for Defendants Walter Little and Tara Little INSTRUCTIONS: 1. Original and two copies of all briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) before argument. 2. The moving party shall file and serve their brief 14 days prior to argument. 3. The responding party shall file their brief 7 days prior to argument. 4. If argument is continued new briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) after the case is relisted. 0,Yak ®19.75 M- Ck-M9v9t tot all DAVID R. BRETZ, by IN THE COURT OF COMMON PLEAS OF SUSAN BRETZ, his Attorney CUMBERLAND COUNTY, PENNSYLVANIA in Fact, : Plaintiff V. WALTER P. LITTLE and TARA L. LITTLE, his wife, Defendants CIVIL ACTION - LAW NO. 09-7658 CIVIL TERM IN RE: DEFENDANTS' MOTION FOR SUMMARY JUDGMENT BEFORE HESS, P.J., EBERT and PECK JJ. ORDER OF COURT AND NOW, this 27?' day of February, 2012, upon consideration of Defendants' Motion for Summary Judgment, and following oral argument held on February 24, 2012, Defendants' Motion for Summary Judgment is denied. Henry F. Coyne, Esq. 3901 Market Street Camp Hill, PA 17011-4227 Attorney for Plaintiff , 'Helen L. Gemmill, Esq. 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 Attorney for Defendants c _ BY THE COURT , r M ? ? r as r = -te = r- -<? r i CD J Christylee . Peck, J. ?' ? :rc i' Dip; l r'.5 tKa ??f `?? ?1 COYNE & COYNE, P.C. Austin F. Grogan, Esq. Pa. Supreme Ct. No. 59020 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 HE PP,OTHONOTi.:,k, 2014 SEP -it Ail 9: Or, CUMBERLAND COUNTY AttorneysKuNffilhilik N 1 A David R. Bretz, by Susan Bretz, his attorney in fact, Plaintiff vs. Walter P. Little and Tara L. Little, his wife; Ray T. Harrigan and Mary D. Harrigan his Wife; Milton Renninger a/k/a Milton Reneker; Lillie Renninger; Jacob R. Renninger a/k/a/ J. R. Renninger: a/k/a J.R. Reneker; Jeremy Miller; Abraham Miller; a/k/a Abram Miller; Abram Miller heirs at law; Samuel Miller;: Thachous Miller; Martha Miller; Adeline Miller; Francis Quigg; Sarah Jane Miller; Jacob Hess; Catherine Miller; William Bady; John Gamber, Attorney-in-fact for Abraham Miller heirs; Frederick May and Magdalona May, his wife;: John Shoop, Administrator For Estate of Jacob Neidig ; Jacob Neidig; John Neidig and Mary Neidig, his wife Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-7658 Civil Term : CIVIL ACTION - LAW : ACTION TO QUIET TITLE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the Plaintiffs David R. Bretz, by Susan Bretz, his attorney in fact. Respectfully submitted: COYNE & COYNE, P.C. Dated: 9 `1-1`74 BY: Austin F. Grogan, 3901 Market Stree Camp Hill, PA 17011- (717) 737-0464 quire • CERTIFICATE OF SERVICE 1, Austin F. Grogan, hereby certify that true copies of the Praecipe for Entrance of Appearance has been served upon the below -referenced individuals personally handing said request to the following: Helen L. Gemmill, Esquire McNees Wallace & Nurick, LLC 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 Dated: COYNE & COYNE, P.C. BY: Austin F. Grog 3901 Market Street Camp Hill, PA 170 4227 (717) 737-0464 Pa. S. Ct. No. 59020 Esquir