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HomeMy WebLinkAbout01-0162CHRISTIANNE SNYDER-TEETS and ALTON E. TEETS, Plaintiffs ROBERT MILLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERIJLND COUNTY, PENNSYLVANIA NO. OI CIVIL ACTION - EQUITY 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 (20} days after this Amended Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defense or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or Dther 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 DFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Le hah demandado a usted en la corte. Si usted quiere ~efenderse de estas demandas expuestas en las paginas siguientes, nsted tiene viente (20) dias de plazo al partir de la fecha de la ~emanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de 3u persona. Sea avisado que si usted no se defiende, la corte zomara medidas y puede entrar una orden contra usted sin previo ~viso o notificacion y pot cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CLrYA DIRECCION 3E ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ICHRISTIANNE SNYDER-TEETS and ALTON E. TEETS, Plaintiffs ROBERT MILLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ~/- /&~- ~2~ 7~ CIVIL ACTION - EQUITY COMPLAINT The Plaintiffs aver the following in support of their Complaint against the Defendant: 1. Petitioners are Christianne Snyder-Teets and Alton E. Teets of Post Office Box 137, Spring Gap, 2. Respondents are Robert Miller 3essup, Maryland 20794. 3. A Complaint has Maryland 21560. of MCIS, P.O. Box 549, referenced docket, the contents of which oy reference. The Complaint demands ~onstructive trust upon the Defendant. 4. Plaintiff will suffer irreparable harm ~hich there is no adequate remedy at law if ~ransfers, encumbers, or otherwise alienates any above-referenced real estate 5. Issuance of an injunction would preserve ~f the parties. 6. Denial of injunctive relief would lead to irreparable harm in the form of damage to and loss she Plaintiff for which an accurate are incorporated herein the imposition of a and injury for the Defendant interest in the the status quo accounting has immediate and of assets of not been made. been filed simultaneously to the above- 7. The Defendant has failed to pay the amount of $641.60 to the municipality of Lower Allen Township for which reason a lien has been entered against the property docketed at 2000-1514. 8. The Defendant has failed the taxes to the amount of $1,139.20 for which reason a lien has against the real estate docketed at 2000-5513. 9. Despite the advance of funds totaling over $50,000.00, the Defendant has refused to pay the taxes and other expenses instance with maintaining the real estate. 10. The Defendant occupied a position as attorney, county in the been entered advisor or counselor to the Plaintiff such as to inspire confidence that the Defendant would act in good faith for the Plaintiff's interest. 11. The Plaintiff had never before in her life executed any legal document without the advice of an immediate family member or Df trusted counsel. 12. At all times prior to and at the time of execution of ~he above-reference Deeds (see att&ched Exhibit A), a confidential ~ttorney-client relationship existed between Mrs. Snyder-Teets and zhe Defendant, and Mrs. Snyder-Teets reposed great trust and Donfidence in the Defendant and relied heavily on the Defendant's ~dvice in her business and other affairs. At all such times, Mrs. Snyder-Teets believed that the Defendant would deal fairly and justly with her, and that the Defendant would never abuse their confidential relationship. 13. Mrs. Snyder-Teets did not deliver possession of the real estate to the Defendant however, but remains, in physical possession of the property including such as to store various items of personal property at the contested location. 14. The consideration mentioned in the deed was not the true consideration for the conveyance of the property to the 9efendant, and in fact was never paid by the Defendant to Mrs. Snyder-Teets. 15. It is conceded that the Defendant refinanced a mortgage lien against the property having had a balance at the time of transfer of approximately $50,000.00; however, the property had an appraised value of $140,000.00 as of the date the property was expected to be repaired. (see attached Exhibit B). 16. The true consideration for the execution of the deed ~as an agreement that the Defendant would pay to Mrs. Snyder-Teets the amount of the appraisal value as of the date of transfer, ~hich was expected to between $102,000.00 to $108,000.00 dollars. 17. The parties expected that the actual value of the property would be between $125,000.00 to $230,000.00 once the property had been fixed up. The Defendant was to have paid to ~rs. Snyder-Teets the amount as the property as appraised at the 2ime of the transfer less the amount of the outstanding liens ~gainst the property. 18. Mrs. Snyder-Teets spoke with the Defendant again during the summer of 2000. The Defendant indicated that he would pay her the balance that was owed within ninety to one hundred and twenty days and asked her to "sit tight". 19. Said property is, and at the time of the execution of said deed was, reasonably worth $105,000.00. The real estate itself, however, is unique; and Mrs. Snyder-Teets therefore has no adequate, comprehensive, alternative remedy at law. 20. At the time Mrs. Snyder-Teets executed the deed in favor of the Defendant, the Defendant had no intention to comply with the agreement with Mrs. Snyder-Teets to improve the property and pay to her the difference between its current value and the outstanding mortgage. The Defendant fraudulently induced Mrs. Snyder-Teets to believe that they would comply with their agreement and keep only the improvement value of the property from the $105,000.00 value as of the time of the transfer through the $125,000.00 to $140,000.00 improved value of the real estate. 21. By reason of the Defendants' fraudulent inducement to Snyder-Teets that he would comply with her request to improve zhe property and repay her the reason of the Defendants' refusal Defendant has violated the trust existing equity therein, and by to comply with said request, the and confidence placed in him as ~n attorney by Mrs. Snyder-Teets. The Defendant acquired said ~eed and property of Mrs. Snyder-Teets solely by means of fraud ~nd breach of confidence. 22. The Quitclaim Deed and the Warranty Deed were drafted the attorney, WHEREFORE, ~ursuant to Pa. Robert Miller. Petitioner requests your Honorable Court to issue, R. Civ. P. Rule 1531, enjoining the Defendant from the sale or transfer estate, fixtures, or Lower Allen Township, of any right, title or interest in the real dwelling located at 95 Kensington Drive, Camp Hill, Cumberland County, Pennsylvania 17011, In the alternative, Petitioner request that a temporary injunction be granted pending a hearing on the matter. COUNT II 23. The proceeding paragraphs (1) one through (22) twenty- 5wo are incorporated herein by reference. 24. The Plaintiff, Alton E. Teets is the spouse of Shristianne Snyder-Teets. 25. At the time of the transfer of the deed the parties ~here married, and as such are entitled to the presumption at law Df ownership of the property as tenants by the entireties. 26. The Plaintiff, Alton E. Teets was unaware that Mrs. Snyder-Teets was considering transferring, or had transferred, zitle to the marital residence at 95 Kensington Drive, Lower Allen Township, Camp Hill, Cumberland County, Pennsylvania 17011. 27. Mr. Teets had substantial items of personal property located at the marital residence, with such items having a zeplacement value of $27,272.00. (see attached Exhibit C). 28. Despite making demand for the same, Defendant has Eailed or refused to return the items of property located at 95 Kensington Drive, Lower Allen Township, Camp Hill, Cumberland County, Pennsylvania 17011. WHEREFORE, the Plaintiff prays judgment as follows: A. Declaring a monetary judgment against the Defendant and in favor of the Plaintiffs in an amount in excess of $55,000.00, for the real estate which amount exceeds the amount requiring arbitration; B. Declaring that the Defendant hold title to said real property in trust for the Plaintiffs; C. Requiring the Defendant to reconvey said real property to the Plaintiffs upon reimbursement of the reasonable and actual expenses the Defendant may have placed into the property; D. For monetary judgment in the amount of $27,272.00 for the personal property; E. Declaring that the Defendant holds title to said personal property in trust for the Plaintiff; F. Requiring the Defendant reconvey said personal property to the Plaintiffs; G. For costs of suit; and H. For such other and further relief Reap ' '~f~ulqy/--itted,e~ s~m as the cou~t may/ deem just and equitable. Matt J.~ ~Eshelman, Esquire Law Office~ of Patrick F. Lauer, Jr. 2108 Marke~ Street, Aztec Building /~~ Camp Hill, Pennsylvania 17011-4706 Date: ~ ~ ID# 72655 Tel. (717) 763-1800 CHRISTIANNE SNYDER-TEETS and ALTON E. TEETS, Plaintiffs VS ROBERT MILLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - EQUITY VERIFICATION We, Christianne Snyder-Teets and Alton E. Teets, state that we are the Petitioners in the above-captioned case and that the facts set forth in the foregoing document are true and correct to the best of our knowledge, information and belief. We realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S. 4904. iDate: -CHRI STIANNF/SNY~ER-TEETS Exhibit A MORTGAGE 1 $, Borrowers RIgM to Reinstate. REQUEST FOR NOTICE OF DEFAULT AND FORECLOSURE UNDER SUPERIOR MORTGAGES OR DEEDS OF TRUST IN WITNESS WHEREOF, Bon'ower has execuled this Modgage. Exhibit B MORTGAGE CHAMPION MORTGAGE CO.. INC.. 20 WATERVIEW BOULEVARD. PARSIPPANY. NEW JERSEY 07054 A$SUR ' 4600 S.'['~EET RD. BAL Y T T~:t":VOS~, 'CI~N~9~I~VANIA LOON PA MENT MOR GAGE - FIRST LIEN THIS MORTGAGE Is made this 6th day of OCTOBER. 19l~g between the Mortgagor. ROBERT MILLER. (herein A~ More Particularly Described in Exhibit "A" Which M Attached Hereto and Made a Part Hereof Tax darnel e 13-25-0022-052 which has the address of 95 KENSINGTON DRIVE. LOWER ALLEN TOWNSHIP, PENNSYLVANIA. (herein "Property Address"); TOGETHER with all the improvements now or hereafter erected on the properly, and all easements, rights. 1. Payment of Principal and Interest. Borrower shall pmmpby day when due the principal and interest indebtedness evidenced by the Nole arid Iste c;~atge$ as provided In the Nole. ?// REALTY TRANSFER TAX L~'~/' B TRANSFER DATA PROPERTY L6¢ATION VALUATION DATA EXEM~ION DATA COHMOITWEALTH OF PENNSYLVANIA RECORDED on ~h~s ~ da~ o~ ~D~ A. D.19~ , in the Recorder's offLce of the sa~d County, in Deed Book Given under my hand and the seal of the said off~oe, =he date 295 Q u ITCL~- 1 ~.1 DEED Tills QUITCLAIM DEED, Excculcd this $ day of June, 1999 by first party, Witness ~ Firs/Patty MY ~MMI~N Exhibit C LITHO IN UB.A. 3.Lawn 84 air 10. 3 OmLS%a=ters ' 13 4 rod~he9%er carbueto~ 14. 2 18 wheel~ba~row t9. W~e~wa~er 23 woode~ b~rrels 3 26.Ford 28.3 ktb~he~ ~Chatrs 30, 3 31. Pa~n~n~ 33.. Oak~ha~d wood flooring ~. 5 ~, cer~mt~ TiLe 15 boxes ~6,Drywu%l 40.2 s~d9 g~inders "~ 42.1 cer~mfo ~{Le cu~ec 43.2 wor~ 44. 2 v~ce 12 ,. 45.~ % electric driP! '46. i 3/B e~ectric drilT ~7. ~ ~e~ o~ ~ood bits 49,1 p~ecis~on level 60,~ pro~ra %./w,e-~ 51.1 mi'!tre'1 box 52. 2 micrometers 53.2 trioub~.e lights 54. 1 hlila~ gun 25 55. s~o~sm!~ 58. 2palint'i sgr&yers ',~ 61. 2 a~r {rin~e~ ' 53.Cabih.t~hardwm ~5. lca~e ~xane 72.video c~era and case an~ 74. 2 76.plum~in~Ools ~nd supplies 78' li5~1e ~"d 81. Misa. ~all ~31 box:ica~p~nter'~ tools Jf CHRISTIANNE SNYDER-TEETS and ALTON E. TEETS, Plaintiffs ROBERT MILLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - EQUITY AND NOW, this consideration of the ORDER OF COURT /~ day of ~~ within PETITION FOR PRELIMINARY 2000, upon INJUNCTION AND EQUITABLE RELIEF, it is hereby ordered that ~atter is scheduled to take place on the /~ ' , , 200{ , at ,~ 30 m in Courtroom No ~land County Courthouse in Carlisle, Pennsylvania. a hearing on the day of of the Pendi~ the hearing s~ in the prece~graph, a temporary i~junction is 7anted tainst the D~ndant, ~nd he is 0reliminar~y enjoin~om the/sale or ~nsfer of/any right, title or /interest ~ the 7e~ est~xture_s,, ~~ng BY THE COURT: CHRISTIAN-NE SNYDER-TEETS and ALTON E. TEETS, Plaintiffs ROBERT MILLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ILk CIVIL ACTION - EQUITY PETITION FOR PRELIMINARY INJUNCTION AND EOUITABLE RELIEF 1. Petitioners are Christianne Snyder-Teets and Alton E. ~eets of Post Office Box 137, Spring Gap, Maryland 21560. 2. Respondent is Robert Miller of MCIS, P.O. Box 549, 3essup, Maryland 20794. His identification number is 254603. 3. A Complaint has been filed simultaneously to the above- referenced docket, the contents of which are incorporated herein Dy reference. The Complaint demands the imposition of a 2onstructive trust upon the Defendant. 4. Plaintiff will suffer irreparable harm and injury for Nhich there is no adequate remedy at law if the Defendant 5ransfers, encumbers, or otherwise alienates any interest in the ~bove-referenced real estate 5. Issuance of an injunction would preserve the Df the parties. 6. Denial of irreparable harm in zhe Plaintiff injunctive relief would the form of damage to status quo lead to immediate and and loss of assets of for which an accurate accounting has not been made. 7. The Defendant has failed to pay the amount of $641.60 to the municipality of Lower Allen Township for which reason a lien has been entered against the property docketed at 2000-1514. 8. The Defendant has failed the taxes to the county in the amount of $1,139.20 for which reason a lien has been entered against the real estate docketed at 2000-5513. 9. Despite the advance of funds totaling over $50,000.00, the Defendant has refused to pay the taxes and other expenses instance with maintaining the real estate. 10. The Defendant occupied a position as attorney, advisor Dr counselor to the Plaintiff such as to inspire confidence that 5he Defendant would act in good faith for the Plaintiff's interest. 11. The Plaintiff had never before in her life executed any legal document without the advice of an immediate family member or of trusted counsel. 12. At all times prior to and at the time of execution of 5he above-reference Deeds (see attached Exhibit A), a confidential attorney-client relationship existed between Mrs. Snyder-Teets and che Defendant, and Mrs. Snyder-Teets reposed great trust and confidence in the Defendant and relied heavily on the Defendant's advice in her business Snyder-Teets believed justly with her, and and other affairs. At all such times, Mrs. that the Defendant would deal fairly and that the Defendant would never abuse their confidential relationship. 13. Mrs. Snyder-Teets did not deliver possession of the real estate to the Defendant however, but remains, in physical possession of the property including such as to store various items of personal property at the contested location. 14. The consideration mentioned in the deed was not the true consideration for the conveyance of the property to the Defendant, and in fact was never paid by the Defendant to Mrs. Snyder-Teets. 15. It is conceded that the Defendant refinanced a mortgage lien against the property having had a balance at the time of transfer of approximately $50,000.00; however, the property had an appraised value of $140,000.00 as of the date the property was expected to be repaired. (see attached Exhibit B). 16. The true consideration for the execution of the deed was an agreement that the Defendant would pay to Mrs, Snyder-Teets the amount of the appraisal value as of the date of transfer, which was expected to between $102,000.00 to $108,000.00 dollars. 17. The parties expected that the actual value of the property would be between $125,000.00 to $230,000.00 once the property had been fixed up. The Defendant was to have paid to Mrs. Snyder-Teets the amount as the property as appraised at the time of the transfer less the amount of the outstanding liens against the property. 18. Mrs. Snyder-Teets spoke with the Defendant again during the summer of 2000. The Defendant indicated that he would pay her the balance that was owed within ninety to one hundred and twenty days and asked her to "sit tight". 19. Said property is, and at the time of the execution of said deed was, reasonably worth $105,000.00. The real estate itself, however, is unique; and Mrs. Snyder-Teets therefore has no adequate, comprehensive, alternative remedy at law. 20. At the time Mrs. Snyder-Teets executed the deed in favor of the Defendant, the Defendant had no intention to comply with the agreement with Mrs. Snyder~Teets to improve the property and pay to her the difference between its current value and the outstanding mortgage. The Defendant fraudulently induced Mrs. Snyder-Teets to believe that they would comply with their agreement and keep only the improvement value of the property from the $105,000.00 value as of the time of the transfer through the $125,000.00 to $140,000.00 improved value of the real estate. 21. By reason of the Defendants' fraudulent inducement to Mrs. Snyder-Teets that he would comply with her request to improve the property and repay her the existing equity therein, and by reason of the Defendants' refusal to comply with said request, the Defendant has violated the trust and confidence placed in him as an attorney by Mrs. Snyder-Teets. The Defendant acquired said ~eed and property of Mrs. Snyder-Teets solely by means of fraud and breach of confidence. 22. The Quitclaim Deed and the Warranty Deed were drafted by the attorney, Robert Miller. WHEREFORE, Petitioner requests your Honorable Court to issue, pursuant to Pa. R. Civ. P. Rule 1531, enjoining the Defendant from the sale or transfer of any right, title or interest in the real estate, fixtures, or dwelling located at 95 Kensington Drive, Lower Allen Township, Camp Hill, Cumberland County, Pennsylvania 17011. In the alternative, Petitioner request that a temporary injunction be granted pending a hearing on the matter. COUNT II 23. The proceeding paragraphs (1) one through (22) twenty- two are incorporated herein by reference. 24. The Plaintiff, Alton E. Teets is the spouse of Christianne Snyder-Teets. 25. At the time of the transfer of the deed the parties where married, and as such are entitled to the presumption at law ~f ownership of the property as tenants by the entireties. 26. The Plaintiff, Alton E. Teets was unaware that Mrs. Enyder-Teets was considering transferring, or had transferred, 5itle to the marital residence at 95 Kensington Drive, Lower Allen township, Camp Hill, Cumberland County, Pennsylvania 17011. 27. Mr. Teets had substantial items of personal property located at the marital residence, with such items having a replacement value of $27,272.00. (see attached Exhibit C). 28. Despite making demand for the same, Defendant has failed or refused to return the items of property located at 95 !Kensington Drive, Lower Allen Township, Camp Hill, Cumberland County, Pennsylvania 17011. WHEREFORE, the Plaintiff, Alton E. Teets requests that the court issue an injunction prohibiting the sale, encumbrance, or other alienation of the personal property set forth in Exhibit C herein or in the alternative issue a temporary injunction pending hearing on the same. Respet Matthe Law Of 2108 Ma Camp Hill, ID# 72655 Esquire k F. Lauer, Jr. ~ket Street, Aztec Building Pennsylvania 17011-4706 Tel. (717) 763-1800 CHRISTIANNE SNYDER-TEETS and ALTON E. TEETS, Plaintiffs VS ROBERT MILLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - EQUITY ~ERIFICATION We, Christianne Snyder-Teets and Alton E. Teets, state that we are the Petitioners in the above-captioned case and that the facts set forth in the foregoing document are true and correct to the best of our knowledge, information and belief. We realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S. 4904. Exhibit A Tills QUITCLAIM DEED, Executed this 8 day o1' Jm~ Ig~ by I]rsl party, Chri~ilnne Snydei', who~e pOll OllJce addresl is Camp I fill, Petmsylvallia, to ~ecoad ~ Firll Plrly /~' THIS MORTGAGE SATiSFiED :,:..,~ ,, ,.,~ ,. ....... BY SATISFACTION,~iECE MORTGAGE ............................. Dollm~a (U.S. $ SO, 0o0,00 Exhibit B MORTGAGE CHAMPION MORTGAGE CO., iNC., 20 WATERVIEW ~OULSVARD. PARS4PPANY. NEW JERSEY 07054 4~0 STREET ~'~OS~, ~N~8~VANIA ~ALLOON PAYMENT MORTGAGE - RRST LIEN A CORREIPONDENT - All Inauk~es ma,/be .Zleected t~ the following Exhibit C 59. 2 a~t ~eguIa~or~ 63. Cabinet ~a:dV~O 70.1 ~o~i~g ?2.vide~ c~:e~a and case 73.M[sc; h~rdware nails, screws, 74. 2 S~ep ~Ladders 75.2 2' ~s~ladders 76.plum~in~: ~ools and supplies OZd 78' li~le ~ed wa~gon ~ Camping 'e~uip~ment 83~ box :ua~en~er's ',~: Exhibit !CHRISTIANNE SNYDER-TEETS and ALTON E. TEETS, Plaintiffs Vo ROBERT MILLER Defendant YOU HAVE BEEN SUED : NO. : CIVIL ACTION - EQUITY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ~0 T I C E IN COURT. If you wish to defend against !the claims set forth in the following pages, you must take action iwithin (20) days after this Amended Complaint and Notice are iserved, by entering a written appearance personally or by attorney and filing in writing with the Court your defense 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 m~ney claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or iother 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. Le hah demandado a usted en la corte. Si usted quiere .defenderse de estas demandas expuestas en las paginas siguientes, iUsted tiene viente (20) dias de plazo al partir de la fecha de la !demanda y la notificacion. Usted debe presentar una apariencia ~scrlta o en persona o por abogado y archivar en la corte en forma !escrita sus defensas o sus objeciones a las demandas en contra de Isu persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE i ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, iVAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION iSE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 2HRISTIANNE SNYDER-TEETS and ALTON E. TEETS, Plaintiffs ~OBERT MILLER : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - EQUITY COMPLAINT The Plaintiffs aver the following in support of their Complaint against the Defendant: 1. Petitioners are Christianne Snyder-Teets and Alton E. Teets of Post Office Box 137, Spring Gap, Maryland 21560. 2. Respondents are Robert Miller of MCIS, P.O. bessup, Maryland 20794. Box 549, 3. A Complaint has been filed simultaneously to the above- ~eferenced docket, the contents of which by reference. The Complaint demands ~onstructive trust upon the Defendant. are incorporated herein the imposition of a 4. Plaintiff will suffer irreparable harm and injury for which there is no adequate remedy at law if the Defendant transfers, encumbers, or otherwise alienates any interest in the above-referenced real estate 5. Issuance of an injunction would preserve the status quo of the parties. 6. Denial of injunctive relief would lead to immediate and irreparable harm in the form of damage to and loss of assets of 'the Plaintiff for which an accurate accounting has not been made. 7. The Defendant has failed to pay the amount of $641.60 ~to the municipality of Lower Allen Township for which reason a lien has been entered against the property docketed at 2000-1514. 8. The Defendant has failed the taxes to ~mount of $1,139.20 for which reason a lien ! Iiagainst the real estate docketed at 2000-5513. 9. Despite the advance of funds totaling over $50,000.00, the Defendant has refused to pay the taxes and other instance with maintaining the real estate. 10. The Defendant occupied a position as attorney, or the county in the has been entered expenses advisor counselor to the Plaintiff such as to inspire confidence that ithe Defendant would act in good faith for the Plaintiff's ~nterest. 11. The Plaintiff had never before in her life executed any ]~egal document without !~f trusted counsel. 12. At all times the advice of an immediate family member or prior to and at the time of execution of the above-reference Deeds (see attached Exhibit A), a confidential 9ttorney-client relationship existed between Mrs. Snyder-Teets and !the Defendant, and Mrs. Snyder-Teets reposed great trust and confidence in the Defendant and relied heavily on the Defendant's advice in her business and other affairs. At all such times, Mrs. Snyder-Teets believed that the Defendant would deal fairly and justly with her, and that the Defendant would never abuse their Confidential relationship. 13. Mrs. Snyder-Teets did not real estate to the Defendant however, possession of the property including deliver possession of the but remains, in physical such as to store various ~items of personal property at the contested location. 14. The consideration mentioned in the deed was not the ~rue consideration for the conveyance of the property to the Defendant, and in fact was never paid by the Defendant to Mrs. iSnyder-Teets. 15. It is conceded that the Defendant refinanced a mortgage ! ~ien against the property having had a balance at the time of itransfer of approximately $50,000.00; however, the property had an iappraised value of $140,000.00 as of the date the property was Ilexpected to be repaired. (see attached Exhibit B). I~ 16. The true consideration for the execution of the deed i was an agreement that the Defendant would pay to Mrs. Snyder-Teets ~he amount of the appraisal value as of the date of transfer, i~hich was expected to between $102,000.00 to $108,000.00 dollars. 17. The parties expected that the actual value of the property would be between $125,000.00 to $230,000.00 once the ~property had been fixed up. The Defendant was to have paid to iMrs. Snyder-Teets the amount as the property as appraised at the i~ime of the transfer less the amount of the outstanding liens against the property. 18. Mrs. Snyder-Teets spoke with the Defendant again during l!the summer of 2000. The Defendant indicated that he would pay her 'llthe balance that was owed within ninety to one hundred and t;wenty i days and asked her to "sit tight". ii 19. Said property is, and at the time of the execution of isald deed was, reasonably worth $105,000.00. The real estate itself, however, is unique; and Mrs. Snyder-Teets therefore has no adequate, comprehensive, alternative remedy at law. 20. At the time Mrs. Snyder-Teets executed the deed in favor of the Defendant, the Defendant had no intention to comply With the agreement with Mrs. Snyder-Teets to improve the property ~nd pay to her the difference between its current value and the ~utstanding mortgage. The Defendant fraudulently induced Mrs. ~nyder-Teets to believe that they would comply with their agreement and keep only the improvement value of the property from zhe $105,000.00 value as of the time of the transfer through the 1125,000.00 to $140,000.00 improved value of the real estate. 21. By reason of the Defendants' fraudulent inducement to Mrs. Snyder-Teets that he would comply with her request to improve the property and repay her the existing equity therein, and by reason of the Defendants' refusal to comply with said request, the pefendant has violated the trust and confidence placed in him as ~n attorney by Mrs. Snyder-Teets. The Defendant acquired said deed and property of Mrs. Snyder-Teets solely by means of fraud and breach of confidence. 22. The Quitclaim Deed and the Warranty Deed were drafted Dy the attorney, Robert Miller. WHEREFORE, Petitioner requests your Honorable Court to issue, pursuant to Pa. R. Civ. P. Rule 1531, enjoining the Defendant from i~he sale or transfer of any right, title or interest in the real estate, fixtures, or dwelling located at 95 Kensington Drive, Lower Allen Township, Camp Hill, Cumberland County, Pennsylvania T~ ~ =~v~. petitioner request that a temporary CERISTIANNE SNYDER-TEETS and ALTON E. TEETS, Plaintiffs VS ROBERT MILLER Defendant NO. CIVIL ACTION - EQUITY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VERIFICATION We, Christianne Snyder-Teets and Alton E. Teets, state that we are the Petitioners in the above-captioned case and that the facts set forth in the foregoing document are true and correct to the best of our knowledge, information and belief. We realize that false statements herein are subject to the penalties for unsworn 'falsification to authorities under 18 Pa. C.S. 4904. Date: ~CHRI STIANNE/SNY~ER-TEETS CFIRISTIANNE SNYDER-TEETS, and ALTON E. TEETS, Plaimiffs, VS. ROBERT MILLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Case No.: 01-162 CIVIL ACTION - EQUITY PREVIOUSLY ASSIGNED TO: J. HESS PRAECIPE TO WITHDRAW PETITION FOR PRELIMINARY INJUNCTION AND EOUITABLE RELIEF TO THE PROTHONOTARY: Kindly mark the Plaimiffs' Petition for Preliminary Injunction in the above-captioned matter as withdrawn without prejudice. Date: Respectfully subn~tted, Matthew J. Eghelman, Esquire Law Offices of Patrick F. Laner, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 IDg 72655 Tel. (717) 763-1800 CHRISTIANNE SNYDER-TEETS, and ALTON E. TEETS, Plaintiffs VS~ ROBERT ~ J.ER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : DOCKET No. 01 - 162 : CIVIL ACTION- EQUITY : PREVIOUSLY ASSIGNED TO: J. HESS I hereby certify that I am this day serving a copy of the foregoing PRAECIPE upon the persons and in the manner indicated below, which services satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by first class mail addressed as follows: Robert 1Waller MCIS-II~ 254603 P.O. Box 549 Jessup, MD 20794 Date: Matthew J. Eshelman, E~mre Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Frill, Pennsylvania 17011-4706 ID~ 72655 Tel. (717) 763-1800 CHRISTIANNE SNYDER-TEETS, and ALTON E. TEETS, Plaintiffs, VS. ROBERT MILLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Case No.: 01-162 CIVIL ACTION - EQUITY PREVIOUSLY ASSIGNED TO: J. HESS PRAECI~E TO INDEX LIS PENDENS TO THE PROTHONOTARY: I hereby certify that the Equity Complaint in the above-captioned matter contains a petition for specific performance of an agreement to purchase or sell real estate. As such, kindly index the above-captioned Complaint upon either the judgment or ejectment and miscellaneous indexes against the defendant and certify it as Lis Pendens in any certificate of search which you are required to make by virtue of your office. Date: Respectfully subm~ted, Matthew J. Esnelman, Esquire Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 72655 Tel. (717) 763-1800 CHRISTIANNE SNYDER-TEETS, and ALTON E. TEETS, Plaintiffs VS. ROBF_RT Mil J Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : DOCKETNo. 01 - 162 : CIVIL ACTION - EQUITY : PREVIOUSLY ASSIGNED TO: J. HESS I"~ERTI I*l(~Al'~; OF ~ERVICE I hereby certify that I am this day serving a copy of the foregoing PRAECIPE upon the persons and in the manner indicated below, which services satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by first class mail addressed as follows: Robert Miller MCIS-ID~ 254603 P.O. Box 549 Jessup, MD 20794 Date: Respectfully submitted, Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp ~ Pennsylvania 17011-4706 IDg 72655 Tel. (717) 763-1800 CHRISTIANNE SNYDER-TEETS and ALTON E. TEETS, Plaintiffs ROBERT MILLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVkNIA NO. 01-162 CIVIL ACTION - EQUITY ACTION TO QUIET TITLE NOTICE: To Robert Miller You have been sued for action to quiet title by the Plaintiffs, Christianne Snyder-Teets, and Alton E. Teets, on the grounds of fraudulent inducement. If you wish to defend, you must enter a written appearance personally or by attorney and file your defenses or objections in writing with the Court. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you without further notice for the relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CA/q GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 CHRISTIANNE SNYDER-TEETS and ALTON E. TEETS, Plaintiffs ROBERT MILLER Defendant IN THE COURT OF COMMON PLFJ~S OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-162 CIVIL ACTION - EQUITY ACTION TO QUIET TITLE AFFIDAVIT Before me, the undersigned Notary Public, this day personally appeared Christianne Snyder-Teets and Alton E. Teets, to me known (or satisfactorily proven), who being duly sworn according to law, deposes and says: We have attempted to contact Defendant and any known associates, even going so far as to contact the Maryland State Correctional System, as he was believed to have been in prison there; as well as the authorities governing the registration and conduct of attorneys in Pennsylvania and Maryland, as the Defendant is believed to be a licensed attorney at law. Nonetheless, we have received no favorable response. We have no knowledge whatsoever as to the current whereabouts of the Defendant, Robert Miller, and would not even know where to begin to discover the same. We believe the service of the notice of the action by posting the same on the premises in question for ~: reasonable period of time would engender a response by the Defendant or one of his agents as they would necessarily need to appear at the premises to properly maintain the house and grounds to the satisfaction of the municiDal code. ~ih~istianne Snyd~-~ts Alton E. Teets Sworn to and subscribed to before me this ~ day , 2001. N Notadal Seal - ~lleil3y A. Mlnlch, Notary Public I ~i~111~ Hill Bom, Cumberland County ~ M~ C~rfll~lllalon Expires Aug. 20, 2001 '~mb~r, Fenn~y~vanJ~ a~i~ti~n gf Ngtades CHRISTIANNE SNYDER-TEETS and ALTON E. TEETS, Plaintiffs ROBERT MILLER Defendant IN THE COURT OF COMMON PLF3%S OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-162 CIVIL ACTION - EQUITY ACTION TO QUIET TITLE A_ND NOW, this ~' day of /~/~/ 2001, it is hereby Ordered and Decreed that the Petitioners, Christianne Snyder-Teets, and Alton E. Teets, are permitted to attempt service upon the Respondent, Robert Miller, in the above-captioned action to quiet title by conspicuously posting a notice on the premises in question at 95 Kensington Drive, Lower Allen Township, Cumberland County, for a period of sixty (60) days; and by advertising a notice of the action once within 30 days of posting notice on the premises in the legal publication designated for the publication of legal notices, and once in one newspaper of general circulation, within Cumberland County. If the Defendant has not responded within sixty (60) days of posting notice on the premises, proper service will be deemed to have been made upon the Defendant, and the Petitioners may pursue the proceedings without further petition to this Court regarding service of process. BY THE COURT: CHRISTIANNE SNYDER-TEETS and ALTON E. TEETS, Plaintiffs ROBERT MILLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-162 CIVIL ACTION - EQUITY ACTION TO QUIET TITLE PETITION TO SERVE PURSUANT TO SPECIAL ORDER OF COURT The Petitioners, Christianne Snyder-Teets, and Alton E. Teets, through their attorneys, The Law Offices of Patrick F. Lauer, Jr., respectfully aver the following in support of their Petition to Serve by Publication pursuant to Rule 430: 1. The Petitioners are Christianne Snyder-Teets and Alton E. Teets, Plaintiffs in the above-captioned action to quiet title, and are individuals residing at PO Box 137, Spring Gap, adult Maryland 21560. 2. The Respondent in this matter is Robert Miller, Defendant in the action to quiet title, who is the owner of record of the parcel of real estate in Lower Allen Township, Cumberland County, commonly addressed as 95 Kensington Drive, Camp Hill, Pennsylvania 17011. 3. The parties executed a deed to the above-referenced matter, which Petitioners now allege to have been fraudulently induced, on or about June 8, 1999. 4. The parties last spoke with the Defendant in the summer of 2000. 5. The Petitioners have had no contact whatsoever with the Respondent for more than ten (10) months. 6. An action to quiet title was filed in Cumberland County Court of Common Pleas on the 9TM day of January 2001. 7. The whereabouts of the Respondent are currently unknown. 8. In the event Defendant is not found, the Petitioners have no wish to claim any rights greater than such title to the premises in question as may be vested in the Respondent. 9. The Petitioners, through their attorneys, have made the following attempts to locate the Respondent pursuant to the recommendations regarding Service Pursuant to Special Order of Court set forth in Pennsylvania Rules of Court Rule 430: (a) Petitioner employed 800-U.S. Search, Inc. who through following the guidelines set forth in Rule 430 had no positive results. See Exhibit "A" attached hereto and incorporated herein by reference. (b) Inquiries of relatives, neighbors, and associates of the Defendant, including the Pennsylvania Supreme Court Disciplinary Board, the Maryland Bar Association and the Maryland State Correctional Facilities, with no positive result. See Exhibit "B" attached and incorporated herein by reference. 11. The Respondent is able to competently read and write in the English language to the best knowledge, information, and belief of the Petitioners. 12. The Petitioners sets forth the following suggested advertisement for publication in any newspaper of general circulation as may be ordered by the Court: See Exhibit "C" attached and incorporated herein by reference. 13. The Petitioners believe service of notice of the action by posting the same on the premises in question for a reasonable period of time would be the sorest way to engender a response, because the Defendant or one of his agents would need to appear at the premises to properly maintain the house and grounds to the satisfaction of the Municipal Code. 14. The Petitioners know of no other method of service of process, which would have a better chance of actual notification of the action. WHEREFORE, the Petitioners, Christianne Snyder-Teets and Alton E. Teets, respectfully request permission to serve the Respondent, Robert Miller, by posting conspicuous notice on the premises for sixty (60) days, and by advertising a notice of the action once each in the Harrisburg Patriot-News and the Cumberland County Law Journal within thirty (30) days thereof; and, if the Defendant has not responded within sixty (60) days of the date posting on the premises, that proper service be deemed to have been made upon the Respondent, and permitting the Petitioners to pursue the proceedings without further petition to this Court regarding service of process. Date: Res%~~ed, Matthew J. Eshelman, Esquire Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 72655 Tel. (717) 763-1800 CHRISTIANNE SNYDER-TEETS and ALTON E. TEETS, Plaintiffs V. ROBERT MILLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-162 CIVIL ACTION - EQUITY ACTION TO QUIET TITLE V~RIFICATION I verify that the statements made in this Pursuant to Special Order of Court are true understand that false statements herein are penalties of 18 Pa. C.S. Section 4904, falsification to authorities. Petition to Serve and correct. made subject to the relating to unsworn ~hris~ianne S~der~ee~s Date: ~/~/~/ II CHRISTIANNE SNYDER-TEETS and ALTON E. TEETS, Plaintiffs ROBERT MILLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-162 CIVIL ACTION - EQUITY ACTION TO QUIET TITLE /%FFIDAVIT We, Christianne Snyder-Teets, and Alton E. Teets, Plaintiffs, state that to the best of our knowledge, the Defendant, Robert Miller, IN WITNESS WHEREOF, is not in any military service at the present I set my hand and seal this 2001. time. ~ day Sworn to and subscribed to before me this ~ day of 2001. ~otar¥ E'ublic Notarial Seal Shelby A, MInlch, Notary Public ! Camb H~II Bom, Cumberland County My Commission ExpIresAug 20 2001 ~t~'~ '. .... ' ..: ' i' CHRISTIANNE SNYDER-TEETS and ALTON E. TEETS, Plaintiffs ROBERT MILLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-162 CIVIL ACTION - EQUITY ACTION TO QUIET TITLE PRAECIPE TO ENTER DEFAULT JUDGMENT TO: THE PROTHONOTARY OF CUMBERLAND COUNTY Date: Please enter judgment against the defendant in the above-captioned matter, Robert Miller, on the issue of liability for failure to response within the~requked time anAmswer to the action to quiet title which contained a notice to defend. I II~t~ [~1~ ,. t Pursuant to Pennsylvania Rules of Civil Procedure,~xRuie 237.1,nwrittgn notice of the plaintiffs intention to file this praecipe for entry of default judgment was mailed to the party against whom judgment is to be entered, Robert Miller, at~er the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the Notice i~, attachedhereto as Exhibit "A" and incorporated herein by reference, aa3 o~. F~,~o,~ol ,~ia~ ¢er¢ i e~. Respecl fully submitted,~'~'~'-- Matthew~ Eshe man, Esquire Law Offices ofPgtfick F. Laner, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 72655 Tel. (717) 763-1800 Exhibit A CHRISTI~NNE SNYDER-TEETS and ALTON E. TEETS, Plaintiffs ROBERT MILLER Defendant IN THE COURT OF COMMON PLF~%S OF CUMBEPJ~AND COUNTY, PENNSYLVANIA NO. 01-162 CIVIL ACTION - EQUITY ACTION TO QUIET TITLE ORDER kND NOW, this ~ ~ day of /~u/~/ 2001, it is hereby Ordered and Decreed that the Petitioners, Christianne Snyder-Teets, and Alton E. Teets, are permitted to attempt service upon the Respondent, Robert Miller, in the above-captioned action to quiet title by conspicuously posting a notice on the premises in question at 95 Kensington Drive, Lower A~len Township, Cumberland County, for a period of sixty (60) days; and by advertising a notice of the action once within 30 days of posting notice on the premises in the legal publication designated for the publication of legal notices, and once in one newspaper of general circulation, within Cuadoerland County. If the Defendant has not responded within sixty (60) days of posting notice on the premises, proper service will be deemed to have been made upon the Defendant, and the Petitioners may pursue the proceedings without further petition to this Court regarding service of process. BY THE COURT: m T~timo~y w~, I here u~ and t~ ~ ~ ~ ~ ~ CHRISTIANNE SNYDER-TEETS and ALTON E. TEETS, Plaintiffs ROBERT MILLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-162 CIVIL ACTION - EQUITY ACTION TO QUIET TITLE AFFIDAVIT OF SERVICE ~n~I, Shelby MSn$ch, being duly sworn, state that on this day of OC~ , 2001, did serve upon Robert Miller, in compliance with the Pennsylvania Rules of Civil Procedure, the foregoing Complaint and Notice in the manner indicated below: Service bv mostin~ on the premises located at: 95 Kensington Drive Lower Allen Township Cumberland County Notar[ze~ on this% i~ day of Notary Public ' ~ Commihon Exp ires Member, Penn~/t~ A~ o~ ~ 2001 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, lg2g Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the }aws :he Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The ~day Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the , County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 4, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in regular daily and/or Sunday/ Metro editions which appeared on the 8th day(s) of November 2001. That neither or said Company is interested in the subject matter of said printed notice or advertising, and that all of the ations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this merit on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and /ed severally by the stockholders and board of directors of the said Company and subsequently duly recorded in ffice for the Recording of Deeds in and for said Courtly of Dauphin in Miscellaneous Book "M", 'ne 14, Page 317. BLICATION COPY Mercier, PennsyNanla Association of Notarl~y commission expires June 6, 2002 LAW OFFICES OF PATRICK LAUER 2108 MARKET STREET, AZTEC BUILDING CAMP HILL, PA. 17011 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ 139,16 $ 1.5o $ 140,66 Publisher's Receipt for Advertising Cost ., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general receipt of the aforesaid notice and publication costs and certifies that the same have PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz NOVEMBER 9, 2001 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are SWORN TO AND SUBSCRIBED before me this 9 day of NOVEMBER, 2001 Notary ~ NOTARIg& SEAL LOIS E. Sgi~'~ER~ No~ Public CUMBERLAND LAW JOURNAL Ln the Court of Cortnnon Pleas of Cumberlmud County. Pennsylvania Civil Action--F~q~ity No, 01-162 CHRISTLM~NE SNYDER-TEETS and ALTON E. TEETS. Plaintiffs ROBERT MILLER, Defendant ACTION TO QUIET TITLE NOTICE: To Robert Miller You have bc~n sued for action to quiet title by the Plaintiffs, Christi- anne Snyder-Tects. and Alton E. Teets, on the grounds of fraudulent inducement. If you wish to defend. you must enter a written appearance personally or by attorney and file your defenses or objections in writ- lng with the Court. You are warned that if you fail to do so the case may proceed with- out you and a Judgment may be en- tered against you without further notice for the relief r~quested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PA- PER 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 BAN ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 {717} 249 3166 Nov. 9