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Home My WebLink About10-2146r 10 SMIGEL, ANDERSON & SACKS, LLP Peter M. Good, Esquire River Chase Office Center I.D. No. 64316 4431 North Front Street, 3rd Floor Roger M. Morgenthal, Esquire Harrisburg, PA 17110-1778 I.D. No. 17143 (717) 234-2401 Attorneys for Plaintiff PENNDEL LAND COMPANY, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. No. It) - a14(.0 1,iv I TPa-m a n 6044 DENVER ASSOCIATES, LP, CIVIL ACTION - LAW c ? , Defendant. PRAECIPE TO ENTER AND INDEX LIS PENDENS c :' ? , .`. CJ am , TO THE PROTHONOTARY AND RECORDER OF DEEDS: Please enter and index the above-captioned case as a Lis Pendens against the property and premises located in South Middelton Township, County of Cumberland and State of Pennsylvania, recorded in Plan Book 273, page 2602, Parcel Identification No.: 10-0636-001, with a legal description as follows: BEGINNING at a point and a PK Nail set in the centerline of Petersburg Road (SR 2001) and continuing along lands now or formerly of James E. and Linda C. Jones, North 82 degrees 40 minutes 49 seconds East for a distance of 347.47 feet to a iron pipe; thence along lands now or formerly of Leonard R. and Vickie E. Boyles, North 80 degrees 43 minutes 02 seconds East for a distance of 828.53 feet to a iron pin; thence along lands of Easter Development and Planning, Inc., South 78 degrees 38 minutes 25 seconds East for a distance of 1,104.65 feet to a iron pin; thence along lands now or formerly of Charles G. Kish and continuing along lands of others in a Development known as Forgedale, South 04 degrees 43 minutes 33 seconds East for a distance of 1,586.00 feet to a iron pin; thence along lands now or formerly of the Pennsylvania Conference Association of Seventh Day Adventists, North 88 degrees 48 minutes 33 seconds West for a distance of 898.57 to a iron pin; thence along lands now or formerly of Ronald J. Ocker, North 00 degrees 06 minutes 02 seconds East for a distance of 754.48 fee to a iron pin; thence along lands of the same, North 88 degrees 30 minutes 07 seconds West for a distance of 576.03 feet to a iron pin; thence along lands now or formerly of James O. and Mary E. Houston, North 06 degrees 22 minutes 14 seconds West for a distance of 454.18 feet to a iron pipe; thence along lands of the same, South 81 degrees 29 minutes 51 seconds West for a distance of 402.80 feet to a iron pip; thence along lands now or formerly of Ronald E. Mell, Jr., North 06 degrees 13 minutes 27 seconds West for a distance of 400.00 feet to a T-Rail; thence along lands of the same South 81 degrees 12 minutes 17 seconds West for a distance of 400.00 feet to a point in the centerline of Petersburg Road and passing through an Angle Iron place 15 feet from the point of termination; thence continuing through the centerline of Petersburg Road, North 08 degrees 34 minutes 57 seconds West for a distance of 104.94 feet to a point and the place of BEGINNING. BEING the same premises which Penndel Land Co., a Delaware corporation, by Deed dated 2/28/2006 and recorded 3/13/2006 in Cumberland County in Record Book 273 page 2602, conveyed onto 6044 Denver Associates, a Pennsylvania limited partnership, in fee. Respectfully submitted, Date: aS P?nndel LaM Cm pan y '10 VISiu, Dr Red Lion , PA 1735(0 l 044 'Denver Assoc. , LP 44 HerahoL Dr FTL C?, PA I'1 l oa, SMIGEL, ANDERSON & SACKS, L.L.P. By: Pet M. Good, Esquir I.D. Number: 64316 Roger M. Morgenthal, Esquire I.D. Number: 17143 River Chase Office Center 4431 North Front Street Harrisburg, PA 17110-1778 (717) 234-2401 Attorneys for Plaintiffs $ 99.50 P 0 ATM coat* (00+/ 2-Wo31 F" )39,7a9 ?)o4,,'& UuUd SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp SOiiCltOr ~~,~~~ts, ~,t ~n~rit~Frf~~~ 1- _.cr _ r F -~.c "~tilF~ ~~~G.l L "~'ry~~{~ ~~ ~,:r t t ,, ~ ~ . . LU ~ U ~ ~\ ~ L ts~~l ~~' L1 { ~J~~Y ^~-. tAil ~~• r F ~ .h. . Penndel Land Company vs. 6044 Denver Associates, LP Case Number 2010-2146 SHERIFF'S RETURN OF SERVICE 03/31/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: 6044 Denver Associates, LP, but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Perry County, PA to serve the within Praecipe to Enter and Index Lis Pendens according to law. 04/05/2010 Perry County Return: And now April 5, 2010 at 1120 hours I, Jack Lotwick, Sheriff of Perry County, Pennsylvania, do herby certify and return that I served a true copy of the within Praecipe to Enter and Index Lis Pendens, upon the within named defendant, to wit: 6044 Denver Associates, LP by making known unto Dana Thompson, Paralegal for 6044 Denver Associates, LP at 44 Hersha Drive, Harrisburg, PA 17102 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.44 April 08, 2010 SO ANSWERS, t~ RON R ANDERSON, SHERIFF q) CountySuite ShenfiT~. Teieoso?i, Inc. Mary Jane Snyder Real Estate Depu William, T. Tully Solicitor ~' ~ Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin PENNDEL LAND COMPANY VS 6044 DENVER ASSOCIATES LP Sheriff s Return No. 2010-T-0937 OTHER COUNTY NO. 102146 And now: APRIL 5, 2010 at 11:20:00 AM served the within PRAECIPE FOR LIS PENDENS upon 6044 DENVER ASSOCIATES LP by personally handing to DANA THOMPSON 1 true attested copy of the original PRAECIPE FOR LIS PENDENS and making known to him/her the contents thereof at 44 HERSHA DRIVE HARRISBURG PA 17102 PARALEGAL Sworn and subscribed to So Answers, before me this 7TH day of April, 2010 ~~~~~~ NOTARIAL SEAL MARY ?ANE SNYDER, Notary Public Highspire, Dauphin County M Commission Ex ire Se t 1, 2010 Sheriff o auphi C nt3c,. P . By Deputy Sheriff Deputy: R HOPKINS Sheriff s Costs: $41.25 4/2/2010 In The Court of Common Pleas of Cumberland County, Pennsylvania Penndel Land Company vs. 6044 Denver Associates, LP 44 Hersha Drive Harrisburg, PA 17102 Civil No. 2010-2146 Now, March 31, 2010, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~~ Sheriff of Cumberland County, PA,. Now, within upon at by handing to a and made known to Sworn and subscribed before me this day of ,20 copy of the original the contents thereof. So answers, Sheriff of COSTS SERVICE_ MILEAGE_ AFFIDAVIT County, PA Affidavit of Service 20 , at o'clock M, served the