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Home My WebLink About02-0092IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Ticor Title Insurance Company, on behalf of Raymond Magaro and ThereSa A. Magaro (nee Long), Plaintiffs, : Complaint - Civil : Docket No. d).9.. - John Scarer (aka John Sierere, John Sierer, : Action to Quiet Title John Seirer); : Jacob Remminger (aka Jacob R. Remminger, : Jacob Renninger, Jacob R. Renninger); : Lillie Renninger (aka Lily Renninger, : Lillian Renninger); : Jacob Milton Renninger (aka Milton Renninger);: their heirs and assigns, : Defendants : NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth on the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Ticor Title Insurance Company, on behalf of Raymond Magaro and Theresa A. Magaro (nee Long), Plaintiffs, John Searer (aka John Sierere, John Sierer, John Seirer); Jacob Remminger (aka Jacob R. Remminger, Jacob Renninger, Jacob R. Renninger); Lillie Renninger (aka Lily Renninger, Lillian Renninger); Jacob Milton Renninger (aka Milton Renninger);: their heirs and assigns, : Defendants : Complaint - Civil Docket No. Action to Quiet Title COMPLAINT TO QUIET TITLE NOW COMES, Ticor Title Insurance Company, on behalf of their insured Raymond L. Magaro and Teresa A. Magaro, nee Long, through its counsel Dilworth Paxson LLP, pursuant to Pa. R.C.P. 1061((b)(2), to quiet title to a certain tract of land located in East Peunsboro Township, Cumberland County, Pennsylvania, known as 121 Salt Road (the "Property"). The Property in question belonged in the distant past to one or more of the above-named defendants, their heirs and assigns. In support of this action, Ticor Title states the following: 1. Ticor Title Insurance Company is a title insurance company located at 711 Third Avenue, 5th Floor, New York, NY 10017. 2. Ticor Title Insurance Company issued a commitment for title insurance dated March 6, 1995 and ultimately a policy to Raymond L. Magaro and Theresa A.Magaro (nee Long), as owners of the Property and Members 1 st Federal Credit Union, as Mortgagee. 3. As of this date, Raymond L. Magaro and Theresa A. Magaro (nee Long) are the fee simple owners as tenants in the entirety of the Property in accordance with deeds recorded in Book 189 page 1139 (attached as Exhibit A) and Book 119 page 835 (attached as Exhibit B). 4. Raymond L. Magaro and Theresa A. Long purchased the Property on March 15, 1995 as evidenced by the deed attached as Exhibit A. On December 22, 1997, as evidenced by the deed attached as Exhibit B, the Property was conveyed by Raymond L. Magaro and Theresa A. Long to Raymond L. Magaro and Theresa A. Magaro, husband and wife. Other than to change the form of ownership to tenants in the entirety, there are no differences between Exhibits A and B. 5. On or about December 22, 1997, the Property was being refinanced. The title search performed by Lawyers Title Insurance Corporation at that time identified exceptions to title insurance coverage which had not been raised in the prior policy issued by Ticor Title Insurance Company. 6. The interests identified which may present a cloud to the title to the Property of Raymond L. and Theresa A. Magaro (nee Long) are: 1) the outstanding interest of John Scarer, (aka Sierere, Sierer, Seirer) his heirs and assigns; 2) the outstanding interest of Lillie Renninger (aka Lily or Lillian) her heirs and assigns; 3) the outstanding interest of Jacob Remminger (aka Jacob Renninger, Jacob R. Renninger and Jacob R. Remminger) his heirs and assigns; and 4) the outstanding interest of Milton Renninger, (aka Jacob Milton Renninger) his heirs and assigns. 7. The Property is described in the deed attached as Exhibit A from Joseph W. Intrieri to Raymond Magaro and Theresa A. Magaro (nee Long) as being: All that certain lot or parcel of land situate in the Township of East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, being shown as Lot No. 1 on a Final Subdivision Plan for Elizabeth D. Intrieri and Louis J. Intrieri, prepared by Hartman & Associ., Inc., dated January 14, 1992, last revised February 26, 1992 and recorded in Subdivision Plan Book 64, page 63, more particularly bounded and described as follows: BEGINNING at an iron pin on the western line of L.R. 21074 and at the southeast comer of Lot No. 1 on the hereinabove mentioned Plan of Lots; thence South 25 degrees, 5 minutes West by lands now or late of D.W. Foltz, 269.43 feet to an iron pipe; thence by Lot No. 2, North 23 degrees 54 minutes 50 seconds West, 374.3 feet to an iron pin on the southern line of a 15 foot wide private right-of-way; thence by southern line of said right-of-way, North 71 degrees 43 minutes East, 159.9 feet to a concrete monument on the western line of L.R. 21074; thence by the western line of L.R. 21074, South 37 degrees 35 minutes East, 187.12 feet to the point and place of BEGINNING. 8. The chain of title to the Property at issue begins in 1859 with a deed to a tract of land including the Property recorded in Deed Book 2K page 530, transferred from Jacob Lantz, Executor of the estate of Philip Lantz, (Grantor), to Jacob C. Kling, (Grantee).(Copy attached as Exhibit C). Kling then conveyed the land including the Property, by deed recorded in Book 3A page 541, to John Searer in 1869. (Copy attached as Exhibit D). Scarer and his wife (also spelled Sierere) conveyed land including the Property in 1871 to Jacob R. Remminger. Fannie Bretz became the owner of the land, including the Property, in 1940 or 1941, through either a will from the heirs of Jacob Remminger (Exhibit E) or by a deed issued by Jacob R. Renninger, recorded in deed Book 12 J 586. (Exhibit F). Fannie Bretz then conveyed a portion of the land, including the Property, to David W. Foltz by deed recorded in Book 130 page 358 (Exhibit G). Foltz, in turn conveyed a portion of the land to Margaret Schreiner recorded in Book 15G page 67. (Attached as Exhibit H). The Foltzs and Schreiner then conveyed their entire holdings, including the Property, to Luigi F. Intrieri and his wife. The estate of Elizabeth Intrieri conveyed the Property, which was one lot of the Plan of Lots recorded in Plan Book 64, page 63, to the Magaros. 9. The chain of title to the Property became uncertain during the period of time between 1869 and 1941. 10. First, the name of John Searer was spelled differently in various legal documents including deeds, nuptial agreements, and estate documents. When Mr. Searer conveyed the tract of land including the Property in 1871, the name of the grantor was spelled "John Sierere", instead of Searer. The name of the grantee was spelled Jacob R. Remminger. 11. In other legal documents in around the same time frame, the name John Searer is spelled in a variety of ways, as is the name of his wife. However, in a deed dated in 1872, property was conveyed to John Kauffman, by a grantor with the spelling of "John Seirer" believed to be the same individual as John Searer. The recital of the conveyance of the property from Kling to Searer in the deed to Kauffman spelled the name of the grantee as "John Sierer". In an agreement dated in 1870 in contemplation of marriage, the name was spelled John S. Sierer and his intended wife was identified as Elatta J2 Ghere. In 1884 when that prenuptial agreement was nullified by a second agreement, the names were spelled "John S. Seirer" and "Elatta J. Seirer". However, in the entry of the record the names were recorded as "John S. Siere" and Ellata J. Seirer, nee Elatta J. Ghen. These variations in spelling are due to transcription errors and there is no doubt that there was only one John Scarer married to a women named Elatta in the chain of title, regardless of the correct spelling of the name. 12. The name Jacob R. Remminger is also spelled differently in various legal documents. I.n later deeds, and in documents related to his estate, his name is spelled Jacob R. Renninger. 13. Jacob R. Renninger is referred to as "Joseph" on one occasion in the recital of a deed dated in 1946 from Fannie S. Betz, grantor, to Warren J. Harder, grantee, but Mr. Renninger is also referred to as Jacob within that same recital. 14. In addition to various spellings of the names of the Scarers and Jacob Renninger which appear to be due to transcription errors, the title is further clouded by the fact that Jacob Renninger died intestate in 1903, apparently leaving two heirs by the name of Milton Renninger and Lillie Renninger. 15. Lillie Renninger died intestate in 1938. It appears that Lillie had no heirs other than Milton. 16. Milton, as the sole survivor would have had an ownership interest in the property of Jacob Renninger, his father. A Last Will and Testament of Milton Renninger bequeaths ail his property to Fannie Bretz. Milton's will was dated in 1933 and was signed by both Milton and Lillie Renninger. Milton's will indicates that his entire interest in the Property was to be left to Fannie Bretz. Milton Renninger died in 1941. 17. Milton Renninger also has been identified in some documents as Jacob Milton Renninger. 18. There is a deed from Jacob R. Renninger dated in 1940 to Fannie S. Bretz recorded in Deed Book 12 J 586. The recital explains that it is the same property conveyed by Jacob Kling to "John Siere". This deed is particularly confusing because other documents confirm that Jacob R. Renninger died in 1903, the property passing to Milton and Lillian. If Milton Renninger's full name was Jacob Milton Renninger it is likely that the deed in 1940 was mistakenly made out in the name of Jacob R. Renninger. 19. It appears that Fannie S. Bretz became the lawful owner of a larger parcel of land which included the Property either through the Last Will and Testament of Milton Renninger upon his death in 1941 or through a conveyance in 1940. 20. Fannie S. Bretz conveyed the larger tract including the Property to David W. Foltz and Margaret Schreiner in 1947 and in 1953 the larger tract of land including the Property was conveyed to the Intrieris and from there to Theresa A. Magaro (neeLong) and Raymond L. Magaro. 21. The various spellings of the name of John Searer (Sierer, Seirere,) and his wife, the name Jacob Remminger (Renninger), the question of the existence of natural heirs to Lillie Renninger and Milton Renninger, and the identity of Jacob R. Renninger in the deed dated 1941 to Fannie Bretz may cloud the title to the Property currently owned by Raymond Magaro and Theresa Magaro (nee Long). WHEREFORE, for the above stated reasons, it is requested that the above named defendants be forever barred from asserting any right, lien, title or interest in the Property inconsistent with the interest or claim of Raymond Magaro and Theresa A. Magaro (nee Long). Respectfully submitted, Dated: January 4, 2002 Linda C. Smith - I.D. #35868 Joseph F. Kessler - I.D. #37411 Victor P. Stabile - I.D. #37449 Dilworth Paxson, LLP 305 North Front St, Suite Harrisburg, PA 17101 (717) 236-4812 4O3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Ticor Title Insurance Company, on behalf of Raymond Magaro and Theresa A. Magaro (nee Long), Plaintiffs, John Searer (aka John Sierere, John Sierer, John Seirer); Jacob Remminger (aka Jacob R. Remminger, Jacob Renninger, Jacob R. Renninger); Lillie Renninger (aka Lily Renninger, LiHian Renninger); Jacob Milton Renninger (aka Milton Renninger);: their heirs and assigns, : Defendants : Complaint - Civil Docket No. Action to Quiet Title Be it known that Ticor Title Insurance Company, on behalf of Raymond Magaro and Theresa A. Magaro (nee Long) of 121 Salt Road, East Pennsboro Township, Cumberland County, Pennsylvania has filed a complaint to Quiet Title to the property at 121 Salt Road, East Pennsboro Township, against any interest of John Searer (aka John Sierere, John Sierer, John Seirer); Jacob Remminger (aka Jacob R. Remminger, Jacob Renninger, Jacob R. Renninger); Lillie Renninger (aka Lily Renninger, Lillian Renninger); Jacob Milton Renninger (aka Milton Renninger);their heirs and assigns. NOTICE 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 by the court 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. 1F 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. PENNSYLVANIA BAR ASSOCIATION LAWYER REFERRAL SERVICE P.O. Box 1086 100 South Street Harrisburg, PA 17108 PA Residents Phone: 1-800-692-7375 or (717) 238-6715 LINDA C. SMITH, ESQ. DILWORTH PAXSON LLP Attomeys for Plaintiff 305 N. Front Street, Suite 403 Harrisburg, PA 17101 717-236-4812 Exhibit A PA WARRANTY ~EED Tax Map #09-14-0835-221 :'! ' ~ :';.;i i~ OF i)!!5D5 , . U, L _ ,., SOU!11'~,' '9'! DE,'. Z5 ?11 1 ZZ~J dayof,.,//",~.-.,.,/~,', 1997 RAYMOND L. MAGARO and TERESA A. MAGARO, formerly known as TERESA A. LONG, husband and wife herein designated as the Grantor(s). RAYMOND L. MAGARO and TERESA A. MAGARO, husband and wife herein designated as the Grantee(s); ]~lhlZlsffZt~. That in consideration of ONE AND 00/100 .................................... ($1.00) Dollars, In hand paid, the receipt whereof is hereby acknowledged, the said grantor(s) do(es) hereby grant and convey to the said grantee(s), /%~J THAT CERTAIN lot or parcel of land situate in the Township of East Pennsboro, County of Cumberland and commonwealth of Pennsylvania, being shown as Lot No. I on a Final Subdivision Plan for Elizabeth D. Intrieri and Louis J. Intrieri, prepared by Hartman & Assoc., Inc., dated January 14, 1992, last revised February 26, 1992 and recorded in Subdivision Plan Book 64, Page 63, more particularly bounded and described as follows= BEGINNING at an iron pin on the western line of L.R. 21074 and at the southeast corner of Lot No. I on the hereinabove mentioned Plan of Lots; thence South 25 degrees, 5 minutes West by lands now or late of D.W. Foltz, 269.43 feet to an iron pips~ thence by Lot No. 2, North 23 degrees 54 minutes 50 seconds West, 374.3 feet to an iron pin on the southern line of a 15 foot wide private right-of-way~ thence by southern line of said right-of-way, North 71 degrees 43 minutes East, 159.9 feet to a concrete monument on the western line of L.R. 21074~ thence by the western line of L.R. 21074, South 37 degrees 35 minutes East, 187.12 feet to the point and place of BEGINNING. IMPROVED with a one story brick dwelling known as 121 Salt Road. BEING THE SAME PREMISES which Joseph W. Intrieri, Executor of the Estate of Elizabeth D. Intrieri, deceased, conveyed unto Teresa A. Long and Raymond L. Magaro by deed dated March 15, 1995 and recorded March 15, 1995 in the Reoorder's Office in and for Cumberland County, Pa. in Record Book 119, Page 635. This conveyance is between husband and wife, therefore it is tax exempt. i~a~ the said grantor(s), do(es) hereby conveyed. specially the property hereby ~h '~ttn~ss llIIt~rguf, ~aid grantor(s) ha Ve year first above written. hereunto set their hand and seal(s) the day and On this, the ZZn~ayof ~e~*~ 1997 the undersigned o~cgr, ptr;onalO appeared ~YMOND L. ~G~O and TERESA A. ~GARO, formerly known as TERESA A. LONG, hueband and wife known to me (or ~atisfactorily proven) to be the person(s) whose name(s) are subscribed to the within instrument, and acknowledged that t he y executed the same for th: purpose therein contained. ~n ~I{Iig~S ~grg~f, I have hereunto set my hand and notarial seat. Exhibit B '~;. 15 th day of Maz'~h 1995 ~[[Ug~[1 JOSEPH W. INTRIERI, EXI~CUTOR of the Estate of ELIZABE7~t D. INTRIERI, deceased, (he~elnufler called lhe G~inlor/s), of Ihe OhO parl and TE~SA A. ~ and ~D L. ~ (her~inafler called th~ Grants,Is), of Ihs other part, tlllitn ail!That in con~deration or ONE HUND~DTH1Kn:;I:;N THOUSAND AND 00/100 ($113,000.00) Dollan, Grantee/s, andasslBns, ALL ~HAT CERTAIN tract of land situate in East PennsborO Township, Cumberland County, Pennsylvania more particularly described as follows, to wit: BEGINNING at an iron pin on the western line of L.R 21074 and at the southeast corner of Lot No. I on the hereinafter mentioned Plan of Lots; thence South 25 degrees, 5 minutes West by lands now or late of D.W. Foltz 269.43 feet to an iron'pipe; thence by Lot No. 2 North 23 degrees 54 minutes 50 seconds, West 374.3 feet to an iron pin on the southern line of a 15 foot wide private right-of- way; thence by southern line of said right-of-way North 71 degrees 43 minutes East 159.9 feet to a concrete monument on the western line of L.R. 21074; thence by the western line of L.R. 21074 South 37 degrees 35 minutes East 1~7.12 ' feet to the point and place of BEGINNING. ~. BEING Lot No. 1 on the Plan of Lots recorded in Plan Book 64, Page 63, and improved with a one story brick dwelling known as 121 Salt Road. BEING part of the same premises which David W. Foltz et al by Deed dated December 14, 1953 and recorded in Cumberland County Recorder's office conveyed to Luigi F. Intrieri and Elizabeth D. Intrieri; said Luigi F. Intrieri predeceased said Elizabeth D. Intrieri whereby she became the sole owner by her right of survivorship as a Tenant by Entireties; said Elizabeth D. Intrieri died testate on June 28, 1994 with her Last Will and Testament being probated by the Register of Wills of Cumberland County on July 11, 1994 and Letters Testamentary issued to Joseph W. Intrieri, the Grantor herein. SAID PREMISES are conveyed together with an easement to use the 15 foot wide right-of-way which bounds the said premises on the North in common with others and subject to the maintenance provisions of the right-of-way agreement dated March 14, 1995 between the owners of the lots on the above Plan of Lots which is to be recorded herewith. UNDER AND SUBJECT to the Acts of Assembly, County and Borough Ordinances, rights of Public Utility and Public Service Companies, existing restrictions and easements, visible or of record, to the extent that any persons or entities have acquired legal rights thereto. SAID PREMISES are furthe~i~s3~y~~ct t~ r~parian rights of others in tho stream wh~°SM~]~ pr~mt'S~s, ths~S~nitary sewer easement and set b.~i~he~s~own o s d Plan ~f = 'Lots. RECORDEi{OF DEEDS ¢;UI.IBERLAllD OOUNT¥' PA '.95 lfli 1,'! 1 )OB ..~1]~ lite said Granlor/s do/do~s hereby convenanl Ia and with lhe said Gramea/s Ihat he , the said Gr. mor/s s~cially SHALL ~D WILL , Warrant and ~or~ver De~eod lira he,gin above described premises, with lbo hereditamonts and appurtenan~s, unto the aid Orantoo/s and ussig.~, against the said Orantor/s and against every othetperson lawfully clal~n8 or who shall herenl~er claim the ~me ur uny pan thereo~, by, frum or unde~ ~ or nny of them. IN WI~SS WIIEREOP, the ~ld Gmntor/s bus/bare cau~d these pre~nts lo be duly executed, the day and year first above wrilte~. Sealed and Delivm'ed in Ihe presence of: ESTATE OF ELIZABETH D. INTRIERI (Seal) (Seal) Cummo.wuuhh ofl'emtsylva.ia: Coullly of : O. Ihis, lite day of 19 , before me, lhe undersigned ofllcer, personally .ppeured who ackoowiedged himself/herself Ia be tho o~ a corpornlion, end thai he/she ns such . beln~ aulborized Io do so, oxeculed lbo ~ore~oln~ Inslrm~m ~or tim purpose Ihe~eln co.lalnod by ~i~.ing Iht fl~me of the cor~ralio~ by hlmsellTIler~[f as Notary Public Commoil'.vcaJlll of Pennsylvania: County of Cumberland : Off Ihis, tile 15thday of M~t~h 19 95 , before me, lite underslBned o~lcer, personally appeared JOSEPH W. I~RIERI, ~tor of t~ Estate of Eltza~th D. Intrieri k~ow. ~o me (ur ~lisfacmrlly proven) to b~ the parson/s who~ name/s ~n~ sub~ibed to the will~n instrument and acknowledged dml he/she/they execuled tim ~me for tho purport Iherein contained. i--C) 119 P, CE 836 Exhibit C Exhibit D Exhibit E TLird.All the remainder of my estate after the naymente above prov~tded for, I give and Bequeath :nrc rynenhew, N. Orr Mc:eels ;,nd iFourth, I h~reby nomin lend Testament. In Witness ~oreof, I, 123rd da~ of Au&uet, 1932. gc~cels, hie ,'ire, of Carlisle, Pennsylvania, absolutely. constitute :,nd :,npoint my Said nephew, l~. Orr ~ckote, nes Eckele, the Testatrix, have to thie, my laet I Signed, eenled, published ~.nd I Testament, in the preeence of us, i in the presence of eaid Testatrix and mmecutl of this my last Will set my hand a~d eeal tht~ lared by the above named Sara Agnes have hereunto eubscribmd our eeeh other. ne8 gckels (coal.) ae and for her lest Will and s at her request as witnesses theretc, ~err[ll F. Hummel C. D MacGregor TBt~ llth d~:! of A:)l:ust A. D., 1921, before me letters of Administration in ~nd for 'c~e Merrlll F. Hummel :~nd C. D. M~cOre;ror the ~puroortlng to be the last Will ~d Pa. , deceased who Being d~ly sworn the testatrix, ~sfa ~es gckels ~and for her Testament and Last Will and ~derst~ding, to the Best Lost "ill and Testament of ~:ilton Renninger, deceaeed tO law, puhlieh~: at the time of so knowledge, observation Sworn and subscribed before this llth da.v of Au[:uet, Lloyd A. Bender, Register !BE IT RE~:.~:BERED th~',t the llth dey of August, A. D., 1921, Before was probated the 1~ v,~ll ~,.nd t~wtsment of Sara A~es Eckels, late of :enn~ylvani~, :!~d: ;~nd on th~ ~me d~v wer~ i~eued theron letters within named~ecutor. 5mid decedent died on Thured~, the 7th d~v of Aurar , . ~- · ,, .... ~Rav~t o~ death filed according to law. Bender. Register for the Probate of ~llle and granting Cumberland,in the ~ommonwenlth of Menneylvania, personally LBing witneeses to the foregoing inetrument of writing ~ckell Dated August ~}, 19}~, late of Mechan&ceBurg, ee ~ud mmy.th&t~th~y were prmemnt¥ and eaw and heard ~ce amd declare the said Instrument of writing as she ~an of ~o~d ~d ~ilpo~lng mlnd, memory belief. Merrill F. B~al C. D. M~Oregor A. Bender, Regieter, etc., Cumberland County. mtary to N. Crt gckele, the ~ D., 19~1, at or about Laet Will and Testament of Milton l~enninger there look to conduct our burialf after ge. rck $. 1933 To any one it me.v con~ern~ we want F~nnie S. Brets have the eay and prive..lege everyth~,-,g, pa.v our funeral expenses, fix up all Business c6ncerning our affairs. We want no one on either side IUlley orRgnninger to miss ~udge or doubt her word as Frmnie S. Bretz has nursed us when ill'j fe_~l us for many yeers stood by ue through those years At our death we want Funnie S. Bretz to settle up, cay ell persons who i h~ve leagle pa~Ders %o she- ageinet ~ts. Everthin~ in the hous~, in the barn and surrounding b~.~lldings in w,,ich we heys stnred our Belongings at de~th Fannie S.' Brets will arrange and dispose ne ehe sees fit. After death anything belonging to us she F~nnie S. Bretz may claim aa her own. Any thing that we should inherit after nut d.: th she Fannie $. Bretz or her [!rs ~hstl receive. All back ts: es if any at our death shall be taken off the est~,t, f, nd not charged to .nythin~ Fannie S. Bretz may ps,ese or have deeds tel We want our possessions to belnn~ to F'nnie S. Bretz as our entire living depended meetly on her such as Clothing, Food, and other - Fannie $. Brets t f needed for naceeeary debts to sell everything except ~9 acres of land and Bull desth we want : ings of our h~mestend wh ch is to B. her reeidene_e or de_spoee (continu%d,~on Dn~e 127 ) of whenever she Fannie $. Brets Witnessed ~vel~m L. Kreiger ~lldred Stahl Sh~,ffer T.i; lltb day of Angst sees fit. Lillie Renninger Milto~ RennXnger A, D., 1941, before me Lloyd A. Bender, Register for the Probate of Wills and ~;ranting ~letters of Administration in and for enid Co~u~ty of ~umberl~d, in the Commonwealth of Penns lvania personally ,.~.me Evelyn L Kreiger and Mildred Stahl Sheller the subscribing witnesses to the foregoing ins~ment of writing purporting to be the l~t Will ~d Test~Ant of ~iltonRenninger Dated Ma'ch ~ - 193~ late of East Penn- ;shore T~ - ~mb Co - Pa, deceased who being d~Y sworn according to law, depose ~d say, that they were ' ,resent, ~d saw ~d he~ the testator, ~ilton Renninger si~ seal, publish, prono~ce ~d declare the said .nst~ent of writing as ~d for h~o Test~ent ~d Last Will, ~d at the time of so doing he was of so~.d dispo~ing mind, memo~ ~d ~derat~ding, to the Best of their knowledge, observation and belief. Evelyn L. Kreig~r Sworn ~d subscribed before me this llth d~ of ~et, 19gl Mildred St~l ~haffer Lloyd ~. Bender, Register ~ IT ~BE~D t~t on the llth day of A~st, A, D., 19bl, before me, Lloyd ~. ~ender, Register, etc., there~ probated the last will ~d testmment of ~ilton Renninger, lets of East pennsboro T~., Cumberl~d County, Penn~ylv~ia, deceased: ~d on the s~e d~ were issued thereon letters' testamentary to F~nny S. Brats, the ~.lthin n~ed executrix. Said decedent died on Frid~ the ~th d~ of July, A. P., 19~1, at or .bout ~:OO o'clock, '.See ~,fftds"lt of de,th filed ,..ccordinE to law. Last "ill a,,d Testament of William Edwin t~iller, deceased ~aet Will and Test~ent of William Edwin Miller I'; William Edwin Miller, of the Borough of Carliele~; Cumberls~d County, Pennsylvania, do mI~ke mnd nublish this m~ last will and testament, hereby revoking end ~aking void all other wills by me at a~y time heretofore made. I give, devise and bequeath my entire estate, real, personal and mixed, whatsoever the same may be nad where- soever the eeme may Be eit~te, to my beloved wife Margaret E. Mtller, to be hers absolutely, and I nominate her to be the executrix of this my last will ,~nd testament. In witness whereof, I have her~unto set m~. h~ i ~d seal this 19th de6' of February, A. D. 19~, Signed, sealed and nublished by the said Willi~ Edwin ~iller as end for his l~st will and te~t:~ment tn the John B Orris T. Ralph Jacobs CU;,'~EB.LAND ~X)uNTY, ~S: This 13th day of A~et A. D. 19151, before me Lloyd A. Render, Re~ister for the Pr~,b~t~ of Wills ~d graf, ting letters of A~inistration in ~d for said Oo~ty of ~berl~d, in the Oommonwe,;lth of P~nnsylvs~ia, p~r~o~,ally~ c~e ~o~ B. Orria, one of the subscribing witnesses to the foregoing instr..ant of writing purporting ~o be the l~t Will ~d Test~ent of Willi~ ~dwin Miller Dated Feb. lq. 19~5 late of Carlisle. ~berland County. Pa. deceased who being duly sworn accord~ to law. depose ~ s~,y. that h.. was pre~eut. ~nd saw an~ he~,r~ ~m,i ~cl:,r~' t?;,~ s~ld ~n~t,'.,me,,~ cf ,,,rtt~:~g r~'-ory ~n.~ u dor>t, ndin~, (c,~nt!nuod on p;.~. !2g ) Exhibit F I~' WlTNE.~S WHE,{EOF~ THE sAID pART THE DAY AND yEAR FIRST ALIOVE wRITTEN. SIGNEO, SEALED AND DELIVERED IN THE pRESENCE OF '" w.'SCOTT co~LE OF THE FIRST pART .HA HEREUNTO SET HANO AND ~E'~L I I I JACOB R.~ENNINGER 5 (SEAL) i STATE OF PENNSYLVANIA cuMuERLAND cOUNTY' ' ) OUsAND NINE HUNDRED .~9 BEFORE ME, THE SUB:~CRIB ; · E yEAR ONE TH .. ON THE 9 DAY'OF ocT~ER IN TH ~_ . .. ~F~,U~ GER AND HE ACKN~LEDGEI) THE ~uoVE ENTU~E T~, uE H ~ ACT At~D'DEED~ Nu ' 'wITNE~5 MY HAND AND JUs31CE' sEAL. NOTARY PuBLIO ' F fiST MONDAT JAN. ~4 . . ~4~ G~r~ISSION EXPIRES · ; i , ',' , ' wITHIN DEED ~IS EAST ' : OENCE OF THE GMANTE~IN'THE I HERE~Y CERTIFY 3HAT THE pRECIS~ RESI pENNS~ORO T~IP. ME~AhICSBURG~ pA. R.O.4. ,j FANNIE S.uRETZ ~ETwEEN d ' ~ .- FANNIE SHAFFE~' t Ct~N~Y pENNSYLVANIA CONS, ~ [.00 ~ . . 'AND FANNIE SH~FFEY uHETZ' OF SAM [~0C,' EAS1'pEhNS~0R0 TWP, ~ECON~ p~HT~ WiTNES~ETH, THAT THE S~ID pAHT 0F THE FIRS DATED FEBRUARY [~O ", OF .THE ~ A-'ON OF THE ~UM'0F '0NE DOLL~R'DOLLA~(~ Y pAHT, FOH At~D IN CONSIDEH II - BY THE ~AID p~TY OF THE. ENT~ED AUGUST 5,[~[ ATES OF AMERICA, ~EL~ ?~ND TRULY PAI'D THESE pHESENT5 ,~THE HECE .. H E K W G D I ' LI' ED~ ENFEOFFED~ HELEASED~ CoNvEYEO ~AhD CONF~MEO~ AND ~Y 3H~SE pHESEN~5 ~0 GRANT ~IBN~. ENFEOFF' RELEASE~ CoNvEY ~ANOCONFIRM UNTO THE sAID P~ OF THE SECON,~ pART HER HEI~S AND As~IGNS~ ALL THAT CERTAIN TRACT OF LAND SITUATE IN E~T pENNSB~O To~NSHIP~ERL~NO COU~ , I I ' DESCRIBED A~ FoLL~S T0 WiT:'~GINNI~ AT'A pO~T ,THENCE TY~ STATE 0F PENNSYLVANIA ~ouNDED AND A ~TAK[, THENCE ~Y LAND~ O~ dOS~PHIwAL'TMAN" NO~TH S~X'A~O A HALF pERCHE~ ~0 A vENTY ONE' AND THREE ~E~'REEs EASTI' FORTY SIX AND LANDS OF ~AID J'ACO~ R[RENNINGER ~O~TH S~ L~NDS 0F THE sAID dOHN .'.SEIHE~ SOUTH THIRTY ~0 TENTH pEACHES TO A sTAKE~T~ENCE UY ~THEH. ~IGH~ AND ONE HALF;DEGREES EAST~p"wTY "F~vE pEHCHE~'TO pLACE OF uEGiNNi~,.CONTAINING E pERCHES AND oNE Ht Nb~Eo AN~ F~Y FOUR pERCHES ,NE~," MEAS[,gE uE.T~E 5Ak~E, MoRE '0R LESS, IT BEI.~ pART OF A LARGER THACT,OF LAND ~HI~ dACOU ~.KLING A~]Q~A~A-' I,II5 wIFE, NDENTURE :DA~ED THE THIRTIETH DAY OF MARCH A.D.-lB69 FOR THE.CONSI.~ERA~ION THEREIN MENTION~-D lid GRANT ANO CONVEY ~HE S~E uNTO THE SAID ~O~ sIERER ~RESENT GRANTOR AND UN~O HIS HEI~S AND AS~ GNS FOREVER. T .' , · REFERENCE ~EII..~ HAD TO THE FOREGOI[IG RECITED DEED wILL 'MO~E FULLY AND AT L~GE AppEAR. I' TO THE ~ · TOGETHER tilTH ALL AND sINGULAR ~ ~HE TEMEklENT8 ~HE~EDIT~.,ENT5 AND AppuRTENANCES 0pF. RTY, CUAIM AND oEMAND WHATSOEVER' uOTH' IN LAW AND~ E. QUITY,-OF :[HE. SAID pAR,'I'Y OF THE EIgST Ap PL~R..[ EN ,N4 (;;E S, UNT 01 TH E SAI R~ OF ,~N TO OR OUT 0~' THE SAID pREM1SES~ AND EVERY pART AND PARCELi THEREOF , ' AND SINSUL N3' THE · TO HAVE''AND TO H~)LD.THE sAID pREMISES' wITH ALL ,~'fy OF 1HE SECOND pat{'[ HEIRS AND ASSIGNS' TO AND FOR THE ONLY pROPER uSE AND uEHOOF OF THE - u~'~ AND ASSIGNS FoREVE m ' - nn u',; THESE pRESEN ,C[Y OF THE SECOND pAi[T~.n .... . ' ,..,.,ccuTORS AND ADMINISTRATORS' uu ,..,- - ' - w~hAN~ GRANT AND AGHEE TO AND WI .... ~"~TS A~O PREMISE~ HEREINAUOV[ C E ...... / ,,~,R~ ALL AND sINGULAN THE HENcuH~''~'' THE.SAIO pART OF ANTED De ~4ENTIONED'~ AND iNTENDED SO~IBE~ ~ITH THE AppurTENANCES ~'uHTO IGNS~ AGAINST THE SAID pA~T OF THE FIRST RA~ AND HEI~S AND AGAINST CONO~PAR~ HEI~S AND ASSO~ FE~SONS WH~SOEVE~ ~LAW~ULLY CLAIMI~' OR TO,~AIM THE S,~4E,O~ ~NY L AND Every OTHEH RE~SO.N .~ THE~E~ SHALL AND wlLL~ BY THESE p~ESENTS~ WA~AN~ AND FOREVE~ DEFEND. .IN WhT. NESS VlHEHEOF, THE SAID pART OF'THE FIH~T pA~T HA, HEREUN30 5ET HAND ~ND SEA L THE AND yEA~ F4RS'f AuovIE WRITTEn. '..~ i~,NED'~ sEALED AND DEL IvERED : ~ . IN. THEP~IESENCE OF w, scoTT CAUL.E:. ~ ~ 'A'[~ OF' "~ENNSYLVANI A )' .JACOU R.RENNINGER (sEAL;) I '1 jiV~ERLAND ~COUNTY ' )~S t · · "' AND 40 BEFO"E -Oh THE 3. .~ DAY OF'FE~HUAHY IN THE yEAR ONE ~HOUSAND NINE HUNDRED juSCRIsEff w,SCOTT c~LE pER~ONALLL~ CAME TH~ ~oVE~NAMED dk~O~ ReRENH INGER AND HE ACKNOWLE~ED ~E Auo~E iNDENIUHE ~0 BE HIS ACT AND DEED* AND OESI~EO THE'S~E MIGHi BE RECORDED AS SUCH. . ~I~NEES MY.HAND AND ~u~TICE SEAL... t ,' ~ ~cOTT COBLE <MY c~MlSSlO~ E~p~H~S FIRST MON. JAN. ~' I ~EHE~Y CEM11FY THAT THE pHECISE RESIDENCE EN~SU~O TWP.~ MECHANICSBt:RG~ pA. FANNIE S.uRETZ t GRANTEE OMPANED BY ~.U, & O. tD246 ~ '~THIS INDENTUNE ,M~DE TH~ T~ENTY-FOURTH DA~ OF NOVEMUEN ,IN'THEE ~EO' ~ yEAN O~ OUR LO~ ~ONE THOU'SAND NI'NE HU'NDNED ANIEL H.H[~LEN~ S EXO~S. wILL ~ . ~ uETwEEN GEORGE A. PLOUGH ~ SURVIVING EXECUTOR OF THE LAST ~0 AND TES~AI.~ENT 'OF DANIEL H.HELLER~ LATE OF THE ~OROUGH OF NE~vVILLE~ LMA N. PLOUGH J - ~ COUNTY OF CU~Et{LA~D ~AND 5TA~~ OF PE~NSYLVANIA~DECEASED~PA~TY OF ONS. ~ ~.00 J pAKT~ " OC. NEwvILLE ~ AND AL~A R. PLOUGH~ O.F sAID BOROUGH OF NEwvILLE~ pA~TY OF THE ATEO NovE~.EN 24,~ ,' NTEHED AUGUST 5~[~[ ~ SECOND pkAT[ ., "~ wHEREAS~ THE ~AIO DANIEL H,HEL~R~ UY vIRTUE OF OIVER GoOD CO~ EYANCES AND ASSURANCES IN LAW~ OULY HA~ AND EXECUTED ~BEC~E , ~l ~ ' CERTAIN ~OT OF GROUN~ 8 T~TE IH SAID )EMESNE~ AS OF FEE~( '~oNGST OTHE~ LANDS~ ) OF AN IN A ,OH~UGH OF NEwvILL[ ~ AND HEREINAF~EH FULLY O~CRlUEB ; AND BEI~ .AS3 wILL AND TESTamENT IN WRITING ~ DATED THE ~TH DAY OF FEURUARY~[~7~WHEREI . ~MONGS3 03HER THINGS* ,HE p~OVlOED A~ FOL~St: "FIRST. - I GIVE, DEVISE AND uEQUEATH MY ENTIRE ESTATE TO"G~oRGE A. PL~UGR AND LIZZIE HELLEN~ Exhibit G E RIBHT, TiTLE,"'INTERESf-~PROPERTY' ;THEREOF, ArID ALSO ALL THE EsTAT , ...... THE FIRST p/~RT, OF, IN~ OR TO THE: ABOVE AS WELL AS tN LAW AS IN EQUITY~ OF THE SAID pARI¥ ur OESCRIBED PREMISES , AND EVERY PART AND pARCEL THEREOF, WITH THE APPURTENANcES' 'ND sINGtlLAR THE ABOVE MENTIONED AND DESCRIBED p.R[.:ISES, TOGETI TO HAVE AND TO HOLD ]I[UL A ...... , Tuc ECONO PART, HER HEIRS AID ASSIGNS FOREVEF iWITH THE APPIIRTENAHCES, UNTO THE SAID pArtlY ur .,~- S IN ¥11TNESS WHEREOF, SEALED ArID DELIVEREO OViE ACRI (SEAL~ IN THE PRESENCE OF ;TATF oF pENNSYLVANIA ) )OUNTY OF CUMBERLAflD '] . ON THE 19TH DAY OF MAY ANNO DOMINI 19~?, BEFOEE ME~ pERSONALLY APPEAREO ABOVE NAIdEO OVll ACRI A!IO IN DIIE FORM oF LAW ACKNOWLEDGED TIlE ABOVE INDENTURE TO BE HIS ACT AND DEED, AND iDESiRED THE .~AME MIGHT BE REcOROEO AS I~JCH. WI~IESS MY HAND AND OFFICIAL SEAL THE DAY AND yEAR AFORESAID. ~ :' "~T · TLE ,. I HI-'REBy CERTIFY TtlAT THE RESIDENCE AND poST OFFICE OF E iS k~CtlANIOSBURG PA, R, D, 6, ROBERT MYERS, JR. d - ATTm"EY FON GRA.TEE [ T.IS I.OE RE..ACE THE CAY O'F JU Y I" THE 3EEO i!1.11~_~5!~',I YEAR OF OUR LORD ONE THOUSAND NINE HUNDRED AND FORTY IFAN"'E S. BRET,Z, sEvE,. TOt ~1~,..i BETWEEN FANNIE S. BRETZ, WlOilW, OF THE TONNSHIP :)AVID W. FOLTZ . :EAST pENNSBORO~ cOUNTYOF cUMBERLAND AND sTATE OF PENN'~YLVANIA, CONS: ~..00 ~ p~,RTY oF THE FIRST pART AND DAVID W. FOLTZ,OF TI-F- SAIVlE pLACE, LOC: EAST pENN~B~O TWP. '. pP~RTY' OF TIlE SEC~IqD PART, wITNESsETH~ THAT THE SAID pAr{TY OF THE )ATD~ JULY 16, 19~."/ IN GoNsIDERATION OF THE SUM OF oNE COLLAR (~. 3AIC BY Tile SAID PARTY OF THE SECrJND PART TO THE ~AID PARTY OF THE FIRST pART, AT' AND BEFORE rile t~EALING AND DELIVERY OF THESE PREsENTS~ THE RECEIPT WHEREOF IS HEREBY ACKNOWLEDGED, HAS GRAN'~ED~ BARGAINED, sCLC, ALIENED, ENFEOFFED~ RELEASED~ cONVEYED AND CON~-'IRMED AND BY THES[ 3RESENTS DOES GRANT, BARGAIN~ SELL, ~LIEN, ENFEOFF, RELEASE, CONVEY AND cONFIRM UNTO THE SA ~ARTY OF THE SECONO p~RT, HIS HEIRS AND ASSIGNS~ ALL THAT cERTAIN TRACT OF LAND sITuATE IN THE TO~StlIP OF EAST PENNSBORO, CoUNTY oF ~UMBERL/~ND AND sTATE oF pENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, T[ . BE(HNNING AT A POINT IN A PUBLIC ROAD, AT THE sOUTIIERN LINE oF LANDS OF O. ACRI; THEN~ SAID PUBLIC RoAD sOUTtt THIRTY-SEvEN (3'/) DEGREES THIRTY-FIVE ~(3.5) r~INUTES EAST FOUR HUNOI EIGHT AND NINE ONE-HUNDREDTHS (~'/8.09.~ FEET TO A POINT; 'IHENCE BY OTHER L.N, IDS OF Wi IS WAS A pART, THIS DAY cONVEyED TO STANLEY L.'BALTOZER, SOUTH EIGHTY-FOUR (8~.) DEGREES · .WE. NTY-NINE (29) MINUTES W~sT TEN HUNDRED AND FORTy (10~.0} FEET~TO A POINT AT THE LINE OF O' ANDS OF FANNIE S. BR.ETZ; THENCE S:f sAID LN'IOS NORTH SIX (6) DEGREES FORTY-THREE (~':~) MINUT[ .AST TWO ttUND,RED FORTY-THREE .A. ND TWENTY-FO~..R ONE-HUNDREDTHS (2~,?.2~.) FEET TO A poINT AT THE .INE OF LANDS OF O, ACRI; THENCE BY SAID LANDS NORTH SEVENTY:ONE ~,'/.t) DEGREES FORTY-FOUR (~, ~INUTES EAST SEVEN HUNDRED FI.FrY-TWO AND~HIRTY'FI:XIR i~qE-HUNDREDTHS ("/.52.:~.') FEET TO A POIN' THE PLACE OF BEGINNING. BEING PART OF TH~- pRDalSES WHICH RAY T. HARRIGAN AND WIFE, BY DEED DATED THE 2OTH DAY OF HOVE 19~,5, AND RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR SAID COIINTY OF CIIMBERIt:.AN IN DEED BOOK "B", OOL. 1:), PAGE 296, GRANTED AND CONVEYED UNTO FANNIE S. BRET3. sEE ALSO THE DEED (3F OVlE ACRI, SI'NGLE MAN, TO FANNIE S. BRETZ, DATED TIlE 19TH DAY OF I~ 19~,?, AND TO BE RECORDED HEREWITH. TOGETHER WITH ALL AND SINGULAR THE TENEMENTS, HEREDITAMENTS AND AP~URTE[4AIjlCES TO THE S BELONGING, OR IN ANYWISE APPERTAINING, AND THE REVERSION OR REVERSIONS, REMAINDER A~D REMAItlD RENTS, ISSUES HND PROFITS THEREOF; AND ALSO ALL THE ESTATE, RIGHT, TITLE, INTEREST, PROPERTY, I~LAIM AND DEMAND WHATSOEVER* BOTH IN LA~' AND EQUITY~ OF TH[ SAID PARTY OF THE FIRST P. ART, OF, TO OR OUT OF THE SAID pHEMISES ANO EVERY PART AND I~ARCEL'THEREOF' TO HAVE AND TO HOLD THE SAID PRE.MI~ES WITH ALL AI~ .SINGLAR THE APPURTENANCES, UNTO THE ' E I R,S' AND. SAID PARTY OF THE SECOND PART, HIS H ASSIGNS TO AND FOR TH[ ONLY PROPER USE AND BEHO0 OF THE SAID PARTY OF THE SEGOND PART,. HIS HEIRS .AND ASSIGNS FOREVER. AND THE SAID P~RTY OF THE FI'RST PA;R?, .F.OR .HERSELF,, HER HEIRS, EXECUTORS AND ADMINISTRA' DOES, BY THESE PRESENTS, COVEN,ANT', GR/~NT AND AGREE TO AND WITH THE SAID PARTY OF THE sEcOHD P, HIS HEIRS AND ASSIGNS, TI~AT SHE THE sAID *PARI:Y OF THE FIRST PART, AND HER HEIRS, ALL AND SINC. ULAR THE HEREDITAk£NTS AND PREMISES HEREINABOVE DESCRIBED AND*GRANTED OR MENTIONED AND INTENDED SO TO BE, WITH THE 'A.PI~u~{TIF~IANCF-S, UNTO THE'SAID pARTY oF.THE sECOHD PART, HIS HEIRS AND ASSIGNS, AGAINST THE sAID PARTY'DF THE FIRST PART AND HER HEIRS AND AGAINST ALL AND EVERY OTHER'PERSON'OR PERSONS WHOMSOEVER LAWFULLY CLAIMING OR TO CLAIM THE sAME OR ANY pAinT THEREOF, SHALL AND WILL BY THE,~E PRESENTS, WARRANT AND FOREVER DEFEND. IN .WITNESS WHEREOF, TttE SAID pARTY OF THE FIRST PART HA~ HEREUNTO SET HER HAND AND SEAL THE DAY AND yEAR FI RsT ABOVE WRITTEN. '. FANNIE S, BRErZ (SEAL) i SlGt~D, sEALED AND DELIVERED IN THE pREsENCE OF STANLEY L. BALT{~ZER R 0BERT MYE RS, dR. STATE OF pENNSYLVANIA ) .... SSt COUNTY DF CUMBERLAND ON THIS, THE 16TH 'DAY OF dULY, I°~?, BEFOREME MILORED HOOPY STONE THE uNDERSIGNED OFFICER pERSONALLY APPEARED FANNIE S. BRETZ, WIDOW, KNOWN TO ~'OR SATISFACT~ILY PROVEN) TO BE THE PERS~ ~HOSE NA~ IS SUBSCRIBED T0:~E .~ITHIN INSTRUMENT~ A~ ACKNOWLEDGED THAT SHE EXECtffEO THE SAME F~ THE PURPOSE~ T~flEIN C~TA ITNESS WHERE ~ IN W , OF I HEREUNTO SET '~ HAND A~ OFFICIAL SEAL. ~ .~~; , . I DO HEREBY CERTI~ T~AT THE PRECI~ RESIDENCE OF THE WlTHIN~D GRA~EE S. ENOLA, PA. NO: ~O897 DEED FANNIE E. BRETZ, TO: STANLEY L. BALTO~ER CONS: $1.00 , LOCi E,PENNSBORO TWP. OATD: dULY 16, 19~? ROBERT MYERS , JR. ATTCRHEY FOR GRANTEE. .( M ) THIS INDENTURE,' MADE TK~. 16TH DAY OF dULY IN THE yEAR OF " ' NINE HUNDRED FORTY-SEVEN. LORD ONE THOUSAND, ~ · ?'[6-~?~= ~NNSB'~O, c~UNTY OF c~BERLAND A~ STATE OF PENNSYLVANIA AN p~Y.0F ~ FIRST PART~ ~O. sTANLE.Y L.' BALTOZEE, OF THE CITY~OF H~RIS- BURG, cOUNTY OF. oAUPH'IN ~D sTATE;AFORESaID, PA~Y OF THE SECOND P~T ~ITNESSETH ~AT ~HE ~1~0 p~TY OF THE FIRST PART, F~ ~D IN cONSIDE ATION OF T~ ~U OF ~E..DOLL~ (~1.OO) ~O OTHER VALUABLE CONSIDCRATIO Exhibit H tN WITNESS wHEREOF THE SAID PARTIES OF THE FIRST PART HAVE HERFUNTO SET THEIR HANDS AND SEALS THE DAY AND YEAR FIRST ABOVE WI~ITTEN. · SIGNED, SEALED AND DELIVERED iN THE PRESENCE OF (SEAL) RAYMOND AD MI CELl j. ROBERT STAUFFER (SEAL) JANET L. MICELI MILDRED VI. wATTS COMMONWEALTH OF PENNSYLVANIA ~ cOUNTY OF CUMBERLAND iS: ON THIS, THE 1LTH DAY OF MARCH, 1957, BEFORE' NE, THE UNOERSi'~NEO OFFICER, PERSONALLY APPEARED RAYMDNO ^ppEAREO RAYMOND A. MICELI AND JANET L. MICELI, HiS WIFE, KNOWN TO ME (OR SATtSFACTORtLY PROVEN) TO BE THE PERSONS WHOSE NAMES ARE sUBSCRIEEO TO THE WITHIN iNS- IN wITNESS wHEREOF, I HEREUNTO SET' MY HAND AND OffiCiAL SEAL. ,/~'IEALt MILDRED W. wATTS M,~ eOM EXP FEB. 16, 1957 I HEREBY CERTIFY~THAT THE PRECISE RESIDENCE OF THE GRANTEE, IN THE,WlTH~'~r~ O~'ED, IS 175~ K. STREET N. W. wASHINGTON, O. C. GEORGE M. HOUCK AT'TORNEY FOR G~.RNTEE. THIS INDENTURE, NO. 2Z+/+ 77 J PENNA DEED '{I l~2.'00 MADE THE C)TH.DAY OF MARCH IN THE YEAR OF. CANCF-LIFO .... OUR LORD ONE THOUSAND NINE HUNDRED AND FIFTY ~ DAVID W. FOLTZ ET UX {I STATE TAX. THREE. TO § . BETWEEN DAVID W, FOLTZ AND VERA L. MARGARET PAULINE SCHREINER CONS. S200.O0 j UNITED STATES HIS WIFE, OF EAST PENNSBORO TOWNSHIP, CUMBER- LOC. EAST PENNSBORO TOWNSHIP {~ ~Ii~i~NALREVENU[ LAND COUNTY, PENNSYLVANIA, pARTIES OF THE FIRST AND DATE[) MARCH 9, 1.053 /~ ~LTAE~ PART'MARGARET PAULINE SCHERINER OF THE CITYI ENTD. MARCH 16, 1957 ~ · ~OF HARRISBURG, DAUPHIN cOUNTY, PENNSYLVANIA, PARTY OF THE SECOND PART, FOR ANO IN CONSIDERATION OF THE SUM OF TWO HUMORED ($2OO.OO') DOLLARS, LAWFUL MONEY THE UNITED STATES OF AMERICA, WELL AND TRULY PAID BY THE SAID PARTY OF THE SECOND PART T.O SAID PARTIES OF THE FIRST PART~ AT AND BEFORE THE SEALING AND DELIVERY OF THESE pRESENTS, THE RECEIPT wHEREOF IS HEREBY ACKNOWLEDGEO, HAVE GRANTED, B~RGAINEO, SOLD, ALIENED, IENFEOFFED, RELEASED, CONVEYED, AND CONFIRMED AND BY THESE PRESENTS DO GRANT~ BARGAIN, SELL, ALLEN, EN- FEOFF, RELEASE, CCNVEY, AND CONFIRM UNTO THE SAID PARTY OF THE SECOND pART HER HEIRS ~NO ASS I GNS, ' ALL THAT CERTAIN PIECE OR pARCEL OF LAND SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND D~SCRIBED AS FOLLOWS, TO WIT:- BEGINNING AT A POINT IN THE wESTERN LINE OF THE SALT ROAD AT THE SOUTHERN LINE OF LANOS OF 0. ACRI; THENCE ALONG THE wESTERN LINE OF SAID SALT ROAO sOUTH THIRTY SEVEN (37)'DEGREEs THIRTY FIVE (35) MINUTES EAST TWO HUNDRED THIRTEEN (213) FEET TO A POINT; THENCE SOUTHWEST~ARDLY ALONG LANDS OF OAVID W. FOLTZ TWO HUNOREO (200) FEET TO A STAKE; THENCE WESTWARDLY ALONG LANOS OF DAVID W. FOLTZ TWO HUNDRE0 NINETY (290) FEET TO A STAKE; THENCE NORTHWAROLY ALONG LANDS OF DAVID W. FOLTZ TWO HUNOREO (200) FEET TO A STAKE; THENCE ALONG LANOS OF O. ACRI NORTH I~3 SEVENTY 'ONE (71) DEGREES FORTY FOUR (~./+) MINUTES EAST TI-REE HUNDRED FIFTY (750) FEET TO A 'AI,~I POINT, THE PLACE OF BEGINNING. · BEING PART OF THE SAME PREMISES WHICH FANNIE S. B~ETZ~WlDOW, BY HER DEED DATED JUI.Y 19~? AND RECORDEO IN THE OFFICE FOR THE RECORDING OF DEEDS IN AND FOR CUMBERLAND COUNTY IN DEEO BOOK O, VOLUME [3, PAGE 358, GRANTED AND CONVEYED uNTO DAVID W. FOLTZ, GRANTOR HEREIN. TOGETHER WITH ALL AND SINGULAR, THE T£NENE'.~TS, HEREDITANENTS AND APPURTENANCES' TO THE SAME BELONGING OR IN ANYWISE APPERTAINING, AND TI~E REVERSION AND REVERSlONS~ REMAINDER AND REMAINDERS, RENTS, ISSUES AND PROFI~;S THEREOF; AND ALSO ALL THE ESTATE~ RIGHT, TITLE, INTEREST, PROPERTY, CLAIM AN0 DEMAND 9,~rIATSOEVER, BOTH IN LAW AND £QuITY:, OF THE SAIO PARTIES OF THE FIRST PART, OF, IN,,TO OR OUT OF THE SAID pREMISES~ AND EVERY PART AND ~ARCEL THEREOF TO HAVE AND TO HOLD THE SAID PREMISES, wITH ALL AND SINGULAR THE APPURTENANCES, UNTO THE SAID PARTY OF THE SECOND PART, HER HEI~S. AND ASSIGNS, T ND FOR THE ONLY PROPER uSE AND BEHOOF OF THE SAID PARTY OF THE sECOND p~RT, HER HEIRS AND ASSIGNS,FOREVER, AND THE SAID PARTIES OF THE FIRST PART, FOR THEMSELVES, THEIR HEIRS, EXECUTORS &DMINISTRATORS, DO BY THESE PRESENTS, COVENANT, GRANT AND AGREE TO'AND WITH THE SAID PARTY OF THE SECOND PARTm HER HEIRS AND ASSIGIqS, THAT THEY THE SAID pARTIES OF THE FIRST PART, THEIR HEIRS ALL AND SItIGULAR THE HEREDITAt~NTS AND PREMISES HEREINABOVE' DESCRIBED AND GRANTE0 OR MENTIONED* AND INTENDED SO TO Eli', wITH AppURTEflANCES, UNTO THE SAID pARTY OF THE SECOND PART, HER HEIRS AND ASSIGNS, AGAINST THE SAID PARTIES OF THE FIRST PART RNO THE~]E: HEIRS AND AGAINST ALL AND EVERY OTHER pERSON OR PERSONS wHOMSOEVER, LAWFULLY CLAIMING OR TO CLAIM THE' SAME OR ANY PART THEREO~, SHALL AND wILL," BY THESE PRESENTS, WARRANT AND FOREVER DEFEND IN wITNESS WHEREOF THE SAID ~ARTIES OF THE FIRST pART HAVE HEREUNTO SET THEIR HANDS AND SEALS THE DAY AND YEAR FIRST ABOVE ~RITTEN. SIGNEOm~SEALED AND DELIVERED , AVIO W. r0LTZ (SEAL) IN THE PRESENCE OF (SEAL) H. L. wITTLE VERA. L. FOLTZ cOMMONWEALTH OF pENNSYLVANIA ~ cOUNTY OF CUMBERLAND L. ON THIS, THE ~TH DAY' OF MARCH, [~), BEFORE ME ~ARRY/WITTLE, THE UNDERSIGNED OFFICER, PERSONALLY APPEARED DAVID W. FOLTZ AND VERA L. FOLTZ, HIS wIFE~ KNOWN TO ME (OR SATISFACTORILY pROVEN) TO BE THE PERSONS WHOSE. NAMES ARE SUBSCRIBED TO THE WITHIN IN- STRbMENT, AND ACKNOWLEDGED THAT THEY EXECUTED THE SAME FOR THE PURPOSES THEREIN CONTAINEO. i ~ HEREUNTO SET M~ HAND AN~ O~FlClAL SEAL. IN WITNESS WHEREOF, I ~HARRY L, WITTLE (( --- JNOTARY PUBLIC I HEREBY CERTIFY THAT THE :PRECISE RESIDENCE OF THE GRANTEE, IN i l-E wiTHIN DEED~ IS 2817 WATSON STREET, HARRISBUHG, PA. ATTORNEY FOR ARB. - ......... L ............................... NO. 2~80 t THIS INDENTURE, DEED ~ MADE THE I~TH DAY OF MARCH IN THE YEAR OF OUR LORD RICHARD g. BROWN ET UX,. ~0NE THOUSAND NINE HUNOR~[i~ANO F IFTY-TI'REE TO ~ BETWEEN RICHARD ,[', GROWN AND RUTH I% GROWN, HIS JOSEPH NEGLEY. ~ wIFE~ OF THE BOROUGH OF NEWVILLE, COUNTY OF CUMBERLAND ~ AND STATE OF PEN~S'YLVANIA, pARTIES OF THE FIRST PART CONS. '* .' AND LOC. NEWVILLE ~ / DATED MARCH 1~, 195~ ~ .. JOSEPH ..~GLEY~ SINGLE MAN, OF ~HE SANE PLACE, PARTY ARCH 16 1953 f OF T~[ SECQflD PARle' ' ENTO. M , ~ WI~SSETH, THAT THE SAID p,~TIES OF THE FIRST PART, TIME lo~ ^M FUR AND/I'~ONSIDERATION OF THE SUM OF NO CONSIDERATION LAWFUL MONEY OF THE uNITED STATES O~ A~ERI~ WELL AND TRULY PAID BY THE SAID PARTY OF THE SECOND PART 10 THE SAiD pARTIES OF THE F~ HARTm AT AND rdEFURE THE ENSE~ lNG AND DELIVERY OF 1HESE PHESENTS, THE RECEIPT WHER~OF'~.HEREuY. AcKNOWLEOGED~ HAVE GRAN'iED, BARGAINED, SOLD, ALIENED, ENFEOFFED, RELEASED, CON~.~ED~AND CUNFIRM[O, ANO UY THESE PRESENTS DO GRANT~ BARGAIN, SELL, ALIEN, ENFEOFF~ REL'r~E, CuNVEY AND CONFIRM uNiO THE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Ticor Title Insurance Company, on behalf of Raymond Magaro and Theresa A. Magaro (nee Long), Complainants Ve John Scarer (aka John Sierere, John Sierer, John Seirer); Jacob Remminger (aka Jacob R. Remminger, Jacob Renninger, Jacob R. Renninger); Lillie Renninger (aka Lily Renninger, Lillian Renninger); Jacob Milton Renninger (aka Milton Renninger);: their heirs and assigns, : Defendants : Complaint - Civil Docket No. ~:~ ~ - Action to Quiet Title MOTION FOR SERVICE BY PUBLICATION NOW COMES, Ticor Title Insurance Company and respectfully moves this Honorable Court for an order to permit service through publication in accordance with Pa. R.C.P. 430 and C.C.R.P. 1009-1in the above captioned action In support of its request, Ticor Title states the following: 1) The above captioned action is one to quiet title to Property located at 121 Salt Road in East Pennsboro, Cumberland County, Pennsylvania, which was conveyed to Raymond Magaro and Theresa A. Magaro (nee Long) in 1995 by deed recorded in Book 189 page 1139, and which they are currently in possession. 2) The title to the Property is clouded by incorrect spellings and misidentification of individuals in deeds and other legal documents dating back to the 1869 through 1941 which time frame is more thoroughly set forth in the complaint.. 3) The persons named in the chain of title to the Property are deceased, except for the current owners in possession. 4) The heirs and assigns of the persons involved in conveyances of the Property that cloud the title are not identifiable as to their existence. 5) Attempts have been made without success, as affirmed in the attached affidavit, to identify and locate any heirs and assigns of John Searer (aka John Sierere, John Sierer); Jacob Remminger (aka Jacob R. Remminger, Jacob Renninger, Jacob R. Renninger; Lillie Renninger (aka Lily Renninger, Lillian Renninger); and Jacob Milton Renninger (aka Milton Renninger). The attached affidavit affirms that the heirs, if any, are unknown. 6) The roles provide for service by special order of court through publication in circumstances such as this where the cloud in the title is ancient and any heirs and assigns cannot be located. The roles specifically state that the Court may permit publication as service upon heirs and assigns if set forth in the complaint or an affidavit that the heirs and assigns are unknown. Pa. R.C.P. 430(b)(2). WHEREFORE, the complainant respectfully moves that this Honorable Court issue the attached proposed order allowing service on the defendants to this action by publication in the Harrisburg Patriot News and the Cumberland Law Journal in accordance with Pa. R.C.P. Rule 430 and C.C.R.P 1066-3. Respectfully submitted, Linda C. Smith - I.D. #35868 Joseph F. Kessler - I.D. #37411 Victor P. Stabile - I.D. #37449 Dilworth Paxson, LLP 305 North Front St., Suite 403 Harrisburg, PA, 17101 717-236-4812 (telephone) 717-236-7811 (facsimile) Dated: January 4, 2002 Ticor Title Instwance Company, o'n behalf of Ra>mond Magaro and Teresa A. Magaro (nee Long), Plaintiffs, V, John Searer (aka ,John Sierere, · John Sierer, .John Seirer); ,Jacob Remmingel* (aka Jacob g. Remminger~ Jacob Renninger, Jacob R. Renninger): Lillie Renninger (.aka Lily Renninger, Lillian Renninger): ,Jacob ~tilton Renninger (aka Milton Renninger): their heirs and assi~s. Defendants, Complaint. Docket No. XFFI:DAVIT IN SUPPORT OF MOTION FOR SERVICE TI-[ROUGH PIBLICAIION COMM:ON3~,ZALTH OF PEN~SYLV.&NLA COb?~ __ Z OF CL$IBEP,.L.&ND BEFORE ME, the subscriber, aNotar3., Public in and for the Commonwealth of Pennsylvania. personally appeared Charles M. Fogm~,, of 617 Gutshall Ro~i, Boiling Springs, PA 17007, who being dui5, sworn according to law, deposes and says as follows: 1. I mn a real estate title abstractor and have ~proximntely 22 5,ears' experience searching titles in Central Pem~sylvmfia. 2. h~ the Spring of 1998, I was eng~ed by Victor Stabile, Esquire t~)r Dihvorth Paxsou LLP Law Offices to identitY, all outstanding title interests in a prope~%, identified as Lot 1~ Plan 64 p~e 63 located in East Pem~sboro Township, Ctanberland count), gp~.en the address of 121 Salt Road. a Tax Map Number of ~09-14-835-221 which is owned by Teresa A. and Raymond L. Mag_.aro by virtue of Cmnberland County Record Book 169 page 1139 dated December 22, 199'7. continued on P~e 2 3. Resem'ch indicates that several possible outstanding interests exist due to misspellings in deeds mid incomplete or ~nissing Estate files. 4. The possible outstmlding interests vest in: A. John Sea'er aka John Sierere aka John Sierer aka John Seirer and his heirs and assigns. B. Jacob Remminger aka Jacob R. Remminger aka Jacob Renninger aka Jacob R. R~nninger, his heh's and assigns. C. Lillie Renninger aka Uti)' Renninger aka I_;tilian Rcnningen her heirs and assigns. D. Jacob ~ffiton Renninger aka ~glton Renninger his heirs and assigns. 5. I hereby yetiS, that the statemems set fotXh in this Affidavit m'e based on a comprehensive sea'ch of the Public Records in the Count,., of Cmnberland. in the Spring of 1998 aid ~n in the Sununer of2001, tbr alt outstanding interests. 6. I hereby yetiS, that all of the ,above tuned Defendants a'e either decesed or their whereabouts, or the whereabouts of any potential heirs, cmmot be ascertained. '7. Semce on the del~ndants or their heirs aid assi.~ls accordingly camot be made other than ttwou._et, l publication. SWORN to mid subscribed before'me [his 7r" d~v of IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Ticor Title Insurance Company, : on behalf of Raymond Magaro and Theresa : A. Magaro (nee Long), : Complainants : John Scarer (aka John Sierere, John Sierer, : John Seirer); : Jacob Remminger (aka Jacob R. Remminger, : Jacob Renninger, Jacob R. Rcnninger); : LilHe Renninger (aka Lily Renninger, : Lillian Renninger); : Jacob Milton (aka Milton Renninger); : their heirs and assigns, : Defendants : Complaint - Civil Docket No. E) ~ Action to Quiet Title ORDER This lb~ day of ?a.~7 , 200.1,, the motion requesting service of the above captioned matter through publication in accordance with the requirements of Pa. R.C.P. 430 and the C.C.R.P. 1009-1 in the Cumberland County Law Journal and the Service of publication will be in the form of the Harrisburg Patriot News is granted. Notice attached hereto. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Ticor Title Insurance Company, on behaff of Raymond Magaro and Theresa (sic) A. Magaro (nee Long), Plaintiffs, Vo John Searer (aka John Sierere, John Sierer, John Seirer); Jacob Remminger (aka Jacob R. Remminger, Jacob Renninger, Jacob R. Renninger); : Lillie Renninger (aka Lily Renninger, : Lillian Renninger); : Jacob Milton Renninger (aka Milton Renninger);: their heirs and assigns, : Defendants : Complaint - Civil Docket No. 02-92 Civil Term Action to Quiet Title MOTION FOR ORDER TO QUIET TITLE AND TO SERVE THE ORDER BY PUBLICATION ON THE DEFENDANTS NOW COMES, Ticor Title Insurance Company, through its counsel, Dilworth Paxson, LLP, and moves for an Order to quiet title to the property known as 121 Salt Road, East Pennsboro, Cumberland County, Pennsylvania pursuant to Rule 1066 of the rules of Civil Procedure. The property is more fully described in the complaint filed in this action and in the deeds recorded in Book 119 page 835, and Book 189 page 1139. This action is being taken by Ticor on behalf of Raymond Magaro and Teresa A. Magaro~ (nee Long) and an Order is sought to quiet title in their names. It is further moved that service of this Order be permitted by publication, as was the Complaint in this case, in consideration of the fact that Defendants are unknown persons. In support of this Motion, Plaintiff states the following: 1) Service of the quiet title action on Defendants was by publication in the Harrisburg Patriot News on January 23, 2002 pursuant to Order of this Court. 2) An affidavit of Michael Morrow providing Proof of Publication in the Harrisburg Patriot News is attached as Exhibit A. 3) Service was also provided through publication in the Cumberland County Law Journal on February 1, 2002 pursuant to Order of this Court. 4) An affidavit of Roger M. Morgenthal providing Proof of Publication in the Cumberland County Law Journal is attached as Exhibit B. 5) The notices published in the Harrisburg Patriot News and the Cumberland County Law Journal included a Notice to Defend. The attached affidavit of counsel, having duly caused a notice of Complaint with the Notice to Defend to be served by publication in accordance with Order of Court dated January 16, 2002, is provided in accordance with Pa. R.C.P. 1066(a) as Exhibit C. 6) It has been more than thirty day since service by publication and filing of the complaint to Quiet Title. 7) No person has come forward to respond to the published notices. 8) The rules of civil procedure provide that the court shall grant appropriate I The caption in the case contains an error in the spelling of Teresa A. Magaro's name. The correct spelling as set forth on the deeds is "Teresa" rather than "Theresa" and all Orders should be entered in the name of Teresa. relief upon affidavit. The rules further provide that upon granting relief, the court shall order that the defendant be forever barred from asserting any right, lien, title or interest in the land inconsistent with the interest or claim of the plaintiff, unless the Defendant takes action as directed within thirty days. Pa.R.C.P., Rule 1066(a); 1066 (b)(1). The Plaintiff specifically requests that the court issue an Order that forever bars the Defendants from asserting any right, lien, title or interest in the land. The Plaintiff contends that it would be appropriate to require the defendant to respond within thirty days of notice of the Order, by filing a responsive pleading with the court, with a copy to Plaintiffs counsel, of Defendant's belief that a legal claim to the property at issue exists and the basis for that claim. 9) Plaintiff further states that because the Defendants are the unknown heirs and assigns of person long deceased, the Order must be served by publication in the same manner as the complaint and Notice to Defend was served. If the Court signs the attached Order, Plaintiff will have the Order published in the Harrisburg Patriot News and the Cumberland County Law Journal. 10) The rules of civil procedure also state that a final judgment will be entered upon filing of a praecipe if the Defendant does not take the directed action within thirty days. A proposed order for final judgment is attached for approval by the Court. WHEREFORE, it is respectfully requested that the proposed Order attached to this Motion be entered which will Quiet Title in the names of Raymond Magaro and Teresa A. Magaro if Defendants fail to take action as directed within thirty days of notice served by publication. If Defendants fail to respond within thirty days of service by publication, a final judgment will be entered upon the filing of a praecipe by the Plaintiff in the form attached as a Proposed Order. Dated: April 3, 2002 Respectfully submitted, Linda C. Smith Dilworth Paxson, LLP 305 N. Front Street, Suite 403 Harrisburg, PA 17101-1236 (717)- 236 4812 Attorney ID # 35868 Exhibit A THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, ,Npproved May 16, 1929 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 laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of ~ and The ~Zd~:~ newspapers of general cimulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, 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 their regular daily and/or Sunday/ Metro editions which appeared on the 23rd day(s) of January 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations 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 statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Da~ook "M", Volume 14, Page 317, PUBLICATION ................................................................................. ~--~ COPY Sworn to and subscri~~fJ~ 2002 A.D. an'lsbu~, Oau~oh~n County J I~TARY PUBLIC ~ My Commlasio~ Exes'es June 6, 200~ ~ commission expires June 6, 2002 Member, Pennsylvania Associal~ ot NOtaries DILWORTH PAXSON, LLP 305 NORTH FRONT STREET, SUITE 403 HARRISBURG, PA. 17101 Statement of Advertising Coats To THE PATRiOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notan/ Fee(s) Total $ 167.69 $ 1.75 $ 169.44 Publisher's Receipt for Advertising Cost publisher of _T_b.~and ~3L~[~:~, newspapers of general receipt of the aforesaid notice and publication costs and certifies that the same have Exhibit B 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 thc 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 primed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of thc said Cumberland Law Journal on the following dates, Viz FEBRUARY 1, 2002 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 Roger M. orgenthal, Editor SWORN TO AND SUBSCRIBED before me this 1 day of FEBRUARY. 2002 LO~S E. 8NYDER, Nobly Pub~ CUMBERLAND LAW JOURNAL NOTICE Be it known that Tlcor Title In surance Company, on behalf of Raymond Magaro and Theresa A. Magaro (nee Long) of 121 Salt Road, East Pennsboro Township. Ctnnber- Land County. Pennsylvania has filed a complaint to Quiet Title to the property at 121 Salt Road. East Pennsboro Township, against any interest of John Seater {a/k/a John Sierere. John Sierer. John Beirer); Jacob Rernmlnger [a/k/a Jacob R Remminger. Jacob Rennto~[er. Ja cob R Renainger): Ltllle Renuinger {a/k/a Lily Renninger. Lillian Renninger); Jacob Milton Renuinger (a/k/a Milton Renrlinger); their heirs and assigns. NOTICE If you wish to defend, you must enter a written appearance person- ally or by attorney and file your defenses ol- objections in writing with the court. You are warned that ff you fail to do so the case may proceed without you and a Judg- ment may be entered against you by the court without further notice for the relief requested by the plain- tiff. You may lose money or prop- erty or other rights Important to you. YOU SHOULD TAKE THIS PA- PER TO YOUR LA!VYER AT ONCE. IF YOU DO NOT HAVE A LAWYEP~ OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, PENNSYLVANIA BAR ASSOCIATION LAWYER REFERRAL SERVICE P.O. Box 186 100 South Street 3 Haxrisburg. PA 17108 PA Residents Phone: 1 800~692~7375 or {717) 238-6715 LINDA C. SMITH, ESQUIRE DILWORTH PAXSON LLP Attorneys for P]aintiif 305 N. Front Street Suite 403 Harrisburg, PA 17101 (717) 236 4812 Feb. I Exhibit C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Ticor Title Insurance Company, on behalf of Raymond Magaro and Theresa (sic) A. Magaro (nee Long), Plaintiffs, John Searer (aka John Sierere, John Sierer, : John Seirer); : Jacob Remminger (aka Jacob R. Remminger, : Jacob Renninger, Jacob R. Renninger); : Lillie Renninger (aka Lily Renninger, : Lillian Renninger); : Jacob Milton Renninger (aka Milton Renninger);: their heirs and assigns, : Defendants : Complaint - Civil Docket No. 02-92 Civil Term Action to Quiet Title AFFIDAVIT OF COUNSEL Linda C. Smith, Esq., Counsel to the Plaintiff, being duly sworn according to law, affirms the following facts to be tree to her best information, knowledge and belief: 1. I caused service of notice of the filing of a Complaint by publication pursuant to order of this court with a notice to defend, in the Harrisburg Patriot News and in the Cumberland Law Journal as set forth in Exhibits A and B. 2. It has been more than thirty days since publication and Defendants have not responded to the Complaint or the Notice to Defend by the filing of an Answer or any other communication. Linda C. Smith Sworn to and subscribed before me this day of April, 2002. Notary Public Notarial Seal Heldl Jo Gmybill, Nota~/Public Harrisburg, Dauphin ,Jounty My Commission Expires Sept. 2, 2002 Member, Pennsvtven!a Associati{m ot Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY APR 1 1 2002 ~ Ticor Title Insurance Company, on behalf of Raymond Magaro and Theresa (sic) A. Magaro (nee Long), Plaintiffs, John Searer (aka John Sierere, John Sierer, John Seirer); Jacob Remminger (aka Jacob R. Remminger, Jacob Renninger, Jacob R. Renninger); Lillie Renninger (aka Lily Renninger, Lillian Renninger); : Complaint- Civil : Docket No. 02-92 Civil Term : Action to Quiet Title Jacob Milton Renninger (aka Milton Renninger);: their heirs and assigns, : Defendants : ORDER AND NOW, this t'/* day of/~ton'/ , 2002, upon consideration of Plaintiffs Motion for an Order to Quiet Title and to Serve the Defendants With This Order by Publication, and affidavits submitted in support thereof, it is hereby ORDERED that Plaintiffs motions are GRANTED. Final Judgment will be entered quieting title in favor of Raymond Magaro and Teresa A. Magaro and against the Defendants to the land located at 121 Salt Road, East Pennsboro Township, Cumberland County, Pennsylvania, and as more particularly described in Plaintiffs Complaint forever barring the Defendants and any of their heirs or assigns from asserting any right, lien, title or interest in the land inconsistent with the interest or claim of Raymond Magaro and Teresa Magaro to this land as set forth in the Complaint, unless the Defendants, or any of them, make known their interest in the land and file a responsive pleading to the Plaintiffs Complaint within thirty (30) days of service of this Order. It is further ORDERED that this Order shall be served upon the Defendants by publication in the Cumberland County Law Journal and in the Harrisburg Patriot News. If Defendants, or any of them, fail to make known their interest in the land and file a responsive pleading to the Plaintiffs' Complaint within thirty (30) days of service by publication as set forth in this Order, final judgment will be entered by Plaintiffs upon praecipe and in the form attached to this Order. 11-i -02 By the Court IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Ticor Title Insurance Company, on behalf of Raymond Magaro and Theresa (sic) A. Magaro (nee Long), Plaintiffs, John Searer (aka John Sierere, John Sierer, John Seirer); Jacob Remminger (aka Jacob R. Remminger, Jacob Renninger, Jacob R. Renninger); Lillie Renninger (aka Lily Renninger, Lillian Renninger); Jacob Milton Renninger (aka Milton Renninger);: their heirs and assigns, : Defendants : Complaint - Civil Docket No. 02-92 Civil Term Action to Quiet Title PROPOSED FINAL ORDER This __ day of 2002, final judgment is hereby entered in the above captioned matter quieting title in favor of Raymond Magaro and Teresa A. Magaro and against Defendants, to the real property located at 121 Salt road, East Pennsboro Township, Cumberland County, Pennsylvania, as more particularly described in the Complaint filed in this matter. The Defendants and any of their heirs and assigns are forever barred from asserting any right, lien, title or interest in this land inconsistent with the interest or claim of Raymond Magaro and Teresa A. Magaro as set forth in the Complaint. By the Court Jo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Ticor Title Insurance Company, on behalf of Raymond Magaro and Theresa (sic) A. Magaro (nee Long), Plaintiffs, John Searer (aka John Sierere, John Sierer, John Seirer); Jacob Remminger (aka Jacob R. Remminger, Jacob Renninger, Jacob R. Renninger); Lillie Renninger (aka Lily Renninger, Lillian Renninger); : Jacob Milton Renninger (aka Milton Renninger);: their heirs and assigns, : Defendants : Complaint- Civil Docket No. 02-92 Civil Term Action to Quiet Title MOTION FOR ORDER TO QUIET TITLE AND TO SERVE THE ORDER BY PUBLICATION ON THE DEFENDANTS NOW COMES, Ticor Title Insurance Company, through its counsel, Dilworth Paxson, LLP, and moves for an Order to quiet title to the property known as 121 Salt Road, East Pennsboro, Cumberland County, Pennsylvania pursuant to Rule 1066 of the rules of Civil Procedure. The property is more fully described in the complaint filed in this action and in the deeds recorded in Book 119 page 835, and Book 189 page 1139. This action is being taken by Ticor on behalf of Raymond Magaro and Teresa A. Magarot (nee Long) and an Order is sought to quiet title in their names. It is further moved that service of this Order be pemfitted by publication, as was the Complaint in this case, in consideration of the fact that Defendants are unknown persons. In support of this Motion, Plaintiff states the following: 1) Service of the quiet title action on Defendants was by publication in the Harrisburg Patriot News on January 23, 2002 pursuant to Order of this Court. 2) An affidavit of Michael Morrow providing Proof of Publication in the Harrisburg Patriot News is attached as Exhibit A. 3) Service was also provided through publication in the Cumberland County Law Journal on February 1, 2002 pursuant to Order of this Court. 4) An affidavit of Roger M. Morgenthal providing Proof of Publication in the Cumberland County Law Journal is attached as Exhibit B. 5) The notices published in the Harrisburg Patriot News and the Cumberland County Law Journal included a Notice to Defend. The attached affidavit of counsel, having duly caused a notice of Complaint with the Notice to Defend to be served by publication in accordance with Order of Court dated January 16, 2002, is provided in accordance with Pa. R.C.P. 1066(a) as Exhibit C. 6) It has been more than thirty day since service by publication and filing of the complaint to Quiet Title. 7) No person has come forward to respond to the published notices. 8) The rules of civil procedure provide that the court shall grant appropriate ~ The caption in the case contains an error in the spelling of Teresa A. Magaro's name. The correct spelling as set forth on the deeds is "Teresa" rather than "Theresa" and all Orders should be entered in the name of Teresa. relief upon affidavit. The rules further provide that upon granting relief, the court shall order that the defendant be forever barred from asserting any right, lien, title or interest in the land inconsistent with the interest or claim of the plaintiff, unless the Defendant takes action as directed within thirty days. Pa.R.C.P., Rule 1066(a); 1066 (b)(1). The Plaintiff specifically requests that the court issue an Order that forever bars the Defendants from asserting any right, lien, title or interest in the land. The Plaintiff contends that it would be appropriate to require the defendant to respond within thirty days of notice of the Order, by filing a responsive pleading with the court, with a copy to Plaintiff's counsel, of Defendant's belief that a legal claim to the property at issue exists and the basis for that claim. 9) Plaintiff further states that because the Defendants are the unknown heirs and assigns of person long deceased, the Order must be served by publication in the same manner as the complaint and Notice to Defend was served. If the Court signs the attached Order, Plaintiff will have the Order published in the Harrisburg Patriot News and the Cumberland County Law Journal. 10) The rules of civil procedure also state that a final judgment will be entered upon filing of a praecipe if the Defendant does not take the directed action within thirty days. A proposed order for final judgment is attached for approval by the Court. WHEREFORE, it is respectfully requested that the proposed Order attached to this Motion be entered which will Quiet Title in the names of Raymond Magaro and Teresa A. Magaro if Defendants fail to take action as directed within thirty days of notice served by publication. If Defendants fail to respond within thirty days of service by publication, a final judgment will be entered upon the filing of a praecipe by the Plaintiff in the fomi attached as a Proposed Order. Dated: April 3, 2002 Respectfully submitted, Linda C. Smith Dilworth Paxson, LLP 305 N. Front Street, Suite 403 Harrisburg, PA 17101-1236 (717)- 236 4812 Attorney ID # 35868 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, .~oproved May16, 1929 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 laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of ~_~t[dg~Y~ and The ~ newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, 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 their regular daily and/or Sunday/ Metro editions which appeared on the 23rd day(s) of January 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations 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 statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Da · · · ok "M", PUBLICATION ................................................................................. Sworn to and subscribed be,~m t~is 2~of Ja..Ib~ 2002 A.D. I Tem/L. Russ[lll, Nota~yPut~lic~~'4~ / /~,~-~1/ L_~'~ z~-~'-~'- ~ ~( IHarflSb~lrg, Dauphin County IN'OTARY PUBLIC ~My Commission Expires June 6, 2005 commission expires June 6, 2002 Member, Pennsylvania Association o! Notaries DILWORTH PAXSON, LLP 305 NORTH FRONT STREET, SUITE 403 HARRISBURG, PA. 17101 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 $ 167.69 $ 1.75 $ 169.44 Publisher's Receipt for Advertising Cost publisher of ~L~l~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 : : SS. COUNTY OF CUMBERLAND : 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 FEBRUARY 1, 2002 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 Roger M. Morgentlial, Edito SWORN TO AND SUBSCRIBED before me this 1 day of FEBRUARY, 2002 CUMBERLAND LAW JOURNAL NOTICE Be it known that Ticor Title In- surance Company, on behalf of Raymond Magaro and Theresa A~ Magaro (nee Long) of 121 Salt Road, East Pennsboro Township, Ctunber- land County, Pennsylvania has filed a complaint to Quiet Title to the property at 121 Salt Road, East Pennsboro Township, against any interest of John Seater {a/k/a John Sierere, John Sierer, John Seirer); Jacob Remminger (a/k/a Jacob R. Remminger, Jacob Renninger, Ja- mb R. Rennhn4~er); Lillie Renninger (a/k/a Lily Renninger, Lillian Renninger); Jacob Milton Renninger (a/k/a Milton Renninger); their heirs and assigns. NOTICE If you wish to defend, you must enter a written appearance person- ally 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 Judg- ment may be entered against you by the court without further notice for the relief requested by the plain- tiff. You may lose money or prop- erty 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. PENNSYLVANIA BAR ASSOCIATION LAWYER REFERRAL SERVICE P.O. Box 186 100 South Street Harrisburg, PA 17108 PA Residents Phone: 1-800-692-7375 or (717) 238-6715 LINDA C. SMITH, ESQUIRE DILWORTH PAXSON LLP Attorneys for Plaintiff 305 N. Front Street Suite 403 Harrisburg, PA 17101 (717) 236-4812 Feb. 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Ticor Title Insurance Company, on behalf of Raymond Magaro and Theresa (sic) A. Magaro (nee Long), Plaintiffs, John Scarer (aka John Sierere, John Sierer, John Seirer); Jacob Remminger (aka Jacob R. Remminger, Jacob Renninger, Jacob R. Renninger); Lillie Renninger (aka Lily Renninger, Lillian Renninger); Jacob Milton Renninger (aka Milton Renninger);: their heirs and assigns, : Defendants : Complaint - Civil Docket No. 02-92 Civil Term Action to Quiet Title AFFIDAVIT OF COUNSEL Linda C. Smith, Esq., Counsel to the Plaintiff, being duly sworn according to law, affirms the following facts to be true to her best information, knowledge and belief: 1. I caused service of notice of the filing of a Complaint by publication pursuant to order of this court with a notice to defend, in the Harrisburg Patriot News and in the Cumberland Law Journal as set forth in Exhibits A and B. 2. It has been more than thirty days since publication and Defendants have not responded to the Complaint or the Notice to Defend by the filing of an Answer or any other communication. Linda C. Smith Sworn to and subscribed before me this ~ day of April, 2002. Notary Public Notarial Seal Heldi Jo Graybill, Notary Public Harrisburg, Dauphin County My Commission Expires Sept. 2, 2002 M~mber, Pennsylvania Association et Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Ticor Title Insurance Company, on behalf of Raymond Magaro and Theresa (sic) A. Magaro (nee Long), Plaintiffs, Ye John Searer (aka John Sierere, John Sierer, : John Seirer); : Jacob Remminger (aka Jacob R. Remminger, : Jacob Renninger, Jacob R. Renninger); : Lillie Renninger (aka Lily Renninger, : Lillian Renninger); : Jacob Milton Renninger (aka Milton Renninger);: their heirs and assigns, : Defendants : Complaint - Civil Docket No. 02-92 Civil Term Action to Quiet Title PRAECIPE TO THEPROTHONOTARY: Please enter Final Judgment in favor of the Plaintiffs in the above-captioned matter, in the form attached hereto, pursuant to this Court's Order of April 11, 2002, for failure of any Defendant to respond to the Complaint filed in this matter. This Court's April 11, 2002 Order was served upon all Defendants pursuant to the April 11, 2002 Order, by publication in the Cumberland County Law Journal on April 26, 2002, and in the Harrisburg Patriot News on April 20, 2002. 19087-1 Dated: June 19, 2002 Respectfully submi,tted, Linda C. Smith Dilworth Paxson, LLP 305 N. Front Street, Suite 403 Harrisburg, PA 17101-1236 (717)- 236 4812 Attorney ID # 35868 19087-1 124450032603 CCS746 Case No. 2002-00092 ******************** *STATEMENT OF COSTS* Pa~e 64 3726/2003 To: Dennis E.. Lebo Cumberland County - Clerk of Courts 1 Courthouse Square Carlisle, Pa I7013 LAWLEY LUKE 771 TOWER ROAD ENOLA, PA 17025 Date Transaction 03/13/02 COURT COSTS Totals Debit Credit Balance 21.47 21.47 21.47 21.47 03/13/02 SHERIFFS COST 1.50 1.50 Totals 1.50 1.50 03/13/02 OFF F.E. ACT158 5.00. 5.00 Totals 5.00 5.00 03/13/02 CCC ACT 139 25.00 25.00 Totals 25.00 25.00 o3/ 3/o2 CVC ACT 139 15.00 15.00 Totals 15.00 15.00 03/13/02 DVC - ACT 44 Totals 10.00 10.00 10.00 10.00 o3/13/o STATE COST A 9.81 9.81 Totals 9.81 9.81 o3/13/o2 STATE COST B 14.72 14.72 Totals 14.72 14.72 03/13/02 JCP FEE Totals 5.00 5.00 5.00 5.00 03/13/02 DISTRICT ATTY Totals 15.00 15.00 15.00 15.00 03/13/02 PLEA Totals 125.00 125.00 125.00 125.00 03/13/02 AUTOMATION FEE 5.00 5.00 LAW OFFICES OF PULEO & D'EMILIO 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 By: Thomas I. Puleo, Esquire Identification No. 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ATLANTIC MORTGAGE & INVESTMENT CORPORATION, a division of ABN AMRO Mortgage Group, Inc Plaintiff Vo SHANE D. BURGER and SHELLEY LEE LAWRENCE, Defendant NO. 02-91 Civil Term A~FFIDAVIT OF SERVICE I, Thomas I. Puleo, Jr., Legal Assistant to Thomas I. Puleo, Esquire, attorney for plaintiff, being duly sworn according to law, deposes and says that he mailed by ordinary mail a Notice of Sale pursuant to Pa.R.C.P 3129.2 upon the persons listed below on the 24th day of July, 2003 as evidenced by the U.S. Postal Service Certificate of Mailing (Fonm 3877), which is attached hereto as Exhibit "A": Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Barry A. Richmond 237 Gravel Hill Road Palmyra, PA 17036 SWORN TO AND SUBSCRIBED BEF~ ME THIS dr/A& DAY OF ,2003. 'OgA 4c PUBIC- ' ' Commonwealth of PA Department of Public Welfare P. O. Box 2675 Harrisburg, PA 17105 Beneficial CDC d/b/a Beneficial P.~ ~. ~Bo~,499 ,,~l;affmas I. Puleo, Jr., Legal Assistant T45omas I. Puleo to NOTARIAL S~-- N FUENTES, Notary Pubhc ] I .. ~Whi~pain Twp., Montgomery County I!elN elqm, unooov JO..-I LAW OFFICES OF PULEO & D'EMILIO 660 Sentry parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 By: Thomas 1. Puleo, Esquire Attorney for PLAINTIFF Identification No. 27615 IN THE coURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ATLANTIC MORTGAGE & INVESTMENT AMRO CORPORATION, a division of ABN Mortgage Group, Inc Plaintiff SHANE D. BURGER and SHELLEY LEE LAWRENCE, Defendant NO. 02-91 ,Civil Term AFFIDAVIT OF SERVIC_~_E I, Thomas I. Puleo, Jr., Legal Assistant to Thomas I. Puleo, Esquire, attorney for plaintiff, being duly sworn according to law, deposes and says that he mailed by ordinary mail a Notice of Sale pursuant to Pa.R.C.P 3129.2 upon the persons listed below on the~th day of July, 2003 as evidenced by the U.S. Postal Service Certificate of Mailing (Form 3877), which is attached hereto as Exhibit "A": Lower Allen Township 1993 Hummel Avenue Camp Hill, PA 17012 Lower Allen Township 120 Limekiln Road New Cumberland, PA 17070 ~-- O ~ssistant t Thomas I. Puleo SWORN TO AND SUBSCRIBED BEFQ..~ME THIS O~~''a'DAY OF - Ct It/ ,2003.. NOTARALSEAL -- LUZ N FUENTES Notary Pubt~c Whitpain Twp,, Montgomery County LMY Comm_isston E. xp?_ ees January 13, 2007~ , i I I I \ LAW OFFICES OF PULEO & D'EMILIO 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 By: Thomas I. Puleo, Esquire Identification No. 27615 Attorney for PLAINTIFF 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ATLANTIC MORTGAGE & INVESTMENT CORPORATION, a division of ABN AMRO Mortgage Group, Inc Plaintiff SHANE D. BURGER and SHELLEY LEE LAWRENCE, Defendant NO. 02-91 Civil Term AFFIDAVIT UNDER PA. RCP RULE 3129 THOMAS I. PULEO, attorney for Plaintiff in the above captioned mortgage foreclosure action, sets forth as of the date the praecipe for the Writ of Execution was filed, the following information concerning the real property located at 403 Deerfield Road, Camp Hill, Cumberland County, Pennsylvania, was true and correct to the best of its lmowledge, information and belief. 1. Name and address of each Owner and/or Reputed Owner: Shane D. Burger 403 Deerfield Road Camp Hill, PA 17011 Shelley Lee Lawrence 142 15~ Street, Unit R New Cumberland, PA 17070 Name and address of each Defendant named in the judgment: Shane D. Burger 403 Deerfield Road Camp Hill, PA 17011 Shelley Lee Lawrence 142 15th Street, Unit R New Cumberland, PA 17070 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Lower Allen Township 1993 Hummel Avenue Camp Hill, PA 17012 Lower Allen Township 120 Limekiln Road New Cumberland, PA 17070 Name and address of the last recorded holder of every mortgage of record: Atlantic Mortgage & Investment Corporation, Plaintiff 7159 Corklan Drive Jacksonville, FL 32258 Barry A. Richmond 237 Gravel Hill Road Palmyra, PA 17036 Beneficial CDC d/b/a Beneficial Mtg. Co. of PA P. O. Box 4499 Harrisburg, PA 17111 Name and address of every other person or entity which has any record lien on the property: None Name and address of every other person or entity which has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Commonwealth of PA Department of Public Welfare P. O. Box 2675 Harrisburg, PA 17105 Name and address of every other person of whom the Plaintiff has knowledge who may have an interest in the property which may be affected by the sale: None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to umswom falsification to authorities. Date: July 25, 2003 Attorney for Plaintiff