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IN THE- COURT OF COMMON PLEAS OF CUMBERLAND C
NO. 21-11-0011 ORPHANS' COURT ~~~ ~ + ~~ j2" "~`
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ESTATE OF LEWIE B. ANDERSON
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PETITION TO MAKE RULE ABSOLUTE AND FOR ORDER APPROVING
PRIVATE SALE OF REAL PROPERTY BY GUARDIAN
TO THE HONORABLE JUDGE OF SAID COURT:
The Petition of Daren D. Anderson, Guardian for the estate and person of his father,
Lewie B. Anderson, represents that:
1. Petitioner, Daren D. Anderson, is an adult individual who resides at 691 South
82nd Street, Harrisburg, Dauphin County, Pennsylvania 17111.
2. On March 9, 2011, after a hearing, The Honorable J. Wesley Oler, Jr. appointed
Daren D. Anderson as guardian of the estate and person of Lewie B. Anderson, an
incapacitated person, and a bond was posted by Daren Anderson of $120,000 with AIA
Insurance acting as surety as required by the Court's Order of Appointment.
3. Lewie B. Anderson, age 82, is a resident at the Golden Living Center, 770 Poplar
Church Road, Camp Hill, Cumberland County, Pennsylvania and possesses little assets save
his real property which he owned jointly with his spouse, Violet Anderson, now deceased.
4. Lewie B. Anderson is now the sole owner in fee simple of real property located at
32 Southmont Drive, Enola, East Pennsboro Township, Cumberland County, Pennsylvania and
acquired the same by Deed dated September 16, 2002 and recorded in the Cumberland County
Recorder of Deeds Office at Deed Book 253 and Page 3199. This property has tax assessment
number 09-14-0835-184. A true and correct copy of the legal description is attached hereto as
Exhibit A.
5. This Property was owned jointly as tenants by the entireties by Lewie Anderson
and his late wife, Violet Anderson; however, Violet Anderson died on April 13, 2011. A copy of
her Death Cert~cate is attached hereto as Exhibit B.
6. On May 5, 2011, Guardian Daren D. Anderson filed a Petition seeking Court
approval to privately sell the above-mentioned real estate pursuant to Orphan's Court Rules
14.4 and 12.10.
7. This Honorable Court issued a Rule to Show Cause dated May 9, 2011, and
returnable within fourteen (14) days after service to the interested parties.
8. Petitioner Guardian served the rule on all interested parties, his siblings, with the
exception of Damond D. Anderson on or about May 13, 2011.
9. Attached hereto as Exhibit C are the consents to the sale of interested party
Deborah Nissley and Dwayne D. Anderson, leaving only Diane D. Coombe and Damond D.
Anderson as not having filed consents to the sale.
10. Also attached hereto as Exhibit D is the Affidavit of Elizabeth D. Snover,
Esquire, concerning service of the Petition and Rule to Show Cause.
11. Petitioner Guardian has been in communication with Diane Coombe, who has
expressed no objection to the sale and, to Petitioner's knowledge at the time of this filing, have
not filed objections in response to the Rule to Show Cause.
12. As set forth on Exhibit D, counsel for Petitioner Guardian attempted to serve
Damond D. Anderson with the Petition and Rule to Show Cause at four separate addresses
which were revealed through a Lexis Nexis Smartlinx search of nationwide public records.
13. Counsel was previously successful in serving Damond Anderson with notice of
the Guardian Petition at the Mechanicsburg addresses, -but it appears that Mr. Anderson has
moved since that notice was sent a few months ago.
t ~
14. Damond D. Anderson has dropped out of contact with all of his siblings and even
failed to attend his mother's funeral last month.
15. Counsel also contacted the Cumberland County Sheriffs Office for the current
whereabouts of Damond D. Anderson, since he is currently under several payment plans for
fines and costs related to DUI convictions.
16. The Sheriff gave an address for Mr. Anderson of 370 Creek Road, Shermans
Dale, Pennsylvania, however, that address also appears to be stale for Mr. Anderson since the
mailing I sent has been returned as unable to forward.
17. On May 18, 2011, counsel for Petitioner Guardian confirmed that on May 17,
2011, five (5) bench warrants were issued for Damond D. Anderson related to his failure to stay
current on his restitution and fines. Those warrants are on Cumberland County Criminal Docket
at Numbers: 938-1991, 2333-1990, 343-1992, 949-1992, and 2978-2004.
18. It is belived and averred that Damond D. Anderson has fled the jurisdiction or is
in hiding relative to these warrants.
19. As such, despite significant efforts by counsel and despite significant costs to the
estate, service upon Damond D. Anderson could not be conferred.
20. Petitioner Guardian asks this Honorable Court, despite this lack of confirmed
service on Damond D. Anderson, to approve the Private Sale as outlined in this Petition.
21. Time is of the essence with this sale.
22. Effectuating alternative service through publication would delay and, possibly,
void the sale under the terms of the Agreement if closing cannot occur before June 29, 2011.
23. Since Petitioner Guardian has pled that the proceeds of the sale, after costs, will
go entirely to the care and board for Lewie B. Anderson at the Golden Living Center, it is
submitted that any objection or claim raised by Damond D. Anderson would be without merit.
f 1
24. In fact, it is estimated that the proceeds from the sale would pay for less than one
(1) years worth of care and board for the incapacitated person.
25. A sale of the real estate is necessary since .the real property mentioned above is
the only significant asset of the estate of Lewie Anderson.
26. This asset needs to be liquidated to pay for the ongoing medical care, treatment,
and board for Lewie Anderson at the Golden Living Center.
27. The above-mentioned real estate has been vacant since March 2010, and
medical testimony at the March 9, 2011 hearing confirms that Lewie Anderson will remain
unable to return to the residence.
28. The real property has been listed for private sale with Real Estate Brokerage
Howard Hanna and with agent Todd Doyle, who is a licensed Real Estate Agent in the
Commonwealth of Pennsylvania.
29. An Agreement of Sale has been signed which would sell the property for
$134,900 to Todd J. Putt. A true and correct copy of the Agreement of Sale and MLS listing is
attached hereto as Exhibit E.
30. Closing is to occur on or before June 29, 2011.
31. The Buyers will bear all closing costs with Seller providing $4,500 in Seller's
Assistance.
32. Taxes will be prorated as of the date of closing and the Seller will pay 1 % of the
transfer taxes.
33. The reaRors' commissions are 6°~ of the total purchase price.
33. It is estimated that the mortgage on the property has spay-off figure of
approximately $70,639.88. This leaves approximately $64,260.12 in equity before settlement
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costs. This figure is well below the $120,000 security already in place as discussed above. As
such, at this time, it is submitted that no additional .security should be required.
34. Daren D. Anderson petitions this Court to issue a decree approving the sale of
said real property for the sum of One Hundred and Thirty-four Thousand Nine Hundred Dollars
($134,900.00), which your Petitioner believes is an excellent price for the property given its
current condition in the market and was the asking price suggested by the Realtor as referenced
in Exhibit E.
35. Based upon this information provided, Petitioner prays that this Honorable Court
find the sale price of $134,900.00 reasonable.
WHEREFORE, Petitioner, Daren D. Anderson, respectfully requests this Court to issue a
Decree of Confirmation Nisi and approve the private sale of 32 Southmont Drive, Enola, East
Pennsboro Township, Cumberland County, Pennsylvania and authorize your Petitioner to
execute a Deed conveying the real property to Todd J. Putt for the sum of One Hundred Thirty-
fourThousand and Nine Hundred Dollars ($134,900.00).
Respectfully submitted,
IE, STEWA~T & WEIDNER
By:
A y I.D. No. 200997
3 arket Street
P. O. Box 109 .
Lemoyne, PA 17043-0109
Telephone (717) 761-4540
Attorneys for
Attorneys for Daren D. Anderson
Date: May 27, 2011
EI~l~IT "A"
ALL THAT CERTAIN piece or parcel of land situate in the Township of East Pennsboro, County of
Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a point on the eastern legal right-of-way line of Southmont Drive, at the northwest
comer of Lot No. 37 on the hereinafter described Final Subdivision Plan; THENCE along the eastern
legal right-of--way line of Southmont Drive, North 18 degrees 26 minutes 00 seconds West, a distance of
32.00 feet to a point at the southwest comer of Lot No. 35 on the hereinafter described Final Subdivision
Plan; THENCE along the southern line of said Lot No. 35, North 71 degrees 34 minutes 00 seconds East,
a distance pf 109.94 feet to a point on the western legal right-of--way of Courtney Lane; THENCE along
the western legal-right-of--way line of Courtney Lane, South 18 degrees 26 minutes 00 seconds East, a
distance of 32.00 feet to a point at the northernmost corner of Lot No. 37 on the hereinafter described
Final Subdivision Plan; THENCE along the northem line of said Lot No. 37, South 7I degrees 34 minutes
00 seconds East, a distance of 109.94 feet to a point on the eastern legal right-of-way line of Southmont
Drive, the point and place of BEGINNING.
CONTAINING 3,518.02 square feet, more or less.
BEING Lot No. 36, Section 3, on the Final Subdivision Plan of Laurel Hills North, Lot No. 3 and Lot
No. 4, dated June 1, 1992, revised August 5, 1996, and recorded in the Office of the Recorder of
Deeds of Cumberland County, Pennsylvania, in Plan Book 73, Page 65.
BEING improved with a townhouse dwelling known as 32 Southmont Drive.
SUBJECT TO an Easement for utility Installation and maintenance which is reserved on all lots and
such other easements, as may be shown in recorded documents, granted to Public Utility Companies for
utility purposes. Electric service will be supplied only from the underground distribution system in
accordance with then current PP&L Company Tariff provisions.
UNDER AND SUBJECT, NEVERTHELESS to restrictions, easements, set-back lines and
conditions as now appear of record including, but not 1united to, Declaration of Covenants and
Restrictions applicable to Final Submission Plan for Laurel Hills North Lots 3 and 4, Section 2,
Section 3, Section 4 and Section 5, East Pennsboro Township, Cumberland County,
Pennsylvania, dated March 25, 1994, and recorded in the Office of the Recorder of Deeds of
Cumberland County, in Miscellaneous Book 469, Page 568.
AND FURTHER UNDER AND SUBJECT to a five (5) foot pedestrian access easement across the
northern portion of the premises as shown on the above referenced Final Subdivision Plan.
.LOCAL REGISTRAR'S CERTIFICATION OF DEATH
WARNING: ft is illegal to duplicate Phis copy by photostat or photograph.
Fee for dais carrificate, $fi:Op Tius. is Eo certify__tbat the inforritatiQn here given is
oorroctly copied f`iom an origins! Cerrificate'of Death
' " `: ;; ..:duly filed with me as..Local RegistEa'r. T.he original
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
NO.2011-0011 ORPHANS' COURT
ESTATE OF LEWIE B. ANDERSON
PETITION PURSUANT TO SECTION 5511 OF THE PROBATE, ESTATES AND
FIDUCIARIES CODE TO ADJUDICATE LEWIE B. ANDERSON TO BE INCAPACITATED
AND TO APPOINT A PLENARY GUARDIAN FOR HIS PERSON AND HIS ESTATE
CONSENT TO PRIVATE SALE
STATE OF TEXAS
ss:
COUNTY OF :
I, Dwayne D. Anderson, agree and consent to the private sale of 32 Southmont Drive,
Enola, East Pennsboro Township, Pennsylvania, as pled in the Petition for Approval of Private
Sale filed on behalf of the estate of Lewie B. Anderson by his plenary guardian, Daren D.
Anderson, and, as a person in interest, have no objection thereto.
Dwayne .Anderson
Dated: rj - ~~1
Sworn to and subscribed before me
this ~~ day of , 2011.
rot `' `Bk. JENNIFERANN PETERS
~ * Notary Public
STATE OF TEXAS
My Comm. Exp. 07-25-2011
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
NO. 2011-0011 ORPHANS' COURT
ESTATE OF LEWIE B. ANDERSON
PETITION PURSUANT TO SECTION 5511 OF THE PROBATE, ESTATES AND
FIDUCIARIES CODE TO ADJUDICATE LEWIE B. ANDERSON TO BE INCAPACITATED
AND TO APPOINT A PLENARY GUARDIAN FOR HIS PERSON AND HIS ESTATE
CONSENT TO PRIVATE SALE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ss:
I, Deborah D. Nissley, .agree and consent to the private sale of 32 Southmont Drive,
Enola, East Pennsboro Township, Pennsylvania, as pled in the Petition for Approval of Private
Sale filed on behalf of the estate of Lewie B. Anderson by his plenary guardian, Daren D.
Anderson, and, as a person in interest, have no objection thereto.
De orah D. Niss ey
Dated' ___~~~~ l
Sworn to and subscribed before me
this 1y of , 2011.
COMMONWEHLi n ur rrh~INSYLVANIA
NOTARIAL SEAL __ __ _ . _ _ _
CHERYL R. GARMAN, Notary Public
Camp HNI Boro, Cumberland County
My Commission Expires May 20, 2012
~.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
NO. 21-11-0011 ORPHANS' COURT
ESTATE OF LEWIE B. ANDERSON
AFFIDAVIT OF SERVICE PROVIDED BY ELIZABETH D. SNOVER
I, ELIZABETH D. SNOVER, hereby affirm that:
1. On May 5, 2011, Guardian Daren D. Anderson filed a Petition Seeking Court
Approval to privately sell the above-mentioned real estate pursuant to Orphan's Court Rules
14.4 and 12.10.
2. This Honorable Court issued a Rule to Show Cause dated May 9, 2011, and
returnable within fourteen (14) days after service to the interested parties.
3. Petitioner Guardian, through counsel Elizabeth D. Snover, served the rule on the
interested parties, the Guardian's siblings, with the exception of Damond D. Anderson, on or
about May 13, 2011, by letter dated May 11, 2011 attached hereto.
4. I attempted to serve Damond D. Anderson with the Petition and Rule to Show
Cause at four separate addresses which were revealed through a Lexis Nexis Smartlinx search
of nationwide public records.
5. I was previously successful in serving Damond Anderson with notice of the
underlying Guardian Petition at the Mechanicsburg addresses, but it appears that Mr. Anderson
has moved since that notice was sent a few months ago.
6. Damond D. Anderson has dropped out of contact with all of his siblings and even
failed to attend his mother's funeral last month, making it extremely difficult to locate a more
recent address.
7. I also contacted the Cumberland County Sheriffs Office for the current
whereabouts of Damond D. Anderson, since I had personal information that he is cun'ently
under the watch of a parole officer due to several payment plans for fines and costs related to
DUI convictions.
8. The Sheriff gave an address for Damond D. Anderson of 370 Creek Road,
Shermans Dale, Pennsylvania, however, that address also appears to be stale for Mr. Anderson
since the mailing I sent to that address has been returned as unable to forward.
9. On May 18, 2011, counsel for Petitioner Guardian confirmed that on May 17,
2011 five (5) bench warrants were issued for Damond D. Anderson related to his failure to stay
current on his restitution and fines. Those warrants are on Cumberland County Criminal Docket
at Numbers: 938-1991, 2333-1990, 343-1992, 949-1992, and 2978-2004.
10. It is believed that Damond D. Anderson has fled the jurisdiction or is in hiding
relative to these warrants.
11. As such, despite sign cant efforts by counsel and despite significant costs to the
estate, service upon Damond D. Anderson could not be confirmed.
JOHNSON, F IE~ ST ~ ~qRT 8 EIDNER
By: /~J
Eliz t Snover
Attome . No. 200997
301 Market Street ~ P. O. Box 109
Lemoyne, PA 17043-0109
Telephone (717) 761-4540
Date: May 26, 2011 Attorneys for Petitioner
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF ~ll.-N1.~~L~(U1~ ;
On the ~ day of , 2011, before me, the subscriber, a Notary
Public in and for said Commonwealth d County, personally came the above-named herein,
and who executed the foregoing Release and have acknowledged to me that he/she voluntarily
executed the same.
In Testimony Whereof, I have hereunto se m hand and my seal.
tary is
iONWEALTH OF PENNSYLVANL4
NOTARIAL SEAL
Clad J. Mahoney, Notary Public
I,amoyne Borough, C1~mberland County
lion F 19, 7A14
JEi~RY R. DUFFIE
RICHARD W STEWART WADE D. MANLEY
EDMUND G. MYERS ELIZABETH D.SNOVER
LAW O F F I C E S ANDREW P. DOLLMAN
DAVID W. DELUGE SARAH E. HOFFMAN
JOHN A. STATLER
CAROLYN B. MCCLAIN
o~soN
JEFFERSON J. SHIPMAN
JEFFREY B. RETTIG
KEVIN E. OSBORNE
OF COUNSEL
DUFFIE
MARK C. DUFFIE HORACE A. JOHNSON
JOHN R. NINOSKY C. ROY WEIDNER, JR
MICHAEL J. CASSIDY
MELISSA PEEL GREEVY F. LEE SHIPMAN
(1965-20D6)
WRITER'S EXT. N0. 136
E-Mnn, edsQjdsw.com
May 11, 2011
~a First C/ass and Certified Mail
Dwayne D. Anderson Diane D. Coombe
8422 Timber Crest 744 Trevor Drive
San Antonio, TX 78250-4406 Garner, NC 27529
Deborah D. Nissley Damond D. Anderson
59 East Main Street 967 W. Trindle Road, Lot 31
Mechanicsburg, PA 17055 Mechanicsburg, PA 17055
Re: Petition for Approval of Private Sale of Real Property Owned
by Lewie B. Anderson, an Incapacitated Person
Orphans' Court of Cumberland County
Docket Number 2011-00011
Dear Sirs and Madams:
As you know, we provided you by letter dated May 4, 2011, with the Petition of Daren
Anderson to sell the real estate owned by your father, Lewie B. Anderson, located at 32 Southmont
Drive, Enola, East Pennsboro Township, Pennsylvania. We believe that this property should be sold
in order to pay for Mr. Anderson's medical care and board at the Golden Living Center.
Enclosed, related to that Petition, please find an Order of Court and Rule to Show Cause
issued by the Honorable J. Wesley Oler, Jr. of the Court of Common Pleas of Cumberland County,
Orphans' Court Division. As you can see by this Rule, which was issued on May 9, 2011, you have
fourteen (14) days from receipt of this Order in order to object to the sale proposed in the Petition. If
you do not plan to object to the Petition, it would be helpful for you to return the enclosed consent
form to the undersigned in the self-addressed, stamped envelope provided for that purpose.
However, if you wish to object to the sale, you have 14 days in which to do so and you must make
your objection by filing it with the Orphans' Court for Cumberland County. A hearing before the
Judge would probably be held on any objection. If you have concerns regarding the sale of this
301 MARKET STREET P.O. BOX 109 LEMOYNE, PENNSYLVANIA 17043-0109
WWWJDSW.COM 717.761.4540 FAX: 717.761.3015 MAILC~JDSW.COM
JOHN50N, DUFFIE, STEWART & WEIDNER, P.C.
Interested Parties of Lewie B. Anderson
May 4, 2011
Page 2
property and are not sure whether or not you would like to object, I ask that you contact the
undersigned directly or contact Daren Anderson regarding the sale and the facts set forth in the
Petition. We are hopeful that there will be no objections to the sale and that it will proceed so that
the proceeds from the sale can go toward Mr. Anderson's medical care and expenses which are
mounting.
Very truly yours,
EDS:mas:aa~saz
Enclosures
JOHNSON, DUFFIE, STEWART & WEIDNER
,.~-~
Elizabe D. Snover
cc: Daren D. Anderson (w/ enc.)
IN RE: ESTATE OF IN THE COURT OF COMMON PLEAS OF
LEWIE B. ANDERSON :CUMBERLAND COUNTY, PENNSYLVANIA
21-11-0011 ORPHANS' COURT
ORDER OF COURT
AND NOW, this 9~' day of May, 2011, upon consideration of the Petition Seeking
Court Approval for Guardian of Incapacitated Person's Estate to Sell Real Property by
Private Sale in Accordance with Pennsylvania Orphans' Court Rules 14.4 and 12.10
IT IS HEREBY ORDERED AND DIRECTED that:
1. A Rule is issued upon all interested parties to show cause why the relief
requested should not be granted;
2. Rule returnable within 14 days of service of this Order;
3. Notice of entry of this order shall be provided to all parties by the Petitioner
and she shall file proof of service with the Court;
4. If no answers to the Rule to Show cause are filed, the relief requested by
Petitioner shall be granted upon the Court's receipt of a Motion requesting Rule be made
Absolute. If the Parties file an answer to this Rule to Show Cause, the Court will
determine if a hearing or further Order of Court is needed;
5. The Office of the Register of Wills shall forward said Answers to this Court;
By the Court,
- --E~iaabeth D.-Snov~r,..Esquir~-__-.-_
Attorney for Petitioner
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JERRY R. DUFFLE
RICHARD W STEWART
EDMUND G. MYERS
DAVID W. DELUGE
JOHN A. STATLER
JEFFERSON J. SHIPMAN
JEFFREY B. RETTIG
KEVIN E. OSBORNE
MARK C. DUFFLE
JOHN R. NINOSKY
MICHAEL J. CASSIDY
MELISSA PEEL GREEVY
1or~soN
DUFFLE
WADE D. MANLEY
ELIZABETH D. SNOVER
ANDREW P. DOLLMAN
SARAH E. HOFFMAN
ANDREW J. PETSU, JR.
CAROLYN B. MCCLAW
OF COUNSEL
HORACE A. JOHNSON
C. ROY WEIDNER, JR
R LEE SHIPMAN
(1965-2006)
May 11, 2011
~a First Class and Certified Mail
Dwayne D. Anderson
8422 Timber Crest
San Antonio, TX 78250-4406
Diane D. Coombe
744 Trevor Drive
Garner, NC 27529
Deborah D. Nissley Damond D. Anderson
59 East Main Street 967 W. Trindle Road, Lot 6
Mechanicsburg, PA 17055 Mechanicsburg, PA 17055
Re: Petition for Approval of Private Sale of Real Property Owned
by Lewie B. Anderson, an Incapacitated Person
Orphans' Court of Cumberland County
Docket Number 2011-00011
Dear Sirs and Madams:
WRITER'S EXT. NO. 136
E-MAIL eda@jdew.com
(Resent 5112/11)
As you know, we provided you by letter dated May 4, 2011, with the Petition of Daren
Anderson to sell the real estate owned by your father, Lewie B. Anderson, located at 32 Southmont
Drive, Enola, East Pennsboro Township, Pennsylvania. We believe that this property should be sold
in order to pay for Mr. Anderson's medical care and board at the Golden Living Center.
Enclosed, related to that Petition, please find an Order of Court and Rule to Show Cause
issued by the Honorable J. Wesley Oler, Jr. of the Court of Common Pleas of Cumberland County,
Orphans' Court Division. As you can see by this Rule, which was issued on May 9, 2011, you have
fourteen (14) days from receipt of this Order in order to object to the sale proposed in the Petition. If
you do not plan to object to the Petition, it would be helpful for you to return the enclosed consent
form to the undersigned in the self-addressed, stamped envelope provided for that purpose.
However, if you wish to object to the sale, you have 14 days in which to do so and you must make
your objection by filing it with the Orphans' Court for Cumberland County. A hearing before the
Judge would probably be held on any objection. If you have concerns regarding the sale of this
property and are not sure whether or not you would like to object, I ask that you contact the
301 MARKET STREET P.0. BOX 109 LEMOYNE, PENNSYLVANIA 17043-0109
WWWJDSW.COM 717.761.4540 FAX: 717.761.3015 MAIL~JDSW.COM
JOHNSON, DUFFIE, STEWART & WEIDNER, P.C.
Interested Parties of Lewie B. Anderson
May 11, 2011
Page 2
undersigned directly or contact Daren Anderson regarding the sale and the facts set forth in the
Petition. We are hopeful that there will be no objections to the sale and that ft will proceed so that
the proceeds from the sale can go toward Mr. Anderson's medical care and expenses which are
mounting.
Very truly yours,
EDS:mas:aa~sas
Enclosures
JOHNSON, DUFFIE, STEWART & WEIDNER
a
Elizabet . Snover
cc: Daren D. Anderson (w/ enc.)
JIiRRY R DUFFIE
RICHARD W.STEWART
EDMUND G. MYERS
DAVID W. DELUGE
JOHN A. STA'rLEIt
JEFFERSON J. SHIPMAN
JEFFREY B. RETTIG
BEVtN E. OSBORNE
MARE C. DUFFIE
JOHN R NINOSBY
MICHAEL J. CASSIDY
MELISSA PEEL GREEVY
1oHivsoiv
DUFFIE
May 11, 2011
~a First Class and Certified Mail
Dwayne D. Anderson Diane D. Coombe
8422 Timber Crest 744 Trevor Drive
San Antonio, TX 78250-4406 Gamer, NC 27529
Deborah D. Nissley Damond D. Anderson
59 East Main Street 370 Creek Road
Mechanicsburg, PA 17055 Shermans Dale, PA 17090
Re: Petition for Approval of Private Sale of Real Properly Owned
by Lewie B. Anderson, an Incapacitated Person
Orphans' Court of Cumberland County
Docket Number 2011-00011
Dear Sirs and Madams:
WADED. MANLEY
ELIZABETH D. SNOVER
ANDREW P. DOLLMAN
SARAH E. HOFFMAN
CAROLYN B. MCCLAAI
OF COUNSEL
HORACE A. Jol~soN
C. RoY WEIDNEIt, JR.
F. LEE SHB7bIAN
(1965-2006)
WRITEE'S 1~. No. 186
E-MnII,ede~jdsw.com
As you know, we provided you by letter dated May 4, 2011, with the Petition of Daren
Anderson to sell the real estate owned by your father, Lewie B. Anderson, located at 32 Southmont
Drive, Enola, East Pennsboro Township, Pennsylvania. We believe that this property should be sold
in order to pay for Mr. Anderson's medical care and board at the Golden Living Center.
Enclosed, related to that Petition, please find an Order of Court and Rule to Show Cause
issued by the Honorable J. Wesley Oler, Jr. of the Court of Common Pleas of Cumberland County,
Orphans' Court Division. As you can see by this Rule, which was issued on May 9, 2011, you have
fourteen (14) days from receipt of this Order in order to object to the sale proposed in the Petition.. If
you do not plan to object to the Petition, it would be helpful for you to return the enclosed consent
form to the undersigned in the self-addressed, stamped envelope provided for that purpose.
However, if you wish to object to the sale, you have 14 days in which to do so and you must make
your objection by filing it with the Orphans' Court for Cumberland County. A hearing before the
Judge would probably be held on any objection. If you have concerns regarding the sale of this
property and are not sure whether or not you would like to object, I ask that you contact the
301 MARHET STREET P.O. BOX 109 LEMOYNE, PENNSYLVANIA 17043-0109
WWW.JDSW.COM 717.761.4540 FAX: 717.7613015 MAIL'~JDSW.COM
JOHNSON, DUFFIE, STEWART & WEIDNER, P.C.
Interested Parties of Lewie B. Anderson
May 11, 2011
Page 2
undersigned directly or contact Daren Anderson regarding the sale and the facts set forth in the
Petition. We are hopeful that there will be no objections to the sale and that it will proceed so that
the proceeds from the sale can go toward Mr. Anderson's medical care and expenses which are
mounting.
Very truly yours,
JOHNSON, DUFFIE, STEWART & WEIDNER
EDS: mas:aa~ sae
Enclosures
n er
cc: Daren D. Anderson (w/ enc.)
JF,RRY R DUFFLE
RICHARD W. STEWART
EDMUND G. MYERS
DAVID W. DELUCE
JOHN A.STATLER
JEFFERSON J. sI-IIPMAN
JEFFREY B. RETTIG
REVIN E. OSBORNE
MARE C. DUFFLE
JOHN R NINOSgI'
MICHAEL J. CASSIDY
MELISSA PEEL GREEVY
WADE D. MANLEY
ELIZABETH D. SNOVER
LAW OFFICES ANDREW P. DOLLMAN
O
O~ A
N
p
B
C~
N
"~ 'v
DUFFLE C
A
R
LYN
MC
I
OF Coi1N$EL
HORACE A. JoI->rrsoN
C. ROY WEIDNER, JR.
E LEE SHIPMAN
(1965-2006)
Vvlz[Tl:u's 1•;1T. NU. 13G
F,-h4ATt, e(IR;icj(IgR~.COm
May 4, 2011
~a First Class and Certified Mall
Dwayne D. Anderson
8422 Timber Crest
San Antonio, TX 78250-4406
Deborah D. Nissley
59 East Main Street
Mechanicsburg, PA 17055
Damond D. Anderson
967 W. Trindle Road, Lot 31
Mechanicsburg, PA 17055
Diane D. Coombe
744 Trevor Drive
Gamer, NC 27529 i ~~ i ~
Damond D. Anderson (t'~ /Ir~~ ~ ('~r~
426 Meadows Lane ~-p ,~ ~ 0 U p ~"
Shermans Dale, PA 1709C~ZQ jU'Y~./`~ 1 ~~ Q0
Re: Petition for Approval of Private Sale of Real Property Owned
by Lewie B. Anderson, an Incapacitated Person
Orphans' Court of Cumberland County
Docket Number 2011-00011
Dear Sirs and Madams:
As you are aware, your brother Daren D. Anderson was appointed plenary guardian of both
the person and estate for your father, Lewie B. Anderson. He has determined that your father's
property located at 32 Southmont Drive, Enola, East Pennsboro Township, Pennsylvania, should be
sold to pay for his medical care and board at the Golden Living Center. With the unfortunate
passing of your mother, your father is now the sole owner of this property since your parents owned
this property jointly with rights of survivorship. This means, on your mother's death, your father
obtained full title to the property as a matter of law and without the need to probate your mother's
Will.
Under the Local Rules of Court for Cumberland County, Daren is required to give notice of
this proposed sale to all heirs to Lewie Anderson. Attached hereto is the Petition we are sending to
Cumberland County Orphan's Court for filing requesting that the property be sold pursuant to an
301 MARKET STREET P.O. BOX 109 I.EMOYNE, PENNSYLVANL4 17043-0109
WWW.JDSW.COM 717.761.4540 FAX: 717.761.3015 MAII,~JDSW.COM
JOHNSON, DUFFIE, STEWART & WEIDNER, P.C.
STANDARD AGREEMENT FOR THE SALE OF REAL ESTATE ASR
_ 7hn fmto xemmmrnded gad ~DPruved qr, bot am mulcted q utt hy. 16e membe/s of 16e Ptomyhsnia Aeeoeiatiaa of RFdLTORSOC tPAR)_
DUAL AND/OR DESIGNATED AGENCY -~
A Broker is a Dual Agent when a $roker represents both Buyer and Seller in the same transaction. A Licensee is a Dual Agent when a 1
Licensee tl:prrseau Bvyer and Seller in the same transaction All of Brokal's licensees are also Dual Agents UNLESS there are separate
Designated Agents for Buyer and Seller. df the same Licensee is designated for Buyer and Seiler, fire Licensee is a Dual Arent
PARTIES
BUYER(S): Todd J Putt ~ --
BUYER'S MAILING ADDRESS:
9 Crooked Dr
Enola PA 17025
PROPERTY ADDRESS
SELLER(S): (ltift q fur t~f~ a~
V to )< l- ,.... ,4,,,ste ~ s.....
SELLER'S MAILING ADDRESS:
PROPERTY
in the municipality of East Pannsboro
in file School District of East pew
Identification (e.g., Tax ID #; Paree] #; Lot, Block; Decd Book, Page,
mont Dr `-
ZIP
County of Cumberland
, m file Commonwealth of Pennsylvania.
Date)•
BUYER'S RELATIONSHIP WITH PA LICENSED BROKER
^No Businesr Relationship (Buyer is not represented by s broker)
Broker (Company) Century 21 Piscioneri
Company Address 3315 MArket Street
Camp H01 PA 17011
Company Phone 7i7-737-2121
Company Fax 717-737-7138
Broker is:
~$(Buyer Agent (Broker represents Buyer only)
^Dual Agent (See Dual and/or Designated Agent box below)
^ Transaction Licensee (Broker and
Licensee(s) (Name) Cal Williams
Direct Phone(s)
Cell Phone(s) _
Fax
Email
Licensee(s) is:
^HuyerAgenl with Designated Agency
~IBuyerAgent without Designated Agency
^Dual Agent (See Dual and/orDesigaated Agent box below}
provide real estate services but do not represent Buyer)
SELLER'S RELATIONSHIP WITH PA LICENSED BROKER
^ No Business Relationship (Seller is not represented by a broker)
Hmker (Company) Howard Hanna
Company Address 4079DerrvSt
Harris(wro, PA 17111
Company Phone 717-5'L q-74ed7?~
Company Fax ~125 (o~f - U 3q ?
Broker is:
^ Seller Ag®t (Broker represents Seller only)
^ Dual Agent (See Dual and/or Designated Agent box below)
Licensee(s) (Name) ~~ / (.{
Dinxt Phone(s) 7 / ] - $'~ 7 -~9 3 L
Cell Phone(s) Sfi.~~
Fax 7th- 5- ti-o3 3
Email 't`..~t~r~, 7 2 Ind .-•a, l Cow
Lieensee(s} rs:
^ Seiler Agent with Designated Agency
Seiler Agem without Designaied Agency
Dual Agent (See Dual and/or Designated A ent box below)
By stgniag this Agreement,
agency, if applicable,
Hvyer Initials: V ~ 1
I Pennsylvania Association of REALTORS`
Buyer and Seller each acknowledge having been previously informed of, and cotasented to, dust
ASR Paee I of 1 I Seller lvitials: a7~i r
Revised 1/10
COPYRIGHT PEIVNSV LVANIA ASSOC1AT10:~ OF REALTORS ®2010
I~IO
Fwm pwwa`d blr, Trne Forms tvww TruvFormv.eom 800-999.9612
g
^ Transaction Licensee (Broker and Licensee(s) provide real rstate services but do not represent Seller)
t I. ~p ~~ ~~P~U[EITt~ dated A i 28 2011
z Seller hereby agrees to sell sad convey to Boyer, who agrees to purchase, ffie identified Property.
3 2. PURCHASE PRICE AND DEPOSITS (1-10)
b (A) Purt~tasc Price S 3 ~ O'C1
9
~l g tea. l--t.,.no(.zs~C 7L. ~F-.
7 '' ..sl U S Dollars), to be
1. Depostl at agmog of thts Agreement: paid by Buyer as follows:
6 2. Deposit within 3 days of the Exeendon Date of this Agreement: $
e 3. $ . 1 000.00
to 4. Remaining balance will be paid at settlement.
t t. (B) All fends paid by Buya, incladiag deposits, will be paid by check, cashier's check or wired fonds. All fonds paid by Boyer
a2 within 30 DAYS of settlement, including funds paid at settlement, well be by cashier's check orwited funds, batnot by p~r-
ts sonateheck:
74 (~') Ikposits, regardless of the form of payment and the person designated as payee, will be paid in U.S. Dollars to Hroka for Sella
is (unless otherwise stated here:
is who will retain deposits in an escrow account in cwnformity with all applicable laws and regulations until wnsumtrtation or to
t7 urination of this Agreeinenl. Only real estate brokers arc required ro hold deposits in accordance with the rules and regulations of
to the State Real Estate Commission. Checks lmdaod as
tg Agreement deposit monies may beheld encashed pending the execution of this
20 3. SELLER ASSIST (If Applicable) (I-10)
/ 2t Shca'witl pay $__ X15-00 '~ or
J Buyer's costs, as permitted by the mortgage ]ender, if any. Sella is onl obli reel ro,% of Purchase Price {0 if not specified) toward
~ approved by mortgage lends. Y >m PeY up to the amount or percentage which is
° 4. SETTLEMENT AND POSSESSION (]-10)
~ (A) Settlement Date is June 29 20i 1 or before if Buya sod Sella agree.
(B) Stxtlmtent will occur in the county where the Propvty is located or in an adjacent coon ng normal business hours, unlcrs
Buya and Sella agree otherwise.
~ (C} At time of settlement, die following will be pro-rated on a daily basis between Buya and Seller, reimbursing where applicable;
current taxes (see Notice Regarding Real Estate Taxes); renks interest on mortgage assumptions; catdominium fees and home-
~ owTa association fees; water and/or sewn fees, togdher with any other !)enable municipal sen~ce fees. All charges will be pro-
3i rated for the period(s) covered. Sella will pay up to and including the dart of settlement and Buya will pay for all days foIlow-
sz ing settlement, unless otterwise stated here:
33
34 (D) Conveyance from Sella will be by fee simple deed of special warranty unless otherwise stated here:
35
3s (E} Payment of transfer taxes will be divided equally between Buya and Sella unless otherwise stated hero:
37
. 3s (F) Possession is to be delivered by deed, existing keys and physical possession to a vacant pro
~ broom-clean, at day and time of settlement, unless Sella, before si n . this A PatY free of debris, with all sWctura
40 subject to a lease. 8ni g greanent, has identified in writing that the Property is
°1 (G) If Sella bas identified in writing that the Property is subjcd to a !rase, possession is to be delivered by deed, elating keys and
d2 assignmart of ertiGting leases for the Pro
~ party, togcthawith security deposits and interest, if any, at day and time ofsettlement Sella
will not enter into any new leases, nor extend exiling leases, for the Property without the written consent of Buya. Buya will
44 acknowledge ccisting lease(s) by initialing thc)ease(s) at the execution of this A
45 Tenant-Oecnpted Property Addendum AR Form T pmt' ~I~ o~~~ ~a~ in this Agreement.
°s 5, DATESrP[ME IS OF THE ESSENCE (I-JO) ~~ is attached.
47 (A) Written acceptance of all parties wilt be on or before:
d8 (B) The Settlement Date and aJl oche dates and tithes identified for the performance of aryl obligah'loru of this A
as essence and are binding. greexnent are of the
so (C~ The Execution Date of this Agreentent is the date when Buya and Sella have indicated full acceptance of this Agreement by sign-
5t ing and/or initialing it. For proposes of this
s2 the this A ASr~ent, the numbs of days will be counted from the Execution Daly excluding
53 ~ greement was executed and including the last day of the time period. All changes to tltis Agreement should be Inl-
tialed and dated.
54 (D) The Settlanent Date is not extended by any atha provision of this Agreement and may only be extended by mutual written agreo-
ss ment of the parties.
56 (E) Certain tams and time periods are pre-printed in this Agreement as a convenience to the Buya and Sella. All pre-printed terms
57 and time periods are negotiable and may be than eel
56 to all parties. g by ~~ng out the pre-printed text and inserting different tams acceptable
s9 6, ZONING (1-10j
so Failure of this Agreement to contain the zoning classification (precut in casts where the property (and each parcel thereof, if sub-
st dividable} is zoned solely or primarily to permit single-family dwellings) will render this A
sz voided an greement voidable at Buyer's option, and, if
s3 Y ~OS7~ tendered by th°Buya will be rct rned~o the Buya without any requirement for court action.
Zoaiag Classificfa~tio~J,: ~'s f%/~~ `~ ~
64 Buyer lnitisls: V 7I ~ ASR Pa e 2 of 1I
'^!'y`- R ScUer lnitiab: ~ r~A+.9t
Revised l/10
~ wnratw by True Forms" www.TrueForms.com aD0.4t)9.9612
65
ss
67
Ba
69
70
77
72
79
74
75
`78
n
7B
7s
eo
B7
ez
a3
B4
B5
87
88
89
90
97
9z
s3
94
95
96
s7
98 .
9
i
1D
70
to
70
t
7
1
t
t
t1
ttt
77z
113
114
775
71s
1n
tie
179
120
7z1
122
t23
124
tzs
72B
1z7
128
tze
130
i37
7. FIXTURES AND PERSONAL PROPERTY (I-IO)
(A) RJCLUDED in this sale are all existing items permanently installed in the Property, free of liens, and other items including
plumbing; heating; radiator covers; lighting fixtures (including drandeliers and ceiling fans); pool and spa equipment {including
covers and cleaning equipment); electric animal fencing systems {excluding collars); garage door opaicrs and haitsmitters; tele-
vision antennas; imported shrubbery, plantings and trees any remaining heating and cooking furls stored on the Property at the .
time of satlement; smoke detectprs and carbon monoxide detectors; sump pumps; storage sheds; fences; mailboxes wall to wall
trerpeting; existing window screens, slam windows and sereen/storm doors; window covering hardware, shades and blinds;
awnings .builE-in air crnrditioners built-in appliances; the rangdoven, unless otherwise stated; and, if'owned, water ttesunent s`
toms, propane tanks, satellite dishei: and security systems. Also included: ~'
-- Au Ann! a,,~~ ~ f ~h v; y
(B) The following uetns are LEASED (not owned by Seller). Contact the provrder/vendor for more information (eg., 7+'ater.treatment
systems, propane tanks, satellite dishes and security systems):
(C) EXCLUDED fixtures and iterns:
8. MORTGAGE CONTINGENCY {I-10)
n WAIVED. This sale is NOT contingent on mortgage financing, although Buyer may obtain mortgage financing and(ar the parties
may include an appraisal caitingency.
~( ELECTED.
(A) This sale is contingent upon Buyer obtaining mortgage financing according to the following terms:
First Mortgage on the'Propetty u>s Second Mortgage oa'tht: Property
loan amount s _ ~2B-~+5-De-- ~ 30, r ~ q ~ Loan Amount S
Minimum Tetm 30 years Minimum Term
Type of mortgage FHA Type of mortgage years
Loan-To-Value (LTV) repo: Loan-To-Vatuc (LTV) ratio:
For non-FHAlVA loans LTV ratio not to exceed % For non-FHANA loans LTV ratio not to exceed •~
Mortgage lender _ First American Mortgaoe Mortgage lender
]merest rate 4.760 %; however, Bayer agrees to accept the
interest rate ea may be committed by the mortgage lender, not
to exceed a maximum interest rate of 5.26 %.
Discount points, loan origination, loan placcmart and other fees
charged by the lender as a percentage of the mortgage loan (exclud-
ing any mortgage insurance pranitrms or VA funding fee) not to
exceed % (0% i f not specified) of the mortgage loan.
Interest rate %; however, Bayer agrees to accept the ~
Interest rate ss may be committed by the mortgage lender; not
1o exceed a maximum interesK rate of •/,,
Discount points, loan origination, loan placanent and other fees
charged by the lender as a percentage of the mortgage Iwn (exchtd-
ing any mortgage insuranx preauums or VA Ginding Fee) not to
exceed •h (0•r6 if not specified} of the mortgage loan.
00 antee the interest rate(s) and fee(s) az or below the maximum lauds stated. if lender(s) gives Brayer the ri
~ gage application (ineludin ant for and ordetin of P eted, wrten mort-
pB g PeYm g appraisal and credit reports without delay, az the time required by
~ lender(s)) for the mortgage terms and to the mortgage lender(s) identified in Paragraph 8(A}, if any, otherwise to a responsible
~ the mortgage lenders) to assist in the mortgage loan process.
O9 (D) Buyer will be In default 17f this Agreement if Brayer Tarnishes false information to anyone concerning Btryer's financial
° and/or emplvytnent status, fails to rnoperate in good faith with processing the mortgage loan applleatioa (ineladtng delay
9 (B) The interest rate(s) and fee(s) provisions in Paragraph 8(A) are satisfied if the mortgage lender(s) gives Buyer the tight to guar-
1 ea rate(s), Huya will do so at least ~ days befarc Settlement Date. Buyer gives Seller the ri ~ bo lode in the inter-
z as prnniried by law and the mort a lend ght, at Seller's sole op8on and
3 the mort a -~ Bag ar(s}, to contribute finandally, without promise of reimbursement, to the Buya and/or
4 gag tier(s) to make the above mortgage tam(s) available to Buyer.
(C) Within days (7 if urn specified) Gum the Execution Date of This Agreement, Buyer will make a con l
mortgage lender(c) of Buyers choice. Broker for Buyer, if any, otherwise Broka~ for Sailer, is authorized to communicate with
of the appraisan, fails to loc$ in interest rate(s) as stated in Paragraph B(B), or otherwise causes the lender to reject, refuse
to approve or issue a mortgage loan commitrnent.
(E) 1. Mortgage Cotnmttment Date: June 1 2011 .Upon receiving a mortgage commitment, Buyer will
promptly deliver a copy of the commttmml to Seller.
2. If Sella does not recelve a copy of the mortgage commitment(s) by the Mortgage Commitment Date, Sella may terminate
this Agreement by written notice to Buyer. Seller's right to terminate continues until Buyer delivers a mort
to Shccr. Until Seger ter7niaates this A omen Bu g~ commitment
grc t, yer is obligated to make a good-faith dfort to obtain mortgagtfinancing.
3. Seller trey terminate this Agreement by written noticx: to Buyer oiler the Mortgage Commitment Date if the mortgage comnritmcnt:
a. Does not satisfy the terms of Paragraph 8(A), OR
b. Contains any condition not sperafied in this Agreement (a.g., the Buyer must settle on another property, an appraisal must
be received by the tender, or the mortgage commitment is not valid through the Settlement Date) thaz is not satisfied and/or
removed in writing by the mortgage traders) within 7 DAYS after the Mortgage Commitmrnt pate in Paragraph
8(Exl), or any extarsion thereof, other than those conditions thaz are customarily satisfied at or near settlement (e.g.,
obtaining insurance, confirming employment).
4. if this Agreement is terminated pursuant to Paragraphs 8(E)(2) m (3), or the mortgage loan(s) is not obtained for settlement,
ail deposit monies will be returned to Buyer axording to the tams of Paragraph 22 and this Agreement will be VOID. 8oycr
will be responsible for any costs incurred by Buyer for any inspections or certifications obtained according to the tams of
this Agreement, and any costs incurred by Suyer for. (I) Title search, title insuuance and/or mechanics' lien insurance, or any
fee for cancellation; (Z) Flood insurance, fire insurance, hazard insurance, mine subsidence insurance, or any fee fa canccl-
lati ~ (3)`,4Ppraisal fees and charges paid in advance to mortgage lender(s). ~ )
Bayer Inlttaza: _.~._ ASR Page 3 of [ 1 Seller initials: .99 t p,,J J
~wo+.~M TroeFonns` wWw.Tru•Formsoom eoortro.ael2 Revised tA0 -"`~"-
t33 (F) If the mortgage lender(s), or a property and casualty insurer providing insurance required by the mortgage lender{s), requires
repairs to the Property, Buyer will, upon receiving the requirements, ddiva a copy of the requirements to Sella. Within 5
13a DAYS of recdving the copy of the requirements, Seiler will notify Buya whcthd Sd1a will make the required repairs at Shcers
1s5 expense.
i3a I .. If Seller makes the aired
t37 req tepairs.to the satisfaction of the mortgage Irnda and/or insures, Buys accepts the Property and
agrees to the RELEASE in Paragraph 24 of this Agreement.
13e '~ 2.. If Seller will not make the re aired ~ '
73e DAYS noti SellaofB 9 rePwrs,. or rf Sella fails to respond within the stated time, Buyer wilt, within 5
74Q ' ~ Uyet'a Cl10rCe f0:
a. Make the repairs/improvemmts. at BnYa's rxpense, with permission and access to the Property given by Shca, which
t41 will not be umrrasonably withfidd, OR
taz b. Terminate this mem
tai Agrce by mitten notice to Seller, with all deposit monies returned to Buya according to the teens of
Paragraph 22 of this Agreemedt,
1aa if Brayer fails to respond within the time stated in Para a h 8
t as to Seller within that time, Beyer wltl acre t the P ~ P ~~) or faro to terminate this Agreement by written notice
p roperty and agree to the RELEASE is Paragraph 24 of this Agreement,
tae ' _
i'HA/VA,1F APPLICABLE
1sT (G) It is expressly agreod that notwithstanding any other provisions of this e~ntract, Buya will not be obligated to complete the purchase
fA9 of the property described herciri er to incur any penalty by forfeiture of tamest mon d
has been given, in accordance with HUD(FHA or VA ~' eposiu or otherwise unless Buya
tso requirements, a written statement by the Federal Housing Cormnissioner,
Veterans Admitristratian, or a Direct Endorserirent lends settle forth the a
t51 f 1.3,989'00 13'/ !~ g PP~~d value of the Property of not less than
152 r~_{the Purchase Price ~ stated in this Agrcemesd). Buya will have the privilege and option of
roceeding with consummation of the tmrrtract without regard to the amount of the appraised valuation. The appraised valuation 1
153 is arrived at to determine the maximum mortgage the Department of Housing and Urn Developmem will insure. HUD does
1 not warrarrt the value nor the condition of the Property. Buyer should satisfy himscltYhersdf that the price and condition of the
55 prol~tY are acceptable.
156 ~ Waraiagt Section 1010 of Title I8, U.S.C.,
1sT ~ Administration Transactions, provides, "Whoever for thDepaztmatt of Housing amd Urban Development and Federal Housing
15a Pose of ...influencing in any way the action of such Department,
tss m~~' ~~ utters or publishes any statement, knowing the same to be false shall be fined under this title or imprisoned not ~
more than two years, or both."
160 (}i) U.S. Department of Housing sad Urban Devdopmeat (IiUD) NOTICE TO PURCFIASERS: Buyers Acknowledgememt
t6t Buya has received the HUD Notice "For Your Protection: Get a Home [n
162 getting an independent home inspection and has thought about this before ~nomthiBAes tutderstands the importance of
163 FHA will not perform a home i on nor ~ g greement. Buya understands that
t64 (1) Certification We the undersi ~~ Suttee the ~~ or condition of the Property.
tes ~ geed, Sella{s) and Buyer{s} party to this transaction each certify that the terms of this contract
for purehase are true to the best of our knowledge and belief, and that any other agreement entered into by any of these parties
166 in connection with this transaction is attached to this A$reemart.
167 9. SELLER REPRESENTATIONS (i-10)
r6B (A) Radon Testing and Remediation {See Notice Regarding Radon}
1s9 Seller has no knowledge about the presence or absarce of radon unless checked below:
1TO L.; 1. Seller has ~sowledge that the Property was tested on the dates and by the methods (eg. charcoal canines, alpha track,
rat Ua}, which produced the results indicated below:
t7z Date: Type of Test Results {picoCrrriesJlites or working levels) Name ofTesting Service
773
77a
175
1T6
1n
na
179
190
7a7
182
183
164
185
186
187
tae
199
190
191
192
193
(~ T. Seller has knowledge that the Property had radon removal systan(s) installed as indicated blow:
Date Installed Type of System
Provide
Copies of all available test reports wBl be delivered to Beyer with this Agreement Seller does sot war:ent the methods
or the results of radon tests.
(B) Status of Water
Seller represents that the Property is served,b ..
Public Water ^Community Water LJOn-site Water L; None
{C) Status of Sewer
Ira represarts that.the P~~aty is served by:
Public Sewer I , jCotnmunity Sewage Disposal Systpn [ j Ten-Acre Permit Fatemption (see Sewage Notice 2)
individual On-lot Sewage Disposal System (see Sewage Notice 1) ^ Holding Tank (sce Sewage Notice 3)
hrdividual On-tot Sewage Disposal System in Proximity to Wdl (see Sewage Notice I; see Sewage Noticc4, if applipble)
None (see Sewage Notice I) ^ None AvailablelPemrit Limitations in Effect (see Sewage Notice 5)
Irll {I:..Mi T ___ _
,-i ~-----.r-.rar•,aYV4
Seller is not aware of historic preservation rash-fictions regarding the Property unless otherwise stated here;
784 gayer 1aiNals:
ASR Page 4 of t t
Revised t/10
Form Denxas~d br TrueForma wxw.TruaForma.eom
800•aD&9812
Se1lerlnitials: _. (~'~r ~~iy~gt yJ
tss (E) 'Property. or a portion of it, is prcfaentialfy trssessed for lax
tss Use Restrictions): P°rP°S<s undo the following Act(s) (sec Notices Regarding Land
~ ~ ^ Farmland end Forest Land Assessment Ad (Clean and Grten Pro
^ Open Space Act (Act 442 of 1967; 32 P.S. §5001 et seq.) ~d1n' Act 319 of 1974; 72 P.S. $5490.1 et seq.)
tag . ~ ~~ Itural Area Security Law (Act 43 of ] 48i; 3 P.S. §901 et seq.)
200
~t {F~ Sella represents that,. as of the date Shca.signed this Agreemrnt, rro putrlic;improvement, rondraninivm ~ homeowner association
m2 assessments have ban made agttittst the Property which rtutrain un ai and That no notice b
203 authority has beer[, saved upon $dler~W anyone on Shcet's behalf including notices relating to violaHoars oof tin or Public
2D4 building, safety or fire o'dirrances that remain uncorrcct & housing,
203 of any such ordinances that remain uncorrected. unless oth~erwise~specified h~ows of no condition that arould cortstinne a violation
z0s
zm (G) Sella lntows of no other potential notices {including viotations) and/or assessrnrnts except as follows:
zoa
2oa (H) Access to a public ro8d may require, issuance of a highway ocwpancy.patt»t from the Department of T
ztc 10. WAIVER OF CONTINGENCIES (q.pS7 ransportation.
2t t If this Agreement ls.cootiagent on Bnycr's ri ht to is
ztz g spec[ and/or repair the Property, or to verify insurability, eaviroameatal
conditions, boundaries, caii6caHons, zoning classi5catioe or use, or any, other information regarding the Property, $uyer's
2t3 faDure to exercise aay of Buyer's options within the Hmes act forth in this Agreement is a WAIVER of ti:t coaHngeacy and
zta gayer nccepta the Property and agrees to the RELEASE is Paragraph 24 of this Agreement.
zts 11. INSPECTIONS (1-10).(Sce Notices Regarding property and Environmental Inspections)
zta (A) Rights and RaponsibiUtiea
zn 1. Seller wilt provide access to insraers' representatives and. as may be required by this A
zte strrveyors, municipal officials, appraisers and in ors. All greement or by mortgage lender(s), to
zts 2. Bvya may make a pre-sutlement walk-throu ~ des and their real estate licensee(s) may attend any inspections.
220 gh spection of the Property. Buyer's right to this inspection is not waived by
any other provision of this Agreement.
22t 3. Seller will have heating aad aB atflltiea rncludiag fuel(s)) oa for all iaspechons/appraisals.
z22 4. All inspectors, including home inspectors, are authorized b Bu ato
223 5. Sella hoc the right, upon request, to rccdve a fro co of art ~ provide a copy ofany inspection Report to Broker for Buyer.
z2a (B) Buyer waives or dears at Bu er's ex PY Y ~nspation Report from the party for whom it was prepared.
Y pensc to have the following Inspections, certifications, and investigations (referred to as
~ "Inspection" or "htspxtions") performed by professional contractors, home inspectors, engineers, architects and other properly
228 licensed or otherwise qualified professionals. It the same i or iS i
zz7 with the Horne Inspection Law, (See Notice Regarding the Home InspechnontLaw)more than one systan, the inspector must comply
zee (C) Fo~dected In~ t ~ Ts~B~ ( ~~wo ast"R a ortntorgency period(s) stateQ in Paragraph l2(A), complexe Inspections, obtain any
zzs in cction R
230 Written Corrective Proposal(s) to Seller, according to the terra of Para d aah 1~ ~n Pmpaty' terminate this Agreement, or submit a
zit Home/Pro arty I 1~P ~)'
23z P aspccHons and Environmental Hazards (mold etc.)
~~ tatted Buyer may conduct an inspection of the Property's structural components; roof; exterior windows and exterior Waived
z33 -I---~ doors; exteriorsiding, Exterior Insulation and Fetish S st
234 Y ~ fascia, gutters and downspouts; swimming pools, hot -/
tubs and spas; appliances; electrical systems; interior and exterior plumbing; public sewer syStern.4 heating andcool-
z35 ing systems; water penetration; electroma alit feel
z30 gn ds; wetlands and flood plain delineation; structure square
237 footage; mold and other environmental hazards {erg., fungi, indoor air quality, asbestos, undergrotmd storage tanks,
etc.); and airy other items Buyer may select. ICBuyer dads to have a home inspection of the Property
z3e the Home InspxBon Law, the home in , as defined in
23s borne i ~ must be performed by a full manber in good standing of a national
24o nspection association, or a parser[ supervised by a full member of a national home inspection association, in
accordance with the ethical standards and code of conduct err practice of that assotaetian, rx by a ProP~Y licensed '
eat a registered enginar or ardtitect. Sx Notice R
2az Wed IafestaHoa ( ~'~a% the Home htsitection Law)
243 ,fin elected Buyer may obtain a written "Waod.Destroying Insect Infesta(iat !na lion R
2aa rr.Tv i a wood-deato ' ~ ~'~ ~ an ~r certified as Waived
za5 ymg pests pesticide applicator and wi u deliver it and all supPottutg dtttwments and _ _
tae eel by the rnspator to Sella. The Report is to be mad[ satisfactory to and in compliance with applicabl~,e fagvs, rnort_ j
2a~ gage lender requirements, and/or Federal insuring and Gurtratrtedng Agenry requirements. The Inspection. is ro be
limited to all readily-visible and atxesablc areas of all structures on the Property, except fertcec. Ifthe htspection
zde reveals active infestation(s), Buyer, at Buyer's
gas Heide applicator to treat the if the ~~~' may obtain a Proposal {rota awood-destroying Pasts Pes-
25o may obtain a written R ~~• inspection reveals datttage from active or previous infestation(s), Huya
zs t ~ professional carttrttctor, bane inspector or struMtual engineer that is limited to
structural damage to the Property caused by wood-destroying organisms.and a Proposal to rrpair the Property.
2sz Radoa
253 }*.tEleetcd Buyer may obtain a radon test of the Pr v from a artified i
zsa r °P~, ttspector. The U.S. Environmental proration Waived
259 Agency (EPA) advises corrective action if the average annual exposure to radon is equal to or highs than 0.02 __J
working leveler er 4 pieoCttries/liter (4pCi/I,).
zss Water Service
25~ Elected Buyer may obtain an ton ofthe uali and
zsa inspect' q tY 9uarrtity of the water system from a properly lick or otherwise la Waived
- qualified water/well testing compaay. If and as required by the inspection eomparty, Seller, et Seller's exprnsc, will '!'Gift'/
zss locateandprovideacxssiotheon-silt(orindividual water
~0 dition, a Setter's err ) s7'~an•SdiawiltrrstorethePropertytoitspreviouscon,
~ exp se, prior to settlement.
zet Buyerlniti~ls: ASR Pa 50(11 1~
~ Seller lnltials: _(~ ~~ iew~ , ". 11
Revised t/10 ~ -"--t~`s"".~y~ "~J~ --
Farm pwrraudM TraeForma` wwvr.TrueForms.eom 9°adtt&9at2
zs2 Oa-lotSewage([fAppticable)
z63 erected Buyer relay obtain an Inspection of the individual an-lot
264 ~ inspector. Ifendas utred thei sewage disposal system from a qualified, professional h,#ysived
2s5 ''O9 by nspxtion company, Seller, et Seller's eucperrse, will locate, provide access to, i__ _
and ernpty the itte$vidwl on-lot sewage disposal system. Sella will restore the property to its previous condition,
268 a[ Sellef8 ex ~"~
zs7 Sews I ' Prnse. prior to scttlanent. See paragraph !2(C) for morn information regarding the individual On-lot
z6e ge nspccdon Coningency.
Property Iasuraaee
2s9 Elected' Buyamay deterrtlin'e the insurabilit ofthePro
z7o Y l~Y by Ong apPiiwaon for propeaty and east,alty insurance for awed
z71 .. the., Property to a responsible insum. Hroka for Buyer, if arty, otherwise Broker for Seller, tray comamnicate with ~~
z7ztarry flood insurance Buns~~ P If the Property is located in a flood plain, Buyer. may bo re;quired to
273 ProperiY Botwdaries ya's ertpeatsq whttfi may need ro be ordered 14 days a mono prior to Satlement Date.
. 274 Elected Buyer may engage the services of a stuvey
s7s. _, or, titie.abstractor, or other qualified profixvonal to assess the legal awed
descriptioat,.exttaintyernd location ofbouneiariex end/otquantum of land Most Setters have not had the property :~i'
27a ~ surveyed as if is not a
zn requinarlalt ofpropaty transfer in.Pennsylvania. Any fences, hedges, walls soil other natural
or constructed barriers may or may not represertt the true boundary lines of the Property. Any numerical represat.
27e rations of size of arc
279 >'rOP°rtY approximations only and may be inaccurate.
Deeds, Restrictions sad Zonlag
280 Elected Huya.may investigate easemrnts, deed end use resttictions includin
~1 r ( g airy historic presayatioa reshictions ex Drell- awed
nsnxs) that apply to the Property and rsview !Deal inning tnditumoes. BuYa may vilify that the: presort use of dte ~
28z
zs3 Property (SUCK az in-law quarters, apartments, home office, day care) is permitted and may elect to make the
284 '48fOaUCnt cootingeart upon an anticipated user Present use:
Lead-Based Paint Razards (For Properties prior w 1976 only)
zs5 Elected Before Buyer is obligated to purchase a residexrtial dwdiin built
~s -r risk essesstnecrtand/or in g prior to 1978, Buyer has the option to conduct a eel
ze7 speaion ofihe Propeaty for the presertce of {cad-based paint and/or lead-basedpaint haz-
ardsunless Buyer waives that right. Regardless of whether thin inspection is elected or waived, the Raldmtial
gas Lead-Based Paint Hazard Reduction Act requires a Seller of
ze9 Bnyerwith an EPA-approved lead hazards informa8on pamphlet~d'U d Protect yonroFamly [rom~Lead in
290 Yonr Rome, abag with a se orate fo
287 P rm, attached to this Agreement, disclosing Seller's knowledge oflead-
based paint hazards and say lead-based paint records regarding the Property. (See Notices Regarding
zee Residential Lead-Based paint Hazard ReducHoa Act)
zs3 Other
z9e Elected
295 ....- --`___._. ,,yjWaived
29s /
287 The Inspections elected above do not apply to the following existing conditions and/or items:
298
299
300 12. INSPECTION CONTINGENCY (1-10)
301 (A) The Contingency period is days (] 0 if not specified) from the Execution Oate of this Agreement for each Inspection elected
3oz ih Paragraph 11(C), extxpt the following.
303 Inspection(s)
304 Contingency Period
305
308
307
30
3
31
311
31
313
314
315
318
3t7
318
319
320
321
322
323
324
325
326
927
days
days
Jaya
s ~ (B) Exezpt as stated in Paragraph 12(C7, if the result of an days
09 will. within the stated Contingency Period: Y btspection elected in Paragraph 11(C) is unsatisfaMexy to Buys, Buya
0 l . Accept the Property with the information shied in the R
=. Terminate this reemeat epat(s) and agree to the RELEASE in Paragraph 24 ofWis Agreement, OR
2 Ag by written notice to Sella, with all deposit monies returned to Huya according to the tams of
Paragraph 22 of this Agreement, OR
3. PrearnttheReport(s)to5ellerwitbaWtittenCorrectiveProposat{'Proposal'~gstingcorreetioosandtortn•editsdedr+edbyBuyer.
The Proposal may, but is oat required to, include the name(s) of a propaiy'licensed or qualified.professional(a) to perform We cor-
Rectionsrequested in the; Proposal, provisions for payment, including retests, and a proj ested date for completion of the erorrec-
tions. Buyer agrees that Sella will not beheld liable for comctions that do not comply with mortgage !alder or govemme;ntal
. requirements if performed in a workmanlike manna atcording to the tams of Buya's Proposal,
a. No later than days (5 ifnot specified) from the end of the Contingency Period(s), Sella will inform Buyer in writ-
ing Wert Sella will:
(1) Satisfy all the tams of Buyer's proposai(s}, OR
(2) Not satisfy all the terms of Buyea's Proposal(s), OR
b. ]f Seller agrees to satisfy the terms of Buyer's Proposal or Buyer and Sella cola imo a mutually aetxptable written agree>
merit, Buyer accepts We Property and agrees to the RELEASE in Paragraph 24 of this Agreanrnt.
c, Within days (2 if not specified) of the receipt ofwritteal notifir~Hon that Sella will not satisfy ell terms of Buyer's
Proposal, or the time stated in paragraph 12{B)(3xa) if Seller fails to choose either option in writing, whichever occurs
fi,~rAStn, Buyer will:
Bayer Iatttalr. ~ ASR Paee 6 elf I I
Revised I/]D Seller Initials: ~~/ ~V,~.y, ~/~
Fam pN,etatd M: True Forms' wW1v.TrueForm~.oom x04496.9812
328
328 (1) Accept the Property with the information staled in the Report(s) and agree to tilt R-ELEASE in Paragraph 24 of this
33o Agreement, OR ,
(2) Terminate this Agreement by writtrn notice to Shcc, with all deposit monies returned to Buya axording to the terms of
331 paragraph 22 of this A
332 greemrnt, OR
333 (3) Enter imo a mutually acceptable. written agreement with Sella, providing for any repairs or improvanents to the
Property and/or any aedit to Buya at settlemrnt, as acceptable to the mortgage lender, if arty,
~4 If Buyer fails to reapoad within the time stated in Para
335 graph 12(B)(3)(c) or fails to terminate this Agreement by
written notice to Seller within that time, $nyer will accept the Property and agree to the RELEASE iu Paragraph
33s 24 of this Agreement:
ss7 (C) If a Report reveals the need to expand or replace the existin individual on-lot sewage disposal system, Shca may,'within
~ naame(of the Osmpaxf~ of receiving the Report, submit a Proposal to Buyer, The proposal will include but not be limited to, the
34o p~Y perform the apansion or replacanrnt; provisions for payment, including: retests: and a projected com-
pletion date for correcdve measures. Within 5 DAYS of receiving Seller`s Pi+oposai
34~t stated time, Buya will notify Sella in•writing of Buyer's choice to: . or if ao Proposal is provided within, the
3a2 1. Agra to the terms ofthc
3a3 2. Terminate this ProP°~, accept the property and agree to the RELEASE in Paragraph 24 of this Agreement, OR
3a< Agreanent by written notice to Shca, with all deposit monies returned to Buya according to rite terrlrs of
3a5 Paragraph 22 of this Agramrnt, OA
3. Accept the Property and the.existing system and agper• to the RELEASE in Paragraph 24 of this Agreement. If required by ¢¢y
Sae mortgage lender and/or any governmental authority, Buya will correct the defects before settlement or within the time required
3a7 by the mortgage lender and/or governmental authori at B
349 t3'+ aye's sole expense, with permission and'access to the Property given
349 by Shca, which may hot be unreasonably withheld, if Sd1a denies Buya permission and/or access to correct the defects, Buya
35o may, within 5 DAYS of Seller's datial, laminate this Agreement by written notice to Shca, with all deposit monies returned
to Buya according to the terms of Paragraph 22 of this Agreanert.
3st If Bayer fails to respond wthin the time stated in Paragraph 12(C) or fails to terminate this A
35z to Sella within that time, Buyer wip acce t the Pro ~~ by written notice
353 13. NOTICES, ASSESSMENTS AND MUNICIPAL REQUIREMENTS (1 Ip) RELEASE in Paragraph 24 of this Agreement.
35d (A) In the event any notices, including violations, and/or assessmrnts are received after Sella has signed this Agreement and before
355 settlement, Shca will within 5 DAYS of receiving the notices and/or assessments rovide a
aye meets to Buya and will notify Buya in writing that Sella will: p ropy of the notices and/or ~~-
3s7 1. Fully comtply with the notices andlw assessments, at Shca's ex
35a notices and/or assessments, Buya accepts the Pro Pte. before settlanent. [f Sella fully complies with the
359 PMY rnd agrees to the RELEASE in Paragraph 24 of this Agreemrnt, OR
2. Not comply with the notices and/or assessments, If Sella choosers not to comply with the notices and/or assessmrnts, or fails
~0 withta the stated time to notify Buyer whether Sella wit( tom 1 H a will notify Sella in writing within .__ DAYS
ssr thaz Buya will: p y' ~
3a2 a. Comply with the notices and/or assessments at 8 er's cx
363 Paragraph 24 of this A H' parse, aaxpt the Property, and agree to the RELEASE in
3sa gpeemerri, OR
b. Terminate this Agreement by written notice to Sella, with all deposit monies returned to Buya according to the reties of
3s5 Paragraph 22 of this A
35e greement.
If Buyer fails to respond within the time sffited in paragraph 13(A)(Z) or folio to terminate this Agreement by written nofice
3e7 to Seller withg a that time, Buyer wAl ac t the Pro
Sae rep pertY sad agree to the RELEASE in Paragraph Za of this Agreement,
(B) if required by law, within _~t) DAYS from the Execution Doge of this Agreanent, but in no case Isla than 1~ DAYS prior
3sa to Settlement Date, Sella will order at Seller's ex
370 1~ a notification from the appropriate municipal department(s) disclosing
notice of any uneomcted violations of zoning, housing, building, safety or fire ordinances and/or a artificate pemtitting oecu-
371 panty of the Property. If Buya receives a notice of an
s72 the notice to Sella. Y required repairs/improvemrnts, Huya will promptly deliver a copy of
373 I . Within S DAYS of receiving notice from the munid
37b rnpy of the notice to Huya and notify Buya in writing that Bagger m~'gg:~y~mpro~~s are required, Shca will deliver e
s. Make the required repairs/improvanents to the satisfaction of the municipality. If Sella makes the required
378 repairsrmprovcments, Buya accepts the and
377 b. Not make the re urred proP~Y agrees to the RELEASE in Paragraph 24 of this Agreematt, OR
3>e q • repairsJunprovements. If Seller chooses not to make the required repairs/improvemrnts, Buya will
notify Shca in writing within 5 DAYS that Buya will:
379 {I) Make the rrsf
3eo repo, mprovemrnts at Buyer's expense, with permission and access to the Property given by Sella, which
will not be ameasonably withheld, OR
3e~ (2) Taminatethis.A
3e2 greemrnt by written notice to Seiler, with all deposit monies rettrmcd to Buya according to the tam's
of Paragraph 22 of this Agreement.
3e3 If Bayer fails to respond within the time stated in Para h 13 B
38a written notice to Sailer within that ti ~p {)( ~) or fails to terminate this Altresment by
3e5 tee, Buyer will accept the Property and agree to the RELEASE in Paragraph
24 of this Agreement, aced Buyer accepts the responsibility to perform rho repairslfmprovemeats according to the
366 terms of the notice provided by the maniclpslity.
3b7 ' 2. If Shca denies Bu a '
388 Y permission to make the required repairsrmprovements, or does not provide Buya access before
Settlement Date to matte the required repaitsrmprovemrnts, Huya may, within _~ DAYS, terminate this Agreement by
389 written •nofice to Sella, with all deposit monies returned to Huya according to the tams of Paragraph 12 of this A
390 3. ifrepairslimprovemrnts arc required and Sella fails to greemrnt.
39[ will perform all repairsrmprovements as required by the notice al ~ s ~e notice to Buya as required in this Paragraph, Sella
pease. Paragraph 13(B)(3)wDl snrvivesettiemeat.
392 $uyer tuitislr. ~ ASR Pa 7 of 1I ~ - T
~ Saner [aitials: -+==~ =-k-r-~
Revised 1/t0
F°'^'os'r,.latbY.TrueForms" www.TruuFortns.eom 8n0-499Ae12
3s3 14. CONDOMINIUi4i/PLANNED COMMUNITY HOMEOWNER ASSOCIATIONS) RESALE NOTICE (I-1D)
~° Pr'oPa7' is NOT a Condominium or part of a Planned Community unless chedccd below.
~ rl CONDOMlMUM. The Property is a unit ofa condominium that is primarily run by a unit owners'sssodation, Section 3407 of the
398 Uniform Condominium Act of Pennsylvania (sec Notice Regarding Condominiums and planned Communities u'
3s>' famish Buyer with a Certificate of Resale and copies of the condominium declaration (other than plats and lest are h~ Sella to
396 the rules and regulations of the association. ~ P ~ bylaws and
ass PLANNED COMMUNITY (HOMEOWNER ASSOCIATION). The Pr
coo Uniform Planned Cornmunily Act (see Notice R n oPa'tY is pari of a planned community as defined by the
40t e$erdi g Condominiums and Planned Commtmities). Section 5407(x} of the pa
aoz requires Sella to famish Buyer with a copy of the Declaration (other than plats and Plans), the bylaws, the ntles acid reguluions
of the assceiatioq.and a Certificate con[aining the provisions serforth in section 5407(a) of the Act.
ao3 THE FOLLOWING APPLIES TO PROPERTIES
4oa THAT ARE PART OF A CONDOMIIKITJM ORA PLANNED COMMUNITY,
~ (A) Within 15 DAYS from the Execution Date of this
Certificate of Resale and any other documents n rnt' Shca' at Shca's expense, will request from the association e
x06 the association is required to provide these dacumen ~ , pa~~ of Sd~e~s~t~~~ tth thrr rdevant AU. The Act
4lIT Provides chat
(B) Shca will promptly deliver to Buyer all documents received.from the association. Under the Act, 5dla is not liable to Buyer for
a°6 the failure of~t)rc association to provide the Certificate in a timely manna or for any incorrect information rovided the
cos in the Certi finale: P hy. association
4io (C) The Act provides that Buya may daclare this Agreement VOID ai any time before Buyer receives the associatioo documents and
for 5 days after reedpt, OR until settlement, whichever occurs first. Buyer's notice to Sdta must be in writing; upon Huya
ate declaring this Agreement voi al! d
473 d+ eposit monies will be'returncd to Buyer according to the terms of Paragraph 22 of this
Agreement.
a7s (D) Buyer f any costs incurred tb Buda for e~rry {right of first refttsal), and the association atercises that right; Shcer will reimburse
xis Y Y y inspaxions or certifications obtained actxuding to the terms of the Agreemrnt
and any ousts incurred by Buyer for. {1) Title search, title insivance and/or mechanics' lien insurance, or any fee for cancellation;
°17 (2) Flood insurance, fire insurance, hazard in
47a and dtarges paid in advance to mort ~~' mine subsidence insuraneG or any Fee for cancellation; (3) Appraisal fees
a7s l5. TITLES, SURVEYS AND COSTS (1 IO) lends,
azo (A} The Property will be conveyed with good and marketable title that is insurable by a reputable title insurance company at the regular
azt rates, free and dear of all lirns, rncumbrances, and easanents, excepting however the following: existing deed trstrictions:
a2z historic preservation restrictions or ordinances; buildin restricti
x23 ground; easements ofrecord; and privileges or rights of public service ompanani~ if~emrnta of roads; easements visible upon the
aza (H) Buyer will pay for the following: (I) Title search, title insurance and/or mechanic' lien insurance, or any fee for cancellation;
426 (2) Flood insurance, fire insurance, heard instrrartce, mine subsidence instrrattce, or any fee for cancellation; (3) Appraisal fees
a2s and charges paid in advance to mort
as (C) ,qny y.~,~, or sirrv s cared gage lender, (4}Buyer's customary settlemrnt costs and accruals.
a2s cy req ~ by the tide insurance company or the abstracting company for preparing an adequate legal
az9 description of the Property (or the correction thereof) will be obtained and paid for by Sella, Any survey or surveys desired by
a3o Buyer or required by the mortgage lends will be obtained and paid for by Buyer.
a3t (D) if Sella is unable to give good and marketable title that is insurable by a reputable title insurance company at the regulau rates, u
spedfied in Paragraph 15(A), Buyer may terminate this Agttiement by written notice to Shca, with all deposit monies rdumed to
a3z Buyer according to the terms of Paragraph 22 of this A
°33 incturcdbyBuyaforan i ~eement. Upon termination, Sella will reimburse Buys for any costs
43a Y nspections or catifitxtias7s obtained according to the turns of this Agreement, and for those items specified
aa5 in Paragraph ] 5(H) itcttis (1), {2), (3) grid in Paragraph IS(C).
a3s (~ Sella is not aware of the status of oil, gas and mineral rights for Property unless otherwise stated blow:
.J Seller does not own all subsurface rights to the property,
a3> ]Oil, Gas and Mineral Rights Addendum (PAR Form OGA~ is attached,
x36 (F) COAL NOTICE (Where Applicable)
439 THISDO('IIMENTMAYNOTSFIL,CONVEY,TRANSFER,tNCWDE ORINSURETHETtTLC7'pTyE
440 1HL• SURFACE LAND DESCRIBER OR REFERRF~ TO HEREIN, AND Tii6 OWNER OR OwNERg OF $ (41U COAL IdAY~H,q~ T~ CpMp~~
Oat RIGHT TO REMOVE ALL SUCH COAL AND IN THAT CONNEC710N, DAMAQE AiAY RESULT TO THE SURFACE OF Tti& LAt4D ANp ANt' Hp~~
4as BUILDING OR OTHER STRUCTURE ON OR M SUCH LAND.
aa3 July 17, 1957, P.L. 984.) '•Buyc aclnowledges that he maY not? be obtainm ~n ~ marrner provided in Sation I of the Aa of
4°'t from roal minin8 operations, and that the 8 'ght of protection against subsidence resultin
sas Property desaibed herein may be prorated from damage due to mine subsidence by a
a4s private contract with the owners of the economic interests in the coal. This adtnowledgemetrt is made for the purpose of complying
with the provisions of Section 14 of the Bituminous M,irre Subsidence and the Land Conservation Act of Apn7 27, 19titi:'
atr Suya agzoes to sign the dead from Sella which deed will contain the aforesaid provision.
°'16 (G) The Property is not a 'Yccreational cabin" as defined in the Pennsylvania Construction Code Ael unless otherwise stated here (see
eras Notice Regarding Recreational Cabins):
~0 16. MAINTENANCE AND RISK OF L055 (1-Itl)
a5t (A) Sella will maintain the Property, grounds, fixtures and personal property specifically listed in this A
x52 normal wear and tear excepted, greement in its present rnndition,
459 {B) If any system O[ appliance included in the sale of Property fails before settlement, Sella wilk
L Repair err replace the failed system or appliance before settlement, OR
ass 2. Provide prompt written notice to Huya of Seller's decision to;
ass a. Credit Buyer at settlement for the fair market value of the failed system or a lion
458 if any, OR PP ce, as acceptable to the mortgage lender,
b. Not repair or replace the failed system or appliance, and not credit Huya at settlement for the fair market value of the
ass failed system or appliance.
a6o Buyer Initialr.-~U.A~IIfJ-~' ASR Page 8 of 11
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4sr 3. If Sclltr does not repair or replace the (aped system m appfianct or agree to aedtt Buya for its fair marked vain
a52 fails to notify Bayer of Seaer's choice, Buya will notify Shctr in writing within t, or if Seller
as3 whichever is earlier, that Bu .~_ DAYS or before Senlemrnt Date,
ass yes will:
~ a. Accept the Property and agree to the RELEASE in Paragraph 24 of this A$rttmrnt, OR
b. Terminate this Agrtxmrnt by writtrn notice to Sella, with all deposit monies returned to Buya according to the tens of
'~ Paragraph'22 of this Agreememt.
°t'r If Buyer teas to respond within the'time stated in P
°~ notice to Seller within that times Buyer will accept thae~Property~od 8or fans to terminate this Agreement by written
ass Agreement. Brae to .the RELEASE is Paragraph 24 of this
a?o {C7 , Sella bears the risk of Ions from firs or other casualties until settlantrrt. if any: Property incluilerd in this sale is destroyed and' not
art replaced prior to settlement, Buyer wi1L•
a~z
ass 1' '~~ ~ ~PSiY in its then currrnt condition together with the proceeds of aiky insurance recovery obtainable by Sella, OR
2. Terminate this Agroe:ment by writtexr notice to Seller, with all deposit monies rttumed to' Buyer according to the tams of
era paragraph 2d of this Agreemart.
q~s 17. HOME WARRANTIES (1-10)
*~ At or before settlement, either party may purchast a home warranty for the Property from athird-parry vendor. Buyer and Seller understand
that a home wamnty for the Property does not alts any disclosure requirements of Seller, will not coves or warrant anY Preexisting
6T8 dtfeets of the Property, and will not alto, waivt or extend any provisions of: this ABreement regarding inspections or certifications
ass' thal Buyer has dextexi or waived as part of this Agreanrnt. Buyer and Sella understand. that a broker who recommends a home
48D warranty may have a business relationship with the home warren
4B7 18. RECORDDVG {9-05) h' company that provides a financial benefit to the broke.
as2 This Agreement will not be recorded in the Otliex of the Records of Deeds or in any other offiex or place of public record. If Suya
aaae causes or permits this Agrctmrnt to be recordexi, Sella may elect to treat such act as a default of this Agreemtrtt.
19. ASSIGNMENT (1-10)
w5 This Agreement is binding upon the parties, their heirs, pssonaf represerrtaHves, guardians and successors, and to the extsu astignablc,
4a5 on the assigns of the parties hereto. B swill not
'~~ otherwise stated in this A ~ transfer or assign this Agreemrnt without the written coasrnt of Sella unless
ass 20. GOVERNING LAW, tAND PERSONAL JUWSD7CTION (9-05) iional transfer tastes.
ass (A) The validity and construction of this Agreement, and the rights and dories of the parties, will be governed in accordance with the
a90 laws of the Commonwealth of Permsylvania,
(B) The parties agree that any dispute, controversy or claim arising undo or in connection with this Agreement or its performance by
as3 tither PAY submitted to a court shall be fled acdusively by and in the state or federal courts sitting in the Commonwealth of
Pennrylvania.
4B° 21. REPRESENTATIONS (7-10)
es (A) All represenations, claims, advertising, promotional activities, brochures or plans of any kind made by Seller, Brokers, thdr
asr licemsexs, employees, ofTicers or partners are not a part of this Agretrrtent unless expressly incorporated or stated in this
ase Agreemrnl. This Agreement contains the whole agreanenrt belwexn Sella and Buyer, and there are no othtr terms, obligations,
covenants, representations, statements or conditions, oral or otherwise, of any kind whatsoever concerning this sale. This
eras Agrexanemt will not be altsed, amended, changed or modified excerpt in writing executed b the
500 (B) Unless otherwise stated in this Agreement, Buyer has inspected the Property (including tlrtrtrras cad an
507 specifically listed herein) before s' this y Personalproperty
502 Property IN 7TS PRESENT CONDITION, snbject to inspection e:oaHrtgeneiea elected ~ this so, and agrees to purchase the
so3 that Brokers, thdr licensees, employees, officers or partners have not made an sod Agreement. Buyer acknowledges
550 of the strnctutytt souodne6s of the Prgperty, the age or coudi(iou of the ttmponents~enviroamental cteo d lions,
sos the permitted nse; nor of conditions existing is the locale where the Property is situated; nor have they made a mechanical
so> inspection of any of the systems contained thersia,
5oa (~ ~Y repairs required by this Agreement will be completed in a workmanlike manna,
(D) Broka{s) have provided or may provide services to assist unrepre~rrted parties in canplying with this Agreement.
SOS 22. DEFAULT, TERMINATION AND RETURN OF DEl'051T5 (1-10)
sto (A} Wllere Huya terminates this A$reemt:nt pursuant to any right granted this
5t1 all deposit monies paid on account of Purchase Price ~ ~mtrtt, Buya wilt be exrtitlexl to a raum of
5t2 Pursuant to the tams of Paragraph 22(B}, and this Agreement will be
VOID. Termination of this Agreement may occur for oiha reasons giving rise to claims by Buya and/or Sella far the deposit
sts monies.
5ia {BJ Rtgardless of the apparent rntitle;merrl to deposit monies, Pennsylvania law, dots not allow a Broker holding deposit monies to
sty determine who is entitled to the
st6 deposit mercies when setdtrrrart does not occur, Broker can only release the deposit monies:
1. It this Agreement is terminated prior to settlement and there is no dispute ova rntitlement to the deposit monies. A written
51 ~ agr'eement signed by both Parties is evidrnce that there is no di ute re
5rs sP garding~deposit monies.
2. If, after Broken has received deposit monies, Broker rexdves s writtrn agreemrnt that is signed by Buyer and Sella, directing
st a Broker how to distribute somt or all of the deposit moniex.
520 3, According to the terms of a tinal order of court.
521 4. Aex:ording to the tams of a or written a
522 Pr' groemeart bertweesr Buya and Sella that directs the Broker how to distribute the
dtrposJi~t ~mo~nies if there is a dispute between the parties that is not rtsolve~: {Soe Paragraph 2Z(C)}
523 Boyer lnitiala: _ J ~{ l ASR Page 9 0[ r t ~
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sz4 {C) Buyer and Sella agree that if there is a dispute over the entitlement to deposit monies that is unresolved 365 daysafla
526 Sr'aP 4( ),
525 the Settlement Date stated in Para h A or any written extensions thereof, the Broker holding the depost monies will, with_
in 30 days of receipt of Buyer's written request, distribute the deposit monies to Buya unless the Broker is in receipt of vaifi-
527 ablewri[ten notice that the dispute is the arb'ect of liti
52a the reeei of Bu J gation. If Broker has received verifiable written notice of litigation prior to
529. Pt yer's request for distribution, Broke will continue to hold the deposit monies until receipt of a written distri-
bution agreement between gayer and Sella or a final court order. Buya and Sella are advised to initiate litigation for any por-
~0 lion of the osit monies
531 dap prior to any distribution made by Sroka pursuant to this Paragraph. Buya and,Shca agree that the
ilistnbution of depttsii monies based upon the passage of tirirc does not legally daermine rntitlanent to deposit monies, and that
s3z the parties maintain their 1 al ri is to
533 eE gh ptasue litigation even afters distribution is made.
(D)' Buyer and Seller agree that Brokawho hold's or distributes deposit monies pursuant to the tams of paragraph 22 or Paursylvania
534 ]aw'will not be liable, Buya and Sella. agree that if any Broker or'affiliatcd li
533s monies, theattoineys' fees and costs of the Broker(s) and (icct °~ is named in, litigation regardibg deposit
sac(s) will be paid by the Party naming diem in litigation.
537 (~ Seller has the option of retaining all sums paid by Buyer, including the de~OSit monies, should Buya:
s3a I. Fail to make any additional payments as specific] in Paragtapti 2, OR
2. Ftntrish false or incomplete information •to Sella, Broka(s}, or any. other party .identified in this Agreement concerning
53e Buyer'slegal orfnancial status, OR
540 3. Violate tit fail to fulfill and
541 perform any other tams or conditions of this Agreemert.
5a2 (F) Unless otherwise checked is Paragraph 22(G}, Seller may elect to resin those sums paid by Buyer, including deposit monies;
1. On account of purchase price, OR
543 2. Asanotties'to be applied to Seller's
sea damages, OR
3. As liquidated damages Cor such default.
sas (G) ®SELLER IS LIMITED 'TO RETAil1'ING SUMS PAID BY BUYER, INCLUDING DEPOSIT MONIES, AS
sas LIQUIDATED DAMAGES.
5a7 (I-n If Sella retains al) sums aid b B
548 Buyv and Sella are relaas d from furtha~liability og b gation and thi q ~datcd damages pursuant to Paragraph Z2(F) or (G),
Sae (1) Brokers and licensees are not responsible for un std d greattent is VOID.
550 23. MEDIATION (1-10) P ~ eposits.
551 Buya and Sella wilt submit all disputes or claims that arise from this Agreentrnt, including disputes and claims over deposit monies,
552 to medtabon. Mediation will be eonduaed in accordance with the Rules and Procedures of the Home Shcas/Home Buyers Disport
5~3 Resolution System, unless it is not available, in which pse Buyer and Sella will mediate according to the terms of the mediation sys-
rem offered or endorsed by Ote local Association of REALTORSd`. Mediation fees, contained in the mediator's foe schedule, will be
555 divided equally among the parties and will be paid before the mediation eonfaence. This mediation process must be concluded before
556 enY Parts' to the dispute may initiate I tnceedin
g57 ~ P gs in any courtroom, with the exception of filing a sttmmons if it is necessary to
stop any statute of limitations from expiring. Any agreemau reached through mediation and si
ssa Notix Regarding Mediation). Any agroamatt to maliate disputes or claims arising fi-om t}tis A ~ ~ ~ patties writ be binding (see
559 24. RELEASE (9-05) ipcemenl will survive sattement.
xi0 Bayer releases, quit claims sad forever discharges SELLER, ALL BROKERS, their LICENSEES, EMPLOYEES and any
ss1 OFFICER or PARTNER of any one of them and any other PERSON FIRM or CO
5ez through them, from any and aB claims, losses or demands, inNuding, but not IimitedRo~p Ar.sonaf ]n~nn,mDa Property aa~r
~3 age and aU of the consequwces thereof, whether known or not, which may arise from the presence of tetatItes or other wood-
564 boring insects, radon, lend-based paint ba2ards, mold, fungi or indoor air uaH
sss iadil+idual o°-lot sewage disposal svatem or detldencies is the on-site water urvice~system,~ eery def~tssor conditions on the
ss6 Property. Should Sella be in default coder the terms of this
567 lion, this release don not deprive Buyer of any right to pursue~anyrrenmedies tbat~may be a er ble adera w or equity This
ssa release will anrvive settlement
ss9 25. REAL ESTATE RECOVERY FUND (9-05)
57° ,~ A Real F.~ste Recovery Fund exists to troimbttrse any persons who have obtained a final civil judgment against a Pennsylvania real
577 estate licensee (or a licensee's affiliates) owing to fraud, mi
'72 unable to collect the judgment after exhausting all legal and ~ resattat~edies. Fortcomple~daails abot~e Fund, cap (717) 78~3-
''T3 \, 3658 or (800) 622-2I I3 (within Pesmsylvanis) and (717} 783-4854 (outside pennsylvania).
574 2ti. COMMUNICATIONS WITH BUYER AND/OR SELLER (1-IO)
575 Wherever this Agreement canta.ins a provision that requires W allows communication/delivery to a Buyer, that provision shell be Satis-
57s Pied by commumcation/delivcy to the Broker for Buya, if any, except for documents regnlred to be delivered pursuant to
577 Paragraph 14. If there is no Broker for Buyer, those provisions may be satisfied only by communiation/ddivery being made direct-
578 ly to Ute Buya, unless otherwise agreed to by the parties, Wherever this Agreement contains a provision that requires a allows com-
s>s munieation/delivery to a Sella, that provision shall be satisfied by communication delivery to the Hroka for Seller, if any. If there is
~0 no Broker for Seller, those provisions may be satisfied only by communiwtitat/delivery being made directly to the Sella, unless other
Sal wise agreed to by the parties,
ssz 27.5PECL4L CLAUSES (I-10)
583 (A) The following are part of this Agreement if checked;
584 ;_] Sale & Settlement of Other Pro Contfn en
5a5 IJ Sale & Settlanent of Other Pr+op~ g °Y Addendum (PAR Form SSP)
566 ~~ Settlement of Other Pro PAY Contutgency ~~ Right to Continue Marketing Addendum (PAR Form SSP-CM)
se7 party Contingency Addendum (PAR Form SOP)
sea J Short Sale Addendum to Agreement of Sale (PAR Form SHS)
569 ;Appraisal Contingency Addendum (PAR Form ACA)
59° J
597 1
592 Buyer laitielr.
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594
~5
596
597
598
599
600
607
602
803
604
605
BO6
607
808
809
610
611
612
813
614
(B) Additional Terms;
s15 gayer a~ Seller acknowledge meipt of a copy of this Agreement at the 8me of signing,
816 Th•
fin
fi18
fi19
s2o
eat
822
6x3
82d
s25
6a6
627
628
62s
630
631
s32
s33
634
is Agreement may be executed in one or more eoanterparta, each of which shall be deemed to be as origieal and which
counterparts
together shall constitute one and the same Agreement of the Parties.
NOTICE 7'O PARTIES; WHEN SIGNED, THIS AGREEMENT IS A BINDING CONTRACT. Parties to this transaction are
advised to consult a Pennsylvania rest estate attorney before signing if they desire legal advice.
Retara of this Agreement, and any addenda sad amendments, including return by electronic transiaission, bearing the signatures
of parties, constitutes acceptance by the parties,
~ Buyer has received the Consamer Notice as adopted by the Shte Real Estate Comsaissfoa at 49 Pa. Code
§35386.
~ Bayer has received a statement of Buyer's estiuusted ebsing costa before nia this A
~ cl8 g greement
Buyer has read and understands the notices sad explanatory information in this
Agreement.
~ Buyer has received a Seller's Property Disclosure Statement before signing thin Agreement, it required by law
(see Information Regarding the Real Estate Seller Disclosure Law),
~ Bayer has received the Deposit Mosey Notice far coo
money) before si m this ( ~t"'e ~~ when Broker for Seller is holding deposit
~ g Agreement
Buyer has received the Lead-Based Paint Hazards Fisclosare, which is attached to this Agreement of Sale, and
the pimp t Protect Yoar Family from Lead in Yoar Home (for properties built prior to 1478)
WITNESS BUYER DATE- ~-i~ ~tr
Todd J utt
WITNESS BUYER
DATE
s35 WITNESS B~,~
DATE`_
636 Seller has received the Consamer Notice as adopted by the State Real Estate Commission at 49 Pa. Code § 3533b.
637 Seller has received u statement of Seller's estimated Uosing costs before signing this Agreement.
s~ Seller has read and aadrerstaads the notices sad explanatory information,la this Agreem/e'nt
a39 WITNESS r ( SELLER U~ f lH+,)) DATE S - ~ -
640 WITNESS
bat WITNESS
SELLER
DATE
SELLER DATE
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...
VER/FICAT/ON
I, Daren D. Anderson, verify that the statements made in the foregoing Petition are true
and correct to the best of my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsecation to authorities.
c~
Daren D. Anderson
Dated: _ 5 ~~`-/~
i ~ • ~,
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing Petition has been duly served upon the
following, by depositing the same in the United States Mail, postage prepaid, in Lemoyne,
Pennsylvania on May 27, 2011:
Diane D. Coombe
744 Trevor Drive
Gamer, NC 27529
Deborah D. Nissley
59 East Main Street
Mechanicsburg, PA 17055
Damond D. Anderson
370 Creek Road
Shermans Dale, PA 17090
Dwayne D. Anderson
8422 Timber Crest
San Antonio, TX 78250406
Elizabet . Snover