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HomeMy WebLinkAbout04-4470 MELISSA J. SPENCER, OF Plaintiff, PENNSYLVANIA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, vs. : CIVIL ACTION - LAW ESTHER GOODHART, SALLY L. : NO. IN, 1./'1 '70 CIVIL, 2004 BERKLlTE, JANE BITNER, MARY ANN HADDAD, : ACTION TO QUIET TITLE GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY : JEAN SEIBERT, NANCY THOMPSON, : JOHN C. DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A. DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing n 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY B ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, Pennsylvania 17013 Phone: 717.249.3166 SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS-AT-UW 26 W. High Street Carlisle, P A II MELISSA J. SPENCER, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW vs. ESTHER GOODHART, SALLY L, : NO. b '-I. 4'1 70 CIVIL, 2004 BERKLlTE, JANE BITNER, MARY ANN HADDAD, : ACTION TO QUIET TITLE GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY : JEAN SEIBERT, NANCY THOMPSON, : JOHN C. DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A. DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. COMPLAINT 1. Plaintiff is MELISSA J. SPENCER, an adult individual, residing at 1041 Big Valley Circle, Lipan, Texas 76462. MELISSA J. SPENCER is the only child of MICHAEL L. CRESSLER, who died August 11, 1996, a resident of Hopewell Township, Cumberland County, Pennsylvania. Plaintiff MELISSA J. CRESSLER was the Administrator of his Estate. 2. MICHAEL L. CRESSLER was the owner of certain mountain ground situate in Southampton Township, Cumberland County, SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle, P A II Pennsylvania, consisting of approximately 25 acres, more or less, which is the subject of this action. 3. MICHAEL L. CRESSLER was the sole owner of this land, but gave his brother, JOHN T. CRESSLER, a Power of Attorney in 1945, while MICHAEL L. CRESSLER was in the military overseas during World War II. The purpose of this Power of Attorney was to allow JOHN T. CRESSLER to deal with the property in the event of MICHAEL L. CRESSLER'S death in the War. The granting of this Power of Attorney was for the purpose of accommodation, and was not intended to convey any actual beneficial ownership of real estate or private property in JOHN T. CRESSLER. 4. JOHN T. CRESSLER did, in fact, utilize the Power of Attorney to convey mountain ground in question to MICHAEL L. CRESSLER and JOHN T. CRESSLER, as tenants in common, through a Deed dated October 17, 1945, and recorded in the Office of the Recorder of Deed of Cumberland County on October 8, 1945, in Deed Book "V", Volume 13, Page 202, a copy of which Deed is attached hereto as Exhibit "A", 5. Years later, after JOHN T. CRESSLER'S death, attempts were made to remedy the cloud on the title. Attached hereto as Exhibit "8" is a letter from Hamilton C. Davis, Esquire, of McCrea and Davis, soliciting a Quit Claim Deed to record title of the mountain 2 SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEVS-AT.L\W 26 W. High Sfreet Carlislel P A II ground in the name of MICHAEL L. CRESSLER. An identical letter from Leslie Brandt, Trust Officer at Commonwealth National Bank, attached hereto as Exhibit "C", seeks the same relief. JOHN T. CRESSLER did not re-convey title to the property to MICHAEL L. CRESSLER during his lifetime. 6. MICHAEL L. CRESSLER attempted in his Will to leave the land in question to his daughter, MELISSA J. CRESSLER, now MELISSA J. SPENCER, but his estate was insolvent as a result of various debts. An Order was entered by the Honorable George E. Hoffer in the ESTATE OF MICHAEL L. CRESSLER, to No. 21- 97-0950, in the Court of Common Pleas of Cumberland County, Pennsylvania, authorizing MELISSA J. CRESSLER to purchase the property from the Estate and providing that such sale shall have the effect of a judicial sale discharging the liens upon the real estate. The Order specifically indicated, however, that it would not have the effect of quieting the title or removing any clouds from the title or resolving any disputes related thereto. 7. As the conveyance in question by JOHN T. CRESSLER was one solely for accommodation, and as the failure to re-convey the property from JOHN T. CRESSLER and MICHAEL L. CRESSLER to MICHAEL L. CRESSLER alone is believed to be an oversight, Plaintiff maintains that no actual beneficial interest in the property was conveyed unto JOHN T. CRESSLER. 3 II 8. To the extent that it may be argued that a beneficial interest was conveyed to JOHN T. CRESSLER, it is averred that JOHN T. CRESSLER died in Cumberland County, Pennsylvania, in 1978, and his Estate is filed to No. 21-78-75, in the Office of the Register of Wills of Cumberland County. It is further averred that the residuary legatees of his Estate included DEWEY CRESSLER (a brother who predeceased JOHN T. CRESSLER), JEAN SANDERSON, ESTHER GOODHART, MICHAEL L. CRESSLER, DONALD I. CRESSLER, SALLY LEE BERKLlTE, JANE SCHLOYER (now JANE BITNER), GOD FRIED DEUTSCH, MELISSA CRESSLER (now MELISSA J. SPENCER, and Plaintiff in this action), and the MEMORIAL LUTHERAN CHURCH, of Shippensburg, Pennsylvania, 9. It is the intention of Plaintiff to designate as Defendants, and to give notice of this action, to all of the residuary beneficiaries of JOHN T. CRESSLER'S Estate, or to their heirs if they are not surviving. 10. Defendant MEMORIAL LUTHERAN CHURCH is a church located SAlOIS SHUFF, FLOWER & LINDSAY at 34 East Orange Street, Shippensburg, Pennsylvania 17257. AtTORNEYS-AT-LAW 26 W. High Street Carlisle, PA 11. The heirs of DEWEY CRESSLER, deceased, (more formally George Dewey Cressler) are Defendants MARGARET SEAVERS, 410 Clifton Road, Sh,ippensburg, Pennsylvania 17257; Defendant DOROTHY CRESSLER, of 26 Montgomery Avenue, 4 SAlOIS SHUFF, FLOWER & LINDSAY A'ITORNEVS-AT-LAW 26 W. High Street Carlisle, fA II Shippensburg, Pemnsylvania17257; Defendant JANET SEIBERT, of 322 Mainsville Road, Shippensburg, Pennsylvania 17257; Defendant BETTY JEAN SEIBERT, of 10 Hedgerow Lane, Carlisle, Pennsylvania 17013; and Defendant NANCY THOMPSON, of 24 Montgomery Avenue, Shippensburg, Pennsylvania 17257. 12. Defendant ESTHER GOODHART, is an adult individual residing at the Episcopal Home, 206 East Surd Street, Shippensburg, Pennsylvania 17257. 13. The heirs of DONALD I. CRESSLER, who died in 1986, are DONALD J. CRESSLER (who is deceased leaving no children); Defendant MARY ANN HADDAD, of 131 Chris Drive, Englewood, Ohio 45233-1146; Defendant GAil FREY, of 1145 Pineville Road, Shippensburg, Pennsylvania 17257; Defendant ETTIE PAPOUTSIS, 9300 aide Scotland Road, Shippensburg, Pennsylvania 17257; Defendant VIOLA EPSTEIN, 57 Jackson Drive, Chambersburg, Pennsylvania 17201; Defendant THOMAS CRESSLER, of One Antler Court, Shippensburg, Pennsylvania 17257; and Defendant KAREN MOHN, of 410 West King Street, Shippensburg, Pennsylvania 17257. 14. Defendant SALLY L BERKLlTE, is an adult individual, residing at 13838 Villa View Drive, Waynesboro, F'ennsylvania 17267. 5 SAIDlS SHUFF, FLOWER & LINDSAY A'ITORNEYS-AT.LAW 26 W. High Streel Carlisle, P A II 15. Defendant JANE BITNER, formerly JANE SCHLOYER, is an adult individual, residing at 1314 Pine Run Road, Abottstown, Pennsylvania 17301. 16. JEAN SANDERSON, previously residing at 159 West High Street, Carlisle, Pennsylvania 17013 is now deceased. She left no surviving spouse or children. After reasonable investigation, Plaintiff believes that no Estate was opened for her in Cumberland County, Pennsylvania where she is believed to have resided at her death, or in Franklin County, Pennsylvania. Plaintiff knows of no heirs of Jane Sanderson. 17. Defendant GOD FRIED DEUTSCH died in the year 2000, and his Will was probated in the Office of the Register of Wills of Cumberland County, to File Number 21-00-0338, His heirs are as follows: Defendant JOHN C. DEUTSCH, of 12420 Conde Drive, Brookville, Florida 34613; Defendant RAY G. DEUTSCH, of 329-B Springfield Road, Shippensburg, Pennsylvania 17257; Defendant DON DEUTSCH, of 49 Maple Avenue, Walnut Bottom, Pennsylvania 17266; Defendant CHARLES A. DEUTSCH, of 732 West Brubaker Valley Road, Lititz, Pennsylvania 17543; Defendant JENNIFER DEUTSCH, of 1810 Harvard Boulevard, Dayton, Ohio 45460; JESSE DEUTSCH, of 313 Pine Road, Mt. Holly Springs, Pennsylvania; and Defendant JESSE LEE 6 SAlOIS SHUFF, FLOWER & LINDSAY A1TORNEYS-AT-LAW 26 W. High Street CarUsle, P A II DEUTSCH, of 3541 Orrstown Road, Orrstown, Pennsylvania 17244. 18. After reasonable investigation, Plaintiff believes that the Defendants' named above are all of the heirs of JOHN T. CRESSLER. WHEREFORE, Plaintiff requests this Honorable Court direct the Defendants be forever barred from asserting any rights, liens, titles, or interest in the land inconsistent with the interest of Plaintiff set forth in the Complaint, and that this Honorable Court direct that MELISSA J. SPENCER, sole child and Administrator of the Estate of MICHAEL L. CRESSLER, has all of the right, title and interest in the land described herein, and that no claim, or right, title or interest in the real estate described herein is in any of the heirs or assigns of the aforesaid JOHN T. CRESSLER. SAlOIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff BY:Ja es D. ~e~;~ 1 26 West High Streei' Esquire U C rlisle, PA 17013 hone: (717) 243-6222 1.0.#27742 7 I I " . , ,S-31-04; 6: 12A~,,1:FTW/AF\^r':-= VERI FICA TION I, MELISSA J. SPENCER, Plaintiff herein, hereby verify that the statements made in this Petition for Involuntary Termination of Parental Rights 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 :)f 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. )11t~~~;/j s~J;~I~VU~L'___' ___ \j Date: August ..3..L, 2004 R (---'1 ~ 0 -n '--j 8 ~ ~ i Cd "- "- " ~ \.r-, '" ,,' "- lP., " " l' , \ , , 0 ~ C..:.;.. ~ SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle. P A MELISSA J. SPENCER, PLAINTIFF VS. ESTHER GOODHART, SALLY L. BERKLlTE, JANE BITNER, MARY ANN HADDAD, GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY JEAN SEIBERT, NANCY THOMPSON, JOHN C. DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A. DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, AND JESSE LEE DEUTSCH, AND, THE MEMORIAL LUTHERAN CHURCH DEFENDANTS To the Prothonotary: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 04-4470 CIVIL,2004 : ACTION TO QUIET TITLE PRAECIPE TO ATTACH Please attach these Exhibits to the Complaint filed on September 3, 2004. Date: 9-1 4- 0 <I Respectfully submitted, Saidis, Shuff, Flower & Lindsay By: I Ja es D. Flower, Jr., \ A orney ID #27742 West High Street Carlisle, P A 17013 Phone: 717.243.6222 Fax: 717.243.6510 Attorneys for Plaintiff MADE THE /1 t# day of j _ . ~ of our Lord one thousand nine hund"ed and fortY..fi ve. in the yea,' I I I I I I I i I I I I I I , I 202.CT~111l1ll1 'l'wI' A,'lllll1wl\1tlI(IUIlIlt.ti 11lml'y !lull. lllC., Jllt.llllllll. J'Il. mbi~ 3Jnbtnturt, BETWEEN Michael L. Cressler, sincle, ~r his AttorneY-in_ract, John T. Cressler, of the Borough of Sh:l,ppens],urg, County of Cumber_ land and itate of PennSYlVania, Irantor, Party of the First Part AND Michnel L. Cressler and John T. Cressler, as Tenants in Common, of the !orou,h of Shippens\ur" County of Cumberland and State of Pennsylvania, Irantees, Parties of the second part, WITNESSETH, that the said part Y emtion of the sum of One Dollar ($1.00) of the first part, f01' and in consid- lawful money of the United States of America, well and t"lly paid by the said part ies of the second part, to the said party of the first pa,'/:, at and before the ensealing and deli,,- ery of these presents, the receipt whereof is hereby acknowledged, has granted, bar. gained, sold, aliened, enfeoffed, released, conveyed and confirmed, and by these lJ1'esents does gmnt, bargain, sell, alien, enfeoff, release, convey and confirm unto the said part ies of the second part, their hei,'s and assigns, All thclse five certain tracts of land situate in Southampton Township, Ct~berland County, Pennsy_ lvania \ounded and described as fallows, to wit: I I I I I I I I Tract No. 3. N~rth 25 degrees East 11 PElrches; thence North 18 degrees West 3&1 perches; thence South 42i degrees East l;~~ perches; thence North 88 degrees East 8 perches; thence South 4,al deRrees East 13.8 perChes. Containing 1 acre, stri()t measure. Beine the same tract of land that Jaco}, Kitzmiller by his deed dated Octolller 4" 1859 and recorded in DeE,d !look "', Volume II, page 4,04 oOnveyed to Michael Cressler. Tract No.1. leiinninC at a stone pile, thence ~ land of Wendel Fogelsanier South 4,3t degrees East 38 DE'rches to stones, thence by land of John and Abram ROdeys South 4,3i degrees West 34 perches to stones; thence North 441 degrees West 38 perches; thence North 44,f degrees East 34 perches. Containing 8 acres, neat measure. I Being the same tract of land that John H. Cressler by his deed dated I May 13, 1657 and recorded in Deed !look 2, Volume I, page 318 con- veyed to Michael Cressler. Tract NO.2. Consisting of two small tr;acts. (a) South 4,5 degrees I East (Ot perches; thence North Ie degree:! West Hi perches; thence , Nortl1 IT, degrees East 20 perches. l b) l!orth 44 degrees West l!~ I percl1es; North is deirees East 8 perches; thence South 48 de~rees East 13.S perches; thence South 25 degrel9S West a perChes. Con- I taining 3 acres 1117 perChes, strict measure. leinl the same tracts of land that John !larnet ~y his deed dated I March 18, 1858 and recorded in Deed !look 2, Volume II, page 403 con_ I' veyed to Michael Cressler. I I I i I . I Tract No.4. North 87, degrees West ':3.8 perches; thence North lei ! degrees East W perches; thence South Hi delrrees East n perches; : thence South Isi degrees West ~O perchl~S; thence South .7! degrees ! East 44.5 perches; thence South 44t degrees East 1.4 perches. Con- I taining 3 acres. , le~ilg the same tract of land that Ma.lry !lowermaster by her deed ! dated the 21st day of December, lS.l and recorded in Deed !look r, I Volume R, Page 405 conveyed to Michael Cressler. i I Tract NO.5. South 121 degrees, West 119.l!! perches; thence North 49 I I degrees, West T2.perches; thence North 4Tt degrees East 38.1 perches; ; I South ,41:>* dei.re~s East,l20.7 perches; ~hence South 171 degrees West I 30.2 patches; thence South .71 degrees East ~7.e perches. Contain_ I ing 9 acres, T. perches. i I leing the same tract of la~d that Elj~as Winters by his deed dated I the 15th day of May, li.5 and recorded in Deed !look ~, Volume ~, I page 407 conveyed to Michael Cressler. I JEIN. the same tracts of land that Johl1l ft. Robart, Treasurer of I CUllberland County, Pennsylvania, 8Y h12l Deeds dated December 71, 1940 I and recorded'in Deed Book tt3 VolWle /3 Page3/'i''i'....;!,oo I conveyed to Michael I.. Cressler, present trantor. I I I , i I I I I i I I I I I i I , I I I i I I I I I I I I I I i I I , I , I I I I I This conveyance is made under and by virtue of a power of attorney I frail Michael L. Cressler to John T. Cressler. Said power of attorney I having been recorded on the Jlst day of June, 1945 in the ~ecorders I Office in Cumberland County, PennsYlvania, in Miscellaneous Docket I 79 page 579. I I ! I i I I i I I I I I i I I I I I i I I I I I I I i I I i I I I I , i ! I i I I I I i I I I I I I I I TOGE'THER with all and singulUl' the buildi"gs, illlJ,,'ovcments, woods, ways, ,'iahts, liber- ties, privileges, hereditaments and applr?'tena"ces to the same belonging, or in anywise appertain- ing, and the ,'eversion and ,'eversions, ,'emainder and "'mainde,'s, ,'ents, issues a?ld profits, the,'e- of, and of eve,'y part a?ld parcel thereof: and also, all the estate, right, title, inte,'est __________ ----------------------------------- JJ?'operty, possession, claim and dema?ld what- soeve,', both in law and equity, of the said pa,'t Y of the first part, of, in and to the said premises, with the appurtenances, TO HAVE AND TO HOLD the said premises, wUh all and singular the appurtenances, -------- -------------- --- - -- - -- -- - --------- ---------- --- --------"nto the said parties of the second part, their heirs and assigns, to the only proper U3e, bene- fit and behoof of the said parti~ the second pa,'t, their heirs and assigns fOj'ever. I I I I I i I I I i I I I I I I I ----------------------------------~-------------war''ant and forever defend. I I I I I , i I i I I I i I I I I I I I , i I And the said Michael L. Cressler, his heirs, executors and administrators, does by these presents covenant, grant and agree to and with the said part ies of the second part, their heirs and assigns forever, that he the said Party of the first part, his Cressler, by his nttorneY-in_fact John T. shall and will-----__ ---- ---- - ----8enerallY____________________________ IN WITNESS WHEREOF, the said pa,.t y of the first pa,.t to these presents ha s hereunto set hi S hand and seal . Dated the day and year first above written. 8ig:nelli, .ealer. .ulli lIelwereill L !L A. I . ~ In I"r IJrmnn of ~ Attorn~y::.i~..:.f~.~~L.: ."AL --..----..&!t.t.f.:____J((...qc__.~.:__~::.--. --g.r.~,!1.!!l~.r.--...--____n____m____________.____n________n.______n.. ~ ~_u__..n.._...__.._.._._.____._____________.______________----------_--h_-----e ....--....--..------....--....--...-----....----...----.-.--.------.--...----.----~ n---n--_---------n-_________________________________h_.h__-...------ Received the day of the date of the above indenture of the above named 8tate of Pennsyl vania l County of CUlllterland ~ ss, On this, the 17 itr day 'of August ~,1945 , befol'e me w. B. McCrea, Jr. the undersigned officer, personally appeared John T. Cressler, A ttorneY-in_ fact for Michael L. Cressler known to me (or satisfactorily proven) to be the person wh08e name i S subsc?~bed to the within instrument, and acknowledged that he lixecuted the same f01' the p1l?'Poses therein contained. In witness whereof, I hereunto set my hand and official seal. 4 I .' )// e... ,tJ, ,/ ....m..mmm..fg:.I:I..:....eY.m.:'~..m...0::~:/-....:... ~ .....~.u.s.t1c.e...Q.t:...the...P..eac.em...............m......... My Commission exph'es Ja~itlLjOlk~'''r. State of County of On this, the }ss. day of .19 , before me the undersigned officer. personally appeared known to me (or satisfactorily proven) to be the person whose name subscribed to the within instrument, and acknowledged that l'xecuted the same for the purposes therein contained. In witness whereof. I hereunto set my hand and official seal. ~.'.--"'h_____-._____._____'._____'_"___n_____.___._______________..___.._.___.__..~ _.n.n--___.___.....n.._____....________.n__.____.....__.___..__...__...___..._..... Title of Officer. , . CERTIFICATE OF RESIDENCE . ......t......m..do hereby c~rtify thllt thft precise [esidellce of the within named grantee is Shippenslture, Cuaberlana Coun~y, ~ennsy vanla Au."" L 4/7/! 4.5 _..............tU.;Y:.../~...ft.t:..e.:3..,L ,1 ttorney fo?.........l.r.antee......................... R R J oM oM I Ol '" :a III QlCII +> +>.c .' 11:: oJ~oJ . .t' ~ ::I '8 . i. +>t.l .. .c CII oM Ol . . '" "'E-t Ol ...1- ~ "' CII+> Q) ~.-t . ~ &I < ~ ~CJ'" ~ .. 'O:a I>. I.'~' i :-. "':I w ;; OllllCII 1IlJ.t I:: III .. '. 'Jr. .. ~ ~ u w 'j.. Ol"'~ OlCII OlOla ,. .. u z CIIIIIl ~ CII~R ~~1Il ~..'. . :E I ~ "'.::llll J.t1ll0 \.-.:. \ ~. '" ~ ~ t.l CII t.lID~ ...... Ot.. t .- ~~ < ~ I J.t OE-t , w ci ~ 0: . .I>.t.l . '" 0 .. " ~". .. u " ~CII ~t.lt.l IIlRI>. .' u . '!l , . ~-~:~' :E . ~~E-i ..., o.~ ....~, , z ...... ~ . CJ+> g , " w . ClIO CIIE-t 1lI~ . ;; oJ +> .8 11l '" J 0 . A~ -g,N +> I:) CJ 0 oM .... oMO CII+> 's =- :::il.... 1-13 oMO~ fo,lO,-t State of .m"~.....m......m......} County at ......;fj..~4.....m.........m... ss. RECORDED on this ..........~...~1:!!....m.... day of ..~....................... A. D. 19.ffJ:, in the Recorde.r's office ol said County, in Deed Book 8 Vol. .....d...., Page '<'.'-,,2,..m. Given under my hand and the seal of the said office, the date above written. ......J.~m.~m............... Recorder. To: Parties in interest in the Estate of JOllIl T. Cressler Dear Folks: I am writing to you as attorney for Micllael L. Cressler concerning a recent development in the Estate of John T. Gressler. It has recently been realized that there was record title standing in the name of John T. Cressler together with M:lchael L. Cressler, for parcels of mountain land situated in Southampton T01011Ship, Cumberland Co'~ty. This was the result of a deed dated October 17, 1945, a copy of which is enclosed. You will note that this deed was signed by John T. Cressler under a power-of- attorney given to him by Michael and that the land prior to' the conveyance of this deed was Michae1.'s land. We are writing on behalf of Michael to request your consent to the execu- tion of a Quit-Claim Deed which will re-vest record title to this mountain land in Michael L. Cressler. I have discussed th:ls and reviewed it with Attorney Zullinger and with Mr. Leslie Brandt and the~, are of the opinion that this Quit-Claim Deed should be executed and that the 1945 deed was not legally effective to give John T. Crespler"any actual benefieial interest in the mountain land. However, before they execute the QUit-Claim Deed, they feel that you all should be advised of the situat:lon and they would like to have your consent and agreement in the execution ,)f the Quit-Claim Deed. Please review this situation and if you have any questions concerning it, please feel free to call upon me or upon Mr. Brandt or Attorney Zullinger. If you agree to the execution of the Quit-Claim Deed, please indicate your agree- ment by signing the enclosed Consent and Release and returning it to me at your convenience. Thank you very much. M,:CREA & DAVIS H,milton C. Davis HCD/vs Ene. To: Parties in interest in the Estate of John T. Cressler Dear Folks: . 1 am writing to you coneerning a reeent development in the Estate of John T. Cressler. We have recently been advised that there was record title qtanding in the name of John T. Cressler together with his brother, Miehael L. Cressler, for parcels of mountain land situated in Southampton Township, Cumberland County. This was the result of a Deed dated October 17, 1945, a copy of which is enclosed. You will note that this Deed was signed by John T. Cressler under a power-of-attorney given to him by Michael and that the land prior to the conveyance of this Deed was Michael's land. We have been contacted by an attorney on behalf of Michael and have been requested to execute a Quit-Claim DeE!d which will revest record title to this mountain land in Michael L. Cressler. 1 have discussed this and reviewed it with Attorney Zullinger and hE! 'and 1 are of the opinion that this Quit-Claim Deed should be exeeuted alld that the 1945 Deed was not legally effective to give John T. Cressler any aetual beneficial interest in the mountain land. However, before we execute the Quit-Claim Deed, we feel that you all should be advised of thl' situation and we like to have your eonsent and agreement in the execution of the Quit-Claim Deed. Please review this situation and call if you have any questions con- cerning it. If you agree to the execution of the Quit-Claim Deed, please indicate your agreement by signing the enclosed Consent and Release and returning it to me at your convenience. Thank you very much. CO~IMONWEALTH NATIONAL BANK, formerly The First National Bank of Shippensburg By: Leslie Brandt, Trust Off ieer Ene. SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS.AT-UW 26 W. High Street Carlisle. P A MELISSA J. SPENCER, PLAINTIFF VS. ESTHER GOODHART, SALLY L. BERKLITE, JANE BITNER, MARY ANN HADDAD, GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY JEAN SEIBERT, NANCY THOMPSON, JOHN C. DEUTSCH, RAY G, DEUTSCH, DON DEUTSCH, CHARLES A. DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, AND JESSE LEE DEUTSCH, AND, THE MEMORIAL LUTHERAN CHURCH DEFENDANTS : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 04-4470 CIVIL,2004 : ACTION TO QUIET TITLE CERTIFICATE OF SERVICE On this j{ffJay of J;tlltlJtr: 2004 I, Adele H. GrouP. hereby certifY that I served a true and correct copy of the foregoing PRAECIPE TO ATTACH via United States Mail, first- class, postage prepaid addressed as follows: Jane Bitner and Sally L. Berklite C/o John R. White, Esquire Campbell & White, P.C. 112 Baltimore Street Gettysburg, P A 17325 SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle. P A " Esther Goodhart The Episcopal Home 206 E. Burd Street Shippensburg, P A 17257 Thomas Cressler I Antler Court Shippensburg, P A 17257 Betty Jean Seibert 10 Hedge Row Lane Carlisle, PA 17013 Don Deutsch 49 Maple Avenue Walnut Bottom, P A 17266 Jesse Deutsch 313 Pine Road Mt. Holly Springs, P A 17065 Memorial Lutheran Church 34 East Orange Street Shippensburg, P A 17257 Gail Frey 9145 Pineville Road Shippensburg, P A 17268 Ettie Papoutsis 9300 Olde Scotland Road Shippensburg, P A 17257 Violet Epstein 57 Jackson Drive Chambersburg,PA 17201 Karen Mohn 410 W. King Street Shippensburg, P A 17257 Margaret Seavers 410 Clifton Road Shippensburg, P A 17257 SAIDIS SHUFF, FLOWER & LINDSAY AlTORNEYSeAT_LAW 26 W. High Street Carlisle, P A II Dorothy Cressler 26 Montgomery Avenue Shippensburg, P A 17257 Jane Seibert 322 Mainsville Road Shippensburg, P A 17257 Nancy Thompson 26 Montgomery Avenue Shippensburg, P A 17257 Ray G. Deutsch 329-B Springville Road Shippensburg, P A 17257 Jesse Lee Deutsch 3541 Orrstown Road Orrstown, P A 17244 Charles A. Deutsch 732 W. Brubaker Valley Road Lititz, PA 17543 Mary Ann Haddad 131 Chris Drive Englewood,OH 45322-1146 John C. Deutsch 12420 Conde Drive Brookville, FL 34613 Jennifer Deutsch 1810 Harvard Blvd. Dayton, OH 45460 SAlOIS, SHUFF, FLOWER & LIND SA Y aM/(fl~~ n c r--> = ~} .=- (/'J PI '- o -q -< ~i71 -n~:':::~ , .( C),Cl r. -,,', ~ . , _ ',..J.;-rl C::; -\'-. ~~C"..: o -< SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle. P A 'I MELISSA J. SPENCER, Plaintiff, vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW ESTHER GOODHART, SALLY L. : NO. 04-4470 CIVIL BERKLlTE, JANE BITNER, MARY ANN HADDAD, : ACTION TO QUIET TITLE GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY : JEAN SEIBERT, NANCY THOMPSON, : JOHN C. DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A. DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. TO THE PROTHONOTARY: PRAECIPE Please reinstate the Complaint in this matter. Date: October 5, 2004 SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for the Plaintiff By '''-..../ James D. Flower, Jr., Esquir 26 West High Street Carlisle, PA 17013 (717) 243-6222 I.D. #27742 o ," ~ ,..., c? ~ o '1" .... ::r....r] rn? -am 'uS: ~~~/ :'.].:: -T] <;:~(;;J (~'~rt'l '::-:'\ :D. ~~:;.. C) C) -. , u., -0 -",~ ..... <,>? U1 SHERIFF'S RETURN - REGULAR CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT -QUIET TITLE was served upon GOODHART ESTHER the DEFENDANT , at 1738:00 HOURS, on the 9th day of September, 2004 at 206 E BURD STREET SHIPPENSBURG, PA 17257 by handing to ESTHER GOODHART a true and attested copy of COMPLAINT -QUIET TITLE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavi t Surcharge 18.00 15.54 .00 10.00 .00 43.54 So Answers: ~~n::.-~.~:~ .f' ' / R. Thomas Kline 10/18/2004 SAIDIS SHUFF FLOWER LINDSAY Sworn and Subscribed to before me this Ct, t;J,.. day of ~7 c2~.,'" A.D. '(}UN / f1 h-,J-'~'<./ A{"V / Prothonotary , By: :~ L!J~ J Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL BRYAN WARD Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT -QUIET TITLE was served upon CRESSLER THOMAS the DEFENDANT , at 1908:00 HOURS, on the 9th day of September, 2004 at 1 ANTLER COURT SHIPPENSBURG, PA 17257 by handing to NANCY CRESSLER, WIFE a true and attested copy of COMPLAINT -QUIET TITLE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 11.10 ,DO 10,00 .00 27.10 -~(.~:-~'<~'~:""J_~-;;"~:';:::: f ""'....., , " " /" ,-5'/:':::% ',/;'-:'".t:~;:...~t? R. Thomas Kline 10/18/2004 SAIDIS SHUFF FLOWER LINDSAY Sworn and Subscribed to before th . P d f me is 1. - ay 0 (}lA'-::t :l ()1J L, A. D . f){C;;ten~~~. J , ~ By: ~Uq!~}iff d SHERIFF'S RETURN - REGULAR CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT -QUIET TITLE was served upon SEIBERT BETTY JEAN the DEFENDANT , at 2113:00 HOURS, on the 9th day of September, 2004 at 10 HEDGE ROW LANE CARLISLE, PA 17013 by handing to BETTY SEIBERT a true and attested copy of COMPLAINT -QUIET TITLE together with and at the same time directing Her attention to the contents thereof 0 Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 3.70 000 10.00 .00 19.70 .~... .' /./7 .v~/;:Y' . rc.7.i'<~:((~?"ff'-lt .r R, Thomas Kline 10/18/2004 SAIDIS SHUFF FLOWER LINDSAY Sworn and Subscribed to before By: i~ty ~;?tfJ '" me this f., - day of -0"~ ~J{}1Ji A.D. Qtt"' ()~ n....JJ., , .o~~ rothonotary /067 2 SHERIFF'S RETURN - REGULAR CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT -QUIET TITLE was served upon DEUTSCH DON the DEFENDANT , at 1920:00 HOURS, on the 9th day of September, 2004 at 49 MAPLE AVENUE WALNUT BOTTOM, PA 17266 by handing to JANET DEUTSCH, WIFE a true and attested copy of COMPLAINT -QUIET TITLE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 10.36 .00 10.00 ,00 26.36 10/18/2004 SAIDIS SHUFF FLOWER LINDSAY ~ty stf:;; J By: Sworn and Subscribed to before me this (, ~ day of 9,....7 .2n/. A.D, Q'{-,-, 0- Yl1< pI,.. ~ rothonotary , SHERIFF'S RETURN - REGULAR CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL CPL, MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,pennsylvania, who being duly sworn according to law, says, the within COMPLAINT -QUIET TITLE was served upon DEUTSCH JESSE the DEFENDANT , at 1551:00 HOURS, on the 15th day of September, 2004 at 313 PINE ROAD MT HOLLY SPRINGS, PA 17065 by handing to JESSE DEUTSCH a true and attested copy of COMPLAINT -QUIET TITLE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 4.44 .00 10,00 .00 20,44 R. Thomas Kline --f".' I Sworn and Subscribed to before 10/18/2004 SAIDIS SHUFF FLOWER LINDSAY ~ BY:~~ Deputy S riff me this {.. (;. day of C)""'A'1 ;)b1>o:;' A.D. ~ o "'h.1<.I/,. j ^ ~- othonotary I . SHERIFF'S RETURN - REGULAR CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL CPL. MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT -QUIET TITLE was served upon MEMORIAL LUTHRAN CHURCH the DEFENDANT at 1419:00 HOURS, on the 30th day of September, 2004 at 34 EAST ORANGE STREET SHIPPENSBURG, PA 17257 by handing to RELDA STOOPS, SECRETARY, ADULT IN CHARGE a true and attested copy of COMPLAINT -QUIET TITLE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 14.80 .00 10.00 .00 30.80 v~~ C.?/~~~'~,..".., P;.,," ,..",~';'~;:>:::. ~ r ...>~:u:.~....,,...~-<.!.1.t...f .....-%.>."'~,o~ ......"" R. Thomas Kline Sworn and Subscribed to before 10/18/2004 SAIDIS SHUFF FLOWER LINDSAY BY:~ 0 A-f2 Depu~ Shelfiff . "" me this (,~ day of (}i(ILt"7 clfVl.,. . A.D. 9,(', 0 b,AjJ",,~ Protfionotary , SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: BITNER JANE but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of ADAMS County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE 18th , 2004 , this office was in receipt of the On October attached return from ADAMS Sheriff's Costs: Docketing Out of County Surcharge Dep Adams County 6.00 9.00 10.00 28.20 .00 53.20 10/18/2004 SAIDIS SHUFF So answer5:< ".;:? . "../ R. ~~i;:~:'~~ Sheriff of Cumberland County ? ~_.------ FLOWER LINDSAY Sworn and subscribed to before me this to (, ~ day of QAuu"7 ;l.lj1) ::) A . D . ( h.L- Q )'vt.:OO,-,-, 1\ t~ Prothonotary , .1 In The Court of Common Pleas of Cumberland County, Pennsylvania Melissa J. Spencer VS, Esther Goodhart et al SERVE: Jane Bitner No. 04-4470 civil Now, Septenber 7. 2004 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Adams County to execute this Writ, this deputation being made at the request and risk of the Plaintiff, ~,.,/ . /~' r ...~..~<!" 4~'.e.v-.R Sheriff of Cumberland County, PA Affidavit of Service Now, ,20_, at o'clock M, served the within upon _.___.__ at by handing to copy of the original a and made known to the contents thereof. So answers, Sheriff of County. PA Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ , DATE RECEIVED DATE PROCESSED SHERIFF'S DEPARTMENT ADAMS COUNTY , PENNSYLVANIA COURTHOUSE,GETTYSBURG,PA17325 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN INSTAUCTtoNS: See "INSTRUCTIONS FOR SERVICE OF PROCESS BY THE SHERIFF" on the reverse of the last (No.5) copy of this fCH'm. Please type or prinllegibty, insuring readability of all copies. Do not detach any copies. ACSD EHV,# 2. COURT NUMBER 1. PLAINTIFFISI MELISSA J. SPENCER 04-4470 Civil 3. DEFENDANT/S! 4. TYPE OF WRIT OR COMPLAINT, ESTHER GOODHART, IT AL Comolaint To Quiet Title 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC., TO SERVICE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED OR SOLO. SERVE . Jane Bitner 6. ADDRESS (Street or RFD. Apartment No., City, Bora, Twp.. Slate and ZIP CODE) AT 1314 Pine Run Road, Abbottstown, PA 7. INDICATE UNUSUAL SERVICE: 0 PERSONAL 0 PERSON IN CHARGE 0 DEPUTIZE 0 CEAr. MAIL 0 AEGISTERED MAIL 0 POSTED 0 OTHEA Now, , I, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of County to execute this Writ and make return therof according to law. This deputation being made at the request and risk of the plaintiff. SHERIFF OF ADAMS COUNTY 8. $PECIAlIN$TRUCTION$ OR OTHER INFORMA liON THAT WILL ASSIST IN EXPEDITING SERVICE. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.S. WAIVER OF WATCHMAN-Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment. without liability on the part of such deputy or the sheriff 10 any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereof. 9. SIGNATURE of ATTORNEY or other ORIGINATOR requesting service on behalf of: ~ PLAINTIFF o DEFENDANT 10. TELEPHONE NUMBER 11. DATE James D. Flower, Jr., Esq. (717) 243-6222 SPACE BELOW FOR USE OF SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE 12. I acknowledge receipt of the writ SIGNATURE of Authorized ACSD Deputy or Clerk and Title 13. Date Received 14. Expiration I ~ date 0' compl.;n, as ;nd;cated abov.. 9-8-2004 OCT. 3 2004 15. I hereby CERTIFY and RETURN that I M have personally served, 0 have served person in charge, 0 have legal evidence of service as shown in "Remarks" (on reverse) o have posled the above described property with the writ or complaint described on the individual, company, corporation, etc., allhe address shown above or on the individual, company, corporation, etc., at the address inserted below by handing/or Posting a TRUE and ATTESTED COPY therof. 16. 0 I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc., named above. (See remarks below) 17. Name and title of individual served 18. A. person 01 SUitable age and discretion Read Order then residing In the defendant's usual place 01 abode. 0 0 20. Date of Service 21. Time Jane Bitner 19. Address ot where served (complete only if different than shown above) (Street or RFD, Apartment No., City, Boro, Twp., State and ZIP CODE) 9/8/2004 6: lOPM 22. ATTEMPTS Dep.lnt. Date 23. Advance Costs 24. $1.'l>.OO Ro. gmff 14~ 25. MI... Dep.lnt. Dep.lnt. 27. Total Coats $28.20 Pd. 9/15/04 28. ~ REFUND $121.80 ck. #11633 AFFIRMED and subscribed to before me this NA day ot Oat. 9 8 2004 Signature of Sheriff RAYMOND W. NEWMAN D... 9/8/2004 ProIhonotwy.a.putylNotary PubIc SIEAIFF OF AD..... COUNTY MY COMMISSION EXPIRES I ACKNO\NLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE OF AlITHOAlZEO ISSUING AUTHORITY AND TITlE. 39. Dale Received PROTHONOTARY 'I SHERIFF'S RETURN OF S~RVICE ( ) ( 1 ) The within upon defendant by mailing to by prepaid, a true and attested copy thereof at , the within named mail, return receipt requested, postage on the ( ) The return receipt signed by defendant on the made a part of this return. ( 2) Outside the Commonwealth, pursuant to Pa. and attested copy thereof at is hereto attached and R.C.P.405 (c) (1) (2), by mailing a true in the following manner: ) (a) to the defendant by ( ) registered ( ) certified mail, return receipt requested, postage prepaid, addressee only on the said receipt being returned NOT signed by defendant, but with a notation by the Postal Authorities that Defendant refused to accept the same. The returned receipt and envelope is attached hereto and made a part of this return. And thereafter: ) (b) To the defendant by ordinary mail addressed to defendant at same address, with the return address of the Sheriff appearing thereon, on the I further certify that after fifteen (15) days from the mailing date, I have not received said envelope back from the Postal Authorities. A certificate of mailing is hereto attached as a proof of mailing. ( 3) By publication in the Adams County Legal Journal, a weekly publication of general circulation in the County of Adams, Commonwealth of Pennsylvania, and the Gettysburg Times, a daily newspaper published in the County of Adams, Commonwealth of Pennsylvania and having general circulation in said County for successive weeks of The Affidavits from said Adams County Legal Journal and Gettysburg Times, are hereto attached and made part of this return. ( 4) By mailing to by mail, return receipt requested, postage prepaid, on the a true and attested copy thereof at The Authorities m~rked . is hereto attached. ( ) (5) Other returned by the Postal , ".c"__ ',.,., rc~--~--------"'---' DATE RECEIVED -"~''''':'~- ,,",'" ..~~. DATE PROCESSED SHERIFF'S DEPARTMENT ADAMS COUNTY, PENNSYLVANIA COURTtfOUSE. GETTYSBURG, PA 17325 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN INSTRUCTIONS: See "INSTRUCTIONS FOR SERVICE OF PROCESS BY THE SHERIFF" on the reverse of the last (No.5) copy of this form. Please type or print legibly, insuring readability of aJl copies. Do not detach any copies. ACID ENV 01 2. COURT NUMBER 1. PLAINTIFF/SI : j~Ll";~A .J. ,~;':)t.l-~(.;~(~ 3. DEFENDANTISI 'J4-!+!}7'J '~ivl1 4. TYPE OF WRIT OR COMPLAINT, L~'J<:L'i\ ~;().)L~i'\i.U i..~.i.}L, C.OL181nirl:: to UU1e-t U ':.11.:-' 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC., TO SERVICE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED OR SOLD. SERVE . J;~I,):::, ~l rn~~'.i.: 6. ADDRESS (Street or RFO. Apartmenl No., City, Bora, Twp., Stale and ZIP CODE) AT 1314- f'lne r(un t\O{J;j'j '\bcot ts to','.11. " 7. INDJCATE UNUSUAL SERVICE: 0 PERSONAL 0 PERSON IN CHARGE 0 DEPUTIZE 0 CERT. MAIL 0 REGISTERED MAIL 0 POSTED 0 OTHER Now, , I, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of County to execute this Writ and make return therof according to law, This deputation being made at the request and risk of the plaintiff. SHERIFF OF ADAMS COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE, NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAiVER OF WATCHMAN-Any deputy sheriff fevying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein fOf any loss, destruction or removal of any such property before sheriff's sale thereof. 9. SrGNATURE of ATTORNEY or other ORIGINATOR requesting service on behalf of: !X. PLAINTIFF o DEFENDANT 10. TELEPHONE NUMBER 11. DATE J.:;mC~3 [). L1Tm',TX 1 j r.) Ese.:. (717) 2(~j~"622L SPACE BELOW FOR USE OF SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE 12. I acknow5edge receipt of the writ SIGNATURE of Authorized ACSD Deputy or Clerk and TittG 13. Date Received or complaint as indicated above. 14. Expiration IIiI'iiIQ date r)-J'-l.ud4 OCT. 3 2004 15. I hereby CERTIFY and RETURN thati M. have personally served, rJ have served person in charge, 0 have legal evidence of seMce as shown in "Remarks" (on reverse) o have posted the above described property with the writ or complaint described on the individual, company, corporation, etc., at the address shown above or on the individual, company, corporation, etc., at the address inserted below by handing/or Posting a TRUE....d ATTESTED COPY therof. 16. 0 I hereby certify and return a NOT FOUND because I am unable to locale the individual, company, corporation, etc., named above. (See remarks below) 17. Name and title of individual served JaDe '._'.1 tijCr 18. A person of suitable age and discretion then residing in the defendant's usual piece of abode. 0 20. Date of Service 21. Time Read Order o 19. Address of where served (complete only if different than shown above) (Street or AFD, Apartment No., City, Bora, Twp., State and ZIP CODE) " J :., ~ 1. '. L 22. ATTEMPTS Dep.lnl. Dolo 23. Advance Costs .j.TI:l.OO Ela. 3a:iff 25. Mil.. Dep.lnt. Dep.lnt. L....,\. AFFIRMED and subscribed 10 before me this ./., " day of ~ Date c...., "'/ '.;.t J' ;. -,'. SWure 01 SIlori!'. ,)/- J'}~".,. ' ;ll-\.-':c'ir~,: Dalo ;'7 l;~! ','; _Pul>l~ SHEAIFF OF ADMIS COUNTY lAY COMMISSION EXPIRES I ACKNOWLEDGE RECEIPT OF THE S--. RETURN SIGNATURE OF AUTHORIZED ISSUING AUTHORITY AND TITLE. 39. Date Received SHERIFF'S RETURN OF SERVICE ( ) ( 1 ) The within upon defendant by mailing to by prepaid, a true and attested copy thereof at , the within named mail, return receipt requested, postage on the The return receipt signed by defendant on the is hereto attached and made a part of this return, ) (2) Outside the Commonwealth, pursuant to Pa. R.C.P.405 (c) (1) (2), by mailing a true and attested copy thereof at in the following manner: ) (a) to the defendant by ( ) registered ( ) certified mail, return receipt requested, postage prepaid, addressee only on the said receipt being returned NOT signed by defendant, but with a notation by the Postal Authorities that Defendant refused to accept the same. The returned receipt and envelope is attached hereto and made a part of this return. And thereafter: ) (b) To the defendant by ordinary mail addressed to defendant at same address, with the return address of the Sheriff appearing thereon, on the I further certify that after fifteen (15) days from the mailing date, I have not received said envelope back from the Postal Authorities. A certificate of mailing is hereto attached as a proof of mailing. ( 3) By publication in the Adams County Legal Journal, a weekly publication of general circulation in the County of Adams, Commonwealth of Pennsylvania, and the Gettysburg Times, a daily newspaper published in the County of Adams, Commonwealth of Pennsylvania and having general circulation in said County for successive weeks of The Affidavits from said Adams County Legal Journal and Gettysburg Times, are hereto attached and made part of this return. ( 4) By mailing to by mail, return receipt requested, postage prepaid, on the a true and attested copy thereof at The ,- , . Authorities markeci is hereto attached. ( ) (5) Other returned by the Postal DATE RECEIVED DATE PROCESSED SHERIFF'S DEPARTMENT ADAMS COUNTY, PENNSYLVANIA COURTHOUSE, GETTYSBURG, PA 17325 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN INSTRUCTIONS: See ....INSTRUCTIONS FOR SERVICE OF PROCESS BY THE SHERIFF" on the reverse of the last (No.5) copy of this form. Please type or print legibfy, insuring readability of all copies. Do not detach any c:opies. ACSD ENY.I 1. PLAINTlFFISI 2. COURT NUMBER . U4-4470 Civil 3. DEFENDANTISI 4. TYPE OF WRIT OR COMPLAINT: LSWU( JX)l!l1\,U E. AL Coer:: Iaint To ( Jiet Ii tIe 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC., TO SERVICE OR DESCRIPTION OF PROPERTY TO BE LEVIED. ATTACHED OR SOLO. SERVE . Jane Gi. tnel' 6. ADDRESS (Street Of' AFD. Apartment No., City, Boro. Twp.. State and ZIP CODE) AT 1314 PineRut1 Rtlcd, AbbottstOWl1, PA 7. INDICATE UNUSUAL SERVICE: 0 PERSONAL 0 PERSON IN CHARGE 0 DEPUTIZE 0 CERT. MAllO REGISTERED MAllO POSTED 0 OTHER Now, , I, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of County to execute this Writ and make return therof according to law. This deputation being made at the request and risk of the plaintiff. SHERIFF OF ADAMS COUNTY B. SPECIAL INSTRUCTIONS OR OTHEA INFORMATION THAT WilL ASSIST IN EXPEDITING SERVtcE. NOTE QNL Y APPLICABLE ON WRIT OF EXECUTION: N.S. WAIVER OF WATCHMAN-Any deputy sherifllevylng upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part 01 such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before shefiff's sale thereof. 9. SIGNATURE of ATTORNEY or other ORIGINATOR requesting service on behalf of: IX PLAINTIFF o DEFENDANT 10. TELEPHONE NUMBER 11. DATE James D. ~'lower, Jr., Esq. Ul7) 243-6222 SPACE BELOW FOR USE OF SHERIFF ONLY DO NOT WRITE BELOW THIS LINE 12. I acknowledge receipt of the writ 1 SIGNATURE of AUthorized ACSD Deputy or Clerk and Title 113. Date Received 114. Expiration ,_ date or complaint as indicated above. C', r 'j .'/.' i "..,..". 3 2004 ,-(j-..\)U... '^'~, I, 15. I hereby CERTIFY and RETURN that I K have personally served, 0 have served person in charge. 0 have legal evidence of service as shown in "Remarks" (on reverse) o have posted the above described property with the writ or complaint described on the individual, company, corporation, etc., at the address shown above or on the individual, company, corporation, etc., at the address inserted below by handing/or Posting a TRUE .nd ATTESTED COPY therof. Jane bi tner 19. Address of where served (comp.lete only if different than shown above) (Street or RFD, Apartment No., City, Bora, Twp" State and ZIP CODE) 16. 0 I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc., named above. (See remarks below) 17. Name and title of individual served 18. A person Of suitable age and discretion Read Order then residIng in the detendent's usual 0 p'-c:e.ofllbode..O 20. Date of Service 21. Time J/'d12004 ,J: llitY.i 22. ATTEMPTS Dep.lnt, O.te 23. Advance Costs 25. MIIH Dep,lnt. Dep.lnl. AFFIRMED and subscribed 10 before me this 28. ~ REFUND Si2LSO ck. ,il1G33 SO ANSWER. /) ~.oo &. Dal. d.y of ') ~of~ '). t\ . - j . ~AtIs aouNT't.. (" t . 0aI0 --- MY COMMISSION EXPIRES I ACKNOWLEDGE RECEIPT OF THE SHERIFF'S IlETUNl SIGNATURE OF AUTHORIZED ISSUING AUTHORITY AND TITLE. 39. Oate Received ". " ;}\ SHERIFF'S RETURN OF SERVICE ) ( 1 ) The within upon defendant by mailing to by prepaid, a true and attested copy thereof at , the within named mail, return receipt requested, postage on the ) The return receipt signed by defendant on the made a part of this return, ( 2) Outside the Commonwealth, pursuant to Pa. and attested copy thereof at is hereto attached and R.C.P.405 (c) (1) (2), by mailing a true in the following manner: ) (a) to the defendant by ( ) registered ( ) certified mail, return receipt requested, postage prepaid, addressee only on the said receipt being returned NOT signed by defendant, but with a notation by the Postal Authorities that Defendant refused to accept the same. The returned receipt and envelope is attached hereto and made a part of this return. And thereafter: ( ) (b) To the defendant by ordinary mail addressed to defendant at same address, with the return address of the Sheriff appearing thereon, on the I further certify that after fifteen (15) days from the mailing date, I have not received said envelope back from the Postal Authorities. A certificate of mailing is hereto attached as a proof of mailing. ( ( 3) By publication in the Adams County Legal Journal, a weekly publication of general circulation in the County of Adams, Commonwealth of Pennsylvania, and the Gettysburg Times, a daily newspaper published in the County of Adams, Commonwealth of Pennsylvania and having general circulation in said County for successive weeks of The Affidavits from said Adams County Legal Journal and Gettysburg Times, are hereto attached and made part of this return. ( ) ( 4) By mailing to by mail, return receipt requested, postage prepaid, on the a true and attested copy thereof at The Authorities marked is hereto attached, ) (5) Other returned by the Postal SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: BERKLITE SALLY L but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE 18th , 2004 , this office was in receipt of the On October attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge Dep Franklin Co 6.00 9.00 10.00 317.48 .00 342.48 10/18/2004 SAIDIS SHUFF So answers: >:c'~~</' -E:. . Co... R. Thomas Kline Sheriff of Cumberland ------ ~,~..- ~ County FLOWER LINDSAY Sworn and subscribed to before me this I-!:: day of 9'''.~'J 2vv -{ A,D. r\. .,. Q. ~;OO,'"' ~ ' ~ Prothonotary' '. In The Court of Common Pleas of Cumberland County, Pennsylvania Speneer VB. Goodhart, et al. SERVE: No. 04-4470 civil Sally Berklite Now, , I, SHERlFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. :r'~~-t!~ Sheriff of Cumberland County, PA Now, Affidavit of Service ~. iiJ ,20~,at /'tf.s~o'clock P M. served the (j~. Q~ ~~ j "'- /~~ / ' 13 ISf- y~:c V~ A~ )~~, rP~ J~ ~ 17~.f within upon at by handing to a ,-I~/ ~ , copy of the original ~. ~~ and made known to ~v the contents thereof. So answers, ~ ,0/ f,q.~' (!y.~~ .' n ""''''~:-::-;-'-~ - - \ (\ /\ G.p '\h:lmrdD . ~I.." .~-----,yv~..J<.. ~ I C.h,:rnl~ef',t-';Ir'" "'. " JJii:- '; '; I.' Sh 'ff U ~'V .', "-""". - en l_.____________.._ !~'-;J:--,.,: '7; ~"\.'rZ\I_'l County. P A Swom and subscribed be me this .l.!!..... day of .,' ., 20 ~ 'f- ,M.. ~tiJ. ~~ COSTS SERVICE MILEAGE AFFIDA VII $ $ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: FREY GAIL but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On October 18th , 2004 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 10/18/2004 SAIDIS SHUFF So answers: ~- -; _-;/7<__"~~-:>-;:O,:.s;::::? ~;_ .:~ R;' Thomas -Kline { Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me this ~~ day of0"'~""J ~IJV rf A . D . (~ Q fv.,I',,) ~Dr4- Prothonotary ) In The Court of Common Pleas of Cumberland County, Pennsylvania Melissa J. Spencer VS. Esther Goodhart et al SERVE: Gail Frey ~1- l)~r 1-e....- No. 04-4470 civil Now, Septanber 7, 2004' , T, SHERiFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. r;~~~R Sheriff of Cumberland County, P A . Affidavit of Service Now, J:#.~v /..1 ~.(],~ ~ .... ."b2-:~. at 'fA..~- ~ . "--f~ . by handing to 0 ad HUt a </--~! ~v , 20 d at 1(1;'- t>:f o'clock LM. served the within upon 1S-1 cJ( 'Jr, S. ~." 1a... /7;J..d/ copy of the original ~'r~~ and made known to ~ the contents thereof So answers, c.~M,W{ ,~ PA : ~.O~' Sheriff of . c..-k-fL<. . COSTS SERVICE MILEAGE AFFIDAVIT $ Sworn and subscribed b fore me this 1';' day of $ . NO({;[iaIS<:aJ I C~J~lJ3rd D. _M~Cru-/y> NC1:1-ry ~)\'Hi~ ,~'Iibersb';f~ ;]<:>[0 Fr~'lli'l' MyC(lrrJlfJj;'Sj'~f1 L,;;j~,,;":I,,:':,' 2,>>:: ,I ------- SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: PAPOUTSIS ETTIE but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE 18th , 2004 , this office was in receipt of the On October attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16,00 10/18/2004 SAIDIS SHUFF So an~wer),"- "- y. . -"'.....-? ~ --.~, .,.-~-y ~c - c c- R', Thomas Kline Sheriff of Cumberland ...~.- County FLOWER LINDSAY Sworn and subscribed to before me this c,e day OfCf""" J..IJVS A.D. } (l. ,1-'_ Q 1M,au,,) 1Jp{~ ~ ~ Prothonotary In The Court of Common Pleas of Cumberland County, Pennsylvania Melissa J. Spencer VS. Esther Goodhart et al SERVE: Ettie Papoutsis ~t.f-)'~?>.T f't!..- No, 04-4470 civil Now, September 7, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~~~#J Sheriff of Cum berland County, P A . Affidavit of Service Now, S.opieA bPI QI ,2()::)1( , at I' / [) o'clock PM. served the within (/")'flait\t QLl.let "-r;-cPe. upon E.~te. EOfbj,tTS t's at-0OtI\.k.l;^ (~L<.1\.'\:)' Si.e;l~ Os:::.J;.(ce.. by handing to ~r GtiJe. Fb.fout..s;.s a -!:rue. - Q... tt-e 'S'tts:1 and made known to fv?r copy of the original (~.i1~ {g,,,'(:Jt (;'tJi? the contents thereof.. So answers, ~.~, ! -r/;jJjPJ I She~f 1;. / County, PA Sworn and SUbSCrib;J:;1re me this SI day 0 .'.,20 () 4- ~.~ ~"ml..~ I r_ COSTS SERVICE MILEAGE AFFIDAVIT $ --- NotJriaJ Seal -- Ri~l13r:iD, MCr~:}.:-ty, Not;!ry Pi.),); Ch;:nlb<;/sblfg l)Oro '~" L' M r .,,_I[.I,1"JI11 y ~OlTJlm$SlOll Exp![('s );..L ::J, $ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: EPSTEIN VIOLET but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On October 18th , 2004 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 ,00 ,DO 16.00 10/18/2004 SAIDIS SHUFF So answers'.. /' ;~;k~-=:~ R. Thomas Kline Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me day of 9"" 'J ;).00 -{ A . D , ~/v_ Q ~L,' ~- Prothonotary , i<:o l.'- this In The Court of Common Pleas of Cumberland County, Pennsylvania Melissa J. Spencer VS. Esther Goodhart et al SERVE: Violet Epstein f)tf- .;).2~" f<-. No. 04-4470 civil Now, Septanber 7, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~~~~R Sheriff of Cumberland County, PA . Affidavit of Service Now, (......3D "- 0 i ,20_, at Ir-'f S- o'clock M. served the -::hk' within I ......+C" r~ ,J C-tJ" rJ'r( lJpOllV {Q Glt." lif'STI~;f r at '57 J'tktc. <;; D,..J P(2... u.j.8c . by handing to ~ '" r~""'-A-" R...P 'Ii'Ll fV a Co ~'-Ac "'" copy of the original and made known to 1-+ \. ^"'-- the contents thereof. ~.~. V PA-A-:, C>'D~ So answers, f1'24 t' Ie<. ( rJ County, PA 20~ COSTS SERVICE MILEAGE AFFIDAVIT $ Sworn and subscribed me this :30 day of ;Qz ~~ - NotarialSeaJ l RidJardD M t' 'Ch . C~'lrty, Net'lY Publj: iur.bersblli-g Bo/' '~.", M C "._' _ - _ 0, j f" l,,:,m C0~;Jh ' I Y orV,);~,.,;:o,: r::xpTr~'_' _h:: "'-, -,'~ i '---- , ----.--------- $ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: MOHN KAREN but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE 18th , 2004 , this office was in receipt of the On October attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge 6..00 .00 10.00 .00 .00 16.00 10/18/2004 SAIDIS SHUFF So an~I^l:~ .//::,:-/ / / ;> . X-A~<~-'_______>" / ~ ~--c;:~_:':'':;''--L--.,----;:7/ R. ' Thomas Kl ine (' Sheriff of Cumberiand County FLOWER LINDSAY Sworn and subscribed to before me this (,t. dayofC}.""u"l / ;).01J ';) A.D. C ~IL<-- Q 'rub ~pP", ~ Jd:' Prothonotary} Q ,v In The Court of Common Pleas of Cumberland County, Pennsylvania Melissa J. Spencer VS. Esther Goodhart et al SERVE: Karen Mohn tJ'I-)J~r H..... No. 04-4470 civil Now, Septanber 7. 2004 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. i"~-<~R Sheriff of Cum her land County, PA . Affidavit of Service Now, Sf'Pi 11 C().",,- pLyQ,,iff /,u GX./lt'.f T\'TLE , K~l.-rNtI{)~H r S' ~ L1 0J Cci~ 4.J~1 P M1) c;: A~r ^tJ 1 ~ V{) I k f M d th , 20~ at . 1 o'c oc' . serve e within upon at rfMYvVlE~g{!,ue6' , .. fll by handing to a rr-R..\J~ lA"t't€ <::,,--- and made known to H ft-fL copy of the original CffI'vI. P ( Ii I ~ the contents thereof So answers, "G~.~ PA' Ca.COR~ ~\-1 County, PA Sworn and SUbSCribej~1O; me this ~ day of ., 20 ~ I.f ,~ ~~~~ COSTS SERVICE MILEAGE AFFIDAVIT $ .-......-1 Notarial :-:;,~;]1 I Rit.:hard D_ MCClOY, Notary PlIl!li; Ch<:.mbersbu,g ::\0ro, I'JiJ:tLi:; ! My ComhmsiOll Expi:-,:s 1:,:1. 2';' I $ If SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: SEAVERS MARGARET but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On October 18th , 2004 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 10/18/2004 SAIDIS SHUFF So answerSj >-,:'.~.. ~~... R.. Thomas Kline Sheriff of Cumberland County ./ FLOWER LINDSAY Sworn and subscribed to before day ofr1 .<d .., ~ 'f ;JV1: 't A.D. q'r'~ c> n,di,,, (Q.,-r;; Prothonotary' 0 me this ,e, (. j:) In The Court of Common Pleas of Cumberland County, Pennsylvania Melissa J. Spencer VS. Esther Goodhart et al SERVE: Margaret Seavers &'I-Jd-~I Fe.-- No. 04-4470 civil Now, Septanber 7. 2004 ,!, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~~~~R Sheriff of Cumberland County. P A Affidavit of Service Now, cr-fl!-o~ , 20_, at 1 ~ ~J o'clock P M. served the within 1'7 d\1LC/1n\'-\. \ S (,4 v'S'.!' Co vt1PUl- ( c' T upon mA1LcA-rt-rH~ R-.4Y'/ilLL at t.{ II:) ~ur-'(")I" D fl. ::; 1-\-66. PI). by handing to S ~r,- ~ . tlO.M I- , copy of the original ~'..~~ the contents thereof. a and made known to ~ So answers, ~~1~.. ~ -/,. WlJ~ . . Sheriff County, P A Sworn and subscribed ~ore mow,J" "'" Of,/.U~O ;.f ~. IJz- t.--tctL-L A-... r t ( ti. 't-e. - \ COSTS SERVICE MILEAGE AFFIDAVIT $ -- R NOf<lfJal $,,' -'--. $ c/<.;hasd D MCC'~'1 ~ <,~j l J~mbersb)'-~ iJ ... L NOi,~ry Plib'. M~~~,;:;"~;;,;,;,;::,~;,.:,,:. : I ~I SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: CRESSLER DOROTHY but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On October 18th , 2004 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 10/18/2004 SAIDIS SHUFF So answ.ers~ ~/,///// ,.~ ..~ / C---"--:o . ...,. ?~~'..r/ ./:,.,/' ~< Thomas K{in~ .C --'-'- Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me day of 9-",... J ,10-0 ~ A.D. n. ~ 0. fMAl~,.. ^~ '--i"'l Prothonotary , "'" (.'- this 'J;;' In The Court of Common Pleas of Cumberland County, Pennsylvania Melissa J. Spencer VS. Esther Goodhart et al SERVE: Dorothy Cressler tN-).)!j.r . rC- No. 04-4470 civil Now, Septenber 7, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~~~~ Sheriff of Cumberland County, PA . Affidavit of Service Now, II.{ Sf\fT CoY'"' r t.-A I rT'\ , 20d, at ,(-I r o'clock...&:.. M. served the within upon. Do/?...c ll~+t-c!.. ~ fZS. $l)Z/' at ~ VYllO ~~(:,cYY\~ J4-0~'t by handing to S/tvo-1 f\- I~I ~.t- s ~ ~ f 4- l1 'L,? a copy of the original . ~.~~ and made known to ivJ the contents thereof. So answers, t;;;~ ~~ (! RPV K.Ur/ County, PA Sworn and subscribed efore me thik~.L day of (j;.. UUA.' <<- '-?n . , 20 I tf '- t COSTS SERVICE MILEAGE AFFIDAVIT $ NOfarial Seal Richard 0 M"C~rh, N C . ~_, '-'J, olary PI:blj- , IWlll!?ersblll"g i)(!ro FrTl My COImnissicll E\I;'r,~; ';,".li'I~,{ 1 I , $ --..---.-- SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: SEIBERT JANE but was unable to locate Her in his bailiwick.. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE 18th , 2004 , this office was in receipt of the On October attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 10/18/2004 SAIDIS SHUFF So answer,,: ._ c:~ ;2..-/~~~/.... ~<' ~.c-.. _~"'c-::;;?;"--- R. Thomas Kline \ Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me this II e day of h ,1tlVS A.D.. (~f1~ 0 Ih, il,.., ~ Prothonotary. 'iJ In The Court of Common Pleas of Cumberland Couuty, Pennsylvania Melissa J. Spencer VS. dtf-;);J.5 'P'- Esther Goodhart et al SERVE: Jane Seibert No. 04-4470 civil Now, Septenber 7, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. :r'~~~~ Sheriff of Cumberland County, PA . Affidavit of Service Now, IS- 5t-ptefJ\t:er ,200'1, at 9."$5 o'clock :.A- M. served the within c::'/VIP/QI nt c)-\. G,Llet T'-t:P~ I upon. . J Qn.e:t Sie. ber.~ at ..t<--- S(':] Fratt'diQ' CO S^et'l~ aLee... by handing to Jaret '.) fpbp.rT- a 1:r-v.e 4- cttl:estpri copy of the original ~.h;rft: and made known to her the contents thereof. So answers, ~~ P+1:. (1"i ~fr~,. ~flR Sheriff of County, P A Sworn and ~bSCribe2~ me this 12- day of . ., 20H &~ifnl~ I . ;I' I. t.. i COSTS SERVICE :MILEAGE AFFIDAVIT $ . .Nol;u-iid S('.1] ---I $ RHJlJId D, Mc;_':.::t~i, Pl'bli " Clw,n;bersbJlrg D~)[~) C, ,'Iffy CO!T::ni~sj()n E\i;;r;:~ J; , ~,,) '''1 i --...------ "' SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R.. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: THOMPSON NANCY but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On October 18th , 2004 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 ..00 .00 16.00 10/18/2004 SAIDIS SHUFF So answer:;;:,: ...,.' c___";) _~--,,---,:_ '__'- -- .~;;:-.-~~'", R: Thomas Kline G Sheriff of Cumberland .....--- .---"- County FLOWER LINDSAY Sworn and subscribed to before me this ~ g- day of YAW A'J d,tJV6 A.D. ~Ah f2 )rue.!" , ~ Prothonotary ,J/ In The Court of Common Pleas of Cumberland County, Pennsylvania Melissa J. Spencer SERVE: VS. Esther Goodhart et al Nancy Thanpson dc.f-}-)'; .,. rL- No. 04-4470 civil Now, Septenber 7. 2004 , I, SHERiFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~~~~ Sheriff of Cum berland County, P A . Affidavit of Service , 20~ at / / '9'..5'"0 'clock A M. served the within J? ?S~ a copy of the original ~'.~~ and made known to S~ the contents thereof. So answers, ~. D.fJf1r ~'O~" ~. . . / 4 . '. " /". / .,~ })'. u . / ... of t'~!!t:. Jc-',t,A7 V . sw.. om and sUbscribe~e. m~this J.:L day of. . .' . . ' 20 I if- . V-~:~/-. ~~~ COSTS SERVICE MILEAGE AFFIDAVIT $ . NOfarial S'~;11 Rldlard D, M~Cl:ll-' Chambersbilg 0lfO" My COllJlm~s,on cx" ~ J-'tdJli $ .._J' SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: DEUTSCH RAY G but was unable to locate Him in his bailiwick, He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE 18th , 2004 , this office was in receipt of the On October attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge 6,00 ,00 10,00 ,00 .00 16.00 10/18/2004 SAIDIS SHUFF So answel:!?:' .' _. , .r'. .'.. ..._--;-c"----'" ,,__~:-;;;>---""--~-'- './~~ ~?~</ R(, Thomas Kline Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me this day of r;",,, 7 :2t'O.5 A.D. Gl'L- (J. fn/j/L,/ ~ Prothonotary , , "'-' , c- '. In The Court of Common Pleas of Cumberland County, Pennsylvania Melissa J, Spencer VS. Esther Goodhart et al SERVE: Ray G. Deutsch N r;, r- .;S.1!IJ.J../ Ii-/) ~'/_ ;;l~3 I r---<./ No. 04-4470 civil Now, septanber 7, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~~~~ Sheriff of Cumberland County, PA Given address is CUmberland County. . Affidavit of Service Now, ,20-, at o'clock M. served the within upon at by handing to copy of the original a and made known to the contents thereof. So answers, .~~~Ln-. Sheriff of ~"c.#,vkL"",' County, PA Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE :MILEAGE AFFIDAVIT $ $ SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-04470 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R.. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT DEUTSCH RAY G but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT -QUIET TITLE , NOT FOUND , as to the within named DEFENDANT , DEUTSCH RAY G 329 B SPRINGVILLE ROAD SHIPPENSBURG, PA 17257 DEFENDANT NOT LOCATED AT 329 SPRINGVILLE RD NEW ADDRESS IS 307 MEANS HOLLOW RD SHIPPENSBURG - FRANKLIN COUNTY Sheriff's Costs: Docketing Service Not Found Surcharge 6.00 14.80 5.00 10.00 ..00 35.80 So answ::..t";El,y . >' / . /;tc??:;:~~.;:;y~ R. Thomas Kline Sheriff of Cumberland County SAIDIS SHUFF FLOWER LINDSAY 12/01/2004 Sworn and subscribed to before me this (.. .~ day of h / dOV0 A.D. ~ (l }}u;i'/,) ~ P ot onotary , SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: DEUTSCH RAY G but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On December 1st, 2004 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge Dep Franklin Co 6.00 9,00 10.00 38.40 .00 63.40 12/01/2004 SAIDIS SHUFF So answers: .// ,/ 7 :~~--.~~: R, ;ihomas Kli~~ ..- Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me this (, e day of0~ ;1~ A.D'U ~ ~ ~othonotary' . it In The Court of Common Pleas of Cumberland County, Pennsylvania Melissa J. Spencer ~ Esther V~art et al O~ _),~iIY r' . SERVE: Ray G. Deutsch 04-4470 civil No. Now, October 18, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff.. ~~~ Sheriff of Cumberland County, P A Affidavit of Service Now, II /olD' 1S-\-- - , 20 e/f , at fLj : 3:') o'clock L M. served the within r (IMP Q r 1; f -\ lit \ f upon ~\.\ G, T)-e(~'\5 c+-l at \Si L ,n(c>lY] IAlC\'1 (D.c,\ (,lTlh0 hPrc,h~"9 pA /7 po I by handing to ~O" G- 1J-ev-. +<:)('1, \ a \lUQ ~ ~s.-'u1~\ copy of the original (!(jJvJ F I 0' f1 t and made known to ~\., ~. ~ u\<;c "^ \ the contents thereof. So answers, COt'!., l.<.{. elf PI<', ~. of <:f1U>P.JK,LI AJ '. fo,OA YJ ['c,~J~fJ ~~ lJL)~ Sheriff of f . UC~unty, ;J(.' Sworn i ,ub,cribod b,f", _, I methi day o~, 20.u::r-- { (1<.. cc-c .:~~ I ------- - COSTS SERVICE $ MILEAGE AFFIDAVIT Uj. 'I~rd D~~~~~;.e~otaty Public $ Ch'bTSburg. Boro.Franklin County My "TlllSSl0t! ExpIres Jan. 29,2007 , v SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: DEUTSCH JESSE LEE but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On October 18th , 2004 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 10/18/2004 SAIDIS SHUFF So answers: 7 ., /~~;-_. R. Tomas Kline Sheriff of cumberland County FLOWER LINDSAY Sworn and subscribed to before me this day of C},,,w1 ~-1l ,5 A.D.. ~ Q 'h1,~D,__ ~ Prothonotary' Ie. t, , , In The Court of Common Pleas of Cumberland County, Pennsylvania Melissa J. Spencer VS. Esther Goodhart et al SERVE: Jesse Lee Deutsch ~"_;p'5r .7 (-C-- 04-4470 civil No. Now, Septenber 7, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin COmIty to execute this Writ, this deputation being made at the request and risk of the Plaintiff. r~~~ Sheriff of Cumberland County, P A . Affidavit of Service Now, ~(!,r: 4- ,20 tPtf" at I), s-s- o'clockf1. M. served the within CDMP, QUle.T'TIr-Lc //fAt"'tfNZ lu U T ~~H _.(.sry^'!c nI'" ,~ () F..jE~~e.Lubl?tl~~" "') npon by handing to IJEAr-He,2, ~eClr"<f-l GA......... pgf"'.€...;J ",e;.. PI! /;-,..<)/ . (SEe f}.o.D. <'''' ..J~'C~) at if.J. S- r/2.~,<JK..I--, -.I FI4 t2..,v( 01. P4 Me a 7/2.1/ j; I 11 iftf-f T , /' A1 <:: copy ofthe original L d l'f (.) <...."u ~ r I, r<-e. and made known to fjEf<- the contents thereof. So answers, ~:. ~ ~OO PA-: . OJ"D~ ~r"I.C\J Sheriff of COSTS SERVICE MILEAGE AFFIDAVIT $ Sworn and subscribed me this ~ day of NOI;trial S._~;d -----'.---.1 Rldl lId 0 M :1Jly No'rvfl 'I. i Ch<:J"ber~b'lJ ~ dD,\) 1\ ,'\;1 (",.','~ /I:rYC'OIJl1n,~SI)'lEx,)Jr>~J, .', c' , '~J $ 1..1 FRANKLIN COUNTY SHERIFF'S OFFICE 157 LINCOLN WAY EAST CHAMBERSBURG, PA. 17201 Chief Deputy John E. Strine Solicitor David C. Cleaver SHERIFF Robert B. Wollyung Day: (717) 261.3877 Night: (717) 263.1611 Hearing Impaired: (717) 264-8474 Fax: (717) 267-3493 ACCEPTENCE' . OF . SERVICE 4<'! (s€. La.it b0dSch I accept service of the Cn~IAird.. W ~MM~--hlk.. on behalf of . and certify that I am authorized to do so. 1-1e~-(, f) ,) ~-hc.4--., Defendant or Authorized Agent .3S'1\ . 0 rrJ'Iu W/l R.06.L Address 6 fl'~1bw,,}1 {1;>.'1'1 10- Y rV'-j Date 1 ,r SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: DEUTSCH CHARLES A but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of LANCASTER County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On October 18th , 2004 , this office was in receipt of the attached return from LANCASTER Sheriff's Costs: Docketing Out of County Surcharge Dep Lancaster Co 6.00 9.00 10.00 54.50 .00 79.50 10/18/2004 SAIDIS SHUFF So answ:~ . /~/~-:_ // -:;K~~~~ R.. 'Thomas Kline ' Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me this e ~ day OfQ""" ~'1 ;2tJ-().:) A.D. ~AL t2 In-,;Ph' ~ ..' Prothonotary' SHERIFF'S OFFICE 50 NORTH DUKE STREET, P.O. BOX 83480, LANCASTER, PENNSYLVANIA 17608.3480 . (717) 299.8200 SERVE {5' NAME OF INDIVIDUAL COMPANY, CORPORATION, ETC., TO BE SERVED. . Charles A. Deutsch ...,.,. 6. ADDRESS (Street or RFD, Apartment No" City, Bore. Twp" Stale and ZIP Code) AT 732 W. Brubaker Valley Road Lititz, PA 17543 7 INDICATE UNUSUAL SERVICE Yi OEPUTIZE 0 OTHER CUmberland Now, <) 17 20 ~ , I, SHERIFF OF COUNTY, PA., do he~..p cP.y iMJ.u. t.ize the. SS.~ heeJi.f .~ f . f T.=""'R\-f'r County to execute this Writ~ r'il6~~ur':'th.e~eof ~g 10 law. This deputation being made at the request and risk of the plaintiff. 4""",,")"'~'''''', .. /.~~........~ SHERIFF or cou 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE, CUmberland PLEASE TYPE DO NOT DETACH ANY COPIES. 2 C~'!,.':.'4N.w6'E~ivil 4 T't&5ffC!(l'ITai'la.C~'illint to oniet Title SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN 1. PLAINTIFF/SI . Mellssa J. Spencer 3 DEFENDANTISIEsther Goodhart et al CUMBERLAND CO. NOTE ONLY APPLICABLE ON WAIT OF EXECUTION: N.B, WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in pos.session, after notifying person at levyor attachment, without liability on the part of such deputy or Ule sheriff to any plaintiff herein for any toss, destruction or removal of any such property before sheriff's sale thereof 9. SIGNATURE of ATTORNEY or other ORIGINATOR 10. TELEPHONE NUMBER 11 DATE 717-243-6222 9/3/04 S D. FLOWER ES . 12. SEND NOTICE OF SERVICE COpy TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed) SAIDIS, SHUFF, FLOWER & LINDSAY 26 WEST HIGH ST. CARLISLE, PA. 17013 SPACE BELOW FOR USE OF SHERIFF ONLY DO NOT WRITE BELOW THIS LINE NAME of Authorized LeSO De~t~ or Clerk ANNETTE WALTON 717-295-~b09 JM 9/8/04 15 Expiration/Hearing datI:;; 10/4/04 n 13.1 acknowledge receipt of the writ l or complaint as indicated above. r 14 Date Received 16. I hereby CERTIFY and RETURN that have personally served, 0 have legal evidence of service as shown in "Remark.s", 0 ha\le executed as shown in "Remarks", the writ or complaint de ribed on the individual, company, corporation, etc., atthe address shown above or on the individual,company,cor. poration, etc., at the address inserted elow by handing a TRUE and ATTESTED COpy thereol 17.01 hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, elc., named above. (See remark.s below) 18 Name and title of indi\lidual served (if not shown abOve) (Relationship to Defendant) 19 ONoSer\lit:e See Remarks Below (No. 30) ~ 20 Address of where served (complete only it different than shown above) (Street or RFD, Apartment No.. City, 80ro. Twp State and lip Codel 21 Date of Service 22 Time C:) ~ Ul :r: 24. 12 <J- 2 'I-<i'-! -- PM /Z6--m;: Dep.lnt. 30. &11- Corr~cl-- S.TA. 34 31. 37 1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY. Sheriff's Office 4. BLUE - Sheriff's Office r,' -,,- SHERIFF'S OFFICE _Lj'.t )1Jlt'~ ' ~,:-_.-.j, --- 50 NORTH DUKE STREET.. P.O. BOX 83480, LANCASTER, PENNSYLVANIA 17608.3480 . (717) 299.8200 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN PLAINTIFF/Sf ;"'';;'.1 ; '~;~;:d co ':\1'- PLEASE TYPE DO NOT DETACH ANY COPIES. . 2 cR~~r4~'1W'~ivjJ 4 rrfE'-'1"r"ri"I,Ri'J cl:ll'i\'~~trg in t to {~_!i:-;:i ritl~,~ 3 OEFENDANT/S~~'.f: ti' i:::1 C"c,~ :t','fj, SERVE {5 N~ME_ ~F \NDIV\DU~l ~~..MPA~Y CORPORATION ETG TO BE SERVED . 6 ~~~~E~~ (Street o~ ~FD: :partment No City Bora Twp" Stale and ZIP Code) AT 1". :1 t" ,," \.:: llt\ "( ~ _' I"" f1\ ':":;,) 7 INDICATE UNUSUAL SERVICE '(J DEPUTIZE 0 OTHER C-Ijf: ""co"! ;-:'1; Now, ; /'; 20 ~ , I, SHERIFF OF:taIl((tMEn COUNTY, PA" do hereby . '. J. j ,e< County to execute this Wri to law. This deputation being made at the request and risk of the plaintiff. 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: I.. ; '[ ,1;"1i~Lf~ LAND ",-., -...".' I I \ I t', I NOTE ONLY APPLICABLE ON WAIT OF EXECUTION: N,B. W~JVEROFWA.TCHMAN - Any deputy sheriff levying upon or attaching My property under within writ may leave same w'ithout a watchman, in C}lstoqy.of whom~v.ris fOUf'ld in possession, after notifying person of levy oratlachment, wilhoutliabihtyon the part of such deputy or the sheriff to ~l1Ytploiinfiffjherein "tor any loss, destruction or removal of any such property betore sheriff's sale thereof 9. SIGNATURE of ATTORNEV oriath;erQRIGfNATOR '0. TELEPHONE NUMBER 11. DATE ,; f.il";::~' .0. }?:.cWEf? EEC~ n -'-.743.,,622/ 9/3,'-Cl~ 12. SEND NOTICE OF SERVICE COpy TO NAME AND ADDRESS BELOW: (This area must be compleled if notice is 10 be mailed) . ~ -', ,Yj~; ~f;;J17'i'~ FU.)i":t--~Q ~.~ ;-. TIJPSl\{ .' ;':'F/~'.i- r }(~:H :~T ,.'~'Y r,'.l /')1 SPACE BELOW FOR USE OF SHERIFF ONLY 13. I acknowledge receipt of the writ. l or complaint as indicated above f NAME of Authorized LeSO Deputy or,Clerk ~:J:;;~T'i'~' '''1:1'",.,T'f''';!'-: 7! c/,.')9f>_ 3r-!!j' ~ '1;" DO NOT WRITE BELOW THIS LINE 15 Expiration/Hearing dat& }U/.1!04 ~ 14. Date Received q/B/(!t' 16. I hereby CERTIFY and RETURN thaViJ have personally served, 0 have legal evidence of service as shown in "Remarks", 0 have executed as shown in "Remarks", the writorcomplaint de"iCrwed on the individual, company, corporation, elc., atthe address shown aboveoron the mdlVidual, company, cor. poration, etc" al the address inserted below by handing a TRUE and ATTESTED COPY thereol 17 0 I hereby certify and return a NOT FOUND because I am unable to locate Ihe individual, company, 18, Name and title of individual served (if not shown abo....e) (Relationship to Detendant) t::J )q ,~ 23 corporation, etc" named above. (See remarks below) 19. ONOS9fVice See Remarks BelCM' {NO. 30) t:J ~ (fJ 21. Dale of Service 22 Time - PM /fi../ /26~T ~r: , , ~.. f" 30. EMARKS S.TA. t/'{7l.:1 (' ,- I.(/t- .,/1..._ '''1 ,'-- i (" (>/" ",,- ~ C,.:t. roof'" . , i : /t;. ".}?, ~)'-r~ /d" / 34. day at -r ;/ 2 ''') , ~ . .' ( :: \, f'~7;"I")("~/,hL- 3~,Oate. c" , //" -;., j-::~.. ;X":/,,...l{ 6_~r,' 0) <-1 l-i r...-/ SHERIFF OF LANCASTER COUNTY ! ' ~'31. AFFIRMED and SUbscribJ;.d to before me 'this ~ " , 37 Prolfio-n-tilarYI.!?":p::illt"'lr';'f;Vf.i"'lic: MY COMMISSION EXPIRES 1. WHITE - Jssuing Authority 2. PINK - Attorney 3. CANARY - Sheriff's Office 4. BLUE - Sheriff's Office SHERIFF'S RETURN - U,S. CERTIFIED MAIL CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SPENCER MELISSA J VS. GOODHART ESTHER ET AL R. Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,HADDAD MARY ANN by United States Certified Mail postage prepaid, on the 7th day of September,2004 at 0000:00 HOURS, at 131 CHRIS DRIVE ENGLEWOOD, OR 45322-1146 , a true and attested copy of the attached COMPLAINT -QUIET TITLE Together with The returned receipt card was signed by RICHARD M. HADDAD 09/09/2004 on Additional Comments: Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 4.88 ,00 10.00 .00 20.88 So ans.":",:t;.s-://: _:::/ C;;:::C. . /~/....-~... '<~~~--2--/7 'R. Thomas Kline Sheriff of Cumberland County ? Paid by SAIDIS SHUFF FLOWER LINDSAY on 10/18/2004 . Sworn a~ sUbscrtfd to before me this (, day of_""".7 .J1Jv6 A.D. ~ {2 )y,,~, I/ltry,~ P ot onotary ,; g'f->:<: ,. . . . d' WI), ~ Q~~;?1t() 3 'Eo f->.';J o' Otll-:J3~ m ;:J():r- '" I~ ~~g Il _::T$.'< .t;..1::s co ~g.~g::;;i -' "- -' 10 " .... Cirm "':::OeD 10 w aoo:r(l);:;; )> w a.~ g: 3 ~3 " UJ o!1'~ :l. '" R ::;0;0. (1J [(J) " (Jlom.~8."'" l!l ru ::t: 1-" a, "0 c:::J w '" ru .,.~a ~ st3 o..OMI\:) 0 tr @Ql,...fXl<Illl1 S 0 (J! 'UO'"::To..:::-::::J W CIlS\)(I)~(iiQ. 0 N 3~g -<~ 0 N s=aa ro Cii.~ 1 . -og Q.\fl 0 f-> ;::r _(\)0 0 f-> (1)<< :T~.O .,. 3 g III ca 0 0 Do '" e!.' CD P--5 0 "" -Q: ~ CD 3 11 C:J ro 0 - o' -0 ~g CD CD :D ru ~ E' -0 3 b-' f'o p :D '" ~ tr I ~l~ 0 ::;:Vi ~ 'S ~&- l!. S. ~. ~ 2 In ~ a;- Cir.;2 ~~ ~ i S. ~1l ~~ ! . 11, g.~ ~~ i ODD ~ Q, O:DW ~r 0 bS"tJ' m' . 0 i h J:. P3 ~ :D " 3 .J:. m ;:: o _. ~. €b oct J:. 1< ~ 3 I -l g- " 0 0 ;:: e- m' i ~ ~ . ~ ~ '" 'S s 1- Q:, \4 'e '" .g, ., ~ ~ % ~ ~ ~ ~ '0- W, ~ 0- ~ 'e 5\ . -- ~ ~ 't5 \ (fl 1. '"' o 0- '& \i Ui 'ii> \:, 5 -- ~--- --:. ~ "- ~ --:. ~ ~ ~ ~ "- ~ ....::, --:;.. -::::?. ~ ~ ~ ~ ~ ~ ~ ~ :;.-::.. ~ ;. ~ ~ ~ A:. ~ o '" ~ ~ ~~ 1:;~ V" ? <" ~<;J,"O S'tf,r;: '3:::>.4.- ~<>- %.~~ tt, s <!.?, ""0tt, "'""..: ~~0 <.:> - ---- '" " SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SPENCER MELISSA J VS. GOODHART ESTHER ET AL R. Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,DEUTSCH JOHN C by United States Certified Mail postage prepaid, on the 7th day of September,2004 at 0000:00 HOURS, at 12420 CONDE DRIVE BROOKVILLE, FL 34613 , a true and attested copy of the attached COMPLAINT -QUIET TITLE Together with The returned receipt card was signed by 00/00/0000 on Additional Comments: CERTIFIED MAIL FOR JOHN DEUTSCH WAS RETURNED SHOWING A FORWARDING ADDRESS OF PO BOX 165 NEWBURG, PA 17240. Additional Comments Docketing Service Affidavit Surcharge 6.00 4.88 ..00 10.00 .00 20.88 So answers: . ~ ~/ /_.<c:~/ '"'~>~~ :/?----~~/ - / ? - . R. Thomas Kline Sheriff of Cumberland County Sheriff's Costs: Paid by SAIDIS SHUFF FLOWER LINDSAY on 10/18/2004 . Sworn and sUbscr~ to before me this l. "" day of (- '''7 d.ov,{ A.D.. Qtf:/" 0 YVlJ/p~. ) JJ?~ P 0 onotary "-rr- (,1 .j::. (T' .... (,1 '-1-" M..l l)l;) ...... ..../Jo.l ..... ..t,'f,i ~,.f J'I) l:.,i - - -" - II m -; c II 2 - -; 0 - - Ul m - 2 0 - 111 II -. 2'00110:: 11101110,~ !: Cll<=: mal-l!:-I COUl)>.!: llXOlli\; G1 :to':' I- 'll0' -; :t>lJ1 H 3:~ I- 111.!: o.j :J' I'U 111=--" J: x:.c o "0:'" I ~ o :;J I- J):\; 0' -; lJ1 Z:... 'f -l-::. Q:j,) o 00 '" 0 2,~:tC f!!. -. Z Cl) () n ;, g It ~J \ <I> ~O 0' 55"''' "'C:"'o '<"':rc ;: <I> lD ". "'en '"" ;?.o III moo "'cl '" :D ~..... r- "" <I> .. ~ o _...., ~ =:z '" 0 .........<- ~NO O.p.::r o N:l ~o() =: (). (000 - :l (0 "TIo..c rCtl(j) c:..v0C'l .p.-.::r C1l <' -'-(0 c:..v " CJ CJ w ru ru ll'" CJ CJ CJ CJ CJ 0> " C1 " ru " C1 ..ll .........---.. "'''' l"'~ 2 10M HI J; .... .., ~ ... ,. ~ 0 br. ,. .. "- ~ .. c ... '" '. '. '" ... , m t,....... ",;a,. r.,.,.r-':- ~. Jll J i Co~ 0 .-.._~...__.>~----.~ "._'-'-'-"->-'--~"~ ~-.:...., - i f I, "~i~ ~ 0 5=~ 'If ". t Jlgl ..OC!J;! 'Itll ; oJ co " IT' I .. ~ I ~ J ::::. <0 ...... o ....,.~ o o o "'c' o ,... :.:::: ~ ~ ._.. . ru J :::.~ ", .-.- o .. ::::: o ;: C'- ~ _"_ ! .~~ Ie ...~ .. o i, J II I I' JIll '11 II I..gs;' ::.l jj'~'J4, flI';>!. J t: !il~IJi ,~. tilmr' . --.,......,.........- --.,.'-- ~ '~'--............... ~ --"'-.,.--- -.,. ---- ..,..~ ------_.--'---------------~--~~ '- :;= SHERIFF'S RETURN - REGULAR CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT -QUIET TITLE was served upon DEUTSCH JOHN C the DEFENDANT , at 1615:00 HOURS, on the 30th day of September, 2004 at 7 WEST MAIN STREET NEWBURG, PA 17240 by handing to JOHN C DEUTSCH a true and attested copy of COMPLAINT -QUIET TITLE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 15..54 .00 10.00 .00 31.54 ~~~~ R. Thomas Kline . Sworn and Subscribed to before 12/01/2004 SAIDIS,SHUFF FLOWER LINDSAY BY~~ Deputy Sheriff '\ me this (. to day of Cfu ~{ A.D. b . '(V1AIP"i ~ P thonotary J SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2004-04470 P COMMONWEALTH'OF PENNSYLVANIA COUNTY OF CUMBERLAND SPENCER MELISSA J VS. GOODHART ESTHER ET AL R.. Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,DEUTSCH JENNIFER by United States Certified Mail postage prepaid, on the 7th day of September,2004 at 0000:00 HOURS, at 1810 HARVARD BLVD DAYTON, OH 45460 a true and attested copy of the attached COMPLAINT -QUIET TITLE Together with The returned receipt card was signed by 00/00/0000 . on Additional Comments: CERTIFIED MAIL FOR JENNIFER DEUTSCH WAS RETURNED TO SHERIFF'S OFFICE. MAIL HAD BEEN FORWARDED TO MOUNT UNION, PA PRIOR TO BEING RETURNED TO SHERIFF. Additional Comments Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 4.88 .00 10.00 .00 20..88 So answers . ~. .' ..-- . .~./ >.<.... .. ..~... .2-/ ~_/ .-:/ -?~~ ~ ---- R: Thomas Kline Sheriff of Cumberland County Paid by SAIDIS SHUFF FLOWER LINDSAY on 10/18/2004 . Sworn and subscr~d to before me this i, y., day of~ dfJO-S A.D. (~". J Q ~;J,. ~ .. .~-r r thonotary rn..~ !~. -r:: :;;'''i II., ~ ~ "'.. ...... Q.-) fill w :;; [~~I ~~. ! .~}~~;: t .. , rn tr ..JJ ru f'- o f'- <0 o o o o o ..JJ ru ru rn o o f'- '" 0= ~ Z -- R <("'Q)- ....J CII ~ . C:J:~m Wen 0"2 ~C11(1)~ :J.I:~>. <'>~5~ u.......cc: 001:., :JQ, '>CIIoa; 1-1.1<.>_ Z._ VJ = ~.- ~ 't:: 00 '" <.> <.> _.W ,> ~ ;-: a: W '" .... ~~ ., W t:;~ zWQ ~3:e:cc~ I.LlOCl)~c( a:z__ 3: c~a:l.lJa: ~~~~c I-Z:E~~ ~Q~WI- -w ~w UI-::r-J...,J i:i:'D..uw= LL.::E;:::::)Qcc ::JWCI')I-Z CI)~C10:J U ~c:cz:z:. r DODD o - <:t:ucn -5~ 0 '" ~ ~~ '- ~ :Jt -, .,-' ~~ o Cc ~. <:1.... .r- \Yi -",;-"" ~-'~;' L C) I SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle, PA II MELISSA J. SPENCER, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW ESTHER GOODHART, SALLY L. : NO. 04-4470 CIVIL BERKLlTE, JANE BITNER, MARY ANN HADDAD, : ACTION TO QUIET TITLE GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY : JEAN SEIBERT, NANCY THOMPSON, : JOHN C. DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A. DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. PRAECIPE TO THE PROTHONOTARY: Please reinstate the Complaint in this matter and send the reinstated Complaint with the attached memorandum to the ShE~riff for purpose of service. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for the Plaintiff Date: February 16, 20054 (1) ~A.....\\.. "\ James D. FI~~e~r., E~q~r7 26 West High Street Carlisle, PA 17013 (717) 243-6~!22 1.0.#27742 cz; , --,', ,..1 -".-' - --- __t~h- So s" A ~('./-' - In the Court of Common Pleas of Cumberland County, Pennsylvania VS. ~-+L C~~~-t~ No. 04 -l.J '-111) Civil.J\l:2D 4 ~ -.h ~ I ~ D~T;-IIe_ - ~ . ~ l..LA~ L..ll +W\ ~ (\~ To Prothonotary '5-/, ~O~ ~ ~~~ Alto ey fo~ Plaintiff ;-j; v:' No. Tenn, 19 _ .., I'. /\; , , , " C', :. vs. PRAECIPE Filed 19 , Ally. ,..;,' SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R.. Thomas Kline , Sheriff or Deputy Sheriff wh being duly sworn according to law, says, that he made a diligent sea ch and and inquiry for the within named DEFENDANT , to wit: DEUTSCH JENNIFER but was unable to locate Her in his bailiwick. He therefor deputized the sheriff of HUNTINGDON County, Pennsylvani , to serve the within COMPLAINT -QUIET TITLE 29th , 2005 , this office was in receipt of th attached return from HUNTINGDON On March Sheriff's Costs: Docketing Out of County Surcharge Dep Huntingdon Co Postage 18..00 9.00 10..00 30..76 .37 68.13 03/29/2005 SAIDIS SHUFF So answ~: /~.--:---:~.-", ,,) .."..::.--" ..-..,.--_...,,'-_'~{ ..;--C;; .-.c.;..~ /~-:. R. Thomas Kline Sheriff of Cumberland ;.""'" '-'-;:7 County FLOWER LINDSAY Sworn and subscribed to before me this U day of /Qr'd rID (j S Prot -,~1'*o SHERIFF'S RETURN - OUT OF COUNTY , , CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R, Thomas Kline , Sheriff or Deputy Sheriff wh being duly sworn according to law, says, that he made a diligent se rch and and inquiry for the within named DEFENDANT , to wit: DEUTSCH JENNIFER but was unable to locate Her in his bailiwick. He theref re deputized the sheriff of DAUPHIN County, Pennsylva ia, to serve the within COMPLAINT -QUIET TITLE On March 29th , 2005 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin County Postage So ans"".eFs: - . / /' / ~~/~;;.'~ R. Thomas Kline Sheriff of Cumberland Count 6.00 9.00 10.00 31.25 .74 56.99 03/29/2005 SAIDIS SHUFF FLOWER LINDSAY Sworn an~ SUbscribed~ before this a day of l- H 1 ,r- 0<. () 0 "J me ,~ , . n The Court of Common Pleas of Cumberland County, PenniSyl vania Melissa J. Spencer VS.. Esther Goodhart et al SERVE : Jennifer Deutsch Thomas No. 04-4470 civi ow, February 22, 2005 , I, SHERIFF OF CUMBERLAND COUNTY P A,do reby deputize the Sheriff of Huntingdon County to execute this' ri t, this putatian being made at the request and risk afthe Plaintiff. ~%'9:<, < .~(--::::1;~' ~ . ..-t. ~..,_dt'..(.,,_,",:i'~,~~~~-:,~....tV , Sheriff of Cumberland County, P A Affidavit of Service ow, ,20_, at o'clock M. serv d the ithin on handing to copy of the original d made known to the contents thereof. So answers, Sheriff of County .p COSTS om and subscribed before SERVICE $ e this - day of ,20 MILEAGE - AFFIDA VIT $ I N he de N w up at by a an Sw 111 , . SHERIFF'S OFFIC HUNTINGDON COUNTY, PENNSYL ANIA 241 Mif in Street Huntingdon, P 16652 Telephone: 814-6 3-0880 William G. Walters, Sheriff Melissa J. Spencer No. 4470 T em1 2004 Vs. Jennifer Deutsch Thomas Now, this 28th day of February ,2005, I am unable to locate the within n ed defendant, Jennifer Deutsch Thomas , within my bailiwick, return this Notice and Complaint in Quiet Title "NOT FOUND." Reason unable to serve: defendant is no longer the Minister of this church. Postmaster stated she was transferred to the Harrisburg Area, they have no forwarding address for Ms. Thomas So Answers, Sworn and sub~ed to before me this . ~ day of ~l.ti) 20 <;, AD. Il/~~ 61d~ William G. Walters, Sheriff De~rist!~per Chief Deputy/Deputy Costs: Rec. & Doc. Return Not Found Mileage/Postage Surcharge Affidavit Miscellaneous Total Costs .. '~ No tal Seu.l Tammy S. COOH$, Notary Public Huntmgdon Boro, Huntingdon County My Commission Expires Oct. 21. 2006 Member. Pennsylvania Associationot NQtarfes $30.. 76 Paid . . In The Court of Common Pleas of Cumberland Connty, Pc nsylv:mia Melissa Spencer VS. Esther Goodhart SERVE: Jennifer Deutsch Thanas No. 04-4470 civil Now, March 15, 2005 ,I, SHERIFF OF CUMBERLWTI COUN Y, PA, do hereby deputize the Sheriff of Dauphin County to execute tlli Writ, this deputation being made at the request and risk of the Plaintiff. ~' .,- ./"-;;" ~ ,. ~~,;::.~"'-. ~ ~..-.-~~~./ J9 1--' ,. ..-,;1"L- r ~ ~...<' ""'-:;" ~",,,~~.~...... Sheriff of Cumberland County, A Affidavit of Service Now, , 20_, at o'clock M. se ed the within upon at by handing to a copy of the original and made known to , the content~jher~~ . So answers, - ,~. V"'~ "-' ~"~:) (,.) Sheriff of Coun'ty, A Sworn and subscribed before me this _ day of , 20 COSTS SERVICE MILEAGE AFFIDAVIT $ $ , . @ffit~ of t1p~ ~lre:riff William T. Tully Solicitor J. Da iel Basile Chi Deputy Mary Jane Snyder Real Estate Deputy Michael . Rinehart Assistant hief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255.2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania SPENCER MELISSA J vs County of Dauphin THOMAS JENNIFER DEUTSCH Sheriff's Return No.0489-T - -2005 OTHER COUNTY NO. 04-4470 AND NOW:March 18, 2005 at 9: 36AM served the within ACTION TO A QUIET TITLE upon THOMAS JENNIFER DEUTSCH by personally handing to JENNIFER DEUSTH THOMAS DEFT 1 true attested copy(ies) of the original ACTION TO A QUIET TITLE and maki g known to him/her the contents thereof at 175 N FAIRVILLE HARRISBURG, PA AVENUE 17112-0000 Sworn and subscribed to So Answers, JfrJ$L before me this 21ST day of MARCH, 2005 Sheriff of ~~ By NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin Counry My Commission Expires S~pt. 1, 2006 Deputy Sheriff Sheriff's Costs:$31.25 PD 03/17/ 005 RCPT NO 204923 GM SAlOIS SHUFF, FLOWER & LINDSAY ATIQRNEYS-AT-[.AW 26 W. High Street Carlisle. P A MELISSA J. SPENCER, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW vs. ESTHER GOODHART, SALLY L. : NO. 04-4470 CIVIL BERKLlTE, JANE BITNER, MARY ANN HADDAD, : ACTION TO QUIET TITLE GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY : JEAN SEIBERT, NANCY THOMPSON, : JOHN C. DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A. DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. AFFIDAVIT IN ACCORDANCE WITH Pa.R.C.P. ~1066 AND NOW, comes Plaintiff, ME:L1SSA J. SPENCER, through her attorneys, SAlOIS, SHUFF, FLOWER & L1NDS.lIY, and makes the following Affidavit: 1. Plaintiff filed the within action to quiet title on September 3, 2004; 2. Plaintiff was the only child of decedent, MICHAEL L. CRESSLER, who died August 11, 1996, and was appointed administrator c,t.a. of the Estate of MICHAEL L. CRESSLER, by Decree of the Register of Wills of Cumberland County, Pennsylvania, on December 4, 1997, to docket number 1997-00950: SAlOIS SHUFF, FLOWER & LINDSAY AITORNEVS-AT.LAW 26 W. High Street Carlisle, PA 3. The Will of MICHAEL L. CRESSLER provided, in pertinent part, that all of his mountain ground situate in Southampton Township, Cumberland County, Pennsylvania, would pass to his daughter, Plaintiff MELISSA J. CRESSLER; 4. The Estate of MICHAEL L. CRESSLER was insolvent as a resul of various debts, and an Order was entered by the Honorable George E. Hoffer to said Estate authorizing MELISSA J. CRESSLER to purchase the property from the Estate provided that such sale shall not have the effect of a judicial sale discharging the liens upon the real estate, but specifically providing, however, that said Order would not have the effect of clouding the title or removing any clouds from the title or resolving any disputes related thereto. She did purchase :iiaid mountain ground from the estate in accordance with that Court Order; 5. The mountain ground in question located in Southampton Township and consisting of approximately 25 acres, more or less, was conveyed by MICHAEL L. CRESSLER'S brother, JOHN T. CRESSLER, in accordance with a Power of Attorney, granted to him in 1945, while MICHAEL L. CRESSLER was in the military overseas during World War II, into the name of JOHN T. CRESSLER and MICHAEL L. CRESSLER, as tenants in common, through Deed dated October 17, 1945, and recorded in the Office of the Recorde!r of Deeds of Cumberland County on October 8, 1945, in Deed Book "V", Volume 13, Page 202, a copy of which Deed was attached as Exhibit "A" to the Complaint in this action to quiet title; 6. Said conveyance was witl10ut consideration and was for the convenience of MICHAEL L. CRESSLER, however, JOHN T. CRESSLER failed to re- SAIDIS SHUFF, FLOWER & LINDSAY AITOKNEYS'-AT.UW 26 W. High Street Carlisle, PA convey the property to MICHAEL L. CRESSLER before the death of JOHN T. CRESSLER; 7. Based upon the research and review of the records relating to the Estate of JOHN T. CRESSLER, and any heirs of the heirs of JOHN T. CRESSLER, it is believed and averred that the list of Defendants are all of the individuals and entities that could assert a claim to the aforesaid mountain ground in Southampton Township, Cumberland County, Pennsylvania, based upon any claim of inheritance from JOHN T. CRESSLER; 8. Attached as Exhibit "A" to this Affidavit are the Sheriff's Returns confirming that services was completed for all of Ithe Defendants; 9. All Defendants were advisedl, 20 days or more after service of the Complaint on them, that they were in default for failure to enter a written appearance, and that judgment could be taken against them; 10. The Notices of Default are clttached hereto as Exhibit "B", the last notice of which was served upon JENNIFER DIEUTSCH THOMAS (formerly Jennifer Deutsch) of 175 North Fairview Avenue, Harrisburg, Pennsylvania 17112, on April 8, 2005; 11. No Defendant in this action has filed an Answer to the Complaint contesting the relief sought; 12. Plaintiff's counsel has received a number of calls from Defendants and on a few occasions, attorneys, on behalf of Defendants, and believes that no Defendant currently intends to contest the relief sought in Plaintiff's Complaint. SAlOIS SHUFF, FLOWER & LINDSAY AlTORNEYS-ATeUW 26 W. High Street Carlisle, P A WHEREFORE, in accordance with Pa.R.C.P. 91066, Plaintiff requests that this Honorable Court enter an Order barring all Defendants from asserting an right, lien, title or interest in the land inconsistent with the interest or claim of Plaintiff, unless Defendant takes such action as the COUlt directs within thirty days thereafter and, in accordance with Pa.R.C.P. 91066(b)(4), enter an Order to the effect that Plaintiff is henceforth the owner in fee simple of the mountain ground in question, specifically all mountain ground in the name of MIICHAEL L. CRESSLER or MICHAEL L. CRESSLER and JOHN T. CRESSLER, as tenants in common, situate in Southampton Township, Cumberland County, Pennsylvania. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for thiS Plaintiff Date: July15, 2005 ;James D. Flo r, ., Esquire 26 West High Street Carlisle, PA 17013 (717) 243-6222 I.D.#27"742 Sworn and subscribed to before me this 15th day of July, 2005. ) NOTARIAlSEAL [J MERLENE J. MARHEVKA.. NOTARY PUIIUC CARLISLE. CUMBERLAND COUNTY.. I~A MY COMMISSION EXPIRES JUNE 8. 2<J08 ~ ,"", (') c: ::>~' c-;~ -. :,~ r--' "" c;:-.> <-" <.~ c. rOo Q, -' -r:-,"\ fi1.~ -YJ 11:!; :"''1' t':\)1 ~~;? - CP :J: ( ~"( ~. ,^CI <r' c:.> :~ .. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MAR 3 1 2005 SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: DEUTSCH JENNIFER but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of HUNTINGDON County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On March 29th , 2005 , this office was in receipt of the attached return from HUNTINGDON Sheriff's Costs: Docketing Out of County Surcharge Dep Huntingdon Co Postage 18.00 9..00 10.00 30.76 .37 68.13 03/29/2005 SAIDIS SHUFF So an~S'": ../'? .>:?"'.:........ ~_.-:;/ ...-;;~~..~" .//-;;;c;~~~-;P R.. Thomas Kline c: Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me this day of A.D. Prothonotary SHERIFF'S RETURN ~ U. S. CERTIFIED !viAlL CASE NO: 2004~04470 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SPENCER MELISSA J VS. GOODHART ESTHER ET AL R. Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,DEUTSCH JENNIFER by United States Certified Mail postage prepaid, on the 7th day of Septenilier,2004 at 0000:00 HOURS/ at 1810 HARVARD BLVD DAYTON, OH 45460 a true and attested copy of the attached COMPLAINT ~QUIET TITLE Together with The returned receipt card was signed by 00/00/0000 on Additional Comments: CERTIFIED MAIL FOR JENNIFER DEUTSCH WAS RETUru~ED TO SHERIFF'S OFFICE. MAIL HAD BEEN FORWARDED TO MOUNT UNION, PA PRIOR TO BEING RETURNED TO SHERIFF. Additional Comments Docketing Service Affidavit Surcharge 6.00 4.88 .00 10.00 .00 20.88 So answers-,_ .__~ "" <,---- .---;;::::~.:'~-::5- - ,~~<~:~~:.'~:::~-~-- - /~c'-'--;;'~~~> ?_.__. -,.-- R-:" Thomas Kline Sheriff of Cumberland County Sheriff's Costs: Paid by SAIDIS SHUFF FLOWER LINDSAY on 10/18/2004 . Sworn and subscribed to before me this day of A.D. Prothonotary III The Court of ComrHon Pleas of Cumberland Cl1~mty, Pennsylvania Melissa J. Spencer VS. Esther Goodhart et a1 SERVE: Jennifer Deutsch Thanas No. 04-4470 civil Now, February 22, 2005 , I, SfIERIFF OF CUJvlBERLAND COUNTY, P A, do hereby deputize the Sheriff of Huntingdon County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~~ _4' -' 7' p- ~"'4. " .;, ;.o:;.....~ ?~J' Sheriff of Cum her land County, PA Affidavit of Service Now, ,20_, at __ o'clock M. served the within upon at "by handing to a copy of the original and made knovm to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDA V[T $ 3> SHERIFF'S OFFICE HUNTINGDON COUNTY, PENNSYL VANIA 241 Mifflin Street Huntingdon, P A 16652 Telephone: 814-643-0880 William G. WaIters, Sheriff Melissa J. Spencer No. 4470 Term: 2004 Vs. Jennifer Deutsch Thomas Now, this 28th day of February , 2005 ,I am unable to locate the within named defendant, Jennifer Deutsch Thomas , within my bailiwick, return this Notice and Complaint in Quiet Title "NOT FOUND." Reason unable to serve: defendant is no longer the Minister of this church. Postmaster stated she was transferred to the Harrisburg Area, they have no forwarding addxess for Ms. Thomas So Answers, ;:(/a~ &' /d~ Sworn and sUb~ed to before me this . ~ day of ~!t 20 <;", AD. blic -~ William G. Walters, Sheriff /'k }-7 / De~' Christop~~per Chief Deputy/Deputy Costs: Rec. & Doc. Return Not Found Mileage/Postage Surcharge Affidavit Miscellaneous $9.00 $~.OO $9.76 No la] Sea] T~mmy S. Coons. Notary Public Huntmgdon Bom, Huntingdon County My Commission Expires Oct. 21, 2006 Member, PennsyJvaniaAsSOC.iajjonof Notaries $3.00 Total Costs $30.76 Paid In The Court of Common Pleas of Cumberland County, Pennsylvania Melissa Spencer VS. Esther Goodhart SERVE: Jennifer Deutsch Thomas No. 04-4470 civil Now March 15, 2005 , , I, SfIERIFF OF CUJY1BERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin " County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~/")/ .//#;' r ~~~4"~--...J' Sheriff of Cumberland County, P A Affidavit of Senrice Now, ,20 , at o'clock - -- M. served the within upon at by handing to a copy of the original So answers, co ~. '..n .~-' the contel1tfil:Per~f. ;::.:.c: ~-::: ;;v ~:~ ;~~~; :~ :'c-,,- t'; -..l ,~~.;;::~=; ~ - -..'-. <: ~ :~}~S' m ,1""1. "-;.....' . :-- z o Lv ;- and made lmown to Sheriff of Coun'ty, PA Sworn and subscribed before me this _ day of , 20 COSTS SERVICE MILEAGE AFFIDAVIT $ $ @tlic~ of :tlp~ ~4P:rift William T Tully Solicitor 1 Daniel Basile Chief Deputy Mary Jane Snyder Rea] Estate Deputy Michael W, Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (7] 7) 255-2660 fax: (7] 7) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania SPENCER MELISS.1\. J vs County of Dauphin THOMAS JENNIFER DEUTSCH Sheriff's Return No. 0489-T - -2005 OTHER COUNTY NO. 04-.4470 AND NOW:March 18, 2005 at 9:36AM served the within ACTION TO A QUIET TITLE upon THOMAS JENNIFER DEUTSCH by personally handing to JENNIFER DEUSTH THOMAS DEFT 1 true attested copy(ies) of the original ACTION TO A QUIET TITLE and making known to him/her the contents thereof at 175 N FAIRVI.LLE AVENUE HARRISBURG, PA l7ll2-0000 ~~ So Answers, :;K~ """He o,~... By Sworn and subscribed to before me this 2lST day of MARCH, 2005 NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspirc, Dauphin County My Commission Expires Sept. 1, 2006 Deputy Sheriff Sheriff's Costs: $31.25 PD 03/l7/2005 RCPT NO 204923 GM SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2004-04470 P COMMONWEALTH" OF PENNSYLVANIA COUNTY OF CUMBERLAND SPENCER MELISSA J VS. GOODHART ESTHER ET AL R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,DEUTSCH JENNIFER by United States Certified Mail postage prepaid, on the 7th day of SepteIT~er/2004 at 0000:00 HOURS, at 1810 HARVARD BLVD DAYTON, OH 45460 a true and attested copy of the attached COMPLAINT -QUIET TITLE Together with The returned receipt card was signed by 00/00/0000 on Additional Comments: CERTIFIED MAIL FOR JENNIFER DEUTSCH WAS RETURNED TO SHERIFF'S OFFICE. MAIL HAD BEEN FORWARDED TO MOUNT UNION, PA PRIOR TO BEING RETURNED TO SHERIFF. Additional Comments Sheriff's Costs: Docketing Service Affidavi t Surcharge 6.00 4.88 .00 10.00 .00 20.88 So answers _'- _"C" -~~~;~~~~:::'~;~ R: Thomas Kl ine Sheriff of Cumberland County Paid by SAIDIS SHUFF FLOWER LINDSAY on 10/18/2004 . Sworn and subscribed to before me this day of A.D. Prothonotary ,.,..".,..""'"~ ,""'\- ~ if1"'~i (tit:! ~I i)~~ ~ ~~ ~:~~: .~ ,~ ";1 ~,~".'.; "'.~.j!l:iJ"'~. ~i I :l;",:.};",~, ~~: ::EM ~\.",,\:,:tO;: iV{?!':~~ ,t',,~ _ "f; /'" Q 1 ilE :; ~, '~'!tt l;;~ ~~~ ~ ~~L \-.:; ... ~H:;:J ,"'" :;.J'iii4 ~ f -; .~ ;J .~,--~ ITl tr .ll ru ['- o ['- OJ o o o o o .ll ru ru ITl o o ['- Cl= ;:2 Z 0 <"i: Q)~ ..JGI~~ a:.c~ct1 w... 0'.- OJ v, c ~GI(I)~ =>.cffi>. Ut-5~ l1.....r:c OOt<l> ::JQ. , ~ GI 0 _ ZU()~ .- <IJ =>:::T"":e 00 '" () () c,... , ~ ,,~.t\ ~L5 ~' "''.t' ,-.:;,( ,r- '" W :r .... '" )(~ <IJ W , tu~ ZWQ ~s:a:CZ:Q WOI-CI;Ia: .a:z~cz:~ C:::':::a:w::- c+-w.....a: CZ:oaUlQC I-z:Eo:iCl.L. Z =:la:o !:!::!8z~+- ==6:::I:::;~ I.L. UWca u..:E=:lOc::c: ::::IWCI;II-Z ~t::OO::::l -C(zz, DODD ....... 00 v r ::; .r: u (/) - :J Q) o bVO .-.J ~ \"\, tr~ ~ ~ c c Q) ...., .-" ~.. I ~~, 0J, t::: (i fr~"~ ~..'~ r } '- " I \1 ;'i Ii 1'1 r: fi r ~ (~ II q 11 ,1 II /! IJ lJ II Ij 11 I' ~ Ii j",' Ii il Ii: i$ i ~i i~ ,\ j I j j ii < , .' . ! :i , "j- " ~ , "1 I II , ! . 1 1 ! j i I 1 ; I I , ,( j I j "j i SHERIFF'S RETURN - REGULAR CASE NO: 2004~04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT -QUIET TITLE was served upon GOODHART ESTHER the DEFENDANT at 1738:00 HOURS, on the 9th day of September, 2004 at 206 E BURD STREET SHIPPENSBURG, PA 17257 by handing to ESTHER GOODHART a true and attested copy of COMPLAINT -QUIET TITLE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 15.54 .00 10.00 .00 43.54 /". , ,/~&'. ~#'} /:'" .,.,.Y" ,r"';;/" PP~! /,4-"'~" --, ~.~:~ /'. ':~..; .~<:?' ~ ~~,.." .,-.-~......... .:,,,,..'~" , -y &.~...,... .'. ~.,..~;v'- .- " ~.,. "- </' - R. Thomas Kline day of 10/18/2004 SAIDIS SHUFF FLOWER LINDSAY BY:~')2 C / J , /l~ ~puty Sheriff Sworn and Subscribed to before me this A.D. Prothonotary -- In The Court of Common Pleas of Cumberland County, Pennsylvania Spencer VB. Goodhart, et a1. SERVE: No, 04-4470 civil Sally Berk1ite Now, , I, SHERIFF OF CUMBERLAND COUNTY, P A, do bereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~~.--L~ Sheriff of Cumberland County, PA Affidavit of Service Now, ~-/" t!rn1j'. Q ~'--'/ ,~~-& IILLL; ~ /3 ! -3;:- Y^-LC ~ V~ ~~-<,~ j ~ /~,,~= I ' ?O Il<! at l....s ~o'clock , - .-' --'-- P M. served the within upon at )fC'L1A-J.4~' jJCL 17~-J- by handing to a ,/-t~/ - {U-L~ copy of the original Cc,-y. ~ J<:U'- and made known to -fl' I ~V(/ the contents thereof. So answers, ~u.... ,'OJ p~, /;} 't1'7 _0 " , ~.07~, 1------____ r-. \ r\ _ ^ i I''''''''nii:''C::S~'._--'.~~~ ~ ,I . -. ;~, . ,. ..' ". i Ji,' ' . , Sheriff I ' ._---,~----._--. /'" ~ ~'\.'rZ\I/l County, PA Swom and subscribed b~ methls~dayof~ '-. ,20 Ii',," {l_~",-,-..xg.. ~~pA~4 COSTS SERVICE $ MILEAGE AFFIDA VIT 3) SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: BERKLITE SALLY L but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On October 18th , 2004 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge Dep Franklin Co So answe~$_: -.., 6.00 9.00 10.00 317.48 .00 342.48 10/18/2004 SAIDIS SHUFF --.:;;-.- -"/,,- --- R. Thomas Kline Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me this day of A.D. Prothonotary DI..TE R~CF.!VED Dp,TE PROGESSEI S,HERh":'F'S DEPAf~T tJlENT ADAMS COUNTY, PENNSYL V "'MiA COURTHOllSE, GETTYSBURG, P'A 10'325 SHERIFF SERVICE PROCESS RECEIPT. and AFFIDAVIT OF RETURN INSTRUCTIONS: See "INSTRUCTIONS FOR SERVICE OF PROCESS BY THE SHERIFF" on the reverse of the last (No.5) copy of this form Please type or print legibly, insuring readability 01 all copies Do not det!lch any copies. ACSO ENV.K 2. COURT NUMBER 04-4470 Civil 4. TYPE OF WRIT OR COMPLAINT Comolaint To Quiet Ti tIe , TO SERVICE OR DESCRIPTIOI\I OF PROPERTY TO BE LEVIED, ATTACHED OR SOLD. 1 PLAINTIFF/SI MELISSA J. SPENCER 3 DEFENDANT/SI ESTHER GOODHART , IT AL SERVE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC . Jane Bitner 6 ADDRESS (Street or RFD, Apartment No., City, Boro, Twp., State and ZIP CODE) AT 1314 Pine Run Road, Abbottstown, PA 7. INDICATE UNUSUAL SERVICE: Now, o PERSONAL 0 PERSON IN CHARGE 0 DEPUTIZE 0 CERT. MAIL 0 REGISTERED MAIL 0 POSTED 0 OTHER , I, SHERIFF OF ADAMS COUNTY, PA., do hereby deputlze the Sheriff of County to execute this Writ and make return therof according to law, This deputation being made at the request and risk of the plaintiff. SHERIFF OF ADAMS COUNTY B_ SPECIAllNSTAUCTIONS OR OTHER INFORMATION THAT WilL ASSIST IN EXPEDITING SERVICE. NOTE ONLY APPLICABLE ON WAIT OF EXECUTION: N.B_ WAIVER OF WATCHMAN-Any deputy sheriff levt'ing upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, aller notifying person of levy or aUachment. without liability on the part of such deputy or the sheriff to any plainlitf herein lor any loss, destruction or removal of any such property before sheriffs sale thereof 9. SIGNATURE of A.TTORNEY or other ORIGINATOR requesting service on behalf 01 K PLAINTIFF o DEFENDANT 10. TELEPHONE NUMBER 11 DATE James D. Flower, Jr., Esq. (717) 243-6222 SPACE BELOW FOR USE OF SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE 14. Expiration I ~ date OCT. 3 2004 SIGNATURE 01 Authorized ACSD Deputy or Clerk and Tille 13. Date Received 12. I acknowledge receipt of the writ or complaint as indicated above. 9-8-2004 15 (hereby CERTIFY and RETURN that I K have personally served, 0 have served person in charge, 0 have legal evidence of service as shown in "Remarks" (on reverse) ::J have posted the above described property with the writ or complaint described on the individual, company, corporation, etc., althe address shown above or on the individual, company, corporation, etc., at the address inserted below by handing/or Posting a TRUE and ATTESTED COpy therof 16. 0 I hereby certify and return a NOT FOUND because I am unable to locale the individual, company, corporation, etc., named above. (See remarks below) 17. Name and title of individual served Jane Bitner 1 B. A person or suitable age and discretion then residing in the delendant's usual place of abode. 0 Read Order o 19. Address of where served (complete only if dilferenllhan shown above) (Street or RFD, Apartment No., City, Boro. Twp., State and ZIP CODE) 20. Dale 01 Service 21. Time 9/8/2004 6:10PM Advanc~ Costs 25. Miles Dep.lnt. Dep.lnt. 22. ATTEMPTS Dep.lnt. Date 28. ~~ REFUND $121.80 ck. #11633 AFFIRMED and subscribed 10 before me this NA day of Date 9/8/2004 Signa1ure of Sheriff RAYMOND W. NEI.MAN Date 9/8/2004 ProlhonotarylDeputylNotar)' Public SHERIFF IOF ADAMS COUNTY MY COMMISSION EXPIRES I ACKNOWLEDGE RECEIPT OF THE SHERiFF'S RETURN StGNA TURE OF AUTHORIZED ISSUING AUTHORITY AND TITLE. J 39. oalo Rece;vod Pr-{OTHONC-T/,F~"V SHERIFF'S RETU~ - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline . Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT . to wit: BITNER JANE but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of ADlI.MS County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On October 18th . 2004 , this office was in receipt of the attached return from ADAMS Sheriff's Costs: Docketing Out of County Surcharge Dep Adams County So answers: , 6.00 9.00 10.00 28.20 .00 53.20 10/18/2004 SAIDIS SHUFF - - . . ._- ;:;:'-;"~:"'-~'~>-""--;,:-"-,--':~~" --".... ,,-~~_....-'""--'.-'''-,---,. ~ R. Thoma;' In lne- ,'" .~ Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me this day of A.D. Prothonotary En The Court of ComIl,on Pleas of Cumberland C-,unty, Pennsylvania Melissa J. Spencer VS. Esther Goodhart et al SERVE: Jane Bitner No. 04-4470 civil Now, Septanber 7, 2004 , I, SfIERIFF OF CUlvIBERLA."ND COUNTY, P A, do hereby deputize the Sheriff of Adams County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. CZ~ f" ~Jo- ,/.-;;' .,.,... ,y....-:...... , .' ,-~... ""~-' ./-':<. ~ "'??It~"~~ /f ""..B:.~;~~~ Sheriff of Cumherland County, PA Affidavit of Service ,20_, at o'clock M. served the Now, within upon at by handing to copy originaC------ ... and made Imown to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of , 20 COSTS SERVICE MILEAGE AFFIDAVIT $ $ SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2004~04470 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SPENCER MELISSA J VS. GOODHART ESTHER ET AL R, Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,HADDAD MARY ANN by United States Certified Mail postage prepaid, on the 7th day of September,2004 at 0000:00 HOURS, at 131 CHRIS DRIVE ENGLEWOOD, OH 45322-1146 , a true and attested copy of the attached COMPLAINT -QUIET TITLE Together with The returned receipt card was signed by RICHARD M. HADDAD 09/09/2004 on Additional Comments: Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 4.88 .00 10.00 .00 20.88 So answeJ~s-: .._~__-..... .- ~ r;:;::::~-:'::_'-"_-':-,,,,cc:"--:.:-:,-~'--~~~''''-;'''~:"'::;------- ~".~,~~~4~/Z---'--( R. Thomas Kline Sheriff of Cumberland County Paid by SAIDIS SHUFF FLOWER LINDSAY on 10/18/2004 . Sworn and subscribed to before me this day of A.D, Prothonotary Complete jtems 1,2, and 3. Also complete item 4 if Restricted Delivery is desired, . Print your name and address on the reverse so that we can return the card to you, . Attach this card to the back of the maHpiece, or on the front if space permits, 1. Article Addressed 10: AS~e ,/ ) ...' /~~ ~,)' 2,'7,4 /.. DAgent ,., )' / )'" ,.. -', o. ", -::/ --I.' -. ."".'/,'.',: ~~Addr" e. S, Received by ( Pn'nted Name) I C. O'aie of Delivery Q-tj-(!:( D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No Mary Ann Haddad 131 Chris Drive Englewood, OH 45322-1146 3. pprvlce Type ~ Certified Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise D C.O.D. 4, Restricted Delivery? (Extra Fee) DYes 7003 2260 0000 8707 2716 o'j- Llej.1C, c.", --,-----.-.---------------- PS Form 3811, August 2001 Domestic Retum Receipt 102595-02-M-1540 In The Court of Con. .00 Pleas of Cumberland ( unty, Pennsylvania Melissa J. spencer (,il/. 'L);; r. J, c-. I tf ':',,)., I VS. Esther Goodhart et al SERVE: Gail Frey No. 04-4470 civil Now, Septanber 7, 2004 ,I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Franklin _ County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~0?/ /~. r ~~~4~ S'oeriffof Cumherland County, PA Now, ,J,o/;mj/'t/ ! 7 . Mfidavit of Service /'1/ ,../7 /1M dth , 20~, at /(1; v71 o'clockt1 . serve e If ' f!h'X.1'. &,<.-~ ff-vCLL- lIpon__.,.. ..~__ ._~~2-!G.,,?J=~--- atf/~~-. ~. J''f~ II} '., /~ by handing to ';u ,lJ i- Iv J Ii +~I 4~r within I)'"" j();, 8, Ui.-I,? .' . itl. . v 17;1.c/ and made knovm to J!vJ copy of the original ~'-'-Y' :Jr.A--'-"~- ;Z~ft.. L/ a the contents thereof. So answers, QlO<<.W{ ,1 p.~ : (lo, 1'1./f1i" Co ,t.1 .". . ."U. ~. - . 'J ." V; ..' , ' . 7. (~1(,vl::z3 ;1',:vC.l~A_~2- Sheriff of f-'/v),,;/;-<~.,'/v'// County^~ ." (/ V Sworn and subscribed before me this L day of~, 20 ,t(- () L<..,;-.- , , C VeL iCe .:-<-.0)< e '" ~'(\ I' I I _...._j COSTS SERVICE MILEAGE AFFIDAVIT f~-c---..__... ! C~!~j;I:~,~~~~~;~,:! /~;~~~:;:;:t:~:"~;J I !vi_~' r:~'Ji,:!"!:', C,.r" i $ $ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: FREY GAIL but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE 18th , 2004 , this office was in receipt of the On October attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge So answers ~- 6.00 .00 10.00 .00 .00 16.00 10/18/2004 SAIDIS SHUFF /. " ~':'e:;':~-"__ _._-."'-;;':-~""~...,~_:-.--" '-~::::-->"'-.--~;"- .....--;.;.;. -~-- ~~ ,'- - - ~-' ~- "- ~-.-,----..(.~-~,----_.::,.../ R. Thomas Kline { Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me this day of A.D. Prothonotary In Tbe Court OfeOl ,lon Pleas of Cumberland mnty, Pennsylvania Melissa J. Spencer VS. Esther Goodhart et al SERVE: Ettie Papoutsis ti.(J.;li\T Ft- No. 04-4470 civil Now, Sept611ber 7, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~,~ ~. r ....-.:~~--r ~.R Sheriff of Cumberland County,PA . Affidavit of Service Now, 5p~ ber Q\ ,2COlf ,atLI D o'clock PM. served the within (" ,"'pla.i(\--t QLl.:et 77 de upon ..~2~/e.._j:bp>t1.:tSi ',5..;--_.______ _~_ at hcJttlld^' CCWl1:)' St..e;;,~ Q('.;(./ce by handing to ~.r Et:};ie. ?QPO(At:s~ , a .tfv.e.. -tZ~sW copy of the original (' ~:/I 1:: {ji, ,'pt TtJt? I and made IalOvm to Aer the contents thereof. So ariswers, ~' 1ra. Rq.' , I.. ' ."~'~" U ~?fJ. ~fP_ . ~ I County. PA Sworn and subscribe . before methis C11 dayo' . ," 20 ()+ ""~JL~ p-.'~rO)Ld ,. I c' ( COSTS SERVICE MILEAGE AFFIDA V1T $ Ir~-;:i[";~~~:;, .. }.,:" ,-,.1:',',-, ,::;,.1::;:: r~,;r;",- . .1;-,,; !.....~----- - ~----- 3> SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: PAPOUTSIS ETTIE but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On October 18th , 2004 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 . .00 10.00 .00 .00 16.00 10/18/2004 SAIDIS SHUFF So a~lSwer~:_ ~. .... _<~-~S.;,--<:1.??~ -::--- R. Thomas Kline Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me this day of A.D. Prothonotary In The Court of Con wn Pleas of Cumberland ( unty, Pennsylvania Melissa J. Spencer VS. Esther Goodhart et al SERVE: Violet Epstein flY -,).2~ I p..:- No. 04-4470 civil Now, Septanber 7, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin . County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ..."",......r::y?' ~ r ...~~~~~~ Sheriff of Cum herland County ,P A . M:fidavit of Service Now, 7>30-0'-( , 20~, at I> 'f:) o'clock M. served the within .,- (-I4~t"-'----,) (:-1' '-' tJ'r( I upon , , _.,t!i ~~,ql.~_i:l-.~_~~(c',____._~_~ at '57 J'4f:.LC S; C r-' urZ-, o.f-Gc.. by handing to l'i<o, (L"",-A. <0' \l.-p '''iLl (~ (;.{)",,(\.,4c ,J, copy of the original a and made knovm to l-+ \. ^',- the contents thereof. ~'~' DA-: fl' . Vl:D' '~ So answers, ~ ~WwJ2 · Shenffof J' . '- Ff:>-4 t' k-L ( (J County, PA COSTS SERVICE MILEAGE AFFIDA VIT $ Sworn and subscribed qefore me this ;x, day o{ , 20 ~ /1., L&.(~<~f~- ,h ,.. _ N{ltar,;;I :;~'aI hil.;nllrdD.McC'.:'ilJ' My E:e'iC, -) i $ :_.:'.r'iT.~ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: EPSTEIN VIOLET but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On October 18th , 2004 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out.of County Surcharge 6.00 .00 10.00 .00 .00 16.00 10/18/2004 SAIDIS SHUFF So answe:r::_e~ ~__ _./'__ J ..~;;-~~;;~~::;:.:_/ R. Thomas Kline Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me this day of A.D. Prothonotary SHERIFF'S RETURN - PnGU1.AH CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT -QUIET TITLE was served upon CRESSLER THOMAS the DEFENDANT at 1908:00 HOURS, on the 9th day of September, 2004 at 1 ANTLER COURT SHIPPENSBURG, PA 17257 by handing to NANCY CRESSLER, WIFE a true and attested copy of COMPLAINT -QUIET TITLE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 11.10 .00 10.00 .00 27.10 R. Thomas Kline 10/18/2004 SAIDIS SHUFF FLOWER LINDSAY Sworn and Subscribed to before By: '~ . J I i'l.-- {/V--.. '<I ~uty Sheriff me this day of A.D. Prothonotary In Tbe Court of Con iOn Pleas of Cumberland ( ,unty, Pennsylvania Melissa J. Spencer VS. Esther Goodhart et al SERVE: Karen Mohn {-fl- ;)):'; c. /.--<- No. 04-4470 civil Now, SeptEl11ber 7, 2004. , I, SfIERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin _ County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~r;.~~~R Sberiff of Cumberland County,P A . Mfidavit of Service Now, St:' PI /'l , 20~, at 1 f V 0 o'c1ockf M. served the within COv'l\. pLA,rt-rr I"U 00'l{'f TlTU:: . 1Jpon____K~~~lo.l_f:1J)f.;~___ at l~~ U ,1.-1 CC'>LvJ iL I A'? f' IIf1 I ' \' A l" r- r1t1rvVJF.fg{j,~' , f li , by handing to a "Iic.JJE /J,'iTe ~~ and made known to H IZ-.R- copy of the original C (1Y"\ P ( Ii I .~ the contents thereof. So answers, Sworn and SUbSCrjbe~~ me this --.L2 day of, . . ,20 t if ,/l II l - . ___ lLR tJjctZk. ~ ;1')0 ~'7 . . / -- ~ Oh.2Jf ~ t "Y1 1-1 ~"V" ~ I . , r- (j COSTS SERVICE MILEAGE AFFIDAV1T ~. l<'v"--- ..' -A'. ",', . County PA \/ll'I,vN-/lV ' '/" I' . PA. u9-w--.u. . ("1, : Ct1,~H~ $ $ , L...-...._____._.._.~._____..._.__.___~_,._._.,_ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: MOHN KAREN but was unable to locate Her in his bailiv.fick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE 18th , 2004 , this office was in receipt of the On October attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge So answeJ:'~ -, 6,00 .00 10.00 .00 .00 16.00 10/18/2004 SAIDIS SHUFF FLOWER LINDSAY Sworn and subscribed to before me this day of A.D. Prothonotary In The Court of Com. _on Pleas of Cumberland ( unty, Pennsylvania Melissa J. Spencer VS. Esther Goodhart et al SERVE: Margaret Seavers [ tf- ,~d ?} I Fe- No. 04-4470 civil Now, Septanber 7, 2004 , I, SfIERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~r:V /.67. r "~~~..r ~~ SheriffofCwnberland County, PA . Affidavit of Service Now, '1- ttf-O'-( ,20_, atDefr.... o'clock P M. served the within ntlft'lo/-tn\'_ \ SGh'(Y f C-v vNP'ur ( e'l npon '___ m Pr-r...ct~\ s;: I;: 4f"iv'LS . ,.."._-----.-_.~,_.,._----.__.-"-.,),-~- --_..---.,....._-.-_._.~.. ....------.-----..----, at l.{ (I;) <'_u r- ~ t-' f) {1.. . s: I h; G ;'//} by handing to s; i~\,,- ~.a:~t-- . copy of the original //. <',...:L -leUI, L:rJ~.'~.~ the contents thereof. a and made known to ~ So answers, ~,. PA-" (). d.~:~UI ::n,' . V".1~~~' . 1-1,1"" i:W"I\',J;) ~l u County. PA Sworn and subscribed \1efore me thi~ J.::L day of 11....{ IY , 0 t <! , J, . .-'~ r- tr- U,cI'0L.^--. /" t f ct., " ~'1 / .. \ COSTS SERVICE MILEAGE AFFIDA v1T $ r--:~!'h~;;~S~;-._,------ 1M,. C"". '--__~__,_ Lj" 3> SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: SEAVERS MARGARET but was unable to locate Her lTI his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On October 18th , 2004 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 10/18/2004 SAIDIS SHUFF So answe~~",;,. ~_ .- - .-'--_.- ~~~::::.------ -" _.~-- -- - ~~ " ~;;- --L R. Thomas Kline Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me this day of A.D. Prothonotary In The Court of COlL....lOn Pleas of Cumberland I.... Junty, Pennsylvania Melissa J. Spencer VS. Esther Goodhart et al SERVE: Dorothy Cressler (11.(_ ;; ,).';} r .. _ f'- 04-4470 civil No. Now, September 7, 2004 , I, SfIERlFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~r:?/ /~' r ...~~~~~...;> Sheriff of Cum her land County, FA Affidavit of Service Now, / 'f Sf\f\ , 20d, at JI:1J o'clock A- M. served the Co.,.,.,,{lL..;:} {~ within upon --DtV?~1Y,tC.Khc~-Hf':""-__c ..____._~____n__________ n~_____ at ~ - VY1. <0 ,:,\:c:..c'-...-.r""i J~/(L SH~ .~. f 4- 11 'L')7 by handing to SI-JvvJ ~ I~I ~t- copy of the original en,zr r:1- JiZf.L a and made known to 1uJ,.) the contents thereof So answers, .~~ l-;{ pr+ ',n .. G 1'1T~'-. ~. I.,.. t W.~p=O . ~h . r '-' en_ V , {! 0~J ((UtI/ County, P A swornandSUbSCribe~!:;~ me thi~~ day of _ ,20,f/ <f Jz UC~-'L' t~ ~ Ii ~' ! - COSTS SERVICE MILEAGE AFFIDA VTT $ Ui,~:~;g,,;;~'~~;~!).;;---::~.--l . LIV'-Wlji!l!'C""'. _. . u"'''r --'-'-"-"- 3> SHERIFF'S RETURN - OUT OF COlWTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: CRESSLER DOROTHY but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On October 18th , 2004 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 10/18/2004 SAIDIS SHUFF So answers...:._ .. ~.;.-~~: /~~,.-:---~:~-~~~--~ R'. Th~mas Klin;" '----.. . Sheriff of Cumberland County ::::> FLOWER LINDSAY Sworn and subscribed to before me this day of A.D. Prothonotary In The Court of Cor" Jon Pleas of Cumberland ( . mnty, Pennsylvania Melissa J. Spencer ;....~,'I .. r ~ G it - c"c"'- 3>' F- L- VS. Esther Goodhart et al SERVE: Jane Seibert No. 04-4470 civil Now, SeptEmber 7, 2004. , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~r:?/.!' p;~ r ...'P.~~~~R Sheriff of Cumberland County, PA . A(fidavit of Service Now, IS" stopte.r>\he>r , 200"f, at~SS o'clockfr M. served the within CwMf/al'nt 6{. Qu',-et TIHp, upon . _. .J9.n.e1:__ 51ebec:t::'.. ......._. __.____._ ... ____.__. _ __ ..._.__'__._ at .-F{~ 5(7 Frall'r:l;;,' (6 S'Ael"r* . ~[ce.. byhandingto To.r.et 2;iphprT a tr-v.e 4 oJie.sted and made known to her copy of the original U'7'hiJlT: the contents thereof. So answers, ~~1" fOA'" .. \ e r ~ ~ f)... _, ,;; " L Ji ~'U I'C"""'-'~' ~6t!~<<L- .. , Sheriff of County, P A Sworn and subscribed before (me this I ~ dayof ~r , 20 1t'1- {l t.QUZ-L~ d'n ~&t~ . . /1, .1 COSTS SERVICE $ MILEAGE AFFIDA \i1T r Ri'i,:,,~;;~:.~i:'S%:~--- $ I .~"".:"cc""'. N'/CU"-:.:l..Cc'an L-..._.____ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: SEIBERT JANE but was unable to locate Her lTI his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE 18th , 2004 , this office was in receipt of the On October attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge So answers: ~)'---':/ .~:---- _--:Z< - _.".'*E------;:-'--- ._; ~ / 6.00 .00 10.00 .00 .00 16.00 10/18/2004 SAIDIS SHUFF /' . R. Thomas Kline Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me this day of A.D. prothonotary SHERIFF'S RETURN - REGULAR CASE NO: 2004~04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL BRYAN WARD Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duljr sworn according to law, says, the within COMPLAINT -QUIET TITLE was served upon SEIBERT BETTY JEAN the DEFENDANT , at 2113:00 HOURS, on the 9t'1. day of September, 2004 at 10 HEDGEROW LANE CARLISLE, PA 17013 by handing to BETTY SEIBERT a true and attested copy of COMPLAINT -QUIET TITLE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 3.70 .00 10.00 .00 19.70 ._.-.;!~':l""oI ~!''' R. Thomas Kline . ..,....'_/-~,:. '.!,.,~ .<,"/". ":.~~.__-A{!:.::"'~.Io-;# 10/18/2004 SAIDIS SHUFF FLOWER LINDSAY Sworn and Subscribed to before By: /~~ IAJ~ J De];! ty Sheriff me this day of A.D. Prothonotary In The Court of Corron Pleas of Cumberland ( unty, Pennsylvania Melissa J. Spencer SERVE: VS. Esther Goodhart et al Nancy Thcrnpson ~ C'i.);rj I (c.- No. 04-4470 civil }Jovv, September 7, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin . County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~r;t/ , ~ r "'~~~4~~ Sheriff of Cumberland County, PA Affidavit of Service . }Jaw, / ij .~ ~ Gf''l--,~~~f nrnnAc,lrj1Z~li'F~___ _.___ at J-1 ,/)lm-:lj~1-~yA~H-/ <)~~/}kl~ ~u))/c; by handing to -5 ~ "-- . ~I tu&.?-- , 20coY', at &Yj" o'clock/! M. served the within l? A~"/ a copy of the original 'i -, j~' errv'1'.. ~' l'<-"--ce.. U and made known to J~ the contents thereof So answers, ~V'1J.Pt1~. &.4~'. o ~0. -... ~.. ,,' . . /. . . /f .... '/ . c . , . .... ,,' . ) , ",' u' 7:3 h, a / / Sheri of flt"oN/Jft::,,' . Vi coun';[';A -:; l./ Sworn and subscribed efore mJ~this ft,day of/ .7f.- ,20 t..f- L- f'y(,~ _ UL-<<..",,- .<--/-. ih . <<'. tU.~ / - . ' COSTS SERV1CE $ MILEAGE AFFIDA V[T !-"d,='5E~~~::, -... 3> I Ct'a!1lbe~r;t:li"',' hT:.'Co!1;'J'U',Z;n ---'---"-'-- SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: THOMPSON NANCY bu~ was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On October 18th , 2004 , this office wa.s in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 10/18/2004 SAIDIS SHUFF So answer~: . ,P;-::;Oj~:~.>';;;': < .. ____ R: Thomas Kl ine L.... Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me this day of A.D. Prothonotary SHERIFF'S RETURN - REGULAR CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL CPL. MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT -QUIET TITLE waf; served upon DEUTSCH JOHN C the DEFENDANT , at 1615: 00 HOURS, on the 30th day of September, 2004 at 7 WEST MAIN STREET NEWBURG, PA 17240 by handing to JOHN C DEUTSCH a true and attested copy of COMPLAINT -QUIET TITLE together with and at the same time directing His attention:o the contents thereof. sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 15.54 .00 10.00 ,00 31.54 l' /~. ~(/)# ~"/ . .r d~'"??~~<:' ../~~..A-" R. Thomas Kline . day of 12/01/2004 SAIDIS. SHUFF FLOWER LINDSAY BY~~~(?_~ ~ Deputy Sheriff '\ Sworn and Subscribed to before me this A.D, Prothonotary .:.: SHERIFF'S RETURN - U. S. C!<:Kl'Hl!<:LJ JVlA1L CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SPENCER MELISSA J VS. GOODHART ESTHER ET AL R, Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,DEUTSCH JOHN C by United States Certified Mail postage prepaid, on the 7th day of September,2004 at 0000:00 HOURSr at 12420 CONDE DRIVE BROOKVILLE, FL 34613 , a true ~ , and attested copy of the attached COMPLAINT -QUIET TITLE Together with The returned receipt card was signed by 00/00/0000 on Additional Comments: CERTIFIED MAIL FOR JOHN DEUTSCH WAS RETURNED SHOWING A FORWARDING ADDRESS OF PO BOX 165 NEWBURG, PA 17240. Additional Comments Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 4.88 .00 10.00 .00 20.88 So answers: .C' -~:~~~:~~:~ R." Thoma:s Kline Sheriff of Cumberland County Paid by SAIDIS SHUFF FLOWER LINDSAY on 10/18/2004 . Sworn and subscribed to before me this day of A.D. Prothonotary \>\ $:' <I' .'. I,) +' ~'l:)..\ i).1:~ ,. ,.;- , ,.'V. " ""'1:", ,\~.,.~ V::~ - .-1"::' ZiJ~O:: <IIOe"," ~lJl-rZ~ ~otn'p-;; )))..: ~~'~ '" ,. ~ -\ :0 ~\.rl ~:... ~, ~ ~; e" f1\'~ :0 n,l. '-..~'~ -z.;: 1)...... J' -'\ ~ ',,'\ o 0 {jl ~. ~ \)1 <. C f1\ JJ ~ - -- - "- ~:, :::;. ;::. :;... - - ::-. :;:..." ~ "-' c::- :;...~ ::-.> "- ";- ';;-" (') (') 00 92 :,C: -"... _.~ ii, on ...t. ... a; 0 G "c: 0 """'O;:1.~." CJ~ ';;! () " g "'" c: (.'> (/l ~ ~ ...0::......... >- -;.z w ,... to \~..@ ~ g; \~ III It r" .~ co 11II.1::. -.l :... ,0 0 ... . '" ..,'- \P ,,; g- o it> ~ ,*O() 0<:. (')' :0- Cl roo~ " ~ C "[1-... r(1)'{!, CJ>Cl:::r .;:..~. ",0<: ...(1) CJ> :;-~ z,;; "". (j~~ \~f ",., Z Ci ::~ J.; "' 1'\l ~ -..I ~ CI ~ -" r-~~" SH~RIFF'S RETURN - REGULAR CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT -QUIET TITLE was served upon DEUTSCH DON the DEFENDANT , at 1920:00 HOURS, on the 9th day of September, 2004 at 49 MAPLE AVENUE WALNUT BOTTOM, PA 17266 by handing to JANET DEUTSCH, WIFE a true and attested copy of COMPLAINT -QUIET TITLE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 10.36 .00 10.00 , .00 26.36 ..," Ad~'~:'2i;::_~? ~ i;.o" R. Thomas Kline 10/18/2004 SAIDIS SHUFF FLOWER LINDSAY Sworn and Subscribed to before By: ;~_ tJ~~ J Dep ty Sheriff me this day of A.D. Prothonotary ;::",Ht=Hirr w Ur-rlL.Jt:: 50 NORTH DUr~E STREET, f-.v. 80)( 83480, LAhICASTEF.. PEI\JNSYLVANIJl, 176u,- ..A80 . (717) 299-8200 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN PLEASE TYPE DO !~OT DETACH ANY COPIES. 2 C'O~'::4N4"mlE~ivil , T'tfj'6t~CI!"Ta\,j~ee!~'t!'iint to Quiet Title , PLAINTIFF/SI Melissa J. Spencer 3 DEFENDANT/s/Esther Goodhart et al SERVE {5 NAME OF INDIVIDUAl. COMPANY, CORPORATION, ETe.. TO BE SERVED ~ Charles A. Deutsch ...".. 6 ADDRESS (Street or RFD, Apartment No City, Bore. Twp, Stale and ZIP Code) AT 732 W. Brubaker valley Road Lititz, FA 17543 7 INDICATE UNUSUAL SERVICE ~ DEPUTIZE 0 OTHER Cunberland Now, --5U1 20 ~ , I, SHERIFF OF . COUNTY, PA., do her.~by !;ieputlle the S~e9ft~1 T ;:mr;::jl~t-pr County to execute this Writ,~tld:'1Tl?k._e{eturl"'! thexeof}iCeprOrng to law. This deputation being made at the request and risk of the plaintiff.~' " ..".,.< --..., - SHERIFf Of- COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: Cumberland CUMBERLAND CO. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff ,evying upon or allaching allY property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notitying person of levy or attachment. without liability on the part at such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereol 9. SIGNATURE of ATTORNEY or other ORIGINATOR 10. TELEPHONE NUMBER 111' DATE ES D. FLOWER ES . 717-.243-6222 9/3/04 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be compl.~ted if notice is to be mailed). SAIDIS, SHUFF, FLOWER & LINDSAY 26 WEST HIGH ST. CARLISLE, FA. 17013 SPACE BELOW FOR USE OF SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE NAME of Authorized LeSO Depu:e,or Clerk 14 Date Received 15 131 aCknowledge receipt 01 the writ. I ANNETI'E WALTO" 717 295 3 09 JM occompla"la"od,caledabo" r '", - - 9/8/04 16. I hereby CERTIFY and RETURN that have personally served, 0 have legal eVidence of servIce as shown In 'Remarks'. 0 have executed as shown In "Remarks", the writ or complaint de nbed on the individual company corporation etc at the address shown above or on the individual company cor- poration, etc.. at the address Inserted tielow by handing a TRUE and ATTESTED COPY thereol Expiration/Hearing dattri 10/4/04 0 o :>': 8 17 0 I hereby certify and return a NOT FOUND because I am unable to locale the individual, company corporation, etc., named above. (See remarks below) d 18 Name and title 01 individual served (if no! shown above) (Relationship to Defendant) t9. ONoService ~ See Remarks Below (No. 301 (J) 20. Address of where served (complete only if differenl than shown above) (Slreet orRFD,ApartmentNo ,Cily, Bora. Twp State and Zip Codel 12 Qeb:J 23 ATTEMPTS 21 Dale 01 Service 22 Time '" S,T.A. '1-2'(-6'-1 - PM IZ6-rn-; Dep.lnt. 24 30 "5ervecL Oel: t::11- Co,r/"ecf- Y931? 31 "3's-,., 34 da t 37 Y~<<J2, MY COMMISSION EXPIRES 1 WHITE - i!:;sumg Authoril\' 2. PINK _ Attomey 3. CANARY - Sheriff's Office <1 BLUE - Sheriff's Office SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline . Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: DEUTSCH CHARLES A but was unable to locate Him lD his bailiwick. He therefore deputized the sheriff of LANCASTER County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On October 18th , 2004 , this office was in receipt of the attached return from LANCASTER Sheriff's Costs: Docketing Out of County Surcharge Dep Lancaster Co 6.00 9,00 10.00 54.50 .00 79.50 10/18/2004 SAIDIS SHUFF So answe:r:s-"" j ~... _ ___ ,..,-.;:;.c::--;-.:;:~::----=-- /,;;K~ ~~/ ~-- ...c::.~~--- -" .....- "--;:,,--,,,:__ 'L_- /-' R. Thomas Kline Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me this day of A.D. Prothonotary SHERIFF'S RETURN - REGULAR CASE NO: 20D4-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT -QUIET TITLE was served upon DEUTSCH JESSE the DEFENDANT , at 1551:00 HOURS, on the 15th day of September, 2004 at 313 PINE ROAD MT HOLLY SPRINGS, PA 17065 by handing to JESSE DEUTSCH a true and attested copy of COMPLAINT -QUIET TITLE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 4.44 .00 10.00 .00 20.44 ::;? R. Thomas Kline day of 10/18/2004 ,^mm 'HDee FLOWER UND,^Y~ BY:~~~~ - Deputy S riff Sworn and Subscribed to before me this A.D. Prothonotary In The Court of Corron Pleas of Cumberland (' unty, Pennsylvania Melissa J. Spencer VS. Esther Goodhart et al SERVE: Jesse Lee Deutsch ty.;p:5 i- . ? C-. , No. 04-4470 civil Now, September 7, 2004 , I, SHERIFF OF CUJI1BERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin . County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~r;'/ /#' r ;"~~<I"~~~J Sheriff of Cumberland County, PA . Affidavit of Service Now, c!! I! " 4- ,20 I!'tf, at I), :':S o'clockfl. M. served the within {"',UP (j'U'&i Ti rLE upon /jeArtf.;c/2 DIO.;;T5t'.fi ~"-t'PMC7"''f''''''- ,,/, ,le';;,E Lee ilEa"'''''''') _ __.,c_.._._____,____..___u___.__..c. ',____ __, _, _...._____:-____ ..._--:"_._(_.~.~___. _____ .___n __....______.______nm ..__,__"...._.__.__,"" _.__,..__... _.. .._,_____________.,_ -------...__._. /~' L.4~~ (;:~.4!..[ ,1,(."..::~ by handing to /JE A rH"":C 1t?LT4 c:,.( ,- . (SEE ,4a <L c/, PII 17i-<Jt' S~/,u) at .if ~5- rt2I'>"""- '- , ooJ FA a.;v( 0I.,q .v E a 7/Z C/ i3 I If /'TE-JI , copy ofthe original [&1)-1 P cr u { t!'cT r I t'l~<j: and made known to ;kp- the contents thereof . ~ :c'O PA-.' . rr~ "1 ~ - n I' ~.. U trc~ So answers, -~z~.. '" _~. .~. ,,- of ~^~ Ki <k"-o/. eA ~1",'~ l I ~"Jt..., L~ , - Sworn and subscribedJbt(fore me this ~ day of /Mer*- ,20M t-. ,/~~ (tU1A_ 'L ~, 'U-Le, 'f ./.. ' COSTS SERVICE MILEAGE AFFIDAVIT $ ! ;-'!(;>"~;',', ) r,-id.:'rC:D. f.,j,--:::""r; I Ci,.c:J,j ::'!C~SL"~;-t . , I 1,,'ly Ci)~:.',T11;~;~,< 1;1 , L"___~_~~,._._ $ FRANKLIN COUNTY SHERIFF'S OFFICE 157 LINCOLN WAY EAST CHAMBERSBURG, PA. 17201 Chief Deputy John E. Strine Solicitor David C. Cleaver SHERIFF Robert B. Wollyung Day: (717) 261.3877 Night: (717) 263.1611 Hearing Impaired: (717) 264-8474 Fax: (717) 267-3493 ACCEPTENCE. . OF. SERVICE r accept service of the C1,~1/4n;t (,...,( 1/-.-4't-hll.:- on behalf of CD (I (SiL U-<: b"'.0J-J>-, , and certify that r am authorized. to do so. +- j i? dttw {, 0- -]) CACti. cl, Defel.ldant or Authorized Agent 3SL[ii c1 .0 rrcltn i..<.;') I(C6,L Address o 'Tdt\~,,, , (1 11:;.'1'1 I Q- <-I~[) 'I Date i SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: DEUTSCH JESSE LEE but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On October 18th , 2004 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge So answers: 6.00 .00 10.00 .00 .00 16.00 10/18/2004 SAIDIS SHUFF ~.-- - . _,;_,~~~~~~~,,--~2~::~~::';"-~- R. Thomas Kline Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me this day of A.D. Prothonotary SHERIFF'S RETURN - REGU1AX CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL CPL. MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT ~QUIET TITLE was served upon MEMORIAL LUTHRAN CHURCH the DEFENDANT at 1419:00 HOURS, on the 30th day of September, 2004 at 34 EAST ORANGE STREET SHIPPENSBURG, PA 17257 by handing to RELDA STOOPS, SECRETARY, ADULT IN CHARGE a true and attested copy of COMPLAINT -QUIET TITLE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 14,80 .00 10.00 .00 30.80 -=r;;;:'~'.t.,~/{~~.~~, ..,. __ '~'-__'~' ;:"1l;-i_:::;-..!;.>~:_ 1 ,.' ~.,. ..i R. Thomas Kline day of 10/18/2004 SAIDIS SHUFF FLOWER LINDSAY BY:-zd~~ A-i2 Deputy'She~ff Sworn and Subscribed to before me this A.D. Prothonotary In The Court of Comlhlm Pleas of Cumberland C. ..mty, Pennsylvania Melissa J. Spencer VS. Esther Goodhart et al SERVE: Ray G. Leutsch - ~ 1u:~ M-);J..~' 04-4470 civil No. Now, October 18, 2004 , I, SfIERIFF OF CU1vlBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~9L:.~~-<./~~ Sheriff of Cumherland County, P A Affidavit of Service Now, flha 1 S,\- , 20 t/( , at f t/ : 3::> 0' clock r? M. served the within (r) '-;'if n r I ; r ~ (1+ \ f b-erA\5 c+\ k 0 upon \eI (,., \ ~ at 1Si L Inr~(n (~7Clcl roc,1 (I[1(H'.' bp,s //)11'" n PA I 17.f)o I . by handing to 'V.rA'v1 r,-, '\leG {.C:;C'/, \ a -'"-'(- uc:. -~ ~':Y:_,,""-SJ.c\ copy of the original r(?h/) -;0 I ()I f1 t I the contents thereof. and made known to~" ~. --r~ '0\~ \\ \ So answers, C-C tv (l(, ,{ H4' - (p ~. o-t YiLAIvi<:L' ^'.. ) . -\y~,r^ n Cr~'tl~1J Sheriff of , , [)-pr ~~ ' M.{'11- t County, p~_ Sworn f ,ub"ribo' bofo" me this.- day O~D 0 , 20~_ . ,(,l ...- /( elL (c L., ~e..S( _____ ,J COSTS SERVICE MILEAGE AFFIDAVIT $ f U.--- Not:1rial ::>eal Ri, 'md D ~1cC~1V, Notary Public Ch..l"nblll'g BQfO, hiUlkhr~ Counry ~y "lJli::(:_~"pjres Jan. 29,2007 $ ?,. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: DEUTSCH RAY G but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On December 1st, 2004 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out or County Surcharge Dep Franklin Co So answers: 6.00 . 9.00 10.00 38.40 ,00 63.40 12/01/2004 SAIDIS SHUFF .~.._) ---" ",- J, -:.--: <~>",____::-,_, . --;-:..Y',;::;;::;;f;~ . ._~':-.6;;:.-~ R. 'Thomas Kline Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me this day or A.D. Prothonotary SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: DEUTSCH RAY G but was unable to locate 7,. ~ D.Lfi In his bailiiiV'ick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE 18th , 2004 , this office was in receipt of the On October attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 10/18/2004 SAIDIS SHUFF So answex:.s,_ . /_ /!"" """,_:),~,-:;:;C'~~:..>-~_;:::<;:;;::~::>=-~.,,~~--~ .___,~~"''C-/,r:;;:~.f';''-- /~(::~.:--?- R'. Thomas Kline Sheriff of Cumberland County FLOWER LINDSAY Sworn and subscribed to before me this day of A.D. Prothonotary In Tbe Court of Con iOn Pleas of Cumberland (' unty, Pennsylvania Melissa J. Spencer VS. Esther Goodhart et al SERVE: Ray G. Deutsch ^/ s r- ,:SF l].)./ li-l) l[j_~4')Sl v I ,. - I>v No. 04-4470 civil Now, SeptEmber 7, 2004 , I, SHERIFF OF CUlvlBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin _ County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. . ~r:V/ /~. r ""'~~~f"~.R Sheriff of Cum herland County. P A Given address is Cumberland County. . M:fidavit of Service Now, ,20_, at__ o'clock M. served the within upon __ at by handing to a copy ofthe original and made knovm to the contents thereof. So ariswers, .fi~.v0P 7f.,~~ . . (/'c:/ Sheriff of r,<'_k "--",,,. County, PA Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDA \lIT $ $ SHERIFF'S RETU~~ - NOT FOUND CASE NO: 2004-04470 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SPENCER MELISSA J VS GOODHART ESTHER ET AL R, Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and lnqulry for the within named DEFENDANT DEUTSCH RAY G but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT -QUIET TITLE , NOT FOUND , as to the within named DEFENDANT , DEUTSCH RAY G 329 B SPRINGVILLE ROAD SHIPPENSBURG, PA 17257 DEFENDANT NOT LOCATED AT 329 SPRINGVILLE RD NEW ADDRESS IS 307 MEANS HOLLOW RD SHIPPENSBURG - FRANKLIN COUNTY Sheriff's Costs: Docketing Service Not Found Surcharge 6.00 14.80 5.00 10.00 .00 35.80 So answerEjy .... . .. ?5~:;;::::C=-L:=-::~'" R. Thomas Kline Sheriff of Cumberland County SAIDIS SHUFF FLOWER LINDSAY 12/01/2004 Sworn and subscribed to before me this day of A.D. Prothonotary MELISSA J. SPENCER, Plaintiff, vs. ESTHER GOODHART, SALLY L. BERKLlTE, JANE BITNER, MARY ANN HADDAD, GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER. JANET SEIBERT, BETTY. JEAN SEIBERT, NANCY THOMPSON, . JOHN C. DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. . IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA . CIVIL ACTION- LAW . NO. 04-4470 CIVIL . ACTION TO QUIET TITLE IMPORTANT NOTICE TO SALLY BERKLlTE, Defendant 13838 Villa View Drive Waynesboro, PA 17268 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A )RNEY5'AT'LAW 'N. High Street ;arlisJe, PA FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. SAIDIS JFF, FLOWER LINDSAY TORNEYS'AT-LAW W. High StrEet Carlisle, PA YOU SHOULD TAKE THIS NOTICE TO A I_AWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS },T A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATE 02/17/05 SAlOIS, SHUFf', FLOWER & LINDSAY Attorney for the Plaintiff . ~ (j)) ~x--- James D. Flower, Jr, V 1.0. #27742 26 West High Street Carlisle, PA 17013 (717) 243-6222 Iv1ELlSSA J. SPENCER, Plaintiff, . IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA vs. . CIVIL ACTION - LAW ESTHER GOODHART, SAllY L, . NO. 04-44;'0 CIVil BERKLlTE, JAI\jE BITNER, MARY ANN HADDAD, . ACTION TO QUIET TITLE GAil FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY . JEAN SEIBERT, NANCY THOMPSON, . JOHN C. DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. IMPORTANT NOTICE TO JANE BITNER, Defendant 1314 Pine Run Road Abbottstown, PA 17301 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING SAIDlS ~r1J~~~~R WITH THE COURT YOUR DEFESES OR OBJECTIONS TO THE CLAIMS SET TORNEYS"AT"LAW iW. HighStreel Carlisle, PA FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS SAID IS JFF, FLOWER , LINDSAY TORNEYS"AT-LAW ,w. High Street Carlisle, PA YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO '~OT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PI', 17013 (717) 249-3166 DATE 02/17/05 SAlOIS, SHUFf:, FLOWER & LINDSAY Attorney for the Plaintiff By ?/J fJ) ~~ ames D, Flower, Jr. 10. #27742 26 West High Street Carlisle, PI', 17013 (717) 243-6222 ! iI~ELlSSA J SPEI'>JCER, Plaintiff, . IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COU"ny, PENNSYLVANIA vs. : CIVIL ACTION - LAW ESTHER GOODHART, SALLY L : NO. 04-44'70 CIVIL BERKLlTE, JANE BITNER, MARY ANN HADDAD, . ACTION TO QUIET TITLE GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY. JEAN SEIBERT, NANCY THOMPSON, : JOHN C. DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A. DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. IMPORTANT NOTICE TO. DOROTHY CRESSLER, Defendant 26 Montgomery Avenue Shippensburg, Pennsylvania 17257 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING SAIDIS ~ilN~~~iR WITH THE COURT YOUR DEFESES OR OBJECTIONS TO THE CLAIMS SET TORNEYSoAToLAW iW. High Street Carlisle, PA FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARII'>JG AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. SAIDIS IFF, FLOWER LINDSAY ORNEYSoAPLAW W, High Street ~arJisle, PA I' I Ii I I I I YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWVER OR CANNOT AFFORD OI~E, GO TO OR TELEPHOhiE THE OFFICE SET FORTH BELOW THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRlt\JG A L.II.WYER. IF YOU CANNOT AFFORD TO HIRE p, LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATE 02/17/05 SAlOIS, SHUFF, FLOWER & LINDSAY Attorney for the Plaintiff , \ -.," By \ U--( 6) cJ-l~- James D. Flower, Jr. V l 1.0. #27742 26 West High Street Carlisle, PA 17013 (717) 243-6222 MELISSA J. SPENCER, Plaintiff . IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA vs . CIVIL ACTION - LAW ESTHER GOODHART, SALLY L BERKLlTE, JANE BITNER, MARY ANN HADDAD, GAIL FREY, ETTIE PAPOUTSIS, VIOL.L\, EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY. JEAN SEIBERT, NANCY THOMPSON, . JOHN C. DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A DEUTSCH. JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. . NO. 04-4470 CIVIL . ACTION TO OUIET TITLE IMPORTANT NOTICE TO THOMAS CRESSLER, Defendant One Antler Court Shippensburg, Pennsylvania 17257 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A roRNEYSoAT'LAW W. High Street Carlisle, PA FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. SAIDIS JFF, FLO'WER . LINDSAY TORNEYSaAToLAW W. High Street Carlisle, PA /: YOU SHOULD TAf(E THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAW'{ER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LA\t\lYER THIS OFFICE M,LI,\' BE ABLE TO PROVIDE YOU WITH INFORMATION .ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS In A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATE 02/17/05 SAIDIS, SHUFF, FLOWER & LINDSAY Attorney for the Plaintiff I ~ By \ ~/{~ 6}- r;, ~j Jarnes . Flower, Jr. v , LD, #27742 V 26 West High Street Carlisle, PA 17013 (717) 243-6222 II!1ELlSSA J. SPENCER. Plaintiff, . IN THE COURT OF COII!1fv10N PLEAS OF . CUMBERLAND COUNTY, PENNSYLVAI\JIA vs. . CIVIL ACTION - LAW ESTHER GOODHART, SALLY L. . NO. 04-4470 CIVIL BERKLlTE, JANE BITNER MARY ANN HADDAD, . ACTION TO OUIET TITLE GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER f/J\REN fvlOHN, MARGARET SEAVERS, DOROTHY CRESSLER. JANET SEIBERT. BETTY. JEAN SEIBERT, NANCY THOMPSON, . JOHN C DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. IMPORTANT NOTICE TO DON DEUTSCH, Defendant 49 Maple Avenue Walnut Bottom, Pennsylvania 17266 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING SAIDIS lUFF, FLOWER WITH THE COURT YOUR DEFESES OR OBJECTIONS TO THE CLAIMS SET & LINDSAY .ITORNEYSoAYoLAW :6 W. High Streel Carlisle, PA FORTH AGAINST YOU. UNLESS YOU ACT WITf-'IN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE EI\JTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. SAIDIS 'lUFF, FLOWER & LINDSAY A'ITORNEYS'AT.LAt.\' 26 W. High StTl.'ct Carlisle, PA YOU SHOULD TAKE THIS NOTICE TO A LP,Wl'ER AT OI\ICE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING ,Ie, L,Ie,WYER IF YOU CANNOT AFFORD TO HIRE A UWliYER, THIS OFFICE lvlA Y BE ABLE TO PROVIDE YOU WITH INFORMATION ,"-BOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Stree., Carlisle. PA 17013 (717) 249-3166 DATE: 02/17/05 SAlOIS, SHUF'F, FLOWER & LINDSAY Attorney for the Plaintiff C\l r. ~~~- By \ J.,1A.-'"vC Q) \. . '-':\ , I James cJ.FIc1wer, Jr. \J V LD #27742 26 West High Street Carlisle, PA 17013 (717) :!43-6222 SAlDIS tUFF, FLOWER & LINDSAY 'l.TfORNEYSoAToLAW 2.6 W. High Street Carlis]!'., PA MELISSA J SPENCER, Plaintiff, . IN THE COUR.T OF COIv1MON PLEAS OF . CUMBERLAND COUNTY, PENlo,JSYLVANIA vs. . CIVIL ACTION - LAW ESTHER GOODHART, SALLY L . NO. 04-4470 CIVIL BERKLlTE, JANE BITNER MARY ANN HADDAD, . ACTION TO QUIET TITLE GAIL FREY ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY. JEAN SEIBERT, NANCY THOMPSON, . JOHN C DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A DEUTSCH. JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants IMPORTANT NOTICE TO JESSE DEUTSCH, Defendant 313 Pine Road Carlisle, Pennsylvania 17D65 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY A HORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFESES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) D/'.YS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. SAIDIS UFF, FLOWER It LINDSAY ITORNEY~.AT'L^\N 5 W. Rigll Street Carlisle, PA YOU SHOULD TAKE THIS hJOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD OI\)E, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATE 02/17/05 SAlOIS, SHUFF, FLOWER & LINDSAY Attorney for th,= Plaintiff " Bi'. , ' ,lj--f 0) ri~\ Jarnes o. Flower, Jr. \J 1.0. #2'7742 V' 26 West High Street Carlisle, PA 17013 (717) 2~43-6222 SAlDIS 'lUFF, FLOWER & LINDSAY ATJ'ORNEYSoAPLA'W 26W. HighStrec\ Carlisle, PA Iv1ELlSSfI, J. SPENCER, Plaintiff, . IN THE COUFn OF C0fv1fv10t\! PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA . CIVIL ACTIOI\! - LAW vs. . NO. 04-4470 CIVIL ESTHER GOODHART, SALLY L. BERKLlTE, JANE BITNER, MARY ANN HADDAD, GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREl\) 1v10HN, MARGARET SEfI,VERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY. JEAN SEIBERT, NANCY THOMPSON, . JOHN C. DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the Iv1EMORIAL LUTHERAN CHURCH, Defendants. . ACTION TO QUIET TITLE IMPORTANT NOTICE TO. JESSE LEE DEUTSCH, Defendant cia Heather O. Deutsch 3541 Orrstown Road Orrstown, Pennsylvania 17244 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE iN WRITING WITH THE COURT YOUR DEFESES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS SAIDIS JFF, FLOWER LINDSAY 'ORNEYS-AT-LAW W. HighStreel Carlisle, PA YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD m~E, GO TO OR TELEPHOI'-JE THE OFFICE SET FORTH BELOW THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORlvlJ>.TION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATE: 02/17/05 SAlOIS, SHUFF, FLOWER & LINDSAY Attorney for the Plaintiff , \ / \/ ~ , ~ /. C-}v)()' ,01 James 0. Flowel':Jr. V 1.0.#27742 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS ruFF, FLOWER 5:, LINDSAY TIORNEYS-AT-LAW ,6 W. High Stre~( Carlisle, PA Iv1ELlSSA J. SPE/\JCER. Plaintiff, . iN THE COUFn OF COMIv10N PLEAS OF . CUMBERLAND COUNTY. PENNSYLVANIA vs. . CIVIL ACTION - LAW ESTHER GOODHART, SALLY L. . NO. 04-4470 CIViL BERKLlTE, JANE BITNER, MARY ANN HADDAD, . ACTION TO OUIET TITLE GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS III! CRESSLER. KAREN fv10HN, . MARGARETSEAVERS,DOROTHY i CRESSLER JANET SEIBERT, BETTY. JEAN SEIBERT, N,ANCY THOMPSON, JOHN C. DEUTSCH, RAY G. DEUTSCH. DON DEUTSCH, CHARLES A DEUTSCH. JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORI.AL LUTHERAN CHURCH, Defendants. IMPORTANT NOTICE TO JOHN C DEUTSCH, Defendant 7 West Main Street Newburg, Pennsylvania 17240 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE iN WRITING WITH THE COURT YOUR DEFESES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHiN TEN (10) DJi,YS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAiNST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS SAIDIS JFF, FLO\VER l LINDSAY TORNEYS'AT-LAW W. High Street Carlisle, PA YOU SHOULD TAKE THIS NOTICE TO fe, LAWYER P.T ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHOI~E THE OFFICE SET FORTH BELOW THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAtf1/YER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT rv1P,Y OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PI'. 17013 (717) 249-3166 DATE 02/17/05 SAlOIS, SHUFF, FLOWER & LINDSAY Attorney for the Plaintiff \ r-,,~ By\ G / arnes D. Flower, Jr. I.D #27742 , / 26 West High Street \ ./ v Carlisle, PI'. 17013 (717) 2.43~6222 SAIDIS UFF, FLOWER :, LINDSAY rrORNEYSoAToLAW I) W. High Street Carlisle, PA hAELlSSA J. SPENCER, Plaintiff, . Ihl THE COURT OF COlv1Iv10N PLEAS OF . CUMBERLAND COUNTY, PENNSYLVAIIJIA vs. . CIVIL ACTIOIIJ - LAW ESTHER GOODHART, SALLY L. . NO. 04-4470 CIVIL BERKLlTE, JANE BITNER, MARY AI\!N HADDAD. . ACTION TO QUIET TITLE GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER. KAREN fv10HN, MARGARET SEAVERS, DOROTHY CRESSLER. JANET SEIBERT, BETTY. JEAN SEIBERT, NANCY THOMPSON, . JOHN C DEUTSCH, RAY G DEUTSCH, DON DEUTSCH, CHARLES A DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants IMPORTANT NOTICE TO VIOLET EPSTEIN, Defendant 57 Jackson Drive Chambersburg, Pennsylvania 17201 YOU ARE IN DEFAULT BECAUSE YOJ HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFESES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST yOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY 13E ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. SAIDIS UFF, FLOWER , LINDSAY jORNEYS'AT'LAW ; W. High Street Carlisle, PA YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT H/WE A LAWYER OR CA"JhIOT AFFORD OI\)E GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW THIS OFFICE CAN PROVIDE YOU WITH INFORrv1ATIO'~ ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGEhlCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS I'\T A REDUCED FEE OR NO FEE CUlvlBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATE 02/17/05 SAlOIS, SHUFF, FLOWER & LINDSAY Attorney for the Plaintiff By , \ , ~ - -" l f4n.dJhA~ James 0 Flower, Jr. 1.0. #27742 26 West High Street Carlisle, PA 17013 (717) 243~6222 i IvlELlSSA J. SPENCER, Plaintiff, . IN THE COURT OF COfVIMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA V5. . CIVIL ACTION - LAW . NO. 04-4470 CIVIL ESTHER GOODHART, SALLY L. BERKLlTE, JANE BITNER, MARY ANN HADDAD, GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JAI\lET SEIBERT, BETTY. JEAN SEIBERT, NANCY THOMPSON, . JOHN C DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A. DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants . ACTION TO QUIET TITLE IMPORTANT NOTICE TO. GAIL FREY, Defendant 1145 Pineville Road Shippensburg, Pennsylvania 17257 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING SAIDIS ~ITNr;r;~~iR WITH THE COURT YOUR DEFESES OR OBJECTIONS TO THE CLAIMS SET 'TORNEYS'AToLAW i W. High Street CarlislE, PA FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. SAIDIS fFF, FLOWER LINDSAY 'ORNEYS"AToLl\W v..', High Streel Carlisle, PA YOU SHOULD TAKE THIS NOTICE TO.A LAWYER AT Oi'../CE IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHOI\jE THE OFFICE SET FORTH BELOW THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A, REDUCED FEE OR NO FEE CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATE: 02/17/05 SAlOIS, SHUff', FLOWER & LINDSAY Attorney for the Plaintiff ~ fh~) James D, Flower, Jr. V 1.0. #27742 26 West High Street Carlisle, PA 17013 (717) 243-6222 Ii , I , i II Ii If IVlELlSSP, J. SPEI\JCER, , Plaintiff, . II\! THE COURT OF COMfvl0N PLEAS OF . CUMBERLAND COUNTY, PENNSYLVAhjlA vs . CIVIL ACTION - LAW ESTHER GOODHART, SALLY L BERKLlTE, JANE BITNER, MARY ANN HADDAD, GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER. f/-AREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY. JEAN SEIBERT, NANCY THOMPSON, JOHN C. DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A. DEUTSCH, JEI\JNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. . NO. 04~4470 CIVIL . ACTION TO QUIET TITLE IMPORTANT NOTICE TO ESTHER GOODHART, Defendant 206 East Burd Street Shippensburg, PA 17257 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING ;ArDIS '1', FLOWER WITH THE COURT YOUR DEFESES OR OBJECTIONS TO THE CLAIMS SET "INDSAY RNEYS'AT"LAW '. High Street lrlis}e, PA FORTH AGAINST YOU. UNLESS YOU ACT WITHiN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. ,AlDIS FF, FLOWER LINDSAY lRNEYS-AT'LAW V. High Street <'lrlislr., PA YOU SHOULD TAKE THIS NOTICE TO A U\WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHOI>JE THE OFFICE SET FORTH BELOW THIS OFFICE CAN PROVIDE YOU WITH INFORIIIIATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT .A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCiATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATE 02/17/05 SAlOIS, SHUFF, FLOWER & LINDSAY Attorney for the Plaintiff B~.' (;) /~z) James D, Flower, Jr. 1D.#2T742 26 West High Street Carlisle, PA 17013 (717) 243-6222 3AIDIS "F, FLOWER LINDSAY m.NEYS'AT'LAW v. High Streel "rlisle, T'A ,[ I, I' I! MELISSA J. SPENCER, Plaintiff, . IN THE COURT elF COlvHvlO"! PLE.AS OF . CUMBERLAND COUNTY, PENNSYLVANIA \/5. . CIVIL ACTION - LAW ESTHER GOODHART, SALLY L, BERKLlTE JANE BITNER, MARY ANN HADDAD, GAIL FREY, ETTIE PAPOUTSIS, VIOL/I EPSTEIN. THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY. JEAN SEIBERT, NANCY THOMPSON, . JOHN C DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH. CHARLES A DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the Iv1EMORIAL LUTHERAN CHURCH, Defendants. . NO. 04-4470 CIVIL . ACTION TO QUIET TITLE IMPORTANT NOTICE TO MARY ANN HADDAD, Defendant 131 Chris Drive Englewood, Ohio 45322-1146 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFESES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYi3E ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. SAIDIS FF, FLOWER LINDSAY DRNE"S.AToLA~" \1\,' High Streel ::arlisle, FA YOU SHOULD TAKE THIS hJOTICE TO A UWVYER AT ONCE. IF YOU DO NOT HfI,VE A LAWYER OR CAN!\IOT AFFORD ONE, GO TO OR TELEPHO!\IE THE OFFICE SET FORTH BELOW THIS OFFICE CAJ~ PROVIDE YOU WITH INFORlvlATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAVVYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORfv1ATION ABOUT AGEI~CIES TH,LI,T MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCI/I TION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATE 02/17/05 SAlOIS, SHUFF, FLOWER & LINDSAY Attorney for the Plaintiff By i j V)~!\ ames D. Flower, Jr. V i 1.0 #27742 'V 26 West High Street Carlisle, PA 17013 (717) 243-6222 I' II I: I Iv1ELlSSA J. SPEI'~CER, Plaintiff. . IN THE COURT OF COfv1MON PLE,AS OF . CUMBERLAND COUNTY, PENNSYLVANIA vs. . CIVIL ACTIO'~ - LAW ESTHER GOODHART, SALLY L . NO. 04-4470 CIVIL BERKLlTE, JANE BITNER, MARY ANN HADDAD, . ACTION TO QUIET TITLE GAfL FREY, ETTIE PAPOUTSIS. VIOLA EPSTEIN, THOMAS CRESSLER KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER JANET SEIBERT, BETTY. JEAN SEIBERT NANCY THOfv1PSON. JOHN C DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH. and the MEMORIAL LUTHERAN CHURCH, Defendants. IMPORTANT NOTICE TO MEMORIAL LUTHERAN CHURCH, Defendant 34 East Orange Street Shippensburg, Pennsylvania 17257 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING SAIDIS JFJ:~~~iR WITH THE COURT YOUR DEFESES OR OBJECTIONS TO THE CLAIMS SET TORNEYSoAr-LAW W.HighStml FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE Carlisle, PA DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. SAlOIS JFF, FLO'WER ! LINDSAY TORNE\'S-A I-LAW ,w. High Street Carlisle, PA YOU SHOULD TAKE THIS NOTICE TO A l_AVWER IU OI\JCE. IF YOU DO I\JOT HAVE A LAWYER OR CAI\JI'\JOT AFFO?D ONE, GO TO OR TELEPHOI\JE THE OFFICE SET FORTH BELOW THIS OFFICE CAI-.J PROVIDE YOU WITH I II\JFORMATION ABOUT HIRING A LAI/vYER IF YOU CANNOT AFFORD TO HIRE p, LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGEf-.JCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS I~T A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCI/ITION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATE: 02/17/05 SAlOIS, SHUFF, FLOWER & LINDSAY Attorney for the Plaintiff : \.~. ..- ~- \. of.. ; .. '- j By \ u1tt.~ \J) ( I r JJamesp Flo.;Ver,Jr V / J.D. #21742 \~i 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS JFF, FLOWER LINDSAY TORNEVS.AT-LAV,' W, High Street wrlisle, PA Ii Ii I I I , IVlELlSSJI, J. SPEI\)CER, Plaintiff, . IN THE COURT OF COlvllv10N PLEAS OF . CUIv1BERLAND COUNTY, PENI\)SYLVAI\)IA vs. . CIVIL ACTION - LAW ESTHER GOODHART, SALLY L . 1\)0. 04~4470 CIVIL BERKLlTE, JANE BITNER. MARY ANN HADDAD, . ACTION TO QUIET TITLE GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, K<\REN 1V10HN, MARGARET SEAVERS, DOROTHY CRESSLER JANET SEIBERT, BETTY. JEAN SEIBERT, NANCY THOMPSON, JOHN C. DEUTSCH, RAY G. DEUTSCH. DON DEUTSCH, CHARLES A. DEUTSCH. JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. IMPORTANT NOTICE TO ETTIE PAPOUTIS, Defendant 9300 Olde Scotland Road Shippensburg, Pennsylvania 17257 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFESES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. SAIDIS LJFF, FLOWER , LINDSAY jORNEVS'AT'LAW i W. High Street Carlisle, FA YOU SHOULD TAKE THiS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LJWIfYER OR CANNOT AFFORD OI'>JE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW THIS OFFICE CAN PROVIDE YOU VVITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORfvlATION ABOUT AGENCIES THAT 1v1,AS OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATE 02/17/05 SAlOIS, SHUFf 0, FLOWER & LINDSAY Attorney for the Plaintiff BY~~f)C)~ VJames [J Flower, Jr. 1.0. #27742 26 West High Street Carlisle, PA 17013 (717) 243-6222 IVlELlSSA J. SPENCER. Plaintiff. . IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA VS, . CIVIL ACTIOI~ - LAW .1\)0. 04-447 [) CIVIL ESTHER GOODHART, SALLY L BERKLlTE JANE BITNER, MARY ANN HADDAD, GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN. THOMAS CRESSLER. KAREN MOHI~, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY. JEAN SEIBERT. NANCY THOMPSON, JOHN C DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A DEUTSCH. JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. . ACTION TO QUIET TITLE IMPORTANT NOTICE TO: MARGARET SEAVERS, Defendant 410 Clifton Drive Shippensburg, Pennsylvania 17257 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAilED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING SAID IS I~Jt~~iR WITH THE COURT YOUR DEFESES OR OBJECTIONS TO THE CLAIMS SET ORNt.\'S'AT'LAR' 1,\/. High SCreel CaT!is[e, PA FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY E3E ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. SAlOIS JFF, FLOWER LINDSAY roRNEYS-AT.LAW W. High Srreel Carlisle, PA YOU SHOULD TAfCE THIS NOTICE TO p, LL,WYER AT ONCE IF YOU DO NOT HAVE A liWVYER OR CAI-JNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW THIS OFFICE CAN PROVIDE YOU WITH INFORlI!1fl,TION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORII!1ATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATE: 02/17/05 SAIDIS, SHUFf:, FLOWER & LINDSAY Attorney for the Plaintiff " I. By \ ~ --::'i I ,_ ' 'a~es /;~oYer,\~J J.D. #27742 , \/ 26 West High Street Carlisle, PA 17013 (717) 243-6222 MELISSA J. SPENCER, Plaintiff, . IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA vs. . CIVIL ACTION - LAW ESTHER GOODHART, SALLY L. . NO. 04-4470 CIVIL BERKLlTE, JANE BITNER, MARY ANN HADDAD, . ACTION TO QUIET TITLE GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY. JEAN SEIBERT, NANCY THOMPSON, . JOHN C, DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. IMPORTANT NOTICE TO. BETTY JEAN SEIBERT, Defendant 10 Hedge Row Lane Carlisle, Pennsylvania 17013 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING SAIDIS lUFF, FLOWER WITH THE COURT YOUR DEFESES OR OBJECTIONS TO THE CLAIMS SET & LINDSAY ... TTORNEYSoAToLA W ~5 W. High Street Carlisle, PA FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. SAIDlS lUFF, FLOWER So. LINDSAY TrORNEYSoAj-LAW ,6 Vll, High Street Carlisle, l'A YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A. LjI,WYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION AEiOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATE: 02/17/05 SAlOIS, SHUFF, FLOWER & LINDSAY Attorney for the Plaintiff B~~€)t?f~-1J_U~ James D. Flower, Jr, LD. #27742 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS ruFF, FLOWER St LINDSAY .ITORNE\'S'AToLAW .6W. High Street Carlisle, FA MELISSA J. SPENCER, Plaintiff, . IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA vs. . CIVIL ACTION - LAW ESTHER GOODHART, SALLY L. . NO. 04-4470 CIVIL BERKLlTE, JANE BITNER, MARY ANN HADDAD, . ACTION TO OUIET TITLE GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER. JANET SEIBERT, BETTY. JEAN SEIBERT, NANCY THOMPSON, . JOHN C DEUTSCH, RAY G DEUTSCH, DON DEUTSCH, CHARLES A. DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. IMPORTANT NOTICE TO. JANET SEIBERT, Defendant 322 Mainsville Road Shippensburg, Pennsylvania 17257 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFESES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST you. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. SAIDIS UFF, FLOWER , LINDSAY 'TORNEl'S'AYoUW ) W, High StreeL Carlisle, PA THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATE: 02/17/05 SAlOIS, SHUF.F, FLOWER & LINDSAY Attorney for the Plaintiff -(fJ~~ James D. lower, Jr. 1.0.#27742 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAlOIS FF, FLOWER LINDSAY DRNEYS'A r.tA W \\1. High Street :ilrlisle, PA Ii Ii II I' If IvlELlSSA J. SPENCER. I Plaintiff I IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENI\)SYLVANIA vs . CIVIL ACTION - LAW ESTHER GOODHART, SALLY L . NO. 04-4470 CIVIL BERKLlTE JANE BITI\JER. MARY ANN HADDAD. . ACTIOr\) TO QUIET TITLE GAIL FREY, ETTIE PAPOUTSIS. VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, Iv1ARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT. BETTY. JEAN SEIBERT, NANCY THOJv1PSON. . JOHN C DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A. DEUTSCH. JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIl\L LUTHERAN CHURCH, Defendants IMPORTANT NOTICE TO NANCY THOMPSON, Defendant 24 Montgomery Avenue Shippensburg, Pennsylvania 17257 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFESES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY E3E ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. SAlOIS JFF, FLOWER , LINDSAY TORNEYS"A r-LA \.1,' W High Street Carlisle, PA YOU SHOULD TAf(E THIS NOTICE TO A. LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CAI'JNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW THIS OFFICE CAN PROVIDE YOU WITH INFORIv1,11,TION ABOUT HIRII'>JG A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE JlBLE TO PROVIDE YOU WITH II\!FORMJl,TION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSOI% )"T A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY B,AR ASSOCIA TiOr\! 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATE. 02117105 SAlOIS, SHUFI=, FLOWER & LINDSAY Attorney for the Plaintiff i' ~~.. \ \ / ,-. '; ". \ By \.-( U),( , ) \ James 0. Flower, Jr. U I.D. #27742 lv 26 West High Street Carlisle, PA 17013 (717) 243-6222 ;AlDIS 'F, FLOWER "INDSAY RNt\'S' A T'W\ W r. High Street Hlisk PA IIiIELlSSp. J. SPEI~CEF:, Plaintiff, . II~ THE COURT OF C0Iv'1/v10N PLEAS OF . CUIv1BERLMID COUhJTY, PENI\jSYLVAI\lIA vs. . CIVIL ACTIOI\) - LAW ESTHER GOODHART, SALLY L BERKLlTE, JP,NE BITI\JER, IIIIPRY Af\lN HADDAD, '3AIl FREY. ETTIE Pp,pOUTSIS VIOLA EPSTEIN. THOIVlAS CRESSLER KAREI\l MOHr\j, IIIIl\RGARET SEJWERS. DOROTHY CRESSLER. JAI\lET SEIBERT, BETTY. JEAN SEIBERT, NANCY THOIIIIPSON, JOHN C DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A DEUTSCH JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE lEE DEUTSCH, and the fVIEilllORIAl lUTHERAI\J CHURCH, Defendants 04-4470 CIVil . NO. . ACTIOI\) TO QUIET TITLE IMPORTANT NOTICE TO. RAY G. DEUTSCH, Defendant 307 Means Hollow Road Shippensburg, Pennsylvania 17257 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONAllY OR BY ATTORNEY AhJD FILE IN WRITING WITH THE COURT YOUR DEFESES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHI!\ TEN (10) DP,YS FROM THE DATE OF THIS I\jOTICE, A JUDGIIIIENT MAY BE ENTERED AGAINST YOU I WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. I I .1'1 I SAIDIS FF, FL01NER LINDSAY DRfmYS'AT'LAW v".'. High Streel :~TlisJe, PA YOU SHOULD TAKE THIS NOTICE Tei F. L!\V,','ER ,q OI~CE. IF YOU Ii DO NOT HA\lE p, LAWYER OR CAI~I~OT AFFORD OI~E, GO TO OR TELEPHOI~E THE OFFICE SET FORTH BELOW THIS OFFICE CAI~ PROVIDE YOU WiTH ! ihJFORIv'1"'TIOI~ ABOUT HIRiNG'" Lfo,W1TR IF YOU CANNOT AFFORD TO HIRE A U.\I\NER THIS OFFICE MP..Y BE ,,",BLE TO PROVIDE YOU WITH INFORl\I;ftTIOhJ ABOUT AGENCIES THAT 1v'1P,Y OFFER LEGAL SERVICES TO ELIGIBLE ?ERSONS /'T fe, REDUCECl FEE OR. I~O FEE. CUMBERLAND COUNTY B.t,R ASSOCIATIOI\! 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATE 03/17/05 SAlOIS, SHUFF, FLOWER & LINDSAY ,Attorney for the IOlaintiff By VllJ?vv~; )) 7}J~~0--. James 0 Flower, Jr. c:? ID #27742 26 West High Street Carlisle, PA 17013 (717) 243-6222 . II~ THE COURT :JF COlvl/vlON PLEAS OF . CUMBERLAI\)O COUf~TY pnmSYLVAf~ip., Iv1ELlSS"', J SPEf\)CEF; Plaintiff, . CIVIL ACTIO/\) ~ LAW V5. CIVIL 04-4470 I~O. ESTHER C300DH.ART SALLY L BERKLlTE, JA!~E B!TI~ER Ivl."',;:;:YAI\)I'>J HADDAD, GAIL FREY, ETTIE PAPOUTSIS, VIOL."', EPSTEIN. THOIv1AS CRESSLER. KAREN 1v10HI'>J. MA;:;:GARETSEAVERS DOROTHY CRESSLER, JANET SEIBERT BETTY. JE,AN SEIBERT, I'>J,ANCY THOIv1PSOI'>J, JOHN C DEUTSCH. Rp,Y G. DEUTSCH DON DEUTSCH CHARLES A. DEUTSCH JENNIFER DEUTSCH. JESSE DEUTSCH, and JESSE LEE DEUTSCH, a~d the Iv1EI\~ORI,AL LUTHERAI'>J CHURCH, Defendants ACTIOf\) TO QUiET TITLE IMPORTANT NOTICE TO KAREN MOHN, Defendant 410 West King Street Shippensburg, Pennsylvania 17257 YOU ARE IN DEFAULT BECAUSE YOU HfWE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY p,TTCRNEY AND FILE IN WRITING SAIDIS IT, FLO\VER WITH THE COURT YOUR DEFESES OR OBJECTIOI\)S TO THE CLAllvlS SET LINDSAY lRNEV5'AToLAW FORTH AGAINST YOU UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE D."'.TE OF THIS NOTICE, 10, JUDGMENT MAY BE ENTERED AGAINST YOU i'. Hi:;]1 StreI'J ~ar!is]e, f'A WITHOUT A HEARING .AI'>JD YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. SAID IS FT, FLOWER LINDSAY ORNEYS'AT'L,4. W w. High Stree: :ar1isle, PA YOU SHOULD T.~KE THIS hJOTICE Te f Lf,WYER f,T OI,CE IF YOU I; [' I, DO !-JOT HAVE 10, L?Yv'\'ER OR CAI~I~OT AFFORD Ol,:=., GO TO OR TELEPHOI,E Ii I: Ii THE OFFICE SET FORTH BELOVV THIS OFFICE CAI~ PROVIDE YOUW!TH 1!~FORlviI'TIOI" AbOUT HIRII\!G ,A. LI'\I\'\'ER IF YOU CANI\!OT AFFORD TO HIRE ,L, LI',WYER, THIS OFFICE /viI'Y BE Jl.BLE TO PROVIDE YOU VVITH IhIFORlviATIOI, .~BOUT ,AC3EI\!CIES THt,T IVi"'Y OFFER LEG.AL S:::RVICES TO ELIGiBLE PERSOhJS I'.T A REDUCED FEE OR NO FEE CUIv18ERLAI\!J COUI\!W BAR p,SSOC.LPTION 32 South Bedford Street Carlisle, PA ; 7013 (7 "I 7) 249-3166 DATE 02/17/05 SAIDIS, SHUFF, FLOWER & LlI\!DSPY Attorney for the Plaintiff By~L11J J:-( (-) )-C~\ !James D Flower, Jr. V . / ID #27742 v 26 West High Street Carlisle, PA 17013 (717) 243-6222 SArDIS UFF, FLO'WER ~ LINDSAY ITORNEYS'AT-LAW G W. High Street Carlisle, PA MELISSA J. SPENCER, Plaintiff, . 11\1 THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA vs. . CIVIL ACTION - lAW ESTHER GOODHART, SALLY L BERKLlTE, JANE BITI\lER, MARY ANN HADDAD. GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN. THOMAS CRESSLER. KAREN IvlOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY. JEAN SEIBERT, NANCY THOMPSON, . JOHN C DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. . NO. 04-44"70 CIVil . ACTION TO QUIET TITLE IMPORTANT NOTICE TO: CHARLES A DEUTSCH, Defendant 95 Pebble Creek Drive Lititz, Pennsylvania 1"7543-"7677 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FilE IN WRITING WITH THE COURT YOUR DEFESES OR OBJECTIONS TO THE CLAIMS SET I FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARII\IG AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. SAIDIS IFF, FLOVlER LINDSAY rDrrNEYS-AT-LJ\\1' W. High Street Carlisle, I'll II I' Ii Ii I YOU SHOULD TAfC!:: THIS r~GTICE TO 10, LAWYER AT O/',CE. IF YOU DO NOT HAVE A LAWYER OR CAI~"JOT AFFORD OI\JE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORIv1ATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE 10, LAWYER, THIS OFFICE Iv1AY BE ABLE TO PROVIDE YOU WITH INFORIv1ATION ABOUT AGENCIES TH/',T Iv1AY OFFER LEGAL SERVICES TO ELIGIBLE PERSOI\JS JI,T A REDUCED FEE OR NO FEE CUIv1BERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATE: 02/17/05 SAlOIS, SHUFI=, FLOWER & LINDSAY Attorney for the Plaintiff c\ \ \ r ' ) ~; / r, i' By'~1j ~\.J r)'~/\ ames [J, Flower, Jr. V , ,1.0. #27742 \/ 26 West High Street Carlisle, PA 17013 (717) 243-6222 ,ArDIS '1', FLOWER LINDSAY RNEYS'AToLAIk' i. High Stree! arlisle, PA II I' 1,~ELlSSJi, J SPEI,CER Plalntifi II\! THE CDURT OF COI,~1\l101\) PLE.,',S DF . CUIv1BERLAI\jD COUI\jTY PENJ\jSYLW,I,11' vs. CIVIL ,4CTION - L.AW .1,0. 04-4478 CIVIL ESTHER GDODHART, SJiU Y L. BERf(LlTE JAl\lE B!TI\jE?, Iv1ARvp,I\jN HADDAD. GAIL FKEY ETTIE PAPOUTSIS VIOLA EPSTEIN THOIv1AS ! CRESSLER. f(AREN 1v10HI\!. I Iv1ARGARET SE.AVERS. DOROTHY CRESSLER" JANET SEIBERT BETTY. JEAN SEIBERT, I\!ANCY THOIv1PSON, . JOHN C D:::UTSCH, RAY G. DEUTSCH DON DEUTSCH. CHARLES ,A, DEUTSCH. JEI\!I\jIF'ER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEIv10RIP,L LUTHERAN CHURCH, Defendants . ACTIO!\! TO QUIET TITLE IMPORTANT !>JOTICE TO JENNIFER DEUTSCH THOMAS, Defendant 175 North Fairville Avenue Harrisburg, Pennsylvania 17112 YOU ARE IN DEFAULT BECAUSE YOU HJWE FAILED TO ENTER A WRITTEN APPEARANCE PERSON.ALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFESES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WiTHIN TEN (10) D/\YS FROM THE Dp,TE OF THIS NOTICE, A JUDGMEI'-iT fv1p,Y Be: ENTERED AG,AINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTP.NT RIGHTS. II SAIDlS rFF, FL01VER LINDSAY 'ORNEYSoAT'UW W. Higrl Stree{ Carlisle, rA I VOU SHOULD TAf(E THIS I-JOTICE TO f.,. LAlIi)'E? ,t,T iJl~CE. IF YOU j i I DO I~OT HF,\!E A LAW\'EF OR CAlmOT AFFOR~ OI~E, GO TO OR TELEPHClI~e: i i THE OFFICE SET FORTH BELOW TrliS OFFICE CAr-J PF:O\!IDE YOU WITH I I INFORlv1.L,TJON ABOUT HIRII-JGA U.\!\'YER I I IF YOU CAI~NOT AFFORD TO HIRE /-. L/!,WYER. TMIS OFFICE Iv1F,Y BE I i iABLe: TO PROVIDE YOU WITH 11~i=ORMjc,TIO'~ ABOUT AC;E:I-JCIES TH.AT M/-S I O,=FER LEC;AL SERVICES TO ELIGIBLE ?ERSOI~SLT A RiEQUCED FEE OR I-JO FEE CUIv1BERLAI-JD COUI~TY BAR ASSOClp.TIOI-J 32 South Bedford Street Carlisle, P/\ i 70 13 (717) 249-3166 DATE 04/08/05 SAlOIS, SHUFF, FLOWER & LlI-JDSAY Attorney for the Plaintiff (\, B~T(A James O. Flower, Jr. 1.0.#27742 \J 26 West High Street Carlisle, F'A 17013 (717) 243-6222 - ,,, n C. ~~ -:: ...., (:;:::I c..~ c~<, o ..., =2." n'\(__;': !D c__ " 0) ,;:,; " '1 r~cf (-) ';;,cn ;-.~\ . ;J -< (.,) C) SAIDIS ,HUFF, FLOWER & LINDSAY ATTORNEYS-At-LAW l6 W. High Street Carlisle, P A ~ECEIVED JUL 19 v\ MELISSA J, SPENCER, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW ESTHER GOODHART, SALLY L : NO. 04-4470 CIVIL BERKLlTE, JANE BITNER, MARY ANN HADDAD, : ACTION TO QUIET TITLE GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY : JEAN SEIBERT, NANCY THOMPSON, JOHN C, DEUTSCH, RAY G, DEUTSCH, DON DEUTSCH, CHARLES A. DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants, DECREE NISI AND NOW, this .2!f .. 1-? ,2005, day of in accordance with the Affidavit filed by Plaintiff, through attorneys, SAlOIS, SHUFF, FLOWER & LINDSAY, under Pa.RC.P. S1066, it is hereby directed that the Defendant to this matter shall be forever barred from asserting any right, lien, title 0 interests in the land that is subject to this action to quiet title, specifically, certain mountain ground situate in Southampton Township, Cumberland County, Pennsylvania, consisting of approximately 25 acres, more or less, titled in the name 0 MICHAEL L. CRESSLER and JOHN T. CRESSLER, as tenants in common, or Deed dated October 17, 1945, and filed in Deed Book "B', Volume 13, Page 202, in th ---. -, :/") >- _.i t--'~ ? C') ;) ('\J U. t.r:; .. , C... 0 C~ () <", SAlOIS mUFF, FLOWER & LINDSAY A'ITORNEYS-AT-LAW 26 W _ High Street Carlisle. PA II Cumberland County Recorder of Deeds Office, which may be inconsistent with th interest or claim of Plaintiff as set froth in the Complaint, and that Plaintiff shall henceforth be the owner in fee simple of said mountain ground, unless any Defendan shall file a formal objection to this Decree Nisi within thirty days of the date of servic of this Order by mail by the Prothonotary of Cumberland County. BY THE COURT: ,If ~~,cP :\' ')J9 o J. SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEVS-AT.LAW 26 W. High Street Carlisle, P A MELISSA J. SPENCER, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW ESTHER GOODHART, SALLY L. : NO, 04-4470 CIVIL BERKLlTE, JANE BITNER, MARY ANN HADDAD, : ACTION TO QUIET TITLE GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY : JEAN SEIBERT, NANCY THOMPSON, : JOHN C, DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A. DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) : ss. COUNTY OF CUMBERLAND ) Personally appeared before me, a notary public, in said Commonwealth and County, JAMES D. FLOWER, JR., who being duly sworn deposes and says that on July 29, 2005, he deposited in the United States Mail, by first class mail, a true and correct copy of the Decree Nisi dated July 25, 2005, in the above captioned case, upon the following individuals: SALLY BERKLlTE 13838 Villa View Drive Waynesboro, PA 17268 SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEVS-AT.LAW 26 w. High Street Carlisle. P A II JANE BITNER 1314 Pine Run Road Abbottstown, PA 17301 DOROTHY CRESSLER 26 Montgomery Avenue Shippensburg, Pennsylvania 17257 THOMAS CRESSLER One Antler Court Shippensburg, Pennsylvania 17257 DON DEUTSCH 49 Maple Avenue Walnut Bottom, Pennsylvania 17266 JESSE DEUTSCH 313 Pine Road Mt. Holly Springs, Pennsylvania 17065 JESSE LEE DEUTSCH c/o Heather O. Deutsch 3541 Orrstown Road Orrstown, Pennsylvania 17244 JOHN C. DEUTSCH 7 West Main Street Newburg, Pennsylvania 17240 VIOLET EPSTEIN 57 Jackson Drive Chambersburg, Pennsylvania 17201 GAIL FREY 1145 Pineville Road Shippensburg, Pennsylvania 17257 ESTHER GOODHART 206 East Burd Street Shippensburg, PA 17257 2 SAlOIS lUFF, FLOWER & LINDSAY i\TTORNEYS-AT-LAW !6 W. High Street Carlisle, PA II MARY ANN HADDAD 131 Chris Drive Englewood, Ohio 45322-1146 MEMORIAL LUTHERAN CHURCH 34 East Orange Street Shippensburg, Pennsylvania 17257 ETTIE PAPOUTIS 9300 Olde Scotland Road Shippensburg, Pennsylvania 17257 MARGARET SEAVERS 410 Clifton Drive Shippensburg, Pennsylvania 17257 BETTY JEAN SEIBERT 10 Hedge Row Lane Carlisle, Pennsylvania 17013 JANET SEIBERT 322 Mainsville Road Shippensburg, Pennsylvania 17257 NANCY THOMPSON 24 Montgomery Avenue Shippensburg, Pennsylvania 17257 RAY G. DEUTSCH 307 Means Hollow Road Shippensburg, Pennsylvania 17257 KAREN MOHN 410 West King Street Shippensburg, Pennsylvania 17257 CHARLES A. DEUTSCH 92 Pebble Creek Drive Lititz, Pennsylvania 17543-7677 3 SAlOIS HUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle, P A II JENNIFER DEUTSCH THOMAS 175 North Fairville Avenue Harrisburg,PA 17112 SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for the Plaintiff Date: August 2, 2005 B: a es D. Flower, Jr., Esquire I # 27742 26 West High Street Carlisle, PA 17013 (717) 243-6222 Sworn and subscribed to before me this .;;wi day of August, 2005. NOTARIAL SEAl MERLENE J. MARHE\IKA, NOTARY PU8LIC CARLISLE. CUMBERlAND COUNTY. PA MY COMMISSION EXPIRES JUNE 8. 2008 4 , ',' (') ~ <, "'Jcil crJ,f}i ~7r' ~'~~~'. ~L '':;C";' Z;.C.... ~;C ~ ." ~ ~ ~ c;") I GO ~ ~:P :B~ '~6 :i:::n 0- zg 15 .-'-1 ,,~ o ~ "p ~ <2 Johnson. Duffie, Stewart & Weidner By: Wade D. Manley, Esquire I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 wdm@jdsw.com Attorneys for Defendant JOHN VAYONOS Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBER:LAND COUNTY, PENNA. : CIVIL ACTION - LAW v. KYLE HARDENBROOK, : NO. 03-4470 Defendant : JURY TRIAL DEMANDED DEFENDANT'S MOT/ON TO COMPEL ANSWERS 1"0 INTERROGA TORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS PROPOUNDED UPON PLAINTIFF , /-fA AND NOW, thiS "j:. day of October, 2005, comes the Defendant, Kyle Hardenbrook, by and through his undersigned attorneys, Johnson, Duffie, Stl~wart & Weidner, and moves for an Order compelling Plaintiff to comply with the requirements of outstanding discovery as follows: 1, The Defendant, Kyle Hardenbrook, the moving p,arty herein, is represented in this matter by Wade D. Manley of Johnson, Duffie, Stewart & Weidner, 301 Market Street, Lemoyne, Pennsylvania, 17043; telephone number (717) 761-4540, and f~lcsimile number (717) 761-3015. 2, The Plaintiff, the responding party herein is John Vanoyos, who is represented in this matter by William p, Douglas, Esquire, The Douglas Law Firm, 27 West High Street, P. 0, Box 261, Carlisle, PA 17013; telephone number (717) 243-1"790, and facsimile number (717) 243-8955. 3. This case involves a claim for personal injuries to the Plaintiffs resulting from a motor vehicle accident which occurred on or about September '14, 2001. 4. On February 4, 2004, the Defendant served the Plaintiffs with the following discovery: a) Interrogatories to the Plaintiffs, a copy of which is attached hereto as Exhibit A; b) Requests for Production of Documents to the Plaintiffs, a copy of which is attached hereto as Exhibit B. 5. On April 19, 2004, the Defendant's prior counSE!I, Jeff McGuire, Esquire, sent to the Plaintiffs' attorney a letter, a copy of which is attached hereto as Exhibit C, relating to the Plaintiffs' failure to answer the above-enumerated discovery items. 6, The Defendant's case was transferred to the L.aw Office of Johnson Duffie in June of 2005 and upon review of the file, it was determined that the Plaintiff still had not complied with the deadline to answer the discovery originally served, 7. Therefore, on June 3, 2005, the undersigned sent a letter to the Plaintiffs attorney advising him that review of the file indicated that his client had failed to answer the discovery posed, but if we were mistaken and the discovery was answered prior to the transfer of the file to our office, please send copies of the Plaintiff's answers and responses to the undersigned's office, A copy of the June 3. 2005 correspondence is attached hereto as Exhibit D, 8. The Plaintiffs attorney did not respond to or acknowledge the June 3, 2005 correspondence, so on August 22, 2005, the undersigned again wrote to the Plaintiff's counsel advising the Plaintiff and his counsel that if the Plaintiffs answers and responses were not sent to defense counsel's office within fifteen (15) days from the datE! of the letter, the instant motion would be presented. A copy of the June 3, 2005 correspondence is attached hereto as Exhibit E, 9, As of the date of the filing of this Motion, no answers or objections have been received from Plaintiffs' counsel to the above-enumerated discovery items. 10, By reason of the foregoing, the Plaintiffs havE' failed to timely respond to the Defendant's discovery, which is the subject of this Motion. 11. The Defendant requires the Plaintiffs' compliance with discovery to evaluate the Plaintiffs' claims involved in this matter and to defend against the Plaintiffs' action, WHEREFORE, the Defendant respectfully requests that an Order be entered compelling the Plaintiffs to answer and respond to the discovery propoundl~d by the Defendant which is the subject of this Motion. JOHNJON, DUFFIE, STEWART & WEIDNER By: /;U 7rl< -Po J Wade D, M ney csj:259178 22740-1883 JOHN VA YONOS Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 03-4470 KYLE HARDENBROOK Defendant : CIVIL ACTION - LAW : JURY TRIAL DEMANDED INTERROGATORIES PROPOUNDED BY DEFENDANT, TO BE ANSWERED BY PLAINTIFF.. FIRST SET TO: John Vayonos c/o William P. Douglas, Esquire 27 West High Street P. O. Box 261 Carlisle, PA 17013..0261 PURSUANT TO THE PROVISIONS ofPa. R.c.P. 4005 and 4006, as amended, you are required to serve a copy on the undersigned, of your Answers :md Objections, if any, in writing and under oath, to the following Interrogatories within thirty (30) days after service of the Interrogatories. The Answers shall be inserted in the spaces provided following each Interrogatory. If there is insufficient space to answer an Interrogatory, the remainder of the Answer shall follow on a supplemental sheet. These Interrogatories shall be deemed to be continuing in nature pursuant to Pa. R.C.P. 4007.4. If between the time of filing your original Answers to these Interrogatories and the time of trial of this matter, you or anyone acting in your behalfleams the identity and location of additional persons having knowledge of discoverable facts and the identity of persons expected to be called as an expert witness at trial not disclosed in your Answers, or if you or an expert witness obtains information upon the basis of which you or he knows that an Answer was incorrect when made, or know that an Answer though correct when made is no longer true, promptly supplement your original Answers under oath to incIude such information thereafter acquired, and promptly furnish such a Supplemental Answer on the undersigned. By: KEARNS -~- d//Oi J T. McGuire, Esquire ttorneyLD. No. 73617 Attorneys for Defendant 3631 North Front Street Harrisburg, P A 17110 (717) 232-7661 Dated: 03-794/68343 1. Please set forth your full legal name. ANSWER: 2. Please set forth any other names which you have used, the inclusive dates during which each such name was used and the reason for such usagtl, ANSWER: , 3. Please set forth your present address, any address used by you during the last ten (10) years and the dates on which you utilized each such address. ANSWER: 4, Please set forth your date of birth and the state, county and city of your birth. ANSWER: 5. Please set forth your social security number. ANSWER: 6. State the names of all spouses with whom you hav,~ been married in the past ten (10) years indicating the date and place of each marriage, and the date and reason for the termination of each marriage, including the term and number of any divorce action. ANSWER: 7. Have you ever been a member of the Armed Services? If so, state: (a) the branch of the military service in which you served; (b) the highest military rank you obtained; (c) your serial number; (d) the inclusive dates of services; (e) the type of discharge you received; and (f) whether or not you served in combat. ANSWER: 8. State the name and address of each school or other educational institution which you have attended, listing the dates of attendance and the courses of study. Include on-the-job and any specialized training which you have received. ANSWER: 9. Have you ever been convicted of a felony or misdemeanor? If so, state: (a) the count and state in which you were convicted; (b) the nature of the felony or misdemeanor of which you were convicted; (c) whether such conviction resulted from a jury verdict, plea of guilty or plea of nolo contendere; (d) the date of your conviction; (e) the name and address of the tribunal imposing sentence; (f) the title of the cause and case number assigned by said tribunal to your case; (g) the nature ofthe sentence imposed; and (h) the dates and places of any facility in which you were incarcerated. ANSWER: 10. Please identify your current employer and each employer for whom you have worked during the past five years and set forth as to your current employer and each past employer: (a) the identity and legal address of your employer(s); (b) your job title and duties during the course of each such employment; (c) dates of employment; (d) yourrate of pay; (e) the number of hours you usually worked each week at each such employment; (f) the name, business and residence address and telephone number of your immediate supervisor at each such employment; and (g) the reason for leaving each past employer. ANSWER: 11. Have you ever made a claim for personal injuries, Worker's Compensation or property damage under any insurance policy, or against any person, fiml or corporation or to any governmental agency? If so, state: (a) the name and address of the person or entity against whom such claim was made; (b) a description of each injury or damage which was the subject of each such claim; (c) the name and address of the tribunal where such claim was filed, the title of the cause, case or claim and the number assigned by the tribunal to such cause, case or claim; (d) the name and address of the insurer affording coverage applicable to said claim and the claim number assigned to said claim; (e) the date and manner in which you suffered the injuries or damage giving rise to such claim; and (f) the date and amount of money paid, if any, to settle or otherwise satisfy said claim. ANSWER: 12. Have you ever suffered any injuries in any accident, either prior or subsequent to the incident referred to in the Complaint? If so, provide: (a) the date, time and place of the accident; (b) a detailed description of the manner in which the accident occurred; ( c) the names and addresses of all physicians, hospitals or health care providers who rendered any treatment to you; (d) the nature of any injuries sustained; (e) the extent of recovery; and (f) the nature of any compensation received. ANSWER: 13. State in detail the nature of the injury or injuries you allege that you suffered as a result of the incident referred to in the Complaint and with respect then~to, indicate the extent and nature of any disability, the location of pain suffered and duration and intensity of such pain, and whether you suffered restraint of your normal activities due to the injuries including the nature of such restraint and the date( s) of such restraint. ANSWER: 14. If you received any treatment with respect to the injuries allegedly suffered, state: (a) the name and address of each physician, hospital or health care provider in which you were treated or admitted; (b) the dates on which said treatment was rendered, including the dates of entry and discharge into and from said hospital or hospitals; (c) describe the services rendered by each of the physicians, hospitals or health care providers listed above; (d) itemize the cost and expenses of all treatment received. ANSWER: 15. Since the date of the incident referred to in your Complaint, have you been treated by or examined by, or conferred with any other physician, surgeon, osteopath, chiropractor, or medical or dental practitioner of any type whatsoever whose name you have not heretofore supplied? If so, indicate: (a) the name and address of each medical practitioner of any type who has examined, treated, conferred or consulted with you; (b) the date of such examination, treatment or consultation; and (c) the condition for which said treatment was provided. ANSWER: 16. Have you sustained any loss of wages, financial loss or diminution in earning capacity as a result of the incident complained of? If so, descnibe the nature and amount of such loss or losses. ANSWER: 17. If you have incurred any medical bills or expenses of any kind in connection with the alleged injuries not heretofore listed, state the person with whom such bill was incurred, the amount of such bill and the service or thing for which the bill was rendered. ANSWER: 18. If you are still receiving medical service or treatment or any nature whatsoever, state the name(s) or the person(s) attending you, the approximate frequency of said treatment or service and the date you last received said treatment or service. ANSWER: 19. Have you consulted in the past 10 years with any physician, hospital or health care provider for any illness, injury, surgical procedure, hospitalization or institutional confinement? If so, state: (a) the name and address of the physician, hospital or health care provider with whom you consulted or were treated; (b) the dates of such consultation; and (c) the nature of the illness, injury or ailment for which the consultation was sought. ANSWER: 20. Do you have a family physician or other health care provider with whom you consult for general physical or mental complaints? If so, provide the name and address of such family physician or health care provider? ANSWER: 21. Have you ever been involved in a motor vehicle accident other than the incident referred to in the Complaint? If so, provide, for each accident: (a) the date of the accident; (b) the state, county and city, township or borough where the accident occurred; (c) the names and addresses of all operators of other motor vehicles involved in the accident; (d) a description of the accident; (e) the nature of any injuries sustained; (f) the names and addresses of all health care providers who treated you for any injuries; and (g) the identity of the police force that investigated the accident. ANSWER: 22, List all hobbies and forms of recreation in which you have participated in the last ten (10) years. ANSWER: 23, Identify by name and address of owner and by the make, model and year, each vehicle known or believed by you to have been involved, directly or indirectly, in the accident referred to in the Complaint. ANSWER: 24. State in detail the manner in which you assert that the incident referred to in the Complaint occurred, specifying the speed, position, direction and location of each vehicle involved during its approach to, at the time of, and immediately after the collision. ANSWER: 25. List the names and addresses of all person known or believed by you or any person acting on your behalf, to have firsthand knowledge of the facts and circumstances of the incident or of the events leading up to or following the incident. ANSWER: 26. List the names and addresses of all persons, including potential expert witnesses, from whom you or anyone acting on your behalf has obtained :my information and/or statements as to how the incident happened or the cause of the incident. ANSWER: 27. State the full name and last known address, giving the street, street number, city and state of every witness known to you, or to your attorneys, or repre:sentatives, who claim to have seen or heard any party to this action make any statement or statements pertaining to any of the events or happenings which is the subject of this suit. ANSWER: 28. Provide the name and address of each person who you know or believe conducted an investigation concerning the incident referred to in the Complaint. ANSWER: 29, At the time of the incident referred to in your Complaint, did you have any condition for which you wore eyeglasses, or for which eyeglasses had bem prescribed for you, and if so, state whether you were wearing eyeglasses at the time of the ineident referred to in the Complaint. ANSWER: 30. Were you ever charged for any violation of the motor vehicle or traffic laws or ordinances of any state or municipality arising out of the incident referred to in your Complaint? If so, state by whom and before whom you were charged and the disposition of the charge. ANSWER: 31. If you intend to call any technicians or experts (including medical experts) as witnesses during the trial of this action, please state with respect to each such technician or expert: (a) his name, address, and the professional occupation and field in which he is an expert (you may attach his curriculum vitae); (b) the subject matter on which the expert is expected to testify and the substance of the facts and opinions to which the expert is expected to testify and a summary of the grounds for each opinion; (c) if the opinion is based upon a medical or scientific rule or principle, or is based upon any code, regulation, standard (governmental or otherwise) or is based upon any scientific, medical or engineering textbook or publication, identify the scientific or medical rule or principle, code or regulation or scientific, medical or engineering textbook or publication; (d) whether any of the experts were compensated for their work and efforts in connection with this action and, if so, state how much the expert is to be paid, whether he has already been paid, and if not, when he will be paid. ANSWER: 32. Have you ever applied for insurance and/or no-fault benefits as a result of the injuries sustained in this accident? If so, state: (a) the name and address of the insurance carrier to whom you have applied; (b) the adjuster or claims person handling the file; (c) the applicable claim(s) nwnber; (d) whether any part of your claim has been rejected. ANSWER: CERTIFICATE OF SERVICE I hereby certify that on this date I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: William P. Douglas, Esquire 27 West High Street P. O. Box 261 Carlisle,PA 17013-0261 CALDWELL & KEARNS By: r\l r j}, t / ...rJj'{1';;" , r.. "-- Dated: (-€/o.l/J {W"j- '-I, Wo y JOHN V A YONOS Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs, : NO, 03-4470 KYLE HARDENBROOK Defendant : CIVIL ACTION - LAW : JURY TRIAL DEMANDED REQUEST FOR PRODUCTION OF DOCUMENTS DIRECTED TO PLAINTIFF, - FIRST REOUEST TO: John Vayonos c/o William P. Douglas, Esquire 27 West High Street P. O. Box 261 Carlisle, PA 17013-0261 PLEASE TAKE NOTICE THAT PURSUANT TO Pa. R,C.P, 4009, you are required to furnish at our office, on or before thirty (30) days of service her'eof, a photostatic copy or like reproduction of the materials enumerated below concerning this action or its subject matter which are in your possession, custody or control and which are not protected by the attorney/client privilege; or, in the alternative, produce the said matter at said time to permit inspection and copying thereof. This request should be deemed continuing, and any response should be supplemented upon receipt of additional information, I. The entire contents of any investigation file(s) and any other documentary material in your possession which support or relate to the allegations contained in Plaintiffs Complaint (excluding references to mental impressions, conclusions or opinions representing strategy or tactics and privileged communications from and to counsel). 2, Any and all statements concerning the action, as defined by Rule 4003.4, from all witnesses including any statements from the parties herein, or their respective agents, servants or employees. 3. All photographs taken or diagrams prepared of the scene of the accident or any instrumentality involved therein. 4. Any and all documents containing the names and home and business addresses of all individuals contacted as potential witnesses. 5. Reports of any and all experts who will testify at trial. 6. Any and all medical records, physician's reports and bills, hospital records or abstracts of same which relate in any way to the injuries allegedly sustained by Plaintiff, as well as the treatment of any similar injuries prior or subsequent to the occurrence in question. 7. All Federal tax returns and W-2's for the five (5) years prior to the accident or incident and for all years up until the time of trial. 8. All documents, not responsive to any of the above requests, which relate in any way to any claimed injuries, losses or damages. 9. All documents or exhibits which you intend to offer at the trial of this matter. Dated: :;)/'1/0 "'I CALDWEL & ~)E~~S / / /; 1 ---L . BY: WI Jef e:tf., cGuire, Esquire A torney LD, #73617 Attorneys for Defendant 3631 North Front Street Harrisburg, PAl 711 0 717-232-7661 CERTIFICATE OF SERVICE AND NOW, this ~ day of ,2004, I hereby certify that I have served a copy of the within document on the followin depositing a true and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: William P. Douglas, Esquire 27 West High Street P. O. Box 261 Carlisle, PA 17013-0261 CALDWELL & KEARNS By: 03-794/68347 CALDWELL & KEARNS A PROFESSIONAL CORPORATION .JAMES R. CLIPPINGER CHARLES J. DEHART. III .JAMES 0 CAMPBELL, JR. .JAMES L GOLDSMITH .JEFFREY' T. McGUIRE- STANLEY J. A LASKOWSKI DOUGLIo.S 1<. MARSICO BRETT M. WOODBURN RAY .J MICHALOWSKI ATTORNEYS AT LAW OF COUNSEl.. RICHARD \... KEARNS CARL G. WASS 3631 NORTH FRONT STREET HARRISBURG. PENNSYLVANIA /7110-1533 THOMAS D. CALDWELL. JR. !I92S-Z0al! -ALSO A MEMBER OF" NJ BAR April 19,2004 717-232-7661 FAX, 717-232-2766 thefirm@ca\dwellkearns.com William P. Douglas, Esquire Douglas Law Office 27 West High Street Carlisle, PA 17013-0261 Re: Vavonos vs. Hardenbrook Dear Bill: I forwarded discovery to you on February 4th and have not yet received your responses. Please provide your responses immediately, or let me know whm I can expect the responses. I would rather not have to file a motion to compel at this point. Very truly yours, DICTATED BUT NOT READ Jeffrey T. McGuire CALDWELL & KEARNS JTM:dlj 03-794/71630 JER!{\ It DUFFIE [{!ClIAnn Vi. STEWAHT C. ROY WE!D~EIt. 11\ EnMlJ!\fJ G. MYERS DWlIJ W DELun: JOHN A STAltEn IEHEIlSON I SIIII'MMc IIAI.PIIII, WIUGIH IR MAllK c:. DUEFIE IOHN R. N!!\iosl\Y ~ICllAEL , CASSIDY MELISSA PEEL GnEEVY ROBEHT M. WALKEll. WAllE 0, MANLEY William P. Douglas, Esq. 27 West High Street Carlisle, PA 17013-0261 LAW OFfiCES ]OHNSONr DUFFIE OF COUNSEL 11ol\ACF A. JOIJNSOf\} F, LEE SllJl'\oJ,'I;\: BRUCE ; r;RO';~~~L\I\ [:::-"dmillCd ,,\Y "ui'. /([2 \VH,lTl'~R't; 1<\"1', NIl J:!~ F>il'lr\l'l,wdm (.l..i(!,-lW,(:Onl June 3, 2005 Re: Vayonos v. Hardenbrook Cumberland County C.C.P. Docket No. 03-4470 Dear Mr. Douglas: Please be advised that the above-referenced matter hals been transferred to this firm for future handling. My review of the file forwarded to us by prior counsel reveals that a set of interrogatories and requests for production of documents were forwarded to your attention on February 4, 2004, for answers and responses by your client. The file does not appear to contain answers or responses to either of the discovery requests. I do note that on April 19, 2004 prior counsel notified you that he had not yet received your client's answers to the discovery requests, and requested that you advise him as to when he may expect those responses. If my review of the file is inaccurate and ypur client did in fact answer prior counsel's discovery requests, please accept my apologies in advance, and if you would be so kind, please forward me a copy of those answers and responses maintained in your file. If your client has not yet answered those discovery requests however, contact me upon r,eceipt of this letter to advise me as to when we may expect to receive those answers and responses. If you have any further questions or concerns in regard to the ,above-referenced matter, please feel free to contact me directly. Very truly yours, :2}'3:0: STEWART & WEIDNER csj:252136 13806-24 cc: Daniel Wyche, Geiee (Claim No. 0045221100101046) Mark A. Hardenbrook JOI MARKET STREET P.O. BOX llli) LEMOYNE, PENNSlLVANIA 1704j,OiO') WWIVIDSWCOM 7177h1.4540 FA), 717.7hU1I15 MAIL@IDSWCOM JOHNSON, DUFFIE, STEWART & WEIDNER, PC JERny R, DUFFIE RICHAnD W STEWART C. ROY WEIDNER, III EDMUND G, MYERS DAVID W DELuCE JOHN A, STATLER JEFFEHSON J, SHIPMAN RALPH H, WRIGHT, In MARK C. DUFFIE JOHN R, NINOSKY MICHAEL J, CASSIDY MELISSA PEEL GREEVY ROBERT M, WALKER WADE D, MANLEY LAW OFFICES ]OHNSONf DUFFIE OF COUNSEL HORACE A, JOHNSON F. LEE SHIPMAN B~GROSSMAN' , /["/2 v\-lHTEF:'S EXT. N\l.122 f<:-J\:IATL\\'dnl :i.(JdSW.(;IJrll August 22, 2005 William P. Douglas, Esq. 27 West High Street Carlisle, PA 17013-0261 Re: Vayonos v. Hardenbrook Cumberland County C.C.P. Docket No. 03-4470 Dear Mr. Douglas: On February 4, 2004, you were served with a request for production of documents and interrogatories, responses to which were to be received by prior c:ounsel within 30 days of the date of service. As of this date, I have not received answers to the interrogatories or to the request for production of documents. Please be advised that if I do not receive answers to the interrogatories and the documents requested in the request for prOduction within 15 days of the date of this letter, I will file a motion to compel. If you have any difficulties, please do not hesitate to give me a call. I am willing to grant a reasonable (but defined) extension, but I have received no request from you to date. If I am unavailable, please feel free to speak with my legal assistant, CarlElen Jensen. Very truly yours, JOHNSON, DUFFIE, STEWART & WEIDNER tv~ ~. Wade D. Manl e5j:256875 13806-24 ee: Daniel Wyche, Geleo (Claim No, 0045221100101046) 301 MARKET STREET P,O. BOX 109 LEMOYNE, PENNSYLVANIA 17043,0109 WWW.JDSW.COM 717.761.4540 FAX: 717,761.3015 MAIL@jDSWCOM JOHNSON, DUFFIE, STEWART & WEIDNER, P.C. CERTIFICA TE OF SERVICE AND NOW, this 11f~ day of October, 2005, the undElrsigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: William P. Douglas, Esq, 27 W, High Street POBox261 Carlisle, PA 17013-0261 JOHNSON, DUFFIE, STEWART & WEIDNER By ;J Il j~ ~ensen -:2 ~, co l") .---1 -.J c.~ r-> ,-', SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS'AT'LAW 26 W. High Street Carlisle. PA MELISSA J. SPENCER, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW ESTHER GOODHART, SALLY L. : NO. 04-4470 CIVIL BERKLlTE, JANE BITNER, MARY ANN HADDAD, : ACTION TO QUIET TITLE GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY : JEAN SEIBERT, NANCY THOMPSON, : JOHN C. DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A. DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. MOTION FOR FINAL ORDER AND NOW COMES Plaintiff MELISSA J. SPENCER, by her Attorneys, SAlOIS, SHUFF, FLOWER & LINDSAY, and makes the following motion: 1. A Decree Nisi was entered in this matter on July 25, 2005, by the Honorable Kevin A. Hess, a copy of which is attached, to the effect that unless any Defendant files a formal objection to the Decree Nisi within thirty days of the date of the service of the Decree Nisi, that the Defendants would be forever barred from asserting any right, lien, title or interest in the land subject to this action to quiet title, specifically, certain mountain land situate in Southampton Township, Cumberland County, SAlOIS SHUFF, FLOWER & LINDSAY ATfORNEYS-AT'UW 26 W. High Street Carlisle, P A , II . I I : Pennsylvania, consisting of approximately 25 acres, more or less, titled in the name of Michael L. Cressler and John T. Cressler, as tenants in common, by Deed dated October 17, 1945, and recorded in Deed Book "B", Volume 13, Page 202, in the Cumberland County Recorder of Deeds' Office. Plaintiff, MELISSA J. SPENCER, would then henceforth be the owner in fee simple in said mountain ground. 2. The undersigned, counsel for Plaintiff, served the Decree Nisi upon each Defendant by mailing a copy with a letter of enclosure to the address of each Defendant, where the Sheriff was successful in obtaining actual service of the original Complaint on each Defendant. A copy of said letter is attached hereto as Exhibit "A". 3. The undersigned has checked the docket and finds that no Defendant filed a formal objection to the Decree Nisi entered in this matter within thirty days, nor indeed up to the date of the filing of this motion. WHEREFORE, Plaintiff requests that a Final Order pursuant to the Decree Nisi be entered in accordance with Pa.R.C.P. g1066. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for the Plaintiff Date: November-2L-2005 James D. Flower, Jr., Esquire 26 West High Street Carlisle, PA 17013 (717) 243-6222 I.D. #27742 SAlOIS SHUFF, FLOWER & LINDSAY ATIURNEYS-AT'LAW 26 W. High Street Carlisle, PA VERIFICATION I, JAMES D. FLOWER, JR., hereby verify that the statements made in the within instrument 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. Section 4904, relating to unsworn falsification to authorities. t~~~~~ Date: November 18, 2005 f J,b,t f+ LA W OFFICES JOHN E. SLIKE ROBERT C. SAlOIS GEOFFREY S. SHUFF JAMES D. FLOWER, JR. CAROL J. LINDSAY BRI AN C. CAFFREY GEORGE F. DOUGLAS, 1II MATTHEW J. ESHELMANt THOMAS E FLOWER I ACL YN M. SMITH SAID IS, SHUFF, FLOWER & LINDSAY A PROFESSIONAL CORPORATION 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 243.6222. FACSIMILE: (717) 243.6486 EMAIL: attorney@ssf1-1aw.com www.ssfl-Iaw.coTI1 July 29, 2005 Sally Berklite 13838 Villa View Drive Waynesboro, PA 17268 Jane Bitner 1314 Pine Run Road Abbottstown, PA 17301 Dorothy Cressler 26 Montgomery Avenue Shippensburg, Pennsylvania 17257 Thomas Cressler One Antler Court Shippensburg, Pennsylvania 17257 Don Deutsch 49 Maple Avenue Walnut Bottom, Pennsylvania 17266 1.o.C'C'c. nOllfC',.....h ...'-'....-''- __........L........;. 313 Pine Road Mt. Holly Springs, Pennsylvania 17065 Jesse Lee Deutsch cia Heather O. Deutsch 3541 Orrstown Road Orrstown, Pennsylvania 17244 John C. Deutsch 7 West Main Street Newburg, Pennsylvania 17240 CAMP HILL OFFICE: 2109 MARKET STREET CAMP HILL, FA 11701 TELEPHONE (717) 737.3405 FACSIMILE: (717) 7:;7-::1,407 jBoMdCl'rlilledCrt'ditoro' Rights Hepresentclliol1 REPLY TO CARLISLE Sally Berklite, et al. Violet Epstein 57 Jackson Drive Chambersburg, Pennsylvania 17201 Gail Frey 1145 Pineville Road Shippensburg, Pennsylvania 17257 Esther Goodhart 206 East Burd Street Shippensburg, PA 17257 Mary Ann Haddad 131 Chris Drive Englewood, Ohio 45322-1146 Memorial Lutheran Church 34 East Orange Street Shippensburg, Pennsylvania 17257 Ettie Papoutis 9300 Olde Scotland Road Shippensburg, Pennsylvania 17257 Margaret Seavers 410 Clifton Drive Shippensburg, Pennsylvania 17257 Betty Jean Seibert 10 Hedge Row Lane Carlisle, Pennsylvania 17013 Janet Seibert 322 Mainsville Road Shippensburg, Pennsylvania 17257 Nancy Thompson 24 Montgomery Avenue Shippensburg, Pennsylvania 17257 2 July 29, 2005 Sally Berklite, et al. 3 July 25, 2005 Ray G. Deutsch 307 Means Hollow Road Shippensburg, Pennsylvania 17257 Karen Mohn 410 West King Street Shippensburg, Pennsylvania 17257 Charles A Deutsch 92 Pebble Creek Drive Lititz, Pennsylvania 17543-7677 Jennifer Deutsch Thomas 175 North Fairville Avenue Harrisburg, PA 17112 RE: QUIET TITLE ACTION Dear Folks: Enclosed is the Court Order that declares Melissa Spencer to be the sole owner of the mountain ground that was the subject of the action to quiet title. The Order provides that it becomes final unless someone files an objection of record within thirty days. Unless you have an objection to clearing the title in this fashion, you need take no action in response to this Court Order. If you have any questions, please call. Very truly yours, SAIDIS, SHUFF, FLOWER & LINDSAY \'1,.<"\---.::-,.,. ,', A' j \ \ ct Vl),...~ ) "./ ! I James D. Flower, Jr. ......~~~.. .... ut JDFJr:mjm Enclosure cc: Melissa Spencer C' 1"'.~ , , ,.:~',J c) nq ~ t"';."i~ ., ., r....) -'n n ..,) C,) .< , SAlOIS SHUFF, FLO\\'ER & LINDSAY ATTORNEYS'AT'LAW 16 W. High Street Carlisle, PA MELISSA J. SPENCER, Plaintiff, . IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW ESTHER GOODHART, SALLY L. . NO. 04-4470 CIVIL BERKLlTE, JANE BITNER, MARY ANN HADDAD, : ACTION TO QUIET TITLE GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY: JEAN SEIBERT, NANCY THOMPSON, JOHN C. DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A. DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. ORDER OF COURT AND NOW, this 2 z ~ day of ,2005, No~ no Answer having been filed by any Defendant to the Decree Nisi entered in this matter on July 25, 2005, IT IS HEREBY DECREED as follows; 1. Defendants or their successors or assigns are forever barred from asserting any right, lien, title or interest in the land subject to this action to Quiet Title, specifically, approximately 25 acres of mountain ground in Southampton Township, Cumberland County described in a Deed titled to Michael L. Cressler and John T Cressler as tenants in common by Deed dated October 17, 1945, and recorded in Deed Book "B", Volume 13, Page 202, in the Office of the Cumberland County Recorder of Deeds; and \ C ,,::l .0, '\ >'::; ,...~) , "'"I.c. l C:'i>'\'i jV'CJ jCj '. SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS.AT'LAW 26 W. High Street Carlisle, PA 2. Plaintiff, MELISSA J. SPENCER, is the owner in fee simple of the land subject to this action, specifically, approximately 25 acres of mountain ground in Southampton Township, Cumberland County described in a Deed titled to Michael L. Cressler and John T. Cressler as tenants in common by Deed dated October 17,1945, and recorded in Deed Book "B", Volume 13, Page 202, in the Office of the Cumberland County Recorder of Deeds. BY THE COURT: J. ;4 /1-;}1-(j{ ~ .~. J45" -r J - -~ I '-" v SAlOIS SHUFF, FLOWER & LINDSAY ATIQRNEYS.AT-LAW 26 w. High Street Carlisle, PA r ~ECEIYED JUL 191005 . . 1\ MELISSA J. SPENCER, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW vs. ESTHER GOODHART, SALLY L. : NO. 04-4470 CIVIL BERKLlTE, JANE BITNER, MARY ANN HADDAD, : ACTION TO QUIET TITLE GAIL FREY, ETTIE PAPOUTSIS, VIOLA EPSTEIN, THOMAS CRESSLER, KAREN MOHN, MARGARET SEAVERS, DOROTHY CRESSLER, JANET SEIBERT, BETTY : JEAN SEIBERT, NANCY THOMPSON, JOHN C. DEUTSCH, RAY G. DEUTSCH, DON DEUTSCH, CHARLES A. DEUTSCH, JENNIFER DEUTSCH, JESSE DEUTSCH, and JESSE LEE DEUTSCH, and the MEMORIAL LUTHERAN CHURCH, Defendants. DECREE NISI AND NOW, this .l!f ~ f~ ,2005, day of in accordance with the Affidavit filed by Plaintiff, through attorneys, SAlOIS, SHUFF, FLOWER & LINDSAY, under Pa.R.C.P. g1066, it is hereby directed that the Defendant to this matter shall be forever barred from asserting any right, lien, title on interests in the land that is subject to this action to quiet title, specifically, certain mountain ground situate in Southampton Township, Cumberland County, Pennsylvania, consisting of approximately 25 acres, more or less, titled in the name 0 MICHAEL L. CRESSLER and JOHN T. CRESSLER, as tenants in common, or Deed dated October 17, 1945, and filed in Deed Book "B', Volume 13, Page 202, in th ~ ") " ) :'\.; t.-- I..~-~' ':-~-" SAlOIS SHUFF, FLOWER & LINDSAY ATIQRNEYS-AT-lAW 26 W. High Street Cal"lisle, PA . . Cumberland County Recorder of Deeds Office, which may be inconsistent with thel interest or claim of Plaintiff as set froth in the Complaint, and that Plaintiff shall henceforth be the owner in fee simple of said mountain ground, unless any Defendan shall file a formal objection to this Decree Nisi within thirty days of the date of service of this Order by mail by the Prothonotary of Cumberland County. BY THE COURT: J. November 23, 2005, Final Judgment is her y entered in favor of the Plaintiff and against Defendants Pursu to PA R. C. P. Rule No. 1066 & Local Rule 1066.4 ,,\9 ~.t-' o 7~ ,c~ Curtis R. Long Protho otaxy