HomeMy WebLinkAbout12-0874
Hubert X. Gilroy, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER ! 1: F's 10 All 11- ` !;1
MARTSON LAW OFFICES
I.D. 29943 ,U-tbEi1L?
rENN'YYEV'r N1
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiffs
STEVEN R. STRAYER and
CARRIE M. STRAYER,
Plaintiff
vs.
MICHAEL A. WITMER, SR.,
LORI WITMER, JUSTIN GALLO
and OTHER UNNAMED AND
UNKNOWN INDIVIDUALS,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 2012- 7
IN EJECTMENT
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 an attorney and filing in
writing with the Court your defenses or objections to the claims set forth against you. You are
warned that if you fail to do so the case may proceed without you and a judgment may be
entered against you by the Court without further notice for any money claimed in the Complaint
or for any other claim or relief requested by the Plaintiff. You may lose money or property or
other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, 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
1-800-990-9108
717-249-3166 7 ?4 `
F:\Clients\14662 Strayer\14662.I.Complaint.wpd
Created: 9/20/04 0:06PM
Revised: 2/9/12 4:49PN1
Hubert X. Gilroy, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
I.D. 29943
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiffs
STEVEN R. STRAYER and
CARRIE M. STRAYER,
Plaintiff
VS.
MICHAEL A. WITMER, SR.,
LORI WITMER, JUSTIN GALLO
and OTHER UNNAMED AND
UNKNOWN INDIVIDUALS,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2012- 1???
IN EJECTMENT
COMPLAINT IN EJECTMENT
PLAINTIFFS, Steven R. Strayer and Carrie M. Strayer, by their attorneys, Martson Law
Offices, sets forth the following:
1. Plaintiffs are Steven R. Strayer and Carrie M. Strayer who are adult individuals
residing at 9 Independence Drive, Shippensburg, Cumberland County,
Pennsylvania, 17257.
2. Defendants are Michael A. Witmer, Sr., Lori Witmer, Justin Gallo and other
unnamed and unknown individuals who currently reside at 175 Whitmer Road,
Shippensburg, Cumberland County, Pennsylvania, 17257.
3. The Plaintiffs are at all times herein mentioned and still are the owners of that
certain parcel of land located at 175 Whitmer Road, Shippensburg, Cumberland
County, Pennsylvania, 17257 (said property hereinafter referred to as the "Subject
Property").
4. The Plaintiffs are the owners of the Subject Property pursuant to a certain deed
whereby the title to the property was conveyed to the Plaintiffs by deed of
November 21, 2011, with James P. Halkias being the Grantor and the Plaintiffs
being the Grantees. A copy of said deed is attached hereto and marked Exhibit
`A'. Said deed was recorded in the Cumberland County Recorder of Deeds Book
on November 23, 2011, at Instrument No. 201132693.
5. Although the Plaintiffs are the legal title holders to the Subject Property, the
Defendants are unlawfully and illegally occupying the Property without any right
or authority of law.
6. Plaintiff has given the Defendants written notice of their ownership of the
Property and, despite such notice, Defendants have refused to remove themselves
from the Property.
7. Defendant Michael A. Witmer, Sr., was a prior owner of the Subject Property
having acquired the Property from deed of Roland Witmer dated August 8, 1989,
as recorded in the Cumberland County Recorder of Deeds Office in Deed Book
34C Page 501. However, the Subject Property was sold to the mentioned James
P. Halkias pursuant to a Tax Claim Bureau Deed dated November 15, 2011, and
recorded in the Cumberland County Recorder of Deeds Office at Instrument No.
201132304.
8. Plaintiffs acquired valid and legal title to the real estate pursuant to the mentioned
deed from Halkias to the Plaintiffs and Defendants have no right to claim title to
the Property nor any right to occupy the Property.
Wherefore, Plaintiffs request your Honorable Court to enter an Order evicting the
Defendants and any other individuals from the Subject Property and declaring further that the
Plaintiffs are sole legal title holder of the Property and that the Defendants have no claim to title.
Dated: February /a , 2012
C
?/w 0'? r
Hubert X. Gilroy, squire
Martson Law Of ces
10 East High Street
Carlisle, PA 17013
(717) 243-3341
ID #29943
Attorney for Plaintiffs
VERIFICATION
The foregoing Complaint is based upon information which has been gathered by my
counsel in the preparation of the lawsuit. The language of the document is that of counsel and
not my own. I have read the document and to the extent that it is based upon information which
I have given to my counsel, it is true and correct to the best of my knowledge, information and
belief. To the extent that the content of the document is that of counsel, I have relied upon
counsel in making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section
4904 relating to unsworn falsification to authorities, which provides that if I make knowingly
false averments, I may be subject to criminal penalties.
STEVEN R. STRAYER
VERIFICATION
The foregoing Complaint is based upon information which has been gathered by my
counsel in the preparation of the lawsuit. The language of the document is that of counsel and
not my own. I have read the document and to the extent that it is based upon information which
I have given to my counsel, it is true and correct to the best of my knowledge, information and
belief. To the extent that the content of the document is that of counsel, I have relied upon
counsel in making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section
4904 relating to unworn falsification to authorities, which provides that if I make knowingly
false averments, I may be subject to criminal penalties.
CARRIE M. STRAYER
3; X603
er
SPECIAL WARRANTY DEED
Tex parcel #39-13-0104-057
This Deed, made the 21" dry of November 2011
Between
JAMES P HALIMS
(hereinafter called the Gramors), of the one pert, and
STWEN SJ AYXR AND CAIRRM SIfRAYER,
(bell .- called the Grantee), of the odrer part,
WitnCSSCth that the said Grab rs for and in cousidaration of the sum of TEN THOUSAND cad
001/100 DOLLARS ($10,000.00) lawfd money of the United States of America, unto them we fl and truly
paid by the said Graa/ee, at or bedale the selling and delivery ha=C the receipt whereof is hereby
ackrawledged, bas cold, bequeathed, aliaaded, trmden%4 rammed, released and quit-clairued, and by
these pnwob does sail, bequesk treader, remise, release and quit-claim unto the wild Graa v, as sole
owner, his hags and aesi
ALL that ca tm land located m Southampton Township, C%unberland County
Pem aylvenia as dowled in Exhibit A:
Being the name pmpaty as Unsfeaed to Grmlor as reoorded in Deed 0201132304 as
recorded die 21" of November 2011.
Together with an and aingdar the tenemems, boroditam mb cad appurborrmoes,
beloogin& or is any wine appertaining, and the r+eveeaioas, rememda% rema, issues and profits thereof,
and also, all the estates, dgbt, tide, I Me , a tproperty, claim and demand whsboeever as well in law as in
equity, of the said party of the first pot, of, in, or to the abow4Wcriibod premises, and every pert end
parcel t mwC with the appurtonanoes.
To have and to hold the aid lot or piax of ground dendbed promises together with the
appuatenances, unto the said Grantee, his heirs cad assigner, forever.
In Witness Whereof, the party of the fist part has hereunto set her hand and seal. Dated the day
and year fist above written.
SBALBD??tAND DELIVERED
OIN PRESENCE OF US:
L
_jM
{SEAL}
P a
s
s:worrddccs/rea1Jfi1es/0RT-3884 Quitclaim deed 1
EXHIBIT 'A'
. ., -
Stdo Of Wok a
County of ft. I a4
On this the QW&Y of 2011, befae me, tea =WwWpod Nd" Pddic,
peraonan weared Jcc P Baltic, kum m do me (Or $Bds&ck% ly proven) to be the person whose name
is sabscrrI I I to the vAMIJ11111 iaatmilnaft, and adbiowiedpd that he eaaecured the s for ft F mpoaes therein
oosttaioed. ,
1N W17NMS WHM", I hMMdD set myhw#Imd of3'WW seal.
I , v? Notary PfbHo
Pubsc My o 'ssioo Mpbw
no a&km of the above-nsmod Craw w is:
1 :fM+ytn&9,C e Ott-Vt.
S }???at? P 117; 57
On boMWof the GAWe
s.worrddoc3lreat/file3l0RT-3884 Quitclaim deed
Appendix "A"
11" DesortM M
=Tu P+orod No. 39.13-01044S7
ALL THAT C WANG xwA hm WO baifd P aectsd tLaasoa s haW is
Soa atplo - Taaoa* Cou* ofCambae W sed Son 43tPeosrylaaL, addssoeibed
b tL?ee e?oiaia?p telcb asilows;
190.1- A+ffi?fG at a bbb q atasor an oae of hod am or of
Oeoepp waMara tbs pt?biia saiodL¦diog ll?os Sleet c2oao>ib Na i Ow Ba * *ww
doeg acid reed Nadh 27J dsp n want, 4523 1 aio6ss b a smw theses d" ionda
am or dosa?ecbr o0wei a liI asd Lresiodw d Noah 57.3 lopes Wsat, 35.23
F. Am b alooes; theses doap Lode am a ha elft at Gemp CbVM4 aai 15
dry nee slug the odd bed. Soath 875 dapm Bess, 44 bo ft *M of
BBt OMM.
COIrTTAII 4012 acres. . a Lr
N06 2 - PIING at an h= peg in the midiia of do pablic road waft
Sooeo the Sloes Ch web a Ne. 1 On Bx* *an by Lad now or iLeaaa b of Jamb
Hds6 Naedi 70 dwtas went; 22 v * 6bee b a afoot dimes by Lade am orAea?aebr of
Owpe lL 9eeoaet, Son& 33 depea west. 333 podw a a aloe; theses by lead ww
or 11 13 of Ieosa 1daBaft desoribe? *bo?rR Saar 56 dsHer Bast, 34 pasObsab a
post is the MWO of odd raid. Noah 1,1.23 derv.6 But 23.41- ch,s to the plsor of
BBODd M.
CONTAD M 4 aaaes and, 3,5 peed
10.3 - G at a post an gw-,gatheert,ooeosr of dw U=t and on a
k net d isotas l?fsHitb. IN.Aw abase; thoaoa d"
comer a[ eerier L¦ds aow or
So odd Lad 8=615 dWww lot 43 paaAw b a now of Lied asw or Sooafy of
Atit wW BM -.NJ e. IF ehenoa dns west, 7peeorasb assawraflad emote 11 of
amps Cbm, thseoa aisag dw Masse` Nadh 13 dspw VW&43 paseitsa b a oounc on
llae of Lwde aowar l ,b, of Gsorpe Clem dnewdns B@d 7 peeobea to life praoa of
B13?iDVNII?iti .
COIVTA1NDd('i 2 noses„ neat a?eoaa<a ,; • ': ,
LB88 M)WZM pero009.13.0104-iliiS and 39-13=0104-10&
DENG the same propsgy, Mldob Roiood Witmer by deed dated AMM 8, 1989
mad reocedeA in tbs Office - of the Rbootuier of Deeds is aid hr dw Coady of
Caabadead, Pbong4vaeia in Boot C34, Pepe $01, paaeeed sod coavsyed b Midod A.
Witmer 8r.
I ii
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number - 201132693
Recorded On 11/23/2011 At 11:08:58 AM
* Iastrmaent Type - DEED
Invoke Number - 97304 User ED - KW
* Grantor - HALL IAS, JAMES P
* Grantee - STRAYER, STEVEN
* Customer - STEVEN STRAYER
* Fuss
STA22 TRANSrZR TALC
STATZ WAIT TAX
STATZ JCS/ACCESS TO
JUSTICE
RECORDING FM
ROEA Or DEEDS
PARCEL CZATIFICATIOtN
rus
AFFORDABLE HOUSING
COUNTY ARCHIVES nm
ROD ARCHIVZS In
SBIPPMMBUAG AREA
SCHOOL DISTRICT
SOUTBAIIPTt9lN TOIINSHIP
TOTAL PAID
$100.00
$0.50
$23.50
$11.50
$10.00
$11.50
$2.00
$3.00
$50.00
$50.00
$262.00
* Total Pages - 4
Certification Page
DO NOT DETACH
This page is now part
of this legal document.
I Certify this to be recorded
in Cumberland County PA
f
RECOnnax o????
" - Iaformaties denoted by as asterisk may change dada`
the verification proem and may not be re0edW on thk pegs.
MWOM
11KI111111
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff +) ; "' r
Jody S Smith u
Chief Deputy -'
?`; 16 16 l
Richard W Stewart
Solicitor OFF C00`
Steven R. Strayer (et al.) Case Number
vs.
Michael A Witmer, Sr (et al.) 2012-874
SHERIFF'S RETURN OF SERVICE
02/13/2012 10:13 AM - William Cline, Corporal, who being duly sworn according to law, states that on February 13,
2012 at 1013 hours, he served a true copy of the within Complaint in Ejectment, upon the within named
defendant, to wit: Occupant of 175 Whitmer Road, Shippensburg, Pennsylvania 17257, by making known
unto Ashley Brukett, adult in charge at 175 Whitmer Road, Shippensburg, Cumberland County,
Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct
copy of the same.
ILLI M CLINE, DEPUTY
02/13/2012 10:13 AM - William Cline, Corporal, who being duly sworn according to law, states that on February 13,
2012 at 1013 hours, he served a true copy of the within Complaint in Ejectment, upon the within named
defendant, to wit: Michael A. Witmer, Sr., by making known unto Ashley Brukett, adult in charge at 175
Whitmer Road, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same
time handing to her personally the said true and correct copy of the same.
WILLIAM CLINE, 15EPUTY
02/13/2012 10:13 AM - William Cline, Corporal, who being duly sworn according to law, states that on February 13,
2012 at 1013 hours, he served a true copy of the within Complaint in Ejectment, upon the within named
defendant, to wit: Lori Witmer, by making known unto Ashley Brukett, adult in charge at 175 Whitmer
Road, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing
to her personally the said true and correct copy of the same.
7-y
W LLIAM CLINE, DEPUTY
02/13/2012 10:13 AM - William Cline, Corporal, who being duly sworn according to law, states that on February 13,
2012 at 1013 hours, he served a true copy of the within Complaint in Ejectment, upon the within named
defendant, to wit: Justin Gallo, by making known unto Ashley Brukett, adult in charge at 175 Whitmer
Road, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing
to her personally the said true and correct copy of the same.
WILLIAM CLINE, DEPUTY
r ",ounb a a t ,,.»ti. I;-
SHERIFF COST: $96.45
February 14, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
?oumvsjlll"
??
IN THE OURT OF COMMON PLEAS OF
PLAINTIFF :eti?('a'lr?C'• CUMBERLAND COUNTY, PENNSYLVANIA
V. : DOCKET NO.
CIVIL ACTION-LAW -UZ Z -?
DEFENDANT zM rn m
y?)Ey Sly : ter- N ?M
. ?>
ANSWER OF DEFENDANT
°i c-n
Defendant, 'r) Chat)/ /)-. 4) a fr-r?e.F , does hereby answer the Complaint in this matter as
follows:
2.?? yr) m i ?'P L- ?. U ??
3._ i__?1 I?Y1L?
4._
5.
7. Aj
s.
WHEREFORE, ?nd prays that the Complaint be dismissed.
r
efendant Pro Se
VERIFICATION
state that I am a defendant in this action and that the
statements made in the foregoing Answer are true and correct to the best of my knowledge,
information and belief. I understand that the foregoing statements are made subject to the penalties
of 18 Pa. C.S. §4904 relating to unworn falsification to authorities.
Date:
Defendant Pro Se
: IN THE OURT OF COMMON PLEAS OF
PLAINTIFF fir? Std CUMBERLAND COUNTY, PENNSYLVANIA
V. : DOCKET NO.
CIVIL ACTION-LAW
DEFENDANT
CERTIFICATE OF SERVICE
I, Lb ' j 1j? S `6,-M - 12- , hereby certify that I served a true and correct copy of
the attached Answer on L--4u b Y. 1 r c at
1
by first class mail, postage prepaid, on the date below.
r
Dated:
Defendant Pro Se
C?
PRAECIPE FOR LISTING CASE FOR TRIAL :zm
-=0
"ur
-<> N C)
(Must be typewritten and submitted in triplicate) -<?
- ?;
r ; 0 ? -r
TO THE PROTHONOTARY OF CUMBERLAND COUNTY ; --
Please list the following case:
? for JURY trial at the next term of civil court.
X? for trial without a jury.
----------------------------------------------------------------------------- -------------------
--.-----------
--------
CAPTION OF CASE
(entire caption must be stated in full)
Steven R. Strayer and
Carrie M. Strayer
(check one)
X? Civil Action - Law
? Appeal from arbitration
(other)
(Plaintiff)
vs.
Michael A. Witmer,
Sr., Lori Witmer Justin
Gallo & Other
Unnamed Individuals (Defendant)
vs.
The trial list will be called on March 27
and
Trials commence on April 23
Pretrials will be held on April 11
(Briefs are due S days before pretrials
,,,- 2012 874
Indicate the attorney who will try case for the party who files this praecipe:
Hubert X. Gilroy, Esquire
Term
Indicate trial counsel for other parties if known:
This case is ready for trial.
Date: March I , 2012
75
4-41 _?71 sr5 7
Signed:
Print Name: H
Gilroy
Attorney for: Plaintiffs
STEVEN R. STRAYER and
CARRIE M. STRAYER,
Plaintiff
V.
MICHAEL A. WITMER, SR., LORI
WITMER, JUSTIN GALLO and OTHER
UNNAMED AND UNKNOWN
INDIVIDUALS
Defendant
IN THE COURT OF COMMON PLEAS OF
THE NINTH JUDICIAL DISTRICT
NO: 2012-874
IN EJECTMENT
IN RE: NON-JURY TRIAL
ORDER OF COURT
AND NOW, this 7T" day of March 2012, the case having been assigned to this
Court for the scheduling of the Non-Jury Trial, it will be held on Monday, 9 April
2012 at 1:30 p.m. in Courtroom No. 6 of the Cumberland County Courthouse.
Distribution List:
? Hubert X. Gilroy, Esq.
10 East High Street
Carlisle, PA 17013
/Michael Witmer, Sr.,
? Lori Witmer,
Austin Gallo,
9 Independence Drive
Shippensburg, PA 17257
-/Court Administration
By the Court,
Thomas A. Placey C.P.J.
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Cpra-?s m4" I ed 3/7 1
P-Y-
STEVEN R. STRAYER and
CARRIE M. STRAYER,
Plaintiff
V.
MICHAEL A. WITMER, SR., LORI
WITMER, JUSTIN GALLO and OTHER
UNNAMED AND UNKNOWN
INDIVIDUALS
Defendant
IN RE: NON-JURY TRIAL
NO: 2012-874
IN EJECTMENT
AMENDED ORDER OF COURT
AND NOW, this 9T" day of March 2012, the Order of Court dated 7 March
2012, is amended to provide the correct address for the defendant's listed on the order.
The remainder of the Order will be in full force and effect.
Distribution List:
W00000464W9 C*,"?Vht
It"
IN THE COURT OF COMMON PLEAS OF
THE NINTH JUDICIAL DISTRICT
By the Court,
Thomas A Placey C.P.J.
/ Hubert X. Gilroy
Esq
,
.
10 East High Street
Carlisle, PA 17013
, ...?
`Y' T
r
V Michael Witmer, Sr., ?- - +
r/ Lori Witmer, o'
-/Justin Gallo, rv =
175 Whitmer Road --
Shippensburg, PA 17257
-/ Court Administration
3?g10-
??/Z
L
r
Hubert X. Gilroy, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
I.D. 29943
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiffs
STEVEN R. STRAYER and
CARRIE M. STRAYER,
Plaintiff
vs
MICHAEL A. WITMER, SR.,
LORI WITMER, JUSTIN GALLO
and OTHER UNNAMED AND
UNKNOWN INDIVIDUALS,
Defendant
h C
• ? i ?t_74? iii ? v.,"??`? S
PEI" N N
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2012-874
IN EJECTMENT
ORDER OF COURT
??
AND NOW this day of April, 2012, the Court having convened a hearing in the
above matter at which the Plaintiffs offered various exhibits and offers of proof agreed to by the
Defendants, and the Defendants having appeared in the nature of Mrs. Lori Witmer who is the
wife of Michael A. Witmer, Sr., and the parties all being in agreement upon the entry of an
Order for a total resolution of this case, it is Ordered and directed as follows:
1. It is found as a fact that the Plaintiffs, Steven R. Strayer and Carrie M. Strayer,
are the legal title holders to the property at 175 Whitmer Road, Shippensburg,
Cumberland County, Pennsylvania, a legal description for said property being
attached hereto and marked Exhibit `A', and said property hereinafter referred to
as the "Subject Property."
2. It is Ordered and directed that the Defendants, Michael A. Witmer, Sr., Lori
Witmer, Justin Gallo and any other unnamed and unknown individuals who may
be residing or present on the Subject Property are hereby ejected and a Judgment
of Possession for the Subject Property is issued in favor of the Plaintiffs.
3. Upon the stated agreement of the parties and in consideration for the Plaintiffs'
agreement to allow the Defendants to continue to reside at the mobile home on
the Subject Property through and including June 30, 2012, the requirements of
Pennsylvania Rules of Civil Procedure 3160 et seq. relative to enforcement of
judgments in an action for ejectment are waived by agreement of the parties
subject to the conditions as set forth in this Order.
4. To satisfy the Judgment for Possession in the above matter, the Sheriff of
Cumberland County is directed to deliver possession of the Subject Property as
described in the attached Exhibit `A' to the Plaintiffs. As per the agreement of
the parties, the Cumberland County Sheriff may proceed with satisfying this
Judgement of Possession without further Order of Court or other proceeding in
this matter but may not proceed until July 1, 2012. In the event the Plaintiffs
desire the Cumberland County Sheriff to proceed with satisfying the Judgment for
Possession, the Plaintiffs must file a Praecipe for Writ of Possession with the
Cumberland County Prothonotary and provide a copy of that filing to the
Cumberland County Sheriff along with any advanced costs the Cumberland
County Sheriff may require in connection with execution of the Judgment.
5. As per the agreement of the parties, this Order shall be deemed to be a Final
Order of Court in this matter.
6. As per the agreement of the parties, the Plaintiffs are immediately granted access
to the Subject Property for purposes of evaluating a proposed location of a well,
surveying, or miscellaneous work consistent with the planning of the construction
of a home on the property. However, Plaintiffs' access shall not in anyway
interfere with the Defendants reasonable use and occupancy of the existing
mobile home on the property.
BY ,
Thomas A. a ey, Judge
cc: ? Hubert X. Gilroy, Esquire
Mr. Michael A. Witmer, Sr.
v/ Mrs. Lori Witmer
"ell C
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¦ EXHIBIT
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