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Home My WebLink About12-6724Johnson, Duffie, Stewart ~ Weidner By: Mark C. Duffie I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 mcd@jdsw.com JOHN R. SCHREIBER, JR PATRICIA A. SCHREIBER 940 South Homer Street Enola, PA 17025, ~ ~ ;..~.I Attorneys for Plaintiff: ; ~, ,;I r and IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT""Y, PENNSY VANIA_ : NO. ~ or1 _ v~~ ~ ~~ 11/ (( ~QYIM Plaintiffs v. RICHARD A. MORRIS and LORI FIRESTONE MORRIS 930 S. Homer Street Enola, PA 17025, Defendants NOTICE TO DEFEND CIVIL ACTION -EQUITY 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 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, Pennsylvania 17013 Telephone: (717) 249-3166 ~s~' a ~10~•~ S '~~ ~ a ~~a~a~~ AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificaci6n de esta Demands y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falls de tomar accion Como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier sums de dinero reclamada en la demands o cualquier otra reclamation o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes pars usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 Johnson, Duffie, Stewart 8~ Weidner By: Mark C. Duffie I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 mcd@jdsw.com JOHN R. SCHREIBER, JR. and PATRICIA A. SCHREIBER 940 South Humer Street Enola, PA 17025, Plaintiffs v. RICHARD A. MORRIS and LORI FIRESTONE MORRIS 930 South Humer Street Enola, PA. 17025, Defendants Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION -EQUITY COMPLAINT AND NOW, this 2nd day of November, 2012, comes the Plaintiffs, JOHN R. SCHREIBER, JR. and PATRICIA A. SCHREIBER, by and through their undersigned attorneys, Johnson, Duffie, Stewart & Weidner, and files this Complaint against Defendants, Richard A. Morris and Lori Firestone Morris, and in support thereof avers as follows: 1. Plaintiffs, JOHN R. SCHREIBER, JR. and PATRICIA A. SCHREIBER, husband and wife, are adult individuals currently residing at 940 South Humer Street, Enola, Cumberland County, Pennsylvania 17025. 2. The Defendants, Richard A. Morris and Lori Firestone Morris, husband and wife, are adult individuals. Richard A. Morris currently resides primarily in Perry c:,ounty and occasionally at 930 South Humer Street, Enola, Cumberland County, Pennsylvania 17025. Lori Firestone Morris currently resides at 930 South Humer Street, Enola, Cumberland County, Pennsylvania 17025. 3. The Plaintiffs are owners of real property municipally known and numbered as 940 South Humer Street, Enola, Cumberland County, Pennsylvania, described as follows: ALL THAT CERTAIN piece or parcel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the center line of a twenty (20) foot private road, said point being referenced one and two hundred ninety-six thousandths (1.296) feet in a southerly direction from the center line of the intersection of said private road with Township Road T-625; thence along the line of land now or formerly of Schreiber, North 89 degrees 11 minutes 00 seconds East, two hundred eight and seventy hundredths (208.70) feet to an iron pin; thence along the same North 03 degrees 34 minutes 00 seconds West, one hundred four and zero hundredths (104.00) feet to a point; thence along the same, North 89 degrees 11 minutes 00 seconds East, fifteen and four hundredths (15.04) feet to an iron pin; thence along the line of land now of Murray, South 09 degrees 25 minutes 00 seconds East, four hundred sixty-six and thirty-three hundredths (466.33) feet to an iron pin; thence along the same North 83 degrees 19 minutes 00 seconds East, forty- two and zero hundredths (42.00) feet to a point in the center line of Creekside Drive, South 05 degrees 08 minutes 00 seconds East, three hundred four and sixteen hundredths (304.16) feet to a point; thence leaving Creekside Drive, South 86 degrees 26 minutes 00 seconds West, one hundred twelve and fifty- seven hundredths (112.57) feet to an iron pin at the line of land now or formerly of Miller; thence along the line of land now or formerly of Miller, North 03 degrees 34 minutes 00 seconds West, two hundred eight and seventy hundredths (208.70) fee to an iron pin; thence continuing along the same South 86 degrees 26 minutes 00 seconds West, two hundred eight and seventy hundredths (208.70) feet to an iron pin in the center line of a twenty (20) foot private road; thence continuing along the center line of said twenty (20) foot private road, North 03 degrees 34 minutes 00 seconds West, four hundred sixty-three and sixty-nine hundredths (463.69) feet to the place of BEGINNING. CONTAINING 3.36 acres of land according to a survey made by William B Whittock, Professional Engineer, dated June 1, 1972. 4. The Plaintiffs purchased 940 South Humer Street, Enola, Pennsylvania on July 2, 1984 from Miller E. Murray. Said Deed was recorded on July 17, 1984, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book U-30, Page 415. 2 5. Defendant, Richard A. Morris and his former wife, Jolene D. Morris, are the titled owners of real property known and numbered as 930 South Humer Street, Enola, Cumberland County, Pennsylvania 17025. Jolene D. Morris passed away on September 14, 2000 thereby vesting title in the Defendant, Richard A. Morris. Said real estate is further described as follows: ALI. THAT CERTAIN piece or parcel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the bed of Humer Street (a 20 foot private right-of-way) at the division line between Lots No. 2 and No. 3 of the hereinafter referenced Subdivision plan; thence in an easterly direction along line of Lot No. 3 North 84 degrees 09 minutes 40 seconds East a distance of 248.83 fee to an iron pin; thence along line of land no or formerly of Milton E. Murray and along line of land now or formerly of Vera E. Murray South 10 degrees 48 minutes 50 seconds East a distance of 95.28 feet to an iron pin at the line dividing Lot No. 2 and Lot No. 1 of said Plan; thence along line of Lot No. 1 South 84 degrees 09 minutes 40 seconds West a distance of 260.86 feet to a point in Humer Street; thence North 03 degrees 34 minutes West a distance of 95.00 feet to the place of BEGINNING. BEING Lot No. 2 on the Final Subdivision Plan for John R. Schreiber, Jr. recorded in Plan Book 46, Page 145, Cumberland County Recorder of Deeds Office. 6. Defendant, Richard A. Morris, acquired said property from John R. Schreiber, Jr. and Patricia A. Schreiber by Deed dated May 10, 1985, and recorded on May 10, 1985, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book 31-G, Page 136. 7. It is believed and therefore averred that Lori Firestone Morris is the wife of Richard A. Morris and currently resides at 930 South Humer Street, Enola, Pennsylvania 17025. 8. It is believed and therefore averred that the Defendants, Richard A. Morris and Lori Firestone Morris have been separated periodically over the past two (2) years. 3 9. Beginning in late spring or early summer of 2011, Defendant, Lori Firestone Morris, began digging and creating flower beds on the rear left corner of the Plaintiffs' property located at 040 South Humer Street, Enola, Pennsylvania. 10. Plaintiffs have informed Defendant, Lori Firestone Morris, on numerous occasions to discontinue digging or planting flower beds on Plaintiffs' property but Defendant, Lori Firestone Morris, has disregarded these directives. 11. Defendant, Richard A. Morris, has also been informed of Defendant, Lori Firestone Morris' actions and has failed to deter any further conduct. COUNT I -QUIET TITLE PURSUANT TO PA.R.C.P. 1061(2) and (3) 12. Plaintiffs' incorporate, by reference, the allegations in Paragraphs 1-11 as if the same were set forth herein at length. 13. The Defendants, by their actions, are encroaching and trespassing on Plaintiffs' property. WHEREFORE, Plaintiffs request this Honorable Court to enter an Order forever barring the Defendants from entering onto or asserting any interest in the portion of Plaintiffs' property upon which Defendants are encroaching, direct the Defendants to pay Plaintiffs' attorneys' fees and issue any other relief that this Court deems appropriate. 4 COUNT II -ACTION IN EJECTMENT 14. Plaintiffs incorporate, by reference, the allegations in Paragraphs 1-~13 as if the same were set forth herein at length. 15. The Defendants have no valid legal right to possession and title of the section of Plaintiffs' property upon which Defendants are encroaching. 16. Plaintiffs are and have been in possession of the portion of Plaintiffs' property upon which Defendants are encroaching. WHEREFORE, Plaintiffs request this Honorable Court to enter an Order forever barring the Defendants from asserting any interest in the parcel owned by Plaintiffs as evidenced by the Deed of record, direct the Defendants to pay Plaintiffs' attorneys' fees and issue any other relief that this Court deems appropriate. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER .- ~ By: ark o . Duffie 301 Market Street P.O. Box 109 Lemoyne, PA 17043 (717) 761-4540 Attorney for Plaintiff 515402 5 VERIFICATION I, JOHN R. SCHREIBER, JR. and PATRICIA A. SCHREIBER, do verify that the statements made in the foregoing Petition are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ~, ,, '~ HN R. SCHREIBER, JR./~ .- - , PATRI IA A. SCHREIBER 6 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson ~=;~.trt1-ut" k' I: Sheriff ..?° ~j~ r ~t~~~{'~'~ I,~`A..;; ~~~~tt<' ~t ~arir:bF,~~~~i Jody S Smith ~ ~~ ~ 2 ~~~ ~ ( ~~ ~: ~~ Chief Deputy -- Richard WStewart CU~iBERLAFdU (U~'j~~°' soiicitor ;~Y~' ` " <.:~"'~ P~t~NSYLVAk~I~, John R Schreiber (et al.) Case Number vs. 2012-6724 Richard Morris (et al.) SHERIFF'S RETURN OF SERVICE 11/09/2012 06:43 PM -Deputy Dennis Fry, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Lori A Morris at 930 S Humer Street, East Pennsboro, Enola, PA 17025. ---~ / "" DENp S FRY, DEP SHERIFF COST: $43.45 November 14, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF t4OTARY Mark W.Allshouse,Esquire OF T E 0-1 Attorney ID#78014 4833 Sprinp,Road 29 PM 3* Shermans Dale,PA 17090 (717)582-4006 CUM� BERLARD COUN' Ty Attorney for Plaintiff JOHN R. SCHREIBER,JR. and IN THE COURT OF COMMON PLEAS PATRICIA A. SCHREIBER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO. 12-6724 RICHARD A. MORRIS and LORI FIRESTONE MORRIS, Defendants CIVIL ACTION—EQUITY NOTICE TO PLEAD TO: Mark C. Duffle, Esquire, Attorney for Plaintiffs JOHNSON, DUFFIE, STEWART& WEIDER 301 Market Street P.O. Box 109 Lemoyne, PA 17043,Plaintiff You are hereby notified to file a written response to the enclosed Counterclaim within twenty(20)days from service hereof or ajudgment may be entered against you. Respectfully submitted, Date: 7 -7 ark W. Allshouse ,E r re Attorney I.D. # 780 4833 Spring Road Shermans Dale,PA 17090 (717)582-4006 Attorney for Defendants Mark W.Allshouse,Esquire Attorney ID#78014 4833 Spring Road Shermans Dale,PA 17090 (717)582-4006 Attorney for Plaintiff JOHN R. SCHREIBER, JR. and IN THE COURT OF COMMON PLEAS PATRICIA A. SCHREIBER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO. 12-6724 RICHARD A. MORRIS and LORI FIRESTONE MORRIS, Defendants : CIVIL ACTION—EQUITY DEFENDANTS' ANSWER AND COUNTERCLAIM TO PLAINTIFFS' COMPLAINT AND NOW, come Defendants, Richard A. Morris and Lori Firestone Morris by and through their attorney, Mark W. Allshouse, Esquire, who respectfully files this Answer to Plaintiffs' Complaint and in support thereof and aver as follows: 1. Admitted upon information and belief 2. Admitted. 3. Denied. By way of further response, it is admitted that Plaintiffs received a Deed dated July 2, 1984 containing the afore-mentioned Deed description recorded in the Recorder of Deeds Office of and for Cumberland County, Pennsylvania in Deed Book U30, Page 415. However, by way of further response, thereafter on or about November 20, 1984 a Final Subdivision Plan for John R. Schreiber, Jr. as prepared by John Brilhart and approved by Cumberland County Planning Commission and East Pennsboro Township, attached hereto as Exhibit"A", subdivided that entire tract into four(4)parcels. By way of further response,by Deed dated May 10, 1985, attached hereto as Exhibit"B", John R. Schreiber, Jr. and Patricia A. Schreiber, his wife, conveyed unto Defendant what is known as Lot No. 2 on the Final Subdivision Plan as attached hereto and made a part hereof as Exhibit"A". It is further believed and,therefore, averred that Plaintiffs have never done a residual tract Deed and, as a result, the lots conveyed from the above-referenced Subdivision Plan must first be excepted out of that Deed prior to determining what lands are actually still owned by Plaintiffs. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted. 9. Denied. To the contrary,the flowerbeds created by Defendant are believed to be within Defendants' property line as shown on the Subdivision Plan and described within their Deed as set forth herein. 10. Admitted. By way of further response, Defendants disagree with Plaintiffs' interpretation of the boundary line and as a result, Defendants continued utilizing the flowerbeds on the property. 11. Admitted. 12. Denied. Paragraph 12 is a paragraph of incorporation to which no response is necessary. 13. Denied. Paragraph 13 is a conclusion of law to which no response is necessary. WHEREFORE, Defendants respectfully request this Honorable Court to enter judgment in favor of Defendants and against Plaintiffs thereby dismissing Plaintiffs' cause of action for quiet title. 14. Denied. Paragraph 14 is a paragraph of incorporation to which no response is necessary. 15. Denied. Paragraph 15 is a conclusion of law to which no response is necessary. 16. Denied. Paragraph 16 is a conclusion of law to which no response is necessary. By way of further response, Plaintiffs' right to possession terminated upon conveyance to Defendant. WHEREFORE, Defendants respectfully request this Honorable Court to enter judgment in favor of Defendants and against Plaintiffs thereby dismissing Plaintiffs' cause of action. COUNTERCLAIM Prescriptive Easement 17. Paragraphs 1 through 16 are hereby incorporated by reference as if set forth at length. 18. Defendants, since moving into their property in October 1986, have continuously used and utilized the property in dispute along the adjoining border with Plaintiffs and have specifically used and utilized the property as follows: a. Installation of a drain/drain field b. Added significant amount of fill and dirt to level their yard area C. Placed brush and grass clippings in and along the property d. Conducted family picnics and recreation e. Utilized it for sled-riding in the winter £ Driven their vehicles and yard equipment across the property g. Continually mowed and maintained the yard h. Maintained, cut and trimmed tree(s) located in the area i. Added plants and flowers, mulch and bedding material 19. Defendants have openly, notoriously and adversely utilized this property or a period in excess of twenty-one (21) years. 20. As a result of the foregoing, Defendants have established and met the requirements and are legally entitled to use by prescriptive easement over the disputed property located along the property lines between the lands of Plaintiffs and Defendants. WHEREFORE, Defendants respectfully request this Honorable Court to enter judgment in favor of Defendants confirming Defendants' right to prescriptive easement and continued use of the disputed property. Adverse Possession 21. Paragraphs 1 through 20 are hereby incorporated by reference as if set forth at length. 22. This cause of action is being plead in the alternative. 23. Defendants have maintained adverse, open and continuous possession of the disputed property running along the adjoining border between the lands of Plaintiffs and Defendants for period in excess of twenty-one (21)years. 24. Defendants' use has been without license or permission. 25. Defendants have possessed the property and have maintained it as their own as set forth in paragraph 18 (a) through (i) above. 26. The property in dispute does not constitute unenclosed woodlands. 27. Defendants have established a claim of adverse possession to the disputed property. WHEREFORE, Defendants respectfully request this Honorable Court to enter judgment in favor of Defendants confirming Defendants' adverse possession. Respectfully submitted, Date: 40b, ark W. Allshouse Esquire Attorney I.D. # 78014 4833 Spring Road Shermans Dale, PA 17090 (717) 582-4006 Attorney for Defendants Exhibit "A" s ees cell _ Hawthorne RvenuL RO I ¢ of S'cs 0l 1ISIO 296'to e°E�`sio t. o' ' -�Z - _ MUM�R STREET 20 R1W F 10't Mac.pavement) c°�v u R �R N 08a 94'00'W c of Right of Woy Line 46.69 vIKE SPIK r� r '- 93-69r 96.00 95.00 90.00 o _ 1112.4 -� r'p�42 -0 O DEDICATED )E' RIGHT ,(oF WRY h LINE 9 p`r} E•in N co 420 o 0 Minimum Suildinq 5+ bock m Line' M LOCATION MRP $honk Jaffrey O 600 1200 Lance J. Rtlond 3:1 -� •N Iy v� • X45 -",A n mmv I►Oa0m_�p0, SCALE IN FEET als Q ) —OW gI r Zacn� 3 2QN �ro ��O NNO �O rT10.� �. Z_ m pcnN o N N °°s n I - 1. 0)c. v vN— d ON O_�a3 N-400 '/' ess R�W-(Z3 14� -�� Q1 J„3 J oa J_ 0 395 N 01 O a3 O wC I•a m Z 410 N I.406 Re- O--Nw- a p�,w O,p 2 °� v N Olean,00 W 20 O / 61,299 sq.Ft`.a '1 i�v O 2 0_-39D•B6 30 L_N 00 E 3 TIME W W1 IV. T'p1m _38 390�y 0 7,01 _„� _9�.5 {II$ 385 `380 N '1 y0 -5sa'� _ �O{- r�-3ea_ ns —`f ` u! 29 9533 OS 8b PI r+ QAa bl 310 .Sctbock—Llnc 5. Min..61�- R m� � �z __ tea' � / �� IPM 80.43 315 - fi-`23y--ko Murray aQ pt.UI C RTTL�RIG OF WRY�i1NE �v�3� g I E m a 40- 99nC 30 .0 0 3y1 I Milton 0 25® . p33s_ I �� _ 16.g'- -- � Vera E SCALE IN FEET `RSP1k_TC{31 3 i.b0�•� AA Murray EROSION CONTROL CREEK2SIDE DRIVE 33 R�W� Npa L.R. 210'18 0.D• 1. stripping of vegetation and grading h't Moc. POvetncnt) I'i pp g g g ng shall be donp in such NOTES: a canner u.131 aWzats.erosion. Total Area: 9.319 Acres Arco Zoned;R-1 Residential Sin le. Fomily. va o a i 2. To the largest degree feasible,paturel vegetation shall be $ awo retained,.protected and suppiemeoled. Contours token from actual Field Survey. iY °J°o relit case peeesbam_ • Represents probe and Pere Arco. Win, ON 3. Disturbed areas,and the duration of espo3ure thereof,shall i - IWnoeipality •'Iron Pin sit ° be kept to a practical minimns. , plat Name c T I Neviewed by cite onvberlend county ■ Conc.Monument e 4. Disturbed areas shall be re-itraded and seeded with perament I plant.,coa°ia-sit°°Nov 20,1984- 'i oo—°' cover as soon as weather and/or construction r p progress exalts. � i'.s ma •p �G: ' It is hereby certified tha��ie undervgne -tics Legal or ! eTairmn haw ; Equitable,Title to the Land shown hereon and at I roods seeratary w or ports thereof shown hereon if not previous) yy j Owner S Subdivider: dedicate d,ore herebytenderedfor dedicationto Punkuse. �- -- John id R. Schreiber 21 Hudi Terrace Owner Reviewedthisday of A✓g 1984,bythe Comp Hill Pa. 11011 East PennsboroTogwnship Engineer. phone:11�-192-3813 ' Commonweol't of Pennsylvania SS ��.�s-•lit!!/ � Engineer county of Cumberland -� FINAL SUBDIVISION PLAN Onthis 916 day e—QL-ML&e 1984,bcfoTe me,a Recommended thi s-ZiLdoy of-+µ- ti 1984,by tht FOR notary pas ,,the undcrsigned personally appeared, East Pennsbaro Township Planning Commission. JOHN Q. SCHREIBE R, JR. who acknowledged this pion to be his act and decd and / �,� •Qn,n,_ desires the s me to be recorded as such. .I�aESfis.._.u�ZSdt`�. Sd.��ddlllp- CAST PENNSBORO TOWNSHIP J __ CZ� a� 7� Owner Ch��Io(((i��rmon �,',• '., ecretory CUMBERLAND COUNTY, PR. sJ/ l,=lR _ Rpprovedthisoy of "^'"=^'`� 1984,byttx SCALERS SHOWN OCT. 23,1984 M Wit!1ncs whereof A•1 hereunto set my hand and scot. East Pennsbor To ship Comnlm�i.'ssioners. Revised Nov. 5,19B4 =f a-L5- M. lXtKt✓ Notary Public 'n3^,alt.t,n'yl.uli Hwt4 esidexrt Secretory My Commission,Expires MZ-b- 1�_ 19 I'S o I hereby certify that this 'plan is correct o5 wslt surveyed and plotted o shown hereon. auuls a.ARM mles ..� �t ' c'•.. --�f John C. Brilhort � Profe ionol Land Surveyor a Survcyinq { Mopping Services Recorded in +he Recorderl�''�} Office in aid 30 W.Allen Street County in Plan Booker Poge�. Mechanicsburg, Pa. A �- T Exhibit "B" 21114T—Wartanl r Deed-„hart Form--Act 1909—Double Sheet Henry Hall, Inc., Indiana, pa. to MADE THE f 0 MA day of M c._� in the year of our Lord one,thousand nine hundred eighty-five O BETWEEN JOHN R. SCHREIBER, JR. and PATRICIA A. SCHREIBER, his wife, of East Pennsboro Township, Cumberland County, Pennsylvania, parties of the first part, zn c_ c Grantor s, A 'and 1= RICHARD (NMN) MORRIS and JOLENE D. MORRIS, his wife, c�a of East Pennsboro Township, Cumberland County, Pennsylvania, parties of the second part Grantee s: WITNESSETH, that in consideration of FIVE THOUSAND FIVE HUNDRED and NO/100 ------------------------------------------------------------Dollars, in hand paid, the receipt whereof is hereby acknowledged, the said grantor s do hereby grant and convey to the said grantee s, ALL THAT CERTAIN piece or parcel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the bed of Humer Street (a 20 foot private right-of-way) at the division line between Lots No. 2 and No. 3 of the hereinafter referenced Subdivision Plan; thence in an easterly direction along line of Lot No. 3 North 84 degrees 09 minutes 40 seconds East a distance of 248.83 feet to an iron pin; thence along line of land now or formerly of Milton E. Murray and along line of land now or formerly of Vera E. Murray South 10 degrees 48 minutes 50 seconds East a distance of 95.28 feet to an iron pin at the line dividing Lot No. 2 and Lot No. 1 of said Plan; thence along line of Lot No. 1 .South 84 degrees 09 minutes 40 seconds West a distance of 260.86 feet to a point in Humer Street; thence North 03 degrees 34 minutes West a distance of 95.00 feet to the place of BEGINNING. BEING Lot No. 2 on the Final Subdivision Plan for John R. Schreiber, Jr. recorded in Plan Book 46, Page 145, Cumberland County Recorder of Deeds Office. UNDER AND SUBJECT to conditions, easements, rights-of-way and restrictions of prior record. TOGETHER with the right of ingress, egress and regress to the Grantees, their heirs and assigns, over and along the said twenty (20) foot private road from Township Road T=-625 to the land above described, in common with other users of said road. /part of BEING the same premises which Milton E. Murray, single man, by deed dated July 2, 1984, recorded in the Cumberland County Recorder of Deeds Office in Deed Book "U", Volume 30, Page 417, granted and con- veyed unto John R. Schreiber, Jr. and Patriciia A. Schreiber, his wife, grantors herein. �- Sc►.oul f3w+. CWNb Co.. Pa. towaditp of ;; d S� 51 b E �" .. �G9t—goal Aeb TtaAlar Tax Pa. )a+a /.Q .�AM•'2`••''^r rt..r Ea+ah TrMtfar T. BOOK( A PAGE 136 �d�c��` •�r`"`� oars ApbIts And the said grantors hereby covenant and agree that they will warrant generally the property hereby conveyed. CUMMONWLAI'ff{ P[tiN `fiY Pd1.4 DEPARTMENT OF REVENUE PEA: - u, TAX FER KfYI; •o m v 9 •.I N tH N O ( 3 d rA r. s0 0 >-4 rx ac 3� h w � � •� m 9 "ate Z 06 w a wa Oua x 4 £ 0 a z 'Q H Q Q xu aw H KC z z 9 xE- w � a O4 O h a 3 a h COMMONWEALTH OF PENNSYLVANIA County of --- - RECORDED on this ................... Q--- day °f --------------------------------- A. D. 19.8, ., in the Recorder's office of the said County,in Deed Book G Vol. _J1............Page ---f-a&--------- Given under my hand a al.of th'�aiASr , the date above written. _--------------------------------------------------------------- Recorder. VERIFICATION We, Richard A. Morris and Lori Firestone Morris, verify that the statements in the foregoing document are true and correct to the best of our knowledge, information and belief under penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: Z�� Richard A. Morrisl�� «�i/a l� Date: or1 Firestone Morris ko0 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document has been duly served upon the following, by depositing a copy of the same in the United States Mail, first-class, postage prepaid, as follows: Mark C. Duffle, Esquire JOHNSON, DUFFIE, STEWART& WEIDER 301 Market Street P.O. Box 109 Lemoyne, PA 17043 Respectfully submitted, Date: ark W. Allshouse, quire Attorney I.D. # 780 4833 Spring Road Shermans Dale, PA 17090 (717) 582-4006 Attorney for Defendants