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Home My WebLink About12-6785Village of Moreland II Condominium IN THE COURT OF COMMON PLEA r,,,~ Cam? `~' -' i Association, :CUMBERLAND COUNTY, PENNS~~JA~6IA --+ Plaintiff z ~' ~ ~ -~ c~~) --~~ a ~ 7 ~s 1 ~ ~~- _ , -~ ~ ' ~} , f.,7 Village of Moreland, Inc., ~~ ~~ ~ r f Defendant °~ :ACTION TO QUIET TITLE "°' 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 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 Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Date: ~~/~/~~Z ~Glark W. Allshous Esquire Attorney ID # 780 4 4833 Spring Road Shermans Dale, PA 17090 (717) 582-4006 Attorney for Plaintiff ~k~~V3.ls~ A~ c Village of Moreland II Condominium IN THE COURT OF COMMON PLEAS Association, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. Village of Moreland, Inc., Defendant :ACTION TO QUIET TITLE COMPLAINT TO OUIET TITLE AND NOW COMES Plaintiff, Village of Moreland II Condominium Association, by and through its attorney, Mark W. Allshouse, Esquire, and files the following Complaint against Defendant named herein: l . Plaintiff is Village of Moreland II Condominium Association, a Pennsylvania Condominium Association established the 20th day of December, 1989 pursuant to Chapter 34 of the Pennsylvania Uniform Condominium Act, having a current mailing address of P.O. Box 1522, Mechanicsburg, PA 17055-9022. 2. Defendant is Village of Moreland, Inc., a Pennsylvania Corporation, original developer of the Village of Moreland II Condominiums, having a registered address of 1013 Mumma Road. Wormleysburg, PA l 7043. 3. Plaintiff has attempted to serve Village of Moreland, Inc. at its registered address, which mail was returned to sender. 4. George J. Adams, an adult individual, is the individual whose name and address is listed on the Department of State Corporation Bureau documents as President, who is currently believed to have an address of 221 West Philadelphia Street, Suite E 200, York, PA 17401 and is the location where Plaintiff is making service of this Complaint. 5. Defendant is the entity named on the Deed as title owner of the lot and ground known as Lot Number 19 as shown on the Declaration Plat for Village of Moreland Condominium Phase IV, Lower Allen Township, Cumberland County, Pennsylvania, prepared by Charles W. Junkins, Registered Surveyor, recorded in Cumberland County Book 66, Page 44, as more fully set forth in the legal description which is attached hereto and made a part hereof as "Exhibit A" ("Property"), being the original developer of Moreland II Condominium Association. 6. Defendant's Deed to the property is an interest adverse to Plaintiff but which claim is without any right as Defendants have no right, estate, title, lien or interest in or to the Property or any part thereof. 7. Plaintiff acquired the Property by virtue of operation of law and/or contract as set forth in the Condominium Declaration for Village of Moreland II Condominium Association, Article XVI, Section 16.1 and which is recorded in the Recorder of Deeds Office of Cumberland County, Pennsylvania in Book 373, Page 1108 dated December 20, 1989. The relevant section thereof is attached hereto and made a part hereof as "Exhibit B". 8. Specifically, Lot No. 19 was determined to be convertible real estate which was not converted or developed nor removed from the Association by Defendant within the seven (7) years as required by the Declaration and the Pennsylvania Uniform Condominium Act. 9. Moreover, historical Minutes reflecting Plaintiff s Association meeting of June 25, ?001 provide evidence, indeed, that not only was the Property was not developed, but that Defendant, actually notified Plaintiff it was Plaintiff's property. A true and correct copy of the Association Meeting Minutes where this occurred are attached hereto and made a part hereof marked as Exhibit "C". 10. Defendant never provided a Deed for the Property. 11. Since that date, the Property has remained dedicated open space and Defendant have taken no action to make any right, claim, interest, use of possession of the Property. 12. As a result of the foregoing, it is believed that Plaintiff has legal right and title to the Property although it has never received a Deed of transfer from Defendant. 13. Defendant's outstanding Deed creates a cloud in title to Plaintiff's ownership. 14. Plaintiff seeks to clear that title cloud by the filing of this action. WHEREFORE, Plaintiff requests this Honorable Court to enter an Order confirming all right, title and interest in the Property to Plaintiff, or in the alternative, directing Defendant to execute a Deed transfer the Property to Plaintiff. Date: li~/5~Z4j2 Du2,,-~ rk W. Allshouse, squire ttorney ID # 7801 4833 Spring Road Shermans Dale, PA 17090 (717) 582-4006 Attorney for Plaintiff Exhibit "A" . f.'~!~ ` X41 IbF ~ .-;. -'. ~~ ~'_ Y . ...~ ~~•1 k~ ..: J.. w:~ .. .. :... F` ~. Y)f t2~~ ~" ~~Rg ;4;~~ ~~~.: ro Yt 4 N -'. ~ ~ p a ~. e a ogy ~,I ~^:c' O , °yao sj°.ppn nMD . ''R~8 ~ ~;M ~ 3t$ 'n?~o `b?~ w~ 4n$ ~: 4~` ,. 0.d o~ a b l -O Obi ~~ ~8"8 0 ~ ~.~a f 2 2 ~ ~ p V ° 8 Y LOAN KRANTIEL ST/B0/NS/Qw PB. J9, PG 706 m Q y ~ NZOXS301Y T~~ lg I ~~~ ,oc s uva J606 s ua, NW J~ J0 ~4 . ~ ~ M ' - _ ._ t o~~~.~ .Q ~~a ? ~ ~t "~w-~- bp~C ~ N ~ ' ~ '~'^ Boa o n ~ .n ~~: o~ •• ~~ ~~~ ~~ - n ~ x~~ O~ h~ b~ ~~~ ~;y ~oo ~yo ~'~ ~~~~ ~°~ L ',~'~ ~ ~ ~ ,y .°^~b ~~ ~ .F V' C ~ I, h i 3 ~~ I n\ 2 I O G ~ ~~ ~ ' g ~ ~ ~I l -~~~ M/2/ ,OS 1~3XLS ~J3LS3/-lD/]O7'7 i I ~r ~~ ~' II ~ V II;1$I ~ Qo9 ~0 1 ~ ~ `1• I; 1 Cam I~ 1~~~ ~ ~:~- y ~ b ~. m 1J _ 1. ~ F~ 2 i~ c I w cAj 1 I N m ti i' ~p I ^ I a i n 1i ~ I s Ad I ~ ~ II 2 I rr_~ Q I I VI I ~ N L( II a I 1 i Y~ 'A' 1 f( ON 107 ~ 'u~t ~ ~J V LJ 1- 04/20/2011 9:17:37 AM CUMBERLAND COUNTY ._- _ _ ~~~ .-yap t~~~~ 2.17i~~y0 y ~ A ~! ~k$"l,~ p 8 ~ Z ;;~ ~ t ~ y , ~ ,~ ®~• ~~ ~ e ~ ~ .Lfi'F~f1C n 1 ii ~ UlN " ~ ~ --- ~,~~ y y Exhibit "B" • contract may be terminated prior to such anniversary only upon the filing of an amendment to this Declaration by the Declarant. Declarant expressly reserves the right to withdraw any or all portions of the Withdrawable Real Estate at any time, at different times, in any. order, without limitation, except as set forth ,in Section 3212 of the Act, and without any requirement that any .other real estate be withdrawn, added or converted; provided, however, that the,Withdrawable Real Estate shall not exceed the area described on Exhibit D hereto. The exact dimensions of the Withdrawable Real Estate shall be adjusted by Declarant in canlormity with the applicable governmental requirements for development, subdivision or withdrawal (without joinder of unit owners). There are no other liaitations or assurances on the option to withdraw the Withdrawable Real Estate frog the Condoainium. ABTiCLE XVI - Convertible Anal Fa*at@ Section 16.1. Reservation. Declarant hereby explicitly reserves an option until the 7th anniversary of the recording of this Declaration to convert all or any portion of the Convertible Real Estate to units, Limited Common Elements,. Common Elements or any combination thereof from time to time in compliance wit!) Section 3231 of the Act without the consent of any unit owner or Mortgagee. The option to corrvert may be terminated prior to such anniversary only upon the lilinq of an amendment to this Declaration by the Declarant. Declarant expressly reserves the right to convert any or all portions of the Convertible Real Estate at any time, at different times, in any order, without limitation and without any requirement that any other real estate be converted, added or withdrawn; provided, however, that the Convertible Real Estate shall not exceed the step described on Exhibit E hereto. There are no other liaitations on the option to convert convertible Real Estate. Section 16.2. Assurances. ,If the Convertible Real Estate is converted, the buildings on the Convertible Real Estate will be located approximately as shown on the Plats attached hereto; however, no assurance is given as to the exact location or dimensions o! the Buildings or units. At such timo as the Convertible Real Estate is completely converted, the maximum number of units on the Convertible Real Estate as an aggregate will be no sots than thirty-four (34) units. The maximum percentage o!•the aggregate land and floor area of all units that say be created within the Convertible Real Estate that may be occupied by units not restricted exclusively to residential use, i! such Convertible Real Estate is converted, is zero (ot) percent, not including home occupations permitted by local _ 35 _ e~ 373 Fb~ 1145 Exhibit "C" MUKELAND C'()NUU ASSOCIATION Ya PO'BC)X 1 X22, MECI-IANtCSBURC.i, PA 17055-9(122 Meeting: Monday, June 2S, 2001 Lower Arlen Township Building, 2"`' #loor Commissioners Room 7:30 pm Agenda: _ _~ .. _.._ _.__._....____.___ V can# Lot Between 4-ptex and duplex I'he Association h.as been notified by the on xinal vacant land between the 4-plea and duplex have became the f~ soc~ationt shy property. I'he I3oarcl needs your input abaut the fiiture use of the land. Please join as our attorney autlines the options the Association has f'or the land and discusses the pros and cabs of each optian. Annual Election I'or the year 2001, we will. be electing a Secretary and Advisor to the executive Board. Each erected officer will serve atwo-year term from July 1, 2041 tc~ June 30, 2003. - Please consider becoming an officer. With out voluntary officers, our associati+.;n would Hoed to hire an external property management group to run our association. !1ncl, of'cairrse, their service is not ~vithaut costs. Cruidelines f . Nominations ~~•ill be accepted form the .floor at the election meeting 2. Both "Proxy" and Official Voter l3allats will be handled in strict amfidencc. 3. "1'wa designated :~ssoction members will be assigned to count the votes. 4. A]1 ballots will be destroyed following a tally of voter ballots ~. Both Proxy and Official Voter Ballots are numbered only as a means tc> prevent duplicate ballots front being cast. i'~1ote: Attached is a "Proxy Voter Ballot". In ordr;r to conduct an affcial election a quorum of 13 eligible voters must cast votes either i.n person ar k)y proxy. if you are absolutel unable to attend the Annual Election Meeting, please cast your vote b}~ completing the enclosed Proxy Voter 13aliat and returning it in a scaled cnvclapc marked proxy vote prior to June 2S, 2001. "I•hank you. -- - __. • I. ~lirhael l_rephan. President of `, ':' '~' ~ '.',~d~s~ .end 1( Conii~~nlinitun .~\ss~~riati«n. bein~~ auth~,rized t~:, dr, sty. z~erif~ that the state«-~: 7-~ ire -.l•~t~ 1~~r ~~,~-in~ c~f~cument are true a-x3 cun'ect to the hest i~l~ n~i~ kna~~~led~~e, irltormation ~tnci }.~~li~'~. 1 ui~ierstanti that any false staterr,cr~t> herc~ia7 are made subject tt> the penalties ~~f 1 ti Pa.C'.~..~~. tit~cti-an -3~)0-~. relating; to uns~~-~~rn talitieation to authorities. VfLL.~GE~: t~E: L~it)REL..-1ND lI C'ONDC-~11tiIL`"~~1 ASSUCI~ l lOti It~1-~hae I~rephan_ President Mark W.Allshouse,Es FILED-OFFICE Attorney ID#78014 quire OF THE PROTHONOTARY 4833 Spring Road 2013 APR 10 AN 11` 2 5 Sherinans Dale,PA 17090 (717)5824006 CUMBERLAND COUNTY Attorney for Plaintiff PENNSYLVANIA Village of Moreland 11 Condominium IN THE COURT OF COMMON PLEAS Association, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 12-6785 Village of Moreland, Inc., Defendant ACTION TO QUIET TITLE PROOF OF SERVICE I hereby certify and affirm that service of the Important 10-Day Notice dated March 26, 2013 regarding the Complaint to Quiet Title in the above-captioned matter was made upon Defendant by advertising legal notice of the same once in the Cumberland Law Journal on April 5, 2013 and once in The Sentinel newspaper on March 27,2013. Proofs of said publication evidencing service are attached hereto. I hereby make this affirmation that information contained herein is true and correct under penalty of law for sworn falsification of statements to authorities. Respectfully submitted, Date: ark W. Allishouse squire Attorney ID# 78 4 4833 Spring Ro Shermans Dale,PA 17090 (717) 582-4006 Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS 9'4 DAY OF 2013. NZJTARY BLIC tW W_F_MRMVAMA 14M)AWMILSEAL S&We AUshouse,Nancy public CK"TWP'Nay camty PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587,approved May 16, 1929),P. L.1784 COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND Lisa Marie Coyne,Esquire,Editor of the Cumberland Law Journal.,of the County and State aforesaid,being duly sworn, according to law,deposes and says that the Cumberland Law Journal,a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952,and designated by the local courts as the official legal periodical for the publication of all legal notices, and has,since January 2, 1952,been regularly issued weekly in the said County,and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz April 5, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation,and that he is not interested in the subject matter of the aforesaid notice or advertisement,and that all allegations in the foregoing statements as to time,place and character of publication are true. isa Marie Co e, Editor SWORN TO AND SUBSCRIBED before me this 5 day of April, 2013 f r Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Pudic FARML LE BOROUGH,CUMBERLAND COUNTY Commi ssion Expires Apr 28,2014 CUMBERLAND LAW JOURNAL NOTICE OF COMLAINT TO YOUR LAWYER AT ONCE.IF YOU DO QUTE'!`TITLE♦OAM28M NOT HAVE A LAWYER OR CANNOT VMLAOE OF K0RELAXD,Ewc. AFFORD ONE, GO TO OR TELE- PHONE THE OFFICE SET FORTH In the Court of Common Pleas, BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County,Pennsylvania Cumberland County NO. 12-6785 Bar Association 32 South Bedford Street Village of Moreland II Carlisle,PA 17013 Condominium Association, (717)249-3166 Plaintiff A copy of the filed Complaint may V. be obtained by contacting the Pro- Village of Moreland,Inc., thonotary of Court of Common Pleas Defendant listed Cumberland County or counsel listed below. ACTION TO QUIET TITLE MARK W ALLSHOUSE,ESQUIRE CHRISTIAN LAWYER TO: Village of Moreland, Inc., De- SOLUTIONS,LLC fendant 4833 Spring Road DATE OF NOTICE: March 26, Shermans Dale,PA 17090 2012. Apr. 5 Village of Moreland II Condo- minium Association has filed a civil Complaint to quiet title upon real Property currently titled in the name of Village of Moreland, Inc, for real Property known as Lot Number 19 as shown on the Declaration Plat for Village of Moreland Condominium Phase IV, Lower Allen Township, Cumberland County, Pennsylvania, prepared by Charles W. Junl ins, Registered Surveyor, recorded in Cumberland County Book 66, Page 44. Complete service by publication was made on March 1,2012. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSON- ALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES 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. YOU SHOULD TAKE THIS PAPER TO 13 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Jackie Cox,Sales Director, of The Sentinel, of the County and State aforesaid,being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle,County and State aforesaid,was established December 13th,1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): March 27, 2013 COPY OF NOTICE OF PUBLICATION , .. Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the g fore g oin statement as 4 . to time, place and character of publication n K.44 A l ' r g iK. Sworn to d subscribed before me this ti 2012 m J � M � 1 e 3, 1 Notary Public . * I1 My commission expires: 4 1 NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public CARLISLE BGROUGH, CUh"BERLAND CNTY My Commission Expires Jan 27, 2014 Mark W.Allshouse,Esquire f't~ ifs f> lit""lc �7 + Attorney ID#78014 �7fl,'i3 .. 4833 Spring Road Sherm ns Dale,PA 17090 Gf 3jEPR l 7 PH f , (717)5824006 CU( Ib'EPE A'r'D Attorney for Plaintiff PE IVhS YE�";1911411 Village of Moreland 11 Condominium : IN THE COURT OF COMMON PLEAS Association, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 12-6785 Village of Moreland, Inc., Defendant : ACTION TO QUIET TITLE PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: AND NOW, comes the Plaintiff,, Village of Moreland II Condominium Association by and through its attorney, Mark W. Allshouse, Esquire, and requests that a default judgment be entered against the Defendant as follows: 1. The Complaint to Quiet Title with Notice to Defend was filed in the Office of the Prothonotary for the Court of Common Pleas of Cumberland County, Pennsylvania on November 6, 2012. 2. A Motion for Alternate Service was filed with the Office of the Prothonotary on February 4,2013 requesting that Plaintiff be allowed to serve the Complaint upon Defendant by publication due to Plaintiffs inability to properly locate Defendant. 3. On February 5, 2013,the Court issued an Order allowing Plaintiff to advertise by publication once in the Cumberland Law Journal and once in The Sentinel newspaper. 4. The Complaint was reinstated with the Prothonotary of Cumberland County on February 21, 2013. 5. Service of the Complaint was properly made per the Order of Court upon the Defendant by advertising legal notice of the pending action in the Cumberland Law Journal on March 1,2013 and in The Sentinel on February 21,2013. Plaintiff's Proof of Service filed with the Prothonotary on March 6, 2013 is attached hereto as Exhibit"A". 6. Upon the expiration of the initial twenty (20)day time period within which the Defendant should have responded to the initial Complaint, no answer was filed. 16 5D PO ATTY C+abgq P,#a893i5 No Nok-e ptai(d <beff uhffmhDoks unknown T Plaintiff property served the Notice of intention to take default judgment upon the Defendant by advertising legal notice of the same in the Cumberland Law Journal on April 5, 2013 and in The Sentinel on March 27, 2013. Plaintiffs Proof of Service filed with the Prothonotary on April 10,2013 is attached hereto as Exhibit `B". 8. No response was received from Defendant within the time period set forth in the Notice to intention to take default judgment. WHEREFORE, Plaintiff respectfully requests that a default judgment be entered in favor of the Plaintiff and against the Defendant confirming all right,title and interest in the property known as Lot Number 19 as shown on the Declaration Plat for Village of Moreland Condominium Phase IV, Lower Allen Township, Cumberland County, Pennsylvania, prepared by Charles W. Junkins,Registered Surveyor, recorded in Cumberland County Book 66,Page 44. Respectfully submitted, Date: cr X A-le ark W. Allshouse, squire Attorney 113,94 780 4833 Spring Road Shermans Dale, PA 17090 (717) 582-4006 Attorney for Plaintiff Exhibit "A" F IL%ii'ii 1=F itee-, Mark W.Allshouse,Esquire .r i' F €,40'10 i=i4 i Attorney ID 9 78014 4833 Spring Road 2013 � R G �� Shermans Dale, PA 17090 (717)582-4006 (U��wt (�LrIPiD C0U1'iTY Attorney for Plaintiff uE 114�SYLVANiA", Village of Moreland II Condominium : IN THE COURT OF COMMON PLEAS Association, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 12-6785 Village of Moreland, Inc., Defendant : ACTION TO QUIET TITLE PROOF OF SERVICE Pursuant to Order of Court dated February 8, 2013, I hereby certify and affirm that service of the Complaint to Quiet Title was made upon Defendant by advertising legal notice of the pending action to Quiet Title once in the Cumberland Legal Journal on March 1,2013 and once in The Sentinel newspaper on February 21,2013. Proofs of said publication evidencing service are attached hereto. I hereby make this affirmation that information contained herein is true and correct under penalty of law for swom falsification of statements to authorities. Respectfully submitted, Date:.3 4/20 I'S E '' t ark W. Allshouse, squire Attorney ID# 7801 4833 Spring Road Shermans Dale,PA 17090 (717) 582-4006 Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS 5 DAY OF 2013. NOTARY PUBLIC T caan�torlwancrlt oe pmvntsxtvalun NOPAR1ALgi3g1, Mmeh 29 2016 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL ("Under Act No. 587, approved May 16, 1929),P. L.1784 COMMONWEALTH OF PENNSYLVANIA Ss. COUNTY OF CUMBERLAND Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid,being duly sworn, according to law,deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official Iegal periodical for the publication of all legal notices,and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz March 1, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal,a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement,and that all allegations in the foregoing statements as to time, place and character of publication are true. Lis Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this I day of March, 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 CUMBERLAND LAW JOURNAL NOTICE COMPLAINT TO QUIET BE ABLE TO PROVIDE YOU WITH TITLE AGAINST VILLAGE OF INFORMATION ABOUT AGENCIES MORELAND,INC. THAT MAY OFFER LEGAL SERVICES --- TO ELIGIBLE PERSONS AT A RE- In the Court of Common Pleas DUCED FEE OR NO FEE. Cumberland County,Pennsylvania Cumberland County --- Bar Association NO. 12-6785 32 South Bedford Street --- Carlisle,PA 17413 Village of Moreland II (717)249-3166 Condominium Association, A copy of the filed Complaint may Plaintiff be obtained by contacting the Pro- v, thonotary of Court of Common Pleas Village of Moreland, Inc., of Cumberland County or counsel Defendant listed below. -- MARK W.ALLSHOUSE, ACTION TO QUIET TITLE ESQUIRE --- CHRISTIAN LAWYER Village of Moreland II Condomini- SOLUTIONS,LLC um Association has filed a civil Com- 4833 Spring Road plaint to quiet title upon real property Shermans Dale,PA 17090 currently titled in the name of Village Mar. 1 of Moreland, Inc. for real property known as Lot Number 19 as shown on the Declaration Plat for Village of Moreland Condominium Phase IV, Lower Allen Township, Cumberland County, Pennsylvania, prepared by Charles W. Junldns, Registered Surveyor, recorded in Cumberland County Book 66,Page 44, If you wish to defend,you must enter a written appearance person- ally or by an attorney and file your defenses or objections in writing with the Court.You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you without further notice for the relief requested by the Plaintiff, You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.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 12 PROOF OF PUBLICATION State of Pennsylvania,County of Cumberland Tackie Cox,Sales Director,of The Sentinel,of the County and State aforesaid,being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle,County and State aforesaid,was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): February 21, 2013 COPY OF NOTICE OF PUBLICATION y3$ o E og Affiant further deposes that he/she is not as7 0 � . wLL 7r� z ncan o �. interested in the subject matter of the �m 5= w aforesaid notice or advertisement, and that om 6= o� all allegations in the foregoing statement as 3 S qua % to time,place and character of publication U1 0 UO f a > g� g3 Wm f O 3 Cps a,da! q0 2 g o t yy m 8 � s V Sworn to and subscribei before me this ej .11 YF � a nm ° F a o"� 8 Notary Public , m. X05 $ '. 3. ! S XC e7Xm {i a g r� My commission expires: Stagy 'E"a- °?rc _ ECA�RLISLE ARIAL SEAL-,...,..,..,,..�.. .i N HECKENOORN ary Public GH, CUMBERLAND CNN[tyres Jan 2i. 2014 Exhibit "B" FILED-OFFICE Mark W.Allshouse,Esquire OF THE PROTHONOTARY Attorney ID#78014 4833 Spring Road �Q13 APR I O Aid 1I 26 Shermans Dale,PA 17090 (717)582-4006 CUMBERLAND COUNTY Attorney for Plaintiff PENNSYLVANIA Village of Moreland II Condominium IN THE COURT OF COMMON PLEAS Association, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 12-6785 Village of Moreland, Inc., Defendant : ACTION TO QUIET TITLE PROOF OF SERVICE I hereby certify and affirm that service of the Important 10-Day Notice dated March 26, 2013 regarding the Complaint to Quiet Title in the above-captioned matter was made upon Defendant by advertising legal notice of the same once in the Cumberland Law Journal on April 5, 2013 and once in The Sentinel newspaper on March 27, 2013. Proofs of said publication evidencing service are attached hereto. I hereby make this affirmation that information contained herein is true and correct under penalty of law for sworn falsification of statements to authorities. Respectfully submitted, Date: ark W. Allshouse squire Attorney ID # 780 4 4833 Spring Ro Shermans Dale, PA 17090 (717) 582-4006 Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS 9 Eb DAY OF 2013. N TARY BLIC COMMONWEALTH OF PENNSYLVAMA NOTARM Sallie AllshouPublic Carroll TWpnty commission 29,2016 PROOF OF PUBLICATION State of Pennsylvania,County of Cumberland Jackie Cox,Sales Director,of The Sentinel,of the County and State aforesaid,being duly sworn, deposes and says that THE SENTINEL,a newspaper of general circulation in the Borough of Carlisle,County and State aforesaid,was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County,and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): March 27,2013 COPY OF NOTICE OF PUBLICATION 1 Affiant further deposes that he/she is not z. interested in the subject matter of the aforesaid notice or advertisement,and that a ' all allegations in the foregoing statement as to time,place and character of publication ar e. °e,• t ,rq•��a`6�ar t xc, c I � Sworn to d subscribed before me this Z�tL 2013 r n` y Notary Public My commission expires: t� NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH,CUMBERLAND CNTY My Cor^.mission Expires Jan 77,2014 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929),P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne,Esquire,Editor of the Cumberland Law Journal, of the County and State aforesaid,being duly sworn, according to law,deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices,and has, since January 2, 1952,been regularly issued weekly in the said County,and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz April 5, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal,a legal periodical of general circulation,and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time,place and character of publication are true. isa Marie Coyne,Editor SWORN TO AND SUBSCRIBED before me this 5 day of April. 2013 Notary EGARLNOTARIAL SEAL ISLE BORAH A COLLINS Notary Public OUGH.CUMB ERLAND COUNTY ssion Expires Apr 2B.2014 CUMBERLAND LAW JOURNAL NOTICE OF COMPLAINT TO YOURLAWYERAT ONCE.IFYOU DO QUIET TITLE AGAINST NOT HAVE A LAWYER OR CANNOT VILLAGE OF MORELAND,INC. AFFORD ONE, GO TO OR TOLE- _ PHONE THE OFFICE SET FORTH In the Court of Common Pleas, BELOW TO FIND OUT WHERE YOU Cumberland County,Pennsylvania CAN GET LEGAL HELP. Cumberland County NO. 12-6785 Bar Association 32 South Bedford Street Village of Moreland II Carlisle,PA 17013 Condominium Association, (717)249-3166 Plaintifff A copy of the Sled Complaint may be obtained by contacting the pro- V. thonotary of Court of Common pleas Village of Moreland,Inc., of Cumberland County or counsel Defendant listed below. ACTION TO QUIET TITLE MARK W.ALLSHOUSE,ESQUIRE CHRISTIAN LAWYER TO: Village of Moreland, Inc., De- SOLUTIONS,LLC fendant 4833 Spring Road DATE OF NOTICE: March 26, Shermans Dale,PA 17090 2012. Apr. 5 Village of Moreland II Condo- minium Association has filed a civil Complaint to quiet title upon real Property currently titled in the name of Village of Moreland, Inc. for real Property known as Lot Number 19 as shown on the Declaration Plat for Village of Moreland Condominium Phase IV, Lower Allen Township, Cumberland County, Pennsylvania, prepared by Charles W. Junkins, Registered Surveyor, recorded in Cumberland County Book 66, Page 44. Complete service by publication was made on March 1,2013, YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSON- ALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES 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. YOU SHOULD TAKE THIS PAPER TO 13 4 "ii ro-OFFiCE Mark W.Allshouse,Esquire 1,i �To'"_f�'f 0 510N O I AR Attorney ID#78014 4833 Spring Road -6il Shermans Dale,PA 17090 (717)582-4006 ll °fif?Ef,LAp CUB t'� Attorney for Plaintiff t C 1 y IJA I Village of Moreland II Condominium IN THE COURT OF COMMON PLEAS Association, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 12-6785 Village of Moreland, Inc., Defendant : ACTION TO QUIET TITLE MOTION FOR FINAL DECREE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 1037 AND NOW, comes the Plaintiff, Village of Moreland 11 Condominium Association, by and through its attorney, Mark W. Allshouse, Esq., and files the within Motion for Final Decree and in support thereof, states as follows: . 1. The Complaint to Quiet Title with Notice to Defend was filed in the Office of the Prothonotary for the Court of Common Pleas of Cumberland County, Pennsylvania on November 6, 2012. 2. A Motion for Alternate Service was filed with the Office of the Prothonotary on February 4, 2013 requesting that Plaintiff be allowed to serve the Complaint upon Defendant by publication due to Plaintiff's inability to properly locate Defendant. 3. On February 5, 2013,the Court issued an Order allowing Plaintiff to advertise by publication once in the Cumberland Law Journal and once in The Sentinel newspaper. 4. The Complaint was reinstated with the Prothonotary of Cumberland County on February 21, 2013. 5. Service of the Complaint was properly made per the Order of Court upon the Defendant by advertising legal notice of the pending action in the Cumberland Law Journal on March 1, 2013 and in The Sentinel on February 21, 2013. Plaintiff's Proof of Service filed with the Prothonotary on March 6, 2013 is attached hereto as Exhibit"A". 6. Upon the expiration of the initial twenty (20) day time period within which the Defendant should have responded to the initial Complaint, no answer was filed. 7. Plaintiff properly served the Notice of intention to take default judgment upon the Defendant by advertising legal notice of the same in the Cumberland Law Journal on April 5, 2013 and in The Sentinel on March 27, 2013. Plaintiff's Proof of Service filed with the Prothonotary on April 10, 2013 is attached hereto as Exhibit`B". 8. No response was received from Defendant within the time period set forth in the Notice to intention to take default judgment. 9. The Prothonotary of Cumberland County entered judgment on April 17, 2013. A true and correct copy of the Notice Under Rule 236 is attached hereto and made a part hereof as Exhibit"C". 10. Plaintiff properly serviced notice of the judgment upon the Defendant by advertising legal notice of the same in the Cumberland Law Journal on May 3, 2013 and in The Sentinel on April 23, 2013. True and correct copies of Plaintiff's Proofs of Service are attached hereto and made a part hereof as Exhibit"D". 11. Thirty(30) days from the date of advertisement of the judgment have passed. 12. Pennsylvania Rule of Civil Procedure 1037 states that, "in cases in which equitable relief was sought, the Court shall enter the appropriate Order upon the judgment of default...." 13. In this matter, Plaintiff seeks the equitable relief of a quiet title and a Court Order awarding Plaintiff fee simple ownership of the subject property. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter the attached Order confirming fee simple title in Plaintiff. Respectfully submitted, Date: (0/6PIVS ark W. Allshouse squire Attorney ID # 780 4 4833 Spring Roa Sher-mans Dale, PA 17090 (717) 582-4006 Attorney for Plaintiff Exhibit "A" Mark W.Allshouse,Esquire Attorney ID#78014 �' i'�' '� a i' ►iC�d ia>>�1 4833 Spring Road Shermans Dale,PA 17090 20,13 MIAR -5 AM 10: 4 0 (717)582-4006 Attorney for Plaintiff iJ i i '.�I�S.L ti l� COUNTY I'LEN31SYLVANIA Village of Moreland II Condominium : IN THE COURT OF COMMON PLEAS Association, CUMBERLAND COUNTY,PENNSYLVANIA Plaintiff V. NO. 12-6785 Village of Moreland, Inc., Defendant : ACTION TO QUIET TITLE PROOF OF SERVICE Pursuant to Order of Court dated February 8, 20 13, I hereby certify and affirm that service of the Complaint to Quiet Title was made upon Defendant by advertising legal notice of the pending action to Quiet Title once in the Cumberland Legal Journal on March 1,2013 and once in The Sentinel newspaper on February 21, 2013. Proofs of said publication evidencing service are attached hereto. I hereby make this affirmation that information contained herein is true and correct under penalty of law for sworn falsification of statements to authorities. Respectfully submitted, Date:3 f /2013 t/ ark W. Allshouse, squire Attorney ID#7801 4833 Spring Road Sherman Dale, PA 17090 (717) 582-4006 Attorney for Plaintiff SWORN TO AND SUBPCRIBED BEFORE ME THIS 'S� DAY OF �� , 2013. Nf6tARY PUBLIC col�sorlw�AL,,_„_11;of P>�lrlslizvarun NOTARIAL SEAL Carroll Twp,Perry Cou ty =mbdm enins Mamh29,2016 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587,approved May 16, 1929),P. L.1784 COMMONWEALTH OF PENNSYLVANIA : : ss. COUNTY OF CUMBERLAND Lisa Marie Coyne,Esquire,Editor of the Cumberland Law Journal,of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal,a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices,and has, since January 2, 1952,been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz March 1, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation,and that he is not interested in the subject matter of the aforesaid notice or advertisement,and that all allegations in the foregoing statements as to time,place and character of publication are true. n Li Marie Coyne,Editor SWORN TO AND SUBSCRIBED before me this 1 day of March,2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 CUMBERLAND LAW JOURNAL NOTICE COM ST V] TO E QUMT op BE ABLE TO PROVIDE YOU WITH TITLE AGAINST ,MC.}E OF INFORMATION ABOUT AGENCIES MORFS 'INC• THAT MAY OFFER LEGAL SERVICES In the Court of Common Pleas TO E ELIGIBLE PERSONS AT A RE- Cumberland County,p�„ylvania FEE OR NO FEE. Cumberland County NO. 12-6785 Bar Association 32 South Bedford Street Village of Moreland II Carlisle,PA 17013 Condominium Association, (717)249-3166 Plaintiff be obtained of the filed Complaint may V. tained by contacting the Pro- Village of Moreland,Inc thonotary of Court of Common Pleas Of Cumberland County or counsel Defendant listed below. ACTION TO QUIET TITLE MARK W ALLSHOUSE, ESQUIRE Village of Moreland II Condomini_ CHRISTIAN LAWYER SOLUTIONS,LLC um Association has filed a civil Com- Plaint to quiet title upon real property `+833 Spring Road currently titled in the name f illle Shermans Dale,PA 17090 Of Moreland, Inc. for real property Mar. 1 known as Lot Number 19 as shown on the Declaration Plat for Village of Moreland Condominium Phase IV, Lower Allen Township, Cumberland County, Pennsylvania, prepared by Surveyor, recorded Charles W. Junkins, Registered County Book 66 Page m Cumberland 'You wish to dend, you must enter a written appearance person- ally or by an attorney and file your defenses or objections in writing with the Court.You are warned that ifyou fail to do so the case may proceed without you and a judgment may be entered against you without further notice for the relief requested by the Plaintiff. You may lose money or Property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.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 12 PROOF OF PUBLICATION State of Pennsylvania,County of Cumberland Jackie Cox,Sales Director, of The Sentinel,of the County and State aforesaid,being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle,County and State aforesaid,was established December 13th,1881, since which date THE SENTINEL has been regularly issued in said County,and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): February 21,2013 COPY OF NOTICE OF PUBLICATION .r R �r" Affiant further deposes that he/she is not ` �4 x " r{ z interested in the subject matter of the aforesaid notice or advertisement,and that a s' u� all allegations in the foregoing statement as to time,place and character of publication e. } tel o rz s A; �. c , � •;tau z. � 9�. � ,• � •�; ` Sworn to and subscribe before me this s. r Notary Public a . a h'i My commission expires: +'. • ry _ '.S3s'L�IL�e NOTARIAL SEAL BAMBI ANN HECKENDORN " Notary Public F CARLISLE BOROUGH, CUMBERLAND CNTY fvly Commission Expires Jan 27, 2,114 Exhibit "B" Mark W.Allshouse,Esquire 1f ��1E P'OT r ILED-OFFICE Attorney ID#78014 HpNp MR,r 4833 Spring Road 2013 APR 10 Shermans Dale,PA 17090 A� 1• Zb Actor ey for CU ME JRLANp COUNTY Attorney for Plaintiff NSYLVANIA Village of Moreland II Condominium : IN THE COURT OF COMMON PLEAS Association, CUMBERLAND COUNTY,PENNSYLVANIA Plaintiff V. : NO. 12-6785 Village of Moreland, Inc., Defendant : ACTION TO QUIET TITLE PROOF OF SERVICE I hereby certify and affirm that service of the Important 10-Day Notice dated March 26, 2013 regarding the Complaint to Quiet Title in the above-captioned matter was made upon Defendant by advertising legal notice of the same once in the Cumberland Law Journal on April 5, 2013 and once in The Sentinel newspaper on March 27, 2013. Proofs of said publication evidencing service are attached hereto. I hereby make this affirmation that information contained herein is true and correct under penalty of law for sworn falsification of statements to authorities. Respectfully submitted, Date: *Attomey W. AllshoZ squire ID#7 4833 Spring Ro Shermans Dale,PA 17090 (717) 582-4006 Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS 9 DAY OF�ni-i/ ,2013. N TARY MELIC COIrAQONWFALTH OF PFNNSYLVAMA NOTARIAL SEAL Sallie Atlshouse,Notary Public Carroll Twp,Petry County commission cOm Match 29,2016 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587,approved May 16, 1929),P. L.1784 COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND ; Lisa Marie Coyne,Esquire,Editor of the Cumberland Law Journal,of the County and State aforesaid,being duly sworn, according to law,deposes and says that the Cumberland Law Journal,a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices,and has,since January 2, 1952,been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz April 5, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal,a legal periodical of general circulation,and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time,place and character of publication are true. r isa Marie Co e,Editor SWORN TO AND SUBSCRIBED before me this 5 day of April,2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public FCARMLIYSLEBOROUGH,CUMBERLAND COUNTY Commission Expires Apr 28,2014 CUMBERLAND LAW JOURNAL NOTICE OF COMPLAINT TO FOUR LAWYER AT ONCE.IF YOU DO QUIET TITRE AGAINST NOT HAVE A LAWYER OR CANNOT VILLAGE OF MORELAND,INC. AFFORD ONE, GO TO OR TELE- PHONE THE OFFICE SET FORTH In the Court of Common Pleas, BELOW TO FIND OUT WHERE YOU Cumberland County,Pennsylvania CAN GET LEGAL HELP. Cumberland County NO. 12-6785 Bar Association 32 South Bedford Street Village of Moreland Il Carlisle,PA 17013 Condominium Association, (717)249-3166 Plaintif A copy of the filed Complaint may be obtained by contacting the Pro_ v. thonotary of Court of Common Pleas Village of Moreland,Inc., of Cumberland County or counsel Defendant listed below. ACTION TO QUIET TITLE MARK W.ALLSHOUSE,ESQUIRE CHRISTIAN LAWYER TO: Village of Moreland, Inc., De- SOLUTIONS,LLC fendant 4833 Spring Road DATE OF NOTICE: March 26, Shermans Dale,PA 17090 2012. Apr.5 Village of Moreland Il Condo- minium Association has filed a civil. Complaint to quiet title upon real property currently titled in the name of Village of Moreland, Inc. for real Property lmown as Lot Number 19 as shown on the Declaration Plat for Village of Moreland Condominium Phase IV, Lower Allen Township, Cumberland County, Pennsylvania, prepared by Charles W. Junldns, Registered Surveyor, recorded in Cumberland County Book 66, Page 44. Complete service by publication was made on March 1,2012. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSON- ALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES 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. YOU SHOULD TAKE THIS PAPER TO 13 PROOF OF PUBLICATION State of Pennsylvania,County of Cumberland Jackie Cox,Sales Director,of The Sentinel,of the County and State aforesaid,being duly sworn,deposes and says that THE SENTINEL,a newspaper of general circulation in the Borough of Carlisle,County and State aforesaid,was established December 13th,1881, since which date THE SENTINEL has been regularly issued in said County,and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): March 27,2013 COPY OF NOTICE OF PUBLICATION Affiant fiuther deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement,and that all allegations in the foregoing statement as 1111111611k to tune,place and character of publication ar e. Sworn to d subscribed before me this 7,1t, -h 2DI3 Notary Public My commission expires: NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH.CUMBERLAND CNTY MY Corrmission Expires Jan 27.2014 r Exhibit "C" Mark W.Allshouse,Esquire Attorney ID 4 78014 4833 Spring Road Shermans Dale,PA 17090 (717)582-4006 Attorney for Plaintiff Village of Moreland II Condominium IN THE COURT OF COMMON PLEAS Association, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 12-6785 Village of Moreland, Inc., Defendant : ACTION TO QUIET TITLE NOTICE UNDER RULE 236 To: Village of Moreland, Inc., Defendant Pursuant to the requirements of Pa. R.C.P. 236 notice is hereby given that on April 17h , 2013, a judgment was entered against you in this office in the above-captioned matter. Date: Prothonotary Exhibit "D" PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid,being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz May 3, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. (—)Lisa Mariell Coyne, Edit hr SWORN TO AND SUBSCRIBED before me this 3 day of May, 2013 L� Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 26,2014 CUMBERLAND LAW JOURNAL NOTICE UNDER RULE 236 In the Court of Common Pleas Cumberland County,Pennsylvania NO. 12-6785 Village of Moreland II Condominium Association, Plaintiff v. Village of Moreland,Inc., . Defendant ACTION TO QUIET TITLE TO: Village of Moreland, Inc., De- fendant DATE OF NOTICE:April 17,2013. Pursuant to the requirements of Pa.R.C.P.236 notice is hereby given that on April 17, 2013, a judgment was entered against you by the Cum- berland County Prothonotary in the above-captioned matter. MARK W.ALLSHOUSE,ESQUIRE CHRISTIAN LAWYER SOLUTIONS,LLC 4833 Spring Road Shermans Dale,PA 17090 May 3 6 PROOF OF PUBLICATION State of Pennsylvania,County of Cumberland Jackie Cox,Sales Director of The Sentinel,of the County and State aforesaid,being duly sworn,deposes and says that THE SENTINEL,a newspaper of general circulation in the Borough of Carlisle,County and State aforesaid,was established December 131h 1881, since which date THE SENTINEL has been regularly issued in said County,and that the Printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): April a 2013 COPY OF NOTICE OF PUBLICATION ✓ ��/ r� f wti t I f".r Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement,and that ,i,.;, X, ik� 1 x .a f p J � F all allegations in the foregoing statement as ¢ ti rlr 4 r�� to time,place and character of publication • ��{�x r _fi t n��; •�.�+� {�N yid }� r is[��t r �'"ay t s. SWorjg t and sub 'bed re me this Notary Public My commission expires: NOTARIAL SEMI BAMBI ANN t1ECKENDORN Notary PWIC CARLISLE BOROUGH.CUI"BERLAND CNTY A My Commf sisi Erpire, Q L Village of Moreland II Condominium IN THE COURT OF COMMON PLEAS Association, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 12-6785 Village of Moreland, Inc., Defendant : ACTION TO QUIET TITLE ORDER OF COURT AND NOW, this day of t/U.M, Q , 2013, it is hereby ORDERED that full fee simple title is hereby vested in Plaintiff, Village of Moreland II Condominium Association, to the property known as Lot Number 19 as shown on the Declaration Plat for Village of Moreland Condominium Phase IV, Lower Allen Township, Cumberland County, Pennsylvania,prepared by Charles W. Junkins, Registered Surveyor, recorded in Cumberland County Book 66, Page 44 consistent with the judgment obtained in the above-captioned matter. This Order of Court shall be indexed against the property. rn03 c =rn CO c) CD .=CD €; ..4 ti': Y l�18��3