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HomeMy WebLinkAbout04-6346 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PaulS.Zook Eva K. Zook Plaintiffs : No: OLf~~~~ ~ : Civil Action - Law vs. W.W. White Defendant 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 WRmEN 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 ANY OTHER CLAIM FOR 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 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA (717) 249-3166 t~0. ~ C H. ANTHONY ADAMS ATTORNEY AT LAW SUPREME COURT ID NO. 25502 49 WEST ORANGE STREET, SUITE 3 SHIPPENSBURG, PA 17257 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PaulS. look Eva K. look Plaintiffs : No: : Civil Action - Law vs. W.W. White Defendant COMPLAINT AND now, come the Plaintiffs, Paul S. look and Eva K. look, by and through their attorney, H. Anthony Adams and state the following cause of action and in support thereof, aver as follows: 1. Plaintiffs are Paul S. look and Eva K. look, adult individuals who reside at 11264 Otterbein School Road, Newburg, Pennsylvania 17240. 2. Defendant is W.W. White his heirs, executors, administrators and assigns. 3. Plaintiffs are the owners of land by virtue of a special warranty deed dated August 29, 2003 as recorded in the Office of the Recorder of Deeds a copy of which is attached hereto and the description of which is incorporated herein by reference. 4. The Grantor in the deed to Plaintiffs is Clarence J. Myers who obtained title to the land by quitclaim deed dated May 10, 1990 as recorded in the Office of the Recorder of Deeds. 5. The predecessor in title to the lands conveyed by Clarence J. Myers and Catherine M. Myers was W.W. White, Defendant. 6. The Plaintiffs know of no other parties claiming an interest in the property. 7. Due to missing, lost or unrecorded deeds the chain of title from W.W. White to Plaintiff cannot be clearly established. 8. The Plaintiffs request the court enter an order to quiet title and to declare all right, title and interest in the property. 9. The Plaintiffs are in possession of the property. WHEREFORE, Plaintiff request the Court enter an order declaring all right, title and interest in them and that the Defendant, his heirs and assigns be barred from any claim to said property and that the court order such other relief as may be just and equitable. Respectfully submitted, ~~ H. Anthony Adams, EsqUIre Attorney for Plaintiffs VERIFICATION We verify that the statements made in this Complaint are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: f11r j ~,. (~C;' -j~?'~ PaulS. Zook ~ Date: ~ 0/'1 ...1 l/ { (Jl/l\.. "'- Eva K. Zook yd- '--\ 'J~U '\ r \'I1fi'J '" F;'Word Processing\realestate\client's work\myers, clarence j.TO zook, paul et uX.deed.30 ac tract.Aug03.doc '. ~:i:,:,'~EI;~ Tax Parcell.D. No.- .;- ,: ..:i: [)[::)~ .-"ddiO CrJUNT'i'.., THIS DEED J3 SEP 2 AfJ 8 25 MADE this 29th day of AUGUST in the year TWO THOUSAND THREE (2003), BETWEEN CLARENCE J MYERS, widower, of 75 Stoney Lane, Newburg, Cumberland County, Pennsylvania, Grantor, AND PAUL S ZOOK and EVA K ZOOK, husband and wife, of Newburg, Cumberland County, Pennsylvania, Grantees. WITNESSETH that in consideration of the sum of SIXTY-NINE THOUSAND DOLLARS ($69,000.00), in hand paid, the receipt whereof is hereby acknowledged, the said Grantor does grant and convey in fee simple to said Grantees, their heirs and assigns, All the following described real estate, lying and being situate in Hopewell Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a point at corner of other lands now or formerly of the Grantors herein; thence by said land 1,093.95 feet to a corner; thence by same, 381.15 feet to a point in line of lands now or formerly of William Powell; thence by Powell, 150 feet, more or less; thence by same, and lands now or formerly of Harry Monn, 712.90 feet to a corner of Parcel No. 9 on the tax assessment maps of Cumberland County; thence by Parcel No.9, 612.21 feet; thence by Parcel Nos. 7 and 7B on said map, 1,312.60 feet to line of lands now or formerly of Richard Gardner; thence by Gardner, 526.70 feet; thence by same, 101.10 feet to a corner of lands now or. formerly of Thomas Papoutsis; thence by Papoutsis, 811.90 feet to a point in line of lands now or formerly of Jay Hoover; thence by Jay Hoover, 562.50 feet to a point, the place of BEGINNING. CONTAINING 30.00 Acres, more or less. BEING THE SAME REAL ESTATE WHICH Clarence J Myers and Catherine M Myers, his wife, by thei r deed dated May 10, 1990, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book "P", Volume 34, Page 1198, granted and conveyed to Clarence J Myers and Catherine Myers, his wife. Catherine Myers died May 11, 2000, leaving to survive her, her husband, Clarence 1 Myers, in whom full title vested by.. operation of law, Grantor herein. law Office Forest N Myers 137 Park Place West, Snippensburg, Pennsylvania 17257 2v:':::~'~ ~ 8 'JO~ ;:\::: 717532.9046 . ~ AND the said Grantor will warrant specially the property hereby conveyed. IN WITNESS WHEREOF, the said Grantor has hereunto set his hand and seal the day and year first above written. WITNESS: j~~~.~ "~._-- /;eL~L~(SEAl) CLAkY~E J M~ - . '-(e-,o ACKNOWLEDGMENT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND / FRANKLIN On this 29th day of AUGUST, 2003, before me, a Notary Public, the undersigned officer, personally appeared CLARENCE J MYERS, knownt9 me (or satisfactorily proven) to be the person whose name is subscribed to the within' instrument, and acknowledged the foregoing to be his act and deed and desired the same to be recorded as such. . >~~ESS my hand and official seal, the d~~ \d year ~fo:esaid. . ~'i'!'" . . \ .~~~ '" ~ . 'it).. '- \..~_~~~ ~__ :~,It.~ _'~.U~. ...';.y-.4..3.... -..- --~. - --;>- ~-;J~s::~~,....~. .~.., ....,. Notar\! Public .~it>>. ';""-~...1i<;d"'<t'''-~ 1 ..,..~""~. o::/'...r.' ~,. ,,' ." ~ :~~"'''''' .~ ~'ff'\e'l;;i:\."'~J..~<~ ~"1~~;:.~. ~ ~..., ~~~}".~,..". '~~~~:~i~f';G~,"':.!"I~;':'" "'.\l~.t~.~~~~':~>t~r:.:..~ ~~b .':;;~:'lo.("- ~-;;.o"",,...,,~...,' .. .',,' ~C-' "::.'l~~~"'" ,,,,? ~~?\~..: .:~O ~:..~;~.... ;"!..,'. .. 1*. .rf:". ~:~,..i..;.i.~t:t..~~ ~....." ~c '. .~-1 "':"'_~ :. \n.,.~~, ',.. "~""'" r.,I".....w' .~'.." '..... " 4- p' .'. ,. , 1','.:'tariJ! Seal H. Anthul!) Adam;. Norary Pu:,lic Shipp~lIsblJri 3,-"0, Cumberlar.d County My Cormnissi.,q E^pir~;, M~v I ~ 2006 ;'.}~'..' '-""1 "~ .~'..,:. '". .. ' - "' := t".,.-:J~ I certify that the precise ~esiqenc~ and Post Office adpress of the Grantees is: [(..db V D 4+~-~\~~ sJv-e.;~ /~c J _ ~ ... t. \ ~JP J...\.M 'J-....-c..., 0::7 '1\ '- 72> C.( v .J \ \ ,/:-(bs. ---...... --..... , \ ..... ..) '. ' <::-~ \.....:.- --;;;;:-~~.~;.:.--"--- Attorney for Grantees Page 2 of 2 5007 259 NM. .. 3 ~-t\ ~ ~ ,,;:0 -, ~ ~ UJ a: =2cl ~ ~ <--^ I V\ C" 0 t'-.:> c: > .....-.. r- (:~"., '-.~ :: ~.. -- -"-1 ......'., C7 r: Pl C') _.I - l i :r"" /' - " - .. ... ~~~ ~~ -...-! r',,) -' -... Ul ~I IN THE COURT OF COMMON !PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PaulS. look Eva K. Zook Plaintiffs C;3% : No: 04~"16 Civil : Civil Action - Law vs. W.W. White Defendant PETITION FOR SERVICE BY PUBLICATION AND NOW come Plaintiffs, Paul S. look and Eva K. Zook, by and through their Attorney, H. Anthony Adams, and set forth the following: 1. Plaintiffs are Paul S. look and Eva K. Zook, adult individuals, who reside at 11264 Otterbein School Road, Newburg, Pennsylvania, 17240. 2. On or about August 29,2003, the Plaintiffs purchased 30 acres of land from Clarence J. Myers by virtue of a deed recorded in Deed Book 259 page 3. 3. The title to the property is not clear and to remove cloud from title Plaintiffs brought an action at this term and number against their Grantor's only known predecessor in title W.W. White and his heirs, executors, administrators and assigns. 4. Inquiry has been made to local area neighbors, examination of local tax records and land records and no one has knowledge of W.W. White. W. W. White is believed to have died in or around 1890. 5. There is no record of W.W. White's heirs, assj!~ns, executors or administrators and they are unknown. WHEREFORE, Plaintiffs pray your Honorable Court allow them to make service upon W.W. White, his executors, administrators, heirs and assigns by publication pursuant to Pa. R.C.p. 430 (b) (1) (2) Respectfully submitted, H.~~;rn Attorney for Plaintiffs 49 W. Orange Street, Suite 3 Shippensburgl,PA 17257 (717)-532-3270 VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities: 'fke ~b~d~;:J'."iU ~11'i1!1;11l tJ ~:".. ll.i:J .!ol ;fLul;v" <I, III u "ub"ULutt. v<:,ifi..,ation Date: 1,/;/15 ~p 3- Paul S. Zook 7 ~ c.-.-:::- Date:OJ;/j/oJ fd ' aNCL ~.. Eva K. Zook NOTICE If you wish to defend, you must enter a written appearance personally or by attorney and file your defenses or objections in writing with the court. You are warned that if you fail to do 50 the ease 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 THS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFIC SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT FINDING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PaulS.Zook Eva K. Zook Plaintiffs : No: 04-6346 Civil : Civil Action - Law vs. W.W. White Defendant TO: W.W. WHITE his heirs, executors, administrators and assigns You are notified that the Plaintiffs, Paul S. Zook and Eva K. Zook, have commenced an action to Quiet Title against you entered to No. 04-6346 Civil in the Court of Common Pleas of Cumberland County, Pennsylvania which you are required to defend. This action concerns the land herein described: ALL the following described real estate, lying and being situate in Hopewell Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a point at corner of other lands now or formerly of Grantors herein; thence by said land 1,093.95 feet to a corner; thence by same, 381.15 feet to a point in line of lands now or formerly of Willam Powell; thence by Powell, 150 feet, more or less; thence by same and lands now or formerly of Harry Monn, 712.90 feet to a corner of Parcel No.9 on the tax assessment maps of Cumberland County; thence by Parcel No.9, 612.21 feet; thence by Parcel Nos. 7 and 7B on said map, 1,212.60 feet to line of lands now or formerly of Richard Gardner; thence by Gardner, 526.70 feet; thence by same, 101.10 feet to a corner of lands now or formerly of Thomas Papoutsis; thence by Papoutsis, 811.90 feet to a point in line of lands now or formerly of Jay Hoover; thence by Jay Hoover, 562,50 feet to a point, the place of BEGINNING. CONTAINING 30.00 acres, more or less .-/ . (! 1 7.o0~ '\ # IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PaulS. Zook Eva K. Zook Plaintiffs G'~'/(P : No: 04-3346 Civil : Civil Action - Law vs. W.W. White Defendant ORDER IVI~ And now this z. "):!. day of Fel3n:lllry, 2005 after consideration of the facts set forth in the forgoing Petition, Plaintiffs are granted the right to make service by publication on W.W. White, his executors, administrators, heirs and assigns, pursuant to Pa. R. C. D. 430 (b)(i) (2). Byth cO~J J. \jjN7i\IA~:\~Njd .A1Nr:CY) /T'., -;,"C, -;:",~ir/',!n:J 91] :21 ~ld Z - ~~I~ SiJnZ Ab'\i.iD>l':J;-;J.C::~;d 3Hl 3~'A:i=IC~CJ3l~_j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PaulS. Zook Eva K. Zook Plaintiffs (P ?ife, : No: 01 J346 Civil : Civil Action - Law vs. W.W. White Defendant PETITION FOR DECREE Now come the Petitioners, Paul S. Zook and Eva K. Zook, by and through their attorney, H. Anthony Adams and set forth the following: 1. Petitioners on or about December 17,2004 filed a complaint to the above term and number. 2. Petitioners sought and obtained the right to make service of the complaint by publication by petition filed February 28, 2005 and Court Order dated March 2, 2005. 3. Publication was made in the News-Chronicle on March 18, 2005 and in the Cumberland Law Journal on March 18, 2005. Proofs of publication are attached hereto. 4. The publications referred to in the previous paragraphs included the complaint which contained the required notice to defend. - 5. Six months have passed and no answer or other response has been filed to the complaint. 6. Petitioners request the Honorable Court enter a decree and order directing that the Defendant, his heirs or assigns be barred from asserting any interest inconsistent with the claim of Plaintiffs unless answer or claim is made within 30 days. " \ \(((X-~ --:>~ H. Anthony Adams, Esquire Attorney for Petitioners 49 West Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 VERIACATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date:~oS ~C9S---O) ~ H. ANTHONY ADAMS o C '"T;ij- ,,-l:!'- ;~~. -? 0~~.' ,.."'-, '~~ ~. g <-" c./> r<1 --0 rv -J .~s:- 2~ ~ -<.. Q, _-1 :r;..... fl1E- -om :.09 ~Qi .,L""":", ("1-- z.'M S 'P' ~ ~ ::l.. '-P. c- --' y " r ;". =-!~r ~-fl ('~-". ? c, ",..",'. .. -.....-., _.' .-.! <;. , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA rr' PaulS.Zook Eva K. Zook Plaintiffs (,3~\p : No: 04~ Civil : Civil Action - Law vs. W.W. White Defendant DECREE AND ORDER AND NOW this L{ tL day of 0 c\. 2005 after review of the attached petition and upon the motion of H. Anthony Adams, it is directed that the defendant be forever barred from asserting any right, lien, title or interest in the land inconsistent with the claim by Plaintiffs unless answer, claim or other action is taken which 30 days from the last publication of this decree. By the Court /-) I J. A1;'I':;1J 9 (; :Z Hd ~- 1:]0 SilVZ AU\rlC;'~C'h.L;~::~:d jHl =10 :!Jt::!:,i(J'{EJl!:1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Paul S. Zook Eva K. Zook Plaintiffs : No: 04-6346 Civil : Civil Action - Law vs. W.W. White Defendant PRAECIPE TO THE PROTHONOTARY: Enter on Appearance Docket and on Decree a notation that the defendant failed to take the action directed in the last advertisement within the time therein limited; and transmit to the Recorder of Deeds a certified copy of the Decree containing the notation above described. Respectfully submitted, ~--- \" ~~<;::--, ~ ~-~~ H. Anthony Adams, Esquire Attorney for Plaintiffs 49 West Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 " . . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYL VANIA 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 October 21, 2005 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, / SWoRN TO AND SUBSCRIBED before me this 21 day of October. 2005 ditor ~~~~,~A/ I NOT ARI.\L SEAL t ~<~)!;? E. SNVPER, Notary Put~\.~ 1 C y!::;!!:: 3',ro, Cumberland COli:I'\,' ; :\ (>n","'::-:-::,.1" E-X{';H", i\~ar:.:h :~. ,ld(" ;..-.,.", ".""""'<'~'-'~" ~,,-, """.'~~ ~"--"'~---"'''~'"'--~'' CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law No.: 04-6346 Civil Paul S. Zook. Eva K. Zook Plaintiffs vs. W.W. White Defendant TO: W.W. White, his heirs, execu- tors. administrators and assigns. You are notified that an Order has been entered to No. 04-6346 Civil in the Court of Common Pleas of Cumberland County. Pennsylva- nia on Octo her 4, 2005 directing that within thirty (30) days after this publication you shall make answer or file claim or take other action or be forever barred from asserting any right, lien, title or interest in- consistent with the interest or claim set forth in the plaintiffs' complaint to the land therein described. The order is as follows: DECREE AND ORDER AND NOW this 4th day of Octo- ber 2005 after review of the attached petition and upon the motion of H. Anthony Adams, it is directed that the defendant be forever barred from asserting any right, lien, title or Interest in the land Inconsistent with the claim by Plaintiffs unless answer, claim or other action is taken within 30 days from the last publication of this decree. By the Court jsjJ. Wesley Oler, Jr., J. H. ANTHONY ADAMS Supreme Court ID# 25502 Attomey for Plaintiff 49 W. Orange Street Suite 3 Shlppensburg. PA 17257 (717) 532-3270 Oct. 21 6 ~ Proof of Publication of Notice in The News-Chronicle COUNTY OF CUMBERLAND COMMONWEALTH OF PENNSYLVANIA H. ANTHONY ADAMS Leslie R. Berrier, being duly sworn according to law, deposes and says that she is the Manager of 'The News-Chronicle," which is a bi-weekly newspaper of general circulation published in Shippensburg Township, Cumberland County, Pennsylvania, by Latrobe Printing and Publishing Company, a corporation duly organized and existing under the laws of the Commonwealth of Pennsylvania having its principal place of business at 1011 Ritner Highway (P.O. Box 100), Shippensburg, Pennsylvania; that she is authorized to and does make this affidavit on its behalf; that the printed notice, advertisement of publication attached hereto is the same as was printed in the regular editions and issues of "The News-Chronicle" on the following date(s) October 18.2005 Affiant further deposes that neither she nor "The News-Chronicle" and The Latrobe Printing and Publishing Company have any interest in the subject matters of the aforesaid notice or advertisement, and that the facts set forth in the foregoing affidavit is true and correct. ;~;~'Rt~~~f~ "lAC . ' d~ Day of tLoh-fr\ ,2005 I Notarial Seal Kristen L. Statler, Notary Public Bedford 60ro, Bedford County My Commission Expires Feb. 13.2006 Member, Pennsylvania A,-',sociation Of Notaries d(Lo-fcM d j-;u.i~ Notary Public To: 'The News-Chronicle" Shippensburg, P A 17257 For publishing the notice attached hereto: On the stated date( s) ................ $ Affidavit ............................. .$ Total...._................_........... $ 49.50 2.00 51.50 Copy of Notice of Publication IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Paul S. Zook Eva K. Zook Plaintiffs : No: 04-6346 Civil : Civil Action. Law vs. W.w. WMe Defendant To: W.W. Wh~e, his heirs, executors, administrators and assigns You are notffied that an Order has been entered to No. 04-3346 Civil in the Court of Common Pleas of Cumberland County, Pennsylvania on October 4, 2005 directing that within thirty (30) days after this publication you shall make answer or file claim. or take other action or be forever barred from asserting any right, lien, title or interest inconsistent with the Interest or claim set forth in the plaintiffs' compla;nt to the land therein described. This order is as follows: DECREE AND ORDER AND NOW this --AllL. dey of October 2005 after review of the attached petition and upon the motion of H. Anthony Adams, it is directed that the defendant be forever barred from asserting any right, lien, title or interest in the land Inconsistent with the claims by Plaintiffs unless answer, claim or other action Is taken which 30 days from the last publication of this decree. By the Court Isi J. Wesley Oler, Jr. Adv. NC Oct. 18. () -q " "'::\~ '-," -,. --: C:) .,.,,< III % r,,) -;-1 N :-!1 't:, :( -... -J '- -' -... , C:; ~; -- ~ (.'1 > :,,) ~ G; .< ~. ~ ~ t .~ . '>/ .. . f.; '.'rl,t_ f: 1- - -'-"- ., A <,; "",.'1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA r-' r PaulS. Zook Eva K. Zook Plaintiffs l,3l\\P : No: 04~ Civil : Civil Action - Law vs. W.W. White Defendant DECREE AND ORDER AND NOW this l{ ft, day of n L1 2005 after review of the attached petition and upon the motion of H. Anthony Adams, it is directed that the defendant be forever barred from asserting any right, lien, title or interest in the land inconsistent with the claim by Plaintiffs unless answer, claim or other action is taken which 30 days from the last publication of this decree. By the Court /' // .~ i Novanber 22, 2005, Final Judgment is here 'entered in favor of the Plaintiff and against the Defendant Pursuant to PA R.C.P Rule No 1066 & Loea Rule 1066.4 J. ~s~ :7. ,- \ ....:') \~.f' ~~7 s../J ::,IJJj... ~o ('5 '14 ( '... ,.\, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlY, PENNSYLVANIA PaulS.Zook Eva K. Zook Plaintiffs C,311<S : No: 04 J3415 Civil : Civil Action - Law vs. W.W. White Defendant PETITION FOR DECREE Now come the Petitioners, Paul S. Zook and Eva K. Zook, by and through their attorney, H. Anthony Adams and set forth the following: 1. Petitioners on or about December 17,2004 filed a complaint to the above term and number. 2. Petitioners sought and obtained the right to make service of the complaint by publication by petition filed February 28, 2005 and Court Order dated March 2, 2005. 3. Publication was made in the News-Chronicle on March 18, 2005 and in the Cumberland Law Journal on March 18, 2005. Proofs of publication are attached hereto. 4. The publications referred to in the previous paragraphs included the complaint which contained the required notice to defend. .' '. ,l, 5. Six months have passed and no answer or other response has been filed to the complaint. 6. Petitioners request the Honorable Court enter a decree and order directing that the Defendant, his heirs or assigns be barred from asserting any interest inconsistent with the claim of Plaintiffs unless answer or claim is made within 30 days. ~ \\~~ H. Anthony Adams, Esquire Attorney for Petitioners 49 West Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532 - 3270 VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date:~O-S .\~~~ H. ANTHONY ADAMS ~ ~ ~l (> / ~~ ...." f.;::;> c~, <..:...(1 UJ r-'''l ..,~ f'-"> -' o -11 :;:J 7:_:....,-, \ ilr-;:; :~)9 ',- -:~ ~::::: . ..., -- ~-' <C) (SiTl ...\ -.,:.. ~,O -< :."-:-~ ....0 -,