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Home My WebLink About13-5204 STEPHANIE A. MORRIS, IN THE COURT OF COMMON PLEAS PLAINTIFF OF CUMBERLAND COUNTY vs. t(J N0. TAMMY R. LITTLE, DEFENDANT LIS PENDENS PRAECIPE FOR LIS PENDENS TO THE PROTHONOTARY: As shown on the attached documents please index a lis pendens against TAMMY R. LITTLE and real property known as 59 Clugston Road, Newville, Pennsylvania 17241. Respectfully submitted, By: Steve owel; Esquire H ell Law Firm 19 Bridge Street New Cumberland, PA 17070 � Supreme Court I.D. 62063 (717) 770 -1277 mco Plaintiff s Counsel ' N Date: ;September 3, 2013 r -�!•�� x,11. �zz� Y`� hD�rCtr �`• 1 STEPHANIE A. MORRIS, IN THE COURT OF COMMON PLEAS PLAINTIFF OF CUMBERLAND COUNTY vs. / NO. ) 3 5 � q & ,I 1 `('e.ra1 TAMMY R. LITTLE, DEFENDANT LIS PENDENS NOTICE OF LIS PENDENS AGAINST REAL PROPERTY KNOWN AS 59 CLUGSTON ROAD, NEWVILLE, PENNSYLVANIA 17241 AND TAX PARCELS 30 -09- 0509 -004, 30 -09- 509 -56 AND 30- 09 -509- 57 TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please index this Lis Pendens against Defendant TAMMY It LITTLE of 59 Clugston Road, Newville, PA 17241. 1. Plaintiff Stephanie A. Morris is represented by Steven Howell, Esquire of 619 Bridge Street, New Cumberland, PA 17070 (717- 770 - 1277). 2. Defendant Tammy R. Little is a an adult individual residing at 59 Clugston Road, Newville, PA 17241 and is represented by Derek J. Cordier, Esquire of 319 South Front Street, Harrisburg, PA 17104. 3. Plaintiff and Defendant are subject to an Order of Court dated June 19, 2013 by the Honorable Thomas A. Placey of the Court of Common Pleas for Cumberland County in Case No. 2011- 02097. See Exhibit "A ". 4. Plaintiff and Defendant are litigants in a Cumberland County case captioned as Tammy Little v. Stephanie Morris, No. 2011- 02097. S. The June 19, 2013 Court Order directly affects title to 59 Clugston Road, Newville, PA 17241 as follows: "Defendant [Stephanie A. Morris] shall deliver to Plaintijps attorney [Derek j. Cordier, Esquire] an executed deed to transfer the property at issue to Tammy Little." , "The executed deed shall be held in escrow by Plaintij]'s attorney." "Plaintiffs attorney shall neither deliver to Plaintiff [Tammy R Little] nor record this executed deed until such time as the exchange of funds [$60,000.00] required under the 22 August 2010 Property Settlement Agreement are paid to Stephanie Morris [See Exhibit "B')." "If Plaintiff cannot arrange the financing necessary to remove Defendant from the mortgage and pay the Defendant what is owed under the terms of the Property Settlement Agreement within ninety (90) days of this order; the property at issue shall be listed for sale with a licensed real estate broker that is mutually acceptable to both parties and the executed deed shall be returned to Defendant's attorney [Steven Howell, Esquire]." 6. The real property subject to this Order is described in Record Book 226, Page 3951 and Instrument Number 200941163. 7. The doctrine of lis pendens provides notice to third parties that any interest that may be acquired in the property pending the litigation will be subject to the result of the action. Blumenfeld v. R M. Shoemaker Co. 286 Pa. Super. 540,429 A.2d 654 (1981). 8. Third parties are hereby placed on notice that no deed may be recorded nor any refinance take place without the sum of SIXTY THOUSAND AND 0/100 ($60,000.00) DOLLARS being paid directly to Stephanie A. Morris. Any payment may be made payable to Stephanie A. Morris but sent to her attorney, Steven Howell, Esquire of 619 Bridge Street, New Cumberland, PA 17070. Respectfully submitted, By: Ste n Howel , Esquire owell Law Firm 619 Bridge Street New Cumberland, PA 17070 Supreme Court I.D. 62063 1 (717) 770 -1277 Plaintiffs Counsel Date: September 3, 2013 VERIFICATION I /we verify that the statements made in the foregoing document are true and correct. I /we understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. This Verification is made by counsel and is based upon the express language of the June 19, 2013 Order of Court regarding the real estate ssue. BY:" St n Howl, Esqui e Date- eptember 3, 2013 OF THE I'RO rH F !C Of OTApY 2013 jUn 19 .P . TAMMY LITTLE, CUMBERLAND t pu.N. y or Pt.WNS YLVANI Plaintiff A V. IN THE COURT OF COMMON PLEAS. OF THE NINTH JUDICIAL DISTRICT STEPHANIE MORRIS, Defendant 2011 -02097 CIVIL'TERM IN:.RE; PETITION FOR SPECIAL RELIEF TO REQUIRE THE DEFENDANT TO PROVIDE T..HeORIGINAL S °IGNE0 I LAI +NTLfiF>IN:ORD R TO.4{ ;I €'T= :: TITLE AND ALLOW FOR REFINANCING OF THE PROPERTY AND DEFENDANT'S ANSWER ORDER OF COURT AND NOW, this 19 th day of June 2013, upon consideration of Plaintiff's petition and Defendant's answer thereto, the following Order is entered: 1. Defendant shall. deliver to Plaintiff's attorney an executed deed to transfer the property.at issue to Tammy Little; 2. The executed deed shall be held in escrow by Plaintiff's attorney; 3. Plaintiff's attorney shall neither deliver to Plaintiff nor record this executed deed until such time as the exchange of funds required under the 22 August 2010 . Property Settlement Agreement are paid to Step Morris; 4. If Plaintiff cannot arrange the financing necessary to remove Defendant from the .mortgage and pay the Defendant what is owed under the terms of the Property Settlement Agreement within ninety (90) days of this order, the property at issue shall be listed for sale with a licensed real estate broker that is mutually acceptable to both parties and the executed deed shall be returned to Defendant's attorney. EXHIBIT 6 z E COURT, D�stribu# Thoma Pla.cey C.P.J. Steve n Howell ; Esq. Derek J..Cordier Esq. i The balance of the proceeds shall be divided equally among and between the b parties. 7. Any and all utilities in the name of STEPHANIE MORRIS, including but not limited to ble internet and electric, shall be changed to the name of TAMMY LITTLE prior to ca , TAMMY LITTLE'S deployment to Iraq. 8, There is an existing balance due on the Lowe's credit card in which STEPHANIE MORRIS is the primary cardholder. TAMMY LITTLE shall pay the balance in full prior to her deployment to Iraq on August 22, 2010. The parties agree that as soon as possible, but under no circumstances later than j 9 p TAMMY I thirty (30) days after TAMMY LITTLE returns from her deployment to Iraq, LITTLE shall pay to STEPHANIE MORRIS a lump sum payment of SIXTY THOUSAND ($60,000.00) DOLLARS. ' STEPHANIE MORRIS shall be under no obligation to vacate the jointly owned 10 Pennsylvania property located at 59 Clugston Road, Newville, Cumberland County, owned 17241 until TAMMY LITTLE has refinanced the mortgage against the jointly or has received the lump sum payment of SIXTY THOUSAND ($60,000.00) prop e rtY DOLLARS, whichever occurs first. 11. Should STEPHANIE MORRIS reside at the jointly owned residence located at 59 Clugston Road, Newville, Cumberland County, Pennsylvania 17241 after TAMMY LITTLE deploys for Iraq on August 22, 2010, STEPHANIE MORRIS shall be � s onsible for fifty (50 %) percent of the cost of all electric, gas, oil and water. Fifty re p ercent shall be the responsibility of TAMMY LITTLE, which shall cover the (50 / ) p co co of utilitied necessary to care for all of the animals on the jointly owned p ropert y Cumberland County, Pennsylvania 17241 . located at 59 Clugston Road, Newville, or cable or internet, that cost � (Should there be other utility costs such as telephone EXHIBIT s x n E m STEPHANIE A. MORRIS, Plaintiff VS. TAMMY R. LITTLE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LIS PENDENS �3 -5;20 NO CIVIL PRAECIPE TO SATISFY AND RELEASE LIS PENDENS TO THE PROTHONOTARY: Please mark the Lis Pendens recorded on September 4, 2013 as satisfied and released upon praecipe by Plaintiffs Counsel. Respectfully submitted, By: S en How- (squire 619 Bridge Street New Cumberland, PA 17070 Supreme Court ID 62063 (717) 770 -1277 Voice Plaintiffs Counsel Date: February 11, 2014 RETURN TO: ALL STAR TITLE 6225 SMITH AVENUE, SUITE 202 BALTIMORE, MD 21209 1- 800 -580 -0677 P-1-0939 ALL soe 44.50 PD Tirti C-# 18f 8q8 o 5r 8(o