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Home My WebLink About13-6240 Supreme Court , -, Rennsylvania COUr =of -Comoro Pleas For Prothonotary Use Only: R� r i t i� t + /�l Cv`1Cover�, h et Docket No: S7 1.r CUMBERLAND Coun i Fn The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or otherpapers as required by law or rules of court. Commencement of Action: S Complaint 0 Writ of Summons ® Petition E Transfer from Another Jurisdiction ® Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: T ABIJAH IMMANUEL GEORGE M CORNWALL Dollar Amount Requested: Owithin arbitration limits I Are money damages requested? ®Yes No O (check one) Qoutside arbitration limits N Is this a Class Action Suit? 0 Yes El No Is this an MDJAppeal? 0 Yes 0 No A Name of Plaintiff /Appellant's Attorney: Check here if you have no attorney (are a Self - Represented (Pro Se] Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRJMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS 0 Intentional ® Buyer Plaintiff Administrative Agencies ® Malicious Prosecution ® Debt Collection: Credit Card rl Board of Assessment ® Motor Vehicle ® Debt Collection: Other ® Board of Elections ® Nuisance ® Dept. of Transportation ® Premises Liability ® Statutory Appeal: Other S 0 Product Liability (does not include Employment tort) Dispute: Slander /Libel / Defamation Discrimination ® C Other: Employment Dispute: Other Zoning Board T ® Other: I ® Other: O MASS TORT Asbestos N Tobacco Toxic Tort - DES Toxic Tort - Implant REAL PR.OPI 1.2TY MISCELLANEOUS ® Toxic Waste Other: ®ejectment [3 Common Law /Statutory Arbitration B ® 13minent Domain /Condenination Q Declaratory Judgment 0 Ground Rent Mandamus L ndlordffcn.mt Dispute E] Non - Domestic Relations Mortga,;c Foreclosure: Residential Restraining Order PROFESSIONAL L IABILITY ® Mortgage Forcclosure: Commercial Q Quo Warranto Q Dental Partition 0 Replevin Q Legal Ej Quict Title ® Other: Medical 0111cr: ® Other Professional: Updated 1 /1/2011 a " F #° ED i)r THE PROTHONOTARY ABIJAH IMMANUEL 2913 0CT 2 3 AN 1 f : 3 L 6828 Torresdale Ave Philadelphia, PA 19135 CUMBERLAND COW4T`( (215)333 -2233 PENNSYLVANIA THIS IS NOT AN ARBITRATION CASE CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION — CIVIL VS. GEORGE M CORNWALL No: ✓' l��`i v � and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse ACTION TO QUIET TITLE to plaintiff's ownership. DEFENDANT(S) NOTICE TO DEFEND 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. NAME: LAWYERS REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION ADDRESS: 32 S Bedford St Carlisle, PA 17013 -3302 (717) 249 -3166 atULl 12- y 1 . . ABIJAH IMMANUEL 6828 Torresdale Ave Philadelphia, PA 19135 (215)333 -2233 THIS IS NOT AN ARBITRATION CASE CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION — CIVIL VS. �l GEORGE M CORNWALL No: and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse ACTION TO QUIET TITLE to plaintiff's ownership. DEFENDANT(S) COMPLAINT IN ACTION TO QUIET TITLE 1. The cause of this action is as follows: Title insurance companies will not provide marketable title to Plaintiff's buyers unless Plaintiff completes an Action to Quiet Title. 2. The Plaintiff is ABIJAH IMMANUEL has a mailing address of 6828 Torresdale Avenue, First Floor, Philadelphia, Pennsylvania 19135. 3. Defendant(s) is /are GEORGE M CORNWALL an individual with a current address believed to be at P.O. Box 258 -430 5331 SW Mc Adam Ave, Portland, Oregon 97239. 4. Additional Defendants are all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to Plaintiff's ownership, or any cloud to Plaintiff's title. 5. With regard to those properties that were purchased by Plaintiff or Plaintiffs agent at either a tax sale or repository sale, some or all of the sales conveyed title to Plaintiff, free and clear of all mortgages, judgments and other claims, pursuant to the real estate tax sale law. In the alternative it is believed and alleged that any mortgages; judgments and any other claims held by defendants have either been paid and not satisfied off record or divested by. Pa statutes and should be stricken from the record. 6. Defendant(s) GEORGE M CORNWALL became fee simple owner of real property described in this Count as follows, to wit: ALL THAT CE -RTAIN lot with Folio Number: 23 -32- 2336 -407 (10 C Orange St) being more fully described in a Deed among the land records of the county and state set forth in Deed Book and Page # 280 -517. 7. On or about September 19, 2013 the Dauphin County Tax Claim Bureau, by the powers vested in it pursuant to the Real Estate Tax Sale Law, 72 P.S.. § 5860.101 et seq., sold property to Plaintiff. The Tax Claim Bureau sold the Property for nonpayment of taxes that constituted a valid lien on the Property, to Plaintiff, as the highest bidder at a public auction. 8. The legal and procedural authority pursuant to which plaintiff have filed this Action to Quiet Title is found in PA R.C.P. No. 1061(b)(4) which provides that: "...The action may be brought ... (4) to obtain possession of land sold at a judicial or tax sale..." , and PA R.C.P. No. 1061 (b) (3) "to compel an adverse party to file, record, cancel, surrender or satisfy of record, or admit the validity,. invalidity or discharge of, any document, obligation or deed affecting any right, lien, title or interest in land". Plaintiff seek a Court Order barring and enjoining Defendants, pursuant to PA R.C.P. No. 1066 (b) (1) shall order that the defendant. be forever barred from asserting any right, lien, title or interest in the land inconsistent with the interest or claim of the plaintiff set forth in the complaint...... WHEREFORE, Plaintiff respectfully prays that your Honorable Court will enter an Order and Decree that states that Plaintiff are the legal owner of the herein described real property and furthermore, enjoin said Defendant, his /her /their heirs, personal representatives, executors, administrators, successors and assigns and generally any and all other person(s) from having or claiming to have any type of right, lien, title or interest in and to said real property which is in any manner inconsistent with the interest, right, title of Plaintiff herein; and finally, enter an Order under PA R.C.P. No. 1066(b), granting the foregoing relief, together with a Writ of Possession as provided under PA R.C.P. No. 1061 (b)(4). Respectfully submitted, Date: IU l t C) /(a By ABIJAH IMMANUEL 6828 Torresdale Ave. Philadelphia, Pa 19135 (215)- 333 -2233 Verification The undersigned named Plaintiff takes this verification subject to Pa R.C.P. No. 1024 and states pursuant to 1S Pa C.S. Section 4904 that the facts set forth are true and correct subject to the following limitations, to wit: (1) facts alleged herein are taken from some of tiic facts alleged by Defendant in their Petition; or (2) information received from third parties, however, until further discovery is concluded, Plaintiff, cannot second party verify said facts; or (3) information from public records; or (4) I)clief that the Prothonotary strictly complied with Pa R.C.P. No. 236; or (5) a hon review of the circumsta e involved; or (6) upon either opinion, ifVd"rstan ling; Said Plaintiff re ery s the ribht to amend this verification after comp c 'On of the oral depo itio s. i A_bi J I mmanuel Plaintiff ABIJAH IMMANUEL 6828 Torresdale Ave Philadelphia, PA 19135 ' ° tile, 2: (215)333-2233 (215)333-2233 C1.FL '^ k �ENNS YL "A'NOT AN RATION CASE CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION—CIVIL VS. GEORGE M CORNWALL No: 2013-6240 and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse ACTION TO QUIET TITLE to plaintiff's ownership. DEFENDANT(S) To: GEORGE M CORNWALL P.O. Box 258-430 5331 SW Mc Adam Ave, Portland, Oregon 97239 Date of Notice: November 21St,2013. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY 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 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NAME: LAWYERS REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION ADDRESS: 32 S Bedford St Carlisle, PA 17013-3302 (717) 249-3166 t ABIJAH IMMANUEL 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION—CIVIL VS. GEORGE M CORNWALL No: 2013-6240 and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse ACTION TO QUIET TITLE to plaintiff's ownership. DEFENDANT(S) CERTIFICATE OF SERVICE I hereby certify that on this date IlLv 13 a copy of the foregoing pleading was served upon Defendant in this action. Service by first-class mail,postage, prepaid was sent to: GEORGE M CORNWALL P.O. Box 258-430 5331 SW Mc Adam Ave, Portland, Oregon 97239 BY; Abijah Imma uel 2 ABIJAH IMMANUEL „' 6828 Torresdale Ave Philadelphia, PA 19135 J } (215)333-2233 ;• E RL,r=.NC COUNTY THIS IS is VA N A ARBITRATION CASE : CUMBERLAND COUNTY, ABIJAH IMMANUEL : PENNSYLVANIA. : COURT OF COMMON PLEAS PLAINTIFF : TRIAL DIVISION—CIVIL VS. • GEORGE M CORNWALL : No: 2013-6240 • and all other persons unknown claiming any • right,title, estate, lien or interest in the real • property described in the complaint adverse : ACTION TO QUIET TITLE to plaintiff's ownership. DEFENDANT(S) • • MOTION FOR COURT ORDER PA. R.C.P. NO. 1066(a), (b) 1 AND NOW, the Plaintiff files the following Motion for Order under Pa.R.C.P. 1066(a), (b)(1) and in support thereof, aver the following: 1. Plaintiff is ABIJAH IMMANUEL, plaintiff in the above captioned matter. 2. Defendant is GEORGE M CORNWALL in the above captioned matter. 3. The present litigation involves an action to quiet title with regard to property known as lot or piece of ground situate in CUMBERLAND County,Pennsylvania real property described in this Count as follows,ALL THAT CERTAIN lot with Folio Number:23-32-2336-407(10 C Orange St)being more fully described in a Deed among the land records of the county and state set forth in Deed Book and Page # 280-517. 4. The Defendant is the former owner of the Subject Property; the Subject property having been sold to the Plaintiff by the CUMBERLAND County Tax Claim Bureau at upset sale on September 19TH , 2013 (Exhibit"A"). 5. Plaintiff filed a Complaint in Action to Quiet Tiled on October 23rd , 2013, requesting that the Court enter and Order quieting title to the Subject Premises. 6. The Defendant was served by via certified mail with a true and correct copy of the Complaint(endorsed with a Notice to Defend) on 10/31/2013. Pursuant to PA.R.C.P. 400 (b)...original process may be served also by a competent adult in the following actions: equity, partition, prevent waste, and declaratory judgment when declaratory relief is the only relief sought. Attached hereto and made part hereof, is a true copy of the "Return receipt" and acceptance of service (exhibit`B".) 7. GEORGE M CORNWALL,Defendant was sent a Notice of Default Judgment on 11/21/2013. (Exhibit"C") 8. To date, the Defendant has failed to file a response to the Complaint and more than 30 days have passed since service of the Complaint upon Defendant. 9. The Defendant is in default for failure to file a response to the Complaint within the time required under the Rules of Civil Procedure. 10. Rule 1066 provides, inter alia, that the Court may enter and Order in favor of a plaintiff when the defendant, as here, fails to file a response to a Complaint within the time required under the Rules of Civil Procedure. 11. Pursuant to Pa.R.C.P. 1066(a) The court shall grant appropriate relief upon affidavit that a complaint containing a notice to defend has been served and that the defendant has not filed an answer, or after a hearing or trial on the pleadings or merits....., contemporaneously with the filing of this Motion, Plaintiff are filing Affidavit stating that Defendant has been served with a Complaint containing a notice to defendant and that the Defendant has failed to file an answer.(Exhibit"D") 12. For the foregoing reasons, Plaintiff respectfully request that this Honorable Court issue and Order pursuant to Rule 1066 (b) (1) shall order that the defendant be forever barred from asserting any right, lien, title or interest in the land inconsistent with the interest or claim of the plaintiff set forth in the complaint..... , a proposed copy of which is attached hereto. WHEREFORE, Plaintiff, ABIJAH IMMANUEL, respectfully request that this Honorable Court enter an Order in accordance with Pa.R.C.P. 1066 (a), (b) 1 against the Defendant, GEORGE M CORNWALL, quieting his title to the Subject Premises, CUMBERLAND County,Pennsylvania, Folio Number: 23-32-2336-407(10 C Orange St)being more fully described in a Deed among the land records of the county and state set forth in Deed Book and Page# 280-517. espectfully Submi ted, BY; III — II:IJAH IMMANU L 6828 Torresdale Ave • iladelphia, PA 19135 EXHIBIT A UPSET PRICE SALE 00330M Tax ct(lItalin ?&wrau 3rr? Gets Peeb Made this day of November 20 , 13 between the TAX CLAIM BUREAU, of the County of Cumberland, Pennsylvania, as Trustee, Abijah Immanuel GRANTOR, and Grantee .1.t#ItessetII, that in consideration of $ $52,000.00 in hand paid, receipt whereof is hereby acknowledged, the said Grantor does hereby grant and convey unto the said Grantee, his heirs and assigns, the certain premises situate in Mt. Holly Springs Borough Cumberland County, Pennsylvania, as follows: 10 C Orange Street tax parcel#23-32-2336-407 see Appendix A for Legal Description George M Cornwell Owner or reputed owner as returned to said Bureau 10 C Orange Street Mt.Holly Springs PA 17065 the same having been sold by the Tax Claim Bureau to the said grantee, on the 19 day September 2013 of Anno Domini two thousand and after due advertisement according to law, the period of redemption for the payment of tax claims having expired without the property having been redeemed, or any tax judgements heretofore having been entered against the described property having not been satisfied, or no agreement to stay the sale of the within described property having been entered into, or the within described real estate no longer remaining in possession of a sequestrator, by Upset Price Sale. under and by virtue of the Act of 1947 PL 1368 (Real Estate Tax Sale Law), pin IN HUMS kl31ereof, said Grantor has hereunto caused this Deed to be executed by its Director the day and year first above written. TAX CLAIM BUREAU OF Signed, Sealed and Delivered CUMBERL: rD 0 ,- TY, PENNSYLVANIA, in the presence of: S / By �► (SEAL) ct. COMMONWEALTH OF PENNSYLVANIA ss: COUNTY OF CUMBERLAND On this, the - day of ,OPA 1 20 before me. the Prothonotary of the County of Cumberland, the undersigned officer. personally appeared Appendix "A" Tax Parcel No. 23-32-2336-407 Legal Description ALL THAT CERTAIN lot of land with improvements thereon erected situate in the Borough of Mount Holly springs, Pennsylvania, bounded and described in accordance with a certain Subdivision Plan for James H. and Mary C. Slyder by Larry V. Neidlinger, P.E.R.S., dated November 2, 2006, consisting of four pages, approved by the Borough Council of Mount Holly Springs, Pennsylvania on December 11, 2006, through a certain Agreement to Settle Boundary Dispute Between Adjoiners dated December 7, 2006, a copy of which was recorded on December 12, 2006 in Cumberland County Recorder of Deeds' Miscellaneous Book 732, Page 3581, with full sized copy of said Subdivision Plan also recorded in Right of Way Plan Book 14, Page 22, and more particularly bounded and described as follows: BEGINNING at an iron pin set on the westerly side of Orange Street at the dividing line between Lot No. 8 and Lot No. 9 as shown on the aforesaid Subdivision Plan; thence, along the westerly side of said Orange Street, South 37 degrees 52 minutes 16 seconds East 36.00 feet to an iron pin set at the dividing line between Lot No. 9 and Lot No. 10 of said Subdivision Plan; thence, along said dividing line between Lot No. 9 and Lot No. 10, South 52 degrees 07 minutes 44 seconds West 101.57 feet to an iron pin set at line of lands now or formerly of Suzanne G. White and Stephen T Blair; thence, by said lands now or formerly of White and Blair, North 37 degrees 29 minutes 06 seconds West 36.00 feet to an iron pin set at the dividing line between Lot No. 8 and Lot No. 9; thence, along said dividing line between Lot No. 8 and Lot No. 9, North 52 degrees 07 minutes 44 seconds East 101.33 feet to an iron pin set at the westerly side of Orange Street, the point and place of BEGININNG. CONTAINING 3,652.15 square feet, more or less. BEING all of Lot No. 9 as shown on the above mentioned Subdivision Plan for James E. and Mary C. Slyder. AND BEING the same premises which James H. Slyder and Mary C. Slyder, husband and wife, conveyed to George M. Cornwall, by deed dated May 8, 2007 and recorded in the Cumberland County Recorder of Deeds Office in Book 280, Page 517. EXHIBIT B i USP .COM. 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Find a 7IP Code n' Hold Mail _...__ Change of Address Tracking Number:70101870000209585395 Scheduled Delivery Day:October 31,2013 Product & Tracking Information Available Options Postal Product: Features: Email Updates First-Class Mail® Certified Mail" Return Receipt DATES,TIME STATUS OF ITENI LOCATION October 31,2013,12:15 Delivered PORTLAND,OR 97239 pm October 31,2013,4:09 Processed through PORTLAND,OR 97220 am LISPS Sort Facility October 30,2013,4:53 Processed through PORTLAND,OR 97220 pm USPS Sort Facility October 28,2013,10:42 Processed at USPS PHILADELPHIA PA 19176 pm Origin Sort Facility October 28,2013 Depart USPS Sort PHILADELPHIA PA 19176 Facility October 28,2013,5:18 Dispatched to Sort PHILADELPHIA PA 19135 pm Facility October 28,2013,4:54 Acceptance PHILADELPHIA PA 19135 Pm D"�r?: CC;rLE7 771/3 SECTION ` COMPLETE THIS SECTION ON DELIVERY e 3,4j:.: ` k erY is desired• X . : I,1 /0 0�n trtt 4 on the reverse A. " _ D Addressee to you B. R ,, re- C. D. a of•=Iive ttach th bac k of the rrtallpiece, d ; D le del 17 1:3 Yes IC . ' C:1 No t If YES e er = ; , • � ! � p OTHER LISPS SITES —.0 e S. � Business Customer Gateway Postal hspectors, . i yC ia v ,, Inspector General, s � t� l Q Express Mall Postal Explorer> � � � �ffi°- '��`�� ,�, 4 � �Retrtm;;Receipt fo`Merlcltandtse � C7 C.O.D.' ,� � ,� fiAafl t 4. ResMcted,Delivery7-(Extra Fee) 0 Yes ,i 7010 1870 0002 0958 5395 • 1/1 '"� 1T a t € = i 1Domeslc"Retun Receipt '"" 10259&o2,M-1d' EXHIBIT C ABIJAH IMMANUEL 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE : CUMBERLAND COUNTY, ABIJAH IMMANUEL : PENNSYLVANIA. : COURT OF COMMON PLEAS PLAINTIFF : TRIAL DIVISION—CIVIL • VS. • GEORGE M CORNWALL : No: 2013-6240 • • and all other persons unknown claiming any • right,title, estate, lien or interest in the real property described in the complaint adverse : ACTION TO QUIET TITLE to plaintiff's ownership. • DEFENDANT(S) • To: GEORGE M CORNWALL P.O. Box 258-430 5331 SW Mc Adam Ave, Portland, Oregon 97239 Date of Notice: November 21st ,2013. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY 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 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NAME: LAWYERS REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION ADDRESS: 32 S Bedford St Carlisle, PA 17013-3302 (717) 249-3166 1 ABIJAH IMMANUEL 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE : CUMBERLAND COUNTY, ABIJAH IMMANUEL : PENNSYLVANIA. : COURT OF COMMON PLEAS PLAINTIFF : TRIAL DIVISION–CIVIL VS. • • GEORGE M CORNWALL : No: 2013-6240 • and all other persons unknown claiming any right, title, estate, lien or interest in the real • property described in the complaint adverse : ACTION TO QUIET TITLE to plaintiff's ownership. DEFENDANT(S) • • CERTIFICATE OF SERVICE I hereby certify that on this date iticib3 a copy of the foregoing pleading was served upon Defendant in this action. Service by first-class mail,postage, prepaid was sent to: GEORGE M CORNWALL P.O. Box 258-430 5331 SW Mc Adam Ave, Portland, Oregon 97239 BY; A — - Abijah I m • , EXHIBIT D ABIJAH IMMANUEL 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE : CUMBERLAND COUNTY, ABIJAH IMMANUEL : PENNSYLVANIA. : COURT OF COMMON PLEAS PLAINTIFF : TRIAL DIVISION—CIVIL • VS. GEORGE M CORNWALL : No: 2013-6240 • • and all other persons unknown claiming any • right, title, estate, lien or interest in the real property described in the complaint adverse : ACTION TO QUIET TITLE to plaintiffs ownership. • DEFENDANT(S) • • PLAINTIFFS AFFIDAVIT FILED PURSUANT PA R.C.P. NO 1066(A) County of Philadelphia Commonwealth of PA : The undersigned, being authorized to take this Affidavit on behalf Plaintiffs, takes this Affidavit under PA R.C.P. No 1066(a) and states that the following facts are true and correct, to wit: 1. The Defendant was served by via certified mail with a true and correct copy of the Complaint (endorsed with a Notice to Defend) on 10/31/2013. Pursuant to PA.R.C.P. 400 (b)...original process may be served also by a competent adult in the following actions: equity, partition, prevent waste, and declaratory judgment when declaratory relief is the only relief sought. Attached hereto and made part hereof, is a true copy of the "Return receipt" and acceptance of service (exhibit "A". GEORGE M CORNWALL was served via certified mail on October 23"1 , 2013 at the following address. P.O. Box 258-430 5331 SW Mc Adam Ave, Portland, Oregon 97239. A true and correct copy of the sheriff's return of service is attached hereto. 2. Said Defendants have not filed an Answer or otherwise pleaded to Complaint within twenty(30) days from service. WHEREFORE, Defendant prays that the Court enter a judgment pursuant to PA.R.C.P. 1066(a), (b) (1) granting the relief requested by Plaintiff. espectfully Sub itted, 3 I BY; II /�I� t� ./ F , BIJAH IMMA UEL r 1 6828 Torresdal- Ave hiladelphia, PA 9135 Sworn to and subscribed before me this e2, day of December , 2013 _, Notary Publi CONMONWEALVI OF PENNSYLVANIA NOTARIAL SEAL MARILUZ CURIEL Notary Public City al PMad ,Phiia. P. Commission E June 11, 16 ABIJAH IMMANUEL 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE : CUMBERLAND COUNTY, ABIJAH IMMANUEL : PENNSYLVANIA. : COURT OF COMMON PLEAS PLAINTIFF • TRIAL DIVISION—CIVIL VS. : • GEORGE M CORNWALL No: 2013-6240 • • and all other persons unknown claiming any : right, title, estate, lien or interest in the real : property described in the complaint adverse ACTION TO QUIET TITLE to plaintiff's ownership. : DEFENDANT(S) : • • CERTIFICATE OF SERVICE I hereby certify that on this date a copy of the foregoing pleading was served upon Defendant of record in this action. Service by first-class mail, postage,prepaid was sent to: GEORGE M CORNWALL P.O. Box 258-430 5331 SW Mc Adam Ave, Portland, Oregon 97239 ' t BY; ,Aaldiblik F,, ;ABIJAH IMMAN f 6828 Torresdal:Ave Philadelphia, PA 1,6135 r y��r4�e 1�0 � V ,rr _ t'r�,.; fs .t . . I �r b c ABIJAH IMMANUEL 'a 9 •`'4- - H C 18 hi ' 4 6828 Torresdale Ave r.5,T* ?t �fY � �14hr�1� nt+ �� n !t CC, Philadelphia, PA 19135 V'"" r'' ' tiv, u ; { "�. .��' k �;,NIA (215)333-2233 THIS IS NOT AN ARBITRATION CASE : CUMBERLAND COUNTY, ABIJAH IMMANUEL : PENNSYLVANIA. : COURT OF COMMON PLEAS PLAINTIFF : TRIAL DIVISION—CIVIL VS. GEORGE M CORNWALL : No: 2013-6240 • • and all other persons unknown claiming any • right, title, estate, lien or interest in the real property described in the complaint adverse : ACTION TO QUIET TITLE to plaintiff's ownership. • DEFENDANT(S) ORDER '1h On this I I day of ¶ u WYE t,t , 2013, upon consideration of service of the Complaint endorsed with a Notice to Defend served on October 31st , 2013, and no answer having been made by Defendant,GEORGE M CORNWALL,AND upon consideration of the Plaintiff's MOTION FOR COURT ORDER PURSUANT TO Pa.R.C.P. 1061 (b)(4), 1066(a),(b)(1)the following ORDER is entered: granting the foregoing relief, together with a Writ of Possession as provided under PA R.C.P. No. 1061 (b)(4). Judgment shall be herby entered against the defendants,GEORGE M CORNWALL,heirs and assigns,and said Defendants shall be forever barred from asserting any right,lien,title or interest in the land inconsistent with the interest or claim of the plaintiff,ABIJAH IMMANUEL their heirs and assigns,as set forth in their complaint, unless said defendant files exceptions within thirty (30) days from the entry of this order pursuant to PA.R.C.P. 1066(b)(1). If such action is not taken with the 30 day period, the Prothonatary, upon praecipe of the plaintiffs, shall enter final judgment; Upon filing of the praecipe with the Prothonatary, the Plaintiffs shall present for recording at the Office of the Recorder of Deeds a certified copy of the Judgment and Order for recording. The property subject to this Order is located 10 C Orange St in,CUMBERLAND County,Pennsylvania,Folio Number: 23-32-2336-407 (10 C Orange St) being more fully described in a Deed among the land records of the county and state set forth in Deed Book and Page# 280-517. All filing and recording fees to record this Court Order shall be paid by Plaintiff. The Prothonatary/Recorder of Deeds is hereby directed to enter this order of record and to mail a copy of this Order to all parties of record pursuant to PA.R.C.P. 236. BY THE COURT: By: J Distribution List XORGE M CORNWALL P.O. Box 258-430 5331 SW Mc Adam Ave, Portland, Oregon 97239 ABIJAH IMMANUEL 6828 Torresdale Ave Philadelphia Pa, 19135 COPIICS iera, ai/Sh 3 WL L iut! T PR OT110,1.' 20130EC 18 AM 6: 4 4 4 ABIJAH IMMANUEL 6828 Torresdale Ave y C U M B LER L AND C QUNFf Y Philadelphia, PA 19135 L P ENNSYLVANIA (215)333-2233 THIS IS NOT AN ARBITRATION CASE CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION—CIVIL VS. GEORGE M CORNWALL No: 2013-6240 and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse ACTION TO QUIET TITLE to plaintiffs ownership. DEFENDANT(S) ORDER On this 11 day of IDUP%6v 2013, upon consideration of service of the Complaint endorsed with a Notice to Defend served on October 31St , 2013, and no answer having been made by Defendant,GEORGE M CORNWALL,AND upon consideration of the Plaintiff s MOTIONFOR COURT ORDER PURSUANT TO Pa.R.C.P. 1061 (b)(4), 1066(a),(b)(])the following ORDER is entered:granting the foregoing relief, together with a Writ of Possession as provided under PA R.C.P. No. 1061 (b)(4). Judgment shall be herby entered against the defendants,GEORGE M CORNWALL,heirs and assigns,and said Defendants shall be forever barred from asserting any right,lien,title or interest in the land inconsistent with the interest or claim of the plaintiff,ABIJAH IMMANUEL their heirs and assigns,as set forth in their complaint, unless said defendant files exceptions within ihirdy- (30)--days from the entry of this order pursuant to PA.R.C.P. 1066(b)(1). If such action is not taken � ith,f ; 3Q;dayperiod, the Prothonatary, I b�lq- Fno-I d q nen f is h& mb en* red in vcr ci4ie OR bqi ursu"i PA P0P RUN loa,p WL upon praecipe of the plaintiffs, shall enter final judgment; Upon filing of the praecipe with the Prothonatary, the Plaintiffs shall present for recording at the Office of the Recorder of Deeds a certified copy of the Judgment and Order for recording. The property subject to this Order is located 10 C Orange St in,CUMBERLAND County,Pennsylvania,Folio Number: 23-32-2336-407 (10 C Orange St) being more fully described in a Deed among the land records of the county and state set forth in Deed Book and Page#280-517. All filing and recording fees to record this Court Order shall be paid by Plaintiff. The Prothonatary/Recorder of Deeds is hereby directed to enter this order of record and to mail a copy of this Order to all parties of record pursuant to PA.R.C.P. 236. BY THE COURT: By: _ J Distribution List ZGEORGE M CORNWALL P.O. Box 258-430 5331 SW Mc Adam Ave, Portland, Oregon 97239 ABIJAH IMMANUEL 6828 Torresdale Ave Philadelphia Pa, 19135 r.. C. ABIJAH IMMANUEL Vii. ` r'rTHCffTAc ' 6828 Torresdale Ave 2,914 JAN 22 AM 10; S9 Philadelphia, PA 19135 (215)333-2233 CUMB L i2 9A' T T THIS IS N011U.;PRV'AWIA,S ARBITRATION CASE CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION—CIVIL VS. GEORGE M CORNWALL No: 2013-6240 and all other persons unknown claiming any right,title, estate, lien or interest in the real property described in the complaint adverse ACTION TO QUIET TITLE to plaintiff's ownership. DEFENDANT(S) PRAECIPE FOR FINAL JUDGMENT TO THE PROTHONATARY, Kindly enter Final Judgment against Defendant, GEORGE M CORNWALL, pursuant to Court Order dated December 17th, 2013, a true Copy of which is attached hereto as Exhibit"A", for failure to file Exceptions. No certification is required under Pa. R.C.P. 237 as no a y as appeared in the action. BY; ABIJAH IMRri UEL $lL . PAPt ENTRY OF JUDGMENT AND NOW, this omvd day of , 2014, Judgment is entered in accordance with the prior Order of Court. PROTH ARY !: ABIJAH IMMANUEL 6828 Torresdale Ave Philadelphia, PA 19135 GEORGE M CORNWALL P.O. Box 258-430 5331 SW Mc Adam Ave, Portland, Oregon 97239 c7 s ;;._ a R i 1.10�'w r- 0% 14 4 ABIJAH IMMANUEL 2&IVP bK 1 h� "1 013 0EEC ( 8 iii �= 6828 Torresdale Ave r - , n r,d i 1 Philadelphia PA 19135 'r � ' q�u+` C��1MBErRLMNO CHNIN T (215)333-2233 sit--TN � :s �, P1~1i1 SYLVA N1 THIS IS NOT AN ARBITRATION CASE CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION–CIVIL VS. GEORGE M CORNWALL No: 2013-6240 and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse ACTION TO QUIET TITLE to plaintiff s ownership. DEFENDANT(S) ORDER 'lh On this day of 14u A tf , 2013, upon consideration of service of the Complaint endorsed with a Notice to Defend served on October 31 S` , 2013, and no answer having been made by Defendant,GEORGE M CORNWALL,AND upon consideration of the Plaintiff's MOTIONFOR COURT ORDER PURSUANT TO Pa.R.C.P. 1061 (b)(4),1066(a),(b)(1)the following ORDER is entered:granting the foregoing relief, together with a Writ of Possession as provided under PA R.C.P. No. 1061 (b)(4). Judgment shall be herby entered against the defendants,GEORGE M CORNWALL,heirs and assigns,and said Defendants shall be forever barred from asserting any right,lien,title or interest in the land inconsistent with the interest or claim of the plaintiff,ABIJAH IMMANUEL their heirs and assigns,as set forth in their complaint, unless said defendant files exceptions within thirty (30) days from the entry of this order pursuant to PA.R.C.P. 1066(b)(1). If such action is not taken with the 30 day period, the Prothonatary, t 4�lq- Fna1 , d t�en� is he rebG e. i�ci i n Ivor c�-N,e P(airv4�` gCLUASf bbi pursuani � PA P-CP 'Ru.1e low-d Loca,i �e (�(�• , �y , PR.dT c&)0-rAP–y upon praecipe of the plaintiffs, shall enter final judgment; Upon filing of the praecipe with the Prothonatary, the Plaintiffi shall present for recording at the Office of the Recorder of Deeds a certified copy of the Judgment and Order for recording. The property subject to this Order is located 10 C Orange St in,CUMBERLAND County,Pennsylvania,Folio Number: 23-32-2336-407 (10 C Orange St) being more fully described in a Deed among the land records of the county and state set forth in Deed Book and Page 4 280-517. All -filing and recording fees to record this Court Order shall be paid by Plaintiff. The Prothonatary/Recorder of Deeds is hereby directed to enter this order of record and to mail a copy of this Order to all parties of record pursuant to PA.R.C.P. 236. BY THE COURT: By: r— J Distribution List ZGEORGE M CORNWALL P.O. Box 258-430 5331 SW Mc Adam Ave, Portland, Oregon 97239 ABIJAH IMMANUEL 6828 Torresdale Ave Philadelphia Pa, 19135 TRUE COPY FROM RECORD n - In Testimony whereof,I here unto set my hand and the se4il of said.Co i at carlisie,Pa.// This day of `' - 201�� r• f��.,` Prothonotary OFFICE OF THE PROTHONOTARY CUMBERLAND COUNTY DAVID D. BUELL PROTHONOTARY Date: 1/23/14 TO: Abijah Immanuel We are returning the enclosed transaction(s) for the following reason(s) : • Incorrect fee received: $ should be: $ • Need signature • Must provide duplicate copies of the proposed judgment, decree or order and stamped envelopes addressed to the said persons and/or attorneys for notification. Please note: This notification is not a substitute for service of process. • Other reasons : I'm sending this duplicate copy of the Praecipe for Final Judgment with a certified copy of the 12/17/14 Order. Thank you. P. Buell notary Square, Suite 100 17013 Note. All transactions dirpptpri in th:c rafirp r- -1-- QVT 4613o-h --TrAmaM e\ Mr. Abijah Immanuel 68285 Torresdale Avenue 1st Flow Philadelphia NI XI E U.S. POSTAGE >> PITNEY BOWES esrMsig'ssrOne ASMAZI1227 ozriin7o13 $ 000.46° ' 0001368646 JA 23 2014 i€ 4 z / RETURN TO SENDER ATTf1PTE2 - NUT K.NOWN UNABLE TO FORWARD BC: 17013339499 *0119-02164-23-42