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Home My WebLink About14-0683 Supreme Court of lennsylvania Court of.Common Pleas For Prothonotary Use Only. Civil Cover Sheet Docket No: `'�•� .Q -/'r�' County ? LIVE The information collected on this form is used solely for court administration purposes. This farm does not sztpplenrent or replace tlae /ilirtg a17d service of pleadings or other papers as required by lativ or rules of court. Coors encement of Action: S Li'( Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: ` I , -eft I Are money damages requested? ❑Yes Dollar Amount Requested: ❑within arbitration limits (check one) []outside arbitration limits O ,, R � iv N Is this a Class Action Suit? El Yes No Is this an MDJAppeal? El C Yes o A Name of Plaintiff /Appellant's Attorney: ❑ Check here if you have no attorney (are a Self - Represented (�'ro Sel Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY 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 ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other S ❑ Product Liability (does not include E mass tort) ❑Employment 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 PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Other: ❑ Ejectment ❑ Common Law /Statutory Arbitration B ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal 9Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1/2011 r Stephen D. Tiley, Esquire Supreme Court No. 32318 Frey and Tiley, Attorneys for the Plaintiff 5 South Hanover Street Tel.: 717- 243 -5838 Carlisle Pennsylvania 17013 Fax.: 717 - 243 -6441 DAVID A. KRULAC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA V. CIVIL ACTION - LAW . DORIS B. GARMAN, cn�� ESTATE OF DORIS B. . ACTION TO QUIET TITLE cn � vs GARMAN, -.- _- UNKNOWN HEIRS OF DORIS ` B. GARMAN, NO. 2014- r3 G NORTH STAR CAPITAL ACQUISITION, LLC, LOWER ALLEN TOWNSHIP AUTHORITY, CITIFINANCIAL SERCIES, INC.,: ONEMAIN FINANCIAL, CHURCH OF GOD HOME, INC. Defendants. 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 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association _ fjb3- -7 �� I 32 South Bedford Street /. -#f 7 Carlisle, Pennsylvania 17013 S' Telephone: 717- 249 -3166 0 /oz Stephen D. Tiley, Esquire Supreme Court No. 32318 Frey and Tiley Attorneys for the Plaintiff 5 South Hanover Street Tel.: 717 - 243 -5838 Carlisle, Pennsylvania 17013 Fax.: 717 -243 -6441 DAVID A. KRULAC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA V. CIVIL ACTION - LAW DORIS B. GARMAN, ESTATE OF DORIS B. ACTION TO QUIET TITLE GARMAN, UNKNOWN HEIRS OF DORIS � B. GARMAN, N0.2014- NORTH STAR CAPITAL ACQUISITION, LLC, LOWER ALLEN TOWNSHIP AUTHORITY, CITIFINANCIAL SERCIES, INC.,: ONEMAIN FINANCIAL, CHURCH OF GOD HOME, INC. Defendants COMPLAINT TO QUIET TITLE AND NOW, comes David A. Krulac, Plaintiff, by his attorney, Stephen D. Tiley, Esquire, and files this Complaint to Quiet Title, of which the following is a statem ent: First Named Parties 1. Plaintiff is David A. Krulac, an adult individual, of Cumberland County, Pennsylvania, having a business address of P.O. Box 1064, Mechanicsburg, Pennsylvania, 17065. 2. Defendant Doris B. Garman is deceased. The said Doris B. Garman was formerly a resident of 5 Wayne Circle, Camp Hill, Pennsylvania Complaint to Quiet Title Krulac v. Garman, et. al. Page 1 of 14 17011, the property which is the subject of this quiet title action. (See also paragraphs 23 through 38 of this Complaint.) The Property 3. This Quiet Title Action concerns the following property (hereinafter referred to as the "Property"): ALL THAT CERTAIN tract of land with the buildings and improvements thereon erected situated in Lower Allen Township, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northerly line of Wayne Circle, which point is 240.71 feet East of the northeasterly corner of Wayne Circle and Wayne Road and the dividing line between Lots Nos. 138 and 139; thence along the said division line North 3 degrees 59 minutes 30 seconds West 124.27 feet to a point; thence along the southerly line of Lots 127, 126 and 125 on said Plan South 59 degrees 3 minutes 30 seconds East 117.02 feet to a point on the westerly line of Lot No. 140; thence along same South 42 degrees 35 minutes West 109.85 feet to a point on the northerly line of Wayne Circle aforesaid; thence along same in an arc having a radius of 45 feet to the left, in a westerly direction forty (40) feet to a point, the Place of BEGINNING. BEING Lot No. 139 in Plan of Cumberland Park, Inc., which Plan is recorded in the Cumberland County Recorder's Office in i Plan Book 4, Page 86, and being improved with a dwelling known as 5 Wayne Circle. BEING the same premises which Debra L. Raemore (formerly known as Debra Kaye Long) and Jon S. Raemore, her husband by deed dated November 13, 1985 and recorded in the Office of the Recorder of Deeds in and for the County of Cumberland, Pennsylvania in Book "P," Volume 31, Page 88, . granted and conveyed to Doris B. Garman. ALSO BEING the same premises which the Cumberland County Tax Claim Bureau, by deed dated October 6, 2011 and recorded October 10, 2011 in the aforementioned Recorder's Office Complaint to Quiet Title Krulac v. Garman, et. al. Page 2 of 14 to Instrument Number 2011- 27922, granted and conveyed as the property of Doris B. Garman, to David A. Krulac. ALSO KNOWN AS 5 Wayne Circle, Camp Hill, PA 17011. ALSO KNOWN AS UPI No.: 13 -24- 0797 -139. 4. On September 22, 2011 Plaintiff purchased the Property at a Judicial Tax Sale, pursuant to proceedings filed by the Cumberland County Tax Claim Bureau to Cumberland County Prothonotary No..: 2011 -2715. 5. Plaintiff paid $50,000, plus recording costs and transfer tax, for the Property. 6. On October 10, 2011 the Cumberland County Tax Claim Bureau recorded a deed conveying the Property to the Plaintiff, David A. Krulac. A copy of the deed is attached hereto, marked Exhibit 'A" and is incorporated herein by reference thereto. The Property was sold as the property of Doris B. Garman. The deed is recorded to Cumberland County Instrument No.: 2011 - 27922. A 60 year abstract of title is attached hereto as Exhibit "B." 7. As can be seen from the Recorder's certificate attached to the Tax Claim Bureau Deed which is Exhibit "A" to this Complaint, the Recorder incorrectly indexed the deed as being from David A. Krulac as Grantor to Doris B. Garman as Grantee. However, at some point thereafter the Recorder of Deeds corrected the indexing to Doris B. Garman as Grantor and David A. Krulac as Grantee. 8. Plaintiff is in possession of the Property. 9. The Judicial Tax Sale sold the Property free and clear of all liens and encumbrances except ground rents separately taxed. The Property is not subject to any ground rents. Complaint to Quiet Title Krulac v. Garman, et. al. Page 3 of 14 North Star Capital 10. Defendant North Star Capital Acquisition, LLC, is a foreign entity: (a) Having a Pennsylvania registered office of: c/o CT Corporation System, Dauphin, Pennsylvania (No address given. See paragraph 11 of this Complaint.); (b) Believed to have an business address of. 170 North Pointe Parkway, Suite 300, Amherst, NY 14228 (as identified by internet search), and (c) Also of c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054, which is the address given in the hereinafter referenced complaint that North Star Capital Acquisition, LLC filed against the Defendant Doris B. Garman. 11. The registered office of CT Corporation System (referenced at paragraph 10 (a) of this Complaint) is: 116 Pine Street, Suite 320, Harrisburg, Pennsylvania 17101. (See paragraph 5(a) of this Complaint.) 12. The Property had been subject to a judgment in favor of Defendant North Star Capital Acquisition, LLC, which was filed to Cumberland County Prothonotary number 2009 -06216 in the amount of $1,660.48. (the "North Star lien ") The North Star lien was a result of a judgment issued against Doris iB. Garman. 13, The Judicial Tax Sale did not produce sufficient funds to make any payment on the North Star lien, and no payment to that creditor was in fact made. Complaint to Quiet Title Krulac v. Garman, et. al. Page 4 of 14 14. The North Star lien was extinguished by the Tax Claim Bureau's Judicial Tax Sale of the Property, but it remains unsatisfied on the Prothonotary's records. Lower Allen Township Authority 15. The Defendant Lower Allen Township Authority is a Pennsylvania municipal authority having an address of 120 Limekiln Road, New Cumberland , Pennsylvania 17070. 16. The Property had been subject to four municipal liens in favor of Defendant Lower Allen Township Authority, which are filed to Cumberland County Prothonotary numbers: 2007 - 02992, 2008 - 02769, 2009 - 02712, and 2010 -2871. (the "Authority Liens ") The Authority Liens were filed against the Property with Doris B. Garman as the owner thereof. 17. As part of the Tax Claim Bureau Judicial Sale proceedings the Cumberland County Tax Claim Bureau obtained payoff amounts for the Authority Liens and paid them in full. The Authority Liens were extinguished by the Tax Claim Bureau's Judicial Sale of the Property, but they remain unsatisfied on the Prothonotary's records. CitiFinancial Services, Inc. (OneMain Financial) 18, The Defendant CitiFinancial Services Inc. is a business entity with an address of: CitiFinancial Services, Inc., c/o OneMain Financial, 3401 Hartzdale Drive, Suite 126, Camp Hill, PA 17011. The said physical address is the same as set forth on the hereinafter referenced Citi Mortgage. Defendant OneMain Financial is the successor of CitiFinancial Services, Inc. for this loan and has an office at the address given in this paragraph of this Complaint. Complaint to Quiet Title Krulac v. Garman, et. al. Page 5 of 14 1.9. Additional addresses. for the Defendant Citi Financial Services Inc. given on the hereinafter mentioned payoff statement and the hereinafter mentioned satisfaction piece are: (a) CitiFinancial, 6400 Las Colinas Blvd., Mail Stop — C2 -83, Irving, Texas, 75039, and (b) CitiFinancial Investment Recovery, Attn: Payment Processing, C /O: Latasha Anderson 605 Munn Rd, Fort Mills, South Carolina 29713. (c) CitiFinancial Services, Inc., 14700 Citicorp Drive, MC: 1020, Hagerstown, Maryland 21742. 20. The Property had been subject to a mortgage in favor of Defendant Citifinancial Services, Inc. recorded April 23, 2003 in Cumberland County Mortgage Book 1807, Page 4074 in the amount of $75,753.81. (the "Citi Mortgage ") The Citi Mortgage was given by Doris B Garman. 21. As part of the Tax Claim Bureau Judicial Sale proceedings the Cumberland County Tax Claim Bureau obtained a payoff statement for the Citi Mortgage indicating an unpaid balance of $74,804.04. As part of the Judicial Tax Sale proceedings Citi Financial received $36,998.35 of the sale proceeds. 22. A satisfaction piece was recorded for the Citi Mortgage on April 9, 2012 to Instrument No. 2012 - 09989. The lien of this mortgage was also extinguished by the Tax Claim Bureau's Judicial Sale of the Property. Doris B. Garman Estate & Heirs 23. Defendant Estate of Doris B. Garman is the estate of the individual referenced at paragraph 2 of this Complaint. There is no known court appointed Complaint to Quiet Title Krulac v. Garman, et. al. Page 6 of 14 administrator or executor of the Estate of Doris B. Garman, nor outstanding administration of the said Estate. 24. Defendant "Unknown Heirs of Doris B. Garman" are such unknown heirs of the individual referenced at paragraph 2 of this Complaint. 25. The Plaintiff believes, and therefor avers, that the Defendant, Doris B. Garman is deceased, having died April 23, 2010, a resident of Cumberland County, Pennsylvania. 26. In the files of the Cumberland County Tax Claim Bureau there exists a copy of an obituary for Doris B. Garman, that appeared in The Patriot newspaper on May 12, 2010, a copy of which is attached hereto as Exhibit "C," and is incorporated herein by reference thereto. 27. In the files of the Cumberland County Tax Claim Bureau there exists a copy of an Accurint computer search report for Doris B. Garman indicating that she died at age 80, a copy of which is attached hereto as Exhibit "D," and is incorporated herein by reference thereto. Also attached as a part of Exhibit "D" is an obituary search from Ancestry.com showing that Doris B. Garman was born on October 20, 1929 and died on April 23, 2010 at age 80. 28. The obituary attached hereto as Exhibit "C" states that Doris B. Garman was survived by unspecified cousins. 29. Emory D. Hostetter of 30 Kough Road, Newville, Pennsylvania 17241 was identified by the Tax Claim Bureau as one of those cousins and is being served with a copy of this Complaint, although not a specifically named defendant. Emory D. Hostetter had contacted an attorney in Shippensburg, Pennsylvania, with the intention of taking out letters of administration in the estate of Doris B. Garman. However, when he learned of the hereinafter Complaint to Quiet Title Krulac v. Garman, et. al. Page 7 of 14 described Will held by PNC Bank, and that the estate had no net assets, he ceased interest in taking out letter of administration. 30. The decedent, Doris B. Garman died leaving a Last Will and Testament dated January 4, 1984, naming CCNB Bank, N.A. of Camp Hill, Pennsylvania, as Executor. By letter of June 22, 2010 to the Cumberland County Register of Wills Office PNC Bank, N. A., successor to CCNB Bank, N.A.; renounced its right to serve as Executor. A copy of that letter is attached as Exhibit "E" and is incorporated herein by reference thereto. 31. The June 22, 2010 letter included a copy of the January 4, 1984 Will and indicated that PNC Bank, N.A. retained the original. A copy of the Will is attached as Exhibit "F" and is incorporated herein by reference thereto. 32. The June 22, 2010 letter is from Linda J. Lundberg, of PNC Wealth Management, 4242 Carlisle Pike, Camp Hill, Pennsylvania 17011 on behalf of PNC Bank, N.A., Executor. A copy of this Complaint is being served upon PNC Wealth Management at said address, as the entity acting for PNC Bank, N.A., named Executor of the Will of Doris B. Garman. 33. PNC Bank, N.A., Executor, also maintains a branch bank at 4242 Carlisle Pike, Camp Hill, Pennsylvania 17011. A copy of this Complaint is being served upon PNC Bank, N.A.at said address, as named Executor of the Will of Doris B. Garman. 34. Paragraph First of the January 4, 1984 Will names Frank Barrancotto and Josephine Barrancotto, husband and wife, of 3936 Bernice Drive, San Diego, California, as residuary beneficiaries, or the survivor of them as sole residuary beneficiary, so long as at least one of them survives. Complaint to Quiet Title Krulac v. Garman, et. al. Page 8 of 14 35. The June 22, 2010 . PNC letter states that through discussions with their son, it was confirmed that Frank Barrancotto died in 1994 and that Josephine Barrancotto died in February 20, 2010, prior to the passing of Doris B. Garman on April 23, 2010. 36. Frank Barrancotto died on November 22, 1994 as evidenced by a printout of an Ancestry.com search attached as Exhibit "G" and is incorporated herein by reference thereto. 37. Josephine Barrancotto died on February 20, 2010 as evidenced by a printout of an Ancestry.com search attached as Exhibit "H" and is incorporated herein by reference thereto. 38. Paragraph Second of the January 4, 1984 Will names The Church of God Home of Carlisle, Pennsylvania, as contingent residuary beneficiary. Church of God Home, Inc. 39. Defendant Church of God Home, Inc. is a Pennsylvania non - profit corporation of 801 North Hanover Street, Carlisle, Pennsylvania 17013. 40. Defendant Church of God Home, Inc. is the residuary beneficiary of the estate of Doris B. Garman as provided in her unfiled January 4, 1984 and as described in paragraphs 34 through 38 of this Complaint. 41. The June 22, 2010 PNC letter states that The Church of God Home declined to serve as administrator. 42. As of.the date of the filing of this Complaint no Will of Doris B. Garman has been probated and no individual or entity has petitioned for letters testamentary, nor petitioned for letters of administration with or without a Will. Complaint to Quiet Title Krulac v. Garman, et. al. Page 9 of 14 Legal Background 43. Pa. R.C.P.1061(b)(2) provides, that an action to quiet title may be brought: "when an action of ejectment will not lie, to determine any right, lien, title or interest in the land, or determine the validity or discharge of any document, obligation or deed affecting any right, lien title or interest in land." 44. The Plaintiff being in possession of the Property, an action in ejectment may not be brought by him. 45. Pa. R.C.P.1061(b)(3) provides, in part, that an action to quiet title may be brought to compel an adverse party to satisfy of record, or admit the discharge of, any document, obligaton or deed affecting any right, title, or interest in land. 46. Pa. R.C.P.1061(b)(4) provides that an action to quiet title may be brought to obtain possession of land sold at judicial or tax sale. 47. Pa. R.C.P. 1066 provides: (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 answer, or after a hearing or trial on the pleadings or merits. (b) Upon granting relief to the plaintiff, the court: (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, i unless the defendant takes such action as the order directs within thirty days thereafter. If such action is not taken within the thirty- day period, the prothonotary on praecipe of the plaintiff shall enter final judgment; Complaint to Quiet Title Krulac v. Garman, et. al. Page 10 of 14 (2) shall enter a final judgment that a document, obligation or deed affecting a right, lien title or interest in the land is cancelled or is valid, invalid or discharged or that a copy of a lost plan, document, obligation or deed is an authentic copy; (3) shall enter a final judgment ordering the defendant, the prothonotary, or the recorder of deeds to file, record, cancel, surrender or satisfy of record, as the case may be, any plan, document, obligation or deed determined to be valid, invalid, satisfied or discharged, and to execute and deliver any document, obligation or deed necessary to make the order effective; or (4) shall enter any other order necessary for the granting of proper relief. WHEREFORE, the Plaintiff prays Your Honorable Court for an Order: (a) Declaring that the Tax Claim Bureau Deed to Plaintiff recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania to Instrument Number 2011 -27922 is valid to convey full fee simple title to the property known as Cumberland County UPI No. 13 -24- 0797 -139 to David A. Krulac, an adult individual, of Cumberland County, Pennsylvania. (b) Declaring that the Defendant, Doris 'B. Garman, is barred from asserting any right, lien, title, or interest in the Property inconsistent with the claim of the Plaintiff; (c) Declaring that the Defendant, Estate of Doris B. Garman, is barred from asserting any right, lien, title, or interest in the Property inconsistent with the claim of the Plaintiff; (d) Declaring that the Defendants, Heirs of Doris B. Garman, are barred from asserting any right, lien, title, or interest in the Property inconsistent with the claim of the Plaintiff; Complaint to Quiet Title Krulac v. Garman, et. al. Page 11 of 14 (e) Declaring that the Defendant, Church of God Home, Inc., is barred from asserting any right, lien, title, or interest in the Property inconsistent with the claim of the Plaintiff; (f) Declaring that the Plaintiff is the legal owner of the Property and that legal title to the Property is vested solely in the Plaintiff, and that the Court's Order be recorded in the Recorder of Deeds Office of Cumberland County, Pennsylvania, and indexed as a deed with the Grantors being "Doris B. Garman," "Estate of Doris B. Garman," and "Heirs of Doris B. Garman," and that these proceedings, or an authenticated copy thereof, shall at all times hereinafter be taken as evidence of the facts decreed and established herein. (g) Declaring that any lien or interest of the Defendant North Star Capital Acquisition, LLC in the Property was extinguished by the September 22, 2011 Judicial Tax Sale and forever barring North Star Capital Acquisition, LLC from asserting any right, lien, title, or interest in the Property inconsistent with the interest of the Plaintiff, on the basis of the judgment filed to Cumberland County No. 2009 - 02616, or on any other basis predating this Complaint. (h) Directing the Cumberland County Prothonotary to mark the judgment of North Star Capital Acquisition, LLC, filed to Cumberland County No. 2009 -02616 satisfied on the record. (i) Declaring that any lien or interest of the Defendant Lower Allen Township Authority in the Property was extinguished by the September 22, 2011 Judicial Tax Sale and forever barring it from asserting any right, lien, title, or . interest in the Property inconsistent with the interest of the Plaintiff, on the basis of the judgments filed to Cumberland County Prothonotary numbers: 2007- 02992, 2008 - 02769, 2009 - 02712, and 2010 -2871 or on any other basis predating this Complaint. Complaint to Quiet Title Krulac v. Garman, et. al. Page 12 of 14 (j) Directing the Cumberland County Prothonotary to mark the judgments of Lower Allen Township Authority filed to Cumberland County Prothonotary numbers: 2007 - 02992, 2008 - 02769, 2009 - 02712, and 2010 -2871 satisfied on the record. (k) Declaring that any lien or interest of the Defendant CitiFinancial Services, Inc. in the Property was extinguished by the September 22, 2011 Judicial Tax Sale and forever barring it from asserting any right, lien, title, or interest in the Property inconsistent with the interest of the Plaintiff, on the basis of the mortgage recorded to Cumberland County Mortgage - Book 1807, Page 4074. (1) Such other and further relief as the Court may deem just and proper. Dated: 1c;; Respectfully submitted, STEPHEN D. TILEY, Esquire FREY and TILEY Attorney for Plaintiff 5 South Hanover Street Carlisle, PA 17013 Tel.: (717) 243 -5838 Supreme Court No.: 32318 Complaint to Quiet Title Krulac v. Garman, et. al. Page 13 of 14 VERIFICATION I verify that the statements made in the foregoing Complaint to Quiet Title are true and correct, partially upon personal knowledge and partially upon my belief; to the extent language in the Answer is that of my attorneys, I have relied upon my attorneys in making this Verification. I understand that false statements herein are made and subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. DAVID A. KRULAC 7 Complaint to Quiet Title Krulac v. Garman, et. al. Page 14 of 14 0 12:58 7177319081 DK PAGE 18/24 1 I . I NI I I� N .ruD1CIAL SALi'r 03VB7 Lax tRa is APPb Made this .................... October .................. day of .......................... between the TAX CLAIM BUREAU,, of the County. of Cumberland, Pennsylvania, as Trustee, GRANTOR, and David A. Krulac .......................................................... ............................... ............. Grantee t itrmss Pr that n consideration of $50 + c"" � �� h i $•••• 000 •••••••• ...... .00 .......... in hand paid, receipt whereof is hereby acknowledged, the said Grantor does hereby grant and convey unto the said Grantee n heirs and assigns, the certain premises situate in Lower Allen Township Cumberland County, Pennsylvania, as follows: 5 Wayne Circle tax parcel # 13-24 -0797 -139 see Appendix A for Legal Description Doris B. Garman Owner or reputed owner as returned to said Bureau 5 Wayne Circle Camp Mill, PA 17011 the same having been sold by the Tax Claim .13ureau to the said grantee, on the ...........22 ................. day of ..... Sep.tember ............... 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 seclueslrator, by Judicial Sale. under and by virtue of the Act of 1947 PL 1368 (Real Estate Tax Sale Law), P n pitness p4ererlf, said Grauror has hereunto caused this Deed to be executed by its Director the day and year first above written. TA BUREAU OF Signed. Scaled and Delivered CUMSE ND COU I'sNNSYLVANIA, in the presence of: T STE ................................................................. ............................... B ...... ....... . ....... (SEAL) cc or r. OF PLNNSYI.VANIA SS COUNTY OF CUNIBF.RLAND /J Onthis. the ................. /.Q �...I............. day r..f ............fi-' �................ ............................... before me, the Prothonotary of the County of Cumberland, the undersigned officer, Personally appeared Melissa I i Mxell ....... ....... ..... ............................... xel Director of the Tax Claim Bureau of the County of Cumberland, ,ComauonivealY t of Pennsylvania, known to me to be. the person described in the foregoing InSLL,t1t�i�li� i�LI.�C 11JJ N�'le(�;I.l`•1.a5t he executed the same in the capacity therein stated and for the pur- poS +s tlt3? et �W�, _�•� -.�. .� �,� }? b'.•,�'�Eit� . sh ve hereunto set . id o -..ea l. my }tend v '1 E�Y�fK^n!""a+oAd.illtrffiN•, r ............... ... ....(! .- ............................. Terlifirair of 1rsitilrnrr L;a r by-certify a at h( precise residence of the grantee herein is as follows: ................................ David A. Krulac, P O Box 1064, Mechanicsburg PA 17055 . to Stephen D.T51ey rr1 „ Cumberland County, Assistant Solicitor - 04/30/2019 12:50 7177219021 DK PAGE 19/24 Appendix "A" Tax Parcel No. 13 -24 -0797 -139 Legal Description ALL THAT CERTAIN tract of land, with the buildings and improvements thereon erected situated in Lower Allen township, Cowity of Cumberland and State of PenzLsylvania, more particularly bounded: and described, as follows, to wit: BEGINNING at a. point on the Northerly line of Wayne Circle, which point is 240.71 feet east of the Northeasterly corner of Wayne Circle and Wayne Road and the dividing line between Lots Nos. 1.38 and 139; thence along the said division line North 3 degrees 59 minutes 30 seconds West 124.27 feet to a point; tlience zlo:n.g the Southerly line of Lots 127, 126, and. 125 on said Plan South 59 degrees 3 minutes 30 seconds East 117.02 feet to a point on. the Westerly line of Lot No. 140; thence along same South 42 degrees 35 minutes West 109.85 feet to a point on the Northerly line of Wayne Circle aforesaid; thence along same in an arc having a radius of 45 feet to the left, in a Westerly direction fbi ty (40) feet to a point, the place of BEG1 NOTING. BEING lot 139 in Plan of Cumberland Paris, Inc., which Plan is recorded in the Cumberland Co. Recorder's Office in Plain Book 4, Page 86, and being improved with a dwelling known as 5 Wayne Circle. BEING the same premises which Debra L. Raemore (formerly known as Debra Kaye Long), and Ton S. Ra.emore, her husband, by deed dated November 23, 1985 and recorded in the Office of the Recorder of Deeds in and for. the County of Cumberland, Pew)sylvania in Book P31, Page 88, granted and conveyed to Doris B. Garman. 04/,;;0:''2019 12: 58 11 - DK 2 P=;GE 0/24 ROBERT P. ?IEGL.ER RECORDER OF DEEDS CUMBERLAND COUNTY — � ^' 1 1 COURTHOUSE SQUARE _ P, ,a ��— CARLISLE, PA, 17013 717 -240 -6370 p, Instrument: Number - 201127922 Recorded On 1.0/1.0/2011 At 110:42:26 AM * Total Pages - 5 Instrument Type - DEED Invoice Number - 94645 User ED - MSW * Grantor - ERULA.C, DAVID A, Grantee - GARMAN, DORIS B * Customer - CUIVl.T3ERLA.ND COUNTY * FEES STATE TRANSFER TAX $1,205.00 Certification Page STATE WAIT TAX $0.50 STATE JCS /ACCESS TO $23.50 DO NOT DETACH J"JSTICE RECORDING FEES — $12.50 RECORDER OF DEEDS This page is now part - PARCEL CERTIFICATION $10.00 of this legal document. FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 WEST SHORE SCHOOL $602.50 DISTRICT LOWER ALLEN TOWNSHIP $602.50 TOTAL PAID $2,473.00 I Certify this to be recorded in Cumberland County PA �p Cti/y RECORDER 'EDS 1, - Informmion denoted by an asterisk may change during the verification process And mAy not. be reflected on this page. I ( 003V57 !!`` III I(il��fl�IlE ill �Itll�� II Exhibit "B" Abstract of Title (a) Deed Recorded To: inst. No. 2011 -27922 Grantor: Tax Claim Bureau (Property of Doris B. Garman) Grantee: David A. Krulac Date: October 6, 2011 Recorded: October 10, 2011 (b) Deed Recorded To: 28 -G -993 Grantor: Lawrence M. Harder and Margaret M. Harder (h /w) Grantee: Doris B. Garman Date: October 6, 1978 Recorded: October 10, 1978 (c) Deed Recorded To: 25 +358 Grantor: Thomas Daly and Ruth A. Daly (h /w) Grantee: Lawrence M. Harder and Margaret M. Harder (h /w) Date: September 28,1973 Recorded: October 2, 1973 Exhibit "B" Page I of 3 (d) Deed Recorded To: 23 -Q -302 Grantor: Edwin C. Hench and Maureen 0. Hench (h /w) Grantee: Thomas Daly and Ruth A. Daly (h /w) Date: May 20,1970 Recorded: May 21,1970 (e) Deed Recorded To: 22 -M -584 Grantor: Donald W. Hench and Ruby J. Hench (h /w) Grantee: Edwin C. Hench and Maureen 0. Hench (h /w) Date: September 1, 1967 Recorded: September 8, 1967 ( Deed Recorded To: 21 -P -518 Grantor: Philip N. Brownstein, Federal Housing Commissioner Grantee: Donald W. Hench and Ruby J. Hench (h /w) Date: May 26,1965 Recorded: June 1, 1965 Exhibit , B „ `,�' Page 2 of 3 (g) Deed Recorded To: 21 -N -261 Grantor: Clyde E. Fisher, Sheriff. Sold as the property of LaVerne William Braddock, defendant, and John T. Shoop, Jacqueline R. Shoop and Mildred R. Shoop, Garnishees of Terre Tenants Grantee: Philip N. Brownstein, Federal Housing Commissioner Date: February 10, 1965 Recorded: March 17,1965 (h) Deed Recorded To: 19 -W -94 Grantor: Charles A. Gilbert and Anne E. Gilbert (h /w) Grantee: LaVerne William Braddock Date: April 26,1960 Recorded: June 4, 1960 (i) Deed Recorded To: 19 -W -94 Grantor: Allen Park Development Corp., a Pennsylvania corp. Grantee: Charles A. Gilbert and Anne E. Gilbert Ch/w) Date: January 11, 1950 Recorded: January 12, 1950 Exhibit "B" Page 3 0, f 3 Doris Garman Obituary: Doris Garman's Obi by the Patriui:-l`TC s. Page 1 of 1 Doris Betty Garman Doris Betty Garman, of Camp Hill, passed away recently at home. She was a daughter of the late Thomas C. and Grace. Hostetter Garman. She was a member of Shiremanstown Church of God. Surviving are several cousins. Graveside services will be 10:30 a.m. Thursday At Blain Cemetery with her pastor Rev. Floyd R. Carlen Jr. officiating. A memorial service will be scheduled at a later date. Memorial contributions may be made to her church, 35 South Locust Street, Shiremanstown, PA 17011. To sign the online guest book visit malpezzifuneralhome.com Published in Patriot -News on May 12, 2010 _...... __ ._... - - - --- — — - -- _ ..... -r"..� I T ciVa Page 1 of 1 Advanced Person Search Results Records: 1 to i of 1 Search Terms Used - Last Name: GARMAN; First Name: DORIS; Middle Name: B; City: CAMP HILL; State: PA; Full Name SSN Address Phone Indicators Next Steps 1. DORIS BETTY GARMAN 4W522 OProperty DORIS B GARMAN 5 WAYNE CIR APT 9 717- 975 -0854 - EDT D B GARMAN Link lD: 898703725 CAMP HILL PA 17011.6660 Learn haw DOB: 1'012011929► phone number Nov 85 -Sep 10 be Accurint Reports may Age at death: 80 y can assist i DOB: 11111929 disconnected. you:See Age at death: 80 Examples DOB: 1950 Age at death: 80 5 WAYNE CIR 717- 975 -0854 - EDT Gender •Female CAMP HILL PA 17011.6660 phone number *View Sources ( -9) Nov 85 - May 10 may be disconnected. Setup Alert 5 WAYNE CIR 717 - 975 -0854 - EDT LOWER ALLEN PA 17011.6660 phone number Nov 05 - Jun 08 may be disconnected. 5 WAYNE 9 CIR CAMP HILL PA 17011 Aug 07 RR 1 APT CAMP HILL PA 17011 Aug 94 - Apr 10 Records: i to 1 of 1 Your DPPA Permissible Use: Court, Law Enforcement or Government Agencies Your GaLBA Permissible Use: Authorized by Consumer 0 7 Lexixiw About LexisNexis I Terms & Conditions Copyright © 2010 LexisNexis Risk Solutions. All rights reserved. https ://secure.accurint.com/app/bps /raise 10/15/2010 • Sign in Sign • +� `; 729 ^. • Home • What is AncientFaces? • • Family History • Vintage Photos • Latest j2hotos • Browse ;photos • + Share your memories • Sign in m ind people and famili Search Safari Power Saver Click to Start Flash Plug -in ance'5try.L om i Doris B Garman (1929 - 2010) Lime Id photos Add Stories Discuss add photos Birth Oct 20, 1929 Death Apr 23, 2010 (age 80) sumames History of the Garman surname 297 records of Doris Garman Find birth, death, marriage, and divorce records of Doris B Garman at Ancestry.com • 35 birth records • 239 marriage records • 21 death records • 2 divorce records Get records of Doris B Garman PNC WEALTH MANAGEMENT PO Box 308 Camp Hill PA 17001 -0308 Direct I)ial (717) 730 -2265 Toll Free 1- 800- 762 -0616 F.maii . iinda.iundberg @puc.coui June 22, 2010 Register of Wills Cumberland County Court House South Hanover St- Carlisle 1'A 17013 _Re: Doris B. Garman, Deceased April 23, 2010 Dear Register: Please be advised Ms. Garman passed -away on April 23, 2010 a resident of Lower Allen Twp., Cumberland County, PA. PNC Bank' is it► possession of her original will dated January 4, 1989 that appoints CCNB Bank, N.A., now PNC Bank, National Association as executor of her estate. INC Bank, National Association. hereby renounces its appointment as executor. Enclosed you will find a copy of the original Will. A renunciation form will be completed once an Administrator has been identified. i will retain the original Will until someone comes forward to be appointed as Administrator of Ms. Garman's Estate. The two individuals named as beneficiaries in item First of the Will are now deceased. This has been verified through discussions with their son. Frank Barrancotto passed -away in 1994 and Josephine Barrancotto passed -away February 20, 2010. i have contacted the Church of God ' Home in Carlisle and informed them of their potential interest. They have declined to serve as administrator. Ms. Garman had a cousin, Emory Hostetter who had contacted an attorney, Richard Weber of Shippensburg and was in the process of petitioning the Court to be appointed as Administrator before the "CCNB" Will was discovered. Once the Will was discovered the process was discontinued. Copies of this letter are being sent, to: The Church of God Home via Certified Mail Mark Pacella, Commonwealth of PA, Office of Attorney General Richard Weber, Esquire James D. Bogar, Esquire S' erel Linda J. Lundberg, CTFA Vice President Mamber of The PNC Financial Services Group Enclosure 42+2 C,arli.5le Pike U1- U600 -03 -6 Camp HiiLLr Pennsylvania 17011 Bill ato &AMnuitt OF D=S B. GARNM I, DORIS B. SAM", of Lower Allen Township, Cumberland county, Pennsylvania, make, publish and declare this as and for my Last Will and Testament, hereby revoking all other Wills and Codicils heretofore made by me. FIRST I devise and bequeath all the rest, residue and remainder of my estate of whatever nature and wherever situate, including any property over which I hold power of appointment and together with any insurance policies thereon, unto PRANK BARRANCOTTO and JOSEPHINE BARRANCOTTO, his wife, or the survivor thereof, of 3936 Bernice Drive, San Diego, California, if at least one (1) of them survives me,. SECOND If both Frank Barrancotto and Josephine Barrancotto predecease me, I devise and bequeath all the rest, residue and remainder of my estate of whatever nature and Wherever situate, including any property over which I hold power of appointment and together with any insurance policies thereon, unto the CHURCH OF GOD HOME, of Carlisle, Pennsylvania, for general purposes as they deem fit and appropriate. THIRD In addition to all powers granted to them by law and by other provisions of this Will, I give the fiduciaries acting hereunder the following powers, applicable to all property, exercisable without court approval and effective until actual distribution of all property: (A) To sell at public or private sale, or to lease, for any period of time, any real or personal property and to give s ` options for sales, exchanges or leases, for such prices and upon such terms (including credit, with or without security) or conditions as are deemed proper. This includes the power to give legally sufficient instruments for transfer of the property and to receive the procoeds of any disposition of it. (B) To partition, subdivide, or improve zeal estate and to enter into'agreements concerning the partition, subdivision, improvement, zoning or management of real estate and to impose or extinguish restrictions on real estate. (C) To compromise any claim or controversy and to abandon any property which is of little or no value. (D) To invest in all forms of property, including stocks, common trust funds and mortgage investment funds-, without restriction to investments authorized for Pennsylvania fiduci- aries, as are deemed proper, without regard to any principle of diversification, risk or productivity. (E) To exercise any option; right or privilege granted in insurance policies or in other investments. (r) To exercise any election or privilege given by the Federal and other tax laws, including, but not necessarily being limitted to, personal income, gift and estate or inheritance tax laws. (G) To make distributions to my herein named benefici- arics in cash or in kind or partly in each. (H) To borrow money from themselves or others in order to pay debts, taxes, or estate or trust administration expenses, to protect or improve any property held under my will, and for investment purposes. (I) To select a mode of payment under any qualified retirement plan (pension plan, profit sharing plan, employee stock ownership plan, or any other type of qualified plan) to the extent the plan or the law permits them to do so, and to exercise any other rights which they may have under the plan, in whatever manner they consider advisable. FouRTH I direct that all inheritance, estate, transfer, succession and death taxes, of any kind whatsoever, which may be payable by reason of my death, whether or not with respect to property passing under this Will, shall be paid out of the principal of my residuary estate. FIFTH All interests hereunder, whether principal or .Z income, which aze undistributed and in the possession of the fiduciaries acting hereunder, even though vested or distributable, shall, not be subject to attachment, execution or sequestration for any debt, contract, obligation or liability of any beneficiary, and furthermore, shall not be subject to pledge, assignment, conveyance or anticipation. SIXTH I nominate and appoint CCNB BANK, N.A., of Camp 'dill, Pennsylvania, Executor of this, my Last Will and Testament. 1 direct that my executor shall not be recraircd to post Eec=--J t'y or a bond for the performance of their duties in any jurisdiction. IN WITNESS WHEREOF, I have hereunto set my hand and seal to this,, my Last Will and Testament, this day of �111u.( - , 19v`l. Doris B. Garman Signed, scaled, published and declared by the above - named Testatrix as and for her Last will and Testament in our presence, who, at her request, in her presence and in the presence of each other, have hereunto subscribed our names as attesting witnesses. Address ' Address 3 :may 1i • Sign in Like • *1 721 '. • Home • What is AncientFaces? • Family History • Vintage Photos o Latest photos o Browse photos • + Share your memories • Sign in Find people and famili Search Free Obituary Search obituaries.ancestry.com 1) Enter any name & search free! 2) Get their obituary instantly. Frank Barrancotto (1907 - 1994) • Lkco !d photos Add Stories Discuss add photos Birth Feb 18, 1907 Death Nov 22, 1994 (age 87) surnames History of the Barrancotto surname 9 records of Frank Barrancotto Find birth, death, marriage, and divorce records of Frank Barrancotto at Ancestry.com. • 2 birth records • 4 marriage records • 2 death records • 1 divorce record Get records of Frank Ban•ancotto Temp I '_'"13Y 0 "IMM Frank Barrancotto's Biography Add details Frank Barrancotto 1907 - 1994 was a member of the Barrancotto family. Frank was born on February 18, 1907. Frank died on November 22, 1994 at 87 years old. Frank Barrancotto's last known residence is at San Diego, San Diego County, CA 92107. . ............ .. ............I.................. We were able to locate a death record for Frank Barrancotto in the United States Social Security Master Death Index (SSDI). What is the SSDI? Obituary Social securi benefits Free stock photos Social security disability InfO11t1k5 Help Frank's family complete this biography Add details Add photos Add stories Details about Frank Barrancotto Add details Surnames History of the Barrancotto surname Last Known Residence San Diego, San Diego County, CA 92107 Born February 18, 1907 View 2 birth records Death November 22, 1994 View 2 death records Discuss Frank Barrancotto Share your memories below with the rest of Frank's family. W rite a commen Write a comment... Obituary Add details We don't have information about the obituary records of Frank. .......................... View 2 death records Find out wh you came from. � ancest ~y.�_��a �' . 5 _ What they did + Where they lived , And how A all led to you r . ... _ 9 records of Frank Barrancotto Find birth, death, marriage, and divorce records of Frank Barrancotto at Ancestryy com • 2 birth records • 4 marriage records • Sian in • Like 2. • +� ; 72 J • Home • What is AncientFaces? • Family History • Vintage Photos • Latest photos • Browse photos • + Share your memories • Sign in Find people an famil+ Search Free Obituary Search obituaries.ancestry.com 1) Enter any name & search free! 2) Get their obituary instantly. Josephine Barrancotto (1913 - 2010) Wko d photos Add Stories Discuss add photos Birth May 2, 1913 Death Feb 20, 2010 (age 96) surnames History of the Barrancotto surname 5 records of Josephine Barrancotto Find birth, death, marriage, and divorce records of Josephine Barrancotto at Ancestry.com • 1 birth record • 2 marriage records • 1 death record • 1 divorce record Get records of Josephine Barrancotto Josephine Barrancotto's Biography Add details Josephine Barrancotto 1913 - 2010 was a member of the Barrancotto family. Josephine was born on May 2, 1913. Josephine died on February 20, 2010 at 96 years old. Josephine Barrancotto's last known residence is at San Diego, San Diego County, CA 92107. We were able to locate a death record for Josephine Barrancotto in the United States Social Security Master _.._ .............. ............................... Death Index (SSDI). The death certificate for this record has been observed. This data can be considered accurate. What is the SSDI? Ohituary Social security benefits Free stock photos Social security-disahility infolinks Help Josephine's family complete this biography Add details Add photos Add stories Details about Josephine Barrancotto Add details Surnames History of the Barrancotto surname Last Known Residence San Diego, San Diego County, CA 92107 Born May 2 1913 View 1 birtl record Death February 20, 2010 View 1 death record Discuss Josephine Barrancotto Share your memories below with the rest of Josephine's family. Write a commen Write a comment... Poste Obituary Add details No one has entered information regarding the obituary records of Josephine. View 1 death record Arrest Records: 2 Secrets instantcheckmate.com 1) Enter Name and State. 2) Access Full Background Checks Instantly. 5 records of Josephine Barrancotto Find birth, death, marriage, and divorce records of Josephine Barrancotto at Ancestry.com t6 �`$W" " Stephen D. Tiley, Esquire Supreme Court No. 32318 Frey and Tiley Attorneys for the Plaintiff 5 South Hanover Street Tel.: 717 - 243 =5838 Carlisle, Pennsylvania 17013 Fax.: 717- 243 -6441 DAVID A. KRULAC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA V. CIVIL ACTION - LAW DORIS B. GARMAN, ESTATE OF DORIS B. ACTION TO QUIET TITLE GARMAN," , ; UNKNOWN HEIRS OF DORIS ern m �, B. GARMAN, NO 2014- NORTH STAR CAPITAL G - ---� ACQUISITION, LLC, v ° °^ LOWER ALLEN TOWNSHIP � CD AUTHORITY, CITIFINANCIAL SERCIES, INC.,: ONEMAIN FINANCIAL, CHURCH OF GOD HOME, INC. : Defendants MOTION FOR SERVICE BY PUBLICATION AND NOW, comes David A. Krulac, Plaintiff, by his attorney, Stephen D. Tiley, Esquire, and files this Motion for Service by Publication, of which the following is a statement: 1. Plaintiff is David A. Krulac, an adult individual, of Cumberland County, Pennsylvania, having a business address of P.O. Box 1064, Mechanicsburg, Pennsylvania, 17065. 2. First named Defendant Doris B. Garman was formerly a resident of 5 Wayne Circle, Camp Hill, Pennsylvania 17011, the property which is the subject of this quiet title action. Motion for Service by Publication Krulac v. Garman, et. al, Page I of 4 . 3. The Property was sold to the Plaintiff, David A. Krulac, by the Cumberland County Tax Claim Bureau, at a Judicial Sale. 4. This Court entered a Rule to Show Cause on March 11, 2011 directing all interested parties to appear and show cause why a decree should not be entered selling the Property free and clear of all liens and encumbrances except ground rent separately taxed. That Rule is entered to Cumberland County No. 2011 -2715 Civil. Pursuant to that Rule an Order was entered.on June 2, 2011 directing that the Property be sold as aforesaid. 5. The March 11, 2011 Rule further provided for service on the heirs, assigns or legal representatives of Doris B. Garman by publication once in the Cumberland Law Journal and once in the Patriot -News, at least 15 days prior to the returnable date, pursuant to Pa. R.C.P. 430. 6. In lieu of an affidavit, various additional efforts to locate the heirs of Doris B. Garman are described in paragraphs 23 through 38 of the Complaint to Quiet Title, which initiated this Action. 7. Pa. R.C.P. 410(a) provides: (a) In actions involving title to, interest in, possession of, or charges or liens upon real property, original process shall be served upon the defendant in the manner provided by Rule 400 et seq. 8. Pa. R.C.P. 430 provides for service by publication upon special order of the Court when service cannot otherwise be made. Furthermore, Pa. R.C.P. 430(b)(2) provides that: (2) When service is made by publication upon the heirs and assigns of a named former owner or party in interest, the court may permit publication against the heirs or assigns Motion far Service by Publication Krulac v. Garman, et. al. Page 2 of 4 generally if it is set forth in the complaint or an affidavit that they are unknown. 9. Paragraph 24 of the Complaint states that the heirs of Doris B. Garman are unknown. 10. Pa. R.C.P. 410(c) states as follows: (c) If service is made pursuant to an order of court under Rule 430(a), the court shall direct one or more of the following methods of service: (1) publication as provided b Rule 430(b), (2) posting a copy of the original process on the most public part of the property, (3) registered mail to the defendant's last known address, and (4) such other methods, if any, as the court deems appropriate to give notice to the defendant. 11. The Plaintiff requests that the Court enter a special order for Service by Publication on the heirs of Doris B. Garman, according to the Notice attached hereto as Exhibit "A." Said Notice to be published once in the Cumberland Law Journal and once in the Harrisburg Patriot -News. 12. The Plaintiff further requests that the Court's order for Service provide for posting of a copy of the Complaint, and the Notice attached hereto as Exhibit "A" on subject Property, on a conspicuous place, by the Cumberland County Sheriff. WHEREFORE, Plaintiff prays Your Honorable Court for a special order for Service of the Complaint of Quiet Title upon the heirs of Doris B. Garman, by Motion for Service by Publication Krulac v. Garman, et. al. Page 3 of 4 publication of the Notice attached hereto as Exhibit "A" once in the Cumberland Law Journal and once in the Harrisburg Patriot -News and by the Plaintiff's posting of the said Notice, and a copy of the Complaint to Quiet Title on a conspicuous place at the property, to wit: 5 Wayne Circle, Camp Hill (Lower Allen Township), PA 17011. Dated :°�° Respectfully submitted, ' L i STEPHEN D. TILEY, Esquire FREY and TILEY Attorney for Plaintiff 5 South Hanover Street Carlisle, PA 17013 Tel.: (717) 243 -5838 Supreme Court No.: 32318 Motion for Service by Publication Krulac v. Garman, et. al. Page 4 of 4 DAVID A. KRULAC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA V. CIVIL ACTION - LAW DORIS B. GARMAN, ESTATE OF DORIS B. ACTION TO QUIET TITLE GARMAN, UNKNOWN HEIRS OF DORIS B. GARMAN, NO. 2014 - NORTH STAR CAPITAL ACQUISITION, LLC, LOWER ALLEN TOWNSHIP AUTHORITY, CITIFINANCIAL SERCIES, INC.,: ONEMAIN FINANCIAL, CHURCH OF GOD HOME, INC. Defendants TO: DORIS B. GARMAN ESTATE OF DORIS B. GARMAN UNKNOWN HEIRS OF DORIS B. GARMAN You are notified that the Plaintiff, David A. Krulac, has commenced an action in Quiet Title against you entered to No. 2014- in the Court of Common Pleas of Cumberland County, Pennsylvania, which you are required to defend. This action concerns the land here described: . ALL THAT CERTAIN tract of land with the buildings and improvements thereon erected situated in Lower Allen Township, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northerly line of Wayne Circle, which point is 240.71 feet East of the northeasterly corner of Wayne Circle and Wayne Road and the dividing line between Lots Nos. 138 and 139; thence along the said division line North 3 degrees 59 minutes 30 seconds West 124.27 feet to a point, thence along the southerly line of Lots 127, and 125 on said Plan Exhibit "A" - Advertisement Page 1 of 2 South 59 degrees 3 minutes 30 seconds East 117.02 feet to a point on the westerly line of Lot No. 140; thence along same South 42 degrees 35 minutes West 109.85 feet to a point on the northerly line of Wayne Circle aforesaid; thence along same in an arc having a radius of 45 feet to the left, in a westerly direction forty (40) feet to a point, the Place of BEGINNING. BEING Lot No. 139 in Plan of Cumberland Park, Inc., which Plan is recorded in the Cumberland County Recorder's Office in Plan Book 4, Page 86, and being improved with a dwelling known as 5 Wayne Circle. ALSO KNOWN AS 5 Wayne Circle, Camp Hill, PA 17011. ALSO KNOWN AS UPI No.: 13 -24- 0797 -139. 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 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 BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. , Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: 717- 249 -3166 By: Ron Anderson, Sheriff By: Stephen D. Tiley, Esquire Attorney for Plaintiff Frey & Tiley 5 South Hanover Street Carlisle, PA 17013 (717) 243 -5838 Exhibit "A" - Advertisement Page 2 of 2 Stephen D. Tiley, Esquire Supreme Court No. 32318 Frey and Tiley Attorneys for the Plaintiff 5 South Hanover Street Tel.: 717-243-5838 Carlisle, Pennsylvania 17013 Fax.: 717-243-6441 DAVID A. KRULAC, • IN THE COURT OF COMMON PLEAS • OF CUMBERLAND COUNTY, Plaintiff • PENNSYLVANIA • v. • CIVIL ACTION - LAW • DORIS B. GARMAN, • ESTATE OF DORIS B. ACTION TO QUIET TITLE GARMAN, • UNKNOWN HEIRS OF DORIS • B. GARMAN, • NO. 2014- 6n C fft141 NORTH STAR CAPITAL ACQUISITION, LLC, r7 LOWER ALLEN TOWNSHIP AUTHORITY, • zr►'E rri rr1-.- CITIFINANCIAL SERCIES, INC., : th rn ONEMAIN FINANCIAL, �-� c> `;' CHURCH OF GOD HOME, INC. : n sf. zC) Defendants : x c ORDER FOR SERVICE BY PUBLICATION Ff // AND NOW, this f (/ (/day of February, 2014, upon consideration of the within Motion for Service By Publication, Doris B. Garman, the Estate of Doris B. Garman, and the Unknown Heirs of Doris B. Garman, shall be served by publication of the Notice attached to the Motion as Exhibit "A" once in the Cumberland Law Journal and once in the Harrisburg Patriot-News and by the Plaintiff posting the said Notice, and a copy of the Complaint to Quiet Title, on a conspicuous place at the property, to wit: 5 Wayne Circle, Camp Hill (Lower Allen Township), PA 17011. n2.. (12.4 B - - 6o , a rvytit 04-1-y g. cTit 1€.7 J. Order for Service by Publication Krulac v. Garman, et. al. Page 1 of I Stephen D. Tiley, Esquire Frey and Tiley Attorneys for the Plaintiff 5 South Hanover Street Carlisle, Pennsylvania 17013 DAVID A. KRULAC, Plaintiff v. DORIS B. GARMAN, ESTATE OF DORIS B. GARMAN, UNKNOWN HEIRS OF DORIS B. GARMAN, • NORTH STAR CAPITAL ACQUISITION, LLC, • LOWER ALLEN TOWNSHIP AUTHORITY, • CITIFINANCIAL SERCIES, INC., : ONEMAIN FINANCIAL, • CHURCH OF GOD HOME, INC. : Defendants Supreme Court No. 32318 Tel.: 717- 243 -5838 Fax.: 717- 243 -6441 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION TO QUIET TITLE NO. 2014- 0683 -CIVIL -Q AFFIDAVIT OF SERVICE BY PUBLICATION The Complaint to Quiet Title filed in the above captioned matter was served upon Doris B. Garman, the Estate of Doris B. Garman, and the Unknown Heirs of Doris B. Garman, by publication in the Cumberland Law Journal on February 21, 2014, and by publication in the Harrisburg Patriot News on February 18, 2014, of the Notices attached to the Proofs of Publication, which are attached hereto. The Proof of Publication for the Cumberland Law Journal is attached hereto as Exhibit "A." The Proof of Publication for the Harrisburg Patriot News is attached hereto as Exhibit "B." I make these statements pursuant to 18 Pa. Cons. Stat. §4904 relating to unsworn falsification to authorities and understand that false statements may subject me to criminal penalties under that statute. ohdr9/2- // Stephen D. Tiley, Esquire Counsel for Plaintiff Frey and Tiley 5 South Hanover Street Carlisle, PA 17013 Tel. No. (717) 243 -5838 Sup. Ct. ID 32318 P1 CD T 74 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 February 21, 2014 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 Mari Coyne, E9litor SWORN TO AND SUBSCRIBED before me this 21 day of February, 2014 NOTARIAL SEAL DEBORAH A COLLINS Notary Public ARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL ACTION TO QUIET TITLE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action —Law NO. 2014 - 00683 -CIVIL DAVID A. KRULAC, Plaintiff v. DORIS B. GARMAN, ESTATE OF DORIS B. GARMAN, UNKNOWN HEIRS OF DORIS B. GARMAN, NORTH STAR CAPITAL ACQUISITION, LLC, LOWER ALLEN TOWNSHIP AUTHORITY, CITIFINANCIAL SERVICES, INC., ONEMAIN FINANCIAL, CHURCH OF GOD HOME, INC., Defendants TO: DORIS B. GARMAN, ESTATE OF DORIS B. GARMAN, UNKNOWN HEIRS OF DORIS B. GARMAN You are notified that the Plaintiff David A. Krulac, has commenced an Action in Quiet Title against you entered to No. 2014 - 00683 -Civil in the Court of Common Pleas of Cum- berland County, Pennsylvania, which you are required to defend. This action concerns the land here described: ALL THAT CERTAIN tract of land with the buildings and improvements thereon erected situated in Lower Allen Township, County of Cumber- land and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northerly line of Wayne Circle, which point is 240.71 feet East of the north- easterly corner of Wayne Circle and Wayne Road and the dividing line be- tween Lots Nos. 138 and 139; thence along the said division line North 3 degrees 59 minutes 30 seconds West 124.27 feet to a point; thence along the southerly line of Lots 127, 126 and 125 on said Plan South 59 5 degrees 3 minutes 30 seconds East 117.02 feet to a point on the westerly line of Lot No. 140; thence along same South 42 degrees 35 minutes West 109.85 feet to a point on the northerly line of Wayne Circle aforesaid; thence along same in an arc having a radius of 45 feet to the left, in a westerly direction forty (40) feet to a point, the Place of BEGINNING. BEING Lot No. 139 in Plan of Cumberland Park, Inc., which Plan is recorded in the Cumberland County Recorder's Office in Plan Book 4, Page 86 and being improved with a dwell- ing known as 5 Wayne. Circle. ALSO KNOWN AS 5 Wayne Circle, Camp Hill, PA 17011. ALSO KNOWN AS UPI No.: 13 -24- 0797 -139. NOTICE If you wish to defend, you must enter a written appearance person- ally or by attorney and file your de- fenses 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 BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A RE- DUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street CUMBERLAND LAW JOURNAL Carlisle, PA 17013 Telephone: (717) 249 -3166 By: Ron Anderson, Sheriff STEPHEN D. TILEY, ESQUIRE FREY & TILEY Attorneys for Plaintiff 5 South Hanover Street Carlisle, PA 17013 (717) 243 -5838 Feb. 21 6 'A" The Patriot -News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717 -255 -8213 FREY & TILEY 5 S HANOVER ST CARLISLE PA 17013 O patrioi News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and /or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M ", Volume 14, Page 317. PUBLICATION COPY J 4 72 "in IN THE COURT OF COMMON P OF CUMBERLAND COUNTY, LEAS SYLVANIA PENN - CIVILACTION -LAW ACTION TO QUIET TITLE DAVID ANO.2014- 00683 -CIVIL Plaintiff KRULAC, v. DORIs B. GARMAN, ESTATE OF DORIS B. GARMAN, UNKNOWN HEIRS OF DORIS B. GARMAN, NORTH STAR CAPITAL ACQUISITION, LLC LOWER ALLEN TOWNSHIP AUTHORITY CITIFINANCIAL SERVICES, INC. ONEMAIN FINANCIAL, CHURCH OF GOD HOME, INC. Defendants TO: DORIS B. GARMAN UNKNOWN HEIRS OF DORIS B. GARMAN You are notified dA. Krulac,hascommencetl nacttiion Quiet Title against you entered to No. 14-00683 -Civil In the Court of Common eas of Cumberland County, Pennsylva- " PirNfeUI %R Le'V deed to defend. Attorney for Plaintiff Frey & They 5 South Hanover Street Carlisle PA 17013 (717) 243 -5838 This ad _# 00022907,67 an on the dates shown below: February 18, 2014 worn to nd subscribed be me this 20 day of February, 2014 A.D. I Via �� Pus Ic 0'- + CGF'41�i0!`,t�Al�7;a_._ ztst�ti ,tot:nri:t Seat fAI:n.n>:a EXHIBIT The Patriot -News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717 - 255 -8213 FREY & TILEY s S HANOVER ST IN THE COURT OF COMMON PLEAS OF CUhiBERLAND COUNTY, PENN - CIVILACTION -LAW ACTION TO QUIET TITLE 17013 NO. 2014-00683-CIVIL DAVID A. KRULAC, Plaintiff v. DORIS B. GARMAN, ESTATE OF DORIS 8. GARMAN, UNKNOWN HEIRS OF DORIS B. GARMAN, NORTH STAR CAPITAL ACQUISITION, LLC LOWER ALLEN TOWNSHIP AUTHORITY CITIFINANCIAL SERVICES, INC. ONEMAIN FINANCIAL, , CHURCH OF GOD HOME, INC. Defendants TO: DORIS B. GARMAN ESTATE OF DORIS B. GARMAN UNKNOWN HEIRS OF DORIS B. GARMAN - You are notified that the Plaintiff, Da- vid A. Krulac, has commenced an action In Quiet Title against you entered to No. 2014- 00683 -Civ11 In the Court of Common Pleas cf Cumberland County, Pennsylva- nia, which You are required to defend. This action concerns the land here de- scribed: ALL THAT CERTAIN tract of land with the buildings and Improvements thereon erected situated In Lower Allen Town- ship, County of Cumberland and State of ' Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING.ata point on the northerly line of Wayne Circle, which point is 240.71 feet East of the northeasterly corner of Wayne Circle and Wayne Road and the dlvltling line between Lots Nos. 138 and 139; h3deg division a or publication which is securely attached hereto is exactly as printed and published in their regular North 3 degrees 59 minutes 30 seconds West southerly feet to of Lots 127, 126 along pity Weekly editions which appeared on the date(s) indicated below. That neither she nor said the southerly line of Lots 127, 126 and 125 on said Plan South 59 degrees 3 minutes subject matter of said printed notice or advertising, and that all of the allegations of this statement as the we westerly line tof Lot No. i140 thence ter of publication are true; and along same South 42 degrees 35 minutes West 109.85 fee to a paint on the norther- al knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on along same In an arc havingaradiu feet 'o. aforesaid by virtue and pursuant to a resolution unanimously.passed and adopted severally by the the �latriot News Now you know PA THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss duly sworn according to law, deposes and says: :ountant of The Patriot News Co., a corporation organized and existing under the laws of the ia, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday eneral circulation, printed and published at 1900 Patriot Drive, in the City, County and State s and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, n continuously published ever since; ly line of Wayne Circle afore is th t to the left, In a westerly direction for- . GINNING. feet toa point, the place ofBE- (rectors of the said Company and subsequently duly recorded in the office for the Recording of Deeds • BEING Lot No.139In Pion or Cumber- aphin in Miscellaneous Book "M ", Volume 14, Page 317. land Park, Inc., which Plan Is recorded In the Cumberland County Recorder's Of- fice In Plan Book 4, Page 86, and being Improved with a dwelling known as 5 Wayne Circle. ALSO KNOWN AS 5 Wayne Circle, Comp Hill, PA 17011 ALSO KNOWN AS UPI No.: 13-24 -0797- 139. If you wish to def n d, you must enter a written appearance personally or by at- torney and file your defenses or objec- tions in writing with the court. You are warned that If you fall to do so the case may proceed without you and a Judgment may be entered against you without fur- ther notice for the relief requested by the plaintiff. You may lose money or proper- ty 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 TEL- EPHONE 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 MAYBE ABLE TO PROVIDE YOU WITH INFOR- MATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONSATA REDUCED FEE OR.NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: 717-249-3166 By: Ran Anderson, Sheriff By: Stephen D. Tiley, Esquire Attorney for Plaintiff Frey & Tiler 5 South Hanover Street Carlisle PA 17013 (717) 243.5838 This ad # 0002290767 an on the dates shown below: February 18, 2014 worn to :nd subscribed be me this 20 day of February, 2014 A.D. IC O, SNE._ 11 ` r �c7i Seal .It10c. ;aC(ly. ..• `C:.r �S.f11C,i t,:'':a�r i ,.1 p ar7 oc qa1 :n ±�FJ~Rf }t1��cvl�itlA1`•.T.. .. exinurozn The Patriot -News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717- 255 -8213 FREY & TILEY 5 S HANOVER ST IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENN- SYLVANIA CIVIACTION -LAW ACTION TO QUIET TITLE NO. 2014-00683-CIVIL DAVID A. KRULAC, Plaintiff • v. DORIS B. GARMAN, ESTATE OF DORIS 8. GARMAN, UNKNOWN HEIRS OF DORIS B. GARMAN, NORTH STAR CAPITAL ACQUISITION, LLC LOWER ALLEN TOWNSHIP AUTHORITY CITIFINANCIAL SERVICES, INC. ONEMAIN FINANCIAL, CHURCH OF GOD HOME, INC. Defendants TO: DORIS 8. GARMAN ESTATE OF DORIS B. GARMAN UNKNOWN HEIRS OF DORIS B. GARMAN You are notified that the Plaintiff, Da vid A. Krulac, has commenced an actlo In Quiet Title against you entered to No. 2014. 00683 -Civil In the Court of Common Pleas of Cumberland County, Pennsylva nla, which you are required to defend. This action concerns the land here de- scribed: ALL THAT CERTAIN tract of land wit the buildings and Improvements thereon erected situated In Lower Allen Town- ship, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northerly line of Wayne Circle, which point is 240.71 feet East of the northeasterly corner of Warne Circle and Wayne Road and the dividing Ilne between Lots Nos. 138 and 139; thence along the said division line North 3 degrees 59 minutes 30 seconds the southerly line of Lots point; 127, 126 and 125 on said Plan South 59 degrees 3 minutes 30 seconds East 117.02 feet to a point on the westerly Ilne of Lot No. 740; thence along same South 42 degrees 35 minutes West 109.85 feet to a point on the norther n h ly line of Wayne Circle aforesaid; thence along some In an arc having o radius of 45 feet to the left, In a westerly direction for- i veikim t..c� o�lnt the Place of BE- GINNING. ,- -��- _ I BEING Lot No. 139 In Plan of Cumber- land Park, Inc., which Plan Is recorded In the Cumberland County Recorder's Of- fice In Plan Book 4, Page 86, and being Improved with a dwelling known as 5 ' Wayne Circle. ALSO KNOWN AS 5 Wayne Circle, Camp Hill, PA 17011 ALSO KNOWN AS UPI No.: 13 -24 -0797- 139. If you wish to def a d, you must enter a written appearance personally or by at- torney and file your defenses or oblec- tlons in writing with the court. You are warned that If you tali to do so the case may proceed without you and a lodgment may be entered against you without fur- ther notice for the relief requested by the plaintiff. You may lose money or proper- . ty 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 TEL- EPHONE 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 MAYBE ABLE TO PROVIDE YOU WITH INFOR- MATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR.NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: 717-249-3166 By: Ron Anderson, Sheriff By: Stephen D. Tlley, Esquire Attorney for Plaintiff Frey & They 5 South Hanover Street Carlisle PA 17013 - (717) 243 -5838 e Now you know PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss 'duly sworn according to law, deposes and says: :ountant of The Patriot News Co., a corporation organized and existing under the laws of the ia, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday eneral circulation, printed and published at 1900 Patriot Drive, in the City, County and State s and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, In continuously published ever since; e or publication which is securely attached hereto is exactly as printed and published in their regular nity Weekly editions which appeared on the date(s) indicated below. That neither she nor said subject matter of said printed notice or advertising, and that all of the allegations of this statement as :ter of publication are true; and al knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on o. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the rectors of the said Company and subsequently duly recorded in the office for the Recording of Deeds ,Iphin in Miscellaneous Book "M ", Volume 14, Page 317. This ad # 0002291 67 an on the dates shown below: February 18, 2014 orn to nd subscribed be e this 20 day of February, 2014 A.D. Ua 1c COMMO SH OF PENNSNLVANIA Notarial seal Public Holly Lynn Warfel, Notary my WashingtonTwp•, Dauphin 2016 My Commission Expires Dec. 12, Aa1E� MEMBER PENNS�t`taN1.A A O('l NOT 4T1ON OF Stephen D. Tiley, Esquire Frey and Tiley Attorneys for the Plaintiff 5 South Hanover Street Carlisle, Pennsylvania 17013 DAVID A. KRULAC, Plaintiff v. DORIS B. GARMAN, ESTATE OF DORIS B. GARMAN, • UNKNOWN HEIRS OF DORIS • B. GARMAN, NORTH STAR CAPITAL • ACQUISITION, LLC, LOWER ALLEN TOWNSHIP : AUTHORITY, • CITIFINANCIAL SERCIES, INC., : Supreme Court No. 32318 ONEMAIN FINANCIAL, CHURCH OF GOD HOME, INC. : Defendants Tel.: 717-243-5838 Fax.: 717-243-6441 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C7 c. CIVIL ACTION - LAW rn cr' =r11 ACTION TO QUIET TITLE NO. 2014-0683-CIVIL 2014-0683-CIVIL r-- cz- 4*". AFFIDAVIT OF RETURN OF SERVICE BY MAIL On February 5, 2014, I mailed a true copy of the Complaint to Quiet Title by certified mail, return receipt requested to the following defendants, at the addresses given: CitiFinancial Services, Inc. 14700 Citicorp Dr., MC 1020 Hagerstown, MD 21742 CitiFinancial 6400 Las Colinas Blvd., Mail Stop C2-83 Irvine, TX 75039 CitiFinancial Investment Recovery c/o Latasha Anderson 605 Munn Rd., E Fort Mills, SC 29715 North Star Capital Acquisitions, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Rd., C306 Mt. Laurel, NJ 08054 The defendants signed the return receipt upon delivery and the receipt, attached hereto as Exhibit "A," was returned by the Post Office after delivery, as indicated on the return receipt cards. Affidavit of Return of Service by Mail; Krulac v. Garman, et. al. Page 1 of 2 CD ' I make these statements pursuant to 18 Pa. Cons. Stat. §4904 relating to unsworn falsification to authorities and understand that false statements may subject me to criminal penalties under that statute. Stephen D. Tiley, Esquire Counsel for Plaintiff Frey and Tiley 5 South Hanover Street Carlisle, PA 17013 Tel. No. (717) 243-5838 Sup. Ct. ID 32318 Affidavit of Return of Service by Mail: Krulac v. Garman, et. al. Page 1 of 2 SENDER: COMPLETE THIS SECTION • Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery Is desired. • Paint your name and address on the reverse so that we can retum the card to you. • Attach this card to the back of the maiipiece, or on the front If space permits. cie Addressed to: ADO 145 CD/i nag avd, !Nil step Ca fie, TX 75 ©39 COMPLETE THIS SECTION ON DELIVERY rY. D. is delivery address different from Item 1? ❑ Y If YES, enter delivery address below: 0 No ce Type Cert led Mali 0 Express Mall Reglstered 0 Return Receipt for Merchandise 0 limuted Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes (Trar-ster from service Iabei/ 17}O . 1 I; 3 5 0© O O'E13 6621 ' 2 3 6 0 2. Article Number PS Form 3811, February 2004 Domestic Return Receipt 102595 -02-M -1540 SENDER: COMPLETE THIS SECTION • Complete items 1, 2, and 3. Also complete item 4 If Restricted Delivery Is desired. • Print your name and address on the reverse so that we can retum the card to you. • Attach this card to the back of the maiipiece, or on the front if space permits. COMPLETE THIS SECTION ON DELIVERY . Article Addressed to: NOflh V /PI0 . Ott 11.• D. Is delivery address different from item 1? ❑ Y =s If YES, enter delivery address below: ❑ No ❑ Agent ❑ Addressee ae of +eliv: ry C�© l ooth ji/ csi 455xi a-tPs, P. C. i /o &Shup 64d C394 Int tl are/ AI .7- Off c5d 2. Article Number (Transfer from service ?abeQ Reglstered ❑ Insured Mal ❑ Express Mall ❑ Return Receipt for Merchandise ❑ C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes PS Form 3811, February 200 9nE2 ¶299 E000 'OD E 1Tr[© Luc Hetum Receipt 102595-02 -M -1540 SENDER: COMPLETE THIS SECTION • Complete items 1, 2, and 3. Also complete Item 4 if Restricted Delivery Is desired. • Print your name and address on the reverse so that we can retum the card to you. • Attach this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: fi Fnl(ncc,al . Viccs, Z c. 1q700 Clicerp Drive, /11e I i a17401, COMPLETE THIS SECTION ON DELIVERY A. Signature CITICORP MAIL ROOM:,. 0 Agent ❑ Addressee ' B. Received by ( Printed Name) Ee D. is delivery address different from item 1? :.0 Yes If YES, enter delivery address below: ❑ No irvlce Type i Certified Mall O Registered ❑ Insured Mall ❑ Express Mall 0 Return Receipt for Merchandise ▪ C.O.D. 4. Restricted Delivery? (Extra Fee) ❑ Yes 2. Article Number (Transfer from service label) PS Form 3811, February 2C. ES E 2299 E000 005E rtrtQz rsrrc Hetim Receipt 102595-02 -M -1540 SENDER: COMPLETE THIS SECTION • Complete Items 1, 2, and 3. Also complete Item 4 If Restricted Delivery Is desired. • Print your name and address on the reverse so that we can return the card to you. • Attach this card to the back of the mailpiece, or on the front if space permits. COMPLETE THIS SECTION ON DELIVERY ❑ Agent, 1 ❑ Addre ssee very w 1. Article Addressed to: o finaii/ .1nv Las/) 4 41(211r-7-7 d5 %%'Vinyl neyl /s, sC 097) D. Is delivery address differ If YES, enter delivery ad from item 1? ❑ Yes below: ❑ No 2. Article Number - (Transfer from service label) PS Form 3811, February 2004 all ❑ Express Mall ❑ Registered ❑ Retum Receipt for Merchandise ❑ Insured Mall 0 C.O.D. 4. Restricted Delivery? (Erdra Fee) j'sdd'tititiJ c Retum Receipt 102595-02 -M -1540 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r 't Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 0di IIir.1 0,474,9 . 2014 LIAR 17 APB 10: co CUMBERLAND COUNTY PENNSYLVANIA David Krulac vs. Doris B. Garman (et al.) Case Number 2014 -683 SHERIFF'S RETURN OF SERVICE 02/07/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint to Quiet Title as "Not Found" at 5 Wayne Circle, Lower Allen Township, Camp Hill, PA 17011. Residence is vacant. 02/07/2014 02:50 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint to Quiet Title by handing a true copy to a person representing themselves to be Stephanie Kleinfelter, Senior Trust Advisor, who accepted as "Adult Person in Charge" for Estate of Doris B. Garman at do PNC Wealth Management, 4242 Carlisle Pike, Camp Hill, PA 17011. JASON KINKER, DEPUTY 02/07/2014 02:50 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint to Quiet Title by handing a true copy to a person representing themselves to be Stephanie Kleinfelter, Senior Trust Advisor, who accepted as "Adult Person in Charge" for Esate of Doris B. Garman at do PNC Bank, Executor, 4242 Carlisle Pike, Camp Hill, PA 17011. JASON KINSL R, DEPUTY 02/07/2014 03:11 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint to Quiet Title by handing a true copy to a person representing themselves to be Scott Albright, Assistant Manager, who accepted as "Adult Person in Charge" for Citifinancial Service, Inc. do OneMain Financial at 3401 Hartzdale Drive, Suite 126, Lower Allen, Camp Hill, PA 17011. JASON NSL , EPUTY 02/07/2014 03:11 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint to Quiet Title by handing a true copy to a person representing themselves to be Scott Albright, Assistant Manager, who accepted as "Adult Person in Charge" for OneMain Financial at 3401 Hartzdale Drive, Suite 126, Lower Allen, Camp Hill, PA 17011. e UTY `1 JASON INS ,DEP 02/10/2014 10:40 AM - Deputy William Cline, being duly sworn according to law, served the requested Complaint to Quiet Title by handing a true copy to a person representing themselves to be Carson Ritchie, VP of Operations, who accepted as "Adult Person in Charge" for Church of God Home, Inc. at 801 N. Hanover Street, Carlisle Borough, Carlisle, PA 17013. CountySu to Sherfii, Te!eosofi, L lAM CLINE, DEPUTY 02/102014 The requested Complaint to Quiet Title returned by the Sheriff of Dauphin County, the within named Defendant North Star Capita Acquisition, LLC, not found. Hon. Jack Lotwick, Sheriff, Return of Service attached to andmade part of the within record. 02/20/2014 06:00 PM - The requested Complaint to Quiet Title served by the Sheriff of York County upon James Chubb, who accepted for Lower Allen Township Authority, at 120 Limekiln Road, New Cumberland, PA 17070. Richard Keuerleber, Sheriff, Return of Service attached to and made part of the within record. 02C24/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Lower Allen Township Authority, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Complaint to Quiet Title according to law. SHERIFF COST: $244.12 SO ANSWERS, March 05, 2014 RONNYR ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleasoft, (Pilitt Ed file I Shelley Ruhl Real Esta a Deputy Matthew L. Owens Solicitor Commonwealth of Pennsylvania County of Dauphin Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101 -2079 ph: (717) 780 -6590 fax: (717) 255 -2889 Jack Lotwick Sheriff Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy DAVID A. KRULAC VS NORTH STAR CAPITAL ACQUISITION, LLC Sheriffs Return No. 2014 -T -0415 OTHER COUNTY NO. 2014-683 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for NORTH STAR CAPITAL ACQUISITION, LLC the DEFENDANT named in the within COMPLAINT TO QUIET TITLE and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, FEBRUARY 18, 2014. REFUSED BY CT CORPORATION, 116 PINE STREET, SUITE 320, HARRISBURG, PA 17101. THEY ARE NOT THE REGISTERED AGENT FOR THE DEFENDANT. Sworn and subscribed to before me this 19TH day of February, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County My Commission Expires January 8, 2018 So Answers, By De Sheriff Da ty: J FRUHWIRTH Sheriffs Costs: $41.25 2/14/2014 Richard P Keuerleber Sheriff Reuben B Zeager Chief Deputy, Operations SHERIFF'S OFFICE OF YORK COUNTY PETER J. MANGAN, ES Solici Richard E Rice Chief Deputy, Administrat, DAVID A KRULAC vs. DORIS B. GARMAN ET AL (et al.) Case Number 2014 -683 SHERIFF'S RETURN OF SERVICE 02/20/2014 06:00 PM - DEPUTY BRANDON POLASH, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED COMPLAINT TO QUIET TITLE (CTQT) BY HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE JAMES CHUBB, HEAD OPERATOR, WHO ACCEPTED AS "ADULT PERSON IN CHARGE" FOR LOWER ALLEN TOWNSHIP AUTHORITY AT 120 LIMEKILN ROAD, NEW CUMBERLAND, PA 17070. SHERIFF COST: $45.40 BRANDON POLASH, DEPUTY SO ERS, February 26, 2014 RICHARD P KEUEA-LEBER, SHERIFF Affirmed and subscribed t o before me this 26TH day of FEBRUARY NOTARY 2014 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sheila E. Cook, Notary Public City of York, York County My Commission Expires Feb. 1, 2017 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES Stephen D. Tiley, Esquire Frey and Tiley Attorneys for the Plaintiff 5 South Hanover Street Carlisle, Pennsylvania 17013 Supreme Court No. 32318 Tel.: 717- 243 -5838 Fax.: 717- 243 -6441 DAVID A. KRULAC, • • Plaintiff • v. • DORIS B. GARMAN, ESTATE OF DORIS B. GARMAN, UNKNOWN HEIRS OF DORIS B. GARMAN, NORTH STAR CAPITAL ACQUISITION, LLC, LOWER ALLEN TOWNSHIP AUTHORITY, • CITIFINANCIAL SERCIES, INC., : ONEMAIN FINANCIAL, CHURCH OF GOD HOME, INC. : Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION TO QUIET TITLE NO. 2014 - 0683 -CIVIL AFFIDAVIT OF RETURN OF SERVICE REGARDING NORTH STAR CAPITAL ACQUISITION, LLC Paragraphs 10(a) and 11 of the Complaint filed in the above - captioned matter referenced the registered office of North Star Capital Acquisition, LLC. According to the Pennsylvania Department of State, Corporation Bureau, the registered office is CT Corporation System of Dauphin County, Pennsylvania. Attached hereto as Exhibit "A" is a printout of the Corporation Bureau page for North Star Capital Acquisition, LLC, as it appeared on March 19, 2013. Cil According to the Pennsylvania Corporation Bureau, the registered office of CT Corporation System is 116 Pine Street, Suite 320, Harrisburg, PA 17101. A printout of the Corporation Bureau page for CT Corporation System as of March 19, 2014 is attached hereto as Exhibit "B." Affidavit of Return of Service Regarding North Star Capital Acquisition, LLC Krulac v. Garman, et. al. Page 1 of 3 On March 17, 2014 the Cumberland County Sheriffs Office filed a Return of Service stating, at the third to last paragraph therein, that the Dauphin County Sheriff was unable to locate North Star Capital Acquisition, LLC in its bailiwick. The Cumberland County Sheriffs Return attaches a Sheriffs Return from Dauphin County indicating that on February 18, 2014 they were unable to serve North Star Capital Acquisition, LLC because the aforementioned CT Corporation of 116 Pine Street, Suite 320, Harrisburg, PA 17101 refused service stating that they were not the registered agents for the Defendant. Paragraph 10(b) of the Complaint stated that North Star Capital Acquisition, LLC was believed to have an address of 170 North Pointe Parkway, Suite 300, Amherst, NY 14228. On February 5, 2014 a certified copy of the Complaint was mailed to the defendant, North Star Capital Acquisition, LLC, at the aforesaid Amherst, NY address by certified mail, return receipt requested. Thereafter, the post office returned the envelope marked "Not deliverable," "Unable to forward," "Return to Sender." A copy of both sides of the envelope is attached hereto as Exhibit "C." An Internet search of 170 North Pointe Parkway, Suite 300, Amherst, NY 14228 showed North Star Capital Acquisition, LLC as having such an address, with a telephone number of (716) 799-0525. A call to that telephone number resulted in a message indicating that the number was no longer in service. Paragraphs 10(c) and 12 of the Complaint state that North Star Capital Acquisition, LLC was listed in a Complaint that it filed against Doris B. Garman as having an address. c/o Apothaker & Associates, P.C., 520 Fellowship Road, C306, Mt. Laurel, NJ 08054. North Star Capital Acquisition, LLC was served at that address on February 7, 2014 as shown in the Affidavit of Return of Service by Mail filed by Stephen D. Tiley, Esquire, Counsel for the Plaintiff in the above- captioned matter, on March 4, 2014. Affidavit of Return of Service Regarding North Star Capital Acquisition, LLC Krulac v. Garman, et. al. Page 2 of 3 I make these statements pursuant to 18 Pa. Cons. Stat. §4904 relating to unsworn falsification to authorities and understand that false statements may subject me to criminal penalties under that statute. o71�97,0 or4 PSIAP- "10 7.4 Steph =. D. Tiley, Esquire Counsel for Plaintiff Frey and Tiley 5 South Hanover Street Carlisle, PA 17013 Tel. No. (717) 243 -5838 Sup. Ct. ID 32318 Affidavit of Return of Service Regarding North Star Capital Acquisition, LLC Krulac v. Garman, et. al. Page 3 of 3 Search By Business Name By Business Entity ID Verify Verify Certification Online Orders Register fcr Online Orders Order Good Standing Order Certified Documents Order Business List 1\ily Imades Search for images Corporations Online Services 1 Corporations 1 Forms 1 Contact Corporations 1 Business Services Business Entity Filing History Date: 3/19/2014 (Select the link above to view the Business Entity's Filing History) Business Name History Name Name Type North Star Capital Acquisition LLC Current Name Limited Liability Company - Foreign - Information Entity Number: 3901809 Status: Active Entity Creation Date: 8/17/2009 State of Business.: UT Registered Office Address: % C T Corporation System (term) PA Dauphin Mailing Address: No Address Copyright © 2002 Pennsylvania Department of State. All Rights Reserved, Privacy Policy I Security Policy pennsytvania DEPARTMENT OF STATE Search By Business Name Ey Business Entity ID Verify Verify Certification Online Orders Register for Online Orders Oder Good Standing Oder Cerilfied Documents Order Business List My maces Search for Images Corporations Online Services 1 Corporations 1 Forms 1 Contact Corporations 1 Business Services Business Entity Filing History Date: 3/19/2014 (Select the link above to view the Business Entity's Filing History) Business Name History Name C T CORPORATION SYSTEM Name Type Current Name Business Corporation - Entity Number: Status: Entity Creation Date: State of Business.: Registered Office Address. Mailing Address: Foreign - Information 52252 Active 9/9/1936 DE 116 Pine St Ste 320 Harrisburg PA 17101 Dauphin No Address Officers Name: Title: Address: ALAN METCALFE President 30 SOUTH 1TH STREET PHILADELPHIA PA 19103 Name: Title: Address: MARY METCALFE Secretary 30 SOUTH 1TH STREET PHILADELPHIA PA 19103 Name: Address: MARY METCALFE Treasurer 30 SOUTH 1TH STREET PHILADELPHIA PA 19103 Name: RICHARD I PARKER Title: Address: Vice President 30 SOUTH 1TH STREET PHILADELPHIA PA 19103 Copyright © 2002 Pennsylvania Department of State. All Rights Reserved. Privacy Policy I Security Policy 1 1 1 1 7011 3500 0003 6621 2339 TO: J000 FIRST CLASS. MAIL FREY & TILEY ATTORNEYS-AT-LAW 5 SOUTH HANOVER STREET CARLISLE, PA 17013 #1, • S. POSTAGE CARL ISLPALO E . PA 0013 FEB 05, .11 AMOUNT 8429 0009,261-08 North Star Capital Acquisitions, LLC 170 North Pointe Parkway, Suite 300 Amherst, NY 14228 14228 084-1N 03/07/14 RETURN TO SENDER UNABLE TO FORWARD UNABLE TO FORWARD RETURN TO SENDER SENDER; OPIVINgrr 77-11,9 15FOTIQN • Complete items 1, 2, and 3. Also complete Item 4 If Restricted Delivery is desired., 11 Print your name and address on the reverse so that we can return the card to you. la Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: 4'96142, 11O Alit de ark .5tute 3D Aly 1 qc2:2Fi COMPET g SFCTION PN PEI-IVFRY A. Si nature 0 Agent I 0 Addressee x B. Received by (Printed Name) C. Date of Delivery D. Is delivery address ditfnt.from item If YES, enter delivery address below: D Yes 0 No • S9rvice Type 10 Certified Mall 0 Registered 1:3 Insured Mall 0 Express Mali ' 0 Return Receipt for Merchandis El C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (Transfer from service labe0 71 7 0 1 1 5 0 0 0003 6 6 2 1 2339 PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 Stephen D. Tiley, Esquire Frey and Tiley Attorneys for the Plaintiff 5 South Hanover Street Carlisle, Pennsylvania 17013 DAVID A. KRULAC, Plaintiff v. Supreme Court No. 32318 Tel.: 717-243-5838 Fax.: 717-243-6441 • DORIS B. GARMAN, ESTATE OF DORIS B. • GARMAN, UNKNOWN HEIRS OF DORIS B. GARMAN, NORTH STAR CAPITAL ACQUISITION, LLC, LOWER ALLEN TOWNSHIP AUTHORITY, CITIFINANCIAL SERCIES, INC., : ONEMAIN FINANCIAL, CHURCH OF GOD HOME, INC. : Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION TO QUIET TITLE NO. 2014-00683-CIVIL ACCEPTANCE OF SERVICE :41.• I■3 0-N rfl CL, I accept service of the Complaint to Quiet Title filed by David A. Krulac. I accept service on behalf of Emory D. Hostetter, of 30 Kough Road, Newville, Pennsylvania 17241, and certify that I am authorized to do so. Date: February ,;2 2014 Emory D. Hostetter, (print name) Address: ( Stephen D. Tiley, Esquire Frey and Tiley Attorneys for the Plaintiff 5 South Hanover Street Carlisle, Pennsylvania 17013 Supreme Court No. 32318 Tel.: 717-243-5838 Fax.:. 717-243-6441 DAVID A. KRULAC, Plaintiff DORIS B. GARMAN, ESTATE OF DORIS B. GARMAN, UNKNOWN HEIRS OF DORIS B. GARMAN, NORTH STAR CAPITAL ACQUISITION, LLC, LOWER ALLEN TOWNSHIP AUTHORITY, CITIFINANCIAL SERCIES, INC., ONEMAIN FINANCIAL, CHURCH OF GOD HOME, INC. : Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION TO QUIET TITLE NO. 2014-00683-CIVIL MOTION FOR ORDER AND NOW, comes David A. Krulac, Plaintiff, by his attorney, Stephen D. Tiley, Esquire, and files this Motion for Order, of which the following is a statement: 1. This Quiet Title Action was initiated by Complaint filed February 5, 2014. 2. All of the Defendants have been served with a copy of the Complaint and a Notice to Defend as evidenced by the Sheriffs Return filed March 17, 2014 and the various Affidavits of Service filed by the undersigned and the Affidavit of Posting filed by the Plaintiff. Motion for Order - Krulac v. Garman, et al. Page 1 of 4 3. Pa, R.C.P. 1066 provides, in er alia: (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. 4. C.C.R.P. 1066-2 provides: Except as otherwise provided by Order of Court, when the complaint has been served by publication and judgment has been entered against the defendant in accordance with Pa.R.C.P. 1066(b)(1), the time within which the defendant shall take the action directed by the decree of the Court shall be thirty (30) days after the last publication of notice of such decree. 5. The Complaint in the within action, together with its Notice to Defend, was served by publication upon Doris B. Garman, the Estate of Doris B. Garman, and the Unknown Heirs of Doris B. Garman. 6. No answer has been filed by any Defendant. WHEREFORE, the Plaintiff prays Your Honorable Court for an Order: (a) Declaring that the Tax Claim Bureau Deed to Plaintiff recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania to Instrument Number 2011-27922 is valid to convey full fee simple title to the property known as Cumberland County UPI No. 13-24-0797-139 to David A. Krulac, an adult individual, of Cumberland County, Pennsylvania. (b) Declaring that the Defendant, Doris B. Garman, is barred from asserting any right, lien, title, or interest in the Property inconsistent with the claim of the Plaintiff; Motion for Order - Krulac v. Garman, et. aL Page 2 of 5 (c) Declaring that the Defendant, Estate of Doris B. Garman, is barred from asserting any right, lien, title, or interest in the Property inconsistent with the claim of the Plaintiff; (d) Declaring that the Defendants, Heirs of Doris B. Garman, are barred from asserting any right, lien, title, or interest in the Property inconsistent with the claim of the Plaintiff; (e) Declaring that the Defendant, Church of God Home, inc., is barred from asserting any right, lien, title, or interest in the Property inconsistent with the claim of the Plaintiff; (f) Declaring that the Plaintiff is the legal owner of the Property and that legal title to the Property is vested solely in the Plaintiff, and that the Court's Order be recorded in the Recorder of Deeds Office of Cumberland County, Pennsylvania, and indexed as a deed with the Grantors being "Doris B. Garman," "Estate of Doris B. Garman," and "Heirs of Doris B. Garman," and that these proceedings, or an authenticated copy thereof, shall at all times hereinafter be taken as evidence of the facts decreed and established herein. (g) Declaring that any lien or interest of the Defendant North Star Capital Acquisition, LLC in the Property was extinguished by the September 22, 2011 Judicial Tax Sale and forever barring North Star Capital Acquisition, LLC from asserting any right, lien, title, or interest in the Property inconsistent with the interest of the Plaintiff, on the basis of the judgment filed to Cumberland County No. 2009-02616, or on any other basis predating this Complaint. (h) Directing the Cumberland County Prothonotary to mark the judgment of North Star Capital Acquisition, LLC, filed to Cumberland County No. 2009-02616 satisfied on the record. Motion for Order - Krulac v. Garman, et. al. Page 3 of 5 (i) Declaring that any lien or interest of the Defendant Lower Allen Township Authority in the Property was extinguished by the September 22, 2011 Judicial Tax Sale and forever barring it from asserting any right, lien, title, or interest in the Property inconsistent with the interest of the Plaintiff, on the basis of the judgments filed to Cumberland County Prothonotary numbers: 2007- 02992, 2008-02769, 2009-02712, and 2010-2871 or on any other basis predating the Complaint. (j) Directing the Cumberland County Prothonotary to mark the judgments of Lower Allen Township Authority filed to Cumberland County Prothonotary numbers: 2007-02992, 2008-02769, 2009-02712, and 2010-2871 satisfied on the record. (k) Declaring that any lien or interest of the Defendant CitiFinancial Services, Inc. in the Property was extinguished by the September 22, 2011 Judicial Tax Sale and forever barring it from asserting any right, lien, title, or interest in the Property inconsistent with the interest of the Plaintiff, on the basis of the mortgage recorded to Cumberland County Mortgage Book 1807, Page 4074, or on any other basis predating the Complaint. UNLESS the applicable Defendant files an answer or other responsive pleading within thirty (30) days after the last publication of notice of the Court's Decree or Order. Dated: g7 ,:201/ Respectfully submitted, STE HEN D. TILEY, Esquire FREY and TILEY Attorney for Plaintiff 5 South Hanover Street Carlisle, PA 17013 Tel.: (717) 243-5838 Supreme Court No.: 32318 Motion for Order - Krulac v. Garman, et. al. Page 4 of 5 Stephen D. Tiley, Esquire Frey and Tiley Attorneys for the Plaintiff 5 South Hanover Street Carlisle, Pennsylvania 17013 Supreme Court No. 32318 Tel.: 717- 243 -5838 Fax.: 717- 243 -6441 DAVID A. KRULAC, Plaintiff v. DORIS B. GARMAN, ESTATE OF DORIS B. GARMAN, • UNKNOWN HEIRS OF DORIS • B. GARMAN, NORTH STAR CAPITAL ACQUISITION, LLC, LOWER ALLEN TOWNSHIP AUTHORITY, • CITIFINANCIAL SERCIES, INC., : ONEMAIN FINANCIAL, CHURCH OF GOD HOME, INC. : Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION TO QUIET TITLE NO. 2014 - 0683 -CIVIL AFFIDAVIT OF POSTING G.3 I, David A. Krulac, posted the property, which is the subject of the above - captioned quiet title action, to wit: 5 Wayne Circle, Camp Hill (Lower Allen Township), Pennsylvania 17011 with a true and correct copy of the Notice ordered for publication by the Court ordered on February 10, 2014, and a copy of the Complaint to Quiet Title. The property was posted by me on February 2014 at )0 Am. A copy of photographs showing a close -up of where the Notice was posted, and a picture taken further away showing the location of posting on the property, is attached hereto as Exhibit "A." Affidavit of Posting Krulac v. Garman, et. al. Page 1 of 2 I make these statements pursuant to 18 Pa. Cons. Stat. §4904 relating to unsworn falsification to authorities and understand that false statements may subject me to criminal penalties under that statute. bato David A. Krulac, Plaintiff P. 0. Box 1064 Mechanicsburg, PA 17065 Affidavit of Posting Krulac v. Garman, et. al. Page 2 of 2 • • 1 Stephen D. Tiley, Esquire Frey and Tiley Attorneys for the Plaintiff 5 South Hanover Street Carlisle, Pennsylvania 17013 Supreme Court No. 32318 Tel.: 717-243-5838 Fax.: 717-243-6441 DAVID A. KRULAC, • Plaintiff v. DORIS B. GARMAN, - ESTATE OF DORIS B. • GARMAN, - UNKNOWN HEIRS OF DORIS • B. GARMAN, • NORTH STAR CAPITAL • ACQUISITION, LLC, - LOWER ALLEN TOWNSHIP • AUTHORITY, - CITIFINANCIAL SERCIES, INC., : ONEMAIN FINANCIAL, • CHURCH OF GOD HOME, INC. : • Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION TO QUIET TITLE NO. 2014-0683-CIVIL AFFIDAVIT CONCERNING SERVICE OF VACANT PROPERTY Pa. R.C.P. 410 provides that original process shall also be served upon any person not named as a party and is found in possession of the property, in real property actions. The first paragraph of the Sheriff's Retum filed March 17, 2014 states that the property known as 5 Wayne Circle, Lower Allen Township, Camp Hill, PA 17011, which is the subject property in this quiet title action, was found to be vacant. The property was also posted by the Plaintiff, as evidenced by the Affidavit of Posting filed contemporaneously herewith. Affidavit Concerning Service of Vacant Property Krulac v. Garman, et. al. Page 1 of 2 I make these statements pursuant to 18 Pa. Cons. Stat. §4904 relating to unsworn falsification to authorities and understand that false statements may subject me to criminal penalties under that statute. Steph n D. Tiley, Esquire Counsel for Plaintiff Frey and Tiley 5 South Hanover Street Carlisle, PA 17013 Tel. No. (717) 243-5838 Sup. Ct. ID 32318 Affidavit Concerning Service of Vacant Property Krulac v. Garman, et. aL Page 2 of 2 Stephen D. Tiley, Esquire Frey and Tiley Attorneys for the Plaintiff 5 South Hanover Street Carlisle, Pennsylvania 17013 DAVID A. KRULAC, Plaintiff v. Supreme Court No. 32318 Tel.: 717- 243 -5838 Fax.: 717- 243 -6441 DORIS B. GARMAN, ESTATE OF DORIS B. • GARMAN, UNKNOWN HEIRS OF DORIS • B. GARMAN, NORTH STAR CAPITAL ACQUISITION, LLC, LOWER ALLEN TOWNSHIP AUTHORITY, • • CITIFINANCIAL SERCIES, INC., : ONEMAIN FINANCIAL, • CHURCH OF GOD HOME, INC. Defendants • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION TO QUIET TITLE NO. 2014 -0683 -CIVIL AFFIDAVIT OF SERVICE HEIRS OF DORIS B. GARMAN ry The only living heir of Doris B. Garman, deceased, who is known to the undersigned, is Emorry D. Hostetter, of 30 Kough Road, Newville, Pennsylvania 17241. His daughter, Joanne Hutchinson, as attorney -in -fact for Emorry D. Hostetter, signed an Acceptance of Service on February 28, 2014, which Acceptance was filed on March 26, 2014. Doris B. Garman, the Doris B. Garman Estate, and the unknown heirs of Doris B. Garman were served by publication. See Affidavit of Service by Publication filed March 4, 2014. Affidavit of Service, Heirs of Doris B. Garman Krulac v. Garman, et. al. Page 1 of 2 The Court's February 10, 2014 Order for Service by Publication also required that copy of the Notice and Complaint to Quiet Title be posted at a conspicuous place on the property, to wit: 5 Wayne Circle, Camp Hill (Lower Allen Township), Pennsylvania 17011. See Affidavit of Posting by David A. Krulac, Plaintiff, filed on April 1, 2014. I make these statements pursuant to 18 Pa. Cons. Stat. §4904 relating to unsworn falsification to authorities and understand that false statements may subject me to criminal penalties under that statute. Affidavit of Service, Heirs of Doris B. Garman Krulac v. Garman, et. al. Stephen D. Tiley, Esquire Counsel for Plaintiff Frey and Tiley 5 South Hanover Street Carlisle, PA 17013 Tel. No. (717) 243-5838 Sup. Ct. ID 32318 Pae 2 o 2 Stephen D. Tiley, Esquire Frey and Tiley Attorneys for the Plaintiff 5 South Hanover Street Carlisle, Pennsylvania 17013 Supreme Court No. 32318 Tel.: 717- 243 -5838 Fax.: 717- 243 -6441 DAVID A. KRULAC, Plaintiff v. DORIS B. GARMAN, • ESTATE OF DORIS B. • GARMAN, • UNKNOWN HEIRS OF DORIS • B. GARMAN, NORTH STAR CAPITAL • ACQUISITION, LLC, LOWER ALLEN TOWNSHIP AUTHORITY, • CITIFINANCIAL SERCIES, INC., : ONEMAIN FINANCIAL, CHURCH OF GOD HOME, INC. : Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION TO QUIET TITLE NO. 2014 -00683 CIVIL C7 n.� ca ORDER AND JUDGMENT IN FAVOR OF PLAINTIFF zs% AND NOW, this day of April, 2014, upon consideration of the within Motion for Order, and the Sheriffs Return of Service and affidavits of service and posting having been filed, and as none of the Defendants have filed any answer or other responsive pleading to the Complaint, it is ORDERED THAT UNLESS THE DEFENDANTS SHALL FILE AN ANSWER OR OTHER RESPONSIVE PLEADING WITHIN THIRTY (30) DAYS AFTER THE LAST PUBLICATION OF NOTICE OF THIS ORDER, that the Court orders and enters judgment in favor of the Plaintiff, as follows: (a) The Tax Claim Bureau Deed to Plaintiff recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania to Instrument Number 2011 -27922 is valid to convey full fee simple title to the property known as Order and Judgment in favor of Plaintiff- Krulac v. Garman, et. al. Page 1 of 4 Cumberland County UPI No. 13 -24- 0797 -139 to David A. Krulac, an adult individual, of Cumberland County, Pennsylvania. (b) The Defendant, Doris B. Garman, is barred from asserting any right, lien, title, or interest in the Property inconsistent with the claim of the Plaintiff; (c) The Defendant, Estate of Doris B. Garman, is barred from asserting any right, lien, title, or interest in the Property inconsistent with the claim of the Plaintiff; (d) The Defendants, Heirs of Doris B. Garman, are barred from asserting any right, lien, title, or interest in the Property inconsistent with the claim of the Plaintiff; (e) The Defendant, Church of God Home, Inc., is barred from asserting any right, lien, title, or interest in the Property inconsistent with the claim of the Plaintiff; (f) The Plaintiff, David A. Krulac, is the legal owner of the Property and that legal title to the Property is vested solely in the Plaintiff, David A. Krulac, and that the Court's Order be recorded in the Recorder of Deeds Office of Cumberland County, Pennsylvania, and indexed as a deed with the Grantors being "Doris B. Garman," "Estate of Doris B. Garman," and "Heirs of Doris B. Garman," and that these proceedings, or an authenticated copy thereof, shall at all times hereinafter be taken as evidence of the facts decreed and established herein. (g) Any lien or interest of the Defendant North Star Capital Acquisition, LLC in the Property was extinguished by the September 22, 2011 Judicial Tax Sale and North Star Capital Acquisition, LLC is forever barred from asserting any right, lien, title, or interest in the Property inconsistent with the interest of the Order and Judgment in favor of Plaintiff- Krulac v. Garman, et. al. Page 2 of 4 Plaintiff, on the basis of the judgment filed to Cumberland County No. 2009- 02616, or on any other basis predating the Complaint filed in this Quiet Title Action. (h) The Cumberland County Prothonotary shall mark the judgment of North Star Capital Acquisition, LLC, filed to Cumberland County No. 2009 -02616 satisfied on the record. (i) Any lien or interest of the Defendant Lower Allen Township Authority in the Property was extinguished by the September 22, 2011 Judicial Tax Sale and forever barring it from asserting any right, lien, title, or interest in the Property inconsistent with the interest of the Plaintiff, on the basis of the judgments filed to Cumberland County Prothonotary numbers: 2007 - 02992, 2008 - 02769, 2009 - 02712, and 2010 -2871 or on any other basis predating the Complaint filed in this_Quiet Title Action. (j) The Cumberland County Prothonotary shall mark the judgments of Lower Allen Township Authority filed to Cumberland County Prothonotary numbers: 2007 - 02992, 2008 - 02769, 2009 - 02712, and 2010 -2871 satisfied on the record. (k) Any lien or interest of the Defendant CitiFinancial Services, Inc. in the Property was extinguished by the September 22, 2011 Judicial Tax Sale and CitiFinancial Services, Inc. is forever barred it from asserting any right, lien, title, or interest in the Property inconsistent with the interest of the Plaintiff, on the basis of the mortgage recorded to Cumberland County Mortgage Book 1807, Page 4074 or on any other basis predating the Complaint filed in this Quiet Title Action. THIS ORDER shall be served upon Doris B. Garman, Estate of Doris B. Garman, and Unknown Heirs of Doris B. Garman, by one (1) publication in a newspaper of general circulation in Cumberland County and the Cumberland Order and Judgment in favor of Plaintiff- Krulac v. Garman, et. al. Page 3 of 4 Law Journal, of the Notice attached to the Motion for Order as Exhibit "A." (Pursuant to C.C.R.P. 1066-3) By the ourt, Albert H. Mastand, J. /8-1e.phen D. Tiley, Esquire, 5 South Hanover St., Carlisle, PA 17013 —North Star Capital Acquisition, LLC, c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054 ,kowerAIIen Township Authority, New Cumberland , Pennsylvania 17070 ,...-CitiFinancial, 6400 Las Colinas Blvd., Mail Stop — C2-83, Irving, Texas, 75039 itiFinancial Investment Recovery, Attn: Payment Processing, CIO: Latasha Anderson, 605 Munn Rd, Fort Mills, South Carolina 29713 ..eiiFinancial Services, Inc., 14700 Citicorp Drive, MC: 1020, Hagerstown, Maryland 21742 .,„..Emory D. Hostetter, c/o Joanne Hutchinson, 418 Steelstown Road, Newville, PA 17241 ,,--Church of God Home, Inc., 801 North Hanover Street, Carlisle, Pennsylvania 17013 eCop t.cL, 10//cf Order and Judgment in favor of Plaintiff- Krulac v. Garman, et. al. Page 4 of 4 DAVID A. KRULAC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA v. CIVIL ACTION - LAW DORIS B. GARMAN, ESTATE OF DORIS B. ACTION TO QUIET TITLE GARMAN, UNKNOWN HEIRS OF DORIS : B. GARMAN, : NO. 2014-0683-CIVIL co 122' r-- -orn NORTH STAR CAPITAL * . CL; CD I ACQUISITION, LLC, --r• —r1 LOWER ALLEN TOWNSHIP : r-rn -v < -.ie. --r• AUTHORITY, • CITIFINANCIAL SERCIES, INC., : ONEMAIN FINANCIAL, . CHURCH OF GOD HOME, INC. : Defendants AFFIDAVIT OF SERVICE BY PUBLICATION ▪ 1::=) Notice of the Court's April 7, 2014 Order giving the Defendants thirty (30) days to file an answer or other responsive pleading in the above captioned matter was served upon Doris B. Garman, the Estate of Doris B. Garman, and the Unknown Heirs of Doris B. Garman, by publication in the Cumberland Law Journal on April 18, 2014, and by publication in the Harrisburg Patriot News on April 15, 2014, of the Notices attached to the Proofs of Publication, which are attached hereto. The Proof of Publication for the Cumberland Law Journal is attached hereto as Exhibit "A." The Proof of Publication for the Harrisburg Patriot News is attached hereto as Exhibit "B." I make these statements pursuant to 18 Pa. Cons. Stat. §4904 relating to unsworn falsification to authorities and understand that false statements may subject me to criminal penalties under that statute. 42,e0 075; Stephen D. Tiley, Esquire Counsel for Plaintiff Frey and Tiley 5 South Hanover Street Carlisle, PA 17013 Tel. No. (717) 243-5838 Sup. Ct. ID 32318 14) 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 18, 2014 Affiantfurther 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. . "A" sa Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 18 day of April, 2014 NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL ACTION TO QUIET TITLE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action —Law NO. 2014 -00683 CIVIL DAVID A. KRULAC, Plaintiff v. DORIS B. GARMAN, ESTATE OF DORIS B. GARMAN, UNKNOWN HEIRS OF DORIS B. GARMAN, NORTH STAR CAPITAL ACQUISITION, LLC, LOWER ALLEN TOWNSHIP AUTHORITY, CITIFINANCIAL SERVICES, INC., ONEMAIN FINANCIAL, CHURCH OF GOD HOME, INC., Defendants TO: DORIS B. GARMAN, ESTATE OF DORIS B. GARMAN, UNKNOWN HEIRS OF DORIS B. GARMAN You are notified that an Order has been entered to No. 2014 -00683 in the Court of Common Pleas of Cum- berland County, Pennsylvania, on April 7, 2014 directing that within thirty (30) days after this publica- tion you shall file an answer or other responsive pleading or be forever barred from asserting any right, lien, title or interest inconsistent with the interest or claim set forth in the plaintiff's complaint to the land here described: ALL THAT CERTAIN tract of land with the buildings and improvements thereon erected situated in Lower Allen Township, County of Cumber- land and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northerly line of Wayne Circle, which point is 240.71 feet East of the north- easterly corner of Wayne Circle and Wayne Road and the dividing line be- tween Lots Nos. 138 and 139; thence along the said division line North 8 3 degrees 59 minutes 30 seconds West 124.27 feet to a point; thence along the southerly line of Lots 127, 126 and 125 on said Plan South 59 degrees 3 minutes 30 seconds East 117.02 feet to a point on the westerly line of Lot No. 140; thence along same South 42 degrees 35 minutes West 109.85 feet to a point on the northerly line of Wayne Circle aforesaid; thence along same in an arc having a radius of 45 feet to the left, in a westerly direction forty (40) feet to a point, the Place of BEGINNING. BEING Lot No. 139 in Plan of Cumberland Park, Inc., which Plan is recorded in the Cumberland County Recorder's Office in Plan Book 4, Page 86 and being improved with a dwell- ing known as 5 Wayne Circle. ALSO KNOWN AS 5 Wayne Circle, Camp Hill, PA 17011. ALSO KNOWN AS UPI No.: 13 -24- 0797 -139. By: Ron Anderson, Sheriff STEPHEN D. TILEY, ESQUIRE FREY & TILEY Attorneys for Plaintiff 5 South Hanover Street Carlisle, PA 17013 (717) 243 -5838 Apr. 18 The Patriot -News Co. 2020 Technology Pkwy Suite 300 ilechanicsburg, PA 17050 Inquiries - 717 - 255 -8213 FREY & TILEY 5 S HANOVER ST CARLISLE PA 17013 1ie atriot News Now you know DAVID A. KRULAC, Plaintiff v. DORIS 8. GARMAN, ESTATE OF DORIS B. GARMAN, UNKNOWN HEIRS OF DORIS 8. GARMAN, NORTH STAR CAPITAL ACQUISITION, LL'C, LOWER ALLEN TOWNSHIP AUTHORITY, CITIFINANCIAL SERCIES, INC., ONEMAIN FINANCIAL, CHURCH OF GOD HOME, INC. Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION TO QUIET TITLE NO. 2014-00683 CIVIL TO: DORIS B. GARMAN ESTATE OF DORIS B. GARMAN UNKNOWN HEIRS OF DORIS B. GARMAN You are notified that an Order has been entered to No. 2014-00683 in the Court of Common Pleas of Cumberland County, Pennsylvania, on April 7, 2014 directing that within thirty (30) days after this publication you shall file an answer or other responsive pleading or be forever barred from asserting any right, lien, title or interest inconsistent with the Interest or claim set forth in the plaintiff's complaint to the land nere described: ALL THAT CERTAIN tract of land with the buildings and improvements thereon erected situated In Lower Allen Township, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northerly line of Wayne Circle, which point Is 240.71 feet East of the northeasterly corner of Wayne Circle and Wayne Road and the dividing line between Lots Nos. 138 and 139; thence along the said division line North 3 degrees 59 minutes 30 seconds West 124.27 feet to a point; thence along the southerly line of Lots 127, 126 and 125 on said Plan South 59 degrees 3 minutes 30 seconds East 117.02 feet to a point on the westerly line of Lot No. 140; thence along same South 42 degrees 35 minutes West 109.85 feet to a point on the northerly line of Wayne Circle aforesaid; thence along same In an arc having a radius of 45 feet to the left, In a westerly direction forty (40) feet to a point, the Place of BEGINNING. BEING Lot No. 1391n Plan of Cumberland Park, Inc., which Plan Is recorded in the Cumberland County Recorder's Office in Plan Book 4, Page 86, and being improved with a dwelling known as 5 Wayne Circle. ALSO KNOWN AS 5 Wayne Circle, Camp Hill, PA 17011. ALSO KNOWN AS UPI No.: 13-24 -0797- 139. By: Ron Anderson, Sheriff By: Stephen D. Tiler, Esquire Attorney for Plaintiff Frey & Tiler 5 South Hanover Street Carlisle, PA 17013 (717) 243 -5838 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss �g duly sworn according to law, deposes and says: ,ccountant of The Patriot News Co., a corporation organized and existing under the laws of the ania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the my of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday general circulation, printed and published at 1900 Patriot Drive, in the City, County and State Jews and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, en continuously published ever since; ce or publication which is securely attached hereto is exactly as printed and published in their regular anity Weekly editions which appeared on the date(s) indicated below. That neither she nor said i subject matter of said printed notice or advertising, and that all of the allegations of this statement as ter of publication are true; and ial knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on o. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the rectors of the said Company and subsequently duly recorded in the office for the Recording of Deeds rectors in Miscellaneous Book "M ", Volume 14, Page 317. This ad # 00022 51 ran on the dates shown below: April 15, 2014 and subscribed before e • 18 day of Aril, 2014 A.D. rr 6 :0 :7 i'f?4MWEALTH OF PENNSYLVANIA t'io1y Lynn WNotarial Seal arfel, Notary Public W' hington 7Wp., Dauphin County L Commission E 4,fires Pe1:.12 2026 "`M'i :11. ` RINSYLVAN1A ASSiMT1ON OF` NOTARIES Stephen D. Tiley, Esquire Supreme Court No. 32318 Frey and Tiley Attorneys for the Plaintiff 5 South Hanover Street Tel.: 717-243-5838 Carlisle, Pennsylvania 17013 Fax.: 717-243-6441 DAVID A. KRULAC, • IN THE COURT OF COMMON PLEAS • OF CUMBERLAND COUNTY, Plaintiff • PENNSYLVANIA • • v. • CIVIL ACTION - LAW DORIS B. GARMAN, ESTATE OF DORIS B. • ACTION TO QUIET TITLE GARMAN, • UNKNOWN HEIRS OF DORIS : B. GARMAN, NO. 2014-0683-CIVIL NORTH STAR CAPITAL • ACQUISITION, LLC, • --vmco,, LOWER ALLEN TOWNSHIP : 22::73 ,f` Cl)r— tv AUTHORITY, : --<?' CITIFINANCIAL SERCIES, INC., : ONEMAIN FINANCIAL, C' CHURCH OF GOD HOME, INC. : ' Defendants • PREAECIPE TO THE PROTHONOTARY: Enter on Appearance Docket and on Decree (Order and Judgment in Favor of Plaintiff dated April 7, 2014) a notation that the defendants failed to take the action directed in the last advertisement, and as directed in the Order dated April 7, 2014, within the time therein limited; and transmit to the Recorder of Deeds a certified copy of the Decree (Order and Judgment in Favor of Plaintiff dated April 7, 2014) containing the notation above-described. (See C.C.R.P.1066-4.) —wow .2-p?5 Stephen i. Tiley, Esquire Counsel for Plaintiff Frey and They 5 South Hanover Street Carlisle, PA 17013 7D Tel. No. (717) 243-5838 Sup. Ct. ID 32318 ©7 3 ‘,/7 Praecipe:Krulac v. Garman, et. al. Page 1 of 1