HomeMy WebLinkAbout14-0675 Supreme Cort:Vof� Pennsylvania
COU F Of P1eas For Prothonotary Use Only:
oveSheet IMF.
Docket No: �l
CU BERLAIVD �/ County // r!p 7T� '
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service ofpleadings or other a ers as required by law or rules of court.
Commencement of Action:
S 0 Complaint 1l Writ of Summons Petition
Transfer from Another Jurisdiction Declaration of Taking
E
C Lead Plaintiff's Name: Lead Defendant's Name:
Lee H. Laughlin Richard H. Laughlin
T
I Are money damages requested? 0 Yes El No Dollar Amount Requested: Mwithin arbitration limits
(check one) r outside arbitration limits
O
1 N Is this a Class Action Suit? 0 Yes x, No Is this an MDJAppeal? Yes 1 No
F
A Name of Plaintiff/Appellant's Attorney: Jer A. Weigle, Esquire
I Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant)
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
E
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
El Intentional " Buyer Plaintiff Administrative Agencies
Malicious Prosecution Debt Collection: Credit Card 0 Board of Assessment
Motor Vehicle r-3 Debt Collection: Other
Board of Elections
Nuisance Dept. of Transportation
Premises Liability Statutory Appeal: Other
i S Product Liability (does not include
mass tort)
E Employment Dispute:
1 Slander/Libel/ Defamation Discrimination
C Other: 13 Employment Dispute: Other Zoning Board
T 1l Other:
I Other:
O MASS TORT
0 Asbestos
N [] Tobacco
Toxic Tort - DES
n Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
0 Toxic Waste
[3 Other: Ejectment Common Law /Statutory Arbitration
B Eminent Domain/Condemnation 13 Declaratory Judgment
1] Ground Rent Mandamus
Landlord/Tenant Dispute Non - Domestic Relations
Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABLITY
Mortgage Foreclosure: Commercial Q Quo Warrarito
Dental IM Partitions Replevin
Legal [3 Quiet Title Other:
Medical Other:
E] Other Professional:
Updated 1/1/2011
L ED
14 FEB -5 Pn 12.. 5'5
LEE H. LAUGHLIN, IN THE�MWIT ftVN PLEAS OF
CUMBERLIL1W
Plaintiff,
CIVIL ACTION — EQUITY
VS. NO. l7 - 6'tl6'
�v1
RICHARD H. LAUGHLIN,
Defendant. ACTION IN PARTITION
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 with out 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 TO FIND OUT WHERE YOU CAN GET HELP.
THE OFFICE LISTED BELOW CAN PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THE
OFFICE LISTED BELOW 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, PA 17013
(717) 249 -3166
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court.
sy d 3 �
WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257 -1397
1
LEE H.LAUGHLIN, IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
Plaintiff,
CIVIL ACTION — EQUITY
VS.
NO.
RICHARD H. LAUGHLIN,
Defendant. ACTION IN PARTITION
COMPLAINT FOR PARTITION OF REAL ESTATE
1. Plaintiff, Lee Laughlin, is an adult individual currently residing at 41 Turnpike Road,
Newburg, Cumberland County, Pennsylvania 17240.
2. Defendant, Richard H. Laughlin, is an adult individual currently residing at 15 Laughlin
Lane, Newburg, Cumberland County, Pennsylvania, 17240.
3. Plaintiff and Defendant are joint owners of certain mountain real estate in Hopewell
Township, Cumberland County, Pennsylvania as described below, with the Plaintiff
owning an undivided four -fifths interest and the Defendant own an undivided one -fifth
interest in said mountain real estate; having the following legal description:
ALL that certain tract of land lying and being in Hopewell Township,
Cumberland County and Commonwealth of Pennsylvania, bounded and described
as follows, to wit:
BEGINNING at a chestnut tree; thence by lands now or formerly of William
Keeseman's heirs North thirty-three and one -half (33 %) degrees West twenty -
eight and six tenths (28.6) perches to a hickory; thence North thirteen and one-
WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257 -1397
half (13 %2) degrees East fourteen and five tenths (14.5) perches to a post; thence
South seventy -three and one -half (73 %2) degrees East fifty -four (54) perches to a
hickory; thence by land now or formerly of A. C. Book South sixty and one -half
(60 1 /2) degrees West forty -five (45) perches to the place of BEGINNING.
CONTAINING six (6) acres and sixty -eight (68) perches, neat measure.
4. The above - referenced property known as 6 acres of mountain ground in Hopewell
Township, Cumberland County, Pennsylvania, was obtained by Hughie D. Laughlin,
Defendant, Plaintiff, Daniel G. Laughlin, and Janice M. Chamberlin by Deed dated
November 1, 1977, and recorded in the office of the Recorder of Deeds of Cumberland
County in Deed Book "27, Page 593. Said Deed is attached hereto, made a part hereof,
and marked "Exhibit A."
Upon the demise of said Hughie D. Laughlin, his one -fifth interest in said real
estate was conveyed to his surviving spouse, Dorothy M. Laughlin.
Upon the demise of Dorothy M. Laughlin, the one -fifth interest in said real estate
was equally divided between the Executor of her Estate, who is the same as Plaintiff, as
well as Daniel G. Laughlin, and Janice M. Chamberlin by Deed dated March 20, 2013,
recorded in the office of the Recorder of Deeds of Cumberland County, with Instrument
Number 201312449. Said Deed is attached hereto, made a part hereof, and marked
"Exhibit B."
Janice M. Chamberlin then conveyed her interest in the said real estate to Plaintiff
by Deed dated July 20, 2013, recorded in the office of the Recorder of Deeds of
WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257 -1397
Cumberland County, with Instrument Number 201332148. Said Deed is attached hereto,
made a part hereof, and marked "Exhibit C."
Similarly, Daniel G. Laughlin conveyed his interest in the said real estate to
Plaintiff by Deed dated July 20, 2013, recorded in the office of the Recorder of Deeds of .
Cumberland County, with Instrument Number 201332149. Said Deed is attached hereto,
made a part hereof, and marked "Exhibit D."
As a result of the above - referenced transactions, Plaintiff now owns an undivided
four -fifths interest in the referenced 6 acres of mountain ground with Defendant owning
the remaining one -fifth interest.
5. A copy of a survey for the above - referenced mountain land has been attached hereto,
made a part hereof, and marked "Exhibit E"
6. Plaintiff now wishes to either acquire Defendant's undivided one -fifth interest in said
mountain real estate, or, in the alternative, to divide his four -fifths interest from the
remaining one -fifth interest owned by the Defendant.
7. To date, numerous attempts to reach an agreement with the Defendant to either acquire
the Defendants one -fifth interest from the Defendant or to divide their respective interest
in said mountain estate through phone call and written communications have failed.
* WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257 -1397
8. In summation, no amicable solution of this matter has yet to be achieved; therefore, a
legal partition of the above - described real estate is the only alternative yet available to
Plaintiff pursuant to Pennsylvania Rules of Civil Procedure beginning with Rule 1551.
WHEREFORE, Plaintiff demands that:
(a) the Court decree partition of the above - referenced real estate and in accordance with
Pennsylvania Rules of Civil Procedure as cited above.
(b) the share or shares to which the respective parties are entitled be set out to them in
severalty and that all proper and necessary conveyances and assurances be executed carrying
such partition into effect; and that, if the real estate cannot be divided without prejudice to or
spoiling the while, such proper and necessary sale or sales of the same be made by such persons
and in such manner as the Court may direct;
(c) such other and further relief be granted as the Court deems just and proper.
Very truly yours,
WEIGLE & ASSOCIATES, P.C.
B (A4
A.
Je . eigle, Esquire
Attorney or Plaintiff
Attorney ID #01624
126 East King Street
Shippensburg, PA 17257
Telephone: (717) 532 -7388
WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBVRG, PA 17257 -1397
VERIFICATION
I, Lee H. Laughlin, verify that the statements made in this Complaint for Partition of Real
Estate are true and correct. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities.
Date
Lee H. Laughl' laintiff
WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257 -1397
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5 MADE THE 6d -t-
day of in the year
of our Lord one thousand Trine hundred seventy -seven (1977)
$ETWEEN MARY E. LAUGHLIN, Executrix of the Estate of Arthur H. Laughlin,
WGHIE D. LAUGHLIN and DOROTHY M. LAUGHLIN, his wife, RICHARD H.
t LAUGHLIN and RACHEL M. LAUGHLIN, his wife, and LEE H. LAUGHLIN
and JEANETTE A. LAUGHLIN, his wife, all of R. D. 8 1, Newburg,
Pennsylvania, hereinafter called the
i
1
i and HUGHIE A LAUGHLIN, RICHARD H. LAUGHLIN, LEE H. LAUGHLIN, DANIEL
G. LAUGHLIN, all of R. D. 5 1, Newburg, Pennsylvania, and JANICE M.
CHA.NfBERLIN, of Star Route 2, Shippensburg, Pennsylvania, - hereinafter
called the
Grantees
WITNESSETH, that in coneWenation of ONE DOLLAR ($1.00) -- —_ -- ---- --
{{{i - Aollara,
in hand paid, the receipt whereof is hereby acknowledged, the said grantors do hereby grant
and convey to the said grantees , their heirs and assigns, 3
1 pp a
9 ALL that certain tract of land lying and being in Hopewell Township, Cumberland
County and State of Pennsylvania, 'bounded and described as follow, to wit:
BEGINNING at a chestnut tree; thence by lands now or formerly of William Keeseman's i
heirs North thirty -three and one -half (33'x) degrees West twenty -eight and six
R tenths (28.6) perches to a hickory; thence North thirteen and one -half (13'�
degrees East fourteen and five tenths (14.5) perches to a post; thence South
seventy-three and one -half 7331) de ''• "`
y ( degrees East fifty -four (54) perches to a i
ta�tii hickory; thence by land now or formerly of A. C. Book South sixty and one -half
NI (60'k) degrees West forty -five (45) perches to the place of BEGINNING. CONTAINING
99 six (6) acres and sixty -eight (68) perches, neat measure.
0
a � BEING the same tract which G. Harold Laughlin and Reba B. Laughlin, his wife, by
their deed dated January 28, 1944, and recorded in Cumberland County Deed Book
"V ", Volume 12, at Page 69, conveyed to Arthur H. Laughlin, Hughie D. Laughlin, c
and their children, subject, however, to a life estate interest in the above
described premises in the said G. Harold Laughlin; and the said G. Harold i
• Laughlin passed away on January 2, 1947, , thereby vesting the entire fee in
Arthur H. Laughlin, Hughie D.Laughlin, Richard H. Laughlin and Lee H. Laughlin,
the latter two persons being the only children born of Arthur H. Laughlin and r
Hugh G. Laughlin on January 28, 1944; and the said Arthur H.'Laughlin died i
testate on March 23, 1977, with Letters Testamentary having been granted to
Mary E. Laughlin, widow of Arthur H. Laughlin on June 7, 1977, who together
with the above mentioned Hughie D.Laughlin, Richard H. Laughlin, Lee H. Laughlin
and their spouses are the grantors herein.
A C
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S 0 C'./1 -ti t1N T— m.fiip of 1! s
Cumb. Co., Pa.
School is. Cumb. Co., Pe. N Krx-
1 % Real Estefi Tr+eds Tex irr G_ ^
1 �• $eel E:fale Tramiu Tax
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Date .A f. '.II . 0•te Amf.
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W. /Cot Cumb e.,Disf. Col. As �3
11 ° COMMONWEALTH Oil PENtJSYLVAN!A -
DEPARTMENT OF REVFNUE —
l • ..,, REALTY t —
I N T FER
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DOOMN27 PACE 593 EXHIBIT
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f And the said Grantor Mary E. Laughlin hereby covenants and agrees that she
will warrant specially the property hereby conveyed; and the said Rughie D. Laughlin
and Dorothy M. Laughlin, his wife, Richard H. Laughlin and Rachel M. Laughlin,
his wife, Lee R. Laughlin and Jeanette A. Laughlin, his wife, covenant and
agree that they and everyone of them will warrant generally the property
hereby conveyed. p
i j¢hl( C�i.:S CLdLty�t �i / N
(SEAL)
Ma E. Laughlin, Executrix of the
Estate of Arthur H. Laughlin
IN WITNESS WHEREOF, said gmtora ha vehereunto set their hand sand seal s
the day and year first above written. .j;,, (SEAL)
a r, Lau _
tt
i biptb. 9peaieb sub 3DetibettD u h ie D. ss
S y
Il[ tits �tCgtJltt C
or "� _ Laug h
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UIM n. uljzdzx J ss�Ar.
eGtn� `/ (SEAL)
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State of PENNSYLVANIA J (SEAL)
s e Jeanette A. Laughl i -
County of CUMBERLAND
On this, the !/e!� day of /y�'+► K/ �L. 1877 r
s , before me,
a Notray Public in and for said County and State
the undersigned 05cer, Versovally appeared j
Mary E
u Li. i. Laughlin. Hughie D. Laughlin and Dorothy M. Laughlin, his wife', Richard H.
nn,andsRacel M. Laughlin, his wife, and Lee H. Laughlin and Jeanette A.
£ w me ( A proven) to be the person a whose name a are subscribed to the
within instrument, and acknowledged that . they executed same for the purposes therein .
contained.
IN WITNESS WHEREOF, l hereunto s my ha and official seal
i IVUTAR sa .Y ^.
MY Commission Fxpi •s July 31 797H ` • ?.. °:; �. ••. .
- — S�eosliuig'P'a m5:7�"�au"efy _�• . i._', �;•...
} State of
i County of 68.
111
OA this, the day of ,18 , before me,
I 1
{ the underai9ned o$tcer, personally appeared
known to me (or satisfactorily proven) to be the person whose name subscribed to the
within instrument, and acknowledged that executed same for the purposes therein
contained.
IN WITNESS WHEREOF, I hereunto set my hand and ofk -ial seal
• Title of O5cer.
do hereby certify that the precise residence and complete post oQlee address
k of the within named grantee is - R. D. $ 1, Newburg, Pennsylvania 17240
1 r
>karney for _
BOOVf/27 PACE 594
i
1
___. _.._.. .. _...._.._........... _ ..... ...... _._..... ........
. _. .....,. ...._.. .....,
3
,i
r� REALTY TRANSFER TAX FOR RECORDER'S USE ONLY
Rwao (�Tm BOOK NUMB R -
COMMORWEALTH OF PENNSYLVANIA AFFIDAVIT OF VALUE PAGE NUM ER
DEPARTMENT OF REVENUE DATE RECO �J
( + BUREAU Of COUNTY COLLECTIONS
COMPLETE APPLICABLE SECTIONS IN FULL AND FILE IN DUPLICATE WITH RECORDER OF DEEDS WHEN (1) THE
FULL CONSIDERATION IS NOT SET FORTH IN THE DEED, (2) THE TRANSFER IS WIHTOUT CONSIDERATION OR A GIFT,
1 O R ( A TAX EXEMPTION IS CLAIMED. (REFER SECT, S. RTT ACT OF DEC. 27, 1951, P.L. 1742 AS AMENDED) }
SECTION 1
(COMP FOR ALL TRANSACTIONS)
1 Q o.G a lZ fl7 l /7121, � A
ADDR 21P COPE ,
e�a lZ 12 #
( ORANTEE(Sl ADDRESS ZIP CODE 1
• LOCATION OF LAND. TENEMENTS AND H 1 MENTSi
•� R. . STREET & HUMaFft OR OTHER DESCRIPTION NAME OF OC L O VERNMENTAL NIT ~ COUNTY "•
E FULL CONSIDERATIONS HIGHEST ASSESSED VALUE
}` t FAIR MARKET VALUE S REALTY TRANSFER TAX -PAID $
1
'1 TAX EXEMPT TRANSACTIONS: IF TRANSFER IS PARTIALLY OR WHOLLY EXEMPT, SHOW AMOUNT EXEMPT,
RE SOtj (S) AND CIT7 PORTION OF LAW. -
Oo T
7
IF tHIS IS A T ANSFER FROM A STRAW, AGENT OR TRUST AGREEMENT, COMPLETE THE REVERSE SIDE, i
SECTION II
_ (COMPLETE ONLY IF PROPERTY WAS SUSJ ECT TO LIEN OR MORTGAGE AT THE TIME OF TRANSFER)
1.
EXISTING MORTGAGE: S DISPOSITION II
S
- MORTGAGEE ADDRESS
n EXISTING MORTGAGE: f DISPOSITION j
MORTGAGEE ADDRESS f
EXISTING LIEN OR OSLIGATIONI S DISPOSITION 1 ( .
f i i
LIENHOLDER ADDRESS
y EXISTING LIEN OR OBLIGATION: S DISPOSITION
I 't 7
((( (� L+ENNOLDER ADDRESS }
SECTION III t
(COMPLETE ONLY IF TRANSFER IS RESULT OF JUDICIAL SALE) —
OFFICIAL CONDUCTING SALE
. NAME ADDRESS TITLE
SUCCESSFUL BIDDER I
J NAME ADDRESS TITLE
R 1
1 JUDGEMENT PLUS HIGHEST ASSESSED
PRIOR LIENS BID PRICE VALUE }
7.
HIGHEST ASSESSED VALUE''=
r..
J UDGEMENT PLUS INTEREST f
R
BID PRICE rs'Ij ;ti
ICE %�'i� S
1
PRIOR RECORDED LIEN S S _ Gy <i }ez •,•' +,
Ir PRIOR RECORDED MORTGAGE S 5
PRIOR RECORDED MORTGAGE S S s • "Y` ^''` "�"'�`' " "'�
UNPAID REAL ESTATE TAXES S '•' "�' �'�:""� ` " "�'� " %'+•`'
MATER RENT DUE S 5
SEWAGE RENT DUE S S:t�� i•?'• !
1 @ j
ATTORNEY FEES S i
1 I i OTHER (COSTS. ETC.) 5 5 "•�`•` 1
TOTAL S f .I
99 NOTEI CALCULATIONS MUST BE SHOWN IN ALL COLUMNS,.
. ALL OF THE INFORMATION ENTERED I
SWORN AND SU B !m I THI ON BOTH SIDES OF THIS AFFIDAVIT IS I
,, • J._ :,)(.!r •;� _•. TRUE, FULL AND COMPLETE TO THE
SLIMIN IE MY
F. KNOWLEDGE, INFORMATION
� . 3 Y; ii AND BE
Q V ART P4RLiC r, ^7
S Si"
GRANTS GENT O G ANTES
MYC6a0 .�1,S20rjE�GPiAE�`�. i
��I.. .
GRAN TO 0 AGENT GRANTOR j
ii •••••• S��NlC/� L PACE 595 .• a STRAW TRUST.
ii
i
:\2013 \Weigle, Jerry A\L,aughlin, Dorothy M. Estate\Executors Deed mountain land.doc
T HIS DEED
0039 DR
MADE THE day of , in the year of our Lord two thousand and
lirteen (2013).
ETWEEN LEE H. LAUGHLIN, as Executor of the ESTATE OF DOROTHY M.
LAUGHLIN, late of Hopewell Township, Cumberland County, Pennsylvania,
hereinafter referred to as Grantor,
' 1 f
i,ND LEE H. LAUGHLIN, DANIEL G. LAUGHLIN, and JANICE M.
CHAMBERLIN, Beneficiaries of the Estate of Dorothy M. Laughlin, hereinafter
referred to as Grantee,
WHEREAS, the said Estate of Dorothy M. Laughlin, was vested in her lifetime with an
divided one -fifth (115) interest in the legal title to premises hereinafter described, situate in the
ownship of Hopewell, County of Cumberland, Commonwealth of Pennsylvania; and,
WHEREAS, the said Dorothy M. Laughlin died testate on August 25, 2012; with her Last Will
d Testament having been subsequently duly probated in Cumberland County, Pennsylvania; and,
WHEREAS, the said real estate hereinafter described was not specifically devised, and the said
ee H. Laughlin subsequently qualified as Executor of the Estate of Dorothy M. Laughlin.
NOW THEREFORE, This Indenture Witnesseth that the said Lee H. Laughlin as Executor
foresaid, for and in consideration -of the sum of ONE DOLLAR ($1.00), lawful money of the United
tates of America to him in hand paid by the said Grantee, at and before the sealing and delivery hereof,
he receipt whereof is hereby acknowledged, has granted, bargained, sold, aliened, released and
onfirmed, and by these presents, by virtue of the power and authority in Lee H. Laughlin vested by the
robate, Estates and Fiduciaries Code of the Commonwealth of Pennsylvania, does grant, bargain, sell,
lien, release and confirm unto the said Grantee, their heirs and assigns,
]ALL that certain tract of land lying and being in Hopewell Township, Cumberland County and
ommonwealth of Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a chestnut tree; thence by lands now or formerly of William Keeseman's heirs
orth thirty -three and one -half (33 %) degrees West twenty -eight and six tenths (28.6) perches to a
ckory; thence North thirteen and one -half (13 %2) degrees East fourteen and five tenths (14.5) perches
o a post; thence South seventy -three and one -half (73 1 /2) degrees East fifty -four (54) perches to a
ickory; thence by land now or formerly of A. C. Book South sixty and one -half (60 1 /2) degrees West
orty -five (45) perches to the place of BEGINNING. CONTAINING six (6) acres and sixty -eight (68)
erches, neat measure.
EXHIBIT
IV
WEIGLE & ASSOCIATES, P.C. - ATTORNE11 STREET - SHIPPENSBURG, PA 17257 -1397
1
:\2013 \Weigle, Jerry A \Laughlin, Dorothy M. Estate \Executors Deed mountain land.doc
BEING the same premises which Mary E. Laughlin, Executrix of the Estate of Arthur H.
Laughlin, Hughie D. Laughlin and Dorothy M. Laughlin, his wife, Richard H. Laughlin and Rachel M.
aughlin, his wife, and Lee H. Laughlin and Jeanette A. Laughlin, his wife, by their deed dated
ovember 1, 1977, and recorded in Cumberland County, Pennsylvania, at Deed Book "N," Volume 27,
it Page 593, conveyed to Hughie D. Laughlin, Richard H. Laughlin, Lee H. Laughlin, Daniel G.
aughlin, and Janice M. Chamberlin, thereby vesting in the same Hughie D. Laughlin an undivided one -
ifth (115) interest in the above described premises. The said Hughie D. Laughlin died testate on May
7, 2003, leaving a Last Will and Testament which granted all of his estate to his beloved wife, Dorothy
q. Laughlin, with Letters Testamentary subsequently having beer! granted to the said Dorothy M.
aughlin, in Cumberland County, Pennsylvania, on or about December 10, 2010, at Estate No. 21 -10-
213, thereby vesting the above referenced one -fifth (115) interest in the above - described property in the
aid Dorothy M. Laughlin. The said Dorothy M. Laughlin died testate on August 25, 2012, with Letters
estamentary subsequently having been granted, to the above mentioned Lee H. Laughlin in Cumberland
ounty, Pennsylvania, on or about September 28, 2012 (Estate No. 21 -12- 1069), who is the Grantor
erein.
AND THE SAID Grantor hereby covenants and agrees that he will warrant specially the
roperty hereby conveyed.
AND THE SAID. Grantor, Executor as aforesaid, his heirs, executors and administrators, does
covenant, promise and agree to and with the said Grantee, their heirs and assigns, by these presents, that
ie Grantor has not done, committed any act, matter or thing whatsoever whereby the premises hereby
anted, or any part thereof, is, are, shall or may be impeached, charged or encumbered in title, or
otherwise howsoever.
IN WITNESS WHEREOF, the said Executor of the Estate of Dorothy M. Laughlin, deceased,
rantor herein, has hereunto set his hand and seal the day and year first above written.
igned, Sealed and Delivered
n the Presence of .
F/
C
Lee H. Laughlin
Executor of the Estate of Dorothy M. Laughlin
THIS IS A CONVEYANCE FROM DECEASED PARENT TO CHILDREN AND IS THEREFORE EXEMPT FROM THE
PENNSYLVANIA REAL ESTATE TRANSFER TAX.
WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257 -1397
i
A20I'Meigle, Jerry A \Laughlin, Dorothy M. Estate\Executors Deed mountain land.doc
OMMONWEALTH OF PENN
SS
OUNTY OF
On this, the ` ,,day of , 2013, before me, a Notary Public in and for
aid County and State, the undersigned officer, personally appeared LEE H. LAUGHLIN as the
xecutor of the Estate of Dorothy M. Laughlin, known to me (or satisfactorily proven) to be the person
hose name is subscribed to the within instrument, and acknowledged that he executed the same in the
apacity therein stated and for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal. c'
qN art' Publi
do hereby certify that ompl epos office ddress f the withi ed Grant e is:
ate:
Aehalf of Grantee
WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW -- 126 EAST KING STREET - SHIPPENSBURG, PA 17257 -1397
ROBERT P. ZIEGLER
RECORDER OF DEEDS'
CUMBERLAND COUNTY
Tit ...
1 COURTHOUSE SQUARE
CARLISLE, PA 17013 _
t j D
717 - 240 -6370 _ j .'
Instrument Number - 201312449
Recorded On 4/18/2013 At 11:54:52 AM * Total Pages - 5
• Instrument Type - DEED
Invoice Number - 134544 User ED - SW
• Grantor - LAUGHLIN, DOROTHY M
• Grantee - LAUGHLIN, LEE H
• Customer - WEIGLE & ASSOC
* FEES
STATE WRIT TAX $0.50 Certification Page
STATE JCS /ACCESS TO $23.50
JUSTICE DO NOT DETACH
RECORDING FEES — $12.50
RECORDER OF DEEDS This a e is now art
PARCEL CERTIFICATION $10.00 P g P
FEES of this legal document.
AFFORDABLE HOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
SHIPPENSBURG AREA SCHOOL $0.00
DISTRICT
HOPEWELL TOWNSHIP $0.00
TOTAL PAID $63.00
I Certify this to be recorded
in Cumberland County PA
C0 cu�e�
RECORDER O
* - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
0039DR
III II I II I IIIII I 1 111111 III
F L
003SS0
Tax LD.: 11- 07- 0495 -002
f `✓ 7'v
THIS DEED
2
MADE THIS day o in the year of our Lord two thousand and thirteen
(2013).
BETWEEN JANICE 11f CHAMBERLIN, married woman, of 75 Dead End Lane,
Shippensburg, Pennsylvania 17257, hereinafter referred to as Grantor
AND LEE H. LAUGHLIN, married man, of 41 Turnpike Road, Newburg,
Pennsylvania 17240 hereinafter referred to as Grantees
WITNESSETH, that for and in consideration of the sum of SIX THOUSAND TWO
HUNDRED DOLLARS ($6,200.00), in hand paid, the receipt whereof is hereby acknowledged,
the. said Grantor do hereby grant and convey, in fee simple to the said Grantee, his heirs and
assigns,
ALL that certain tract of land lying and being in Hopewell Township, Cumberland County and
Commonwealth of Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a chestnut tree; thence by lands now or formerly of William Keeseman's heirs
North thirty-three and one -half (33 %2) degrees West twenty -eight and six tenths (28.6) perches to
a hickory thence North thirteen and one -half (13 %2) degrees East fourteen and five tenths (14.5)
perches to a post; thence South seventy -three and one -half (73 %2) degrees East fifty -four (54)
perches to a hickory; thence by land now or formerly of A. C. Book South sixty and one -half (60
%2) degrees West forty-five (45) perches to the place of BEGINNING. CONTAINING six (6)
acres and sixty -eight (68) perches, neat measure.
BEING the same premises which Mary E. Laughlin, Executrix of the Estate of Arthur H.
Laughlin, Hughie D. Laughlin and Dorothy M. Laughlin, his wife, Richard H. Laughlin and
Rachel M. Laughlin, his wife, and Lee H. Laughlin and Jeanette A. Laughlin, his wife, by their
deed dated November 1, 1977, and recorded in Cumberland County, Pennsylvania, at Deed Book
"N," Volume 27, at Page 593, conveyed to Hughie D. Laughlin, Richard H. Laughlin, Lee H.
Laughlin, Daniel G. Laughlin, and Janice M. Chamberlin, thereby vesting in Janice M.
Chamberlin, an undivided one -fifth (115) interest in the above described premises.
ALSO BEING the same real estate that Lee H. Laughlin, as Executor of the Estate of Dorothy M.
Laughlin, by his deed dated March 26, 2013, and recorded April 18, 2013, and recorded in the
Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, at Instrument
Number 201312449, granted and conveyed the estate's one -fifth (115) interest to Lee H. Laughlin,
finis is a Lag exempt - : EXHIBIT fide brother.
a
WEIGLE & ASSOCIATES, P.C. - ATTOR G STREET - SHIPPENSBURG, PA 17257 -1397
Daniel G. Laughlin, and Janice M. Chamberlin thereby vesting in Janice M. Chamberlin an
undivided one - fifteenth (1115) interest in the above described real estate.
The purpose of this deed is to convey Janice M. Chamberlin's undivided four - fifteenths interest to
Lee H. Lau hlin.
UNDER AND SUBJECT to existing covenants, agreements, conditions, easements, restrictions
and rights of record to the extent valid and enforceable and still applicable to the above - described
premises.
And the said Grantor hereby covenants and agrees that she will warrant specially the
property hereby conveyed.
IN WITNESS WHEREOF, Grantor has hereunto set her hand and seal the day and year
first above written.
Signed, Sealed and Delivered
in the Presence of c�
C
111 J M. Chamberlin
Wilbur C. Chamberlin, spouse of Janice M. Chamberlin, executed this Deed to release any right,
title or interest that he may ha a in the Bove described real estate by virtue of his marriage.
g c
Wilbur C. C Berlin
WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257 -1397
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ��`�` SS
On this, theq day of 2013, before me, a Notary Public in and
for said County and State, the un signe fficer, personally appeared Janice M. Chamberlin,
known to me (or satisfactorily proven) to be the person whose name is subscribed to the within
instrument, and acknowledged that she executed the same for the purposes herein contained
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
0 i
N P �blic
COMMO NWEALTH OF PENNSYLVANI
NOTARIAL SEAL
Jerry A. Weigle, Notary Public
City of Shippensburg, Cumberland County
My Commission Expires October 7, 2014
COMMONWEALTH OF PENNSYLVANIA
: SS
COUNTY OF 6 this, the 1: day of 2013, before me, a Notary Public in and
for said County and State, the un signed cer, personally appeared Wilbur C. Chamberlin,
known to me (or satisfactorily proven) to be the person whose name is subscribed to the within
instrument, and acknowledged that he executed the same for the purposes herein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal. }
( //� /` era S �� }',„ � , ��, •.
i I•'
Notary ublic
COMMONWEALTH OF P NNSYLVA
NOTARIAL.SEAL
Jerry A. Weigle, Notary Publio
city of Shippensburg, Cumberland Coun
My Commission Expires October 7, 2014
I do hereby certify that the complete ost office address of the thin named Grantee is
�/ � r
Date: o�Cv
Attorn y for Grantee
Y
WEIGLE & ASSOCIATES, P.C. — ATTORNEYS AT LAW — 126 EAST KING STREET — SHIPPENSBURG, PA 17257-1397
ROBERT P. ZIEGLER
RECORDER OF DEEDS ��
:.
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717- 240 -6370
Instrument Number - 201332148
Recorded On 9/30/2013 At 11:34:56 AM * Total Pages - 4
• Instrument Type - DEED
Invoice Number - 148211 User ID - SW
• Grantor - CHAMBERLIN, JANICE M
• Grantee - LAUGHLIN, LEE H
• Customer - SOUTH CENTRAL HOME SETTLEMENTS
* FEES
STATE WRIT TAX $0.50 Certification Page
STATE JCS /ACCESS TO $23.50
JUSTICE DO NOT DETACH
RECORDING FEES — $11.50
RECORDER OF DEEDS
PARCEL CERTIFICATION $15.00 This page is now part
FEES of this legal document.
AFFORDABLE HOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
SHIPPENSBURG AREA SCHOOL $0.00
DISTRICT
HOPEWELL TOWNSHIP $0.00
TOTAL PAID $67.00
I Certify this to be recorded
in Cumberland County PA
o f Cluj
0r 9� / x IPA
RECORDER O D EDS
t�so
* - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
003SSO
III IIIIIIIIIIIIIIIIIIIIIII
FILE
003881
Tax I.D.: 11-07 -0495 -002
T HIs DEED
MADE TH1iS day of in the year of our Lord two thousand and thirteen
(2013).
BETWEEN DAIVI.EL G. LAUGHLLJIV, married man, of 14 Laughlin. Lane, Newburg,
Pennsylvania 17240, hereinafter referred to as Grantor
AND LEE H. LAUGHLIN, married man, of 41 Turnpike Road, Newburg,
Pennsylvania 17240, hereinafter referred to as Grantees
wnwESSETH, that for and in consideration of the sum of SIX THOUSAND TTV0
HUNDRED DO LLARS ($6,700.00), in hand paid, the receipt whereof is hereby acknowledged,
the said Grantor do hereby grant and convey, in fee simple to the said Grantees, his heirs and
assigns,
ALL that certain tract of land lying and being in Hopewell Township, Cumberland County and
Commonwealth of Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a chestnut tree; thence by lauds now or formerly of William Keeseman's heirs
North thirty -three and one -half (33 %2) degrees West twenty -eight and six tenths (28.6) perches to
a hickory; thence North thirteen and one -half (13 Y2) degrees East fourteen and five tenths (145)
perches to a post; thence South seventy -three and one -half (73 'h) degrees East fifly-four (54)
perches to a hickory; thence by land now or formerly of A. C. Book South sixty and one -half (60
%2) degrees West forty five (45) perches to the place of BEGINNING. CONTAR4ING six (6)
acres and sixty -eight (68) perches, neat measure.
BEING the same premises which Mary E. La ughren, Executrix of the Estate of Arthur H.
Laughlin, Hughie D. La ughlin and Dorothy M. Laughlin, his wife, Richard H. Laughlin and
Rachel M. Laughlin, his wife, and Lee H. Laughlin and Jeanette A. La ughlin, his wife, by their
deed dated November 1, 1977, and recorded in Cumberland County, Pennsylvania, at Deed Book
"N," Volume 27, at Page 593, conveyed to Hughie D. La ughlin, Richard H. Laughlin, Lee H.
La nghlin, Daniel G. Laughlin, and Janice M. Chamberlin, thereby vesting in Daniel G. Laughlin,
an undivided one -fifth (1 /5) interest in the above described premises.
ALSO BEING the same real estate that Lee H. La ughlin, as Executor of the Estate of Dorothy M.
La ughlin, by his deed dated March 26, 2013, and recorded April 18, 2013, and recorded in the
Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, at Instrument
Number 201312449, gran ted and conveyed the estate's one -fifth (115) interest to Lee H. La ughlin,
This is a tax exempt EXHIBIT r to brother.
i
D"_
WEIGLE & ASSOCIATES, P.C. - ATTORNE STREET - SHIPPENSBURG. PA 17257 -1397
Daniel G. Laughlin, and Janice M. Chamberlin thereby vesting in Daniel G. Laughlin an
undivided one - fifteenth (1115) interest in the above described real estate.
The purpose of this deed is to convey Daniel G. Laughlin's undivided four - fifteenths interest to
Lee H. Laughlin.
UDDER AND SUBJECT to existing covenants, agreements, conditions, easements, restrictions
and rights of record to the extent valid and' enforceable and still applicable to the above - described
premises.
And the said Grantor hereby covenants and agrees that he will warrant specially the
property hereby conveyed.
IN WITNESS WHEREOF, Grantor has hereunto set his hand and seal the day and year
first above written.
Signed, Sealed and Delivered
in the Presence of
ZIA4 t!
�-f
Daniel G. Laughlin
Barbara M. Laughlin, spouse of Daniel G. Laughlin, executed this Deed to release any right, title
or interest that she may have in the above described real estate by virtue of her marriage.
fA
\. Barbara M. Laughlin
WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257 -1397
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF
On this, th of 2013, before me, a Notary Public in and
for said County and State, the 4(dersigied officer, personally appeared Daniel G. Lau ghlin
known to me (or satisfactorily proven) to be the person whose name is subs. m - bed to the within
instrument, and acknowledged that he executed the same for the purposes herein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
I r
otary P blic
COMMONWEALTH OF PENNSYL NIA
NOTARIAL SEAL
Jerry A. Weigle, Notary Public
City of Shippensburg, Cumberland County
My Commission Expires October 7, 2014
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF
On this, th¢ lo day of 2013, before me, a I Totary Public in and
for said County and State, the und officer, personally appeared Barbara A La ughlin,
known to me (or satisfactorily proven) to be the person whose name is subscribed to the within
in rmnent, and acknowledged that she executed the same for the purposes herein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seaL
r
( A O I �2u lic
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Jerry A. Weigle, Notary Public
City of Shippensburg, Cumberland County
My Commission Expires October 7, 2014
I do hereby c that the complete post office address of the within named Grantee is
Dater
C A1 7Z � ey for tee
V
WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257 -1397
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY .
1 COURTHOUSE SQUARE
CARLISLE, PA 17013 -
717 - 240 -6370 -
Instrument Number - 201332149
Recorded On 9/30/2013 At 11:34:57 AM *. Total Pages - 4
• Instrument Type - DEED
Invoice Number - 148211 User ID - SW
• Grantor - LAUGHLIN, DANIEL G
• Grantee - LAUGHLIN, LEE H
• Customer - SOUTH CENTRAL HOME SETTLEMENTS
* FEES
STATE WRIT TAX $0.50 Certification Page
STATE JCS /ACCESS TO $23.50
JUSTICE DO NOT DETACH
RECORDING FEES - $11.50
RECORDER OF DEEDS This a e is now art
PARCEL CERTIFICATION $15.00 P g P
FEES of this legal document.
AFFORDABLE HOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
SHIPPENSBURG AREA SCHOOL $0.00
DISTRICT
HOPEWELL TOWNSHIP $0.00
TOTAL PAID. $67.00
I Certify this to be recorded
in Cumberland County PA
o f co mae
°
=EC=DE
1750
* - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
003SS1
III IIIIIIIIIIII III IIIII II III
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L IBIT �.n 7
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson
Sheriff t [ }
2y1' i:.dE 1t#(7d',. . ... C 1 E PRO T HONt{
Jody S Smith
"'�
Chief Deputy 20 I FEB I I PM 3: 15
Richard W Stewart CUMBERLAND COUNTY
Solicitor PENNSYLVANIA
Lee Harold Laughlin
vs. Case Number
Richard H Laughlin 2014-675
SHERIFF'S RETURN OF SERVICE
02/06/2014 02:03 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint&
Notice by"personally" handing a true copy to a person representing themselv-:'to be the Defendant, to
wit: Richard H Laughlin at 15 Laughlin Lane, Newburg, PA 17240.
Arrdigea
UTSHALL, DEPUTY
SHERIFF COST: $51.09 SO ANSWERS,
February 07, 2014 RONNY ANDERSON, SHERIFF