HomeMy WebLinkAbout01-5017IN RE: :
CONDEMNATION BY THE :
REDEVELOPMENT AUTHORITY OF :
THE COUNTY OF CUMBERLAND :
OF THE PREMISES KNOWN AND :
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA
EMMA C. WENTZEL and
FRANK TOTH,
Plaintiffs
REDEVELOPMENT AUTHORITY OF
THE COUNTY OF CUMBERLAND,
Defendant
AND NOW, this ..L~_~i~ay of July,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5017 CIVIL TERM
· EMINENT DOMAIN PROCEEDINGS
ORDER
2002, on consideration of a Petition of the
Redevelopment Authority of the County of Cumberland for Writ of Possession and the
Petition to Make Rule Absolute, it is hereby ordered that the Rule is made absolute and
that a Writ of Possession shall issue for the property located at 68 East King Street,
Shippensburg, Cumberland County Pennsylvania, against Emma C. Wentzel and Frank
Toth, Condemnees.
By the Court,
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA, BEING THE
PROPERTY OF EMMA W. TOTH,
a/k/a EMMA C. WENTZEL, and
FRANK TOTH,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-~ CIVIL TERM
EMINENT DOMAIN PROCEEDING
DECLARATION O~__FF TAK__IING_
Pursuant to the authority granted to it at 35 P.S. 1712.1 of the Urban Redevelopment Law
and 26 P.S. 1-101, et seq., the Eminent Domain Code, the Redevelopment Authority of the
County of Cumberland hereby declares:
1
The Condemnor is the Redevelopment Authority of the County of Cumberland, with its
principal place of business being located at 114 North Hanover Street, Carlisle,
Cumberland County, Pennsylvania.
2
Pursuant to 35 P.S. 1712. l(a), Condemnor has the power to acquire by eminent domain
any property properly certified to Condemnor as a blighted property.
3
The Cumberland County Vacant Property Reinvestment Board (hereinafter the "BOard")
by Resolution dated June 8, 2000, certified the premises hereinafter described (hereinafter
the "Premises ) to Condemnor as a blighted property.
4
On July 20, 2000, the Cumberland County Planning Commission did certify the Premises
as a blighted property to Condemnor and did submit a recommendation to Condemnor as
to the appropriate reuse of the Premises.
5
On July 12, 2000, the Borough of Shippensburg Planning Commission did certify the
Premises as a blighted property to Condemnor and did submit a recommendation as to the
appropriate reuse of the Premises.
6
The appropriate reuse of the Premises, as recommended by the aforesaid Planning
Commissions, for residential re-use, is not inconsistent with the Comprehensive Plan of the
County of Cumberland nor the Borough of Shippensburg.
7
The purpose of the COndemnation is to acquire a blighted property that has been certified
as a blighted property in accordance with the provisions of 35 P.S. 1712.1, as amended,
and to dispose of said property in accordance with the recommendations of the aforesaid
Planning Commissions.
8
The interest in the property hereinafter described is hereby condemned in fee simple or
absolute title by the Condemnor pursuant to the Urban Redevelopment Law at 35 P.S.
1712.1, as authorized by Resolution adopted by the Condemnor on the 8th day of June,
2001. A copy of the Resolution is attached as Exhibit "A." The original Resolution may be
examined at the offices of the Condemnor at the above address.
9
A description of the Premises condemned sufficient for its identification
attached Exhibit "B." is set forth in the
10
On the same day as this Declaration of Taking is being filed with the Prothonotary, a Notice
of Filing of Declaration of Taking is being filed in the Office of the Recorder of Deeds in and
for Cumberland County, Pennsylvania, in accordance with Section 404 of the Eminent
Domain Code, 26 P.S. 1-404.
11
The nature of the title acquired in and to the property is a fee simple or absolute title.
12
The Condemnor files with this Declaration of Taking an open-end bond without surety
pursuant to Section 403(a) of the Eminent Domain Code, 26 P.S. 1-403(a). Just
compensation is made or secured by the filing of the bond. A copy of the bond is attached
as Exhibit "C."
ATTEST:
Secretary '~ --
REDEVELOPMENT AUTHORITy OF
THE COUNTY OF CUMBERLAND
~Esquire
Redevelopment Authority of the
County of Cumberland
114 North Hanover Street
Carlisle, PA 17013
717-249-0789
A:\68DecTkg.wpd
I verify that the statements in the foregoing pleading are true and correct. I understand that
false statements herein are made subject to the penalties of 18 PaCS 4904 relating to
unswom falsification to authorities.
REDEVELOPMENT AUTHORITY OF
THE COUNTY OF CUMBF-?RLAND
Chris opher Gulo'tta- , ~'; '
Executive Director
RESOLUTION AUTHORIZING THE FILING OF A
DECLARATION OF TAKING AND ALL NECESSARY ACTION
FOR THE ACQUISITION THEREOF OF THE
PREMISES LOCATED AT
68 EAST KING STREET
SHIPPENSBURG, CUMBERLAND COUNTY, PA
WHEREAS, Ordinance No, 99~ 1 of the County of Cumberland created and empowered
~umberland ~~unty Vacant Pr~perty Re~nvestment ~~ard (here~nafter the ``B~ard~~) t~ tahcet
with regard to blighted properties, as that term
Redevelopment Law; and is defined in the Ordinance and the Urban
WHEREAS, the Board had reviewed COnditions existing at 68 East King Street,
Sh/PPensburg, Cumberland County, Pennsylvania, (hereinafter the "Premises',); and
WHEREAS, the Board had determined that the Premises was vacant and exhibited one
or more of the COnditions of a blighted property as set forth in Ordinance No. 99-1; and
WHEREAS, the Board adopted a Blight
that the Premises is blighted; and Determination Resolution No. 2000-6 determining
WHEREAS, the property owner of the Premises, Emma W. Toth, a/k/a Emma C. Wentzel
and Frank Toth (hereinafter the "Owners"), had been served with the
Resolution No. 2000-6 and notified of their right to appeal the determination or provide a
rehabilitation plan; and Blight Determination
WHEREAS, the Owner did not file an appeal nor did they file a rehabilitation p/an; and
WHEREAS, the BOard adopted a Second Resolution No. 2000-9 certifying the Premises
to the Redevelopment Authority of the County of Cumberland as blighted; and
WHEREAS, in accordance with the provisions of the Urban Redevelopment Law and the
Rules and Regulations of the Board,
Planning Commission a report on the Premises was transmitted to the
of the County of Cumberland and the Planing Commission of the
Borough of Shippensburg for tho ·
whether the property was b inh ,~s~e...c~o. mmls, slons to make their own determ nation as to
re-use of the Premises; and = t...,., ~,~u [o supra t a recommendation as to the appropriate
WHEREAS, on July 20, 2000, the Cumberland County Planning Commission determined
that the Premises is blighted and recommended with the re-use plan be to use the
Premises for residential purposes; and
WHEREAS, the Borough of Shippensburg Planning Commission determined on July 12,
2000, that the Premises is a blighted property and did concur With the recommended re-
use of the Premises, as aforesaid; and
EXHIBIT "A"
WHEREAS, the Redevelopment Authority had previously attempted to negotiate the
acquisition of the Premises in lieu of COndemnation without success; and
WHEREAS, in accordance with the Urban Redevelopment L
Redevelopment Authority is authorized aw as nd
domain proceedinns to acquire title to th ~ .... L' ._ame ed, the
= · e --~,.;~es through eminent
NOW, THEREFORE, BE IT RESOLVED that the Redevelopment Authority of the County
of Cumberland, in accordance with authority conferred by/aw, accepts
the Premises located at 68 East King Street, ShiPpensburg,the certification of
Pennsylvania, as a blighted property and does further select Cumberland County,
acquisition and disposition in accordance with law the Premises, which are more fully
described: and apPropriate for
ALL THAT CERTAIN lot of ground with two-story stone dwelling house
two-car garage thereon
at the Southwest corner of King and Penn Streets, Borough a~
erected, known as No, 68 East King Street, situate
Shippensburg, Cumberland County, Pennsylvania, bounded and described
as follows: On the North by King Street; on the East by Penn Street; on the
South by improved lot formerly of Margaret S. Berry, now or formerly of
Glenn Etter, formerly a part of this lot; and on the West by improved lot
formerly of John Hosfeld Estate. no
extendin nfro ~,.,.~,... _,-..' worformerlyofG Le -
g nt'~,'..~r,,ng~[reetfromthePennStree~ncuarrb~oOrtgye_lSo~nega~r~
one-half (41-1/2) feet to the line of the said G. Leonard Fogelsonger
property, and extending from the King Street curb Southwardly one hundred
eleven (111) feet to the line which is now the Southerly side of the concrete
garage wall on these premises, along which Southerly line this line abuts to
a width of forty-two (42) feet.
RESOLVED that the title to be acquired shall be absolute or fee simple title, inClUding all
easements, dghts of way, and real property interests of whatsoever nature.
RESOLVED that counsel for the Redevelopment Authority and its proper officers are
hereby authorized to file a Declaration of Taking and Such other proceedings, inCluding
the entry of Such bond as may be necessary or desirable, to carry out the purpose of this
resolution.
RESOLVED that the institution of Such proceedings, and any damages which may be
agreed upon or awarded to any party in interest shall be Paid out of the funds of the
Redevelopment Authority.
ATTEST
Date:~¢~_L_.
A:\68EKing Resol.wpd
EXHIBIT "B"
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of ground with two-story stone dwelling house and two-car garage
thereon erected, known as No. 68 East King Street, situate at the Southwest corner of King
and Penn Streets, Borough of Shippensburg, Cumberland County, Pennsylvania, bounded
and described as follows: On the North by King Street; on the East by Penn Street; on the
South by improved lot formerly of Margaret S. Berry, now or formerly of Glenn Etter,
formerly a part of this lot; and on the West by improved lot formerly of John Hosfeld Estate,
now or formerly of G. Leonard Foge/songer; extending in front along King Street from the
Penn Street curb, forty-one and one-half (41-1/2) feet to the line of the said G. Leonard
Foge/songer property, and extending from the King Street curb Southwardly one hundred
eleven (111) feet to the line which is now the Southerly side of the concrete garage wall
on these premises, along which Southerly line this line abuts to a width of forty-two ('42)
feet.
EXHIBIT "C"
B___ONq
KNOW ALL MEN BY THESE PRESENTS, that a De
the ~.~:~ay of_.~ ~,~ rd-- ,~,,^ .... claration of Taking havino been ¢~,~,~
of Cumberland (the "Ob'l~gOr"~'bo~',,'cUo~'or~aYt me R. ede...velopmen, Authority o~'the Co~;
~ p Le ano politic and existing under the laws of
the Commonwealth of Pennsylvania, being held and firmly bound unto the Commonwealth
of Pennsylvania (the "Obligee") for the use and benefit of the owner or owners of the
property condemned as hereinafter noted, and other proper parties in interest, for such
amount of damage as the owner or owners of the property and other parties in interest
shall be entitled to receive after the same shall have been agreed upon or assessed in the
manner prescribed by law, by the reason of the condemnation by Obligor of certain land
improvements located in the Borough of Shippensburg, Cumberland County, and
described as follows:
ALL THAT CERTAIN lot of ground with two-story stone dwelling house and
two-car garage thereon erected, known as No. 68 East King Street, situate
at the Southwest corner of King and Penn Streets, Borough of
Shippensburg, Cumberland County, Pennsylvania, bounded and described
as follows: On the North by King Street; on the East by Penn Street; on the
South by improved lot formerly of Margaret S. Berry, now or formerly of
Glenn Etter, formerly a part of this lot; and on the West by improved lot
formerly of John Hosfeld Estate, now or formerly of G. Leonard Fogelsonger;
extending in front along King Street from the Penn Street curb, forty-one and
one-half ('41-1/2) feet to the line of the said G. Leonard Fogelsonger
property, and extending from the King Street curb Southwardly one hundred
eleven (111) feet to the line which is now the Southerly side of the concrete
garage wall on these premises, along which Southerly line this line abuts to
a width of forty-two (42) feet.
BEING the premises of Emma W. Toth, a/Ida Emma C. Wentzel, and Frank
Toth, to which payment well and truly to be made, the Obligor does bind itself
and its successors and assigns, firmly by these presents.
WHEREAS, the Obligor has COndemned said property and it cannot agree with the owner
or owners of said land and buildings upon the just compensation to be paid for the
damages sustained by said owner or owners as a result of the condemnation:
NOW THE CONDITION of this bond is such that if the Obligor shall pay or cause to be paid
such amount of damages as the said owner or owners of the property and other parties in
interest shall be entitled to receive by reason of such condemnation, after the same shall
have been agreed upon or assessed in the manner provided by law, then this obligation
shall be void; otherwise, to be and remain in full force and effect.
SEALED with the corporate seal and duly executed this .~'¢%day of_ I/'~t4,.~ V~'"'
2001.
ATTEST
Secretary
REDEVELOPMENT AUTHORITY OF
THE COUNTY OF CUMBERLAND
' J' mJeC George
Chairman
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA, BEING THE
PROPERTY OF EMMA W. TOTH,
a/Ida EMMA C. WENTZEL, and
FRANK TOTH
· IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 01- ~"~[ 9h CIVIL TERM
: EMINENT DOMAIN PROCEEDING
MEMORANDUM OF FILING OF NOTICE
TO THEPROTHONOTARY:
Notice of the above-captioned condemnation is recorded in the Office of the Recorder of
Deeds in and for Cumberland County, Pennsylvania, in Miscellaneous Book (~ g O, Page
2.q~'~, , having been filed of record on the 2.~d~ay of Y~ u~'~/~ ,2001.
~~5'n,~Esquire
Attorney for Condemnor
Redevelopment Authority of
the County of Cumberland
114 North Hanover Street
Carlisle, PA 17013
717-249-0789
Date:
A:'~68Memo.wpd
IN RE:
CONDEMNATION BY THE :
REDEVELOPMENT AUTHORITY :
OF THE COUNTY OF CUMBERLAND :
OF THE PREMISES KNOWN AND :
NUMBERED AS 68 EAST KING :
STREET, SHIPPENSBURG, :
CUMBERLAND COUNTY, :
PENNSYLVANIA, BEING THE :
PROPERTY OF EMMA W. TOTH, :
a/k/a EMMA C. WENTZEL, and :
FRANK TOTH
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01- _~'OI ~, CIVIL TERM
EMINENT DOMAIN PROCEEDING
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
: SS
COUNTY OF CUMBERLAND :
Christopher C. Houston, being duly sworn according to law, deposes and says that he
served a Notice of Condemnation, a trup. and correct copy which is attached hereto, by
certified mail to Frank Toth, on the ~),~3~,~lay of ~ u~ 4 ~J ,-)L ,2001, as evidenced
by the attached return receipt. ' ' -/
Christopher C. Houston, Esquire
Attorney for Condemnor
Redevelopment Authority of
the County of Cumberland
114 North Hanover Street
Carlisle, PA 17013
717-249-0789
Sworn and subscri, j;).e,d to
befor~ me, this/'(~ day
of ~~.~, 2001.
I~tary Public
A:~68AffSer-,wpd
· Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
· . Pdnt your name and address on the reverse
so that we can return the card to you.
· Attach this card to the back of the mailpieca,
or on the front if space permits.
1. A~ic~ Addmssecl to:
ONE EAST BUILD ST
.SHIPPENSBURG PA 17257
A. Received by (P~ase Print C~arly) B. Date of Delivery
C.
, address different fromitem 17 i-I Yes
enter delivery address below: ][][No
3. S,rvice Type ;.
· I~ C~med Mail [] Express Mail
i--~ Rf~gistemd [] Return Receipt for Merchandise
r'l Ir~Jre~i Mail [] C.O.D.
4. Restdcted Daiivery? (Ex~a Fee) }~ Yes
2. A~i¢le Number (Copy from service ~be~) 7099 3220 0009 5575 0759
PS Form 3811, July 1999 Dom~--tic R~um Receipt ~02595-00-M-0952
DIRECTOR OF REAL ESTATE DEVELOPMENT
REDEVELOPMENT AUTM.ORITY OF
Cb'M~ELAND COUNT~ '_:
114 N HANOVER ST
CARLISLE PA 17013
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA, BEING THE
PROPERTY OF EMMA W. TOTH,
a/k/a EMMA C. WENTZEL, and
FRANK TOTH
IN THE COURT Of COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01- -%~'O~'~- CIVIL TERM
EMINENT DOMAIN PROCEEDING
:
NOTICE OF CONDEMNATION
In accordance with Section 405 of the eminent Domain Code of 1964, 26 P.S. 1-405, the
Redevelopment Authority of the County of Cumberland notifies you that:
A Declaration of Taking, a copy of which is attached as Exhibit "A," was filed on the
2, ~}~'day of ~c~j~ , 2001, in the Court of Common Pleas of
Cumberland County~ at the above-named term and number.
Your property has been condemned by the Redevelopment Authority of the county
of Cumberland pursuant to the provisions of 35 P.S. 1712.1 for blighted property
removal. Identification of your property appears on Exhibit "B" on the Declaration
of Taking.
If you wish to challenge the power or right of the Redevelopment Authority of the
County of Cumberland to appropriate the condemned property, the sufficiency of
the security, the procedure followed by the Condemnor, or the Declaration of
Taking, you are required to file Preliminary Objections within thirty (30) days after
being served with this notice.
-- Chr~n, Esquire
Attorney for Condemnor
Redevelopment Authority of
the County of Cumberland
114 North Hanover Street
Carlisle, PA 17013
717-249-0789
A:\68NotCon.wpd
IN RE~
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY
Of THE COUNTY OF CUMBERLAND :
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA, BEING THE
PROPERTY OF EMMA W. TOTH,
a/k/a EMMA C. WENTZEL, and :
FRANK TOTH, :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01- ?j~)i 7 CIVIL TERM
EMINENT DOMAIN PROCEEDING
DECLARATION OF TAKING
Pursuant to the authority granted to it at 35 P.S. 1712.1 of the Urban Redevelopment Law
and 26 P.S. 1-101, et seq., the Eminent Domain Code, the Redevelopment Authority of the
County of Cumberland hereby declares:
1
The Condemnor is the Redevelopment Authority of the County of Cumberland, with its
principal place of business being located at 114 North Hanover Street, Carlisle,
Cumberland County, Pennsylvania.
2
Pursuant to 35 P.S. 1712.1(a), Condemnor has the power to acquire by eminent domain
any property properly certified to Condemnor as a blighted property.
3
The Cumberland County Vacant Property Reinvestment Board (hereinafter the "Board")
by Resolution dated June 8.2000, certified the premises hereinafter described (hereinafter
the "Premises") to Condemnor as a blighted property.
4
On July 20, 2000, the Cumberland County Planning Commission did certify the Premises
as a blighted property to Condemnor and did submit a recommendation to Condemnor as
to the appropriate reuse of the Premises.
5
On July 12, 2000, the Borough of Shippensburg Planning Commission did certify the
Premises as a blighted property to Condemnor and did submit a recommendation as to the
appropriate reuse of the Premises.
6
The appropriate reuse of the Premises, as recommended by the aforesaid Planning
Commissions, for residential re-use, is not inconsistent with the Comprehensive Plan of the
County of Cumberland nor the Borough of Shippensburg.
7
The purpose of the condemnation is to acquire a blighted property that has been certified
as a blighted property in accordance with the provisions of 35 P.S. 1712.1, as amended,
and to dispose of said property in accordance with the recommendations of the aforesaid
Planning Commissions.
8
The interest in the property hereinafter described is hereby condemned in fee simple or
absolute title by the Condemnor pursuant to the Urban Redevelopment Law at 35 P.S.
1712.1, as authorized by Resolution adopted by the Condemnor on the 8~h day of June,
2001. A copy of the Resolution is attached as Exhibit "A." The original Resolution may be
examined at the offices of the Condemnor at the above address.
9
A description of the Premises condemned sufficient for its identification is set forth in the
attached Exhibit "B."
10
On the same day as this Declaration of Taking is being filed with the Prothonotary, a Notice
of Filing of Declaration of Taking is being filed in the Office of the Recorder of Deeds in and
for Cumbedan(~ County, Pennsylvania, in accordance with Section 404 of the Eminent
Domain Code, 26 P.S. 1-404.
11
The nature of the title acquired in and to the property is a fee simple or absolute title.
12
The Condemner files with this Declaration of Taking an open-end bond without surety
pursuant to Section 403(a) of the Eminent Domain Code, 26 P.S. 1-403(a). Just
compensation is made or secured by the filing of the bond. A copy of the bond is attached
as Exhibit "C."
ATTEST:
Secretary
REDEVELOPMENT AUTHORITY OF
THE COUNTY OF CUMBERLAND
×?~Jimmie C. George Chairman
Christopher O. Houston, Esquire
Attorney for Condemnor
Redevelopment Authority of the
County of Cumberland
114 North Hanover Street
Carlisle, PA 17013
717-249-0789
A:\68DecTkg.wpd
I verify that the statements in the foregoing pleading are true and correct. I understand that
false statements herein are made subject to the penalties of 18 PaCS 4904 relating to
unsworn falsification to authorities.
REDEVELOPMENT AUTHORITY OF
THE COUNTYOFCUMBERLAND
Christopher Gulotta
Executive Director
RESOLUTION AUTHORIZING THE FILING OF A
DECLARATION OF TAKING AND ALL NECESSARY ACTION
FOR THE ACQUISITION THEREOF OF THE
PREMISES LOCATED AT
68 EAST KING STREET
SHIPPENSBURG, CUMBERLAND COUNTY, PA
WHEREAS. Ordinance No. 99-1 of the County of Cumberland created and empowered the
Cumberland County Vacant Property Reinvestment Board (hereinafter the "Board") to act
with regard to blighted properties, as that term is defined in the Ordinance and the Urban
Redevelopment Law; and
WHEREAS. the Board had reviewed conditions existing at 88 East King Street,
Shippensburg. Cumberland County, Pennsylvania, (hereinafter th_e "Premises"); and
WHEREAS, the Board had determined that the Premises was vacant and exhibited one
or more of the conditions of a blighted property as set forth in Ordinance No. 99-1; and
WHEREAS. the Board adopted a Blight Determination Resolution No. 2000-6 determining
that the Premises is blighted: and
WHEREAS. the property owner of the Premises, Emma W. Toth. a/k/a Emma C. Wentzel
and Frank Toth (hereinafter the "Owners"), had been served with the Blight Determination
Resolution No. 2000-6 and notified of their right to appeal the determination or provide a
rehabilitation plan; and
WHEREAS, the Owner did not file an appeal nor did they file a rehabilitation plan; and
WHEREAS, the Board adopted a Second Resolution No. 2000-9 certifying the Premises
to the Redevelopment Authority of the County of Cumberland as blighted; and
WHEREAS. in accordance with the provisions of the Urban Redevelopment Law and the
Rules and Regulations of the Board, a report on the Premises was transmitted to the
Planning Commission of the County of Cumberland and the Planing Commission of the
Borough of Shippensburg for those commissions to make their own determination as to
whether the property was blighted and to submit a recommendation as to the appropriate
re-use of the Premises; and
WHEREAS, on July 20, 2000. the Cumberland County Planning Commission determined
that the Premises is blighted and recommended with the re-use plan be to use the
Premises for residential purposes; and
WHEREAS, the 8orough of Shippensburg Planning Commission determined on July 12,
2000. that the Premises is a blighted property and did concur with the recommended re-
use of the Premises. as aforesaid; and
EXHIBIT "A"
WHEREAS, the Redevelopment Authority had previously attempted to negotiate the
acquisition of the Premises in lieu of condemnation without success: and
WHEREAS, in accordance with the Urban Redevelopment Law. as amended, the
Redevelopmem Authority is authorized to acquire title to the Premises through eminent
domain proceedings.
NOW, THEREFORE, BE IT RESOLVED that the Redevelopment Authority of the County
of Cumberland in accordance with authority conferred by law, accepts the certification of
the Premises located at 88 East King Street, Shippensburg, Cumberland County,
Pennsylvania. as a blighted property and does further select and appropriate for
acquisition and dispositio¢, in accordance with law the Premises. which are more fully
described:
ALL THAT CERTAIN lot of ground with two-story stone dwelling house and
two-car garage thereon erected, known as No. 68 East King Street, situate
at the Southwest corner of King and Penn Streets. Borough of
Shippenscurg, Cumberland County, Pennsylvania, bounded and described
as follows On the North by King Street; on the East by Penn Street; on the
South by reproved lot formerly of Margaret S. Berry, now or formerly of
Glenn Et:er formerly a part of this lot: and on the West by improved lot
formerly c' John Hosfeld Estate, now or formerly of G. Leonard Fogelsonger;
extendin~c n front along King Street from the Penn Street curb. forty-one and
one-half 41-1/2) feet to the line of the said G. Leonard Fogelsonger
property, and extending from the King Street curb Southwardly one hundred
eleven (111 ) feet to the line which is now the Southerly side of the concrete
garage wa on these premises, along which Southerly line this tine abuts to
a width of %rty-two (42) feet.
RESOLVED that me title to be acquired shall be absolute or fee simple title, including all
easements, rights of way, and real property interests of whatsoever nature.
RESOLVED that counsel for the Redevelopment Authority and its proper officers are
hereby authorized to file a Declaration of Taking and such other proceedings, including
the entry of such =ond as may be necessary or desirable, to carry out the purpose of this
resolution.
RESOLVED that :ne institution of such proceedings, and any damages which may be
agreed upon or -2,varded to any party in interest shall be paid out of the funds of the
Redevelopment A;thority.
ATTEST
Sesretary
EXHIBIT "B"
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of ground with two-story stone dwelling house and two-car ga_rage
thereon erected, known as No. 68 East King Street, situate at {h~ SoL~thwest corner of King
and Penn Streets, Borough of Shippensburg, Cumberland County, Pennsylvania, bounded
and described as follows: On the North by King Street; on the East by Penn Street; on the
South by improved lot formerly of Margaret S. Berry, now or f_ormedy of Glenn Etter,
formerly a part of this lot; and on the West by improved lot formedy of John Hosfeld Estate,
now or formedy of G. Leonard Fogelsonger; extending in front along King Street from the
Penn Street curb, forty-one and one-half (41-1/2) feet to the line of the said G. Leonard
Fogelsonger property, and extending from the King Street curb Southwardly one hundred
eleven (111) feet to the line which is now the Southerly side of the concrete garage wall
on these premises, along which Southerly line this line abuts to a width of forty-two (42)
feet.
EXHIBIT "C"
BOND
KNOW ALL MEN BY THESE PRESENTS, that a Declaration of Taking having been filed
the Z.~layof 1~,~,'~ ,2001,bytheRedevelopmentAuthodtyoftheCounty
of Cumberland (the "Ob-l~gor"), a body corporate and politic and existing under t-he laws of
the Commonwealth of Pennsylvania, being held and firmly bound unto the Commonwealth
of Pennsylvania (the "Obligee") for the use and benefit of the owner or owners of the
property condemned as hereinafter noted, and other proper parties in interest, for such
amount of damage as the owner or owners of the property and other parties in interest
shall be entitled to receive after the same shall have been agreed upon or assessed in the
manner prescribed by law, by the reason of the condemnation by Obligor of certain land
improvements located in the Borough of Shippensburg, Cumberland County, and
described as follows:
ALL THAT CERTAIN lot of ground with two-story stone dwelling house and
two-car garage thereon erected, known as No. 68 East King Street, situate
at the Southwest corner of King and Penn Streets, Borough of
Shippensburg, Cumberland County, Pennsylvania, bounded and described
as follows: On the North by King Street; on the East by Penn Street; on the
South by improved lot formerly of Margaret S. Berry, now or formerly of
Glenn Etter, formerly a part of this lot; and on the West by improved lot
formedy of John Hosfeld Estate, now or formedy of G. Leonard Fogelsonger;
extending in front along King Street from the Penn Street curb, forty-one and
one-half (41-1/2) feet to the line of the said G. Leonard Fogelsonger
property, and extending from the King Street curb Southwardly one hundred
eleven (111 ) feet to the line which is now the Southerly side of the concrete
garage wall on these premises, along which Southerly line this line abuts to
a width of forty-two (42) feet.
BEING the premises of Emma W. Toth, a/k/a Emma C. Wentzel, and Frank
Toth, to which payment well and truly to be made, the Obligor does bind itself
and its successors and assigns, firmly by these presents.
WHEREAS, the Obligor has condemned said property and it cannot agree with the owner
or owners of said land and buildings upon the just compensation to be paid for the
damages sustained by said owner or owners as a result of the condemnation:
NOW THE CONDITION of this bond is such that if the Obligor shall pay or cause to be paid
such amount of damages as the said owner or owners of the property and other parties in
interest shall be entitled tO receive by reason of such condemnation, after the same shall
have been agreed upon or assessed in the manner provided by law, then this obligation
shall be void; otherwise, to be and remain in full force and effect.
SEALED with the corporate seal_and_duly executed this }~+~'day of
2001.
ATTEST
Secr~etary ,
REDEVELOPMENT AUTHORITY Of
THE COUNTY OF CUMBERLAND
~J~mmie C. George ~ %/
JChairman
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA, BEING THE
PROPERTY OF EMMA W. TOTH,
a/kJa EMMA C. WENTZEL, and
FRANK TOTH
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 01- ~'OI ~' CIVIL TERM
· EMINENT DOMAIN PROCEEDING
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
· SS
Christopher C. Houston, being duly sworn according to law, deposes and says that he
served a Notice of Condemnation, a true and correct copy which is attached hereto, upon
George F. Douglas, I~., Esquire, on behalf of Emma VV. Toth, a/k/a Emma C. Wentzel and
who executed the attached Acceptance of Service on the .! ~'h'l:lay of ~~_._,
2001.
~:hristoph~r C. Houston, Esquire
Attorney for Condemnor
Redevelopment Authority of
the County of Cumberland
114 North Hanover Street
Carlisle, PA 17013
717-249-0789
Sworn and subscr~d to
before me, this ?~ day
of~;~i~, 2001.
A:~3SAffSer2.w,~d
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA, BEING THE
PROPERTY OF EMMA W. TOTH,
a/k/a EMMA C. WENTZEL, and
FRANK TOTH
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01-5017 CIVIL TERM
:
: EMINENT DOMAIN PROCEEDING
:
ACCEPTANCE OF SERVICE
I accept service of the Declaration of Taking on behalf of Emma C. Wentzel and certify that
I am authorized to do.
Date: C~/
George F'. Douglas, III, Esquire
Douglas, Douglas & Douglas
27 West High Street
Carlisle, PA 17013
IN RE;
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY
Of THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA, BEING THE
PROPERTY OF EMMA W. TOTH,
a/k/a EMMA C. WENTZEL, and
FRANK TOTH
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 01- 5~"O~'~- CIVIL TERM
: EMINENT DOMAIN PROCEEDING
NOTICE OF CONDEMNATION
In accordance with Section 405 of the eminent Domain Code of 1964, 26 P.S. 1-405, the
Redevelopment Authority of the County of Cumberland notifies you that:
A Oe~aration of T~aking, a.copy of which is attached as Exhibit "A," was filed on the
2, ~day of ~;~"7' , 2001, in the Court of Common Pleas of
Cumberland County~ at the above-named term and number.
Your property has been condemned by the Redevelopment Authority of the county
of Cumberland pursuant to the provisions of 35 P.S. 1712.1 for blighted property
removal. Identification of your property appears on Exhibit "B" on the Declaration
of Taking.
If you wish to challenge the power or right of the Redevelopment Authority of the
County of Cumberland to appropriate the condemned property, the sufficiencY of
the security, the procedure followed by the Condemnor, or the Declaration of
Taking, you are required to file Preliminary Objections within thirty (30) days after
being served with this notice.
- CitrOn, Esquire
Attorney for Condemnor
Redevelopment Authority of
the County of Cumberland
114 North Hanover Street
Carlisle, PA 17013
717-249-0789
A:\68NotCon.wpd
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA, BEING THE
PROPERTY OF EMMA W. TOTH,
a/k/a EMMA C. WENTZEL, and
FRANK TOTH,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01- '~')(7 CIVIL TERM
:
· EMINENT DOMAIN PROCEEDING
DECLARATION OF TAKING
Pursuant to the authority granted to it at 35 P.S. 1712.1 of the Urban Redevelopment Law
and 26 P.S. 1-101, et seq., the Eminent Domain Code, the Redevelopment Authority of the
County of Cumberland hereby declares:
1
The Condemnor is the Redevelopment Authority of the County of Cumberland, with its
principal place of business being located at 114 North Hanover Street, Carlisle,
Cumberland County, Pennsylvania.
2
Pursuant to 35 P.S. 1712.1(a), Condemnor has the power to acquire by eminent domain
any property properly certified to Condemnor as a blighted property.
3
The Cumberland County Vacant Property Reinvestment Board (hereinafter the "Board")
by Resolution dated June 8, 2000, certified the premises hereinafter described (hereinafter
the "Premises") to Condemnor as a blighted property.
4
On July 20, 2000, the Cumberland County Planning Commission did certify the Premises
as a blighted property to Condemnor and did submit a recommendation to Condemnor as
to the appropriate reuse of the Premises,
5
On July 12, 2000, the Borough of Shippensburg Planning Commission did certify the
Premises as a blighted property to Condemnor and did submit a recommendation as to the
appropriate reuse of the Premises.
6
The appropriate reuse of the Premises, as recommended by the aforesaid Planning
Commissions, for residential re-use, is not inconsistent with the Comprehensive Plan of the
County of Cumberland nor the Borough of Shippensburg.
7
The purpose of the condemnation is to acquire a blighted property that has been certified
as a blighted property in accordance with the provisions of 35 P.S. 1712.1, as amended,
and to dispose of said property in accordance with the recommendations of the aforesaid
Planning Commissions.
8
The interest in the property hereinafter described is hereby condemned in fee simple or
absolute title by the Conctemnor pursuant to the Urban Redevelopment Law at 35 P.S.
1712.1, as authorized by Resolution adopted by the Condemnor on the 8th day of June,
2001. A copy of the Resolution is attached as Exhibit "A." The original Resolution may be
examined at the offices of the Condemnor at the above address.
9
A description of the Premises condemned sufficient for its identification is set forth in the
attached Exhibit "B."
10
On the same da~ as this Declaration of Taking is being filed with the Prothonotary, a Notice
of Filing of Declaration of TaKing is being filed in the Office of the Recorder of Deeds in and
for Cumberland County; Pennsylvania, in accordance with Section 404 of the Eminent
Domain Code, 26 P.S. 1-404.
11
The nature of the title acquired in and to the property is a fee simple or absolute title.
12
The Condemnor files with this Declaration of Taking an open-end bond without surety
pursuant to Section 403(a) of the Eminent Domain Code, 26 P.S. 1-403(a). Just
compensation is made or secured by the filing of the bond. A copy of the bond is attached
as Exhibit "C."
ATTEST:
Secretary
REDEVELOPMENT AUTHORITY OF
THE COUNTY OF CUMBERLAND
/?'Jimmie C. George
Chairman -'
Christopher O. Houston, Esquire
Attorney for Condemnor
Redevelopment Authority of the
County of Cumberland
114 North Hanover Street
Carlisle, PA 17013
717-249-0789
A:\68DecTkg.wpd
I verify that the statements in the foregoing pleading are true and correct. I understand that
false statements herein are made subject to the penalties of 18 PaCS 4904 relating to
unsworn falsification to authorities.
REDEVELOPMENT AUTHORITY OF
THE COUNTY OF CUMBERLAND
Christopher Gulotta
Executive Director
RESOLUTION AUTHORIZING THE FILING OF A
DECLARATION OF TAKING AND ALL NECESSARY ACTION
FOR THE ACQUISITION THEREOF OF THE
PREMISES LOCATED AT
68 EAST KING STREET
SHIPPENSBURG, CUMBERLAND COUNTY, PA
WHEREAS, Ordnance No. 99-1 of the County of Cumberland created and empowered the
Cumberland County Vacant Property Reinvestment Board (hereinafter the "Board") to act
with regard to blighted properties, as that term is defined in the Ordinance and the Urban
Redevelopment Law; and
WHEREAS. the Board had reviewed conditions existing at 68 East King Street,
Shippensburg. Cumberland County, Pennsylvania, (hereinafter th_e "Premises"); and
WHEREAS, the Board had determined that the Premises was vacant and exhibited one
or more of the conditions of a blighted property as set forth in Ordinance No. 99-1; and
WHEREAS. the Board adopted a Blight Determination Resolution No. 2000-6 determining
that the Premises is blighted: and
WHEREAS, the property owner of the Premises. Emma W. Toth. a~Ja Emma C. Wentzel
and Frank Toth (hereinafter the "Owners"), had been served with the Blight Determination
Resolution No. 2000-6 and notified of their right to appeal the determination or provide a
rehabilitation plan; and
WHEREAS, the Owner did not file an appeal nor did they file a rehabilitation plan: and
WHEREAS. the Board adopted a Second Resolution No. 2000-9 certifying the Premises
to the Redevelopment Authority of the County of Cumberrand as blighted; and
WHEREAS, in accordance with the provisions of the Urban Redevelopment Law and the
Rules and Regulations of the Board, a report on the Premises was transmitted to the
Planning Commission of the County of Cumberland and the Planing Commission of the
Borough of Shippensburg for those commissions to make their own determination as to
whether the procerty was blighted and to submit a recommendation as to the appropriate
re-use of the Premises; and
WHEREAS, on July 20, 2000. the Cumberland County Planning Commission determined
that the Premises is blighted and recommended with the re-use plan be to use the
Premises for residential purposes; and
WHEREAS, the 8orough of Shippensburg Planning Commission determined on July 12,
2000. that the Premises is a blighted property and did concur with the recommended re-
use of the Premises. as aforesaid; and
EXHIBIT "A"
WHEREAS, the Redevelopment Authority had previously attempted to negotiate the
acquisition of the Premises in lieu of condemnation without success: and
WHEREAS, in accordance with the Urban Redevelopment Law. as amended, the
Redevelopment Authority is authorized to acquire title to the Premises through eminent
domain proceedings.
NOW, THEREFORE, BE IT RESOLVED that the Redevelopment Authority of the County
of Cumberland. in accordance with authority conferred by law, accepts the certification of
the Premises Iocated at 68 East King Street, Shippensburg, Cumberland County,
Pennsylvania. as a blighted property and does further select and appropriate for
acquisition and disposition in accordance with law the Premises which are more fully
described:
ALL THAT CERTAIN lot of ground with two-story stone dwelling house and
two-car garage thereon erected, known as No. 68 East King Street, situate
at the Southwest corner of King and Penn Streets. Borough of
Shippensburg, Cumberland County, Pennsylvania, bounded and described
as follows: On the North by King Street; on the East by Penn Street; on the
South by improved lot formerly of Margaret S. Berry, now or formerly of
Glenn E,t~r. formerly a part of this lot: and on the West by improved lot
formerly of John Hosfeld Estate, now or formerly of G. Leonard Fogelsonger:
extending in front along King Street from the Penn Street curb. forty-one and
one-half (41-1/2) feet to the line of the said G. Leonard Fogelsonger
property, and extending from the King Street curb Southwardly one hundred
eleven (111 ) feet to the line which is now the Southerly side of the concrete
garage wall on these premises, along which Southerly line this line abuts to
a width of forty-two (42) feet.
RESOLVED that the title to be acquired shall be absolute or fee simple title, including all
easements, rights of way, and real property interests of whatsoever nature.
RESOLVED that counsel for the Redevelopment Authority and its proper officers are
hereby authorized to file a Declaration of Taking and such other proceedings, including
the entry of such bond as may be necessary or desirable, to carry out the purpose of this
resolution.
RESOLVED that ',he institution of such proceedings, and any damages which may be
agreed upon or awarded to any party in interest shall be paid out of the funds of: the
Redevelopment Authority.
ATTEST
SeCretary
Date: '-~v~< ~ '"'~(~<:~/ J' 68E~ngRe$oLwpU
EXHIBIT "B"
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of ground with two-story stone dwelling house and two-car ga_rage
thereon erected, known as No. 68 East King Street, situate at the Southwest corner of King
and Penn Streets, Borough of Shippensburg, Cumberland County, Pennsylvania, bounded
and described as follows: On the North by King Street; on the East by Penn Street; on the
South by improved lot formerly of Margaret S. Berry, now or formedy of Glenn Etter,
formedy a part of this lot; and on the West by improved lot formerly; of John Hosfeld Estate,
now or formedy of G. Leonard Fogelsonger; extending in front along King Street from the
Penn Street curb, forty-one and one-half (41-1/2) feet to the line of the said G. Leonard
Fogelsonger property, and extending from the King Street curb Southwardly one hundred
eleven (111 ) feet to the line which is now the Southerly side of the concrete garage wall
on these premises, along which Southerly line this line abuts to a width of forty-two (42)
feet.
EXHIBIT "C"
BOND
KNOW ALL MEN BY THESE PRESENTS, that a Declaration of Taking having been filed
the Z.~'~ay of ~ (43 ~ ~a-- ,2001, by the Redevelopment A_uthodty oft_he County
of Cumberland (the "Ob-~gor"), a body corporate and politic and existing under the laws of
the Commonwealth of Pennsylvania, being held and firmly bound unto the Commonwealth
of Pennsylvania (the "Obligee") for the use and benefit of the owner or owners of the
property condemned as hereinafter noted, and other proper parties in interest, for such
amount of damage as the owner or owners of the property and other parties in interest
shall be entitled to receive after the same shall have been agreed upon or assessed in the
manner prescribed by law, by the reason of the condemnation by Obligor of certain land
improvements located in the Borough of Shippensburg, Cumberland County, and
described as follows:
ALL THAT CERTAIN tot of ground with two-story stone dwelling house and
two-car garage thereon erected, known as No. 68 East King Street, situate
at the Southwest corner of King and Penn Streets, Borough of
Shippensburg, Cumberland County, Pennsylvania, bounded and described
as follows: On the North by King Street; on the East by Penn Street; on the
South by improved lot formerly of Margaret S. Berry, now or formerly of
Glenn Etter, formerly a part of this lot; and on the West by improved lot
formedy of John Hosfeld Estate, now or formedy of G. Leonard Fogelsonger;
extending in front along King Street from the Penn Street curb, forty-one and
one-half (41-1/2) feet to the line of the said G. Leonard Fogelsonger
property, and extending from the King Street curb Southwardly one hundred
eleven (111) feet to the line which is now the Southerly side of the concrete
garage wall on these premises, along which Southerly line this line abuts to
a width of forty-two (42) feet.
BEING the premises of Emma W. Toth, a/Ida Emma C. Wentzel, and Frank
Toth, to which payment well and truly to be made, the Obligor does bind itself
and its successors and assigns, firmly by these presents.
WHEREAS, the Obligor has condemned said property and it cannot agree with the owner
or owners of said land and buildings upon the just compensation to be paid for the
damages sustained by said owner or owners as a result of the condemnation:
NOW THE CONDITION of this bond is such that if the Obligor shall pay or cause to be paid
such amount of damages as the said owner or owners of the property and other parties in
interest shall be entitled to receive by reason of such condemnation, after the same shall
have been agreed upon or assessed in the manner provided by law, then this obligation
shall be void; otherwise, to be and remain in full force and effect.
SEALED with the corporate seal_and duly executed this }~'~day--~'~ of'~t/-~u~ ~4.~'''
2001.
ATTEST
Secretary '
REDEVELOPMENT AUTHORITY OF
THE COUNTY Of CUMBERLAND
' Jjmmie C. George -- ~--~.~
~'Chairman
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY OF
THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA
EMMA C. WENTZEL and
FRANK TOTH,
Plaintiffs
REDEVELOPMENT AUTHORITY OF
THE COUNTY OF CUMBERLAND,
Defendant
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 01-5017 CIVIL TERM
· EMINENT DOMAIN PROCEEDINGS
PETITION OF THE REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND
FOR A WRIT OF POSSESSION
The Petition of Redevelopment Authority of the County of Cumberland ("Condemnor")
pursuant to Section 407(a) of the Eminent Domain Code, 26 P.S. 1-407, represents:
1
The Condemnor is the Redevelopment Authority of the County of Cumberland, whose
address is 114 North Hanover Street, Carlisle, Cumberland County, Pennsylvania.
2
On November 29, 2000, Condemnor filed a Declaration of Taking at the above-captioned
term and number·
3
Included in the Declaration of Taking was property owned by Emma C. Wentzel and Frank
Toth ("Condemnees"), located at 66 East King Street, Shippensburg, Cumberland County,
Pennsylvania ("Property").
4
No Preliminary Objections to the Declaration of Taking have been filed.
5
By Order of Court dated November 13, 2001, the Court appointed a Board of View to
assess damages in the condemnation.
6
On May 16, 2002, the Board of View conducted a hearing for purposes of taking testimony
on the issue of the just compensation to be paid to Condemnees.
7
Condemnor submitted testimony from a certified real estate appraiser at the proceedings
before the Board of View that the fair market value of the Property as of the date of taking
was $67,500.
8
Condemnor is entitled to possession of the Property upon payment to the Condemnees
or into the Court of the estimated just compensation.
9
Condemnor desires to pay the amount of estimated just compensation into Court.
10
George F. Douglas, III, Esquire, attorney for Condemnee, Emma C. Wentzel, does not
oppose the filing of this Petition.
WHEREFORE, Condemnor, Redevelopment Authority of the County of Cumberland,
requests that this Court grant a Rule upon Emma C. Wentzel and Frank Toth to show
cause why a Writ of Possession shall not issue upon payment into Court of the estimated
just compensation of $67,500.
ed,
Christophe~C. Houston, Esquire
Attorney for Defendant/Condemnor
114 North Hanover Street
Carlisle, PA 17013
717-249-0789
A:\WritPossPet.wpd
I verify that the statements in the foregoing pleading are true and correct. I understand that
false statements herein are made subject to the penalties of 18 PaCS 4904 relating to
unsworn falsification to authorities.
REDEVELOPMENT AUTHORITY OF THE
COUNTY OF CUMBERLAND
Executive Director
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY OF
THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA
EMMA C. WENTZEL and
FRANK TOTH,
Plaintiffs
REDEVELOPMENT AUTHORITY OF
THE COUNTY OF CUMBERLAND,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5017 CIVIL TERM
EMINENT DOMAIN PROCEEDINGS
AND NOW, this __~ day of ~~_~_~_~_~_~_~~, 2002, on consideration of the Petition
of Redevelopment Authority of the County of Cumberland, a Rule is granted upon Emma
C. Wentzel and Frank Toth to show cause why a Writ of Possession should not issue upon
payment into Court by the Condemnor of the sum of $67,500. Pursuant to 26 P.S. 1-
407(a), this Rule is returnable'~,~ days after service upon Condemnee.
By the Court,
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY OF
THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA
EMMA C. WENTZEL and
FRANK TOTH,
Plaintiffs
V
REDEVELOPMENT AUTHORITY OF
THE COUNTY OF CUMBERLAND,
Defendant
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 01-5017 CIVIL TERM
· EMINENT DOMAIN PROCEEDINGS
PETITION TO MAKE RULE ABSOLUTF
The Petitioner, Redevelopment Authority of the County of Cumberland ("Condemnor"),
represents:
1
Upon a Petition of the Redevelopment Authority of the County of Cumberland for a Writ of
Possession, a Rule was issued on June 7, 2002, to show cause why a Writ of Possession
should not issue with said Rule to be returnable twenty (20) days after service upon
Condemnees.
2
Attached hereto and marked as Exhibit "A" is an Affidavit of Service of said Rule upon
Condemnees.
3
No answer has been filed to Condemnor's Petition and said Rule is now returnable.
WHEREFORE, Condemnor, Redevelopment Authority of the County of Cumberland,
requests that this Honorable Court make the Rule absolute and issue a Writ of Possession
for the property located at 68 East King Street, Shippensburg, Cumberland County,
Pennsylvania, in favor of Condemnor.
mitted,
Christopher C. Houston, Esquire
Attorney for Petitioner/Condemnor
114 North Hanover Street
Carlisle, PA 17013
717-249-0789
A:\RulePet.wpd
I verify that the statements in the foregoing pleading are true and correct. I understand that
false statements herein are made subject to the penalties of 18 PaCS 4904 relating to
unsworn falsification to authorities.
REDEVELOPMENT AUTHORITY OF THE
COUNTY OF CUMBERLAND
Christ~)pher Gulotta
Executive Director
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY OF
THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA
EMMA C. WENTZEL and
FRANK TOTH,
Plaintiffs
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 01-5017 CIVIL TERM
· EMINENT DOMAIN PROCEEDINGS
V
REDEVELOPMENT AUTHORITY OF
THE COUNTY OF CUMBERLAND,
Defendant
AFFIDAVIT OF SERVlCF
I, Christopher C. Houston, Esquire, do hereby certify that I served the Rule with
accompanying Petition of the Redevelopment Authority of the County of Cumberland for
Writ of Possession by first class, postage prepaid, on June 10, 2002, on the following:
George F. Douglas, III, Esquire
Douglas Law Office
27 West High Street
Carlisle, PA 17013
Attorney for Emma C. Wentzel
and by certified mail, postage prepaid, with service being made on or about June 13, 2002,
on the following:
Frank Toth
One East Burd Street
Shippensburg, PA 17257
EXHIBIT "A"
Christopher C. Houston, Esquire
Attorney for Petitioner/Condemnor
114 North Hanover Street
Carlisle, PA 17013
717-249-0789
· cemptete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is de~irecl.
· 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.
1. Article Addressed to:
2. Article Number
(Transfer from service/abe/)
'Printed Name) C. Date of Delivery
D. ts de~ivery address diffef~3t from item l? r-lYes
If YES, enter delivery address below: [] No
3. Service Type
[~Certified Mail [] Exorass Mail
i--I Registered ~ Return Receipt for Memhandise
[] Insured Mail Y"I C.O.D.
4. Restricted Delivery? (Extra Fee) [] Yes
/ Addressee
PS Form 3811, August 2001
Domestic Return Receipt
102595-01 -M-038'
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY OF
THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 01-5017 CIVIL TERM
· EMINENT DOMAIN PROCEEDINGS
EMMA C. WENTZEL and
FRANK TOTH,
Plaintiffs
REDEVELOPMENT AUTHORITY OF
THE COUNTY OF CUMBERLAND,
' Defendant
CERTIFICATE OF SERVICF
i, Christopher C. Houston, Esquire, do hereby certify that on this date I served the
foregoing Petition with proposed Order by first class mail, postage prepaid, upon the
following:
Date:
George F. Douglas, III, Esquire
Douglas Law Office
27 West High Street
Carlisle, PA 17013
Attorney for Emma C. Wentzel
Frank Toth
One East Burd Street
Shippensburg, PA 17257
~, Esquire
Attorney for Petitioner/Condemnor
114 North Hanover Street
Carlisle, PA 17013
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY OF
THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA
EMMA C. WENTZEL and
FRANK TOTH,
Plaintiffs
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 01-5017 CIVIL TERM
· EMINENT DOMAIN PROCEEDINGS
REDEVELOPMENT AUTHORITY OF
THE COUNTY OF CUMBERLAND,
Defendant
TO THE PROTHONOTARY:
Issue a Writ of Possession in the above matter to the Redevelopment Authority of the
County of Cumberland for the property located at 68 East King Street, Shippensburg,
Cumberland County, Pennsylvania.
~n, Esquire
Attorney for Defendant
114 North Hanover Street
Carlisle, PA 17013
717-249-0789
Date:
REDEVELOPMENT AUTHORITY
· nou~m~ ~,-~, .. . n_ L.A ~ollitv ~p~vements ·
· E~no~c Development '
MEMO
DATE: July 31, 2002
TO: Cumberland County Sheriff's Department
FROM: Christopher C. Houston, Esquire ~
RE: No. 01-5017 Civil Term
Writ of Possession
68 E. King Street, Shippensburg, PA
With respect to service of the Writ of Possession for the property at 68 E. King Street,
Shippensburg, PA. This is a vacant and uninhabited property. Please serve the Writ
of Possession upon the property owners, as follows:
Frank Toth
One East Burd Street
Shippensburg, PA
Emma C. Wentzel
242 W. Pomfret Street
Carlisle, PA
Once service has been accomplished upon the owners, please have the deputy contact
me at 249-0789 for purposes of arranging a meeting at the property at 68 E. King St.
for purposes of obtaining possession.
SERVING CUMBERLAND COUNTY SINCE 1975
114 N. HANOVER ST. - STE. 104 · CARLISLE PA 17013-2445
(717) 249-0789 -(717) 697-7703 · (717) 532-8805 · lq~x(717) 249-4071 · E-mail: admln@cchra-c°m
WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160 - 3165 etc.)
Re~tevelopment Authority of the IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
County of Cumberland
VS.
F~ Ibth, One ~ ~ Street, .chi.~ri~ PA
~ C. Wentzel, 242 W. Ponfret $qlBet, ~=n~l ~1~ FD
No.
No. 2001-5017 Civil
Term
Costs
Att'y.__
PI'fi(s)
Prothy._ $ 1.00
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sheriff of Cumberland _County, Pennsylvania
(1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the
following described properly to:
Redevelopment Authority of the County of Cumberland
being: (Premises as follows): Plaintiff (s)
68 East King Street, Shippensburg, Cumberland County Pennsylvania
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defen-
dant (s) and sell his/her (or their) interest therein.
Date July 31, 2002
(SEAL)
~g, _Prothonotary__
Pr°~h°n°F~r-~°mm°n Pleas Co~l C/umbeland County, Peansylvania
Deputy
By virtue of this writ, on the 30th
day of_ August ,_2002
i causedthewithinnamed_Redevelopment Authority of the County of Cumberland
have possession of the premises described q(~Xl~k~¢~a~RcifgX~Iffi 68 East King
, tO
~j~e_et~ Shi~burg~ PA
Sheriff's Costs
Dock~
Surcharge
Poundage
Prothon~
Advance Costs: 150.00
18.00 Sheriff's CostS: 98.53
bl.4/
20.00
1.93 Refunded to Atty on 8/30/02
1.00
30.00
27.60
98~-53
Posession
Milage
Sworn and~ub~crib~d to before me this
day of ~
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA
EMMA C. WENTZEL and
FRANK TOTH,
Plaintiffs
V
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND,
Defendant
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 01-5017 CIVIL TERM
· EMINENT DOMAIN PROCEEDINGS
PETITION OF
REDEVELOPMENT AUTHORITY OF THE COUNTY OF CUMBERLAND
TO DISTRIBUTE DAMAGES PURSUANT TO SECTION 521
OF THE EMINENT DOMAIN CODE
The Petitioner, Redevelopment Authority of the County of Cumberland ("Condemnor"),
represents:
1
The Condemnor is the Redevelopment Authority of the County of Cumberland, whose
address is 114 North Hanover Street, Carlisle, Cumberland County, Pennsylvania.
2
On August 28, 2001, Condemnor filed a Declaration of Taking at the above-captioned term
and number.
3
Included in the Declaration of Taking was property owned Iby Emma C. Wentzel and Frank
Toth ("Condemnees"), located at 68 East King Street, Shippensburg, Cumberland County,
Pennsylvania ("Property").
4
No Preliminary Objections to the Declaration of Taking were filed.
5
By Order of Court dated November 13, 2001, the Court appointed a Board of View to
assess damages in the condemnation.
6
On May 16, 2002, the Board of View conducted a hearing for purposes of taking testimony
on the issue of the just compensation to be paid to Condemnees.
7
Condemnor submitted testimony at the proceedings before the Board of View that the fair
market value of the property as of the date of taking was $67,500.
8
On June 7, 2002, in consideration of a Petition of Condernnor for a Writ of Possession, a
Rule was issued upon Condemnees to show cause why a Writ of Possession should not
issue upon payment into Court by the Condemnor of the sum of $67,500.
9
On July 16, 2002, the previously-issued Rule was made absolute and a Writ of Possession
was ordered to be issued upon payment in to Court of the estimated just compensation of
$67,500.
10
On July 30, 2002, the Report of Viewers was filed with 1:he Court which concluded that
Condemnees were to be awarded damages totaling :$67,500 plus accrued interest
calculated through August 2, 2002, of $1,872.52, for a total sum due of $69,372.52.
11
Condemnor did pay in to the Court on August 2, 2002, the sum of $69,372.52.
12
No appeal to the Report of Viewers was filed by Condemnees.
13
The Condemnee, Emma C. Wentzel, has been represented in these proceedings by
George F. Douglas, III, Esquire, and Condemnee, Frank Toth, has been acting pro se.
14
Emma C. Wentzel and Frank Toth, although married, have been living separate and apart
for many years.
15
Condemnor had understood that Frank Toth did not wish to receive any of the damage
award for the property and, accordingly, had suggested that a written Agreement be
entered into between the Condemnees to be filed along with the Petition for Distribution
of Award, subject to any liens or claims existing as of the date of the filing of the
Declaration of Taking. Attached hereto and marked as Exhibit A is a copy of Condemnor's
correspondence regarding the proposed distribution.
16
No Agreement has been submitted to Condemnor with respect to the proposed distribution
plan submitted by Condemnor.
17
With no appeal having been taken from the Board of Viewers award by any of the parties,
the award has become final.
18
Condemnor has, at all times, been ready and willing to pay the proceeds of the award to
the proper parties in interest pursuant to the proposed distribution plan as set forth herein.
19
By reason of the Condemnees not being in a position to submit an Agreement setting forth
the distribution of the award between the Condemnees, Condemnor desires to distribute
the award made by the Board of Viewers for the reasons that the award is now final and
there is no dispute as to the total amount of the award involved.
20
Pursuant to 26 P.S. 1-521, Condemnor has made a diligent search for liens for all taxes
and municipal claims assessed against the Property and all mortgages, judgments, and
other liens of record for which the particular damages are payable, existing at the date of
the filing of the Declaration of Taking and has determined that the following liens did exist:
A. Borough of Shippensburg v Emma W. Toth and Frank Toth, her Husband -
89 MLD 29278 filed on December 11, 1989,, in the amount of $84.94; and
B. Borough of Shippensburg v Emma Wentz. el, aka Emma Toth, 92 MLD 31435
filed on September 25, 1992, in the amount of $568.30;
21
Condemnor proposes the following schedule of distribution:
A. Borough of Shippensburg in satisfaction of the municipal lien filed at 89 MLD
29278 in the amount of $84.94, which amount the Borough of Shippensburg
is willing to accept in full satisfaction;
B. Borough of Shippensburg in satisfaction of the municipal lien filed at 92 MLD
31435 in the amount of $568.30, which amount the Borough of
Shippensburg is willing to accept in full satisfaction;
C. To Emma C. Wentzel and Frank Toth - $ 68,719.28.
WHEREFORE, Condemnor requests that this Court grant a Rule on Condemnees and the
Borough of Shippensburg to show cause why Condemnor should not distribute the sum
of $69,372.52, being the amount awarded by the Board of Viewers pursuant to the report
filed on July 30, 2002, from which no appeal has been taken, for damages in connection
with the taking of property located at 68 East King Street, Shippensburg, Cumberland
County, Pennsylvania pursuant to the schedule of distribution as set forth herein.
Condemnor further requests that Condemnees and the Borough of Shippensburg be
further directed to show cause, why, upon Praecipe filed with the Prothonotary by
Condemnor that upon such distribution having been made, the Prothonotary should not be
directed to mark the Board of View award for the Property satisfied of record.
Iouston, £squire
Attorney for Condemnor
114 North Hanover Street
Carlisle, PA 17013
717-249-0789
F:\HOUSTON\68EKing Pefition.wpd
I verify that the statements in the foregoing pleading are true and correct. I understand that
false statements herein are made subject to the penalties of 18 PaCS 4904 relating to
unsworn falsification to authorities.
REDEVELOPME-'NT AUTHORITY OF THE
COUNTY OF CUMBERLAND
Executive Director
REDEVELOPMENT AUTHORITY
* Housing Development · Housing Rehabilitation ·
· Housing Manage]nent · Homeownership Programs ·
· Downtown Revitalization · Public Facility Improvements ·
· Economic Development ·
August1,2002
George F. Douglas, III, Esquire
Douglas, Douglas & Douglas
27 West High Street
Carlisle, PA 17013
Mr. Frank Toth
One East Burd Street
Shippensburg, PA 17257
RE: 68 East King Street, Shippensburg
Dear George and Mr. Toth:
Please be advised that we have paid into Court the sum of $69,372.52, which is the
amount recommended by the Board of Viewers to be paid to Condemnees, Ms. Wentzel
and Mr. Toth. If no appeal is taken to the Report of the Board of Viewers, the next step
would be for us to submit a Petition with the Court to distribute the funds deposited in Court
in accordance with a proposed Schedule of Distribution. We had understood that Mr. Toth
did not wish to receive any payment for the property. We ,would suggest that if that is the
case, that Ms. Wentzel and Mr. Toth should enter into an Agreement to that effect, which
would be filed with the Court. Assuming such an Agreement would be submitted, our
proposed Schedule of Distribution would be to make payment in full to Ms. Wentzel,
assuming that there are no liens or claims existing as of the date of the filing of the
Declaration of Taking, which would have a priority position regarding the payment of the
proposed distribution. If no such Agreement is submitted to the Court, then our proposed
Schedule of Distribution would provide for a payment of one-half of the sum due and owing
to each of the Condemnees.
Again, assuming that no appeal is filed, we would intend on promptly filing a Petition with
the Court for distribution. Accordingly, if an Agreement would be worked out between Ms.
Wentzel and Mr. Toth, we would ask that that be done in the near future.
Very truly yours,
kb
cc: Christopher Gulotta
F:\HOUSTON\IAUG1 .WPD
Christopher C. Houston, Esquire
Director of Real Estate Development
EXHIBIT "A"
SERVING CUMBERLAND COUNTY SINCE 1975
114 N. HANOVER ST. - STE. 104 · CARLISLE PA 17013-2445
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01-5017 CIVIL TERM
: EMINENT DOMAIN PROCEEDINGS
EMMA C. WENTZEL and
FRANK TOTH,
Plaintiffs
V
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND,
Defendant
CERTIFICATE OF SERVICE
I, Christopher C. Houston, Esquire, do hereby certify that on this date I served the
foregoing Petition with the proposed Rule by first class mail, postage prepaid, upon the
following:
George F. Douglas, III, Esquire
Attorney for Emma C. Wentzel
Douglas, Douglas & Douglas
27 West High Street
Carlisle, PA 17013
Frank Toth
One East Burd Street
Shippensburg, PA 17257
Emma C. Wentzel
242 West Pomfret Street
Carlisle, PA 17013
Borough of Shippensburg
P. O. Box 129
Shippensburg, PA 17257
~lo~uston, Esquire
Attorney for PetitionedCondemnor
114 North Hanover Street
Carlisle, PA 17013
717-249-0789
Date: "~C(- ! "~f ~(~ %
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA
EMMA C. WENTZEL and
FRANK TOTH,
Plaintiffs
V
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND,
Defendant
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 01-5017 CIVIL TERM
· EMINENT DOMAIN PROCEEDINGS
AND NOW, this y of ,20 n consideration of the
Petition of Redevelopment Authority of the County of Cumberland to Distribute Damages
Pursuant to Section 521 of the Eminent Domain Code, a Rule is granted upon Emma C.
Wentzel and Frank Toth and the Borough of Shippensburg, to show cause why the award
of the Board of Viewers filed July 30, 2002, regarding the condemnation of property located
at 68 East King Street, Shippensburg, Cumberland County, Pennsylvania, in the amount
of $69,372.52 should not be paid and distributed with said distribution being payable as
follows:
1. Borough of Shippensburg - $ 653.24; and
1. Borough of Shippensburg - $ 653.24; and
2. Emma C. Wentzel and Frank Toth - $ 68,719.28.
And why, upon Praecipe filed, that the Prothonotary should not be directed to make said
distribution of the award and to mark the award made by the Board of Viewers for this
Property satisfied of record.
Rule returnable twenty (20) days after service.
By the Court,
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA
EMMA C. WENTZEL and
FRANK TOTH,
Plaintiffs
v
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND,
Defendant
: IN THE COURT' OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
:
: NO. 01-5017 CIVIL TERM
: EMINENT DOMAIN PROCEEDINGS
PETITION TO MAKE RULE ABSOLUTE
The Petitioner, Redevelopment Authority of the County of Cumberland ("Condemnor"),
represents:
1
Upon a Petition of Redevelopment Authority of the County of Cumberland to Distribute
Damages Pursuant to Section 521 of the Eminent Domain Code, a Rule was issued on
December 20, 2002, to show cause why the award of the IE~oard of Viewers filed July 30,
2002, regarding the condemnation of property located at 68 East King Street,
Shippensburg, Cumberland County, Pennsylvania, in the amount of $69,372.52 should not
be paid and distributed, with said distribution being payablle as follows:
A. Borough of Shippensburg - $653.24; and
B. Emma C. Wentzel and Frank Toth - $68,719.28.
And why, upon Praecipe filed, the Prothonotary should not be directed to make said
distribution of the award and to make the award made by the Board of Viewers for this
property satisfied of record, with said Rule returnable twenty (20) days after service.
2
Attached hereto and marked as Exhibit "A" is an Affidavit of Service of said Rule.
3
No Answer has been filed to Condemnor's Petition and said Rule is now returnable.
WHEREFORE, Condemnor, Redevelopment Authority of the County of Cumberland,
requests that this Honorable Court make the Rule absolute and further direct that upon
Praecipe filed by Condemnor, that the Prothonotary be directed to make said distribution
of the award and to mark the award made by the Board of Viewers for this property
satisfied of record.
iitted'
Christopher C. Houston, Esquire
Attorney for PetitionedCondemnor
114 North Hanow.~r Street
Carlisle, PA 1701:3
717-249-0789
F:\HOUSTON\68EKing Pet.wpd
I verify that the statements in the foregoing pleading are tn. Je and correct. I understand that
false statements herein are made subject to the penalties of 18 PaCS 4904 relating to
unswom falsification to authorities.
REDEVELOPMFNT AUTHORITY OF THE
COUNTY OF CUMBERLAND
Executive Director
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA
EMMA C. WENTZEL and
FRANK TOTH,
Plaintiffs
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 01-5017 CIVIL TERM
· EMINENT DOMAIN PROCEEDINGS
V
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND,
Defendant
AFFIDAVIT OF SERVlCF
I, Christopher C. Houston, Esquire, do hereby certify' that I served the Rule with
accompanying Petition of the Redevelopment Authority of the County of Cumberland to
distribute damages pursuant to Section 521 of the Eminent Domain Code by first class
mail, postage prepaid, on January 2, 2003, on the following:
George F. Douglas, III, Esquire
Douglas Law Office
27 West High Street
Carlisle, PA 17013
Attorney for Emma C. Wentzel
Borough of Shippensburg
P. O. Box 129
Shippensburg, PA 17257
EXHIBIT "A"
And by certified mail, postage prepaid, with service being made on or about January 4,
2003, on the following:
Date:
Frank Toth
One East Burd Street
Shippensburg, PA 17257
Christopher C. Houston, Esquire
Attorney for Petitioner/Condemnor
114 North Hanover Street
Carlisle, PA 17013
717-249-0789
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 01-5017 CIVIL TERM
· EMINENT DOMAIN PROCEEDINGS
EMMA C. WENTZEL and
FRANK TOTH,
Plaintiffs
V
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND, ·
Defendant ·
CERTIFICATE OF SERVICE_
I, Christopher C. Houston, Esquire, do hereby certify that on this date I served the
foregoing Petition with proposed Order by first class mail, postage prepaid, upon the
following:
George F. Douglas, III, Esquire
Douglas Law Office
27 West High Street
Carlisle, PA 17013
Attorney for Emma C. Wentzel
Frank Toth
One East Burd Street
Shippensburg, PA 17257
Emma C. Wentzel
242 WeSt Pomfret Street
Carlisle; PA 17013
Borough of Shippensburg
P. O. Box 129
Shippensburg, PA 17257
Christopher C. Houston, Esquire
Attorney for Petitioner/Condemnor
114 North Hanover Street
Carlisle, PA 17013
717-249-0789
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA
EMMA C. WENTZEL and
FRANK TOTH,
Plaintiffs
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 01-5017 CIVIL TERM
· EMINENT DOMAIN PROCEEDINGS
V
REDEVELOPMENT AUTHORITY ·
OF THE COUNTY OF CUMBERLAND, ·
Defendant ·
~ ORDER
AND NOW, this 5t day of __~_, 2003, on consideration of a
Petition of the Redevelopment Authority of the County of Cumberland to Distribute
Damages Pursuant to Section 521 of the Eminent Domain Code and the Petition to Make
Rule Absolute, it is hereby ordered that the Rule is made absolute and that, upon Praecipe
of the Condemnor, the Prothonotary is directed to make distribution of the sum of
$69,372.52 previously paid into the Court by Condemnor, as follows:
1. Borough of Shippensburg - $653.24; and
2. Emma C. Wentzel and Frank Toth - $68,719.28.
It is further ordered and directed that the Prothonotary rnark the award by the Board of
Viewers for this property satisfied of record.
By the Court,
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PENNSYLVANIA,
EMMA C. WENTZEL and
FRANK TOTH,
Plaintiffs
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 01-5017 CIVIL TERM
· EMINENT DOMAIN PROCEEDINGS
V
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND,
Defendant
PRAECIPE
TO THE PROTHONOTARY:
Pursuant to Court Order of January 31, 2003, please make distribution of the sum of
$69,372.52 previously paid into the Court by the Redewglopment Authority of the County
of Cumberland, Condemnor, as follows:
1. Borough of Shippensburg - $653.24; and
2. Emma C. Wentzel and Frank Toth - $68,719.28.
Please also mark the award by the Board of Viewers for this property satisfied of record.
~~Esquire
Attorney for Condemnor
Redevelopment Authority of the County of
Cumberland
114 North Hanover Street
Carlisle, PA 17013
717-249-078(,;)
F:\HOUSTON\68EKingPraecipe.wpd
Date:
IN RE:
CONDEMNATION BY THE
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND
OF THE PREMISES KNOWN AND
NUMBERED AS 68 EAST KING
STREET, SHIPPENSBURG,
CUMBERLAND COUNTY,
PEN NSYLVAN IA
EMMA C. WENTZEL and
FRANK TOTH,
Plaintiffs
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 01-5017 CIVIL TERM
· EMINENT DOMAIN PROCEEDINGS
V
REDEVELOPMENT AUTHORITY
OF THE COUNTY OF CUMBERLAND,
Defendant
ORDER
AND NOW, this 5L day of __~., 2003, on consideration of a
Petition of the Redevelopment Authority of the County of Cumberland to Distribute
Damages Pursuant to Section 521'°f the Eminent Domain ,Code and the Petition to Make
Rule Absolute, it is hereby ordered that the Rule is made absolute and that, upon Praecipe
of the Condemnor, the Prothonotary is directed to make distribution of the sum of
$69,372.52 previously paid into the Court by Condemnor, as follows:
1. Borough of Shippensburg - $653.24; and
2. Emma C. Wentzel and Frank Toth - $68,719.28.
It is further ordered and directed that the Prothonotary mark the award by the Board of
Viewers for this property satisfied of record.
By the Court,
m:3::
,.,nm
o
--Z~o rll
o ~
RECEIPT FOR PAYMENT
Cumberlan~ Cgunty Prothonotary's Office
Carlisle, Pa 17013
Receipt Date
Receipt Time
Receipt No.
13: 53
134422
IN RE CONDEMNATION BY CCRDA (VS)
Case Number 2001-05017
Receipt total. =
.00
TRNS ESC OUT
-- Distribution Of Payment ............................
Transaction Description Payment Amount
BOND 69,372.52-
REFUND 653.24
REFUND 68,719.28
RECEIPT FOR PAYMENT
Cumberland County Prothonotary's Office
Carlisle, Pa 17013
IN RE CONDEMNATION BY CCRDA (VS)
Case Number 2001-05017
Receipt Date
Receipt Time
Receipt No.
2/o7/2oo3
13:54:53
134422
Receipt total. =
Transaction Description
BOND
REFUND
REFUND
.00 TRNS ESC OUT
Distribution Of Payment ............................
Payment Amount
69,372.52-
653.24
68,719.28
14142802072003 Cumberland County Prothonotary's Office Pa~e 1
PYS405 Manual Release Check Regl~ster 2/07/2003
Escrow Tran Date
Distribution Case No Accounting Amount Date Release
REFUND 2001- 05017 TRNS ESC IN 68719.28 2/07/2003
Payee total: 68719.28
REFUND 2001- 05017 TRNS ESC IN 653.24 2/07/2003
Payee total: 653.24
Grand total: 69,372.52