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Home My WebLink About06-0587 Salzmann Hughes, P.c. BY: E. Ralph Godfrey, Esquire Attorney I.D. No_ 77052 354 Alexander Spring Road, Suite] Carlisle, P A 17013 Tckphonc: 717-249-6333 fax 717-249-7334 Attorney for Plaintiff Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYL VANIA VIRGINIA ADAMS, vs. NANCY C. HERLT, individually, in her own right, and NANCY C. HERLT, EXECUTRIX OF THE EST A TE OF ROBERT WAYNE HERLT, SR. AlKJA ROBERT W. HERLT, deceased NO. 06- 557 ~ CIVIL ACTION Defendants PRAECIPE FOR ISSUANCE OF WRIT OF SUMMONS TO THE PROTHONOTARY: Please issue Writ of Summons against the following Defendants: Nancy C. Herlt, individually 633 Brandy Run Road Newville, P A 17241 Nancy C. Herlt, Executrix of the Estate of Robert Wayne Herlt, Sr. aIkIa Robert W. Herlt 633 Brandy Run Road Newville, P A 17241 Date: I ~L- 7 r 0 ~ SALZMANN HUGHES, P.C. ~<--:7 By i / ~E. Ralph Go re squ Attorney I.D. No. 770 354 Alexander Spring Road Carlisle, P A 17013 (717) 249-6333 Attorneys for Plaintiff VIRGINIA ADAMS, Plaintiff vs. NANCY C. HERLT, individually, in her own right, and NANCY C. HERL T, EXECUTRIX OF THE ESTATE OF ROBERT WAYNE HERLT, SR. AlKJA ROBERT W. HERLT, deceased Defendants IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO. 06- .5Y1 CwJ I~ CIVIL ACTION WRIT OF SUMMONS TO: Nancy C. Herlt, individually 633 Brandy Run Road Newville, P A 17241 You are hereby notified that the above-named Plaintiffhas commenced an action against you. Date: I.;; 7. (~ I Seal of the Court Q,v_t;" t: y 7J By /;};:~y J )1<A?J / e uty ( VIRGINIA ADAMS, Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYL VANIA NO. 06- 5'n C;uVt --r bo- vs. NANCY C. HERLT, individually, iu her own right, aud NANCY C. HERL T, EXECUTRIX OF THE ESTATE OF ROBERT WAYNE HERLT, SR. AIKJA ROBERT W. HERLT, deceased CIVIL ACTION Defendants WRIT OF SUMMONS TO: Nancy C. Herlt, Executrix of the Estate of Robert Wayne Herlt, Sr. aJkJa Robert W. Herlt 633 Brandy Run Road Newville, P A 17241 You are hereby notified that the above-named Plaintiff has commenced an action against you. Date: /.) 1-1J6 , (I" ",41 I! )} (J By J:O:~'~ ~{~U Duty / Seal of the Court ;::;s.) ~~ -.0 'J ~ 5: G'\ Lf'\ v., co' q f;,: ~;.". "'tJ\,r.. I'll \ ' '?S >~- ~:'< r-:::_ ,..;.,- ;'... )> .--' ,"'" <:;;> "'" <- ~~ "'- ~- ~ -:::I I;:p rnF;; :Qd -~~ ~ C?'CJ' -_~.i -.} ;~ ~'l \ ::](~5 ;;_)fil :::'-1 ,~ ~.o :<. N ....... "" :::::. <:? .::- N w Salzmann Hughes, P.C. BY: E. Ralph Godfrey, Esquire Attorney 1.0. No. 77052 354 AIl'xander Spring Road, Suite 1 Carlisle, I)A t 7013 Telephone: 717-249-6333 Fax 717-249-7334 Attorney for Plaintiff VIRGINIA ADAMS, Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA vs. NANCY C. HERLT, individually, in her own right, and NANCY C. HERLT, EXECUTRIX OF THE ESTATE OF ROBERT WAYNE HERLT, SR. AJKJA ROBERT W. HERLT, deceased NO.06- ]f)7 ~ CIVIL ACTION Defendants PRAECIPE FOR LIS PENDENS TO THE PROTHONOTARY: Please index the above-captioned action as a lis pendens against the following real property: ALL THAT CERTAIN lot of ground situate in North Middleton Township, County of Cumberland and Commonwealth of Pennsylvania bounded and described as follows: , BEGINNING at a point in the center of the public road leading from (Rt. 641) Carlisle- Newville road to Meadowbrook Park which point is a comer of land, now or fomlerly of Frank S. Cohick and Lois J. Cohick, North 88 degrees 45 minutes West, a distance of 160 feet to a point in land now or formerly of the said Frank S. Cohick and Lois J. Cohick, his wife; thence still along land of the said Frank S. Cohick and Lois J. Cohick south I degree 15 minutes west, a distance of60 feet to a point; thence still along other land of the said Frank S. Cohick and Lois J. Cohick, south 88 degrees 45 minutes east, a dist3l1ce of 160 feet to appoint in the center of the aforesaid public road leading to Meadowbrook Park, north I degree 15 minutes East, a distance of 60 feet 0 a point, the Place of Beginning. Containing 9,600 square feet BEING the same lot of ground which Minnie S. Derr, Widow, by her Attorney-In-Fact, William L. Derr by deed dated February 25,2002 and recorded in the Office of Recorder of Deeds for the County of Cumberl3l1d, Pennsylvania in Deed Book 250, Page 2650. The undersigned hereby certifies that this action affects title to or other interest in the above-described real property. SALZMANN HUGHES, P.C. By E. a ph God qUire Attorney LD. No. 77~ 354 Alexander Spring Roaa-.-- Carlisle,PA 17013 (717) 249-6333 Attorneys for Plaintiff Date: I - :r7 -L' <,., 0 ...... 0 ~ <='" ~ ~':0 ~ G~ -l'l c7" \ -r-"'(1:\ <- ~...,. ..,"'" tl':', I '~ - \ "P" f1"1rJ; cJ. -,_'4 ~ .?- ,J -err. :5] j~-~ l"-' ~':t) c.:J --- -' (Jr-- - r~;" c:\ C .:::..1"'i< ..c:-" ...." \:~~.~A j~ . '--' -Z"l~- ~ ~ ~ '1? .. <.? ,~ ... C- d ~ (1\ ?is l"-' ......-.:. - , SHERIFF'S RETURN - REGULAR . CASE NO: 2006-00587 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ADAMS VIRGINIA VS HERLT NANCY C ET AL MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon HERLT NANCY C the DEFENDANT , at 1428:00 HOURS, on the 8th day of February 2006 at 164 CONODOGUINET MOBILE EST NEWVILLE, PA 17241 by handing to NANCY C HERLT a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge So Answers: 18.00 10.56 .39 10.00 .00 38.95 ~~~~ R. Thomas Kline "'" me this Is - day of 02/09/2006 SALZMANN HUGH~ /"7 //.4 By: :a;:-aA'Y~< Deputy Sheri Sworn and Subscribed to before J A.D. . SHERIFF'S RETURN - REGULAR . CASE NO: 2006-00587 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ADAMS VIRGINIA VS HERLT NANCY C ET AL MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon HERLT NANCY C EXEC OF ESTATE OF ROBERT WAYNE HERLT SR the DEFENDANT , at 1428:00 HOURS, on the 8th day of February, 2006 at 164 CONODOGUINET MOBILE EST NEWVILLE, PA 17241 by handing to NANCY C HERLT a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 -:r~?:}~7,..: ~~,.." .<.:.J;:_ R. Thomas Kline ~;? ~_. :.:~~,~~~-::.(P 02/09/2006 SALZMANN HUGHES Sworn and Subscribed to before By: me this /6""'- day of A.D. ... Salzmann Hughes, P.c. BY: E. Ralph Godfrey, Esquire Attorney I.D. No. 77052 354 Alexander Spring Road, Suite 1 Carlisle, PA 17013 Telephone: 717-249-6333 Fax 717-249-7334 Attorney for Plaintiff Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA VIRGINIA ADAMS, vs. NANCY C. HERLT, individually, in her own right, and NANCY C. HERLT, EXECUTRIX OF THE ESTATE OF ROBERT WAYNE HERLT, SR. AlK/A ROBERT W. HERLT, deceased NO. 06-0587 CIVIL ACTION Defendants PRAECIPE TO STRIKE LIS PENDENS TO THE PROTHONOTARY: Please strike the Lis Pendens indexed in the above-captioned action and against the following real property: ALL THAT CERTAIN lot of ground situate in North Middleton Township, County of Cumberland and Commonwealth of Pennsylvania bounded and described as follows: BEGINNING at a point in the center of the public road leading from (Rt. 641) Carlisle- Newville road to Meadowbrook Park which point is a comer ofland, now or formerly of Frank S. Cohick and Lois J. Cohick, North 88 degrees 45 minutes West, a distance of 160 feet to a point in land now or formerly of the said Frank S. Cohick and Lois J. Cohick, his wife; thence still along land of the said Frank S. Cohick and Lois J. Cohick south 1 degree 15 minutes west, a distance of 60 feet to a point; thence still along other land of the said Frank S. Cohick and Lois J. Cohick, south 88 degrees 45 minutes east, a distance of 160 feet to appoint in the center of the aforesaid public road leading to Meadowbrook Park, north I degree 15 minutes East, a distance of 60 feet 0 a point, the Place of Beginning. BEING the same lot of ground which Minnie S. Derr, Widow, by her Attorney-In-Fact, William 1. Derr by deed dated February 25,2002 and recorded in the Office of Recorder of Deeds for the County of Cumberland, Pennsylvania in Deed Book 250, Page 2650. ... Date: ;J,;:;Is ~ 0<.0 SALZMANN HUGHES, P.C. BYS. E. Ralph Go rre Attorney LD. No. 354 Alexander Spring Road Carlisle, PA 17013 (717) 249-6333 Attorneys for Plaintiff ~ ~; .......... "-J " ~ --t: -- ~ ~ ~. \~', ~\ ~ ~ ~ <:p ~ -;j "" , .- _./ ,..-' _:'i ~',', .-.,.-, '.--.' '.,,->' '-:'t -I', '- .-- .' /:'- ~ (FEB~2-2006 WED 11: 18 AM Salzmann Hughes, p, C, FAX NO, 7172435178 p, 03 Plaintiff IN THE COURT OF CoMMON PLEAS, CUMBERLAND COUNTY, PENNSYL VANIA NO. 06- 6'~1 VIRGINIA ADAMS, VS. NANCY C. HEtaT, individually, in her own right, and NANCY C. HERLT, EXECUTRIX OF THE ESTATE m' ROBERT WAYNE HERLT, SR. AJI(JA ROBERT W. HERLT, deceased Defendants STIPULATION WHEREAS, Plaintiff indexed a Lis Pendens against the Defendants' property local:ed at 50 Meadowbrook Road, Carlisle, PAl 70 13. Plaintiff has agreed to remove the Lis Pendens against the Property pUrsL~ant to the following tenus and conditions: .1. Upon the settlement of the Property, $]0,000.00 shall be placed into an interest bearing account. Defendants shall provide Plaintiff with a H1JD-l; 2. The parties waive the reqllirements of the binding mediation as provided for in the Agreement of Sale; 3. The parties shall submit this matter to non-binding mediation within four (4) months ofthe date ofthis Stipulation; 4, The escrow funds held pursuant to Paragraph 1 shall be released in accordance with the decision ofthe mediator without prejudice to either party to pursue litigation. lflitigation is pursued, the outcome of the litigation shan supersede the mediator's decision over the escrow funds and the funds shall be redistributed in accordance with the final judgment. /FEB~:2-2006 WED 11:16 AM Salzmann Hughes,P,C, FAX NO, 7172435178 p, 04 5. The release of the funds shall in no way etIect the right of each party to continue with this legal action for final court adjudication herein unless a written settlement agreement is executed; 6. Nothing in this Stipulation shall limit Plaintiff's right to recover damages in excess ofthe escrow amount and Defendant may assert a counter claim against Plaintiff. 7. Plaintiff waives her right to specific performance against the property. Dated: d . ~ -6fp By E. Ralph frey, Esquire Attorney for Plainti ff Dated: f(,b. 12.lll)~ By ft1it~.u Michael Scherer, Esqllire Attomey for Defendants "'.... .~ {? ) ,"\ -" -~ I , ~.. g ,-,., .- ... -- .. :,'1 C. ~ '<.. +-., .~- ,~> ... VIRGINIA ADAMS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. DOCKET NO: 06-0587 NANCY C. HERLT, individually, in her Own right, and NANCY C. HERLT, EXECUTRIX OF THE ESTATE OF ROBERT WAYNE HERL T, SR. alkla ROBERT W. HERL TY, deceased CIVIL ACTION - LAW PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly marked the above-captioned action settled, discontinued and ended with prejudice. Respectfully submitted, Salzmann Hughes, P.C. By: E. Ralph od ey, Esquire Attorney I.D. o. 354 Alexander Spring Road Carlisle, Pennsylvania 17015 717.249.6333 Rgodfrev@salzmannhughes.com Date: ~2tJ, 2006 Attorneys for Plaintiff, Virginia Adams . .. VIRGINIA ADAMS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. DOCKET NO: 06-0587 NANCY C. HERLT, individually, in her Own right, and NANCY C. HERLT, EXECUTRIX OF THE ESTATE OF ROBERT WAYNE HERL T, SR. alk/a ROBERT W. HERL TY, deceased CIVIL ACTION - LAW CERTIFICATE OF SERVICE AND NOW, this 21/" day of August, 2006, I, Mary M. Cook, Paralegal, of the law firm of Salzmann Hughes, P.C., attorneys for Plaintiff, hereby certify that I served the within Praecipe to Discontinue this day by depositing the same in the United States mail, postage prepaid, in Carlisle, Pennsylvania, addressed to: Michael Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, Pennsylvania 17013 Salzmann Hughes, P.C. 'rY1 M ~ '-yyj. CoOtL. Mary M. ok, Paralegal (') C "2:, -r)1~" n~C: c--.r . ~::' (/~ ~2 ';':;'- f7~-. \:0- ..V'L_ "f :,~ ::.< , r->. """ g;: q , 0" ~ - - - <;f\ .-\ ~~ ..,.,DJ ~fft\' C:'~\ ~? '~~~ ~; /~rn ~~~ 'D ::.c N N