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Home My WebLink About06-2854 GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. tJ{p - ;2~ sY ~ JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LA WYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMA nON 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, P A 17013 Telephone No. (717) 249-3166 GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. tJ~ -;( fel'{ ~-r~ JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants COMPLAINT NOW, comes the Plaintiffs in the above-captioned matter by and through their counsel, SALZMANN HUGHES, P.C., and files this Complaint in an Action to Quiet Title against the above-designated defendants, and in support thereof set forth the following: 1. Plaintiffs, Gerald P. Jones and Marjorie L. Jones, husband and wife, are adult individuals residing at 75 Goodyear Road, Carlisle, Pennsylvania. 2. John H. Jones and Mary E. Jones and the heirs at law of John H. Jones and Mary E. Jones are named Defendants who are unknown and whose present addresses and whereabouts are unknown. Upon reasonable investigation, it is Plaintiffs belief that John H. Jones and Mary E. Jones are deceased although Plaintiff has been unable to confirm this information. 4. Title to the property known and numbered as 381 Kerrsville Road, West Pennsboro Township, Cumberland County, Pennsylvania, hereinafter the "Property", became vested in John H. Jones and Mary E. Jones by Deed from William Miller Davidson's Heirs dated April 24, 1928, being recorded in Cumberland County Deed Book 10, Vol. U, at page 482. A true and correct copy of which is attached hereto as Exhibit "A" and incorporated herein by this reference. 6. John H. Jones and Mary E. Jones conveyed the Property to Edgar C. Myers and Hazel E. Myers by Deed dated March 24, 1946, and recorded in Cumberland County Deed Book 13, Vol. E, at page 81. A true and correct copy of said Deed is attached hereto, marked as Exhibit "B" and incorporated herein by reference. 7. Donald 1. Myers and Jesse E. Myers, Jr., Executors of the Last Will and Testament of Hazel E. Myers conveyed the Property consisting of two (2) tracts to Plaintiffs Gerald P. Jones and Marjorie L. Jones by Deed dated March 3, 2006, and recorded in Cumberland County Deed Book 273 at page 2958. A true and correct copy of said Deed is attached hereto, marked as Exhibit "c" and incorporated herein by reference. 8. Tract 1 conveyed to Plaintiffs by Edgar C. Myers and Hazel E. Myers described in Exhibit "c" contains an approximate ninety four (94) acre tract (hereinafter "Tract I"), being the same tract described in the Davidson to Jones Deed (Exhibit "A") and the Jones to Myers Deed (Exhibit "B"). 9. Tract 2 conveyed to Plaintiffs by the Executors of the Last Will and Testament of Hazel E. Myers described in Exhibit "c" as follows contains an approximate 5.5 acre tract (hereinafter "Tract 2") adjacent to Tract 1: BEGINNING at a point at the Northeast corner of the lands now or formerly of Hazel E. Myers Estate as described in Deed Book "E". Volume 13, Page 81, said point being on the line of lands now or formerly of AC. Kuhn; thence from said point being on the line of the aforementioned lands of AC. Kuhn, approximately on a bearing of South 69 degrees East a distance of 250 feet more or less to a point at the lands now or formerly of Zane R. Highlands and Vicky L. Highlands; thenc~ along said lands of the Highlands, approximately on a bearing of South 7 degrees West a distance of 500 feet more or less; thence by the same, approximately on a bearing of South 3 degrees East a distance of 513 feet more or less, to a point at the lands now or formerly of William S. Graf, Jr. and Alicele E. Graf; thence by said lands of Graf approximately on a bearing of North 84 degrees West a distance of 216 feet more or less to a point at the aforementioned lands of the Hazel E. Myers Estate; thence by said lands North 1 degrees 00 minutes West 816.75 feet more or less; thence by the same North 13 degrees 30 minutes East 136.12 feet more or less to a point at the Place of BEGINNING 10. Tract 2 was depicted on a Survey for Edgar C. Myers of the Property prepared by Thomas A Neff, Surveyor, dated July 5, 1974, and recorded in Cumberland County Plan Book 26, Page 23, and is clearly shown as a single tract with Tract I. 11. Tract 2 is also depicted on the Final Subdivision Plan for Hazel E. Myers of the Property prepared by Larry V. Neidlinger, P.E.R.S., dated May 21, 1996, and recorded in Cumberland County Plan Book 72, Page 120, and shown as appended to Tract I. 12. However, Tract 2 is not depicted on the Preliminary/Final Subdivision Plan for Edgar C. Myers of the Property prepared by John K. Bixler, III, dated December 5, 1989 and recorded in Cumberland County Plan Book 60, Page 105. 12. From on or about March 24, 1946 until March 3, 2006, the date the Property was conveyed to Plaintiffs, Edgar C. Myers and Hazel E. Myers, were in sole possession of the Property which included Tract 1 and Tract 2; paid the real estate taxes associated with the Property which included Tract I and Tract 2; and maintained the entire Property which included Tract I and Tract 2. 13. From on or about March 3, 2006 until present, Plaintiffs have been in sole possession of the Property which includes Tract 1 and Tract 2; have paid the real estate taxes associated with the Property which includes Tract 1 and Tract 2; and have maintained the entire Property which includes Tract 1 and Tract 2. 14. Currently, there is a fence that encloses and connects Tract I and Tract 2 making no distinction between the two parcels. 15. After reasonable investigation, it is Plaintiffs' belief that the fence currently in place has enclosed and connected Tract 1 and Tract 2 since at least on or about March 24, 1946 when the property was conveyed to Edgar C. Myers and Hazel E. Myers until present. 16. Plaintiffs and their predecessors in title, Edgar C. Myers and Hazel E. Myers, have been in possession of both Tract I and Tract 2 from at least March 29, 1946 until present, which said possession has been actual, continuous, exclusive, visible, notorious, distinct and hostile. 17. None of the Defendants have ever made a claim for possession of, or for title to the premises herein described, nor has any action of ejectment or other proceeding ever been instituted to obtain possession. However, Defendants, as heirs of John H. Jones and Mary E. Jones, may assert an interest or claim in the herein described premises. These alleged or purported claims ofthe Defendants may constitute a cloud upon the marketability of the title of Plaintiff. WHEREFORE, Plaintiff prays that a decree be entered forever barring the defendants and their heirs, personal representatives and assigns, from asserting any right, title or interest in or to the real estate described unless within twenty (20) days from the date of the service of the Complaint, the Defendants or their heirs, personal representatives or assigns commence an action in ejectment. Respectfully submitted, SALZMANN HUGHES, P.C By: JI/JdlJp,1O. James D. Hughes, Es uire Supreme Court No.58884 Susann B. Morrison Supreme Court No. 77041 354 Alexander Spring Road, Ste 1 Carlisle, P A 17013 (717) 249-6333 Date: ::r ! f1 Dip VERIFICATION The foregoing document is based upon information that has been gathered by our counsel and ourselves in the preparation of this action. We have read the statements made in this document and they are true and correct to the best of our knowledge, information and belief. We understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. 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V"""'" ft. ,.,.- ,.0 4.. /~ ,$p ..J/dt ~ ~ I,) t -:- 15 I STATE OF PENNSYlVANIA ) COUNTY OF CUMBERLAND ) SS: ON THE 16TH DAY OF FEBRUARY, 46, BEFO .ME WILLIAM DDSH, JUSTICE OF THE PEACE THE UNDERSIGNED OFfiCER, PERSONALLY APPEARED NELLIE. J. SHE , ~AMES W. SHEFfER NolO MARTIN SHEFFER KNOWN TO ME (OR SATISFACTORILY PROV TO BE THE PERSONS WHO AMES ARE SUBSCRIBED TO THE WITHIN INSTRUMENT AND ACKNOWLEDGED THAT T Y HAVE eXECUTED THE SAME F('fl T CONTAINED, Jt.lO DESIRED HE SAME Ma,GHT BE R OED /oS srnCH. IN WITNESS EREDF, I HEREUNTO SET MY // WILLIAM DOSH J. P. CmNd. EXP. JAN., 1950 PA. R. O. ), /' THE ADORESS OF THE WITHIN-NAMED GRANTEE OAl( G. SHUGHART ON BEHALF OF THE GRANTEE NO: 1484. THIS DEED, MADE THE 29TH DAY or MARCH IN THE YEAR Of ~; ~~;~T~,: iN 'NE.TEEN HUNOOED AND fGHY-S1X (1946) BETWEEN JOHN H. JONES OEEEl ~ '1~~Jn"~l AND MARY E. JONES, HIS WIFE, OF WEST PENNSBOOO TOWNSHIP, JOHN H. JONES, ET UX ! )~42'!1 COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, PARTIES OF TO: ~.-.. tHE FIRST PART J AND EDGAR C. MYERS ANO HAZEL E. MYE~~, HIS EDGAR C. MYERS, E1 UX ~w In, OF ' CONS: 84650.00 , ~ WITNESSETH, THAT IN CONSIDERATIoN of lHE SUM OF fOUR THOUSAND SIX LOCI WEsT PENNSBORO TWP. , HUNDRED AND FIFTY (84650.00) DOLLARS, IN HAND PAID, THE RECEIPT ...'E"EOF DATO: WoRCH 29, lsv.,6 0 IS HEREBY ACKNOWLEDGED, THE SAID GRANTORS DO HEREBY GRANT AND COOVEY E.J1IQ.:J1ARr:1-l ?q, 1Cll..6 Q TO THE SAID GRANTEES ALL THAT CERTAIN TRACT OF LAND LYING ANO BEING SITUATE IN THE TOWNSHIP OF WEST PENNSBORO, COUNTY Of CUMBERLAND ANJ STATr---or PENNSYLVANIA, BouNOE:D AND DEsCRIBED AS FOLLOWS: BEGINNING AT A STONE; THENCE BY LANDS OF GOODHART HEIRS SOUTH THIRTY-EIGHT ()8) DEGREES EAST TWENTY-FIVE (2~) PERCt€S TO A POST; THENCE BY SME SOOTH EIGHTY (ao) DEGREES EAST FIFTY-fiVE AND S ,X TENTHS (55.6) PERCHES TO A POST; THENCE BY SA'-E SOUTH THIRTY-SIX ()6) DEGREES EAST THIRTY ANDFIVE TENTHS ()0.5) PERCHES TO A POST; THHt:E BY LANOS OF IJC KEEHAN HEIRS NORTH EICHTY-SIX (86) DEGREES EAST FORTY-NINE (49) PERCHES TO A STONE; THEfl::E BY THE SAI.f: NORTH EIGHTY-NINE (AND ONE-HALF (8~) DEGREES EAST FORTY-FOUR AND ONE-HALF (44~) PERCHES TO A POST; THENCE BY THE SAME NORTH TEN AND ONE-HALF (1O}) DEGREES WEST FIFTEEN (15) PERCHES TO A POST; THENCE BY LANDS OF WARREN t.C KEEHAN NORTH EIGHTY-TWO (82) OEGREES WEST THIRTY- ONE AND EIGHT TENTH ()1.8) PERCHES TO A POST; THENCE BY THE SA'-E NORTH SIX AND mE-HALF (6b-) DEGREES WEST FORTY-NINE (49) PERCHES TO A STONE; THENCE BY THE SAME NORTH ONE (11' DEGREE WEST FORTY-NINE AND FIVE-TENTH (49.5) PERCHES TO A POINT; THENCE BY THE SA~''E NOOTH T~ilRTEEN AND ONE-HALf (13.f!) DEGREES EAST EIGHT AND ONE-fOURTH )"1.:) PERCHES TO A POST; THENCE BY LANDS OF MARY M. BOSLER AND NORTH FIFTY-NINE (59) DEGREES WEST SEVENTY-SIX (76) PERCHES TO A POST; THENCE BY THE SA'-'E SOUTH EIGHTY-fOUR (84) DEGREES WEST fOURTEn AND TWO TENTH )14.2) PERCHES TO A POST; THENCE BY LANDS OF CHAS. RADABAUGH SOUTH TEN AND ONE-HALf Cla}) DEGREES EAST SIXTY (60) PERCHES TO A POST; THENCE BY THE SAME SOUTH EIGHTY-FOUR (84) DEGREES WEST THIRTY-ONE AND FIVE TENTH ()1.5) PERCHES TO A POST; THENCE BY LAND OF BOSLER HEIRS SOUTH FO~ AND Ort-HALF (4~) DEGREE S EAST FORTY-ONE (41) PERCHES TO A STIlNE; THENCE BY THE SA!.!: NORTH EIGHTY (80) DEGREES EAST THIRTY-ONE ()1) PERCHES TO A POST; THENCE BY THE SA!.!: SaJTH ONE-HALF (~) DEGREE EAST TEN (10) PERCHES TO A LOCUST; THENCE BY THE SAME SOUTH FIFTY-TWO (52) DEGREES EAST TWO (2) PERCHES TO A POST; THENCE BY TF:IE SAME NOOTH EIGHTY-NINE (89) DEGREES EAST THIRTY- TWO ()2) PERCI-ES TO A POINT; THENCE NORTH FIFTY-TWO (52) DEGREES EAST TWO (2) PERCHES TO A POINT; THENCE BYTHE SA~E NORTH EIGHTY-FOUR (84) DEc-REE.S WEST THIRTY-SJX ()6) PERCHES TO ~TONE; THENCE SOUTH EIGHTY- TWO (82) DEGREES WEST THIRTE.EN (1)) PERCHES TO A STONE, THE PLACE Of BEGINNING. C(}.lTAINING NINETY- FOUR (94) ACRES AND SEVENTEEN (17) PERCHES ACCORDING TO SURVEY MADE BY S. O. MOWERY, MARCH 2., 1928. IT BE ING THE SAME TRACT OF LAND WHICH MARGARET S. CORsS AND W. U. C~OSS, HIS WIFE, ET AL BY THEIR DEED BEARING DATE THE Z4TH DAY OF APRIL, 1928, SAID DEED BEING ENTERED OF REODRD IN THE OFFICE OF THE RECORDllR OF DEEDS AT CARLISLE, PENNSYLVANIA, IN DEED BOOK 'U', VOL. 10, PAGE 4BO GRANTED AND Cr1NVEYED UNTO JOHN H. JONES, ONE OF THE GRANTcrtS HEREIN. AND THE SAID GRANTORS WILL WARRANT GENERALLY THE PROPERTY HEREBY CONVEYED. IN WITNESS WHEREOF, SAID GRANTORS HAVE HEREUNTO SET THEIR HANDS AND SEALS, THE DAY AND YEAR FIRST ABOVE-WR ITTEN. SEALED AND DELIVERED I N THE PRESENCE Of ANNA B. BARR ICK JOHN H. UONES (SEAL) MARY E. JONES (SEAL) STATE OF PENNSYLVANIA COUNT Y OF CUMBERLAND ) SS: , ,: ON THIS: 29TH DAY OF MARCH A. D. 1946, BEfCRE ME A NOTARY PUBLIC IN AND FOR SAID COLNTY AND ...~t'....., STATE, PERS'ONALLY CAME THE ABO\[-NAMED JOHN H. JONES AND MARY L JON~SJ' . WifE. AND ACKNOWLEDGED THE fOREGOING DEED TO BE THEIR ACT AND DEED, AND DESIRED THE SAME TO BE"\.Rf:' ROED AS SUCH. WITNESS MY HAND AND NoTARIAL SEAL, THE DAY AND YEM ~IiORE:S~,D. AN~'A B. N. P. COW. EXP> EXHIBIT B 'iJ. -7. :-x- ~ ':J) SI",..'\ 2 Tax Parcel No.: 46-09-0521-045 TIDS INDENTURE r/, -1, fJ? ~: ..-:! MADE THE./ day of -:TwlirThousand Six (2006) ~ '.. e:;::BETWEEN Donald I. Myers and Jesse E. Myers, Jr., Executors of the Last Will and ". Testaihent of HAZEL E. MYERS, late of West Pennsboro TO'Mlship, Cumberland County, .Pennsy.wania, hereinafter called .,,', c, ,-! ..' cC = f':: '-1 'f 1.1 fll :.n- fl/ f4i >t, I . in the year of our Lord GRANTORS, t'.'.. c-<7~ XND GERALD P. JONES and MARJORIE L. JONES, husband and wife, of West Pennsboro Township, Cumberland County, Pennsylvania, hereinafter called GRANTEES, WHEREAS, Hazel E. Myers, at her death, o'Mled the real estate hereinafter described, with buildings and improvements thereon situate in West Pennsooro Township, County of Cumberland, Commonwealth of Pennsylvania, knO'Ml as 381 Kerrsville Road, Carlisle, Pennsylvania; and WHEREAS, Hazel E. Myers, died testate on June 23, 2005, and by her Last Will and Testament dated February 13, 1992, duly proved and registered in the Office of the Register of Wills in and for Cumberland County, Pennsylvania, at Estate Proceedings No. 21-05-0664, named her son, Donald 1. Myers, and her grandson, Jesse E. Myers, Jr., as Executors of said Last Will and Testament; and WHEREAS, Letters Testamentary were issued to the said Executors on July 26, 2005, which Letters Testamentary remain in full force and effect; and WHEREAS, by Item IV, Donald 1. Myers was granted an option to purchase said real estate and, by the signing of this Deed, the said Donald 1. Myers acknowledges that he did not exercise said option within the allotted time and does not desire to exercise the option granted by this ItemN. NOW THIS INDENTURE WITNESSETH, that the said Donald I. Myers and Jesse E. Myers, Jr., by power vested in them by 20 Pa, C.S.A. ~ 3351, for and in consideration of the 8001 f}}'."':' ;...", ,.) " , - .'--s r::(} (Mi..;'.:~, '...X:J EXHIBIT C sum of Four Hundred Thousand and no/100 ($400,000.00) Dollars, lawful money of the United States, to them in hand paid by the said Grantees at and before the sealing and delivery hereof, the receipt whereofis hereby acknowledged, have granted, bargained, sold, aliened, released and conflID1ed, and by these presents, do grant, bargain, sel!, alien, release and confirm unto the said Grantees, their heirs and assigns as tenants by the entirety, TRACT 1: ALL TIfA T CERTAIN tract offannland with the buildings and improvements thereon erected, situate in West Pennsboro Township, Cumberland County, State of Pennsylvania, bounded and described as follows: BEGINNING at a stone; thence by lands now or formerly of Goodhart Heirs, South 38 degrees East 412.5 feet to a post; thence by the same, South 80 degrees East 55.6 917.4 feet to a post; thence by the same, South 36 degrees East 503.25 feet to a post; thence by lands now or formerly of McKeehan Heirs, North 86 degrees East 8085 to a stone; thence by the same, North 89 Yz degrees East 734.25 feet to a post; thence by the same, North 10 Yz degrees West 247.5 feet to a post; thence by lands now or formerly of Warren McKeehan, North 82 degrees West 524.7 feet to a post; thence by the same, North 6 Yz degrees West 808.5 feet to a stone; thence by the same, North 1 degrees West 816.75 feetto a point; thence by the same, North 13 Yz degrees East 136.13 feet to a post; thence by lands now or formerly ofMmyM. Bosler, North 59 degrees West ],254 feet to a post; thence by the same, South 84 degrees West 234.30 feet to a post; thence by lands now or formerly of Chas. Radabaugh, South 10 Yz degrees East 990 feet to a post; thence by the same, South 84 degrees West 5] 9.75 feet to a post; thence by land now or formerly of Bosler Heirs, South 4 Y, degrees East 6765 feet to a stone; thence by the same, North 80 degrees East 5] 1.5 feet to a post; thence by the same, South Y, degrees East 165 feet to a Locust; thence by the same, South 52 degrees East 33 feet to a post; thence by the same, North 89 degrees East 528 feet to a point; thence North 52 degrees East 33 feet to a point; thence by the same, North 84 degrees West 594 feet to a stone; thence, South 82 degrees West 2]4.5 feet to a stone, the Place of BEGINNING. CONTAINING 94 acres and 17 perches according to a survey made by S. D. Mowery, dated March 24, 1928. KNOWN AS and numbered 381 Kerrsville Road, Carlisle, Pennsylvania 17013. BEING the same tract ofland which John H. Jones and Mary E. Jones, his wife, by their Deed dated March 29, 1946, and recorded in Cumberland County Deed Book "E", Volume 13, Page 8], granted and conveyed to Edgar C. Myers and Hazel E. Myers, his wife. The said Edgar C. Myers died on the 14th day of October, 1994, thereby vesting fee simple title, by operation of law, in the said Hazel E. Myers. B,'l,.:~)'.~', f)7:Z P\.........,..c~ ~;(1 . - Jf"".V'''''::':;'.::Jvw TRACT 2: Any and all right, title and interest which the Estate of Hazel E. Myers may have in ALL THAT CERTAIN tract ofland lying and being situate in the TOMlShip of West Pennsboro, County of Cumberland, State of Pennsylvania, bounded and described as follows: BEGINNING at a point at the Northeast corner of the lands now or formerly of Hazel E. Myers Estate as described in Deed Book "E", Volume 13, Page 81, said point being on the line of lands now or formerly of A. C. Kuhn; thence from said point of beginning and along the line of the aforementioned lands of A. C. Kuhn, approximately on a bearing of South 69 degrees East a distance of 250 feet more or less to a point at the lands now or formerly of Zane R. Highlands and Vicky L. Highlands; thence along said lands of the Highlands, approximately on a bearing of South 7 degrees West a distance of 500 feet more or less; thence by the same, approXimately on a bearing of South 3 degrees East a distance of 513 feet more or less, to a point at the lands now or formerly of William S. Graf, Jr. and Alicele E. Graf; thence by said lands of Grafapproximately on a bearing of North 8-1 degrees West a distance of216 feet more or less to a point at the aforernentioned lands of the Hazel E. Myers Estate; thence along said lands North 6 degrees 30 minutes West 132 teet more or less; thence by the same, North 1 degrees 00 minutes West 816.75 feet more or less; thence by the same, North 13 degrees 30 minutes East 136.12 feet more or less to a point at the Place of BEGINNING. CONTAINING 5.5 acres rnore or less. BEING described as " Wetlands" on Final Subdivision Plan for Hazel E. Myers by Larry V Neidlinger, P.E.R.S., dated May 21,1996, and recorded in Cumberland County Plan Book 72 Page 120. UNDER AND SUBJECT TO ALL RESTRICTIONS AND CONDITIONS OF RECORD. The issue of Jesse E. Myers, namely, Stephen Myers, David Myers, Susan Myers, Kimberly Myers and Jesse E. Myers, Jr. join in this deed to convey any right, title and interest they rnay have in this TRACT 2 of the demised property. EXCLUDING HEREFROM FROM ALL THOSE CERTAIN TRACTS OF LAND INCLUDED IN TRACT 1 HEREINBEFORE DESCRIBED WHICH HAVE PREVIOUSLY BE CONVEYED BY EDGAR C. MYERS AND/OR HAZEL E. MYERS: NAME Walter K. Garman DATE 10/2/1967 10/25/1973 RECORDING INFORMATION Deed Book "N", Volume 22, Page 321 Deed Book "K", Volume 25, Page 108 B. Edwin L. Minnich 'B_n'v-- r;:,,"') n.....~f"'.'r'_{"\..~ ~Ju}\ ,r(-/u ;-'lLtJ\.~n;1: Jesse E. Myers 2/20/1975 Deed Book "Y", Volume 25, Page 503 Donald 1. Myers 3/24/1975 Deed Book "Z", Volume 25, Page 360 Gary L. McCalister 7/1111975 Deed Book "D", Volume 26, Page 536. John F. Eppley 10/31/1978 Deed Book "C", Volume 28, Page 942 Donald 1. Myers 2/2/1982 Deed Book "R", Volume 29, Page 583 Donald 1. Myers 1/25/1984 Deed Book "N", Volume 30, Page 781 Donald I. Myers 3/8/1988 Deed Book "F", Volume 33, Page 540 Brenda J. Myers 5/5/1989 Deed Book "X", Volume 33, Page 1089 David L. Myers 6/8/1989 Deed Book "2", Volume 33, Page 572 David L. Myers 7/9/1990 Deed Book "Q", Volume 34, Page 1077 Suzette A. Shultz 7/9/1990 Deed Book "Q", Volume 34, Page 1081 Daryl L. Hurley 7/2511990 Deed Book "R", Volume 34, Page 769 Donald 1. Myers 8/23/1996 Deed Book 144, Page 929 TOGETHER with all and singular the buildings, improvements, ways, waters, water- courses, rights, liberties, privileges, hereditaments and appurtenances whatsoever thereunto belonging, or in anyway appertaining, and the reversions and remainders, rents, issues and profits thereof; and also, all the estate, right, title, interest, use, trust, property, possession, claim and demand whatsoever, ofthe said Hazel E. Myers at and immediately before the time of her death, in law equity or otherwise howsoever, of, in, to or out of the same: TO HAVE AND TO HOLD, the said buildings, improvements, hereditaments and prernises hereby granted and released, or mentioned and intended so to be, with the appurtenances, unto the said, Grantees, their heirs and assigns, to and for the only proper use and behoof of the said Grantees, their heirs and/or assigns forever. And the said Grantors do covenant, promise, and agree, to and with the said Grantees, their heirs and assigns, by these presents, that the said Grantors have not done, committed, or knowingly or willingly suffered to be done or committed, any act, matter or thing whatsoever whereby the premises hereby granted, or any part thereof, is, are, shall or may be impeached, charged or encumbered, in title, charge, estate, or otherwise howsoever. WITNESS the due execution hereof the day, month and year first above written.. Bej"" ";1~/""') t!.",.rC,,.....1 . . !~r, ~. 0 i iI~:~;:, ...)lQ.;..o., WITNr~81l r2itl(~) /J J /+ II /))1' if f-- ell'll/ I \...9 ,....),(i ,,"t. i' ,- \) fe- . ' .- : \ ) __~\ \ \ J, . . \._~ ~, \.. ) ,. ''''-on'/ ~.J[..".l-'''''' r-'".., ',' , '7' \., 0' '" o/")h' i 1 ,- 'T , \..... ,I , . // ..,/ J., ,) 'y-'7 f vC J\}j\j ,/ (( ::.A"'(i C- . /"j "\ I(~! (1 /,/1 /1 " ,~ ;(' .1 L1 ;" / r,' I ~ I ./(, ''1'.( / I I-;J ,,,..-Jet).! ' L ~(' . I,~, " I' " , ,)v f- (.::J.C4.'-L ESTATE OF HAZEL E. MYERS (1 [ rlrr (" (;,,0 (SEAL) Donald.!.. Myers, ndividually and as Executor y1 (SEAL) (SEAL) (SEAL) ../ COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) ,zfJb 'A .' On this, the /' day of ~1A fA c.! f . 2006, before me, the undersigned officer, personally appeared Donald:L. Myers and Jesse E. Myers, Jr., Executors of the Estate of Hazel E. Myers, known to me (or satisfactorily proven) to be the persons whose names are subscribed to the within instrument, and acknowledged that they executed the same for the purposes therein contained. BiiGt '21'7:'~ ',,'V6""Q.......~~ J' ..~ v 1M.\.;C,;;:: '...J (,).<:' IN WITNESS WHEREOF, I hereunto set my hand and official seal. //, +':'\). ., ,. (.' k ;...., /t, ,i :f ,./Ore1j ! ly ..:JA'~l/'1- Notary Public (SEAL) COMMONWEALTH OF PENNSYLVANIA Notarial Seal RobM R. Black. Notary Putlffe Carlisle BORl. Cumbedend COIlnil' My Commission Expires Sept. 28. 2lI09 CERTIFICATE OF RESIDENCE I do hereby certify that the precise residence and complete p~ office address of the within named Grantee is: "1)" ~f:leAr ~& / . ?~ ItJ/ (~I,jl<P~I'1~I/')~' / Date: .> /0 )C? ! / l' . I / Attorne.)Lfor / COMMONWEALTH OF PENNSYL V ANlA I I I / \) / "->._/ SS. ) COUNTY OF CUMBERLAND Recorded on this day of . A.D. 2006, in the Recorder's Office of the said County, in Deed Book . Page Given under my hand and seal of the said office, the date above written, . Recorder nnD-~ r"\:--."'- ~~ '-1u/ ,", .G I,\' P,l:\t~r'ql':'t'; ...." <.;-;.:..;vU;..;t COMMONWEALm OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) On this. the /64)J-- day of It! fhCZCK .2006. before me, the undersigned otlicer. perscma1ly ~ David Myers. Susan M,ers and Kimberly Myers, known to me (or -ti..f'-torily proven) to be the person(s) whose name(s) islare subsen'bed to the within iDsIrumeDt. andacknowledged thai: heJsbt/they execok:d the same fur the purposes therein contained. 58. IN WITNESS WHEREOF, I hacwOO set my hand and official seal. /7;{ 0"1 '1 JU' ,...:). if;' . ('Iv?, ,0. 'I I !I.V' ~v'-V~ I ,I . Notmy Public (SEAL) COMMONWEALTH OF PENNSYLVANIA Notarial Seal Robert R. Black. Notary Public Carlisle Boro: Cumberland County My Commission Expires Sept. 28. 2009 :..'e.. ~,: :;;.;- \;\ ~.-' Bof~t. 273 p,lcr29G4 ..;! WITNESS <", ,'~'~:;':~/' STEPHEN MYERS I STATE OF KENTUCKY ) COUNTY OF ~ : ss. ) On this, the ~ day of March, 2006, before me, the undersigned officer, personally appeared STEPHEN MYERS, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that hey executed same for the purposes therein contained. IN WITNESS WHEREOF. I hereunto set my hand and fficial seal. . 'UI (;u_r~_: L<:': r (...>_ ,~.., ;,....:()Ull D u\ ,.," ~L_r:: 1'J ,\;-'~; 1- ; .....~,. ,'] 1:I\l."':}.-l /' is-/ ~::; I' ,.-, ofDcf:ds BOO~ 273 PA~E2S65 ~ , " ~ (~\~ <-, 0 '.-:::~ ~. C~;) -n c.;.... 'llI. ft- , ....... :1" \~ ~"" \\:j ~ r11p::: -- -fJrn y --J ~ -:rJ CP \':~(> , - , 1..;;;; ~ ~ -0 '.~'t':. -j . . (),~ ~ , ~ . - ~;ln ~ , .." W .. ':'0 "\ '-;l 1') '< ,-'.... cr. ~ GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. O{r:O S'{ C;;..t k.- JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants PETITION FOR LEAVE FOR SERVICE BY PUBLICATION 1. Petitioners Gerald P. Jones and Marjorie 1. Jones, by and through their legal counsel, Salzmann Hughes, P.C., filed with the Prothonotary of Cumberland County an action to quiet title whereby they requested that title to the following tract of ground be quieted and that it be determined that they have sole fee simple title to the same. ALL THAT CERTAIN tract of land lying and being situate in the Township of West Pennsboro, County of Cumberland, Commonweatlh of Pennsylvania, bounded and described as follows: BEGINNING at a point at the Northeast corner of the lands now or formerly of Hazel E. Myers Estate as described in Deed Book "E", Volume 13, Page 81, said point being on the line of lands now or formerly of A.C. Kuhn; thence from said point of beginning and along the line of the aforementioned lands of A.C. Kuhn, approximately on a bearing of South 69 degrees East a distance of 250 feet more or less to a point at the lands now or formerly of Zane R. Highlands and Vicky 1. Highlands; thence along said lands of the Highlands, approximately on a bearing of South 7 degrees East a distance of 513 feet more or less, to a point at the lands now or formerly of William S. Graf, Jr. and Alicele E. Graf; thence by said lands of Graf approximately on a bearing of North 84 degrees West a distance of 216 feet more or less to a point at the aforementioned lands of the Hazel E. Myers Estate; thence along said lands North 6 degrees 30 minutes West 132 feet more or less; thence by the same, North 1 degrees 00 minutes West 816.75 feet more or less; thence by the same, North 13 degrees 30 minutes East 136.12 feet more or less to a point at the Place of Beginning. CONTAINING 5.5 acres more or less. 2. The Petitioners, after making a diligent search and inquiry, have been unable to ascertain the existence and present location of the Defendants and any additional heirs who may have a claim of interest to the above-described premises. WHEREFORE, the Petitioners respectfully asks leave of court to obtain service of the Complaint in the instant matter upon the Respondents by publication pursuant to Cumberland County Rule 1009-1, Rule 1066-1, Rule 1066-2, Rule 1066-3 and rule 1066-4. Respectfully submitted, SALZMANN HUGHES, P.C. By: J0cuuJs ~ James D. Hughes, Esquire Supreme Court No.58884 Susann B. Morrison, Esquire Supreme Court No. 77041 354 Alexander Spring Road, Ste I Carlisle, PA 17013 (717) 249-6333 Attorneys for Plaintiff VERIFICATION The foregoing document is based upon information that has been gathered by our counsel and ourselves in the preparation of this action. We have read the statements made in this document and they are true and correct to the best of our knowledge, information and belief. We understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. ~ 4904, relating to unsworn falsification to authorities. C~L- GERALD P. JO S Date: ~1(ifOlJ " Cl c:;, ....,.. ""'\'.. "i \.:~," ~,~ _.' ~.;, ...~ ~ * ~ :...<' '. -(t,~ : \.;:'.'. '~,'.' I ,.~~~ L.<. 'F~t" .::.<. '* ~~ ~q, ...... ,~)~~:\" cP :." '" .~.'0 l3 .~ ;k -0 -;Jf. t?- v:> o GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-2854 CIVIL JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants PRAECIPE TO REINST ATE TO THE PROTHONOTARY: Please reinstate the Complaint filed by Plaintiffs in the above captioned matter. Respectfully submitted, SALZMANN HUGHES, P.C. By c{0_~,~ Supreme Court No.58884 Susann B. Morrison, Esquire Supreme Court No. 77041 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 (717) 249-6333 Attorney for Plaintiffs Date U/!r/DLt , 0 "" C> (::::::;) c- t~ -~1 <:;.;S'"" "'Tj ('; C_ -< s:; :r:...,., \~l ! I rnF -'," ('T; r::::: U; -C' -i-, -'-" C- ;" N co ....., <. GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants AMENDED PETITION FOR LEAVE FOR SERVICE BY PUBLICATION 1. Petitioners Gerald P. Jones and Marjorie L. Jones, by and through their legal counsel, Salzmann Hughes, P.c., filed with the Prothonotary of Cumberland County an action to quiet title whereby they requested that title to the following tract of ground be quieted and that it be determined that they have sole fee simple title to the same. ALL THAT CERTAIN tract of land lying and being situate in the Township of West Pennsboro, County of Cumberland, Commonweatlh of Pennsylvania, bounded and described as follows: BEGINNING at a point at the Northeast comer of the lands now or formerly of Hazel E. Myers Estate as described in Deed Book "E", Volume 13, Page 81, said point being on the line of lands now or formerly of A.C. Kuhn; thence from said point of beginning and along the line of the aforementioned lands of A.C. Kuhn, approximately on a bearing of South 69 degrees East a distance of 250 feet more or less to a point at the lands now or formerly of Zane R. Highlands and Vicky L. Highlands; thence along said lands of the Highlands, approximately on a bearing of South 7 degrees East a distance of 513 feet more or less, to a point at the lands now or formerly of William S. Graf, Jr. and Alicele E. Graf; thence by said lands of Grafapproximately on a bearing of North 84 degrees West a distance of 216 feet more or less to a point at the aforementioned lands of the Hazel E. Myers Estate; thence along said lands North 6 degrees 30 minutes West 132 feet more or less; thence by the same, North 1 degrees 00 minutes West 816.75 feet more or less; thence by the same, North 13 degrees 30 minutes East 136.12 feet more or less to a point at the Place of Beginning. CONTAINING 5.5 acres more or less. 2. The Petitioners, after making a diligent search and inquiry, have been unable to ascertain the existence and present location of several heirs of John H. Jones and Mary E. Jones who may have a claim of interest to the above-described premises. (See the Affidavit attached hereto and incorporated herein as Exhibit A). 3. Furthermore, it is anticipated that there will be no response from several of the Jones heirs to whom correspondence, an acceptance of service and copy of the complaint was sent. WHEREFORE, the Petitioners respectfully asks leave of court to obtain service of the Complaint in the instant matter upon the Defendants of unknown location and by whom no response is received by publication pursuant to Cumberland County Rule 1009-1, Rule 1066-1, Rule 1066-2, Rule 1066-3 and rule 1066-4. Respectfully submitted, SALZMANN HUGHES, P.C. By:)kJl1J. ~ja James D. Hug es, quire Supreme Court No.58884 Susann B. Morrison, Esquire Supreme Court No. 77041 354 Alexander Spring Road, Ste 1 Carlisle, P A 17013 (717) 249-6333 Attorneys for Plaintiff GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants AFFIDA VIT NOW, comes Susann B. Morrison, Esquire, Affiant, who being duly deposed, does state the following: 1. On May 18, 2006, Plaintiffs filed a Complaint in an Action to Quiet Title to 5.5 acres ofa 99.5 acre tract ofland known as 381 Kerrsville Road, West Pennsboro Township, Cumberland County, Pennsylvania, conveyed to Plaintiffs by Donald I. Myers and Jesse E. Myers, Jr., Executors of the Last Will and Testament of Hazel E. Myers, by Deed dated March 3, 2006. 2. On May 18, 2006, Plaintiffs filed a Petition for Leave of Service by Publication requesting the Court to allow Plaintiff to serve the Complaint in an Action to Quiet Title against Defendants by publication. 2. On behalf of Plaintiffs, a diligent search has been made to obtain addresses or whereabouts of John H. Jones, Mary E. Jones and/or their heirs. 3. An estate search was conducted at the Cumberland County Register of Wills to determine if an estate was opened in Cumberland County for either John H. Jones or Mary E. EXHIBIT A .. Jones between 1946 when John H. Jones and Mary E. Jones conveyed the Property to Edgar C. Myers and Hazel E. Myers until present. 4. The estate search revealed an estate in the name of John H. Jones with a widow by the name of Mary E. Jones and eight (8) children. 5. The estate search revealed an estate in the name of Mary E. Jones listing the same children as the estate in the name of John H. Jones. 6. On behalf of Plaintiffs, the undersigned did contact Donald Myers, the son of prior owners of the subject property, Edgar C. Myers and Hazel E. Myers, who provided an address for Donald Jones, who he believed to be the grandson of John H. Jones and Mary E. Jones. 7. On May 1, 2006, correspondence was sent to Donald Jones at the address where it is believed he resides explaining the situation and requesting he provide the names and addresses of John H. Jones and Mary E. Jones and their heirs. No response has been received to date. 8. Of the heirs found in the estate searches for John H. Jones and Mary E. Jones, addresses were found in the Cumberland County telephone book in the following names: Robert Jones, Norman Jones and Dale Jones. 8. On June 1,2006, correspondence was sent to Robert Jones, Norman Jones and Dale Jones at the addresses found in the telephone book explaining the situation and requesting they contact the undersigned if they are relatives of John H. Jones and Mary E. Jones. 9. On June 12,2006, the undersigned met with Dale Jones, a grandson of John H. Jones and Mary E. Jones, who provided a detailed family history with several addresses. 10. According to Dale Jones, all of the children of John H. Jones and Mary E. Jones are deceased and there are twenty-nine (29) living grandchildren and seven (7) confirmed deceased grandchildren, with two (2) of the deceased grandchildren leaving six (6) surviving issue among them. 11. On June 15, 2006, the undersigned sent correspondence along with an acceptance of service and a copy of the complaint to thirty (30) of the Jones heirs for whom contact information was obtained. 12. After speaking with several relatives of John H. Jones and Mary E. Jones, the whereabouts of any other heirs of John H. Jones and Mary E. Jones are unknown. ~tLU Sworn to and SubsCriid before me l(.j -- This .1 y of (.J U./lL.- , 2006 f;(l/1f#~ f1f=- Not Publi Notarial Seal KIndy L. Coyle, Notary Public C.rll. Boro, ClITIberland County My Commlsslon Expires July 3. 2006 Member, Pennsytvania Association Of Notaries :~,~ ~ ri", 21 ~n!'i-: .. ,---, f'.' o I...::' < ',- --~ ;-j I.i) C:::: .'D -< (..I :. '. 5 J lJ j\J 5~ 2U06 GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs I '.' rt t - . L::.~_~_'._~__""'-'-'_" -....:..c':::="":~-'~-:::::: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ORDER OF COURT '\~ AND NOW, this 't 1 day of J U ~ t. ,2006, upon consideration of the foregoing Petition it is hereby Ordered that service of this Complaint and other related matters, in an action to quiet title be permitted upon the Defendants generally, by publication pursuant to Cumberland County Rule 1009-1, Rule 1066-1, Rule 1066-2, Rule 1066-3, and Rule 1066-4. Said publications shall be by public notice with one publication in a newspaper of general circulation in Cumberland County and one publication in the Cumberland Law JournaL The Plaintiff/Petitioner is directed to obtain service in accordance with the applicable rules on all individuals whose addresses and whereabouts can be determined after a diligent search. If no answer is filed or appearance is made, a judgment by default may be taken against the aforesaid Defendants/Respondents, their heirs, personal representatives or assigns. BY THE COURT, '\~ ~\ J. so :2 \ \d LZ rc\(' SI}ul GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, P A 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: 6-;. 9- 06 ~/ ?f j._A_ S ignat e Printed/typed name: L /6 v J f? . T;.,;v ~_S' I ~ () -(1 +-7 c:=:; ;.1 c', o -.:.-- . '.;2 o ~. GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: 1/11/06 s~J~~ ~ Printed/typed name: !:/fA k.r> -II. A, :;;f1U ') :'-';:1 :-~ (-:-::; \\7"\ ~ ,) r.5 c:::) r..:: GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service ofthe Complaint - Action to Quiet Title iri the above-captioned matter. Date: ro I;::t{ lab I . / ~~~) ignature V Printed/typed name: ,~\eH-a \)("f'tG'<; F~er :.:!j~~~~,~~;)1!;wfd'",-, , .",.~..t.~/~~f!k'""" ,., -r. i- o ~:; (:=: (.~) C~ ....(:.7 Cl r<; GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, P A 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: 0 /p - ~ 1- !J I;; m.~l~ Signature. Printed/typed name: if Loll i5~ !h0f'eJd c_ (-- c..~) o () -n --1 ~>i~l -71" , 'C ?:~' 'J) o r....:;: GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: t. - :2 h- 6 c:. Printed/typed name: J:$~ \J,1h '" <) , 12; Ie iJ t.::.~, tj~ C) ~.,1 ''''' L.. c..) o , () '.. :7.';':~ .> o t"; GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, P A 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: ~..........-..L- .:1-3. ~ro , s~r1'r If. ~ Printed/typed name: GLAblS CeSH-#11R-N -' (") ~.\''', ,-\ ~G\ :fJ , ~.. o ".", c::; \. GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Printed/typed name: ~ b). Date: 0-a1-- d:: c ,.- ':- '~'. r:;?, ,,>:;-,~ '.0:;" c~\ {,:: (;;> \',' GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, P A 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: ~ -2/-0 i:, Printed/typed name: .l1:t. r {e n<!:.. /Jo&n ~",_.,.." "'>I.m..' :C:' ,~, ~ ,,~ti~~~ :::-:~ c;.-, <') ~ 'i.l .-;' (,.'," CJ \,_'=' c:) ~-n r--J .~ GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.c. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title In the above-captioned matter. Dat51 7 ~(, . I printed/typedname:9~. ~7' ~r? J.s:::J..IV~ r-.:t (_) l~:,:" ~~h ,.::;:::;' v"~ c,) CJ ~? c' r'<) GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE O}<' SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Jo Printed/typed name: ignature .MCc y J {/Jt:S j!r,rdlel/Jl/j f~iI._,*" ", ~, c." r;~ c':> c;.) GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Dcfendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, P A 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: .....~4/r ;}p, c;;/tJo/' , ~, S)") 1:0:{, '~ Q' (,) (:,) I...e 0, (". GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, P A 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. D'''9-/ . /1:001& o? s;"",(: ~ =h. 7f7l Printed/typed name: L j, vA r. r IJ E r (";. f~,_ \'"'-.) ~~) ~,/, ,,<> Co ;:~ .-I -;:...,..,. iC;\)~:, \-.:' CJ {'. GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.c. 354 Alexander Spring Road, Ste 1 Carlisle, P A 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned mattei. Date: I- D'1- . :< d. ?,Mk , ~~ C'3"/~) . Signatu Printed/typed name: -:;;;1C~ C. 2e:y J e'/ Cl (,r -;/ .--('"\'.' r-' ~~ ~, .;,> (~\ e;) o ~,~'" ~ ,-p- O t':, GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: .JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: !) b - ;) rJ - J 12 Signat~ W d!f Printed/typed name: DrJffis WoJ--F ~~i.~ij:~,j~;;g.,; r:; <2 ~j~ :",..- ,.- r.....') o .~: ....;:' CJ \".~: GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, P A 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: .~/21/p'} ~-~~ ignature . Printed/typed name: /1',01,,1/ a;... --:S;;;AJ~ .~ c~ .....' C-~ c:.'" <::;/" (") ":n :-::1 .L \'\1 c.) CJ ~ C) f'-':':: GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2854 . , JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service ofthe Complaint - Action to Quiet Title in the above-captioned matter. Date: !;; - 80,0 f..o jI ,.tad l (bJ'.;t;j Signature H eJtrl J, C()f Derrk r I Printed/typed name: ~'I'C' ::""""""'""'-",....-'.:'",,;,,.:'...,..,> .,.,,,,,.,,.,~*::',~ r-') r~) ~.~;~. ~ Q' --' ..c rn ~- (.,..) o ;:>~ -',;... \{; o r".:" GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service ofthe Complaint - Action to Quiet Title in the above-captioned matter. Signature Date: l- / f- IJ t .~ Printed/typed name: pee '1 fYJ..::s:,n ~ s~ q <.,-;:,) v-. (....- c'- ;; ",.;.-- , .' '0 ,-;: .~ c;; ,,,;' GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: ~/"- ,,~ ~j?o 3)~~~. SIgnature . Printed/typed name: ]:) A'( E JON G oS ~ R (J ~~ -" .~ Cl-'" , , '"'~~ c ~~:: .~ -.> c;) t''< GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, P A 17013 I accept service of the Complaint - Action to Quiet Title'in the above-captioned matter. Date: i. -~')-o 6 Printedftypedname: _ ~~~ ~ . o (: ::<.:~ ,~ ~n c',l C) (,'~: ,'0::1"" ...c' ,-'-, --,'" -:-D .< o r......:' GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.c. 354 Alexander Spring Road, Ste 1 Carlisle, P A 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. c9'" · . ,ff..- 06 ~o_ a~H.~ -Signature Printed/typed name: :ir_~;!.r~ii~~i4:~k,'f ., ~l ';71 ~")~ (,.<~ 0::0 \.~:'\ 0::0 V::' GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, P A 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: 6" ~6 - 66 clR7~a.J ature Printed/typed name:~"';7 ,r(-~0 l"-..:l '::,) ~~ Sn (A) o -~ GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.c. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service ofthe Complaint - Action to Quiet Title in the above-captioned matter. Date: 6/(71 (/{ u)/lzf~/ :r ~ ~7' ~ Signature ",,- Printed/typed name: ,41- 711 (//- t., :50 We.!, "-' c~ <;:::::) COP '- ::1 " " ;-:-:.1. ! cr"! N ,/ U1 f") GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Dato~ < '5"-) ;) M C; ~~~~ Printed/typed name: :r 0 fltv ;10 tv E s [ s II E AI (J U r? '~.;.;;;a.... " ~~~!~~1f., ~ !'-..c:> ,~, "-, ,;~ r;;;-' .", -11 c_ \ 0'\ -r::' -_.~ ":'? U'1 ['.,) GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, P A 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date: &/~9 J:l~c. ( , o~;t 1P$L / ~e Printed/typed name: 1~8~1'2/.IE. ~0:A//ff{, 1-.) ,,-) og-; :::''11 (;;;-" .-t C_ ""l: (-~~ ~1 r" -.I :;,;.. CJ G". GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants ACCEPTANCE OF SERVICE TO: Susann B. Morrison, Esquire Salzmann Hughes, P.c. 354 Alexander Spring Road, Ste 1 Carlisle, PA 17013 I accept service of the Complaint - Action to Quiet Title in the above-captioned matter. Date:'l- S . ("') I..c Printed/typed nam . (') N r (~...l ~I <; CJ '11 .;::..-" , c, C~: " \.D ;!:"; - \,Ci 0 ~~L:l CJ .-< GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2854 Civil JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants PETITION FOR FINAL DECREE OF COURT TO: THE HONORABLE mDGES OF SAID COURT NOW, this ?I~ day of , JU.LY ,2006, comes Susann B. Morrison, Esquire, attorney for the above-named Plaintiffs and respectfully represents that an Affidavit has been executed and is attached hereto deposing and saying that a Complaint in the above-captioned Action to Quiet Title, endorsed with Notice to Plead, has been served upon the Defendants by publication pursuant to prior Order dated June 27,2006 of this Honorable Court, and said Defendants have not answered said Complaint, entered an appearance, and/or initiated an action in ejectment although the time to do so has expired. WHEREFORE, the Plaintiffs move this Honorable Court to enter judgment in their favor and against the Defendants and grant the Plaintiffs the relief prayed for in their Complaint in accordance with Pa.R.C.P. 1066(a) and (b)(l). By: James D. u es, Esquire Supreme Court No.58884 Susann B. Morrison, Esquire Supreme Court No. 77041 SALZMANN HUGHES, P.C. 354 Alexander Spring Road, Ste 1 Carlisle, P A 17013 (717) 249-6333 GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 06-2854 Civil JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants AFFIDA VIT NOW, comes Susann B. Morrison, Esquire, Affiant, who being duly deposed, does state the following: 1. In accordance with Order of Court dated June 27,2006, I did cause to be placed for publication a Notice as to the above-captioned Action to Quiet Title. 2. Attached hereto and incorporated as Exhibits A and B, respectively, are copies of the Proofs of Publication from the Cumberland Law Journal and the Sentinel along with the Notices as published. 3. Twenty (20) days has elapsed since publication of the Notices in the Cumberland Law Journal and the Sentinel. 4. In' addition to service by publication, Plaintiff sent certified copies of the Complaint to all known heirs of John H. Jones and Mary E. Jones. 5. Twenty-five (25) of the known heirs of John H. Jones and Mary E. Jones signed an Acceptance of Service of the Complaint, all of which have been filed with the Prothonotary. 4. No responsive pleading has been filed by any party to the Complaint, no appearances have been entered and no action in ejectment has been initiated against Plaintiff. A true and correct copy of the docketing statement for this matter procured from the Prothonotary of Cumberland County is attached hereto and incorporated herein as Exhibit C. ltuoJ-L p,~ Susann B. Morrison, Esquire Sworn to and Subscribed before me This3/Jtday of ::TULty ,2006 ~1/tI1 f -;,t~ Notary Publi . TH OF PENNSYLVANIA NoC8ItlII Sell KIndy L Co)'Ie, Notary Pldc SouIh MIcdetot'l Twp., Cl.mbeIfand ColI1ly My CoImiIIIoi I Expil8aJUy 8, 2010 Member, ~ AIIocIaIIon of Not.llea PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz July 7,2006 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. - SWORN TO AND SUBSCRIBED before me this 7 day of July, 2006 ~4A.dt1.~~ Notary NOTARIAl. SEAL DHORAH A COI.LN Notary PuI:IIIc CAIlIIU 101O. cuqEflWl) COUMV My CoInt1WIIoI. .... ... 2010 Exhibit A CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, pennsylvan1a NO. 06-2854 CML GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs vs. JOHN H. JONES and MARY E. JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E. JONES, Defendants ACfION TO gUIET TITLE You are notified that the Plain- tiffs, Gerald P. Jones and MaIjorie L. Jones, have commenced an Ac- tion to guiet Title against you en- tered to NO. 06-2854 CIVIL In the Court of Common Pleas of Cumber- land County, Pennsylvania, which you are required to defend. This action concerns the land here described: ALL 1lIAT CERTAIN tract of land lying and being situate In the Town- ship of West Pennsboro, County of Cumberland, Commonwealth of Pennsylvania, bounded and de- scribed as follows: BEGINNING at a point at the Northeast comer of the lands now or formerly of Hazel E. Myers Es- tates as described In Deed Book -E,- Volume 13, Page 81, said point be- Ing on the line of lands now or for- merly of A.C. Kuhn; thence from said point ofbegtnnlng and along the line of the aforementioned lands of A.C. Kuhn, approximately on a bearing of South 69 degrees East a distance EKhibitB of 250 feet more or less to a point at the lands now or formerly of Zane R. Highlands and Vicky L. High- lands; thence along said lands of the Highlands, approximately on a bearing of South 7 degrees East a distance of 513 feet more or less, to a point at the lands now or for- merly of William 5. Graf, Jr. and Alicele E. Graf; thence by said lands of Graf approximately on a bearing of North 84 degrees West a distance of 216 feet more or less to a point at the aforementioned lands of the Hazel E. Myers Estate; thence along said lands North 6 degrees 30 min- utes West 132 feet more or less; thence by the same, North 1 de- grees 00 minutes West 816.75 feet more or less; thence by the same. North 13 degrees 30 minutes East 136.12 feet more or less to a point at the Place of Beginning. CONTAINING 5.5 acres more or less. If you wish to defend agaJnst the claims set forth in the following pages, you must take action byen- tering a written appearance person- ally or by attorney and flllng in writ- log 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 pro- ceed without you and a judgment may be entered against you by the court without further notice for any money claimed In the complaint or for any other claim or relief re- quested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PA- PER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR lELEPHONE lHE OFFICE SET FORTH BELOW TO FIND OUT 3 CUMBERLAND LAW JOURNAL WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES TIiAT MAY OFFER LE- GAL SERVICES TO EUGIBLE PER- SONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone No. (717) 249-3166 By: R. Thomas lO1ne, Sheriff SUSANN B. MORRISON, ESQUIRE SALZMANN HUGHES, P.C. Attomeys for Plaintiffs 354 Alexander Spring Road Suite 1 Carlisle, PA 17013 (717) 249-6333 July 7 4 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tammy Shoemaker, Classified Advertising Manager, of The Sentinel, of the County and State aforesaid, being du1y sworn, deposes and says that THE SENTINEL, a newspaper of general circu1ation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s) June 30, 2006. -,,'. "' >e-':><i;;- COPY OF NOTICE OF PUBLICATION .tmKeI ,\ ;\';i~~""_:'>.':- ~"?;.f;'" ".ne'CoutrroFCOiIitoN PLEAS OF " ~CU.8I!RLANOCOUNTY, PENNSYLVANIA ',' " ,'~ma-;'~~j; .~;!~;::::~:::;; ',0,' """",":}.:_:}" NO. 0..2814 CIVIL." . ~ ACtION lOQuIn TITLE" ; '::~. 'v,""'_""";' ~~:, -., v,..- ~E r-:\' ;",,''''' ;"';."~' :.:.;'''''' " . " . ,-', You are noIifIedthat the Pla/n1IIIa. Gerald P. Jones and MarfOrie LJOnea, have . " :e~nc:~:r::n~t~:t:~:~'::n~~~:-;=~I~: ;~~~ ',' .' ,~. , >.' : , Thlsictfon cOriC8!"1tftelirnd henlC,escribed: . ;;/:' '<_ "";:,' :.4' ';\'::. -:--',:'<:-:' ,:~:::_;:,,:,'-?:<'o:/:y, ':\:"'_ ',>>'-",:,,- ;_':--"i _,',.-" '_,: ".<_, .,',,':": : ".- ,'0:::'::_;:';-,:::'>':::,>:.", "\' ,Al,.l THATCEAT,w.fractoHancllYlno ancIbeing ~t~ki!tie TOWn8/11p of Weal PennsbOro, eounlJ of Cumberland. Commonwealth of Pennsylvania, '~~~~~~:_' , ",' ,." ..,. BEGINNINGai. PGtnt _the Northeast comer 0' the Iand8 now or formerly of Hazel E. Myers ,Estate.. ~ In Oiled Book -':", .Volume12, Page 81, , ' . saIcfpofnUJ~iIllOl'ttflelfne~"'nowOl'~ofA.C. ~~n;thenC4tfrom , ' sakS point of,b8gInnlflo and along the I/neo'the a~entioRiId lands of A.C. . . - Ku/im; ~onabearfritofSQutbWdeOf*s Eaetadl8laiJc:e of250 feet more Or.le... to a point at the lands now or foimerIy of Zane R: Highlands .=-~~~= saId=-:'~~513f..t ~or polnt at fonnedy of WHliam S. Graf, Jr. and , ~E. " '. ,. by' ofGrataflploxlmatelyatiabearlngo' North 84 . Wftt. c1atance of 218 feet monl or less tel. point at the . afoAImentlO11ed ..or..... ftUyera Estate; thence aIcm9 said lands . N~8-degr8es30mlniIIIM-W.t~f8etmore or _ thence by the same. ' Noftl'it degteftOOmrm.w.8.18.15f8et more or less; thence by the =;=J3~~ minutes East 136.12 feet mora or Iesa to a point CONTAIN~ ~:5acr8smoraOrIeSS. . ' ,'. I' yoU 'wish to d8fend~ttleclalins set fOrth in the 'ollowlng pages, you must take actIon.bJ~ . wiltten IIiIPeBrance peraonaIIy or by attorney Rnd filing In writing Wlttt the court JIOUl' detent.. Or ObjectIOns to the cfall\1$ setforth against you. You lIftI wtmecf.....1f l/Otl fdto do. 10 the case may pt'OCe8d without you and a jlld'gament may be ..... ~you by the court wIthoutfUrther notice for any " lnOflIy c:failne(( In the..t*Ilat or for any ~hllf claim or raIIef requested by the plalntiff.Y,ou may foiemoney or PI'Operty 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 LEGAL HELP. ". . IF YOU CANNOTAFFORO TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER lEGAL SERVICES TO fUGlBlE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedfonf Street Carlisle, PA 17013 Teleptlone No. (117) 249-3188 By: Ih~....tf ~ :$ERVE I.EGAL'PAPERSTO~ Susann B. MOn1son,'e.quira SALZMANt{ HUGHES,P.C~ 354 Alexander Spring ROad. Suite 1 2.~,!,~!~~'!!..013 l"" /" Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of ~~~~fct<- Sworn to and subscribed before me this 30th day of June, 2006. My commission expires: 9/I/or COMMONWEALTH OF PENNSYLVANIA Notarial Seal Chnstina L. WaIi!t t.W..R.I:),......._ Carlisle 8oro . . -, ruuac My~~County Me -.1.2008 mber. Pennsylvania ASSOCi'a' t. Of . IOn NOfanes ! 10321507312006 PYS51l9 Cumberland County Prothonotary's Office Civil Case Print Page 1 2006-02854 JONES GERALD P ET AL (vs) JONES JOHN H ET AL F i 1 ed. . . . . . . . : Time......... : Reference No..: Case Type.....: Judgment. . . . . . Judge Assigned: Disposed Desc. : ------------ Case Comments ------------- ******************************************************************************** General Index Attorney Info JONES GERALD P PLANITIFF MORRISON SUSANN B 75 GOODYEAR ROAD CARLISLE PA 17013 JONES MARJORIE L 75 GOODYEAR ROAD CARLISLE PA 17013 JONES JOHN H HIBES NART E HEIRS OF JOHN J JONES AND MARY E JONES COMPLAINT -QUIET TITLE .00 EBERT M L JR 5/18/2006 3:26 0/00/0000 0/00/0000 Execution Date Jury Trial. . . . Disposed Date. Higher Crt 1.: Higher Crt 2.: PLANITIFF MORRISON SUSANN B DEFENDANT DEFENDANT DEFENDANT TRUE COpy FROM RECORD tn Testimony whereof, I here unto set my hand and the seal of said Co rt t Carlisle. Pa. rhi ~ cia **************************************************************** * Date Entries ******************************************************************************** 5/18/2006 5/18/2006 6/15/2006 6/20/2006 6/27/2006 6/30/2006 6/30/2006 6/30/2006 6/30/2006 6/30/2006 6/30/2006 6/30/2006 - - - - - - - - - - - - - FIRST ENTRY - - - - - - - - - - - - - - COMPLAINT - ACTION TO QUIET TITLE ------------------------------------------------------------------- PETITION FOR LEAVE FOR SERVICE BY PUBLICATION ------------------------------------------------------------------- PRAECIPE TO REINSTATE - BY SUSANN B MORRISON ATTY FOR PLFFS ------------------------------------------------------------------- AMENDED PETITION FOR LEAVE FOR SERVICE BY PUBLICATION - BY SALZMANN HUGHERS PC FOR PLFF ------------------------------------------------------------------- ORDER OF COURT - 06-27-06 - IN RE: ACTION TO QUIET TITLE - ORDERED THAT SVC OF THIS COMPLAINT AND OTHER RELATED MATTERS IN AN ACTION TO QUIET TITLE BE PERMITTED UPON THE DEFTS GENERALLY BY PUBLICATION PURSUANT TO CUMB CO RULE 1009-1 / RULE 1666-1 / RULE 1066-2 /RULE 1066-3 AND RULE 1066-4 SAID PUBLs SHALL BE BY PUBLIC NOTICE WITH ONE PUBLICATION IN A NEWSPAPER OF GENERAL CIRCULATION IN CUMB CO AND ONE PUB IN THE CUMB LAW JOURNAL - PLFF/PETITIONER IS DIRECTED TO OBTAIN SVC IN ACCORDANCE WITH THE APPLICABLE RULES ON ALL INDIVIDUALS WHOSE ADDRESSES AND WHEREABOUTS CAN BE DETERMINED AFTER A DILIGENT SEARCH - IF NO ANSWER IS FILED OR APPEARANCE IS MADE A JUDGMENT BY DEFAULT MAY BE TAKEN AGAINST THE AFORESAID DEFTS.RESPONDENTS, THEIR HEIRS PERSONAL REP OR ASSIGNS - BY M LEBERT JR J - COPIES MAILED 06-27-06 ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - COMPLAINT-ACTION TO QUIET TITLE - SIGNED BY LLOYD R JONES ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - ACTION TO QUIET TITLE - SIGNED BY KATHLEEN A JONES ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - ACTION TO QUIET TITLE - SIGNED BY LORETTA JONES FISHER ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - ACTION TO QUIET TITLE - SIGNED BY M LOUISE HOSFELD ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - ACTION TO QUIET TITLE - SIGNED BY CHLOE JONES DEITCH ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - ACTION TO QUIET TITLE - SIGNED BY GLADYS CASHMAN ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - ACTION TO QUIET TITLE - SIGNED BY JUDY A Exhibit c 10321507312006 Cumberland County Prothonotary's Office PYS51~ Civil Case Print 2006-02854 JONES GERALD P ET AL (vs) JONES JOHN H ET AL F i 1 ed. . . . . . . . : Time......... : Page 2 Reference No. . : Case Type.....: Judgment. . . . . . Judge Assigned: Disposed Desc. : ------------ Case Comments ------------- 6/30/2006 6/30/2006 6/30/2006 6/30/2006 6/30/2006 6/30/2006 6/30/2006 6/30/2006 6/30/2006 6/30/2006 6/30/2006 6/30/2006 6/30/2006 6/30/2006 7/06/2006 7/06/2006 7/17/2006 7/19/2006 COMPLAINT -QUIET TITLE .00 EBERT M L JR 5/18/2006 3:26 0/00/0000 0/00/0000 Execution Date Jury Trial. . . . Disposed Date. Higher Crt 1.: Higher Crt 2.: NUTTING ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - ACTION TO QUIET TITLE - SIGNED BY DARLENE HOLM ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - ACTION TO QUIET TITLE - SIGNED BY R JONES ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - ACTION TO QUIET TITLE - SIGNED BY NANCY JONES BORDLEMAY ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - ACTION TO QUIET TITLE - SIGNED BY A RICHARD JONES ------------------------------------------------------------------- ACCEPTANCE OF SERVICE -ACTION TO QUIET TITLE- SIGNED BY ELVA F FREY ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - ACTION TO QUIET TITLE - SIGNED BY JOYCE C ZEIGLER ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - ACTION TO QUIET TITLE - SIGNED BY DORIS WOLFE ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - ACTION TO QUIET TITLE - SIGNED BY HAROLD G JONES ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - ACTION TO QUIET TITLE - SIGNED BY HELEN J CARPENTER ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - ACTION TO QUIET TITLE - SIGNED BY DEAN M JONES ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - ACTION TO QUIET TITLE - SIGNED BY DALE JONES JR ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - ACTION TO QUIET TITLE - SIGNED BY STEVE JONES ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - ACTION TO QUIET TITLE - SIGNED BY BETTY A ARNOLD ------------------------------------------------------------------- ACCEPTANCE OF SERVICE -ACTION TO QUIET TITLE- SIGNED BY GARRY R JONES ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - COMPLAINT-ACTION TO QUIET TITLE - BY ARTHUR L JONES ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - COMPLAIN-ACTION TO QUIET TITLE - BY JOAN JONES ESHENOUR ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - ACTION TO QUIET TITLE - BY ROBERT E JONES ------------------------------------------------------------------- ACCEPTANCE OF SERVICE - COMPLAINT-ACTION TO QUIET TITLE - BY JOHN BARRY JONES - - - - - - - - - - - - - - LAST ENTRY - - - - - - - - - - - - _ _ ******************************************************************************** * Escrow Information * * Fees & Debits Beq Bal Pvmts/Adl End Bal * ******************************************************************************** COMPLAINT TAX ON CMPLT SETTLEMENT AUTOMATION JCP FEE 35.00 35.00 .50 .50 5.00 5.00 5.00 5.00 10.00 10.00 ------------------------ 55.50 55.50 .00 .00 .00 .00 .00 ------------ .00 10321507312006 Cumberland County Prothonotary's Office PYS51D Civil Case Print 2006-02854 JONES GERALD P ET AL (vs) JONES JOHN H ET AL Reference No..: Filed........: Case Type.....: COMPLAINT -QUIET TITLE Time. ........: Judgment...... .00 Execution Date Judge Assigned: EBERT M L JR Jury Trial. ... Disposed Desc.: Disposed Date. ------------ Case Comments ------------- Higher Crt 1.: Higher Crt 2.: Page 3 5/18/2006 3:26 0/00/0000 0/00/0000 ******************************************************************************** * End of Case Information * ******************************************************************************** TRUE COpy FROM RECORD In Testimony wher~of, I here UIlto set my halir' '"? the seal 01 sald~IISIe. Pa. fhiS '~rday ~ '-- ~ ", P I. Prothonotary GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-2854 JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants CERTIFICATE OF SERVICE I, the undersigned, hereby certify that on this 31st day of July, 2006, a copy ofPlaintitI's Petition for Final Decree of Court was served via first class U.S. Mail upon all known Defendants. f6ruLb,~ Susann B. Morrison, Esquire Salzmann Hughes, P.C. Supreme Court I.D. # 77041 354 Alexander Spring Road, Suite 1 Carlisle, P A 17015 (717) 249-6333 Attorney for Plaintiff Date: July 31, 2006 :::1 \ ! I (~^ .: '.) r~ 7 '''rr'\'ED AI'" 01 "'''1\ .,,~,_,I "0 ,,JNOf!,1 GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-2854 Civil JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants DECREE OF COURT tA ~ NOW, this l day of l\~\l!. \ ,2006, an affidavit of service of the Complaint with Notice to Plead being attached hereto and no answer having been made by the Defendants, and upon consideration of the foregoing Petition and upon motion ofSusann B. Morrison, Esquire, Attorney for Plaintiffs, It is hereby ORDERED, ADJUDGED AND DECREED that title to the premises that is the subject of this action is hereby vested in the Plaintiffs. Said tract of land is described as follows: ALL THAT CERTAIN tract of land lying and being situate in the Township of West Pennsboro, County of Cumberland, Commonweatlh of Pennsylvania, bounded and described as follows: BEGINNING at a point at the Northeast corner of the lands now or formerly of Hazel E. Myers Estate as described in Deed Book "E", Volume 13, Page 81, said point being on the line of lands now or formerly of A.C. Kuhn; thence from said point of beginning and along the line of the aforementioned lands of AC. Kuhn, approximately on a bearing of South 69 degrees East a distance of 250 feet more or less to a point at the lands now or formerly of Zane R. Highlands and Vicky L. Highlands; thence along said lands of the Highlands, approximately on a bearing of South 7 degrees East a distance of 513 feet more or less, to a point at the lands now or formerly of William S. Oraf, Jr. and Alicele E. Oraf; thence by said lands of Graf approximately on a bearing of North 84 degrees West a distance of 216 feet more or less to a point at the aforementioned lands of the Hazel E. Myers Estate; thence along said lands North 6 degrees 30 minutes West 132 feet more or less; thence by the same, North 1 degrees 00 minutes West 816.75 feet more or less; thence by the same, North 13 degrees 30 minutes East 136.12 feet more or less to a point at the Place of Beginning. CONTAINING 5.5 acres more or less. It is further ORDERED AND DECREED that each of the Defendants be forever barred from asserting any right, lien, title or interest in or to the herein described parcel of land inconsistent with the interest and claim of the Plaintiffs' title to said land; from issuing or maintaining any action attacking the same; or from encumbering, mortgaging or conveying the same, or any part thereof, unless an action of ejectment is filed against the Plaintiffs for recovery of the same within thirty (30) days. BY THE COURT, ,~~ 1. 0\9 ~ ~\j o ,..... ,~ ! , .I;.' " .. GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-2854 Civil JOHN H. JONES and MARY E. : ACTION TO QUIET TITLE JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E.: JONES, Defendants TO THE PROTHONOTARY: Kindly enter on Appearance Docket and on Decree a notation that the Defendants failed to take the action directed in the last advertisement within the time therein limited; and transmit to the Recorder of Deeds a certified copy of the Decree containing the notation above described. Susann B. orri on, Esqmre Salzmann Hughes, P.C. Supreme Court LD. # 77041 354 Alexander Spring Road, Suite 1 Carlisle, P A 17015 (717) 249-6333 Attorney for Plaintiff Date: September 19, 2006 ~ ~ ~ e $ , ~ ~ ~~ Cf'" ~ ~ ~~ ~~.B ""0 \J ~ ~~~ - :P~ ............. f0 ~ \D 0, \ tf;\ ~ ~f) ~-'" . ~CJ ""0 ~.;- "'n ~ \' :x: 96 vJ c 15m ~ 5~ ~ ~ ~ ~ ~ t(\ &'" " PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tamrnv Shoemaker, Classified Advertising Manager, of The Sentinel, of the Cormty and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, Cormty and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said Cormty, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s) August 10, 2006 COPY OF NOTICE OF PUBLICATION GERALD P. JONES and MARJORIE L. JONES, husband. and wife plaintiffs " __ _~,'..'" .~_I - ......,fIL _,) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA v. NO. 06-2854 CIVIL ACTION TO QUIET TITLE JOHN H. JONES and MARYE. JONES, husband and wife. and The Heirs of JOHN H. JONES and MARY E. JONES Defendants o THE HEIRS OF JOHN H. JONES AND MARV E. "JONES: 'ou are notilled that an Order has been entered to Docket No. 06-2854 in the Court of : COmmon pteas of Cumberland County, Pennsylvania on August 3, 2006 directing that within thirty (30) days after this. publication you shall file an action In ejectment or be forever barred from asserting any right, lien, title or interest inconsistent with the Interest or claim set forth .in the Plaintiff's Complaint to tile land here described: ALL THAT CERTAIN tract of land lying and being situate in the Township of West Pennsboro, County of Cumberland, Commonwealth of Pennsylvania. bounded and described as follows: BEGINNING at a point at the Northeast comer of the lands now or formerty of Hazel E. Myers Estate as described In Deed BOOk .E", Volume 13. Page 81, said point being on the line of lands now or formerly of A.C. Kuhn; thence from said point of beglnrnng and along the Une of the aforementioned lands of A.C. Kuhn, approximately on a beartng of South 69 degrees East a distance of 250 feet more or less, toa point at the lands now or formerly of Zane R. Highlands and Vicky L. Highlands; thence along said lands of the Highlands, approximately on a bearing otSouth 7 c1egrees East a distance of 513 feet more or less, to a point at the lands now or formerly of WiUiam S. Graf. Jr. and Allcele E. Graf; thence by said lands of Graf approximately on a bearing of North 84 degrees West a distance of216 feet more or less to.~ point at the aforementioned lands oftfle Hazel E. Myers Estate; thence along said lands North 6 degrees 30 minutes West 132 feet more or less; thence by the same, North 1 degrees 00 minutes West 816.75 feet more or less; thence by the same, North 13 degrees 30 minutes East 136.12 feet more or less to a point at the Place of Beginning, CONTAINING 5.5 acres more or less. By: 8:. I!l2m.M Kline Sheriff SERVE LEGAL PAPERS TO: Susann B. Morrison, Esquire SALZMANN HUGHES. P.C. 354 Alexander Spring Road. Suite 1 Carlisle. PA 17013 (717) 249-6333 AttomeY for Plaintiffs Affiant further deposes that he/ she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of f ~nit~ Sworn to and subscribed before me this 16th, day of August 2006. f.JwMl A~ {fi. fA~ Notary Pu . My commission expires: q II / rf6 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Christina L wdfe, NoIaIy Public Callisle Bora, eumber13nd County My ~ ExpireS Sept. 1,2008 Member. Pennsylvania Association Of Notaries ,.. .'. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEAL TH OF PENNSYL VANIA SSe COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz August 18, 2006 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the 'aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. -' SWORN TO AND SUBSCRIBED before me this 18 day of August, 2006 ~A'~).L. ~J 'h<''''''''N()tary- '....'.. . ,. ',-, ,.... .. (',., -- -...., ".. CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania NO: 06-2854 Civil GERALD P. JONES and MARJORIE L. JONES, husband and wife, Plaintiffs vs. JOHN H. JONES and MARY E. JONES, husband and wife, and The Heirs of JOHN H. JONES and MARY E. JONES, Defendants ACTION TO QUIET TITLE TO THE HEIRS OF JOHN H. JONES AND MARY E. JONES: You are notified that' an Order has been entered to Docket No. 06- 2854 in the Court of Common Pleas of Cumberland County, Pennsylva- nia on August 3, 2006 directing that within thirty (30) days after this publication you shall file an action in ejectment or be forever barred from asserting any right, lien, title or interest inconsistent with the In- terest or claim set forth in the Plaintiffs Complaint to the land here described: ALL THAT CERTAIN tract of land lying and being situate in the Town- ship of West Pennsboro, County of Cumberland, Commonwealth of Pennsylvania, bounded and de- scribed as follows: BEGINNING at a point at the Northeast corner of the lands now or formerly of Hazel E. Myers Es- tate as described in Deed Book "E", Volume 13, Page 81, said point be- ing on the line of lands now or for- merly of A.C. Kuhn; thence from said point of beginning and along the line of the aforementioned lands of A.C. Kuhn, approximately on a bearing of South 69 degrees East a distance of 250 feet more or less to a point at the lands now or formerly of Zane R. Highlands and Vicky L. High- lands: thence along said lands of the Highlands. approximately on a bearing of South 7 degrees East a distance of 513 feet more or less, to a point at the lands now or for- merly of William S. Graf, Jr. and Alicele E. Graf; thence by said lands of Graf approximately on a bearing of North 84 degrees West a distance of 216 feet more or less to a point at the aforementioned lands of the Hazel E. Myers Estate: thence along said lands North 6 degrees 30 min- utes West 132 feet more or less: thence by the same, North 1 de- grees 00 minutes West 816.75 feet more or less; thence by the same, North 13 degrees 30 minutes East 136.12 feet more or less to a point at the Place of Beginnning. CONTAINING 5.5 acres more or less. By: R. Thomas Kline, Sheriff SUSANN B. MORRISON, ESQUIRE SALZMANN HUGHES. P.C. Attorneys for Plaintiffs 354 Alexander Spring Road. Suite 1 Carlisle, PA 17013 (717) 249-6333 Aug. 18 5 0 ~ = ~ c: = ? 0'" -oeD (I') ~:D l"i1ff! f"l'1 -".",; -0 .,&;.- ~l, -oF.; tJjl:.' -09 -<~~::, \D ~'J r:c :-\ r.::.) <: - -0 ?5:B ~c.j ,~C; 3 ~? C) )> <:: ~ Om ~ ~ W .JJ (.,) -<