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Home My WebLink About06-57550 JOSEPH AND CONNIE NEWELL, Plaintiffs V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 6 (o - 5-7 s.5" c-a i 11 -rcr^ RAYMOND DIEHL, Defendant COMPLAINT IN EQUITY QUIET TITLE ADVERSE POSSESSION 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Court Administrator Cumberland County Court House 1 Courthouse Square Carlisle, PA 17011 (717) 240-6200 JOSEPH AND CONNIE NEWELL, Plaintiffs V. RAYMOND DIEHL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Quo- S 75-5 cw-i -ferµ COMPLAINT IN EQUITY QUIET TITLE ADVERSE POSSESSION COMPLAINT 1. The Plaintiffs are Joseph and Connie Newell, adult individuals who reside at 1086 York Road, Dillsburg, Cumberland County, Pennsylvania, 17019. 2. The Defendant is Raymond Diehl, an adult individual who resides at 401 Meyers Road, Boiling Springs, Cumberland County, Pennsylvania, 18007 3. Sometime in July of 1976 the Plaintiffs purchased the residence where they presently reside at 1086 York Road, Dillsburg, PA. 4. Attached hereto, incorporated herein and marked Exhibit "A" is a sketch showing Plaintiffs' real estate marked `(?7. 5. From sometime in 1977 through the present the Plaintiffs have used, cultivated, developed and planted a section of property on and adjacent to their residence set forth in Exhibit "A" which section of property is approximately 45 feet by 200 feet by 15 feet by 200 feet and is set forth in Exhibit "A" as @B Adverse Possession claim. 6. The use of the property has included sheds, driveways, trees, shrubbery, landscaping and wood piles and a wide variety of other activities and uses. 7. The use of this section of property has been continuous and has not interrupted since 1977. 8. The use of this land has been visible, conspicuous and notorious in that the use has involved over the course of time buildings, landscaping, shrubbery, mature trees, a driveway and other uses. 9. The various uses of this land has been exclusive and it has not been shared with any other party including possible owners. 10. The Plaintiffs have acted since that time as if the property were theirs and has been hostile to the present owner, his predecessors in title and others. 11. Plaintiffs believe and therefore aver that the Defendant, sometime in 1985 or 1986, purchased from a prior owner a multi-acre tract of land which is adjacent to the Plaintiff's land and a part of which is the subject of this suit. 12. Sometime in September of 2006 Defendant had a survey completed on his land. 13. Reserving the right to contest the survey, the survey seemed to indicate that his land extends over onto the property which the Plaintiffs have been using since 1977 and which is the subject of this suit. 14. On September 30, 2006 Defendant appeared with a work crew to bulldoze all Plaintiffs' property on this section of real estate. 15. However, due to intervention of Plaintiffs' counsel and the Pennsylvania State Police, Defendant was persuaded to wait until Monday, October 2, 2006 or thereafter. 16. Pennsylvania State Police indicated to Plaintiffand Plaintiffs' counsel that Defendant intended to return to complete the bulldozing. 17. The purpose of this action is to determine the Plaintiffs' right, title and interest in the subject premises as set forth in Exhibit "A" and to establish specific validity of the property description in said parcel of real estate. 18. The Plaintiffs have acquired this section of property set forth in Exhibit "A" through y adverse possession since they have satisfied all of the criteria set forth to establish a claim by adverse possession. WHEREFORE, Plaintiffs request that this Court: A. Enter an Order declaring said Plaintiffs, Joseph and Connie Newell, are the legal owners in fee simple with the premises set forth in Exhibit "A" above free and clear of any and all rights, title and interest, claim or demand of said Defendant, the respective heirs, successors and assigns, and further enjoins said Defendant and the respective heirs, successors, and assigns from denying, impeaching or in any way attacking Plaintiff's ownership interest in said lands and further an Order confirming the validity after survey of the property description of said lands set forth above and further for an Order directing this Court's Order to be filed and recorded in the Office of the Recorder of Deeds for Cumberland County. B. Plaintiffs also request that his Court enter a Preliminary Injunction barring the Defendant from destroying Plaintiffs' personal property which is situated upon the section of land which is the subject of this suit and set forth in Exhibit "A". B. Such other and further relief as the Court shall deem just and proper under the circumstances. L. Rex Bic y 114 So St. Harrisburg, PA 17101 717-234-0577 717-234-7832 fax i00 S s?Ao?[13`tj 1jSn° a? I c,J t 6c) ' I .l ...: Ap ?. IV 117 Ns/ • ,?/ 8"3 U 4 ? t N y36;.q O 77- 63i ?CS 1 t. ?1 G NC wet( EXHIBIT "A" Y VERIFICATION We, Joseph and Connie Newell, hereby verify that the information contained in the foregoing document are true and correct to the best of our information, knowledge and belief We understand that false statements herein are made subject to the penalties of 18 Pa. Section 4904 relating to unworn falsification to authorities. Date: Cbk' ' aO04 / J ph ewell Connie Newell C? Cr ?s it ol? Y cs+ CO ^ C./ JOSEPH AND CONNIE NEWELL, Plaintiffs V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 6 6 - 5-7S5- 6a,, I `Fer- RAYMOND DIEHL, Defendant COMPLAINT IN EQUITY QUIET TITLE ADVERSE POSSESSION PETITION FOR PRELIMINARY INJUNCTION Petitioners Joseph and Connie Newell, through their undersigned counsel, petition this Court for the issuance of a Preliminary Injunction pursuant to Pa. R.Civ. P.1531 and in support therefore allege as follows: 1. Plaintiffs have filed a verified Complaint in Equity with the Prothonotary of this Court on October 2, 2006 a true copy of which is incorporated herein, attached hereto and marked Exhibit "A". 2. Plaintiffs have been in possession of and have otherwise used a section of real estate approximately 45 x 200 x 15 x 200 feet on or adjacent to their property for close to thirty (30) years and have done so on a continuous, visible, notorious, exclusive and hostile manner. 3. This section of land is set forth in Exhibit "A" attached to Plaintiffs' Complaint in Equity. 4. Sometime in August or September 30, 2006 Defendant, Raymond Diehl, had a survey completed with respect to property he owns immediately adjacent to the Plaintiffs' property. 5. Reserving the right to contest the accuracy of Defendant's survey, the survey indicated that the Defendant's property line includes the area which is the subject of this litigation. 6. On Saturday, September 30, 2006, Defendant and a crew with equipment appeared at the Plaintiffs' home with the intent of bulldozing and destroying Plaintiffs' personal property ? C including mature trees, shrubbery, bushes, landscaping and sheds. 7. Through the intervention of Counsel for Plaintiffs and the Pennsylvania State Police the Defendant was persuaded to wait until Monday or Tuesday, October 2' and 3', 2006. (See attached Affidavit of L. Rex Bickley marked Exhibit "A") 8. Had the Defendant bulldozed the property located on this section of real estate, Plaintiffs believe that they would have suffered a loss in excess often thousand ($10,000.00) dollars. 9. Attached hereto are photographs showing some of the trees, shrubbery, and landscaping that are in question. (Exhibit "B") 10. Defendant has indicated that he intends to return on Monday or Tuesday to resume the destruction of the Plaintiffs' personal property. 11. Plaintiffs will suffer immediate and irreparable harm if this injunction is not granted. 12. Plaintiffs have no adequate remedy at law to redress the pending harm from Defendant's conduct. 13. The issuance of an injunction will not be contrary to the pubic interest. 14. The Plaintiffs believe that they have a meritorious adverse possession claim and will likely succeed on the merits. 15. The right of the Plaintiffs to this property is lawful and is enforceable in equity and Plaintiffs will be entitled upon final hearing to a permanent injunction. 16. The Defendant will suffer no economic damage at this juncture for the following reasons: The entire tract of Defendant's land is undeveloped, the portion that is in dispute is actually quite small and has not been used for any other purpose than the Plaintiffs for the past thirty years and the Plaintiffs believe and therefore aver that the Defendant has no immediate intention to use the subject property. WHEREFORE, Petitioners request that this Court: A. Issue a Preliminary Injunction enjoining the Defendant from entering upon this section of land set forth in Plaintiffs' Exhibit "A"; B. Enjoining the Defendant from destroying Plaintiffs' property; and C. Such other and further relief as the Court shall deem just and proper under the circumstances. L. Rex Bi 114 Sou t. Harrisburg, PA 17101 717-234-0577 717-234-7832 fax AFFIDAVIT OF L. REX BICKLEY, ESQUIRE I, L. Rex Bickley, Esquire, swear and certify as follows: I represent Joseph and Connie Newell, Plaintiffs herein. On Saturday morning, September 30, 2006, I was called by the Plaintiffs and requested to come over to their property. When l arrived, Defendant's son, Defendant and his other son arrived shortly thereafter, was at the property line along with a crew of men including a flat bed truck and a bulldozer. The bulldozer had already pushed over and destroyed one of Plaintiffs' trees. I spoke to Defendant and his sons and they indicated that they intended to destroy all of Plaintiffs' property on the section of real estate which is the subject of this action in equity. Discussions continued with the Defendant and finally the Pennsylvania State Police arrived. Through the intervention of the State Police, the Defendants agreed to wait until Monday. At that time it was my intention to discuss the dispute with the Defendant's counsel, Robert Sadis, Esq., and also to seek redress in Court. The State Police Officer indicated to me that Defendants, unless otherwise directed, intended to return on Monday or Tuesday, October 2' and 3', 2006 to resume bulldozing Plaintiffs' property. L. Rex Bic 114 Sou St. Harrisburg, PA 17101 717-234-0577 717-234-7832 fax Date: /,/?-/0 r'. Exx4)t3)1 "A a I s i 1 `3 l JOSEPH AND CONNIE NEWELL, Plaintiffs V. RAYMOND DIEHL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. D 6 ?-7 6 ;-S- COMPLAINT IN EQUITY QUIET TITLE ADVERSE POSSESSION 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Court Administrator Cumberland County Court House I Courthouse Square Carlisle, PA 17011 (717) 240-6200 EXHIBIT "A" JOSEPH AND CONNIE NEWELL, Plaintiffs V. RAYMOND DIEHL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 6!o's 7Sy COMPLAINT IN EQUITY QUIET TITLE ADVERSE POSSESSION COMPLAINT 1. The Plaintiffs are Joseph and Connie Newell, adult individuals who reside at 1086 York Road, Dillsburg, Cumberland County, Pennsylvania, 17019. 2. The Defendant is Raymond Diehl, an adult individual who resides at 401 Meyers Road, Boiling Springs, Cumberland County, Pennsylvania, 18007 3. Sometime in July of 1976 the Plaintiffs purchased the residence where they presently reside at 1086 York Road, Dillsburg, PA. 4. Attached hereto, incorporated herein and marked Exhibit "A" is a sketch showing Plaintiffs' real estate marked `0. 5. From sometime in 1977 through the present the Plaintiffs have used, cultivated, developed and planted a section of property on and adjacent to their residence set forth in Exhibit "A" which section of property is approximately 45 feet by 200 feet by 15 feet by 200 feet and is set forth in Exhibit "A" as @B Adverse Possession claim. 6. The use of the property has included sheds, driveways, trees, shrubbery, landscaping and wood piles and a wide variety of other activities and uses. 7. The use of this section of property has been continuous and has not interrupted since 1977. 8. The use of this land has been visible, conspicuous and notorious in that the use has involved over the course of time buildings, landscaping, shrubbery, mature trees, a driveway and other uses. 9. The various uses of this land has been exclusive and it has not been shared with any other party including possible owners. 10. The Plaintiffs have acted since that time as if the property were theirs and has been hostile to the present owner, his predecessors in title and others. 11. Plaintiffs believe and therefore aver that the Defendant, sometime in 1985 or 1986, purchased from a prior owner a multi-acre tract of land which is adjacent to the Plaintiff's land and a part of which is the subject of this suit. 12. Sometime in September of 2006 Defendant had a survey completed on his land. 13. Reserving the right to contest the survey, the survey seemed to indicate that his land extends over onto the property which the Plaintiffs have been using since 1977 and which is the subject of this suit. 14. On September 30, 2006 Defendant appeared with a work crew to bulldoze all Plaintiffs' property on this section of real estate. 15. However, due to intervention of Plaintiffs' counsel and the Pennsylvania State Police, Defendant was persuaded to wait until Monday, October 2, 2006 or thereafter. 16. Pennsylvania State Police indicated to Plaintiffand Plaintiffs' counsel that Defendant intended to return to complete the bulldozing. 17. The purpose of this action is to determine the Plaintiffs' right, title and interest in the subject premises as set forth in Exhibit "A" and to establish specific validity of the property description in said parcel of real estate. 18. The Plaintiffs have acquired this section of property set forth in Exhibit "A" through 5 adverse possession since they have satisfied all of the criteria set forth to establish a claim by adverse possession. WHEREFORE, Plaintiffs request that this Court: A. Enter an Order declaring said Plaintiffs, Joseph and Connie Newell, are the legal owners in fee simple with the premises set forth in Exhibit "A" above free and clear of any and all rights, title and interest, claim or demand of said Defendant, the respective heirs, successors and assigns, and further enjoins said Defendant and the respective heirs, successors, and assigns from denying, impeaching or in any way attacking Plaintiff's ownership interest in said lands and further an Order confirming the validity after survey of the property description of said lands set forth above and further for an Order directing this Court's Order to be filed and recorded in the Office of the Recorder of Deeds for Cumberland County. B. Plaintiffs also request that his Court enter a Preliminary Injunction barring the Defendant from destroying Plaintiffs' personal property which is situated upon the section of land which is the subject of this suit and set forth in Exhibit "A". B. Such other and further relief as the Court shall deem just and proper under the circumstances. L. Rex Bic y 114 So St. Harrisburg, PA 17101 717-234-0577 717-234-7832 fax S' q7? 53 5 „/ 5 7 ? w J ?O , 08' t ?: .. 1. .- .j? 4qI 4 /V q36; DA EXHIBIT "A" VERIFICATION We, Joseph and Connie Newell, hereby verify that the information contained in the foregoing document are true and correct to the best of our information, knowledge and belief. We understand that false statements herein are made subject to the penalties of 18 Pa. Section 4904 relating to unsworn falsification to authorities. Date: a4;v f 900b Jo Newell C- Onnie Newell ? D ... ? l T. i "`.-' 3 n.j N ` . ,' ?-- _j , S < ?;,.i ; -.. T [;=.? r JOSEPH and CONNIE IN THE COURT OF COMMON PLEAS OF NEWELL, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. CIVIL ACTION - LAW RAYMOND DIEHL, Defendant NO. 06-5755 CIVIL TERM ORDER OF COURT AND NOW, this 2°d day of October, 2006, upon consideration of Plaintiffs' Petition for Preliminary Injunction Relief, it is ordered and directed as follows: 1. Pending further order of court, Defendant is enjoined from entering upon the land which is the subject of this action, as set forth in Plaintiffs' Exhibit "A" attached to the petition; 2. A hearing on the continuation, modification or termination of this preliminary, ex parte injunction shall be held on Thursday, October 5, 2006, at 11:00 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. 3. The injunction provided for herein shall be effective upon Plaintiffs' posting of a bond, with corporate surety acceptable to the court, or cash with the Prothonotary, in accordance with Pa. R. Civ. P. 1531, in the amount of $10,000.00. In the event the said bond or cash is not posted/deposited within 20 days, this order shall be deemed automatically vacated. BY THE COURT, /Rex Bickley, Esq. 114 South Street Harrisburg, PA 17101 Attorney for Plaintiffs n 1 11''rf1 ,,` i f%11-3 4 rr?? -10 'k.ai 'till 14t,.r `yj? ,.y i'"ii v Raymond Diehl 40lMeyers Road Boiling Springs, PA 17007 Defendant, pro Se Courtesy Copy: )(obert Saidis, Esq. 26 West High Street Carlisle, PA 17013 r :rc JOSEPH and CONNIE IN THE COURT OF COMON PLEAS OF NEWELL, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. CIVIL ACTION - LAW RAYMOND DIEHL, Defendant NO. 06-5755 CIVIL TERM SAIDIS, FLOWER & LINDSAY nrroINM nr AW 26 West High Street Carlisle, PA PRAECIPE Please enter my appearance on behalf of the Defendant. Dated: SAIDIS, FLOWER & LINDSAY r•- J' R ert . Saidis, Esquire Supreme Court I.D. #21458 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Defendant v m ?r ' - '? ' .? C re _ . i -;' ?? ' j J - " CJ ? , L- 'l ? ? t { ....a r JOSEPH and CONNIE NEWELL, IN THE COURT OF COMMON PLEAS OF Plaintiffs CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW RAYMOND DIEHL, Defendant NO. 06-5755 CIVIL TERM ORDER OF COURT AND NOW, this 5th day of October, 2006, upon consideration of Plaintiffs' Petition for Preliminary Injunction Relief, and pursuant to an agreement reached between the parties and their respective counsel in open court, it is ordered and directed as follows: 1. The Defendant would continue to be enjoined from entering upon the land marked on Exhibit A, which is attached hereto, for a period of 6 months. 2. That the Plaintiffs would post the bond as required by the Order of October 2, 2006. 3. That the preliminary injunction would expire March 31, 2007, unless the Plaintiffs petition the Court to modify or extend. Rex Bickley, Esquire 114 South Street Harrisburg, PA 17101 For the Plaintiff /obert Saidis, Esquire J 26 West High Street Carlisle, PA 17013 For the Defendant pcb By the Court, i l m (V) Aj CD ? ? ? ? .' Cuq,`ralPd F•elo , C ? t a / N/F ' HAROLD C. WILLS 1. o D.B. 106 Pg. 477 P. B. 85 Pg. 60 I ' ti?l.,. t ?\ \ S?aS 1 ..t ?aJ?s 2?(7Qn Cul", ated Fiend ?fota it NIF \ \ i JOSEPH H. & :ONNIE R. NEWELL v D.B. 31Q Pg. 12 a LANDS OF ,oo h? RA YMOND E. DIEHL _ DONALD E. DIEHL _ _S5 c° ?- 1-i6-O. 2?6„E D. B. 32H Pg. 14 00' P.B. 51 PG 110 Y . 1. 11 ?\\ ?I rte ' if '? Conc: OrA Runs !-'i! /1l l} r ' + ,?c i. ! Fe^ce,rCoo%!'ust St°raGe } A. ea s ?t y N/F m2aar and Fir/d JOSEPH H. & CONNIE R. NEWELL ty ' D- B- 268 P `° g. 781 / r' rr o o ?r t ? N ? Z o ry ?.'y'? t ? N e 1 ,I t ? F'irenz,°d Stn ?3qp A,ea ? `Shed y' ?? J t 1 2 q12 Slone oowe iii Q V J ly, ' y , q ? `t z e ' `1 - ire. 9fed Fie/d a All ' -l N57 5707"W y dgR Rn Y 7 85.4!i--- 5 54'..- r, l e9a//? -o°Lr , -,- WGne I , _ t . Ne9oe /*a ?. /V N57n57'0_7"W? ra s357v y y 83.48' 95. t Nqq o26 c°nc i FryyP?` ?` 63 < w Set , 1 rP 'ebarFound ? - - Naiiset '. _-? CY/ ?"p?rOe'r°Und ? Zf9? r^ N/F ROBERT E. & DORIS E. GINTER D. R. 7,158 Pn 17 78 JOSEPH and CONNIE NEWELL, Plaintiffs V. RAYMOND DIEHL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-5755 CIVIL TERM MOTION FOR RELEASE OF BOND AND DISCONTINUANCE 1. Your Petitioners are Joseph and Connie Newell. 2. This matter has been settled by the parties. 3. Consequently, Petitioners would request that the bond be released and the matter marked as discontinued. WHEREFORE, your Petitioners request the entry of an Order releasing the Bond to the surety and the matter marked discontinued. Respectfully submitted, L. Rex Bickley, 114 South St Harrisb A 17101 717-234-0577 Dannlerunnaolxom Attorney for Plaintiffs May 4, 2008 CERTIFICATE OF SERVICE I, L. Rex Bickley, Esquire, hereby certify that on this aid y of May, 2008 I served a true and correct copy of the foregoing Release Bond and Discontinuance on the following by first class mail, postage prepaid, at Harrisburg, PA 17101 Robert Saidis, Esq. 26 West High St. Carlisle, PA 17013 and Joseph and Connie Newell 1086 York Rd. Dillsburg, PA 17019 L. Rex Biocley 114 South St. Harrisburg, PA 17101 717-234-0577 717-234-7832 fax ?? - ) 1 T ?a t? JOSEPH and CONNIE NEWELL, ; IN THE COURT OF COMMON PLEAS Plaintiffs CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW RAYMOND DIEHL, NO. 06-5755 CIVIL TERM Defendant AMENDED MOTION FOR RELEASE QE BOND AND DISCO ANCE 1. Your Petitioners are Joseph and Connie Newell. 2. This matter has been settled by the parties. 3. The only Order entered in this matter was entered on October 5 2006 signed by the Honorable J. Wesley Oler, Jr. 4. Robert Saidis, Esquire, concurred to the within Motion by email letter dated June 4, 2008. 5. Consequently, Petitioners would request that the bond be released and the matter marked as discontinued. WHEREFORE, your Petitioners request the entry of an Order releasing the Bond to the surety and the matter marked discontinued. 234-0577 Dapplerun(aaol coin June 10, 2008 Attorney for Plaintiffs Respectfully submitted, ckl , 114So t L. 717- Rex Bi Harrisb PA 17101 t, CERTIFICATE OF SFRVK;E I, L. Rex Bickley, Esquire, hereby certify that on this 101 d day of June, 2008 I served a tnw and correct copy of the foregoing Amended Release Bond and Discontinuance on the following by first class mail, postage prepaid, at Harrisburg, PA 17101 Robert Saidis, Esq. 26 West High St. Carlisle, PA 17013 and Joseph and Connie Newell 1086 York Rd. Dillsburg, PA 17019 L. Rex 'c ey 11. uth St. Harrisburg, PA 17101 717-234-0$77 717-234-7832 fax ra yt. n r -? z 7 g JUN 16 zoos O JOSEPH and CONNIE NEWEL ,L, IN THE COURT OF COMMON PLEAS Plaintiffs CUM 3ERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW RAYMOND DIERL, NO. 06-5755 CIVIL 'T'ERM Defendant ORDER AND NOW, to wit, thi I$ It day of T"4c , 2008, upon consideration of the within Motion, the Motion s granted. The Prothonotary is directed to release the Bond filed in the above captioned matter 13 Penn National In n wwe Company and to mark this matter Discontinued. 'AA1 - r C ?J 46 VINWASNN2d 60 .C Wd 81 nr OOOZ M :10