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Home My WebLink About94-00908 " r, , , f: , .' ()O o CT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA PLAINTIFF BANKERS TRUST COMPANY OF (}r,(1/ 1 \ ' NO. -Jd, C_ll.il( yqqtj CALIFORNIA.~.A.. as TRUSTEE FOR VENDEE MORTGAGE TRUST VS. DEFENDANT DAVID S. RIGHTER and ALL OTHER OCCCPANTS. PRAECIPE TO: CUMBE~~ CO~.Y PROTHONOTARY Settle and Discontinue the Confession of Judgecent In Ejectcent in the above captioned case. ::.J ";:0. Attorney in Fact ~ I hereby certify that the foregoing is a true and correct statement of the above case. Date Sworn to and subscrib~d ~u:o:~ ae this "7, t1 .....3 day of ~7i_(.A_.('j1 199-/ Pro. Cost Sheriff Due 'fi't'Ltt,!Lx./x_. (~.!:-L:'X.-4a.L o Cert. Q ", .' . . .~. ..' M:Jfv,'rr. r. '4'..'., ,....'...:y :\~ti~ i:,t::'.:,\," :'~,"':'.>:{"f',:" :.1\' Q.'lit~.:.:,..;'..:!~ l:.'.;!'_;':' i).:,.;. "I::: tJJ"" . ' ' ~l~.rt~~~.Jt/J'..iINtP. Cumberland County Prothonotary By Deputy I. .... -----.'. - ~.~ ..~~_............ -_.~.. -...--. .,..., . ' ~ .. ~ I:l - - ;>. ..,.... ..... "'....:i< (,) C.)~., i4~~ii .....:c-Q~ ~:.-:r;-.I ,':) ~:I 'f)... '.. ~crJ~ - .o....Jh/~ '....:r."".,JltJ "":r~ ...:.. 0<'> ~ ... :i:! " SHERIFF'S RETURN COHMONI'IEAL, TH 0:- PENrlS'{LVAN:A In The Court of Common Pleas of Cumberland County, Pennsylvania No. 90B Civil Term 1994 Complaint in Ejectment and and Notice COUrI':'Y OF CU~!3ERLAND Bankers Trust Company of California, N.A., as Trustee for Vendee Mortgage Trust VS David S. Righter and All Other Occupants R. THOMAS KLINE, Sheriff. who being duly sworn according to law, says. that he made diligent search and inquiry for the within named defendan t to wi t: David S. Richter Rnn All Othpr Oc"c"l1p..nt.. but was unable to loca te them in his bailiwick. He therefore returns the Complaint in Ejectment & Notice NOT FOUND. as to the within named defendant, David S. Righter and All Other Occupants Sheriff's Costs: Docketing Service Affidavit Surcharge So answers: /' 14.00 5.60 -(;:=:7;:I:E: ::eriff 2.00 21.60 Pd. by Atty. 3-30-94 Sworn and subscribed to before me day of ~ :;lJ on~tary j,' J" aA ( 0 no one living in the upstairs of this address. Themail has n been removed from the mailbox for sometime. Deputy left a call- back card. When he later returned to the address the card was gone. but no one contacted us. this 3191- 19. q/f ,.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANKERS TRUST COMPANY OF CALIFORNIA, N.A, as TRUSTEE FOR VENDEE MORTGAGE TRUST, Plaintiff, CIVIL DIVISION NO. : 9()~ t.~ I??~ COMPLAINT IN EJECTMENT Code 140 MORTGAGE FORECLOSURE vs. DAVID S. RIGHTER and ALL OTHER OCCUPANTS, Filed on behalf of plaintiff Defendants. Counsel of record for this party 1 Louis P. Vitti, Esquire PA I.D. #3810 Supreme Court #01072 Louis P. vitti & Assoc., P.C. 1031 Fifth Avenue pittsburgh, PA 15219 (412) 281-1725 .'. . COMPLAINT IN BJBCTMENT NOTICB YOO HAVE BEEN SUED IN COORl'. IF YOO WISH 'ro DEFJ:1ID 1\GAINST '!HE CI.AIMS SET FORlH IN '!HE FOu.cM:NG PAGES, YOO KJS'l' TARE lICl'ICN Wl'lHIN 'lWENl'Y (20) D.\YS lIF1'ER 'lHIS cn!PIAINl' AND NOl'ICE lIRE SERVED, BY E:Nl'ERl}l; A WRlTl'EN APPEARANCE I?ERSClNMLY OR BY '!HE ATroRNEY AND FILIro IN WlUTING Wl'lH '!HE COORl' YOOR DEFalSES AND OBJECl'ICNS 'to '!HE CI.AIMS SET FORlH 1\GAINST YOO. YOO lIRE WARNED '!HAT IF YOO FAIL 'to 00 SO '!HE CASE MAY J.'PIY"RI'TI Wl'1lia1l' YOO AND A .JtlOOMENl' MAY BE E2uu=J 1\GAINST YOO BY '!HE COORl' Wl'1lia1l' FURl'HER NOl'ICE FOR ANY M:::NEY ctADIED IN '!HE cn!PIAINl' OR FOR ANY 0lHER CUIIM OR RELIEF ~ BY '!HE PIAINl'IFF. YOO W<.Y LeSE M:::NEY OR PRJPERl'Y OR aIHER RIGIfl'S IMroRr1INl' 'ro YOO. YaJ S1IXJID TAKE 'lHIS PAPER 'to YOOR IAWYER AT CNCE. IF YOO S1IXJID oor HAVE A IAWYER, OR CANNCIl' AFFORD ONE, GO'ro OR TEIEPHONE '!HE OFFICE SET FORlH BEI.CM 'to FIND oor WHERE YOO C1IN GEl' IE3AL HELP. C1IMBERIAND IAWYER !<I:;tJ:;t<HAL SERVICE COORl' AI:MINISl'RAroR 3RD FIOOR C1IMBERIAND axJNl'Y CXXJRIHaJSE CARLISlE, PA 17013 'l'EIEPHONE: (717) 697-0371 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BANKERS TRUST COMPANY OF CALIFORNIA, N.A., as TRUSTEE FOR VENDEE MORTGAGE TRUST, . . . . plaintiff, vs. . No.: . . . DAVID S. RIGHTER and . . ALL OTHER OCCUPANTS, Defendants. . . COJIPUIJI'l' Dr BJBcoJ:IU5J1'l' AND NOW, comes the above-captioned plaintiff, Bankers Trust Company of California, N.A., et al., by and through its counsel, Louis P. vitti & Associates, P.C. and Louis P. Vitti, Esquire, who files this Complaint as follows: 1. The Plaintiff is a corporation having a principal place of business located at Three Park Plaza, Sixteenth Floor, Irvine, CA 92714. 2. The Defendants are individuals, sui juris, whose last known address was 108 Walton Avenue, Carlisle, PA 17013. 3. On April 23, 1991, the Plaintiff's predecessor in title entered into an Installment Land Contract with Defendants and/or their predecessors in title, the sum of sixty Eight Thousand and nO/l00 Dollars ($68,000.00), and in consideration thereof, the Defendants and/or their predecessors in title, were " to pay Five Hundred Twenty-Three and 01/100 per month. 4. The premises secured by the Installment Land Contract are: See description attached hereto as Exhibit "A". 5. The Installment Land Contract provides generally that in the event of default of payment and/or installment of principal and/or interest, inter alia, that it shall be lawful for Plaintiffs to institute, inter alia, an action in ejectment 6. Since september 1, 1992, the Installment Land Contract has been in default by reason of the failure of the mortgagors to make appropriate payments. 7. Defendants and/or other occupants continue to occupy the said premises described in Exhibit "A". WHEREFORE, Plaintiff prays Your Honorable Court enter Judgment in favor of the Plaintiff, for sole possession of the property and vesting the title of said premises to the Plaintiff as prayed for in the Complaint. Respectfully sUbmitted, LOUIS P. VITTI & ASSOCIATES, P.C. LO~ TRUE COPY FROM RECORD Attorney for Plaintiff In Testimony '.~horuot. I here unto sat my hand IIId the seal.ol saId Court at r1lsle. Pa. 'fI~ day 0 19 </. 2 .';'-1 ''''r:r:~,~" VERIPICATION AND NOW Louis P. vitti verifies that the statements made in this Complaint in Ejectment are true and correct to the best of his knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. By virtue of the fact that the Plaintiff is outside the jurisdiction of the court and the verification cannot be obtained within the time allowed for the filing of this pleading, the pleading is submitted by counsel having sufficient knowledge, information and belief based upon the information provided him by the Plaintiff. Dated 1 February 22, 1994 t,. ;'.~""-: ~LL THAT CERTAIN tract of land situate in North Middleton Tovnship, Cumberland County, ?ennsylvania, bounded and described in accordance vith e survey by Larry V. Neidlinger, R.S., dated March 18, 1977, as follovsl 3EGINNING at a point on the Vestern line of fifty (SO) feet vide Val ton Avenue at the Southeastern corner of land nov or late formerly of Daniel Dinunzio; thence along the Vestern line of said fifty (SO) feet vide lIalton Avenue, in a Southerly direction by a curve to the right a distance of 25.476 feet to a point; thence still along the lIestern line of said fifty (SO) feet vide Valton Avenue by a curve to the left a distance of 56.10 feet to a nail at line ~f land nov or formerly of Quinn; thence along Northern line of said land of Quinn North 79 iegrees 28 minutes 10 seconds lIest 130.13 feet to an existing stake in line, of land nov or formerly of Clyde L. Sutton; thence by said land of Sutton North 0 degrees 59 minutes 30 seconds Vest 80 feet to an iron pin in line of land nov or formerly of Daniel Dinunzio; thence ':>y said land of Dinunzio, South 80 degrees 33 minutes East 142.12 feet to an iron pin, the ?lace of BEGINNING. 3EIlIG the major portion of Lot No.4 and a small portion of Lot No.3 as shovn on the Va1ton Avenue Plsn of Lots recorded in Cumberland County Plan Book 11, at Page 34, together vith the improvements thereon erected, and knovn and numbered as 108 lIalton Avenue. 3EING the same premises vhich the Sheriff of the County of Cumberland, in the State of ?ennsylvania, by deed dated , and recorded February 4, 1991, in the )ffice of the Recorder of Deeds, in and for the County of Cumberland, in Deed Book 'Y' Vol. 34, ?age 911, granted and conveyed unto the Grantor herein, in fee. EXHIBIT "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANKERS TRUST COMPANY OF CALIFORNIA, N.A, as TRUSTEE FOR VENDEE MORTGAGE TRUST, Plaintiff, CIVIL DIVISION NO.: 9t1(' ~r.I 1f11f/ vs. COMPLAINT IN EJECTMENT Code 140 MORTGAGE FORECLOSURE DAVID S. RIGHTER and ALL OTHER OCCUPANTS, Filed on behalf of Plaintiff Defendants. Counsel of record for this party: Louis P. Vitti, Esquire PA I.D. 113810 Supreme Court 1101072 Louis P. vitti & Assoc., P.C. 1031 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 t....' ........- COMPLAINT IN BJBCTMENT NOTICB YOO HAVE BEEN SUED IN CXXJRl'. IF YOO WISH '.l'O IlEFE1lD AGAINST '!HE ClAIMS S'E:r FORIH IN '!HE roLI.CMNG PAGES, YOO MUST TAl<E ACl'ION wrnmr 'lWENlY (20) llo\YS AFl'ER '!HIS a:MPIAINl' AND NOl'ICE ARE SERITED, BY Em'ERING A WRITrEN APPEARANCE PERSONALLY OR BY '!HE ~ AND FILING IN WRITING wrm '!HE CXXJRl' YOOR DEFENSES AND OBJ'ECI'IONS '.l'O '!HE ClAIMS S'E:r FOR1H AGAINST YOO. Yoo ARE WARNED '1llAT IF YOO F7IIL 'ro 00 SO '!HE CASE MAY PIl('I '. . II WI'IHa11' YOO AND A JtlI:G!EN1' M1>.Y BE E1vu;!<w AGAINST Yoo BY '!HE CXXJRl' wnlJCX1I' FURlHER NOl'ICE FOR ANY M:lNEY CIAIMED IN '!HE a:MPIAINl' OR roR ANY C7lHER CIAlM OR RELIEF ~ BY '!HE PIAINl'IFF. Yoo M1>.Y I.ClSE M:lNEY OR PI<OPERIY OR cmlER RIGHIS IMroRrANr 'ro YOO. Yoo SHCX1lD TARE '!HIS PAPER 'ro YOOR !AWYER Nr ONCE. IF YOO SHCX1ID NC1l' HAVE A IAWYER, OR CANNOr AFFORD ONE, GO '.l'O OR TE!EPHONE '!HE OFFICE S'E:r FORtH BE!.CM '.l'O FIND aJr WHEm: Yoo CAN GEl' ux;;u. HELP. aJMBER!AND IAWYER REFERRAL SERVICE CXXJRl' AIroNIS'IRA'l'OR 3RD FLOOR aJMBER!AND CXXJmY o:xJRIHOUSE CARLISIE, PA 17013 TELEPHoNE: (717) 697-0371 3 vs. . . . . . . . No. . . . : . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BANKERS TRUST COMPANY OF CALIFORNIA, N.A., as TRUSTEE FOR VENDEE MORTGAGE TRUST, Plaintiff, DAVID S. RIGHTER and ALL OTHER OCCUPANTS, Defendants. COMPLAIHT IN BJBCTHBHT AND NOW, comes the above-captioned Plaintiff, Bankers Trust Company of California, N.A., et al., by and through its counsel, Louis P. Vitti & Associates, P.C. and Louis P. Vitti, Esquire, who files this complaint as follows: 1. The Plaintiff is a corporation having a principal place of business located at Three Park Plaza, sixteenth Floor, Irvine, CA'92714. 2. The Defendants are individuals, sui juris, whose last known address was 108 Walton Avenue, Carlisle, PA 17013. 3. On April 23, 1991, the Plaintiff's predecessor in title entered into an Installment Land contract with Defendants and/or their predecessors in title, the sum of Sixty Eight Thousand and no/100 Dollars ($68,000.00), and in consideration thereof, the Defendants and/or their predecessors in title, were to pay Five Hundred Twenty-Three and 01/100 per month. 4. The premises secured by the Installment Land Contract are: See description attached hereto as Exhibit "A". 5. The Installment Land Contract provides generally that in the event of default of payment and/or installment of principal and/or interest, inter alia, that it shall be lawful for Plaintiffs to institute, inter alia, an action in ejectment 6. Since September 1, 1992, the Installment Land Contract has been in default by reason of the failure of the mortgagors to make appropriate payments. 7. Defendants and/or other occupants continue to occupy the said premises described in Exhibit "A". WHEREFORE, Plaintiff prays Your Honorable Court enter Judgment in favor of the Plaintiff, for sole possession of the property and vesting the title of said premises to the Plaintiff as prayed for in the Complaint. Respectfully submitted, LOUIS P. VITTI & ASSOCIATES, P.C. LO~ TRUE COpy FROM RECORDAttorney for Plaintiff In TestfmcrlY ',~heroot, I hore unto set my hand Ind the seal. 01 saId Court I rllsle, Pa. Th c:;S"/ft day of . 19 </1./ 't.' ~ I Prolhonallly 2 , '0.' ..~.-. VERIPICATION AND NOW Louis P. vitti verifies that the statements made in this Complaint in Ejectment are true and correct to the best of his knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. By virtue of the fact that the Plaintiff is outside the jurisdiction of the court and the verification cannot be obtained within the time allowed for the filing of this pleading, the pleading is submitted by counsel having sufficient knowledge, information and belief based upon the information provided him by the Plaintiff. Dated: February 22, 1994 ALL THAT CERTAIN tract of land situate in North Middleton Tavnship, Cumberland County, ?ennsylvania, bounded and described in accordance vith a survey by Larry V. Neidlinger, R.5., ~ated Msrch 18, 1977, ss fallavs: 3EGINNING at a paint an the Vestern line of fifty (SO) feet vide Val ton Avenue at the Southeastern corner of land nay or late formerly of Daniel Dinunzio; thence along the Vestern line of said fifty (SO) feet vide Va1ton Avenue, in a Southerly direction by a curve to the right a distance of 25.476 feet to a paint; thence still along the Vestern line of said fifty (SO) feet vide Val tan Avenue by a curve to the left a distance of 56.10 feet to a nail at line ~f land nay or formerly of Quinn; thence along Northern line of said land of Quinn North 79 jegrees 28 minutes 10 seconds Vest 130.13 feet to an existing stake in line, of land nay or formerly of Clyde L. Sutton; thence by said land of Sutton North 0 degrees 59 minutes 30 seconds Vest 80 feet to an iron pin in line of land nov or formerly of Dsniel Dinunzio; thence ~y said Isnd of Dinunzio, South 80 degrees 33 minutes East 142.12 feet to an iron pin, the ?lsce of BEGINNING. arn!Q the major portion of Lot No. 4 and a small portion of Lot No. 3 as shovn on the Valton Avenue Plsn of Lots recorded in Cumberland County Plan Book 11, at Page 34, together vith the improvements thereon erected, and knovn and numbered as 108 Valton Avenue. 3EING the same premises vhich ?ennsylvanis, by deed dated Jffice of the Recorder of Deeds, in ?age 911, granted and conveyed unto the Sheriff of the County of Cumberland, in the State of , and recorded February 4, 1991, in the and for the County of Cumberland, in Deed Book 'Y' Val. 34, the Grantor herein, in fee. EXHIBIT "A" orl~:' -. ,a,- . "':~? .'F i:' /"" i..;. u ,j , .. .;" ~ ~ ~ 1~!':,:':!,-ii~''''l\);:;t!r,.~m-,1! ?iiltii1:c"i" {.." ,,};~'f,...'1;;;: ,~~'?!#"':, ":,"F'k IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANKERS TRUST COMPANY OF CALIFORNIA, N.A, as TRUSTEE FOR VENDEE MORTGAGE TRUST, Plaintiff, CIVIL DIVISION NO. : 9tJ f' 6u.;/ m~ COMPLAINT IN BJBCTKBNT Code 140 MORTGAGE FORECLOSURE vs. DAVID S. RIGHTER and ALL OTHER OCCUPANTS, Filed on behalf of Plaintiff Defendants. Counsel of record for this party 1 Louis P. vitti, Esquire PA I.D. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 1031 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 , . ,............-.- " , "'~ ,. _<':';)k',:i;i~~; ,.~,_ , t':->""_jo"";'i~"y; ^L" .' . ,,~._~..~~ COMPLAINT IN BJBCTMENT NOTICB YCX1 HAVE BEEN SUED m CXllRl'. IF YOO WISH rro IEFmID AG1UNST 'IHE CIAlMS SEl' famI m 'IHE FOLI.C:MIN.; PAGES, YOO KJST TAI<E ACl'IW wrmm '1WENIY (20) Dt\YS AFTER 'lHIS CXJoIPIAINl' AND OOl'ICE ARE SERVED, BY ENl'ERIOO A WRl'l"l'm APPEAR1INCE ~ CR BY '!'HE ATroRNEY AND FILn<<; m WIlI'I'DG Wl'lH 'IHE CXllRl' YOOR IEF.ENSES AND OBJEX::l'IWS rro 'IHE CIAIMS SEl' famI AG1UNST YOO. YOO ARE WARNED 'llIAT IF YOO mIL rro DO SO 'IHE CASE MAY I'R) '.:.] I Wl'l1DJl' YOO AND A JtltQ!ENl' MAY BE Pll'.l'l:&lJ AG1UNST YOO BY 'IHE CXllRl' wrnwr FURmER OOl'ICE :roR ANY ~ CIAIMED m 'IHE CXJoIPIAINl' OR :roR ANY 0lHER CIAIM OR RELIEF ~ BY 'IHE PIAINl'.IFF. YOO MAY I.OOE ~ OR PROPERlY OR 0lHER RIGfI'S IMOORrAm' rro YOO. YCX1 SImID TAKE 'lHIS PAPER rro YOOR IAWYER Nr WeE. IF YOO SImID 001' HAVE A IAWYER, CR CANN7l' AFFORD cm:, GO rro OR ~ '!'HE OFFICE SEl' FORlH BE:I!:M rro FIND a11' WHERE YOO CAN GEl' ImAL HEIP. C1lMBERIAND IAWYER =rmulAL SERVICE CXllRl' AI:MINIS'mA'IOR 3RD FLOOR C1lMBERIAND CXXlNl'Y CXXJRllfOOSE CARLISIE, PA 17013 TEIEPfDlE: (717) 697-0371 3 .,.....,"'....-. ...... lo,."','&tc Ull;;."",:._,iI ....".,,',.,',. " . j- tt! .1;-._ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BANKERS TRUST COMPANY OF . . CALIFORNIA, N.A., as TRUSTEE . . FOR VENDEE MORTGAGE TRUST, . . Plaintiff, . . vs. . No.: . : DAVID S. RIGHTER and ALL OTHER OCCUPANTS, . . Defendants. . . COIIPLAIII'1' :1:. BJB\,'"J,'.RIII'f AND NOW, comes the above-captioned Plaintiff, Bankers Trust Company of California, N.A., et al., by and through its counsel, Louis P. Vitti & Associates, P.C. and Louis P. Vitti, Esquire, who files this Complaint as follows: 1. The Plaintiff is a corporation having a principal place of business located at Three Park Plaza, Sixteenth Floor, Irvine, CA 92714. 2. The Defendants are individuals, sui juris, whose last known address was 108 Walton Avenue, Carlisle, PA 17013. 3. On April 23, 1991, the Plaintiff's predecessor in title entered into an Installment Land Contract with Defendants and/or their predecessors in title, the sum of Sixty Eight Thousand and nO/l00 Dollars ($68,000.00), and in consideration thereof, the Defendants and/or their predecessors in title, were ,-- .', ~""_., -~;., .. ..1!" .'. ~_.. \ltr:~ to pay Five Hundred Twenty-Three and 01/100 per month. 4. The premises secured by the Installment Land Contract arel See description attached hereto as Exhibit "A". 5. The Installment Land Contract provides generally that in the event of default of payment and/or installment of principal and/or interest, inter alia, that it shall be lawful for Plaintiffs to institute, inter alia, an action in ejectment 6. Since September 1, 1992, the Installment Land Contract has been in default by reason of the failure of the mortgagors to make appropriate payments. 7. Defendants and/or other occupants continue to occupy the said premises described in Exhibit "A". WHEREFORE, Plaintiff prays Your Honorable Court enter Judgment in favor of the Plaintiff, for sole possession of the property and vesting the title of said premises to the Plaintiff as prayed for in the Complaint. Respectfully submitted, LOUIS P. VITTI & ASSOCIATES, P.C. iD~~ Attorney for Plaintiff 2 ~ -..- -- - '~ ,".. ~';J~' "gr' ."..':> .'r." . :.. ti ,..' VBRII'ICATION AND NOW Louis P. vitti verifies that the statements made in this complaint in Ejectment are true and correct to the best of his knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. By virtue of the fact that the plaintiff is outside the jurisdiction of the court and the verification cannot be obtained within the time allowed for the filing of this pleading, the pleading is submitted by counsel having sufficient knowledge, information and belief based upon the information provided him by the Plaintiff. Dated: February 22, 1994 .>.~ ._- L:;., ::;j;/,,". ~.s_.~. ALL THAT CERTAIN tract of land aituate in North Hidd1eton Tovnship, Cumberland County, Pennsylvania, bounded and described in accordance vith a survey by Larry V. Neidlinger, R.S., dated March 18, 1977, as follovsl BEGINNING at a point on the Vestern line of fifty (50) feet vide Valton Avenue at the Southeastern corner of land nov or late formerly of Dani~l Dinunzio; thence along the Vestern line of said fifty (SO) feet vide Valton Avenue, in a Southerly direction by a curve to the right a distance of 25.476 feet to a point; thence still along the Vestern line of said fifty (SO) feet vide Valton Avenue by a curve to the left a distsnce of 56.10 feet to a nail at line of land nov or formerly of Quinn: thence along Northern line of said land of Quinn North 79 degrees 28 minutes 10 seconds Vest 130.13 feet to an existing stake in line, of land nov or formerly of Clyde L. Sutton: thence by said land of Sutton North 0 degrees 59 minutes 30 seconds Vest 80 feet to an iron pin in line of land nov or formerly of Daniel Dinunzio; thence by said land of Dinunzio, South 80 degrees 33 minutes East 142.12 feet to an iron pin, ths place of BEGINNING. BEIIIG the major portion of Lot No.4 and a small portion of Lot No.3 as shovn on the Valton Avenue Plan of Lots recorded in Cumberland County Plan Book 11, at Page 34, together vith the improvements thereon erected, and knovn and numbered as 108 Valton Avenue. 3EING the same premises vhich ?ennsylvania, by deed dated )ffice of the Recorder of Deeds, in ?age 911, granted and conveyed unto the Sheriff of the County of Cumberland, in the State of , and recorded February 4, 1991, in the and for the County of Cumberland, in Deed Book 'Y' Vol. 34, the Grantor herein, in fee. EXHIBIT "A" '".:.:....~..,;. . :.~ .."kJ 7:1- ~~ . d 1 Q~ ~ i ~ '<) ~ ~ -:r en .. "";~ ;E ;' ;~.:~~t :".: _.~- i.:.",) . ~ ' .::! J ~