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RONALD E. TIPPEIT,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY. PENNSYLVANIA
n.
.
.
: CIVIL ACTION - LAW
CRAIG A. SHRIFT and
KATHARINE A. GALLAGHER-SHRIFT,
his wife, Defendants
.
: qt..l- 4- 8''12-
: NO. _ CIVll.. TERM 1994
NOTICE
You have been sued in court. If you wish to defend against the claims set fonh 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 an attorney and filing in writing with the
court your defenses or objec:tions to the claims set forth against you. You are warned that if you
fail to do so, the case may proceed 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 TIlE
OFFICE SET FORTI! BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator - Third Roor
Cumberland County Court House
Carlisle, PA 17013
Tele: (717) 240-6200
~/!~JZL
Charles E. Shields, III
Attorney for Plaintiff
Mellon Bank Building
2 West Main Street
Mechanicsburg, PA 17055
(717) 766-0209
RONALD E. TIPPETT,
Plalnlllf
vs.
IN THE COURT OF COtJMON PlEAS
OF CU'-'BERLAND COUNTY,
PENNSYLVANIA
NO._
ACTION TO QUIET mLE
CRAIG A. SHRIFT and
KATHARINE A. GALLAGHER-SHRIFT,
his wile, Delendants
COMPLAINT
AND NOW, comes the PlalntlH, RONALD E. TIPPETT, by and through his attorney,
Charles E. Shields, III, Esquire, 01 2 West Main Street, Mechanlcsburg, Cumberland County,
Pennsylvania, and makes this complaint against the Defendants named herein, their heirs,
devisees, executors, administrators, successors, agents, snd assigns and any and all other
persons known or unknown who are claiming or may claim by, under, or through the Defendants
named herein, any right, Iilie, estate. lien or Interest In the real estate property described
herein adverse to the Plalnliff's Iitle and for cause of aclion alleges the lollowlng:
1. The Plalnliff Is Ronald E. Tippett, an adult Individual who resldss at the subject
premises, which has an address of 3800 GolMew Drive, Mechanlcsburg, Hampden Township,
Cumberland County, Pennsylvsnls, 17055 and which Is also designated as tax parcel # 10-16-
1056-011.
1 a. The Defendants are Craig A. Shrift and Katharine A. Gallagher-Shrift, his wife, who are
adult Individuals who reside at premises having an address of 1011 S. Waterford Way,
Mechanlcsburg, Hampden Township, Cumberland County, Pennsylvania, 17055.
I. RE: PLAINTIFF AND HIS PREMISES
2. Plaintiff acts for himself and his heirs, devisees, executors, administrators, and assigns
In this matter.
3. The said Plaintiff has been continuously In possession of and rasldent on the said
premises for a period In excess of eighteen (18) years.
4. The said Plaintiff has paid property taxes on the said premises for a period in excess of
eighteen (18) years.
5. The subjeot premises consists 01 a Iract 01 two (2) tracts. desarlbed as lollows:
ALL THAT CERTAIN piece or parcsl 01 land situate In the Township 01
Hampden, County 01 Cumberland and Slate 01 Pennsylvania, bounded and described
as lollows:
TRACT NO.1 BEGINNING at a point In the center line 01 a public road at the
corner 01 land 01 George A. Brooks; thence along the cenler line 01 said public road
South 87 degrees 45 minutes West 50 leet to a point In the cenler line 01 said
public road at the corner 01 land 01 Samuel R. Brooks; thence along the line 01 land
01 Samuel R. Brooks, North 8 degrees 30 minutes West 251 leetto a pin; thence
continuing along the line 01 land 01 said Samuel R. Brooks, North 42 degrees 45
minutes East 63 leet to a point In the center 01 the channel 01 a run at the line 01
land 01 Salvatore Acrl; thence down said run by ths center 01 Its channel along the
line 01 land 01 Salvatore Acrl 157 leet, more or less, to a point In the center 01
the channel 01 said run, and at the corner 01 land 01 George A. Brooks; thence along
the line 01 land 01 George A. Brooks South 31 degress West 50 leet to a point;
Ihence continuing along the line 01 land 01 George A. Brooks South 8 degrees 30
minutes East 117 leetto a point In ths center line 01 said public road, the place 01
BEGINNING.
CONTAINING 0.4301 an acre.
TRACT NO. 2 BEGINNING at a point In the center line 01 a public road, at the
corner 01 lands 01 George A. Brooks and Janet E. Brooks, his wile; thence along
said lands 01 George A. Brooks and Janet E. Brooks, his wile, North 8 degrees 30
ITJlnutes West 117 leetto a pin; thence continuing along land 01 same, North 31
degrees East 50 leetto a point In the center 01 the channel 01 a run at line 01 lands
now or lormerly 01 Salvatore Acrl; thence down said run by the center 01 Its
channel and along lands now or lormerly 01 Salvatore Acrl, a distance 01 315 leet;
more or less , to a point in the center 01 a bridge over said run, said run. said
bridge being located In the public road, South 87 degrees 45 minutes West 282
leetto a point In the center line 01 said public road, the place 01 BEGINNING.
(repetition Is In said original)
CONTAINING 0.5501 an acre.
II. RE: PLAINTIFF'S CHAIN AND DERIVATION OF TITLE.
6. The Commonwealth 01 Pennsylvania delivered a warrant, numbered 575. lor a larger
tract 01 land then situate in East Pennsborough Township, now Hampden Township, totalling
220 Acres dated June 20, 1808, to Edward Burd, Esquire and Sarah Lea, Executors 01 Edward
2
Shippen late 01 the city 01 Phlladslphla, Esquire, deceased and Trustees lor the heirs and devises
01 the said Edward Shippen and to Joseph Shippen 01 the Borough 01 Lancaster, County 01
Lancaster, Esquire.
7. Said warrant and the survey made thereon were completed on July 25, 1808 and were
returned on August 18, 1808 and accepted on August 24, 1808, and showsd, pursuant to the
surveyor's draft, a tract 01 223 Acres, 76 perches plus allowance 01 six (6%) per cent lor
roads, etc., recorded In Survey Book "C" volume 9, psge 125. (Ree copy 01 said draft made by
William Whseler, Deputy Surveyor, allached hereto as Exhibit A).
8, Subsequently, the said warrantees, on August 19, 1808, obtained a Patentlrom the
Commonwealth 01 Pennsylvania to these said lands, called "Florence", which was accepted and
recorded In Patent Book "P", volume 63, page 297 on August 24, 1808, whereby the said
warrantees obtained ownership In lee in their various capacities.
9, The said Patentees, granted the said tract known as "Florence" to Jacob Miller 01 the
County 01 Cumberland, yeoman, by deed dsted September 19, 1808 snd recorded October 31,
1809 in the Recorder's Office In and lor Cumberland County In Deed Book "T", volume 1, page
254.
10. Abraham Miller and Abraham Bretz, Executors 01 the last wilt and testament 01 the said
Joseph Mlllsr. deceased, granted and conveyed a tract 01 124 acres and 51 perches, neat
measure, being the southern part 01 the said "Florence" tract, to Joseph Eslinger by deed dated
April 13, 1840 and recorded April 14, 1840 In the Recorder's Olllce aloresald In Deed Book
"55", volume 1, page 361, (see Exhibit B.)
11. James T, Durfee, Esquire, Clerk 01 the Orphans' Court lor the County 01 Cumberland, In
the Commonwealth 01 Pennsylvania, pursuant to an order 01 the said Orphans' Court, granted
and conveyed the aloresald southern part 01 said "Florence" to Samuel L. Eslinger, by deed dated
November 6, 1899 and recorded November 22, 1899 in the Recorder's OHlce aloresald In Deed
Book "Z", volume 5, page 429. (Hampden Township having been lormed out 01 East
Pennsborough [now spelled Pennsboro) Township, In 1845. the tract was designated as being
slluate partly in Hampden Township and partly In East Pennsboro Township),
12, The said Samuel L. Eslinger and Mary J. Eslinger, his wile, granted and conveyed the
same said tract to Henry E. Barley by deed dated and recorded on April 1, 1907 In the
3
Recorder's Office aforesaid In Deed Book "0", volume 7, page 137.
13. The said Henry E. Barley and Helen M. Barley, his wife, granted and conveyed the same
said tract to Salvatore Acrl by deed dated December 15, 1923 and recorded December 17, 1923
In the Recorder's Office eforesald In Deed Book "S", volume 9, page 301.
14. The said Salvatore Acrl and Felomlna Acrl, his wile, granted and conveyed a part of the
said tract consisting of approximately two and one. half (2 1/2) Acres, and bounded on the east
by the center line of a run, to Samuel R. Brooks and Mary C. Brooks, his wife. by deed dated May
8, 1939 and recorded July 27, 1940 In the Recorder's Office aforesaid In Deed Book "E",
volume 12, page 281.
15. The description In said deed Is as follows:
BEGINNING at a point In the public road Bnd at corner of Isnds herein
conveyed and land of Ezra Wertz; thence along land of Ezra Wertz following a
fence line, North 1 degree and 45 minutes East 679 fElet to a point; thence by
other lands of the grantors South 88 degrees and 15 minutes East 73 feet, more
or less, to B Hickory Tree on the bank of the run: thence down ssld run bv the
center of Its channel as It flows 856 feet, more or less, to the center of the public
road; thence along the public road and other lands of the grantors and Harvey
Meck South 87 degrees and 45 minutes West 483 feet. more or less. to the point
In the center of said public road at the line of Ezra Wertz, the place of Beginning.
(Emphasis added). (see Exhibit C which shows the boundaries of Barley's Deed to
Acrl, Exhibit D which uses It as a basis and overlays Acrl's deed to Brooks with
designations of further subdivisions for the Plaintiff Mr, Tippell. and his
neighbor. Mr. Slack. Also. see Exhibit E which shows the pertinent parts of a
survey by Mr. Rechel which was aU ached to Deed 19 Q 335 as an Exhibit).
1 6. The said Samuel R. Brooks and Mary C. Brooks, also known as Mary Brooks, his wile,
granted and conveyed a part of tho said tract, being Tract NO.2 of the subject premises herein.
to George A. Brooks, by deed dated June 21,1947 and recorded July 1. 1947 In the Recorder's
Office aforesaid in Deed Book "N". volume 13. page 341.
17. Subsequently, the said Samuel R, Brooks and Mary C. Brooks. his wile. and the said
George A, Brooks, for various and sundry purposss appearing in the deed, granted and convsyed
the said Tract No.2, to George A. BrOOKS and Janet E. Brooks, his wile. by deed dated September
22. 1960 and recorded September 27. 1970 In the Recorder's Office aforesaid In Deed Book
"A", volume 20. page 42.
18. The description In said deed Is as follows:
4
BEGINNING at a point In the center line of a public road, at the corner of
lands of George A. Brooks and Janet E. Brooks, his wife: thence along .ald land of
George A. Brooks and Janet E. Brooks, his wife, North 8 degree. 30 minutes
West, One hundred seventeen (117) feet to a pin; thence continuing along lands of
same, North 31 degrE/es East, fifty (50) feet 10 a DOlnl In Ihe llenler 01 Iha
channel of A run at linG of lands now or formerly of SalvAtore A.cri: thAnCR down
said run by Ihe cenler ollis channel and along lands now or formerly of Salvatore
Acrl, a distance of Three hundred flheen (315) feet, more or less, 10 a point In
the center of a bridge over sold run, sold bridge being located In the public road
aforesaid; thsnce along the center IIno of said public road, Soulh 87 dsgrees 45
minutes West. two hundred eight-two (282) feet to a point In the cenler line of
said public road, the place of BEGINNING.
CONTAINING fifty. live one-hundredths (.55) of an acre. (Emphasis
added)
19. Also, the sold Samuel R. Brooks snd Mary C. Brooks. his wlfll, granled and conveyed
another part 01 the said Iracl, being Tract No.1 of the subject premises herein, to George A.
Brooks and Janet E. Brooks. his wife, by deed dated January 28, 1960 and recorded February 6,
1960 In Ihe Recorder's Office aforesaid in Deed Book "a", volume 19, page 332.
20. The dsscrlptlon In said deed Is as follows:
BEGINNING at a point In the center line of a public road 01 the corner of
land of George A. Brooks; thence along the center line of sold public road Soulh
eighty-seven (87) degrees forty-five (45) mlnutos West. flhy (50) feet to a
point In the center line of said public road at the corner of land of Samuel R.
Brooks; thence along the line of land of Samuel R. Brooks. North eight (8)
degroes thirty (30) minutes Wesl. two hundred flhy-one (251) feet to a pin;
thence continuing along the line of land of said Samuel R. Brooks, North forty-two
(42) degrees forty-five (45) minutes East. slxty.three (63) feet to a DOlnl In
the canter of the channel of a run at tho line of land of Salvatore Actl: thBnC9 down
said run by the center of lis channel and along the line of land of Salvatore Acrl
one hundred fifty. seven (157) feet, more or less, 10 a DOlnl In the llenter of the
llhannel of said run. and at the corner of land of George A. Brooks; thence along the
line of land of George A. Brooks South thirty-one (31) degrees West flhy (50)
feet to a point; and thence continuing along the line of land of George A. Brooks
South eight (8) degrees thirty (30) minutes East. one hundred seventeen (117)
feet 10 a point In the center line 01 said pUblic road. the place of BEGINNING.
CONTAINING forty.three hundredths (0.43) of an acre. (Emphasis added)
21. The said George A. Brooks and Janet E. Brooks. his wife. granted and conveyed both IraQla
5
~ and ~ comprising the entirety 01 the subject premises herein, to Ronald E. Tippett and
Judith A. Tlppetl, his wile, by deed dated and recorded August 28, 1975 In the Recorder's OIRce
aforesaid, In Deed Book "F", volume 26, page 527.
22. The said Ronald E. Tlppell and Judllh A. Tlppell. his wile granted and conveyed the said
premises to Ronald E. Tlppetl by dead dated June 17, 1992 and recorded August 17, 1992 In the
Recorder's Office alorssald In Deed Book "V", volume 35, page 410, whereupl)n lull IIl1e to the
subject premises bscame vested In the Plaintiff herein.
III. RE: DEFENDANTS' CHAIN AND DERIVATION OF TITLE.
23. Delendants' chain 01 tllle Is derived Irom the same prlmery sources as Is Plalnllffs es Is
more lully outlined and explained In Paragraphs 6 through 13 above.
24. Alter Salvetore Acrl and Felomlna Acrl, his wile, had alreedy granted and conveyed the
tract relerred to In Paragraphs 14 and 15 above to Samuel R. Brooks and Mary C. Brooks, his
wile, the said Acrls granted and conveyed a large tract composed 01 what were once lour separate
larms. Including the balance 01 the Barley tract to Ovldlo Acrl and Ellglo Acrl. by dsed dated and
recorded May 27, 1940 In the Recorder's Office aloresald In Deed Book "0," volume 12, page
375.
25. The description In said deed Is as follows:
BEGINNING at a point near a white oak tree along the public road and
opposite the land of Mrs. Arnold (Bretz Estate) and at the land conveyed to Edward
B. McClune; thence North 67 degrees East 575 feet, more or less, to an Iron road
et the corner of the land of Samuel R. and Ruth A. Moore land North 39 degrees
East 263 feet to the site of hickory stump near a sour cherry tree and at corner
of the land of Ralph Early; thence along the Isnd of Ralph Easily North 88 degrees
East 73 perches (1204.5 It.) to a stone; thence by same South 39 degrees 15
minutes East 18.5 perches (305.25 It.) to a stump; North 61 degrees East 53
perches (874.5 It.) to a point In the Holtz Run and other lands of S. Acrl,
grantor; thence down Holtz Run South 34 degrees 45 minutes east 12.6 perches
(207.9 It.); thence by same South 61 degrees 15 minutes East 8 perches (132
It.); thence by same South 45 degrees 45 minutes East 15.3 perches (252.45
It.) to a point In the run; thence stili by the land of S. Acrl South 52 degroes 45
minutes West 14 perches (231 It.) to a chestnut oak; thence by same South 72
degrees 15 minutes West 6 perches (99 11.) to a stone; thence sill! by Acrl South
12 degrees 45 minutes East 19.5 parches (321.75 ft.) to a point where the
Cornman farm joins the Holtz farm; thence by the same bearing 32.5 parches
(536.25 It.) a total of 858 feet to corner of tha Moore Farm; thence stili by Acrl
land North 81 degrees 45 minutes East 443.85 feet. more or less to a black oak.
6
8tthe comer ollhe land 01 C. Malaro; thence by Magaro land South 32 degrees 45
minutes East 34.3 perches (565.95 II.) to the corner 01 the Magaro land at or
near a cherry tree; thence by same North 83 degrees East 8.5 perches (140.25
II.) more or less, to a point In the Holtz run; thence Southeasterly In the center
01 the run 375 'eetto a point In the run at the land 01 Edward B. McClune and near
a pine tree; thence along the line 01 McClune South 54 1/2 degrees West 120
leet, more or less, to a dogwood tree; thence stili by McClune lollowlng a lence
line South 21 degress 30 minutes East2121eelto a bend In the lence line; thence
by same South 0 degrees 30 minutes East along the fence 573 leetto a bend In the
fence; thsnce South 7 degrees East 200 leet, more or less, 10 a post at corner 01
the lence Line; thence stili by McClune North 87 1/2 degrees East 520 leet.
more or less. to the Conodogulnet Creek; thence Southerly up along the creek
2130 leet. more or less, to the line 01 land 01 Herman Grennlnger; thence along
ths Grennlnger IBnd South 87 degrees West 127 perches (2095.5 II.) to a point
at the line 01 the land 01 Harvey Meek; thence along the Meek land North 48
degrees West 285 leet. more or less, to a point In the run and at land 01 Samuol L.
and MaN C. Brooks: thence un thA run and ~v the land of Brooks Northw9slar(v
880 lost. moro or loss to 0 hlcko(y troo; thence by same North 88 3/4 degrees
West 70 feet to the line 01 I. C. Wertz; thence along the land 01 Wertz North 1 1/4
degrees East 1035 leet. more or less to a point; thence by same North 12 degrees
East 958.65 leet to a point at the line 01 the Holtz larm, thence 511I1 by Wertz
South 80 degrees 30 minutes West 6.24 perches (86.46 It.) to a point at the
corner formerly 01 the Cornman larm; thence stili by Wertz North 77 degrees
West 62.2 perches (1026.3 It.) to a point; thence by same North 76 degrees
West 30.2 perches (498.3 It.) to a post; thence by same South 9 degrees 30
minutes West 28.3 perches (467 It.) to a corner; thence by I. C. Wertz South 83
degrees 16 mlnutss West 34.76 porches (673.64 It.) to the line of the land of
George Feister; Ihence by Feister land North 4 degrees 30 minutes East 31.1
perches (613.16 It.) to a point; thence by same North 16 degrees 16 minutes
East 42.6 perches (702.9 ft.) to a corner at public road; thence along the same
North 85 degrees West 37.6 perches (618.'75 It.) 10 the corner 01 public roads;
thence along public road and the land 01 G. C. Roth North 14 degrees 16 minutes
East 965 leet to a point at or near the white oak tree, the place 01 BEGINNING.
CONTAINING three hundred and thlrty.live (335) acres, more or less.
(emphasis added) (Inconsistencies In spelling and the like are In original.)
26. The successors in title to the said Acrls. to wit: CCNB Bank, N.A., 01 Camp Hili,
Cumberland County, Pennsylvania. TflJstee 01 the Elizabeth Mary Acrl Trust, and Elizabeth
Mary Acrl, widow, 01 East Pennsboro Township. Cumberland County. Pennsylvania, snd CCNB
Bank, N.A. and Michael F. Acrl. Co.executors 01 the Estate 01 Ellglo E. Acrl. granted and conveyed
a tract 01 approximately 145 Acres. Including ths area bounded on the herein mentioned run,
7
subject to some reservallons and exceptions, to Soulh Cenlral Service Corporallon, a
Pennsylvania Corporation, Chester J. Acker and Helen M. Acksr, his wife, and Hampden Square
Develcpment Company, a Pennsylvania lImlled Partnership, by lis General Partner, Detweiler
Enterprises, Inc.. by deed deted June 26, 1982 and recorded June 29, 1982 In the Recorder's
Office aforesaid In Deed Book "U," volume 29. page 983.
27. The description In said deed Is as follows:
BEGINNING at a spike In the center of a public road; thencs along lands
now or formerly of S. Acrl, North 81 degrees 46 minutes East, 253.85 feet to a
black oak; thence along lands now or formerly of C. Magaro, South 32 degrees 46
minutes East, 665.96 feet to a point near a cherry tree; thence along lands now
or formerly of C. Magaro, North 83 degrees East, 140.26 feel to a point In the
Holtz Run; thence southeastwardly along the center of ths Holtz Run, 375 feel to a
point ne.ar a pins tree; thence along lands now or formerly of Edward B, McClune,
South 64-1/2 degrees West, 120 feet to a dogwood tree; thence by lands now or
formerly of Edward B. McClune. South 21 dsgrees 30 minutes East, 212 feet to a
bend In the fence line; thence by lands nor or formerly of Edward B. McClune,
Soulh 00 degrees 30 minutes East, 673 feet to a bend In the fence; thence along
lands now or formerly of Edward B. McClune. South 07 degrees East, 200 feet to
a post 620 feet from the west bank of the Conodogulnet Creek; thence southwardly
along lands nor or formerly of Ovldlo Acrl, 2130 feet, more or less, to a point In
lands nor or formerly of Herman Grennlnger, 620 feet from the west bank of the
Conodogulnet Creek; thence along lands now or formerly of Herman Grennlnger,
South 87 degrees West, 1575.5 feet to a point; thence along lands nor or
formerly of Harvey Msck, North 48 degrees West, 286 feet 10 a oolnlln a Run'
th9n~9 northwardly alaMQ said Run. 880 f99t to a hlcko{y trees; thence along
lands nor or formerly of Samuel L. Brooks. el ux, North 88-3/4 degrees West,
70 feet to a point; thence along lands nor or formerly of I. C. Wertz, North 1-
1/4 degrees East, 1035 feet to a point; thence along lands now or formerly of I.
C. Wertz, North 12 degrees East. 958.65 feet 10 a point; thence along lands nor
or formerly of I. C. Wern, South 80 degrees 30 minutes West, 85.46 feet to a
point; thence elong lands nor or formerly of I. C. Wertz, North 77 degrees West,
150 feet. more or less, to a stake; thence along lands now or formerly of Ovldlo
Acrl. North 16 degrees East, 286.5 feet to a Slake; thence along lands now or
formerly of Ovldlo Acrl, South 80 degrees 38 minutes East, 1315 feet to a center
of a public road; thence along the center of said public road, North 03 degrees 05
minutes East 516 feotto a stake In the center of said public road; thence along the
center of said public road, North 64 degrees 33 minutes West, 155.8 fest to a
stake in the center of said public road; thence along the center of said public road,
North 10 degrees 47 minutes West, 493 feet to a spike, the Place of BEGINNING.
CONTAINING 145 acres and 60 perches, more or less. (emphasis added)
8
28. SubSGquentto the signing, sealing, delivery and aa:eptance 01 the aloresald deed from
CCNB Bank, N.A.. et ai, to South Central Service Corporation. et ai, In or about April 011989,
Gannell Fleming Civil Engineers apparently proceeded to surveyor approved a survey 01 the
aforesaid described property clearly bounded by the center line 01 the run separating the said
property Irom that 01 Messrs. Slack and Tlppell.
29. In connection wllh said survey, a subdivision plan was prepared lor the owners: South
Central Sarvlce Corporation; Chester J. Acker and Helen M. Acker, his wile; and Hampden
Square Development Company and lor the Developer: Pamay Development Company, Inc.
30. The said subdivision plan Includes an owner's statement which slates: "It Is hereby
certified that the undersigned has legal or equitable title to the land shown," The statement Is
then signed by the said owners or their authorized representatives.
31 . Based at least partly upon said representation, the said subdivision plan was
recommended lor approval by the Hampden Township Planning Commission on May 11,1989.
was reviewed by the Cumberland County Planning Commission on May 18,1989. was examined
by the Hampden Township Board 01 Commissioners on June 6, 1989, was approved by the
Hampden Township Engineer on June 22, 1989 and was recorded In the Recorder's Office
aloresald on June 23. 1989 In Plan Book 58. page 79 under the title: "Phase VIII. Final
Subdivision Plan 01 Klngswood."
32. Said Final Subdivision Plan totally and flagrantly Ignored the clearly established
boundary 01 long standing between the tract surveyed and designated on said Subdivision Plan as
"Out Parcel" and that of Messrs. Tippett and Slack.
33. Pursuant to said Final Subdivision Plan, South Central Service Corporation. Hampden
Square Limited Partnership. Chester J. Acker and Helen M. Acker. his wife, granted and
conveyed the said "Out Parcel" of apprl)xlmately 17.502 Acres to Pamay Development Co., Inc.,
a Pennsylvania business Corporation with Its principal offices In Hampden Township,
Cumberland County by deed dated August 7,1989 and recorded August 8. 1989 In the
Recorder's Office aforesaid In Deed Book "C," volume 34, page 318.
34. The description In said deed Is as follows:
BEGINNING at a point on the northerly sideline of Gollvlew Drive. a IIIIy
foot (50') public rlght.of.way at the northeastern corner of an area shown as
9
.out parcel" on the aloresald plan; thence by Gollvlew Drive tha lollowlng live
courses and distances: 1. South seventy.llve degrees forty-six minutes twenty
seconds Wsst (S 75" 46' 20" W), a distance 01 elghty.one and live one
hundredths leet (81.05'); 2, By the arc 01 a curve to the left having a radius 01
lour hundred leet (400'), an arc length 01 one hundred eight-two and sixty.
seven one hundredths leet (182.67'); 3. South lorty-nlne degrees thirty-six
minutes twenty seconde West (S 49' 36' 20" W), a distance 01 eighty-six and
six one hundredths leet (86.06'); 4. By the arc 01 a curvo to the right having a
radius 01 three hundred seventy feet (370'), an arch length 01 one hundred
seventesn and seventy-live one hundredths leet (117.75'); and 5. South
sixty-seven deorees Ilfty minutes twenty seconds West (S 67' 50' 20" W), a
distance 01 ninety and Ilfty-nlne one hundredths leet (90.59'); thence tly lands
now or tormArlv of C. E. SIA~k. tha followlna fluB is} courS98 and dlstanC9&~ 1.
North sixty daorS8S forty-one minutes fortY-Rlahl seconds Wast iN 800 41' 48"
W\. II dls'aneA of on9 hundred twelVA and slxt99n onA hundrAdths f99t (112.16'\:
2. Nrt"h fifty-nine dAtURA!; thlrty.'lvA mlnutas two sAconds WAst iN 590 35'
02" W\. a dlstancA of elahtv.nlne And sbctv-fivA one hundredths fAAt 189.65'\:
~. North twenty. four dArueRs flftv.two minutes flftv.one BAconds West iN 24t\
52' 51" W\. II distance of two hundred eloht99n and SAven'A9n onA hundrAdths
f~At (218.17'\- 4 North tAn dearAA8 tWAntV..RAven mlnutAs fifty..two s9C~nds
WARt IN 100 27' 52" W\. a dlRtAnce of threA hundred ninety..nine and ninety..
one hundredths feet 1399.91 '\' 5. North eiahty..slx dAQrees thlrtv-one
minutes t11fy-one seconds West IN 880 31' 51" W\. a distance of sAventy-three
lael 173'\ 10 a oolnt; thence by lands now or lormerly 01 pamay Development Co.,
Inc. the lollowlng eight courses and distances: 1. North eight degrees thirty.
two minutes twenty seconds West (N 080 32' 20" W), a distance of ninety-live
and sixty-three one hundredths leet (95.63'); 2. North seven degrees seven
minutes Ilfteen seconds West (N 07' 07' 15" W). a distance 01 lour hundred
ninety-eight and thirty-lour one hundredths leet (498.34'); 3. North lorty.
seven degrees zero minutes zero seconds West (N 470 00' 00" W), a distance 01
nine and thirty-two one hundredths feet (9.32'); 4. North lourteen degrees
nineteen minutes twenty-one seconds East (N 140 19' 21" E), a distance 01 two
hundred seventy.seven and eight-three one hundredths leet (277,83'); 5,
North eleven degrees ten minutes thlrty-nlnll seconds West (N 11' 10' 39" W),
a distance 01 two hundred twenty-lour leet (224'); 6. North twenty.three
degrees twenty-five mlnutss thirty-nine seconds West (N 23' 25' 39" W), a
distance 01 one hundred live and seventy -six one hundredths leet (105.76');
7. North lorty-Iour degrees twenty.three minutes IIfty seconds East (N 44' 23'
50" E), a distance 01 thirty-eight and ninety-eight one hundredths leet
(38.98'); and 8, North lourteen degrees seventeen minutes three seconds East
(N 140 17' 03" E), a distance 01 thirty-lour and thirteen one hundredths leet
(34,13') to a point; thence by lands now or formerly 01 South Central Service
Corporation, et , al., the lollowlng two (2) courses and distances: 1. South
sevanty.llve degrees lorty.two minutes fifty. seven seconds East (S 75' 42'
10
157" E), a distance 01 ninety-nine and lorty one hundredths leet (99.40'); 2,
North lourteen degrees twenty-seven minutes lilly-live seconds East (N 140 27'
55" E), It distance 01 seventy leet (70') to a point; thence by lands now or
lormerly 01 The Highlands 01 Hempden Square Partnership, the lollowlng ten
(10) courses and distances: 1. South seventy-lIvs degrees thirty-two minutes
live seconds East (5 7150 32' 05" E), a distance 01 two hundred seventy-two and
three one hundredths feet (272.03'); 2. South twenty-eight degrses thirty-
six minutes thlrty.nlne seconds West (5 280 36' 39" W), a distance 01 two
hundred lilly-eight and forty.slx one hundredths feet (258.46'); 3. South
fourteen degrees zero minutes zero seconds Eest (5 14000' 00" E), a distance or
seven hundred slxty.llve leet (765'); 4, North soventy-slx degrees zero
minutes zero seconds East (N 760 00' 00" E), a distance of one hundred lorty-
feet (140'); 5. South fourteen degrees zero minutes zero seconds East (5 140
00' 00" E), a distance 01 two hundred sixty leet (260'); 6. South seventy.slx
degrees zero minutes zero seconds West (5 760 00' 00" W), a dlstence 01 one
hundred forty leet (140'); 7, South lourteen degrees zero minutes zero
seconds East (5 14" 00' 00" E), a distance of two hundred lilly-five leet
(255'); 8. South lorty-slx degrees zero minutes zero seconds East (5 140 00'
00" E), a distance of one hundred seventy-live feet (175'); 9. North eighty-
six degrees twenty-live minutes lilly-nine seconds East (N 860 25' 59" E), a
distance of one hundred sixty-four and forty-live one hundredths feet
(164.45'); 10. North sixty-eight dtlgrees thlrty.elght minutes fifty seconds
East (N 680 38' 50" E), a distance of one hundred leet (100') to a point; thence
by lands now or lormerly of KormushoH, South fourteen degrees thirteen
minutes forty seconds East (5 140 13' 40" E), a distance 01 one hundred live leet
(105') to a point on the northerly sideline 01 Gollvlew Drive, the point and place
of BEGINNING.
CONTAINING 17,5020 Acres. more or less. (emphasis added to area of
boundary along lands of Messrs. Tippett and Slack; also note the second call
therein Is erroneously described as N 590 35' 02" W, whereas the plan as
recorded lists this call as N 690 35' 02" WI. (Also. several minor variations In
written number versus numeral are In originaL)
35. The said Pamay Development Co,. Inc. granted and conveyed the seme tract Immediately
described above to Highlands of Hampden Square Partnllrshlp, e Pennsylvania Partnership by
deed dated August 7, 1989 and recorded August 9, 1989, In thl! Recorder's OHlce aforesaid In
Deed Book "C," volume 34, page 373.
36. In the meantime. for the purposes and benefit of the said Hampden Square Partnership,
In or about March of 1989, Act One Consultants, Consulting Engineers apparently proceeded to
surveyor spproved a survey further subdividing the said "Out Parcel" above-described, Into
1 1
numerous smallsr lots which. so lar as they bounded the aloresald properties 01 Messrs, Tlppell
and Slack, Ignored the long established and clear boundary line 01 the center line 01 the run.
37. The said subdivision plan Includas a statement and certification: "Ills hereby certified
that the undersigned has legal or equllable lIt1e to the land shown hereon." There Is a lurther
statement that the equllable owner Is Highlands 01 Hampden Square Partnership. The statement
Is then signed by the managing partner 01 Hampden Square.
38, Based at least partly upon said representation, the said subdivision plan was
recommended lor approval by the Hampdsn Township Planning Commission on May 11. 1989.
WIlS reviewed by the Cumberland County Planning Commission on May 18, 1989. was approved
by the Hampdsn Township Commissioners on June 6, 1989. was approved by the Hampden
Township Engineer on September I, 1989 and was recorded In the Recorder's Olllce aloresald
on September I, 1989 In Plan Book 59. page 3 under the lIt1e: "Preliminary/Final
Subdivision Plan 01 Highlands 01 Hampden Square, Phase III".
39. Pursuant to said erroneous survey and plan. the said Highlands 01 Hampden Square
proceeded to grant and convey assorted properties along the boundary with Messrs. Tippen and
Slack to various Individuals and entities.
40. Among the said grants and conveyances was one Irom the said Highlands 01 Hampden
Square to the Otllendants herein. Craig A. Shrill and Katherine A. Gallagher-Shrill, his wile. by
deed dated November 29,1989 and recorded December 6.1989 In the Recorder's Office
aloresald in Deed Book "H," volume 34, page 831,
41 . The descrlpllon In said deed Is as follows:
BEGINNING at a point on the westerly rlght-ol.way line 01 South
Waterlord Way, a filly (50.00') loot rlght.ol-way, at the beginning point 01 the
curve 01 a cul-de-sac at the dividing line 01 Lot 594 and Lot 593 01 the plan 01
lots 01 The Highlands 01 Hampden. Phase III, said point being located on a course 01
South lourteen degrees zero mlnutss zero seconds East (S 140 00' 00" E) a
distance 01 three hundred lilly-six and twenty-six hundredths (356.26') leet
Irom the center line 01 Bentley Road. a IIIIy (50.00') foot wide rlght-ol-way;
thence along said rlght.ol-way line 01 South Waterlord Way along the arc 01 a
curve to the right having a radius 01 twenty-live (25.00') leet and an arc
distance 01 twenty-three and fllly.llvs hundredths (23.55') leet to a point;
thence continuing along said right-of-way line along the arc 01 a curve to the
lell, having a radius 01 sixty (60.00') feet and an arc distance 01 eighty-one and
sixteen hundredths (81,16') leet to a point; thence along Lot 592 of the aloresald
plan on a course 01 Soul.h IIfty-two degrees twenty-seven minutes lilly-live
12
seconds West live hundred fllly.two degrees twenty-seven minutes lilly-five
seconds West (S 52. 27' 55" W) a dlslance 01 Ons hundred sevsnty-elght and
lorty-one hundredths (178.41') leetto a point; Ihence alono land now or
formArly of Ftonllld E. And .Judlth A TlpP'l" on II MUlA. of North tWAnty.'our
rtAtlrllAA fiftv.two minutAs fifty-on.. ssconds Wesl {North 240 52' 51" W\ A
dllltant!A of slohty and fourtAIl" hundredths 180.14'\ fAAt to II polnt~ th9nt!A alenn
lAnd now or form",rly of CharlA! E. Slack on a Mur89 of North ten deorAA8
twenty-RAven minutes flhy..two seconds WAst iN 100 27' 52" W\ 9 dll,aheA of
elohl-lIve and 10rly-one hundredths 185.41 'I leel 10 IJ point; thence along Lot
594 01 the aforssald plan on a course 01 North seventy-six degrees zero minutes
zero seconds East (N 76. 00' 00" E) a distance of two hundred three and lorty-
lour hundredths (203.44') leet to a point, the point and place 01 BEGINNING.
Said Lot being traversed East-West by a portion 01 a 30 foot sanitary
sewer easement along Ihe southern boundary and a portion 01 a 20 loot storm
sewer easement along Ihe northsrn boundary, said lot also being traversed
North-South by a 30 1001 combination bicycle path and sanllary sewer easement,
and a portion 01 a 30 1001 stream easement (15' Irom CILlo
BEING Lot 593 on the Preliminary/Final Plan 01 The Highlands 01
Hampden Square, Phase III, prepared by Act One Consullants, dated March 30,
1989. last revised June 1, 1989, and recorded In the Office 01 the Recorder of
Deeds In and lor Cumberland County, Pennsylvania. In Plan Book 59, Page 3.
(emphasis added to area 01 boundary along lands 01 Messrs. Tippett and Slack).
42. Said description along Plaintiff's boundary and Delendant's alleged boundary has
resulted In an adverss claim on record to Plaintiff's property In that the Delendant's claimed
boundary line clearly crosses the long established and clear real boundary line between
Plaintiff and Delendant as Is shown on Exhibit F.
43. As a result 01 the above stated errors and lalse claims to an Improper and unlawlul
boundary, there Is a cloud upon Plaintiff's title.
44. The said cloud renders the said Plaintiff's said property less than marketable In that II
exposes the Plaintiff, or any assignee, grantee, devisee. or the like 01 the Plalntlflto the
hazards 01 litigation.
13
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SHERIFF'S RETURN
<XM-1QNWEALW OF PENNSYLVANIA,
COUNTY OF Cl1>1BERLAND
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No, 94-4842 Civil
Notice Civil Action, Complaint
Action To Quiet Title
Ronald E, Tippett
VS
Craig A, Shrift and Katharine A,
Gallagher Shrift, his wife
Wesley Cook
_, SIWiOOnX0VC Deputy Sheriff of
Cunberland County, Pennsylyania, who being duly sworn according to law, says,
that he served the within
Notice
T it Ie
Shrift
Civil Action, Complaint Action to Quiet
upon Crfliq and Katharine
, the defendant, at 6:00
0' clock
p ,M, 01"11 EDST, on the
31st
day of --Au.gll ~ t
, 19.ilAat
1011 South Waterford Way, Mechanicsburg , Cunberland County,
Pennsylvania, by handing to Katharine Shri.ft, for herself and on behalf
of her husband Craig Shrift
a true and attested copy of the Notice
T 1 tle
and at the same time directing her
Civil Action,Complaint Action to Quiet
- '
attention to the contents thereof and
the "Notice to Plead" endorsed thereon,
Sheriff's Costs.
Docketing
Serv ice
Affidavit
Surchdrgc
14,00
7,84
So answers. . v 4
r'~---'~< /c,;';:..~
R. Thanas Kline, Sheriff
2,00
2),84 Pd, by Atty,
9-1-94
by
y;'
-:/ ~',
.. d-c/('
SWolTI and subscribed to before me
this
. ",.
'. -
,
day of J'.fl;-""- ~',,-
A.D.
19
Iii/
~7" (,i }I',~G..~~
Prothonotary
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