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HomeMy WebLinkAbout02-4339ROBERT G. SMITH, JR. Plaintiff V. STANLEY D. ADLER; JR., ROBERT A. ADLER AND PAUL J. KILLION, CO-EXECUTORS OF THE ESTATE OF STANLEY D. ADLER, JR., DECEASED AND BETTY J. ADLER; ROBERT A. ADLER AND PAUL J. KILLION, CO-EXECUTORS OF THE BETTY J. ADLER, DECEASED Defendants : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA NO. 4321 CIVIL 1992 REVIVED TO NO. 97-4964 CIVIL 1997 CIVIL ACTION - LAW a2 - 0422y : a-Wrz: OF PRAECIPE FOR WRIT OF REVIVAL To the Prothonotary: Issue writ of revival of judgment entered to Cumberland County No. 4321 Civil 1992, previously revived to No. 97-4964 Civil 1997, and index it in the judgment index against STANLEY D. ADLER, JR.; ROBERT A. ADLER AND PAUL J. KILLION, CO- EXECUTORS OF THE ESTATE OF STANLEY D. ADLER, JR., DECEASED AND BETTY J. ADLER; ROBERT A. ADLER AND PAUL J. KILLION, CO-EXECUTORS OF CS-M7EAKrHE BETTY J. ADLER, DECEASED in the amount of $64,509.50 plus costs and interest from November 5, 1992. David A. Wion, Esquire 109 Locust Street Harrisburg, PA 17101 (717) 236-9301 Attorney for Plaintiff ID # 06883 N r '- a it ROBERT G. SMITH, JR. IN THE COURT OF COMMON PLEAS OF VS. STANLEY D. ADLER,JR., ROBERT A. ADLER AND PAUL J. KILLION, CO-EXECUTORS OF CUMBERLAND COUNTY, PENNSYLVANIA THE ESTATE OF STANLEY D. ADLER, JR., CIVIL ACTION - LAW DECEASED AND BETTY J. ADLER; ROBERT A. ADLER AND PAUL J. KILLION, NO. 02-4339 CIVIL TERM 19 CO-EXECUTORS OF THE ESTATE OF BETTY J. ADLER, DECEASED C/O WILLIAM L. ADLER, ESQ. 125 TACUST STREET 14RIT OF REVIVAL HARRISBURG, PA 17101 TO STANLEY D. ADLER JR TE OF STANLEY D. ADLER, JR., DECEASED AND BETTY J. ADLER; ROBERT A. ADLER AND PAUL KILLION, CO-EXECUTORS OF THE ESTATE OF BETTY _J. AD You are notified that the Plaintiff has commenced a proceeding to revive and continue the lien of the judgment entered to NO. 97-4339 CIVIL TERM 19 The Plaintiff claims that the amount due and unpaid is $ 64.509.50 with interest from November 5, 1992 You are required within twenty (20) days after service of this Writ to file an answer or otherwise, plead to this writ. If you fail to do so, judgment of revival will be entered. Costs $_88.56 PH Atty 2.00 Co. _ Curtis R Long PROTHONOTARY Date September 10, 2002 -19- 19- C .OAt X DEPUTY Seal David A. Wion, Esquire Attorney for the Plaintiff 109 Locust Street Hrrrisburg. PA 17101 717-236-9301 ID # 06883 SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-04339 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SMITH ROBERT G JR VS ADLER STANLEY D JR ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: ADLER STANLEY D JR CO-EXEC ESTATE OF STANLEY D ADLER JR but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within WRIT OF REVIVAL On October 2nd , 2002 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Dauphin Cc 55.50 .00 92.50 10/02/2002 WION ZULLI SEIBERT Sworn and subscribed to before me this •7" day of (_O So answe R. Thomas Kline Sheriff of Cumberland County o2A. D. ?_1y N. i , T`9 Prothonotary SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-04339 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SMITH ROBERT G JR VS ADLER STANLEY D JR ET AL Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: KILLION PAUL J CO-EXEC ESTATE OF STANLEY D ADLER JR, DEC'D but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within WRIT OF REVIVAL On October 2nd , 2002 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 6.00 Out of County .00 Surcharge 10.00 .00 .00 16.00 10/02/2002 WION ZULLI SEIBERT Sworn and subscribed to before me this I ? day of &L,- So answer ti - TThomas Kline Sheriff of Cumberland County o2vy? A. D. Q a Prothonotary SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-04339 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SMITH ROBERT G VS ADLER STANLEY D JR ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: ADLER BETTY J CO-EXEC ESTATE OF BETTY J ADLER, DECEASED but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within WRIT OF REVIVAL On October 2nd , 2002 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs Docketing 6.00 Out of County .00 Surcharge 10.00 .00 .00 16.00 10/02/2002 WION ZULLI SEIBERT So answe Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this 7 'EE day of 6)e-7t??/, , 2UfZ A.D. ?tho02 Tkd-,L? notary SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-04339 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SMITH ROBERT VS ADLER STANLEY D JR ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: ADLER ROBERT A CO-EXEC ESTATE OF BETTY J ADLER, DECEASED but was unable to locate Him deputized the sheriff of DAUPHIN serve the within WRIT OF REVIVAL County, Pennsylvania, to On October 2nd , 2002 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 6.00 Out of County .00 Surcharge 10.00 .00 nn in his bailiwick. He therefore So answer i R T omas Kline Sheriff of Cumberland County 10/02/2002 WION ZULLI SEIBERT Sworn and subscribed to before me this 'r" day of aG0 L A. D. Prothonotary SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-04339 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SMITH ROBERT G JR VS ADLER STANLEY D JR ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: KILLION PAUL J CO-EXEC ESTATE but was unable to locate Him deputized the sheriff of DAUPHIN serve the within WRIT OF REVIVAL County, Pennsylvania, to On October 2nd , 2002 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 6.00 Out of County .00 Surcharge 10.00 .00 .00 16.00 10/02/2002 WION ZULLI SEIBERT So answer R. T omas Kline Sheriff of Cumberland County Sworn and subscribed to before me this -7 a' day of atic-f,", ,duo .z A.D. i Prothonotary BETTY J ADLER, DECEASED in his bailiwick. He therefore i'A f f-ce of P ,*hPxtff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin SMITH ROBERT G JR ADLER BETTY J Sheriff's Return Vs No. 2188-T - - -2002 OTHER COUNTY NO. 02-4339 upon AND NOW:September 19, 2002 at 2:10PM served the within WRIT OF REVIVAL ADLER ROBERT A C/O WILLIAM L ADLER ESQ to DEFT of the original WRIT OF REVIVAL to him/her the contents thereof at 125 LOCUST ST HBG, PA 17101-0000 Sworn and subscribed to refore me this 26TH day of SEPTEMBER, 2002 r\ _1 t t { PROTHONOTARY by personally handing So Answers, J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy and making known Sheriff of hin?unty, Pa. /. By puty Sheriff Sheriff's Costs: $166.50 PD 09/23/2002 RCPT NO 169422 1 true attested copy(ies) ET of t4r ?s4Pxt Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin SMITH ROBERT G JR vs ADLER BETTY J Sheriff's Return No. 2188-T - - -2002 OTHER COUNTY NO. 02-4339 AND NOW: September 19, 2002 at 2:10PM served the within WRIT OF REVIVAL ADLER STANLEY D JR C/O WILLIAM L ADLER ESQ to DEFT of the original upon by personally handing 1 true attested copy(ies) WRIT OF REVIVAL to him/her the contents thereof at 125 LOCUST ST HBG, PA 17101-0000 Sworn and subscribed to )efore me this 26TH day of SEPTEMBER, 2002 - ? 4v ? { y 4 ? ?, (? d J1Y ,/r4 { PROTHONOTARY So Answers, ?°?? and making known Sheriff of D hin Pa. By uty Sheriff Sheriff's Costs: $166.50 PD 09/23/2002 RCPT NO 169422 ET if fllt o$4rrr ff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin SMITH ROBERT G JR Vs ADLER BETTY J Sheriff's Return No. 2188-T - - -2002 OTHER COUNTY NO. 02-4339 So Answers, G/%441c- AND NOW: September 19, 2002 at 2:10PM served the within WRIT OF REVIVAL KILLION PAUL J C/O WILLIAM L ADLER ESQ to DEFT of the original upon by personally handing 1 true attested copy(ies) WRIT OF REVIVAL to him/her the contents thereof at 125 LOCUST ST HBG, PA 17101-0000 Sworn and subscribed to refore me this 26TH day pf` SEPTEMBER, 2002 Ii 1 PROTHONOTARY J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy and making known Sheriff of hin y, Pa. By vt? puty Sheriff Sheriff's Costs: $166.50 PD 09/23/2002 RCPT NO 169422 ET (,AfjYCQ of r "Sheriff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin SMITH ROBERT G JR . ADLER BETTY J Sheriff's Return Vs No. 2188-T - - -2002 OTHER COUNTY NO. 02-4339 upon AND NOW:September 19, 2002 at 2:10PM served the within WRIT OF REVIVAL KILLION PAUL J C/O WILLIAM L ADLER ESQ to DEFT of the original WRIT OF REVIVAL to him/her the contents thereof at 125 LOCUST ST HBG, PA 17101-0000 Sworn and subscribed to tefore me this 26TH day of SEPTEMBER, 2002 4y' PROTHONOTARY by personally handing So Answers, ? ?? e? J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy and making known Sheriff of D hin y, Pa. By uty Sheriff Sheriff's Costs: $166.50 PD 09/23/2002 RCPT NO 169422 1 true attested copy(ies) ET vb ?LQ Dif t4C S rri, f f Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 lax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania SMITH ROBERT G JR vs County of Dauphin ADLER BETTY J Sheriff's Return J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy No. 2188-T - - -2002 OTHER COUNTY NO. 02-4339 AND NOW: September 19, 2002 at 2:10PM served the within WRIT OF REVIVAL upon ADLER ROBERT A by personally handing C/O WILLIAM L ADLER ESQ to DEFT 1 true attested copy(ies) of the original WRIT OF REVIVAL and making known to him/her the contents thereof at 125 LOCUST ST HBG, PA 17101-0000 Sworn and subscribed to So Answers, )efore me this 26TH day of SEPTEMBER, 2002 r ? Sheriff o hiry PROTHONOTARY By f£ Sheriff's Costs: $166.50 PD 09/23/2002 RCPT NO 169422 ET (1Aff-ce ?f e Pxiff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff COnnnonweaith of Pennsylvania SMITH ROBERT G JR vs County of Dauphin ADLER BETTY J Sheriff's Return J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy No. 2188-T - - -2002 OTHER COUNTY NO. 02-4339 AND NOW: September 19, 2002 at 2:10PM served the within WRIT OF REVIVAL upon ADLER BETTY J by personally handing C/O WILLIAM L ADLER ESQ to DEFT 1 true attested copy(ies) of the original WRIT OF REVIVAL and making known to him/her the contents thereof at 125 LOCUST ST HBG, PA 17101-0000 Sworn and subscribed to So Answers, :efore me this 26TH day of SEPTEMBER, 2002 /(- 3 ton 4/0 r Sheriff h' Count Pa. F PROTHONOTARY By eputy Sheriff Sheriff's Costs:$166.50 PD 09/23/2002 RCPT NO 169422 ET In The Court of Common Pleas of Cumberland County, Pennsylvania Robert G. Smith Jr. vs. Stanley D. Adler Jr et al SERVE: Paul J. Killion 02 4339 co-executor of estate of No. Betty J. Adler, deceased Now, September 17, 2002 I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to copy of the original So answers, Sheriff of Sworn and subscribed before me this day of 20 COSTS SERVICE _ MILEAGE _ AFFIDAVIT 20, at o'clock M. served the the contents thereof. County, PA In The Court of Common Pleas of Cumberland County, Pennsylvania Robert G. Smith Jr. vs. Stanley D. Adler Jr et al SERVE: Betty J. Adler co-executor of estate of Betty J. Adler, deceased -Now September 17, 2002 No. 02 4339 I, SHERIFF OF CUMBERLAND COUNTY, PA, do 1iereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ?.,•aa.=n'^?. ?,d-ate Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to So answers, the contents thereof. Sheriff of Sworn and subscribed before me this _ day of 20 20_, at o'clock M. served the copy of the original COSTS SERVICE $ MILEAGE AFFIDAVIT County, PA In The Court of Common Pleas of Cumberland County, Pennsylvania Robert G. Smith Jr. vs. Stanley D. Adler Jr et al SERVE: Paul J. Killion 02 4339 co-executor of estate of No. Stanley D. Adler Jr, deceased Now, September 17, 2002 I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a 20_, at o'clock copy of the original M. served the and made known to So answers, Sheriff of Sworn and subscribed before me this day of 20 COSTS SERVICE _ MILEAGE _ AFFIDAVIT County, PA the contents thereof. In The Court of Common Pleas of Cumberland County, Pennsylvania Robert G. Smith Jr. vs. Stanley D. Adler Jr et al SERVE: Robert A. Adler 02 4339 co-executor of estate of No. Stanley D. Adler Jr, deceased Now, September 17, 2002 I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to copy of the original the contents thereof. So answers, Sheriff of Sworn and subscribed before me this _ day of 20 20_, at o'clock M. served the COSTS SERVICE $ MILEAGE AFFIDAVIT County, PA In The Court of Common Pleas of Cumberland County, Pennsylvania Robert G. Smith Jr. vs. Stanley D. Adler Jr et al SERVE: Stanley D. Adler Jr. co-executor of estate of Stanley D. Adler Jr, deceased Now, September 17, 2002 No. 02 4339 I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of , 20 20_, at o'clock M. served the COSTS SERVICE MILEAGE AFFIDAVI c>5 a T" ? k ? ? iA In The Court of Common Pleas of Cumberland County, Pennsylvania Robert G. Smith Jr. vs. Stanley D. Adler Jr et al SERVE: Robert A. Adler co-executor of estate of Betty J. Adler, deceased -Tow September 17, 2002 No. 02 4339 I, SHERIFF OF CUMBERLAND COUNTY, PA, do :hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to So answers, the contents thereof. Sheriff of Sworn and subscribed before me this _ day of 20 20_, at o'clock M. served the copy of the original COSTS SERVICE $ MILEAGE AFFIDAVIT County, PA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Richard W. Shaffer, Executor of the Estate STATEMENT OF JU of Robert G. Smith, Jr., deceased, No. 4321 CIVIL 1992 Plaintiff REVIVED TO NO. V. Robert A. Adler and Paul J. Killion, Co- Executors of the Estate of Stanley D. Adler, Jr., deceased and Robert Adler and Paul J. Killion, Co-Executors of the Estate of Betty J. Adler, deceased Defendants REVIVED TO NO. PARTIAL RELEASE OF JUDGMENT LIEN WHEREAS, on December 9, 1992, Judgment was entered in and against Defendants in the Court of Common Pleas of Cumberland County CIVIL TERM CIVIL TERM of Plaintiff No. 4321 Civil 1992; such Judgment was revived on September 12, 1997 at No? 4964 Civil 1997 and then revived on November 5, 2002 at No. 4339 Civil 2002; and WHEREAS, Defendants own an interest in that certain real 1249 Market Street, Borough of Lemoyne, Cumberland County, Pennsylvania, described in that certain Deed recorded in the Cumberland County Recorder of Deed Book F-22, Page 820, as more particularly described on Exhibit "A" att& made a part hereof (the "Property"). NOW, THEREFORE, Richard W. Shaffer, as Executor of the known as particularly Office in hereto and of Robert G. Smith, Jr., Plaintiff for himself, his heirs, representatives and assigns, agrees that he will not attach or levy upon, sell or dispose of, claim or demand the Property, in or as a Judgment and hereby releases the lien of the Judgment only on the Property; that nothing herein contained shall affect such Judgment or the lien thereof or upon or against any other property of Defendants or either of them in elsewhere. IN WITNESS WHEREOF, I have executed this Partial Release day of December, 2005. of Robert G. Smith, Jr. sult of the Tided, however, legal validity J County or is I lo+'t W. N COMMONWEALTH OF PENNSYLVANIA COUNTY OF 1044BE bA?Xi L L? I E l+ SS.: On this, the // day of January, 2006, before me, the undersigned officer, personally appeared Richard W. Shaffer, who acknowledged himself to be the Executor of the Estate of Robert G. Smith, Jr., being authorized to do so, executed the foregoing instrument for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and notarial seal the d?y and year aforesaid. Notary Public 4 My Commission Expires: l3? .200 GO4t1[AoNWEALTH OF FENN Notarial Seal Barbara J. Names, Notary ublic South Whitehall Twp., Lehigh County 9.;:"t My Commission Expires Apr. 13, Exhibit "A" ALL THAT CERTAIN piece or parcel of land situate in the Borough of Lemo e, County of Cumberland, Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the northern line of Market Street [sixty (60) feet wide] at the southeastern corner of Lot No. 31 on the Plan of Lots hereinafter mentioned; thence by the eastern line of said Lot No. 31 and through an iron pin two and one-half (2 1 /2 feet north of Market Street, North nineteen (19) degrees forty (40) minutes West, two hundred feet (200.00) to a point; thence by the southern line of Lot No. 29, North seventy (70) degrees twenty (20) minutes East, twenty and thirty-three hundredths (20.33) feet to a point; thence y the eastern line of said Lot No. 29, North twenty-four (24) degrees eight (08) minutes thirt (30) seconds West, one hundred eighty-five and sixty-five hundredths (185.65) feet to a point on the south side of Walnut Street as laid on said plan but not yet opened; thence by the sout ern line of Walnut Street, North sixty-five (65) degrees fifty-one (51) minutes thirty (30) seconds East, one hundred sixty (160.00) feet to a concrete monument upon the southern line of Walnut Street and thence continuing along the southern line of Walnut Street and on the same course seventy-nine and ninety hundredths (79.90) feet to a concrete hub at the northwestern corner f Lot NO. 25; thence by the western line of said Lot No. 25, South twenty-four (24) degrees eight (08) minutes thirty (30) seconds East, two hundred four and forty-three hundredths (204.43) feet to an iron pipe; thence by the northern line of Lot No. 35, South seventy (70) degrees twenty (20) minutes West, fifty-nine and ninety-six hundredths (59.96) feet to an iron pin; thence by the western line of said Lot No. 35, South nineteen (19) degrees forty (40) minutes East through an iron pin two hundred (200.00) feet to the northern line of Market Street aforesaid; and then by the northern line of Market Street, South seventy (70) degrees twenty (20) minutes West, tw hundred one (201.00) feet to a point, the place of BEGINNING. HAVING THEREON ERECTED a building known as 1249 Market Street, Pennsylvania. BEING Lot Nos. 26, 27, 28, 32, 33 and 34 on the Plan of Rosene Farms as laid out by G. Frank Wetzel, Master in Partition in the case of Caroline H. B. Brandt, et al. vs. Jacob H. Longnecker, et al. in the Court of Common Pleas of Cumberland County, Pennsylvania at No. 4 October Term, 1935. Lot Nos. 28 and 33 BEING two of the lots which were awarded to Caroline R. . Daub in the said petition proceedings by a Decree of the Court dated September 15, 1936. Lot Nos. 27 and 34 BEING the same lots which Wernersville National Bank and Trust Company, guardian of the Estate of Maude H. Longnecker, a weak minded person, by its Deed dated September 7, 1955 and recorded in the Office of the Recorder of Deeds o Cumberland County, Pennsylvania in Deed Book 16, Volume R, Page 557, conveyed to said Caroline R. H. Daub. Lot No. 26 BEING the same lot which Carol Bigler Brandt and Margaret A. Br their Deed dated May 10, 1950 and recorded in the Office of the Recorder of D Deed Book 14, Volume I, Page 532, conveyed to Caroline H. Daub and Walter husband. The said Walter H. Daub having died on October 9, 1961, title to the Caroline R. H. Daub absolutely. Lot No. 32 being the same lot which Tradesmens National Bank and Trust Co Trustee under the Will of Jacob H. Longnecker, by its Deed dated April 11, 11 the Office of the Recorder of Deed as aforesaid in Deed Book 14, Volume H., conveyed unto Caroline R. H. Daub. BEING the same premises which Elisabeth H. Daub Hickok and Walter H. Da the Last Will and Testament of Caroline H. Daub, also known as Caroline R. I Deed dated January 25, 1967 and recorded in the Office of the Recorder of De Cumberland County, Pennsylvania in Deed Book F-22, Page 820, granted and Charles Adler, II and Stanley D. Adler, Jr. t, his wife by s aforesaid in Daub, her I lot vested in any, sole and recorded in ;e 377, >, Executors of Daub, by their is in and for 3nveved unto 438898v1 Ln w a r-- % t ROBERT G. SMITH, JR., : IN THE COURT OF COMMON PLEAS RICHARD W. SHAFFER, Executor :CUMBERLAND COUNTY, :PENNSYLVANIA Estate of the Robert G. Smith, Jr., Deceased, Plaintiff V. : NO. 4321 CIVIL 1992 : REVIVED TO NO. 97-4964 CIVIL 1997 : REVIVED TO NO. 02-4339 CIVIL TERM ? STANLEY D. ADLER; JR., ROBERT : CIVIL ACTION - LAW A. ADLER AND PAUL J. KILLION, CO-EXECUTORS OF THE ESTATE OF STANLEY D. ADLER, JR., : NO. DECEASED AND BETTY J. ADLER; ROBERT A. ADLER AND PAUL J. KILLION, CO-EXECUTORS OF THE ESTATE OF BETTY J. ADLER, DECEASED, Defendants PRAECIPE To the Prothonotary: Please enter judgment on the Writ of Revival filed to No. 02-4339 CIVIL TERM in favor of the Plaintiffs Robert G. Smith, Jr.; and Richard W. Shaffer, Executor of the Estate of Robert G. Smith, Jr., Deceased, against Stanley D. Adler, Jr., Robert A. Adler F and Paul J. Killion, Co-Executors of the Estate of Stanley D. Adler, Jr., Deceased and Betty J. Adler, Robert A. Adler and Paul J. Killion, Co-Executors of the Estate of Betty J. Adler, Deceased, pursuant to Rule 3031(a) for failure within the required time to plead to the Writ within twenty (20) days from service thereof as follows: Damages - $64,509.50 Interest- 11/5/1992 - 9/9/2002 - $22,822.66 Costs - $209.00 I hereby certify the written notice of intention to file this Praecipe was given pursuant to Pa. R.C. P. 237.1 (2) by certif.f.-d mail, copy of said notice is attached hereto and incorporated herein by reference. David A. Wion, Esquire 109 Locust Street Dated: Z A Poo Harrisburg, PA 17101 (717) 236-9301 Attorney for Plaintiff ID # 06883 &or ROBERT G. SMITH, JR.; RICHARD W. SHAFFER, Executor of the Estate of Robert G. Smith, Jr., deceased Plaintiff vs. STANLEY D. ADLER, JR.; ROBERT A. ADLER and PAUL J. KILLION, Co-Executors of the Estate of Stanley D. Adler, Jr., deceased, and Betty J. Adler; ROBERT A. ADLER AND PAUL J. KILLION, Co-Executors of the Estate of Betty J. Adler, deceased Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 4321 CIVIL 1992 REVIVED TO NO. 97-4964 CIVIL 1997 REVIVED TO NO. 02-4339 CIVIL 2002 CIVIL ACTION - LAW TO: ROBERT A. ADLER, Co-Executor of the Estate of Stanley D. Adler, deceased, and Co-Executor of the Estate of Betty J. Adler, deceased 2930 Arcona Road Mechanicsburg, PA 17055 PAUL J. KILLION, Co-Executor of the Estate of Stanley D. Adler, deceased, and Co-Executor of the Estate of Betty J. Adler, deceased 545 S. Third Street Lemoyne, PA 17043 DATE OF NOTICE: August 22, 2007 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 N. Bedford Street Carlisle, PA 17013 (800) 990-9108 AVISO IMPORTANTE A: ROBERT A. ADLER, Co-Executor of the Estate of Stanley D. Adler, deceased, and Co-Executor of the Estate of Betty J. Adler, deceased 2930 Arcona Road Mechanicsburg, PA 17055 PAUL J. KILLION, Co-Executor of the Estate of Stanley D. Adler, deceased, and Co-Executor of the Estate of Betty J. Adler, deceased 545 S. Third Street Lemoyne, PA 17.43 FECHA DEL AVISO: August 22, 2007 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARECENCIA ESCRITA POR SI MISMO OA TRAVES DE UN ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESENTADO CONTRA LISTED. A MENOS QUE USTED ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y LISTED PUEDE PERDER SU PROPIEDAD U OTROS DERECHOS IMPORTANTES. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 N. Bedford Street Carlisle, PA 17013 (800) 990-9108 David A. Wion, Esquire WION ZULLI & SEIBERT 109 Locust Street Harrisburg, PA 17101 (717) 236-9301 Attorney for Plaintiff ID #06883 Distribution: William J. Adler, Esquire Adler & Adler 125 Locust Street Harrisburg, PA 17101 ¦ Complete hems 1, 2, and 3. Aiao complete A. . Item 4 If Restricted DeAvery is desired. f ?, ? AMW ¦ Print your name and address on the reverse x ? Addressee so that we can return the card to you. by c. Date of Delivery ery ¦ Attach this card to the back of the mallplece, or on the front if space permits. 9-as-,o. 1. Article Addressed to: 1-6!lsd*vsryaft@sea%rvntftornIWm1? ? Yes If YES, wftr delivery address below. ? Nb PAUL J. KILLION 545 S. Third Street Lemoyne, PA 17043 2 Article Number M MWMW fiom servks 4%W .? PS Form 3811, February 2004 I i i f 3. servo. Type . j Cermied Matt ? Ernes Mau ? PAO"ed III Rehan Rs0W4er#Asn WWlee ? mewed Mail ? C.O.D. 4. Resbtcxed,Pei v0ry? (Ekft Fee) ? Yea 7003 10113 0602 8156 900.5 ? Domeatlc Retum Receipt t?S95 02-M-t640;{ lit Complete Items 1, 2, and 3. Also complete A GS8 1? l Item 4 If Restricted Delivery is desred. A9 _ ¦ Print your name and address on the reverse ? so that we can return the card to you. by ( o, ¦ Attach this card to the back of the mailplec:e, A a» ?, or on the front If space permits. Er D. its (Fern 1? ? Y e s Gw. 1. /1fYVIV Addressed to: ?,y? 4ntar doMMM y I ? ^ ? NO ` i T 1 V V, 2 8 2M7 . ROBERT A. ADLER 4 2930 Arcona Road Mechanicsburg, PA 17055 3. satiice 'hWUSPLI-11, ? . ? CertMied M rprees sit i. ? Inwrad Mail ? O.D. I 4. Reshltdad O~.(Extra Fes) ? Yee 2. ArddeNwftw 7003 1010 0002 8156 8992 PS Form 3811, February 2004 Domestic Retu rn Rae" 11 -WI50 e UNITED S'iIATESAMA16,-?'V .C.; If Sender Please print your name, address, and ZIP+4 in this box • David A. Wion, Esquire MON ZULLI & SEIBERT 109 Locust Street Harrisburg, PA 17101 I I 1111111fitIIIIStill 111111111;if1.1111 Jill 1 11,1111 I UNITED STATE4*Wt~G PA. -1 28 I AUG 2007 PM 3 t. i • Sender. Please print your name, address, and ZIP+4 in this box • David A. Wion, Esquire MON ZULLI & SEIBERT ' 109 Locust Street Harrisburg, PA 17101 i i 'ice=' 1}111f 1!)11111 111 1111 still lfill Ili fill lilt If 11118.11111,111111 I. 1 I It V ?? fl