WINDOW WORLD

    ENTERTAINMENT FOR MARK
   I HAVE TO STOP WITH THE LAWSUIT STORY FOR AWHILE BECAUSE OF WORK, BUT EVERYBODY HAS TIME TO LAUGH.  

A WATERSHED MOMENT

   WE RECEIVED CATHERS AMENDED COMPLAINT ON FRIDAY SEPT. 8TH 2006 AND HAD TILL THE 26TH TO ANSWER.  WHAT I MAY HAVE THOUGHT HALF-HEARTILY, WOULDN'T HAPPEN, DID IN FACT HAPPEN.  AFTER READING THE AMENDED COMPLAINT, MY FIRST THOUGHT WAS OF SIR WALTER SCOTTS FAMOUS QUOTE, " OH, WHAT A TANGLED WEB WE WEAVE, WHEN FIRST WE PRACTICE TO DECEIVE! "  THERE WAS NOW NO DOUBT THEIR LAWSUIT COULD SHUT DOWN OUR DRIVEWAY.  OBVIOUSLY WHEN FACED WITH THAT FACT, IT IS UPSETTING.  BUT, I ALSO LOOKED AT IT FOR WHAT IT WAS.  A BIG LIE. AND THEY JUST MADE A BIG MISTAKE......A GAME CHANGER .
   READING NO. 11, THE MOST IMPORTANT PART OF THEIR AMENDED COMPLAINT, AND COMPARING IT WITH THEIR EXHIBIT "C", I HAD TO DO SOME GUESSING.  WHY WASN'T THESE DIMENSIONS LAYED-OUT  BY A SURVEYOR ?  AND PUT ON EXHIBIT "C"?  OH , I REMEMBER, I HEARD AT THE COURTHOUSE DURING ORAL ARGUMENTS.......THEY COULD  MEASURE THEMSELVES AND SAVE MONEY.    SO, I'LL TRY TO EXPLAIN THIS BY WORDS, AND HOPEFULLY I CAN MAKE IT UNDERSTANDABLE. CATHERS SURVEYED PROPERTY AND THESE DIMENSIONS  ARE NOT ONE AND THE SAME.  THESE DIMENSIONS START AT AN EXISTING MAG NAIL IN THE DRIVEWAY, AND GO 7 FEET ACROSS THE WIDTH OF THE DRIVEWAY, FOLLOWING THE SURVEYED BOUNDARY.  THEN, 43 FEET, TAKES YOU THROUGH THE RIGHT OF WAY TO THE PAVEMENT OF GREEN STREET , WHICH IS NOW CALLED EAST DONORA RD.  THAT DIMENSION TAKES YOU BEYOND THE ACTUAL SURVEYED BOUNDARY OF THE CATHERS PROPERTY.  CATHERS SURVEY, LOOKING AT THEIR EXHIBIT "C", SHOWS A MUCH SMALLER, TRIANGULAR SHAPED, ENCROACHMENT.  EVEN I CAN SEE THERE ARE SOME OBJECTIONS IN THIS AMENDED COMPLAINT, AND THAT'S NOT ALL.  IN ANY CASE, CATHERS NEXT DIMENSION, 26 FEET- 10 INCHES, RUNS SOUTH ALONG GREEN ST., THEN FROM THERE 15 FEET-6 INCHES TO THE EXISTING MAG NAIL.  BECAUSE OUR DRIVEWAY MEETS EAST DONORA RD. AT A SHARP ANGLE THE 26 FEET- 10 INCHES REFLECTS THE LENGTH OF ASPHALT OF OUR DRIVEWAY TOUCHING EAST DONORA RD.
   NOT UNTIL MUCH LATER DID I EVEN BOTHER GOING OUT TO MEASURE THIS, I JUST TOOK AN EDUCATED GUESS.  I FOUND THIS UNBELIEVABLE.  I REMEMBER HOW PRECISE  MR. SHIRE REQUIRED ME TO BE WITH THOSE SHRUBS.  HERE WE ARE IN A LEGAL BATTLE AND THEY CAN'T PAY TO PUT DIMENSIONS DOWN LEGITIMATELY .  MAYBE THEY WANT ME TO PAY?  OK, I'M GAME, BUT LITTLE DID THEY REALIZE HOW ME THINKING WHAT DIMENSIONS NEEDED PUT DOWN, WOULD COME BACK TO HAUNT THEM AT TRAIL.  BESIDES THE ACTUAL SURVEYED PROPERTY THAT MY DRIVEWAY CROSSES, THE TRIANGLE, WHAT ELSE MIGHT BE IMPORTANT?  WELL, IF THEIR CLAIMING I MOVED MY DRIVEWAY WHEN I REPAVED IT, THEN THE DISTANCE BETWEEN THEIR GARAGE AND MY DRIVEWAY WOULD CHANGE.  MAYBE, THAT DISTANCE TODAY WOULD BE IMPORTANT TO KNOW.  THERE ARE A NUMBER OF ENIGMAS WITH THIS AMENDED COMPLAINT.  TO THIS DAY I CAN'T FIGURE OUT 26 FEET - 10 INCHES?  WHEN THE DISTANCE IS FINALLY SURVEYED BY ME PAYING TO HAVE IT PUT ON PAPER, THE MEASUREMENT IS 25.26'.........DID I LOSE SOME ASPHALT SOMEHOW?    
   ON SEPTEMBER 12, 2006 I WENT TO THE SURVEYOR TO HAVE HIM PUT DOWN ON PAPER THE DIMENSIONS THAT I FELT WERE IMPORTANT. THEN I TOOK 2 VIDEOS FROM A CAMCORDER THAT MIGHT HAVE A SECOND OF VIDEO THAT COULD BE HELPFUL TO SHIRE LAW FIRM.  I TALKED TO KEN ABOUT THEIR AMENDED COMPLAINT.  HE SAID WE COULD FILE OBJECTIONS AGAIN, BUT WHY WASTE THE MONEY, WE WILL ANSWER WITH A CLAIM FOR "QUITE TITLE".  YES!!!!!!!  I ASKED KEN TO SEE THE ORIGINAL 1994 APPRAISAL PICTURE, I NEVER REALLY  GOT A GOOD LOOK AT IT.  HE GOT IT AND WE BOTH LOOKED AT IT, KNOWING NOW THE DISTANCE IS 7 FEET, NOT INCHES.  NOW THE PICTURE LOOKED SO TELLING.  AS I WAS LEAVING I SAID TO KEN, '' WE DON'T HAVE ANYTHING TO WORRY ABOUT, DO WE."  KEN HAD THE BIGGEST SMILE AND SAID, " NO".  

CATHERS AMENDED COMPLAINT

THE LONGEST SUMMER- ALMOST OVER

   AT THE END OF AUGUST 2006 AND THE BEGINNING OF SEPTEMBER, BESIDES BRINGING WOOD DOWN TO THE BACK PORCH FOR WINTER AND INSTALLING CONDUIT AND CABLE FOR SECURITY CAMERAS I CONTINUED MY SEARCH FOR EVIDENCE. ON THE 28TH OF AUGUST I WENT TO THE ROSTRAVER MUNICIPAL BUILDING AND ASKED ABOUT THE POSSIBILITY OF AERIAL PHOTOGRAPHS. I WILL FOREVER BE INDEBTED TO THE KIND SECRETARY WHO POINTED ME TO THE WESTMORELAND COUNTY COURTHOUSE.  I ALSO TALKED TO THE ROSTRAVER ROAD SUPERINTENDENT ABOUT EAST DONORA RD. AND THE ASPHALT BERM.  THE NEXT DAY HE CALLS BACK AND SAYS HE CAN'T FIND ANYTHING ON THE BERM, BUT HE RECALLS A PIPE AND DRAIN PUT IN, AND WILL TRY TO LOCATE SOMETHING ON THAT.  HAD A LONG TALK WITH A GOOD NEIGHBOR.  CALLED THE ASPHALT CONTRACTOR ABOUT THE BERM AND HE DIDN'T RECALL TOUCHING THE BERM.  ON SEPT. 12, 2006 I CALLED AND TALKED TO A PREVIOUS OWNER OF OUR PROPERTY.  SHE SAID SHE CAN'T REMEMBER THE LOCATION OF THE DRIVEWAY.  SHE SAID SHE KNOWS OF NO SURVEY.  SHE SAID THE DRIVEWAY WAS PUT THERE IN 1966, MAYBE.   
   

THE LONGEST SUMMER- SOME HOPE

   THROUGH- OUT AUGUST I CONTINUED SEARCHING FOR EVIDENCE.  I MANAGED TO GET CATHERS PRE-BLAST PICTURES AND HAD THEM ENLARGED.  I WAS DISAPPOINTED TO FIND OUT YORK REALITY COULD NOT LOCATE ANY PICTURES FROM 1978.  I FOUND OUT AT WESTMORELAND COUNTY COURTHOUSE THE COMMON SOURCE OF OUR DEEDS.  THEY GO BACK TO BOYD/ WALKER , CO-OWNERS OF LOTS 21,22, ETC., AND THEN THEY DIVIDED THEM UP.  WALKER WAS THE ORIGINAL OWNER OF OUR PROPERTY AND BOYD WAS THE ORIGINAL OWNER OF THE CATHERS PROPERTY.  SO, MAYBE THAT'S WHY?
   ON AUGUST 9TH 2006 I WENT TO THE LIBRARY AGAIN, ONLY THIS TIME, I GET ON THE INTERNET FOR THE FIRST TIME IN MY LIFE.  NOT VERY PRODUCTIVE, I  HAD TO LEARN FROM SCRATCH.  ON AUGUST 15TH THERE WAS A MEETING AT MY DRIVEWAY WITH THE ASPHALT CONTRACTOR, KEN AND MR. SHIRE.  THEY WENT OVER THE ISSUE OF ANY POSSIBLE MOVEMENT OF THE DRIVEWAY.  I TOLD MR. SHIRE AND KEN THE COMMON SOURCE OF THE DEEDS.
   ON AUGUST 22ND I WROTE ON MY CALENDAR.........WENT OVER SABO'S .  THIS WAS PROBABLY THE DAY JIM SAID,  "THERE'S GOT TO BE AERIAL PHOTO'S SOMEWHERE".   ON AUGUST 24TH WE RECEIVED THE JUDGES ORDER ON PRELIMINARY OBJECTIONS.  THEY HAVE TO REDO THEIR COMPLAINT.  LATER IN THE DAY MR. HASSON AND THE CATHERS ARE IN THE DRIVEWAY.
   ON SATURDAY AUGUST 26, 2006, AFTER NOT MENTIONING WHAT SHE SAW BECAUSE SHE DIDN'T RECOGNIZE IT AS MEANINGFUL WHILE CUTTING GRASS ON WEDNESDAY, ARLENE MENTIONS TO ME ," LOOK AT THE BERM" .  WE BOTH WALKED AND DROVE OVER IT FOR YEARS WITHOUT  GIVING IT A THOUGHT.  ARLENE, WITH A PUSH-MOWER, IS STARING RIGHT AT IT, BUT, DOESN'T RECOGNIZE THE SIGNIFICANCE .  SOMETHING TELLS HER TO TELL ME AND I GO RIGHT OUT AND LOOK.  I COME BACK IN THE HOUSE AND TELL HER, " YOU JUST FOUND THE BEST EVIDENCE YET."  THE BERM WAS FLATTENED IN FRONT OF THE DRIVEWAY AND I WAS PRETTY SURE IT PRE-DATED THE 2002 REPAVING.  I REMEMBER BEING ON THE DRIVEWAY WHEN ROSTRAVER TWP INSTALLED THE ASPHALT BERM.  I REMEMBER TELLING THEM, AFTER THEY ASKED, TO FLATTEN  THE BERM IN FRONT OF THE DRIVEWAY.  NOW I HAD TO POSITIVELY DATE THAT BERM.  

ORDER ON PRELIMINARY OBJECTIONS

ORAL ARGUMENTS ON PRELIMINARY OBJECTIONS

                                          WHAT A GRAND OLD BUILDING.

   AUGUST 17, 2006 AT THE WESTMORELAND COUNTY COURTHOUSE.  I GET THERE AT 10;15 AM , 15 MINUTES LATE, ROAD CONSTRUCTION.  JUDGE CARUSO IS THERE, AS ARE MY TWO ATTORNEYS, MR. SHIRE AND KEN BALDONIERI. AFTER THE PLAINTIFFS ATTORNEY , MR. HASSON, GETS THERE , MR. SHIRE GOES FIRST, STATING OUR FOUR OBJECTIONS.   MR. HASSON GOES NEXT AND SAYS HE'S TRYING TO SAVE THE CATHERS MONEY, THAT HE MIGHT HAVE TO GO BACK 200 YEARS TO DO AN ABSTRACT OF TITLE. HE FEELS THAT A DEED SHOWS OWNERSHIP.  MR. SHIRE PULLS OUT THE PLOT PLAN OF EAST DONORA  AND SHOWS THAT MR. HASSON ONLY HAS TO GO BACK TO 1919.  MR. SHIRE ALSO POINTS OUT THAT A DEED DOES NOT SHOW AN UNCLOUDED TITLE.  MR. SHIRE ALSO POINTED OUT TWICE, " ADVERSE POSSESSION" BEING THE ONLY CASE WHERE YOU DON'T NEED TO HAVE AN " ABSTRACT OF TITLE".  JUDGE CARUSO OPENS RULES OF COURT, AND READS, " ABSTRACT OF TITLE UPON WHICH PLAINTIFFS RELY AT LEAST FROM THE COMMON SOURCE."
   FROM MY PERSPECTIVE, AS A LAY-PERSON, THIS WAS A FIRST OPPORTUNITY TO SEE YOUR ATTORNEY AGAINST THEIR ATTORNEY.  I WAS VERY HAPPY WITH WHAT I SAW. THEY WERE WELL PREPARED.  AND,  I WAS DUMBFOUNDED  BY THE FACT THAT THE PLAINTIFFS DID NOT ATTEND.   THIS IS THEIR LAWSUIT.

THE LONGEST SUMMER- DESPERATELY SEARCHING

     THROUGHOUT JULY OF 2006 I SEARCHED FOR ANYTHING THAT MIGHT BE OF HELP TO DEFEND US.  THOUGH I HAD NO IDEA HOW THIS LAWSUIT WOULD PLAY-OUT, 6 INCHES?, AFTER READING ABOUT ADVERSE POSSESSION AND ARLENE TELLING ME THIS IS NOT ABOUT 6 INCHES, I BEGAN TO THINK IN BIGGER DIMENSIONS.  THE SURVEY PIN WAS 7 FEET INTO THE WIDTH OF OUR 9 AND HALF FOOT WIDE DRIVEWAY.  BUT, NO WAY ARLENE, THERE IS NO POSSIBILITY THAT "SUBSTANTIALLY EXPANDED" MEANS ANYTHING MORE THAN 6 INCHES.   IN ANY CASE, I SAVE EVERYTHING, TO THE ANNOYANCE OF SOME, BUT YOU NEVER KNOW WHEN YOU MIGHT NEED IT.  OK, I FOUND THE "DEAR NEIGHBOR"  LETTER FROM  1979.  I LOOKED THROUGH EVERY PICTURE THAT WAS TAKEN.  I SEARCHED EVERY PIECE OF PAPER, AND THERE WERE FAR TO MANY.  I CONSIDERED, DID ANYBODY ELSE TAKE A PICTURE, A FRIEND, A NEIGHBOR, A RELATIVE, A BANK?  I FOUND A PICTURE FROM OUR REFINANCING IN 1994, A STREET SCENE, SHOWING OUR DRIVEWAY BUT IT HAD A COATING OF  SNOW ON IT.  IT DIDN'T APPEAR THAT IT WOULD BE ANY HELP, IT WAS A BAD COPY IN BLACK AND WHITE.  DID THE NEIGHBORS REFINANCE?  WOULD THEY HAVE PICTURES FROM THE REFINANCING?   TODAY I CAN,  WITH THIS COMPUTER,  GO TO THE WESTMORELAND COUNTY COURTHOUSE AND FIND OUT EXACTLY WHEN SOMEBODY REFINANCED .  BUT IN 2006 ALL I COULD  DO WAS GUESS. I FOUND SOME PRE-BLAST SURVEY PICTURES FROM THE TIME WHEN THEY WERE THINKING OF MINING COAL ON THE ACREAGE ABOVE US .  THE NEIGHBORS PROBABLY HAD THEM TAKEN OF THEIR PROPERTY TOO.
   ON JULY 12TH 2006 I WENT TO THE ROSTRAVER TWP MUNICIPAL BUILDING TO SEE THE MAPS ON CATHERS SUBDIVSION AND THE ORIGINAL SURVEY THEY HAD DATED 4-10-1989. WHILE I WAS THERE I TALKED TO THE ROSTRAVER TWP ZONING OFFICER AND THE ROSTRAVER POLICE.  SOMEHOW, I FELT THE NEED TO KNOW ABOUT THE LAW CONCERNING SECURITY CAMERAS.
   I WENT TO FIRST FEDERAL SAVINGS AND LOAN ON JULY 17TH TO SEE ABOUT THE POSSIBILITY OF ANY PICTURES FROM 1978 WHEN WE BOUGHT OUR PROPERTY. AND OF COURSE THEY WERE HELPFUL AND TOLD ME YORK REALTY IN WASHINGTON PA. MAY STILL HAVE THE PICTURES.  BUT I WAS ALSO SHOWN THE ORIGINAL COLOR PICTURES FROM THE 1994 APPRAISAL. WOW, STILL SNOW, BUT YOU CAN SEE  MORE DETAIL NOW.  MR. SALKO SAID THEY COULD BE GIVEN TO MY ATTORNEY.
   I ALSO TALKED ARLENE INTO GOING TO HALF PRICE BOOKS IN BETHEL PARK, PA. YES, I LIKE BOOKS.  TO KEEP UP WITH LEGALESE I BOUGHT " BLACK'S LAW DICTIONARY.  THEN, BECAUSE , I BOUGHT " ELEMENTS OF CIVIL PROCEDURE" AND "THE LITIGATION PARALEGAL".
   IN BLACK'S LAW DICTIONARY UNDER  ADVERSE POSSESSION I READ, " IN ORDER TO ESTABLISH TITLE IN THIS MANNER, THERE MUST BE PROOF OF NON PERMISSIVE USE WHICH IS ACTUAL, OPEN, NOTORIOUS,  EXCLUSIVE AND ADVERSE FOR THE STATUTORY PRESCRIBED PERIOD."
   ON JULY 20TH 2006 ARLENE AND I HAD AN APPOINTMENT  AT SHIRE LAW FIRM. ARLENE NEEDED TO GET HER NAME CHANGED ON OUR DEED.  I TOLD MR. SHIRE THAT FIRST FEDERAL HAD ORIGINAL COLOR PICTURES FROM 1994 AND I SIGNED A RELEASE TO GET THEM.  I GAVE MR. SHIRE THE SURVEYS I GOT THAT THE CATHERS HAD DONE ON 4-10-1989 AND 12-8-1989.  MR. SHIRE ASKED US IF IT WAS OK TO MAKE ORAL ARGUMENTS ON PRELIMINARY OBJECTIONS AND WE AGREED.  AFTER TALKING ABOUT  ANOTHER ISSUE , WITH MY " NEIGHBOR LAW" BOOK IN HAND, I OPENED IT UP AND POINTING, SAID, " I THINK I GOT THIS", REFERRING TO ADVERSE POSSESSION.  MR. SHIRE REALLY DIDN'T SAY ANYTHING, BUT, HE DID WRITE IT DOWN.  I CAN IMAGINE HIM THINKING, '' THINKING IT IS  ONE THING, BUT PROVING IT  IS ANOTHER MATTER ENTIRELY.''

NEIGHBOR LAW FOR DUMMIES

Cover via Amazon   ARLENE AND I WENT TO BARNES AND NOBLE AT THE END OF JUNE 2006 AND FOUND A NUMBER OF BOOKS DEALING WITH NEIGHBOR LAW.  I ENDED UP CHOOSING THE ONE CALLED "NEIGHBOR LAW" FROM NOLO, BY ATTORNEY CORA JORDAN.  IN PLAIN-ENGLISH THIS WELL-WRITTEN BOOK GIVES TONS OF USEFUL INFORMATION TO DEAL WITH NEIGHBOR ISSUES.  I LIST THE TABLE OF CONTENTS BECAUSE I FOUND THE BOOK SO HELPFUL. AND THE LINK TAKES YOU TO AMAZON.

   1. HELP FOR COMMON COMPLAINTS

   2. NOISE

   3. WHEN A TREE IS INJURED OR DESTROYED

   4. ENCROACHMENT: INVADING BRANCHES AND ROOTS

    5. UNSOUND LIMBS AND TREES

   6. BOUNDARY TREES

   7. FRUIT AND NUTS: WHO OWNS WHAT

   8. OBSTRUCTION OF VIEW

   9. BOUNDARY LINES

   10. USING ANOTHER S LAND: TRESPASS AND EASEMENTS

        TRESPASSERS WHO BECOME OWNERS

   11. FENCES

   WHAT WAS THAT?

TRESPASSERS WHO BECOME OWNERS?

   

   GUESS WHAT CHAPTER I READ FIRST?  THEN I READ THE WHOLE BOOK. THEY DON'T TEACH THIS IN HIGH SCHOOL.  THEY SHOULD.  THERE"S NOTHING NEW HERE, THE COURTS HAVE PUBLISHED DECISIONS AS FAR BACK AS THE 13TH CENTURY.  MOST STATE STATUTES IN AMERICA WERE IN PLACE IN THE 1800"S.  BUT THE AVERAGE PERSON, INCLUDING MYSELF, DOESN'T HAVE A CLUE.  THERE, STARING ME IN THE FACE;  TRESPASSERS WHO BECOME OWNERS.  "MANY LANDOWNERS ARE SURPRISED TO LEARN THAT UNDER CERTAIN CIRCUMSTANCES, A TRESPASSER CAN COME ONTO LAND, OCCUPY IT AND GAIN LEGAL OWNERSHIP OF IT......A TRESPASSER MAY ALSO GAIN A LEGAL RIGHT TO USE PART OF SOMEONE ELSE'S PROPERTY; THIS IS CALLED A PRESCRIPTIVE EASEMENT.  THE LEGAL DOCTRINE THAT ALLOWS TRESPASSERS TO BECOME OWNERS IS CALLED " ADVERSE POSSESSION." " ( NEIGHBOR LAW,NOLO , BY CORA JORDAN)  

   AFTER READING THIS CHAPTER I WAS AWESTRUCK.  IT SEEMED TO ME THAT I HAD EVERYTHING REQUIRED FOR ADVERSE POSSESSION, BUT ACTUALLY PROVING IT WAS ANOTHER MATTER ENTIRELY.  BUT I ALSO CAME TO THE CONCLUSION THAT THE NEIGHBORS WERE, IN FACT, PUTTING THEMSELVES AT GREAT RISK.  BY THEM INITIATING THE LAWSUIT, THAT MADE IT POSSIBLE TO POTENTIALLY LOSE THEIR PROPERTY.  IT CAN OCCUR NO OTHER WAY THAN BY A LEGAL PROCEDURE.  AS I MENTIONED EARLIER IN THE STORY, I WAS QUITE CONTENT TO LEAVE THINGS ALONE. MY DRIVEWAY WASN'T RIGHT AND YOUR GARAGE WASN'T RIGHT.   IT WOULD BE AN OXYMORON TO SAY " YOU LEGALLY STOLE MY PROPERTY".  IT WOULD BE MORE ACCURATE TO SAY " BY YOUR FOOLISHNESS, YOU GAVE IT AWAY."    

   THERE IS A GREAT MORAL PURPOSE FOR ADVERSE POSSESSION .  CLICK THE LINK EARLIER IN THE POST AND SEE SOME OF THE REASONS FOR SUCH A THING........IT ACTUALLY PROTECTS YOU THE PROPERTY OWNER.  AND MOST IMPORTANTLY, IT'S ACTUALLY VERY EASY TO PREVENT SOMEONE FROM GAINING OWNERSHIP OF YOUR PROPERTY.........GIVE WRITTEN PERMISSION.   "A LANDOWNER WHO DOESN'T KEEP AN EYE ON HIS PROPERTY CAN LOSE IT."(NEIGHBOR LAW, NOLO, BY ATTORNEY CORA JORDAN)  IN PENNSYLVANIA IT ACTUALLY TAKES 21 YEARS FOR SOMEONE TO GAIN OWNERSHIP OF ANOTHER' S  PROPERTY .    21 YEARS  AND THEN IT'S VERY DIFFICULT , THEY DON'T JUST GIVE PEOPLE'S PROPERTY AWAY,  YOU HAVE TO PROVE A LOT OF THINGS.  AND THE OWNER HAS TO IGNORE HIS PROPERTY.  I WAS GLAD TO HEAR  FROM ONE OF MY ATTORNEYS THAT PA. IS ACTUALLY TRYING TO CHANGE THAT TO 5 YEARS.  
    AGAIN, FOR THE BENEFIT OF A SAD MISSTAKEN TEXTER  THE NEIGHBORS WOULD NEVER , COULD NOT POSSIBLY HAVE EVER LOST ANYTHING, IF THEY DID NOT BRING A LAWSUIT.  I DID WHAT ANYBODY WOULD DO.  I DEFENDED MYSELF.       

IS THE DRIVEWAY UNIQUE ?

   I STARTED DOING A LOT OF THINKING IN JUNE OF 2006.  HOW DID MY DRIVEWAY GET TO BE WHERE IT'S AT.  WAS THERE AN AGREEMENT BETWEEN THE FORMER NEIGHBORS, YOU CAN PUT YOUR DRIVEWAY HERE, CAN I PUT MY GARAGE THERE.  IS MY DRIVEWAY UNIQUE?  AS I LOOK DOWN THE HILL BEHIND MY PROPERTY, ACROSS WEBSTER HOLLOW, I SEE TWO DRIVEWAYS MEETING AND MERGING INTO ONE BEFORE THEY ENTER WEBSTER HOLLOW RD.  AS I DRIVE AROUND ROSTRAVER TWP. AND THE BELLE VERNON AREA I SEE NUMEROUS EXAMPLES OF POTENTIAL PROBLEMS WITH PEOPLES DRIVEWAYS. IT SEEMS WHEN THERE IS SLOPING GROUND, THE NATURAL THING TO DO IS NOT MAKE YOUR DRIVEWAY PERPENDICULAR TO YOUR PROPERTY, BUT RATHER, MEET THE ROAD AT AN ANGLE ACROSS YOUR PROPERTY.  OR, DO THEY ACTUALLY GO ACROSS SOMEONE ELSE'S PROPERTY?  
   AFTER SPENDING THE MONTH OF JUNE AT THE MONESSEN PUBLIC LIBRARY, AND NOT ABLE TO GET ENOUGH SPECIFIC INFORMATION ON NEIGHBOR LAW , I CONVINCED ARLENE IT WAS TIME TO GO TO BARNES AND NOBLE IN GREENSBURG.

THE DRIVEWAY IN ROSTRAVER

ANOTHER VIEW

A FAMOUS DRIVEWAY IN ROSTRAVER

A VIEW OF THE DRIVEWAY.

MY THOUGHTS AFTER PRELIMINARY OBJECTIONS

   AFTER OUR FILING PRELIMINARY OBJECTIONS, A BRIEF IN SUPPORT OF SAID OBJECTIONS, AND THEIR ANSWERS TO PRELIMINARY OBJECTIONS, I COULDN'T  HELP BUT NOTICE A COUPLE THINGS.  FIRST, THE PA. I. D. NO. OF  MR. SHIRE, OUR ATTORNEY 05365    
THEN, THE PA. I. D. NO. OF MR. HASSON, THEIR ATTORNEY 63215   
   NOT A SMALL DIFFERENCE IN EXPERIENCE. THEN READING THE BRIEF IN SUPPORT OF DEFENDANTS PRELIMINARY OBJECTIONS IT'S OBVIOUS THAT IT IS A HIGH QUALITY DOCUMENT.  EVERYTHING THAT IS SAID IS SUPPORTED BY LAW.  CONTRAST THAT WITH THE PLAINTIFFS ANSWER.  " PLAINTIFFS COMPLAINT SPEAKS FOR ITSELF".  
   MEANWHILE I'M THINKING, '' YOU MAY THINK YOUR COMPLAINT SPEAKS FOR ITSELF, BUT I DON'T HAVE A CLUE WHAT YOU ARE TALKING ABOUT."   6 INCHES  ?         I  REMEMBER AFTER THE DRIVEWAY WAS REPAVED ,  BILL CATHERS COMING OVER AND POINTING TO CRACKS, 6 INCHES FROM THE EDGE, SAYING THAT HE THINKS WE EXPANDED OUR DRIVEWAY AND THOSE CRACKS INDICATE THAT THE DRIVEWAY IS SETTLE LING ALONG THE EDGE WHERE IT NEVER WAS.  BUT , I TOLD HIM I DIDN'T BELIEVE THAT AND I WALKED HIM 100 FEET DOWN THE DRIVEWAY AND SHOWED HIM CRACKS IN THE MIDDLE OF THE DRIVEWAY, ASKING HIM WHAT DOES THAT SHOW  .
   HOW COULD I POSSIBLY DEFEND MYSELF AGAINST 6 INCHES?

CATHERS ANSWER TO PRELIMINARY OBJECTIONS

BRIEF IN SUPPORT OF DEFENDANTS' PRELIMINARY OBJECTIONS