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.