MESTER & SCHWARTZ, P.C. BY: Laurence A. Mester, Esquire Identification Nos.: 79184 1333 Race Street Philadelphia, PA 19107 (267) 909-9036 Filed and Attested by PROTHONOTARY 02 FEB 2015 11:51 am D. SAVAGE Attorney for Plaintiff AFFORDABLE HOMES GROUP, INC. 4278 Greenspire Lane New Hope, PA 18938 Plaintiff Philadelphia County Court of Common Pleas vs. No. Term BRAHEEM HART, individually and as heir of the Estate of Tonya Bell, deceased, Greene Street Philadelphia, PA 19144 ALL UNKNOWN HEIRS of Tonya Bell, deceased, Greene Street Philadelphia, PA 19144 LINDA PENNY, Greene Street Philadelphia, PA 19144 WALTER WILLIAMS, Greene Street Philadelphia, PA 19144 Defendants COMPLAINT TO QUIET TITLE Plaintiff, Affordable Homes Group, Inc., by and through its counsel, Mester & Schwartz, P.C., hereby files this Complaint to Quiet Title and states: 1. This is an action to quiet title that refers and relates to real property at Greene Street, Philadelphia, Pennsylvania (the “Property”). Case ID: 150200198 2. Plaintiff, Affordable Homes Group, Inc., is a corporation arising out of and existing pursuant to the laws of the Commonwealth of Pennsylvania with it principal place of business at 4278 Greenspire Lane, New Hope, Pennsylvania. 3. Defendant, Braheem Hart, individually and as heir of the Estate of Tonya Bell, is an adult individual who resides and/or regularly conducts business at Greene Street, Philadelphia, Pennsylvania. 4. Defendant, Unknown Heirs of Tonya Bell, deceased, are unknown individual heirs of Tonya Bell, deceased, who reside and/or regularly conduct business at Greene Street, Philadelphia, Pennsylvania. 5. Defendant, Linda Penny, is an adult individual who resides and/or regularly conducts business at 6. Defendant, Walter Williams, is an adult individual who resides and/or regularly conducts business at 7. Greene Street, Philadelphia, Pennsylvania. Greene Street, Philadelphia, Pennsylvania. On or about June 23, 1997, Walter Williams executed a Deed in favor of Linda Penny which was recorded in the Office of the Recorder of Deeds for Philadelphia County at Deed Book D-337-134 (“Deed I”). Plaintiff attaches and incorporates by reference as Exhibit “A” a true and correct copy of Deed I. 8. According to Deed I, Linda Penny delivered $1.00 to Walter Williams as consideration for Deed I. (Exhibit A) 9. On or about February 20, 2001, Linda Penny executed a Deed in favor of Tonya Bell which was recorded on April 16, 2002 in the Office of the Recorder of Deeds for Philadelphia County at Document No. 50440987 (“Deed II”). Plaintiff attaches and incorporates by reference as Exhibit “B” a true and correct copy of Deed II. Case ID: 150200198 10. According to Deed II, Tonya Bell delivered $1.00 to Linda Penny as consideration for Deed II. (Exhibit B) 11. On or about January 24, 2014, the City of Philadelphia commenced a Civil Tax Action at City of Philadelphia v. Tonya Bell, Docket No. 14-01-T0384. 12. By Decree dated May 19, 2014, the Court ordered that the Property be exposed for Sheriff’s Sale and sold free and clear of all liens and encumbrances. 13. On October 21, 2014, the Sheriff of Philadelphia County exposed the Property for Sheriff’s Sale. 14. Plaintiff was the successful bidder at $40,500. 15. On or about August 20, 2014, Braheem Hart, as sole heir of Tonya Bell, deceased, executed a Deed in favor of Braheem Hart, individually, which was recorded on November 5, 2014 in the Office of the Recorder of Deeds for Philadelphia County at Document No. 52847497 (“Deed III”). Plaintiff attaches and incorporates by reference as Exhibit “C” a true and correct copy of Deed III. 16. On or about November 20, 2014, Plaintiff delivered to the Sheriff of Philadelphia County the balance of the successful bid. 17. On or about December 9, 2014, the Sheriff of Philadelphia County acknowledged the Sheriff’s Deed which was recorded on December 30, 2014 in the Philadelphia County Recorder of Deeds at Document No. 52866104 (the “Sheriff’s Deed”). Plaintiff attaches and incorporates by reference as Exhibit “D” a true and correct copy of Sheriff’s Deed. WHEREFORE Plaintiff, Affordable Homes Group, Inc., respectfully requests this Honorable Court to enter an Order declaring that Defendants, Braheem Hart, individually and as the sole heir of Tonya Bell, deceased, All Unknown Heirs of Tonya Bell, deceased, Linda Case ID: 150200198 Penny and Walter Williams are barred from asserting any right, lien, title or interest in the Property, to enter a Judgment ordering the Recorder of Deeds of Philadelphia County to strike and/or cancel Deed III and to grant such other relief as this Honorable Court deems appropriate. MESTER & SCHWARTZ, P.C. /s/ Laurence A. Mester Laurence A. Mester Attorney for Plaintiff 1333 Race Street Philadelphia, PA 19107 (267) 909-9036 Case ID: 150200198