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HomeMy WebLinkAbout02-4627COMMONWEA4,TH Of PENNSYLVANIA COURT O~ COMMON PLEAS JUDICIAL DISTRICT NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT co*w,o. PLEAS N.. O*~ ~ z/~,,;/'7 NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas a~ oppeal from the judgment rendered by the District Justice ce the date and in the case mentioned below. CV I ~s ~ck will b ~ ONLY ~m this ~m is required u~ P~ R.C$2P. ~ ff~ll~t ~ CLAIMANT (s~ ~. R.C.P.J.P. No. 1~8~ 1001 ( 6 ) in ~ti~ ~e Distdct J~tice, he MUST Thb ~tice of A~I, w~ mcd~d by tb Bisbid Justice, will ¢~ ~s a ~PER~DEAS ~ ~ j~t ~ ~ssessim in ~is cas~ FILE A COMPLAINT within twenty (20) da~ filing his NOTICE o¢ APPEAL. S~a~re of ~th~y ~ D~ty PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be se/red upon appellee). PRAECIPE: To Prothc~otory Enter rule upon (Common eleos RULE: To ff~'m~'/1 ~'"" Name fNa~ -¢/"f , appellee(s), to a complaint file in this appeal ) within twenty (20) days after/ser~ vice of rule or ~ment of non pros. , appellee(s). (1) You am notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days ~ the date of service of this rule upon you by personal service or by certified or registered moil (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of moiling. COURT FILE TO BE FILED WITH PROTHONOTARY AOPC 312-90 PROOF OF SERVICE OF NOTICE OF APPEAL AND RULETO FILE COMPLAINT (T~ is proof of service MUST BE FLED WITHI~~ TEN (10) DAYS ~,~FTER fl:;g the notice of :~p?~;,~/, Check apflticable boxes) COMMONWEALTH OF PENn, SYLVANiA COUNTY OF ; SS AFFIDAVIT: I hereby swear or affirm that I served [~ a copy o~ the rqotice of ~ppea Common Pbas No .... upon the D strict Justice designated there ~ on f , (certified} registered) n~aL senders (da~e o serwc6 ; ~ by personal ~ ';~ oB mcdpt attached hereto, and upon the appel ee (name) , ~ by persona servk;e [~ by (certified (registered} mai senders receipt attached hereto, ~ a~'8: further th-"'-~ ~ served th- -~Rde to F~e a Complaint accompanying the above Notice o~ Appeal ~pon the appel~ee.s~ to whom the Rule was addressed on ~ by person ~l se?~ ce ~ n'a~l senders receipt a tached hereto S~;ORN AFFIRMED AND SUBSC~aIBED BEFORE ME THIS DaY OF COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CU~BEI~T.,2~iD 09-3-05 GAYLE A. ELDER Address! 507 iN. YORK ST. MECHANICSBURG, PA Te~ophone: (717) 766-4575 17055 NOTICE OF JUDGMENT/TRANSCRIPT RESIDENTIAL LEASE PLAINTIFF: NAME and ADDRESS rROGERS, SIMON J 218 E. MAIN STREET MECHANICSBURG, PA 17055 VS. DEFENDANT: NAME and ADDRESS FCOOPER, SELINA A, ET AL. 218 E. MAIN STREET APT.# A (SIDE ENTRANCE ) ~ECHANICSBtIRG, PA 17055 Docket No.: LT- 0000244 - 02 Date F ed: 8/19/02 SELINA A. COOPER 218 E, MAIN STREET APT.# A (SIDE ENTRANCE) MECHANICSBURG, PA 17055 THIS ISffO NOTIFY ~U THAT: Judgment: FOR PLAINTIFF [~ Judgment was entered for: (Name) ROGERS, SIMON J Judgment was entered against MARTIR, LUZ [] Landlord/Tenant action in the amount of $ 1,568.50 on 8/27/02 The amount of rent per month, as established by the District Justice, is $ The total amount of the Security Deposit is $ .00 in a (Date of Judgment) .00. Rent in Arrears Physical Damages Leasehold Property $. o 00 -- $ .00 = Damages/Unjust Detention $ .00 -- $ . ~0 = Less Amt Due Defendant from Cross Complaint -- Interest (if provided by lease) L/T Judgment Amount [~ Attachment Prohibited/ Judgment Costs Victim of Abuse (Act 5, 1996) Attorney Fees []This case dismissed without prejudice. Total Judgment ] Post Judgment Credits Possession granted. Post Judgment Costs Certified Judgment Total ] Possession granted if money judgment i not sat~st~ea Dy t~me ot ewct~on. b__J Possession not granted. ~J Defendants are jointly and severally liable.. [] Levy is stayed for days or [~ generally stayed. ~] Objection to Levy has been filed and hearing will be held: Date: Place: Time: Total Amount Establish..ed Oy.[~J ,.l~ess. Security Deposit Ap~Ji..ed : Adjudica.[ed,,A2'Q,ouj0t.. $. -,~u.uu-$ .uu = $ $ .00 $ .oo $ .00 $ $ ss.5o $ .00 $ 1,568.50 $ $ $ IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN TEN DAYS AFTER THE DATE OF ENTRY OF .JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT, IF ANY. IN ORDER TO OBTAIN A SUPERSEDEAS, THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED. IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE PARTY HAS 30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THE, P~R.TY RILli"JG AN APPEAL MUST INCLUDE A COP~OF TF~ NOT[CE OF JUDGMENT/TRANSCRIPT FORM WITH THE NOTICE OF APPEAL. ~]g~/[~ Date /~ (/' ~'~'('~.~/7 ,District Justice II c~r~ify that this is a true and correct cdpy ot the recorcrot the proceedings containing the judgment. Date , District Justice My commission expires first Monday of January, 2006. SEAL COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CDMBERI~,~D Mag Dist No.; 09-3-05 DJ Name: Hon. A~r~ss: 507 N. YORK ST. MECHANICSBURG, PA (717) 766-4575 17055 LUZ MARTIR 218 E. MAIN STREET APT.# A (SIDE ENTRANCE) MECHANICSBURG, PA 17055 THIS IS TO NOTIFY ¥~OU THAT: Judgment: FOR pr.~ T~['IFF -- ~ Judgment was entered for: (Name) ROGERS, SIMON J Judgment was entered against COOPER~ SELINA A r-~ action in amount of $ 1,568.50 on 827~_.~_L0.~__ Landlord/Tenant the . The amount of rent per month, as established by the District Justice, is $ The total amount of the Security Deposit is $ .00 NOTICE OF JUDGMENT/TRANSCRIPT RESIDENTIAL LEASE PLAINTIFF: NAME and ADDRESS FROGERS, SIMON J 218 E. MAIN STREET MECHANICSBURG, PA 17055 VS. DEFENDANT: NAME and ADDRESS FCOOPER, SELINA A, ET AL. 218 E. MAIN STREET APT.# A (SIDE ENTRANCE) ~ECHANICSBURG, PA 17055 / Docket No.: LT- 0000244 - 02 Date Filed: 8/19/02 in a (Date of Judgment) ,00. Rent in Arrears Physical Damages Leasehold Property $. .00 -- } 00 _. Damages/Unjust Detention $ .00 -- ~ ' 00 - Less Amt Due Defendant from Cross Complaint -- Interest (if provided by lease) LFr Judgment Amount [~ Attachment Prohibited/ Judgment Costs Victim of Abuse (Act 5, 1996) Attorney Fees [~ This dismissed without Total Judgment case prejudice, ] Post Judgment Credits Possession granted, Post Judgment Costs Certified Judgment Total ] Possession granted if money judgment i not sm~st~eO Dy t~me et ewct~on. [] Possession not granted. [] Defendants are jointly and severally liable. · [] Levy is stayed for days or ~1 generally stayed. ~1 Objection has been filed and will be held: to Levy hearing Date: Place: Time: Total Amount Establish..ed ~y. ~J ..l~ess · Security Deposit App..li..ed = A d j u d i c aJ.e ,d~lo.u(~ t.. $. .uu = $ , u ~ o00 $ .00 $ . nn $ ss.5o $ .on $, 1,568.50 $ $ $ IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT, IF ANY. IN ORDER TO OBTAIN A SUPERSEDEAS, THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED. IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE PARTY HAS 30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THE~, PJARTY F/ILIN. G AN APPEAL MUST INCLUDE A COPY-.~OF TI-J{~ NOT[CE OF JUDGMENT/TRANSCRIPT FORM WITH THE NOTICE OF APPEAL. t"]r~/~ Date .~, (/. ~'~"('¢~,,7 .District Justice I c§¢ify th~.t thi!s is a true and correct cdpy of the record-of the proceedings containing the judgment. i District Justice Date My commission expires first Monday of January, 2006- SEAL SIMON J. ROGERS, Plaintiff SELINA A. COOPER and LUC Z. MARTIR, Defendants : 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02- /-/~,o~7 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow the defendants, Selina A. Cooper and Luc Z. Martir, to proceed in forma pauperis. I, Philip C. Briganti, Esquire, attomey for the parties proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Date: Philip C. ][~ganti y Attorney for Defendants MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA SS AFFIDAVIT: I hereby swear or affirm that I served c ,'~,,.I [~copy of the Notice of Appeal, C~nmon Pleas No. ~o-?..'%.~.r~_ ? upon the District Jusf~e designated therein on briand furmer mai I served [ne Hute ~o r-i~e a L;omplain~ _accompa~]ing the above Notice of Appeal upon the appellee(s) to whom the Rule was addressed on ,.¢.,.z2 ¢k,.,,~,~¢, mail, sender's receipt attach~J-~'eretd. .......... '-~ SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME Signature oi o!ficis/ bebre whom affidavi', ;~,;as made TL,e of o#ic;a/ My oommissien expires on .................... SIMON J. ROGERS, Plaintiff Vo SELINA A. COOPER and LUC Z. MARTIR, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . : NO. 02-4627 CIVIL TERM NOTICE TO PLEAD. TO: Simon J. Rogers You are hereby notified to file a written response to the attached Preliminary Objections to Plaintiff's Complaint within twenty (20) days from service hereof or a judgment may be entered against you. Date Philip C. l~;ig ' Counsel for Defendants MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 SIMON J. ROGERS, Plaintiff V. SELINA A. COOPER and LUC Z. MARTIR, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-4627 CIVIL TERM . PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT COME NOW the defendants, Selina A. Cooper and Luc Z. Martir, by counsel, Philip C. Briganti, Esquire, MidPenn Legal Services, and raise the following Preliminary Objections to Plaintiff's Complaint: Motion to Strike Off Complaint for Failure to Confrere to Rules of Court 1. Plaintiff failed to attach to the Complaint a copy of the parties' written lease, a document upon which Plaintiff's claims are based, as required by Pa. R.C.P. No. 1019(i). 2. Plaintiff's Complaint is not verified as required by Pa. R.C.P. No. 1024. WHEREFORE, Defendants request that Plaintiff's Complaint be stricken for failure to conform to the Pennsylvania Rules of Civil Procedure. Respectfully submitted, Counsel for Defendants MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 CERTIFICATE OF SERVICE I, Philip C. Briganti, hereby certify that I am this 31st day of October, 2002, serving a copy of the foregoing Notice to Plead and Preliminary Objections to Plaintiff's Complaint upon Plaintiff, by mailing a true copy of the same to Plaintiff at the following address by first-class U.S. mail, postage prepaid: Simon J. Rogers 218 E. Main Street Mechanicsburg, PA 17055 Philip ~. Brigantj/r Counsel for Defendants MIDPENN LEGAL SERVICES. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 Simon J. Rogers, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02 - 4627 Selina A. Cooper & Luz Z. Martir Defendant CIVIL ACTION - LAW NOTICE TO DEFEND This serves as notice that you have been sued in court. If you wish to defend against the claims set forth in this suit, you must take action by entering a written appearance personally or by attorney and filing in writing with the court your objections or defenses to the claims set forth against you within twenty (20) days after this Complaint and Notice are served. Failure to do so may result in the case proceeding without you and the court may enter a judgement against you without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose property, money or other rights important to you. THIS PAPER SHOULD BE TAKEN TO YOUR ATTORNEY IMMEDIATELY. Dated: 11/18/2002 By: Simon J. Rogers Plaintiff Simon J. Rogers, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02 - 4627 Selina A. Cooper & Luz Z. Marth' Defendant CIVIL ACTION - LAW AMENDED COMPLAINT Attached to this Amended Complaint is a copy of the parties' written lease. Attached to this Amended Complaint is a copy of Verification. Dated: 11/18/2002 By: ~.--.-------~---~ Simon J. Rogers Plaintiff RENT4I, dIPPLiC&TiON Applicimt's CRtDIT R~Ir~NC~$ ~ #: ( ) ..... . Ad~: Ad~: ...... Pho~ #: ( ) , I'ER~ONAL l~lri,~NC~,S ~ ofMolor V~dc, le: .... Yes. r: Color' _,~ _ , _ii_tn pu ot tin, one who ii lnciudffl in.thb npPtJeition wer: .~..~. B~n Ev~ctl~l from Filed rot Bmjkrup~cf the answer is "YES', to Shy ot these questions, pbme esphin lo detail (smtinl places, dat~ u~u~, e~ bdow, usln~ the back ofthb Rental APpiiention foe additional spa~ RESIDENTIAL LI ASE any purpose other than is a [,~Me mb:lie fml~y midenot ~ _d~a_ Ii oomply with.all tM sanita~ laws: pres~"v~m~ or,he d~mised pr~mise~, mhd the lidewalI,J ooimaC~KI th~w~o, du~ the tram of ~.is Ieee. 6. Cvndido~ of Pressdses~ Lessee stipulates that ~ hn ~ ~ ~ pre~s, 7. ~n~ ~~ Wight ~ ~r ~ ~t ~ ~s~, ~ ~a~ not ~ ~t of ~, ~ ~ ~ ~ ~ ~ ~ ~ law, s~l ~ void ~ ~, a ~s consent of Lessor, ~a4ficli mny be withlmld in LeasoFs absolute dim~,etion. Ail altm'ations. ~, im~ovements built, constructed, or plac~d on the demised p~emis~s by l..essee~ with the exce~ion of fixtures q~_ ~ agreetnmt ~ Lessor and Less~, bo tim prope~ of L~sor md remain onthe dotnis~ p~emim~ at tl~ c-44~iration ot soonc~ termination oft~s lense. 9. DassogetoPrms/ses. lfthedemisedpsmnises, er any pan thtreof, shallb~portiallydaum~tbY fire er other ~ not due to Lessee, s nejjips~ or wiMul act or ,.hat of his employee, family, agenk er visitor, time during which, and the extent to whir, h, thc leased iwemis~s may have be~n untenantable: but, i~ the l~ased premises should be darned other than ~ t,~'s ~ or willful act or that of his emplo,/~ the tent shall be prorated up to the time of the damage. 1 O. D~ngeroas M~t~ri~ls. Lessee shall trot keep o~ hnve on the leased premisus ar~' snide o~ thin~ of a dan~rous, inflnmnmble, or expl~ive charact~ that might ~ably increme, th~ danger of Lessee agrees that no signs dull be placed on or about tl~ leased premises by lessee or st his direction without the prior written consent of Lessor. t3. ~ Lessee shall keep no ~ or other animsls m~ or about the le~sed premises with°ut the writtm consent of Lessor. In addition, n Pet Agmmncnt must b~ mmpleted and a pet security 6eposit must be paid. ofthi~ ~ and any ~ mil b~l~8 ~p~ove~ts or 17. Hd~~ ~ I_~ w~h m~ll ~ sub~ ~ all ~ ~ ~ ~o~ ~fb~t ~ ~'~a~ ~ ~ (30) 19. ~ou~ ~~t ~.m~ s~ ~if~ ~t~ ~'~ ~ ~~~ ~h~& thc ~, at ~ ~ of ~, ~11 ~n~e ~ ~ f~ ~ ~ ~ ~ ~ ~i~s ~d 20 A~~t if~~~of~s~smab~~~ ~y pros~ ~, w~ ~ ~y p~ of~ ~ ~pi~ ~, ~ ~ ~v~ ~ ooH~ all ~t p~nbio r~t f~ su~.~ ~liz~ to ~s~ ~ 21. ~'s F~ 22. ~v~. d~g md ~! ~t leave ~ ~ ~ ~!1 ~ the r~ibili~ 24. ln~l~i~: not ~ li&bl~ for an~ rent until possession is ~iv~. ~ ~ ~Aam ~s lea~ · ~sessi~ is ~t ddiv~ ~i~ ~v~ (71 da~ of ~ ~ of ~ t~ 26. ~lssu~: ~s~~ 27. E~me~H~m~ll~.~: ~a~tm~f~of~sp~in ~e d~llin8. 2S. T d~: Av~ of t~ ~ ~b~ ~ ~ ~ ~ P~ is n~ ~, ~ of the ~mi~, - 30. Loc/~: Leez~ is prohibited from adding links to, ~hangin$ or in any way alterin~ loc, ks inst~lled on th~ doors on ~he lXmiSes without tha pri~' writ~n consent of the Lessor If the ~dition or c, hsnb, in8 of such locks is consented to, LCss~c shall provid~ l~ssm' with keys to such looks. 3l, NoEsMleinLond: Thislea~shMICreit~th°relnti°nship°fi~mdl°tdandtenant~l~ss°c and Lessee; no estate shall pass out ofth~ Lessor, Lessm kris o~y · usuguvt and not an estat~ for years. 32. 8everd~/~: lnth~eventthat~ypanofthiale~b~onstn~d&sun~nf°r°esble'ther~ainin$ pnrts of this lease shall be in tull force ~d effect as tho~h th~ unenfe~.~bl~ part or pans w~ro not ~itten into 33. Peal ¢omroL' pest control is the respomibilit~ of Lessor. of this Icu~. 35. ~h~ ~rms: IN ~NITNF.2~ WHI~I~OF, fl~: parties havo ~ this ~as~ at ~ the da~ and ye. ar first abovc x~vi~t~n. MOVE-IN INSPECTION LIST to'-~-~in .... Ih~~' ~ of this tist prio~ to takin$ occal~nU~, uno ~.a..,-,., GENERAL COMMENTS: damage. 'Lesso~ shall havc tl~ right to ~ tim prtmis~ wimi,x rave i~) ousme~s &a~,s ina' ute si~cifically in writing the items ot~ the hst to wtur, n t~ cttssents am1 mutt s~Sn suc sMtcmmt of*dissent, which most th~ be presented to Lessor. ~,~ /._,~ //~ t~x ~ " t~ PET AGREEMENT (ADDENDUM TO RENTAL AGREEMENT) DATED This asr~mmt is atta~hM to and forms a part oftho l~tal Agreemmt datM in tho dwollin8 they oc. Gupy under' the ~ Asreement refm~i to above. Becaus~ ,hi~ Asreoment spec~cany prold2b koepb~ pets vett~o~ the Owne~ peambion, Tenants aSree to die Mowbl8 terms Ind condJl:i~$ Jn exch~$o for thi~ pa'l:nJss~)n: 1) Temmts agree to keep t/~ pet und~ control at rill ~ 2) Tenants ngree to keep their pet reStraln~l, but not tethered, when it is outside their 3) Truants alPee to ~lhem to local ordinances, inc~atn_o leadl and li~usin$ requiremeat~ 4) Tenants asree not to Ioave thdr Pet unattendod for any unreasonablo p~iod~ 5) Tenants asree to.dean up after ~oir pet and dispose ofpefs waste properly and qu~ldy. 6) Tenants asreo not to leave fx)od or water for their pet or any other animal outside thelr 7) ?annts qree tokeep pet f~n beths tmecemflly noisy or ~ressivc whlc~ may cause $) Tenants a~e to hnmodJate~ remody any complaints nmdo Ihrough the Owners or 9) Tenants asree to plx~/ide pet with rosular health earo, indudin8 inoculations as 10) Taiants qreo to provido pet with an identifklti~ taS. 11) Tenants asree to vacate pet's oflkprin8 within eishts weeks of birth, 12) Tanantsapoetoi~. pay for any damase, imsor ,e~.ensec~usedbytheirpet. In addMm, they will mid ~ to ~hdr security deposit which may be used for ckanh8 dnntges hr~ bern aMeesM, .w~. b0 returned to t~e Tenants witMn. ~days tRer they ~:,te the proPerlY or it m 6eemed _,h_.t they no longer have ~e 1~. 13) Truants asreothat Ownors rose~theriBht to revokept, m~jsion to keeP thepe~, dmuld (owner) (Owner) MOVE-OUT INSPECTION LIST the list to which he dissents. LIVINGROOM DINING ROOM KITCHEN HALL BEDROOM BEDROOM #2 BEDROOM BA'~H #1 GENERAL COMMENTS: Simon J. Rogers, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Vo NO. 02 - 4627 Selina A. Cooper & Luz Z. Martir Defendant CIVIL ACTION - LAW VERIFICATION The undersigned, Simon Rogers, hereby verifies that the facts set forth in the foregoing Complaint and Amended Complaint are hue and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Dated: 11 / 18/2002 Simon J. Roget*s Plaintiff