HomeMy WebLinkAbout96-03921
ERIC W. MCRENZIE and
RATHY L. MCRENZIE,
plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERL,AND COUNTY, P~NNSYLVANIA
NO. 96- 3'/.)/ CIVIL TERM
v.
EARL P. GARMAN,
Defendant
NOTICE
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take action
within twenty (20) days after this complaint is served, by
entering a written appearance personally or by attorney and
filing in wr.iting with the court your defenses or objections to
the claims set forth against you. YoU are warned that if you
fail to do so the case may proceed without you, and a judgment
may be entered against you by the Court without further notice
for any money claimed in the Complaint or for any other claim or
relief requcsted by the plaintiff. You may lose money or
property or other rights important to you.
YOU SHOULD TAXE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THI
OFFICI SIT FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR, 4TH FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
AMERICANS WITH DISABILITI ES ACT OF 12.2.Q
The Court of Common pleas of Cumberland county is required
by law to comply with the Americans with Disabilities Act of
1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business
before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business
before the court. You must attend the scheduled conference or
hearing.
ERIC W. MCKENZIE and
KATHY L. MCKENZIE,
Plaintifh
v.
EARL P. GARMAN,
Detendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96- }l1.JI CIVIL TERM
COMPLAINT
COME NOW the plaintiffs, Eric W. McKenzie and Kathy L.
McKenzie, through counsel, Philip c. Briganti, Esquire, Legal
Services, Inc., and represent as follows:
1. Plaintiff Eric W. McKenzie is an adult individual
residing at 514 Park Drive, Boiling springs, Cumberland County,
Pennsylvania 17007.
2. Plaintiff Kathy L. McKenzie is an adult individual
residing at 283 Plaza Drive, Boiling Springs, Cumberland county,
Pennsylvania 17007.
3. The defendant, Earl P. Garman, is an adult individual
residing at 861 N. Middleton Road, Carlisle, Cumberland county,
Pennsylvania 17013.
4. On or about August 16, 1995, Plaintiffs entered into a
written residential lease agreement with Defendant, whereby
Plaintiffs agreed to rent from Defendant a mobile home located at
19 Green Meadows Drive, Carlisle, Cumberland County,
Pennsylvania, 17013, for $400.00 per month. A copy of the
parties' lease agreement is attached hereto, incorporated by
reference and marked as Exhibit "A".
5. Upon executing the lease agreement, Plaintiffs paid to
Defendant a security deposit in the amount of $400.00, prorated
rent for August 1995 in the amount of $14B.OO, and rent for
september 1995 in the amount of $400.00.
6. Plaintiffs moved into the rental premises on or about
August 20, 1995.
I. Breach ~e Imnlied Warrantv of Habitabilitv
7. Plaintiffs repea~ and incorporate by reference their
averments set forth above in Paragraphs 1 through 6.
8. Before Plaintiffs signed the parties' lease, Defendant
advised them that they would have to boil the water at the rental
premises, which comes from a private well, before drinking it or
cooking with it.
9. In addition, almost immediately upon moving into the
rental premises, Plaintiffs discovered that the water emitted a
rotten egg odor which permeated the dwelling, and which remained
on Plaintiffs' dishes after washing and on their skin after
bathing.
10. Several days thereafter, in mid-August 1995, Plaintiffs
advised Defendant of the water odor, but Defendant told them that
he was not going to do anything to correct it.
11. subsequently, on or about August 25, 1995, Plaintiffs
had the water from the rental premises tested, and were informed
by the Gannet Fleming, Inc. Environmental Laboratory that it
contained total coliform bacteria, which could cause diarrhea and
other illnesses A copy of the laboratory report from Gannet
Fleming, Inc., is attached hereto, incorporated by reference and
marked as Exhibit "B".
12. Because of the above-described problems with the water,
Plaintiffs could not drink the water or otherwise use it, had to
buy bottled water for drinking and washing dishes, and had to go
to relatives' homes to bathe.
13. On or about September 5/ 1995/ due to Defendant's
refusal to remedy the water problem, Plaintiffs were required to
have a culligan "Super S" water filter installed, at a cost of
$56.10.
14. This filter removed some of the "rotten egg" odor from
the water/ but not the bacteria, so that Plaintiffs were able to
use the water for bathing, provided that it was kept out of their
mouths and any open cuts/ but they ~till could not use the water
for drinking.
15. Despite the ongoing problems with the water,
Plaintiffs paid $400.00 in rent to Defendant for October 1995/
and $400.00 in rent was paid on their behalf for November 1995,
in addition to the prior months' rent they had already paid.
16. On or about December 10, 1995, the water pipe which
supplied tho shower in the rental premises broke, through no
fault of Plaintiffs, and caused water to gush out inside the
bathroom wall.
l? Plaintiffs had to turn off the water to the entire
dwelling to stop the gushing water and to prevent further damage
to the rental prem\ses.
18. Plaintiffs attempted to contact Defendant several times
but were unable to reach him, and were informed that he was on a
huntin9 trip and could not be contacted.
19. On or about December 15, 1995, Plaintiffs began to
replace the broken pipe in the bathroom, which was rusted out,
and had to remove the bathroom walls surrounding the shower and
part of the floor to make this repair.
20. The walle and the floor were so rotten that they could
not be re-installed, and Plaintiffs had to purchase materials
totaling $134.77 and perform labor valued at $200.00 to restore
the walls and floor so the bathroom would be usable.
21. On or about January 14, 1996, Defendant finally
contacted Plaintiffs, but refused to compensate Plaintiffs for
their expenses in repairing the bathroom or give them a credit
toward their rent.
22. In addition to the above-described problems with the
water and bathroom at the rental premises, Plaintiffs also
discovered the following defects:
a. rotten floor in the master bedroom, which bowed and was
in danger of collapsing
b. strong kerosene odor within the dwelling, which
Plaintiffs believe made their son ill
c. leaking kerosene tank
d. outside doors to rental premises would not close or lock
e. porch was rotten and collapsing
f. serious rat infestation problem
g. several windows which had no glass, but instead were
covered with plastic
23. Detendant was given notice by Plaintitt. of allot the
above-described detects at the rental premises and/or was aware
or these problems, and had a reasonable opportunity to correct
them, but tailed or refused to do so.
24. The above-described defects rendered the rental
premises unsate, unhealthful, and totally or substantially
uninhabitable with virtually no rental value.
25. Detendant, as a residential landlord, had a duty to
otter and maintain the rental premises in a habitable condition,
pursuant to the implied warranty of habitability.
26. Defendant, by offering the leased premises to
Plaintiffs with the above-described defects, and/or by failing
to correct these detects after Plaintiffs took possession of the
premises, was in breach of the implied warranty of habitability.
27. Because of Defendant's breach of the implied warranty
of habitability, plaintiffs commenced moving out of the rental
premises on or about January 16, 1996, and, before they had
removed all of their belongings, were unlawfully locked out of
the premises by Defendant on or about January 20, 1996.
WHEREFORE, Plaintiffs reque"t that a judgment be entered in
their favor and against Defendant in the amount of $2138.87, as
compensation for the rent, repairs, security deposit and other
out-Of-pocket expenRes they incurred as the result of Defendant's
breach of the implied warranty of habitability; and that they be
granted such other and further relief as this Court may deem
reasonable and just.
II. Conversion of Personal procerty
28. Plaintiffs repeat and incorporate by reference their
averments set forth above in p~ragraphs 1 through 27.
29. Since Defendant locked Plaintiffs out of the rental
premises on or about January 20, 1996, he has held and refused to
permit Plaintiffs to remove personal property from the dwelling
which they own or to which they otherwise have a right of
possession, thus wrongfully depriving Plaintiffs of the use and
possession of this property.
30. The value of the property which Defendant has withheld
form Plaintiffs is $6156.67. A list of said property setting
forth the value of each item is attached hereto, incorporated by
reference and marked as Exhibit "C".
31. Plaintiffs have been inconvenienced and otherwise
suffered damages as the result of Defendant's wrongful retention
of their property.
32. Defendant's wrongful retention of Plaintiffs' property
constitutes the tort of conversion.
WHEREFORE, Plaintiffs request that they be awarded a writ of
replevin directing Defendant to immediately restore them with
possession of their property, and a judgment against Defendant
for damages in an amount appropriate to compensate them for
Defendant's wrongful retention of their property; or, in the
alternative, that they be awarded a judgment against Defendant in
the amount of $6156.67, for the conversion of their property.
I II . FRAUD
33. Plaintiffs repeat and incorporate by reference their
averments set forth above in Paragraphs 1-32.
34. After plaintiffs had repeatedly requested Defendant to
permit them to retrieve their property from the rental premises,
Defendant, on three occasions, in or about February 1996 and
March 1996, agreed to let them to pick up their property.
35. However, eftch time when they arrived at the rental
premises, Defendant refused to permit Plaintiffs to remove their
property, and continues to reta~n it over their objections.
36. On one of these occasions, on March 26, 1996,
Plaintiffs reasonably relied on Defendant's misrepresentation
that he would release their property to them in renting aU-Haul
truck with which to move their belongings, at a cost of $47.91.
A copy of the rental receipt for the U-Haul truck is attached
hereto, incorporated by reference and marked as Plaintiffs'
Exhibit "D".
37. Defendant's misrepresentation was intentional, was made
with the purpose of causing Plaintiffs to suffer inconvenience
and financial loss, and constitutes fraud.
WHEREFORE, Plaintiffs request that they be awarded a
judgment against Defendant in the amount of $47.91, and that they
be granted such other and further relief as this Court may deem
reasonable and just.
IV. Violations of the Unfair Trade Practices and Consumer
Protection Law
38. Plaintiffs repeat and incorporate by reference their
av.rm.n~s set forth above in Paragraphs 1 through 37.
39. On or about November 1, 1995, Plaintiffs mailed
Defendant a check dated November 16, 1995, in the amount of
$450.00, tor November 1995 rent and late charges, along with a
note indicating that the check was postdated.
40. Deepite this, Defendant presented the check to his bank
prior to November 16, 1995, when there were insufficient tunds in
Plaintiffs' account, causing them to incur bank charges of
approximately $75.00.
41. Defendant is engaged in "trade" or "commerce" within
the meaning of the Unfair Trade Practices and consumer Protection
Law, 73 P.S. Section 201-1 ~~. (hereinafter "the Act") .
42. Defendants' actions as described in Counts I, II, III
and IV of Plaintiffs' complaint constitute unfair or deceptive
acts or practices in the conduct of trade or commerce within the
meaning of section 3 of the Act (73 P.S. section 201-3).
WHEREFORE, pursuant to section 9.2 of the Act (73 P.S.
Section 201-9.2), Plaintiffs request judgment against Defendant
for their actual damages or $100.00, whichever is greatsr; three
times their actual damages as a statutory penalty; and such other
and further relief as this Court may deem reasonable and just.
V. Punitive Damaoes
43. Plaintiffs repeats and incorporates by reference their
averments set fort.h above in Paragraphs 1 through 42.
44. Defendant's conduct as described in Counts I through V
ot this complaint was wilful, wanton, outrageous, intentional,
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EARL . GARMAN \
861 N. Middleton ROld
Carlisle, PA 17013 , .:" ,
(.'I7~ 24304306 . >;~ .' .
g..~ ,a.(j- r;t? 'fS" J""-.:";/i;,:~.";'",:,
YE.\RLV RENTAl. ,U;RERl\IENT
PIWPf,RTV RU , ,~JU:GlJLAll0NS
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GENF.RAI.: Ll O'~ '.;;
I. Rmt, or $ ,(J tJ. _lIT' p~y_bl.ln ."v"" by Ibe firll or tath.month, Any rml not r.rei,ed by the
third (lrd) day from Ihe due dftle will be ~sscmd lal. penalty ror c:ach day laleat the rile ors'-!)() per day
thll such paymentla deemed lale, ' " " . ' .
2, No IUb.le<<ing, rmti"8 Or otcup_li<m by mor IhAn On. rArnJly will be permllted,
3, No more than rour people ptT home Ar. f ilted,nuee people lillle rq1dar Rut , ^ rowth penon
I\ill requlre addition&l rent of$50,00 pcr month
4, No peddling, wlielling, or cotJUntrti&l VC'lUIIJ f /U'. pmnilted, )
", No wuhen. dtvers--...2!.9Ylsid~_~h~Ji!l~,', 'lLNJn.l.fj_~ " '
6, "R~dmls Ille r~onsfble for Ih. Action, or ~f.fv;..r orth..u dlJldren, guma and pet(s), ,
7, Any behavior wIilth dlsturbs Ihe p.ar<: IIJ~ tr~ "uh:y orlh. community I. prohihited and shell be ~CICt {
to penalty, -. ;, / f I' I, . f : ' ,~
~:I "r"y, ~olll~,~" ~f fed,tt,aI" Stal~: o~ J~~I a . ftJ1 ~r~jnl~~csa~~ 'f~ ~t!f!!Z oflhe!e,,~: ~~ _ ~ ~~__.i
I' ,....'ro... , " \ '! "tY:""..~ l' .
9 ' Any 'cOntinlllng or /tpCftled vlul\tiC:I'< I : II" ~I' 11I1," <11,1 rq,,'II"!nrs ~f/l ~.it,:! ~t ~lJIes dIlmagelo ' \';
dl'c1ling or Inlmcr~ wilh lht CClmfe,h,,, "f'ly." fst' ,'I ,"' rc<i:1!111 ""II ue'IlT'~U1cl.! fill' p',ic!ion prO<:tdures, '
10 Oil gun., ~"ct 8'10" ,ir riO... c: ,h.~ ,l 9; T' "4l,J j, I'r.- I ,hile" in the (()mllnitj ,
II. The rnaiiAg"fTl.nt ,will not be r.~I"'n "10 (I" 'fdtfenl,.lnjllri... (1r lo.~ ofprop<1ty by fire, lhrlt, ..inJ, "
O<'Od, or othtr nAlllrar act! ..hleh A,. I ".,,' I ~;, CC'llrel FII':ip'llellt Blld ftH.Tftlu.r ftlm:,hed on lht .
ground! are ~o'r1y fcr'lhe tnl1vlen~ "fl e I ('ll,llr,tj ,nd &II fN!(r;" IJ~ng rame ;)'. 'c Illlhdr o\\n ri,k, I L
12, Thethl'/111o!ll\' !haJll~ sd ,no lo',v thlll! ~~ ""r hif.~tr th." i2 ""lIT"'" r, 1-", o~ firedipAc< Jlfilltt! . r
are per1T'Jtted, 1 I ~
MOBlU: "('MY. LOTS A!'ID GrKF1tl ' I , I
I. The mnn~enl-:nt rem"c! the,rill,hl I, ":Cl Ilv 'I,,' in:'!;' ,""bUe ho!'lc, or building.u IIillimes for the I
putp<'O< ofin"i"<.1jon or lJti'il;.~ m.;nl',l1&I,"" ,"
2 l'Iothin~","" b. .to,..1 "Ir,;,', nn I!. , I 1 ' r '" IIn~ :1,. ",I'fillr 0' the mob~e home; t?(,unple;
. " , \
tirts,bicydf':\,trtt~h, Mr rf OW~ill,. ~1( '1,J.(' i~ It' l' j ..t. dill I~'I' th-,I j, ~JAAC$1I."d. 'I
3 Any "",",p.r ,j.'ne ~)' II" ',,1 'eI l: "c, . ',) ,I,:., '''IY IA\lm, 10"' uf ,hIU~!', 'y, tree life or
el.etricrllinet .hall~. ",-.;red '" '''l'f'.-",' ': ri,/ .V~",.~i ;~ rnr,~:! i. rol1liro.!, it \\ill..". It Cl' ra;iti"1\l"'
""J1"""
r'UH1~1;'~' r"'~tf1o:~,. "I :,., '.. 10" :""\ ~...." I I'tt~tt;...rJ ~..r\.\.: Wj.: .. I.. '~l.\L lU ~le
rXTT.IUOR l~fl'ROn:.MENTSI '
I No thlll1/lC', AlltrAtion!. or AdrlitJ<'IIS 1<, I"., nhile horr,. or the lot may be made by the reaidmt without
prior written tonsenl or the IOiIllRgemenl., I
2, ~heds. ,wlun~ IlI1d porthes mU.II b. prcl'e1:Y demibed 10 mlUlllAement her ore installation and written
ApprovAl of ruth 10m! be obtained by lhe r~i'!',"l '~fcre work i, !t.vted,
3, II is very importlll!1 lI,"1 r...id''l1I~ ccn""~I..,;th mnn'j\eml'11( contft1J.ing Improvemenllon lols !!Uch lIS
plllJ1linA oftree1. due 10 lJNDERGROI'ND I "I!t.rrn's AND WIRINC; If anI' damnge is done to !!Uch and
managcrnml h.s 001 h..", e<HII"cled the ':0'( "r"l'AlI ,,;;1 Ii. lotely wilh Ihe residmt.
4, No rent'" Ife penn/tied 1'1<\ torocrrle !,I"',, 'Ie r'" 11':11,,'<1 (or the Ille IIJ ",cpa,
5. All shr\Jh",~" pl"nled I,v ,,,';.h'l', 'l'AlI', '111' I~,,' r"'f"ffJ' "flh.lot IlI1d m.y IIcll.. tr:tnovc<j
6 AlIl'll.<b _11,1) be plACed in A c<,nlll. It. ',II:: ,/,,1
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'1'IlUl'/C AND VF.IIJCJ.EIlI " ' ,'" J., . " "I' ,,", '
I. No rl!plJring, chlnging of uil, or ol'rrhslIJulg or "",1111 drivewI)~ In lionl ornillbile home or on ailed -
.Jlr ftnvwhcrc on p""pmy. .' ' " .' .,;.....1 ~ q" :, " . , . ' "'.
~ - 2, 'OperatlOIl of mJnlb,kt1l, dune UlIfll'Jet<. Inow rilohih',' or /IllY ooii~o"vention" vehlde il prolu'biled, I
3, No more than two (2) Willer family lie pm"Jue, on tbe lot. No oolWncrcial or IlIllcrlhll1 JI~ 10D 'e
pickup lJ1/ck il pmnHled to be pl/krd on Ihe lot. ' J 1
4, PArklug of clln on the lawll il prnhibile.! ,.' I~,'
" Unlicmsed vchldrt may nol be plJked on lIle IOL 0 ttal/on or c~pen lie allowed, ,
I.AWN!l AND WATEIl: I, '\',
I. Management rcst'fVcs the dght to ,egulate 1Il. 1\ al . used for wuhlng eall'and wa1crina lawnl
2, Lawns must b. kef)1 nrAI olld nllll'od 10 A hl'iW' "f 3 In(hcs at all times, Ie lawn II nc&Iected and
mlMilrmml hu to mow, Ih. re.,idtnl "ill be ch"'8,,1 a, lIimum of S 20,00 for each /IlQw\ng.
J. Do not Olllh llll)1hinll do"n Ihe <1,01111 'I/ch os ,. '. clolht\ fwd paper, IlIIitll}' Illpkim, Of Iteml
made of plutie or robber, SlIch itnlll .hould br dJ'fXlSod in gasbage oontalnen, , . ;
'ETS, l \. " I'i'" I I
I. ONLY ONE (I) hOI!!. pet pn home i! IIllo.",1 (S2~ 'per month Clltra), Thll wiD become part ufyOOl
monlllly Itnt and will be plYlble wilh Ihe nonlllll rn,l If ~I :M II paid laic, lat. feet willljlJlly,
2, WImI ftI1lmalllU. ol/lai<1. th. hom.lhe)' III'L,I ~e' ,,'.. < 'L1h aJ 1I111im.. and attendod 10 by a ~pQllsible
pmon, ~11 !ll/m..aIJ,:~I!,-~1<l.!Q.r.\l!\1Q9~~ ~t WY.!lm~.:14 ,,:Iudes ~HL1!sl\.y.,@~'A.nlnaIa tmj.rt DO,1 be
.....1lked on other p~'~k, ~ c1'''1) ',I I ,( '. - , ,\,', . ,I ,. r
3, DOG I/OUSES, RAJIRlf I/UICI/I',. OR AI", nil' lJII'UlJ1SllJE P/;r<'s ARrl PERMrnH) BY
SI'EClAL PERMIT ONL ,/, , . ~t"" ' ," ; ~r' '; rl ' I, . ,',
4, Dogs or call or MY animol mAY 1\<11 be lied IJuhilJr II/I;!;teIlJed, llullncludes tying anlmaIsulldcrlb.
home or on any plUt "fthe p/l'lIU!U " ~I . ' ':':' '.' ,',
5, Each resident lI.ilb an anirnlll is leiP"lwble ("I ;'i"~'1J1"11!heir own dOll Of ~'dr.;ppings, wht:f.her on'" ' i
!heir lot or rhewhcre, . . \" " ,
6, IMge dogs Ill. 1101 encomng,') as 'he,. i. Ihllll"'l'l, plICl! ror 'hem In a /IlQbile home 101. One 5Illall
hOUI. pd II allowed.
7, If II allY lim. a ,J"lI '11 c81 0' A"i' ...,her I,et h "":ie. J'"hl)illllIJ other ,..idenYlin any way, YOll wlI1
hove 10 get rid of lhe pet, f '
AGRF.F.Mf.N'I': \ \ ,
Signlll'''. IIllIn,1 "crelo h)' le,i,I.'11 .1"lIllX>lIllil,IJe II', , ~; .:,1,,'11 upon All mcmL.'f' of Ih.;r family and
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Any Vlol.li"" of these Rules OJ,,! Rr;\'lItJ1i,,", 1110)' ~e ~'I ,", rl/( ~i(l:,'n ' '
The MIUlAgrrnent rCSCTVt~ lh.. ,iy),c to 1Il'lJoe d'II11~" ,'" ! '.'t' ~d,UIIcII110 the'e Itulcs and ItcguJalions II it
d,'CTI1s nCCfl!lII)' ,If" J ,'!
RNidl'1lh ~'iII1'W:' "dvi.,~! 1'( ,Wi" dl.1rW'" t1lil1Y no) l'I' " ;,qd....ftiwf I . \ I
kl..,!.oT 13"1,(, ",.' ;'-,,1, /1l:.F/SJ~<. UJI "'-C; fj-I"YJ'
I 11,\ n; Kf:,\O nu~ mlU:t;()),"i(; /l\'U,~ ,\ I,' (I' .l'J. \lHI~S Arm IIF:REIIY AGREE 1'0
nt:COME ,\ R.:~IllI::-; J' C()N~"NlfNG '10 S,\W: ~l U;S A"'V IU,GUIA'f10NS. I DAVE
Rf.n;I~J A C})I'\' 01' TilE CON 111.\<'" . /'Z"..., V
Dille __ :::/fI1~ j...$':.._H__" _ M:'I":z:..:...&~,;~:;:?-;.-:::?::?,~,;, .
MI' '('..~,L:~Y~ ~___
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BRIC W. MCKBNZIB and
KATHY L. MCKBNZIB,
P lainti ff s
IN THB COURT OF COMMON PLBAS OF
CUMBBRLAND COUNTY, PBNNSYLVANfA
v.
NO. 96-
CIVIL TBRM
BARL P. GARMAN,
Defendant
M.f'lQAU'LJ.li.._~fQR1.J)F...P.lll.Tl.QN
IQR. u.U\VIl..TO. nocno .IN fORHA.I'^IJPIlRU
1. We are the plaintiffs in the above matter and because of
our financial condition we are unable to pay the fees and costs
of prosecuting, defending, or appealing the action or proceeding.
2. We are unable to obtain funds from anyone, including our
family and associates, to pay the costs of litigation,
3. We represent that the information below relating to our
ability to pay the fees and costs is true and correct.
(II) Name; -Kl!t;J:Iy.Ju_.Mc;.~QnZ_iJL___~
Address: .2e~.J)J!\rI!a.Prj,'t9___ ____.____m__.
lIoU j,ngSpr ingl!LPA .11_09L_____
Social SecIlrity Number: 1n-~4-:05n.___.__...______
Name; Br iC;. W, Mckel);il ie _.____.__,
Address; 514 Pack Drive.
BoiHng springs, PA ....170.0,7,._..__._..
Social Security Number: ~03-:.54::'O~88_____,
(b) If you are presently employed, state
Bmployer: .I<at.hy " !\H "mer.ican ...R!!l!l~.\!rAn,L___
Address; Carlisle .Pike, J;:arU.!!.l.!!.,.PA_llQ.l.:i_____
Salary or wages per month ;'644 /.0.0,__________,
Type of work; W.aHrells
If YQU are presently unemployed, state
Date of last employment :jric.-:_~/94.._.
Salary or wages per month: _'l;U,.~_I.2..Q_._________~
Type of work: Lab.o.rer _______,_
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