HomeMy WebLinkAbout00-00664
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HELEN V. WARRICK,
Plaintiff
IN THE COURT OF COMMON PLt<;AS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2000-664 CIvtt tt<;1tM
July 17,2000
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JOllN,LUCIDON and
ROSA LUCIDON,
Defendants
NOTICE OF ARBITRATION IlEAtUNG
As Chairman of the Board of Arbitrators appointed in the above captioned case, I
have fixed Tuesday, August 8, 2000, at I :00 o'clock, P. M., in the 5th Floor Hearing Room
of the New Courthouse, Carlisle, Pennsylvania, as the time and place for the hearing.
cc: David A. Greene, Esquire
28 South Pitt Street
Carlisle, P A 17013
Arbitrator
Debra Denison Cantor, Esquire
2331 Market Street
camp Hill, P A 17011
Arbitrator
Matthew J. Eshelman, Esquire
2108 Market Street
Camp Hill, P A 17011
Attorney for Plaintiff
10M tl1cidon
Rosa Lucidon
1910 Spring Road
Carlisle, P A 17013
Defendants
Office of Court Administrator
1 Court House Square
Carlisle, l'A 17013
Bulletin Board
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HELEN V. WARRICK,
Plaintiff
.
.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
vs.
: No. ,~U()() - /PIP 'I ~ ,ku...
.
.
JOHN LUCIDON and
ROSA LUCIDON,
Defendants
: CIVIL ACTION - AT LAW
.
.
PREVIOUSLY ASSIGNED TO: N/A
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 the Complaint and Notice are served,
by entering a written appearance 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 requested by the :
Plaintiff.
You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT
ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPBONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET
LEGAL HELP.
Court Administrator
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
(717) 240-6200
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HELEN V. WARRICK,
Plaintiff
:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. ~ M(} ~ (;{pLj &..tu;t tun...
:
vs.
.
.
.
.
JOHN LUCIDON and
ROSA LUCIDON,
Defendants
CIVIL ACTION - AT LAW
.
.
: PREVIOUSLY ASSIGNED TO: N/A
COMPLAINT
AND NOW, comes the Plaintiff, Helen V. Warrick, through her
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lattorneys, the Law offices of Patrick F. Lauer, Jr., in the person
of Matthew J. Eshelman, brings the following complaint in response
to a Notice of Appeal from a District Justice judgment and in
support thereof respectfully avers the following:
1. The Plaintiff, Helen V. Warrick, is an adult individual,
who currently resides at 346 East North Street, Carlisle,
Cumberland County, Pennsylvania 17013 (hereinafter also referred to
as the Tenant).
2. The Defendants are John and Rosa Lucidon, adult
individuals who currently reside at 1910 Spring Road, Carlisle,
Cumberland County, Pennsylvania 17013 (hereinafter also referred to
as Landlord).
3. On or about December 1, 1998, the parties entered into a
residential lease agreement, a copy of which is attached hereto as
Exhibit "A" and incorporated herein by reference.
4. Tenant Warrick was to rent an unattached dwelling unit
located on the rear of the Landlords' property at 1910 Spring Road,
Carlisle.
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5. The Landlords resided at and continue to reside at the
unattached dwelling unit of the front of the lot at 1910 Spring
Road.
6. On December 1, 1998, Tenant Warrick specifically
requested of the Defendant, Rosa Lucidon that she would like to
have receipts for the rent, water, sewer and trash payments.
7. In the first week of January 1999, Tenant Warrick noticed
there was water coming through the ceiling.
8. Tenant Warrick notified Landlord of the leaks in the
roof.
9. The parties verbally agreed to have Tenant's. boyfriend
Sam, repair the entire roof so long as Landlord purchased the
necessary materials.
10. The first week of April, Tenant Warrick asked Landlord
John Lucidon if she could have a dog.
11. Landlord John Lucidon indicated, "yes."
12. Tenant Warrick requested a written permission letter
regarding the dog.
13. Tenant Warrick likewise repeated her request for written
receipts for rent, water and sewer.
14. Defendant John Lucidon indicated he would provide
receipts, but nonetheless failed to do so.
15. April 25, 1999, Tenant Warrick informed the Landlord that
the roof was leaking again, and that the leak had damaged a box of
clothing.
16. Landlords still did not provide materials to repair the
roof.
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17. Landlords still did not repair the roof.
18. August 11, 1999, Ms. Warrick became suspicious when she
noticed that her electric bill was unusually high for her usage.
19. On August 11, 1999, Ms. Warrick turned off a switch in
her breaker box labelled "pump."
20. On August 12, 1999, Tenant returned from a concert and
noticed that the breaker in her residence had been returned to the
"ON" position.
21. On August 13, 1999, Tenant called a PP&L investigator.
22. The investigator confirmed that the Tenant had been
paying for the hot-tub, lights and the outside refrigerator on the
Landlords' deck.
23. The hot-tub was installed by Landlord and therefore,
Landlord knew or should have known that they were charging the
electric for their appliances to Ms. Warrick.
24. On August 16, Tenant Warrick turned off the breaker and
confronted Landlord regarding having been charged for the !
Landlords' own electric usage.
25. August 17, 1999, Tenant checked the breaker box only to
find that Landlord had turned the switch back on yet again.
26. On August 19, 1999, Tenant came home from work and
checked the breaker box and found that the switch for the breaker
box had been turned on yet again.
27. September 1, 1999, Defendant John Lucidon demanded to
know when Tenant Warrick was moving out.
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28. On September 1, 1999, Defendant John Lucidon indicated to
Ms. Warrick that he had brought people through the apartment to see
if they were interested in renting it.
29. September 5, 1999, the roof leaked a third time, damaging
another box of clothing.
30. Tenant's boyfriend Sam informed
telephone that the roof was leaking again.
yelling causing him to hang-up.
31. Defendant John Lucidon came over to the Tenant's home and
Landlord by way of
The Defendant started
continued yelling at Tenant and Sam, now at the doorway.
32. September 5, 1999, Landlord specifically informed the
Tenant in the presence of several witnesses that she must "get the
hell out!"
33. The remainder of the month of September, Landlord engaged
in a course of conduct calculated to further alarm, annoy and
harass Tenant Warrick.
34. Pursuant to the Landlords' demand, Tenant Warrick removed
herself from the property on or about September 18, 1999.
35. Tenant Warrick had paid to the Defendants a security
deposit in the amount of $600.00.
36. Tenant Warrick vacated the premises in better
condition than they were at the time when she moved in, reasonable
wear and tear excepted.
37. Despite demand, the Landlords failed to reimburse Ms.
Warrick for the twelve remaining days in September 1998.
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38. Ms. Warrick had pre-paid the trash collection for the
entire year; a balance from September 18th would total $32.41.
39. Tenant Warrick subsequently learned that the Defendants
were accepting payments for the water bill in a timely fashion, but
not making payments to the Water Company on time.
40. The Defendants were improperly passing along the late
fees for the water bill to Tenant Warrick in the amount of $15.00.
41. To date, Tenant Warrick has incurred court costs in the
amount of $80.65.
WHEREFORE, demand is hereby made for judgment in an amount
less than $20,000.00 for invasion of privacy; wrongful ejectment;
anticipatory repudiation of the residential lease agreement;
.failure to return the $600.00 security deposit; failure to return
the $32.00 over-payment of electric billings relating to the
electric usage of related accessories; failure to reimburse the
$240.00 in September rent; failure to return the $32.41 over-
payment fqr trash; failure to reimburse the $15.00 overpayment for
water; for the double security deposit pursuant to the Landlord
Tenant Act; plus costs and interest; and any such other relief as
the Court should deem appropriate.
itted,
Date, g~~
Matthew J. Eshelman, Esquire
Law Office of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID* 72655 Tel~ (717) 763-1800
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HELEN V. WARRICK, . IN THE COURT OF COMMON PLEAS
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
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vs. . No.
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.
.
JOHN LUCIDON and : CIVIL ACTION - AT LAW
ROSA LUCIDON, :
Defendants . PREVIOUSLY ASSIGNED TO: N/A
.
VERIFICATION
I, Helen V. Warrick, state that I am the Plaintiff in the
above-captioned case and that the facts set forth in the above
COMPLAINT are true and correct to the best of my knowledge,
information and belief. I realize that false statements herein are
subject to the penalties for unsworn falsification to authorities
under 18 Pa C.S. 4904.
7Uvl ()~
Helen V. Warrick
Dated:
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RBSIDBII'1'IAL 1'.1l!1lA Ac.Jl...-aarr
Th1a agreement 1s lllade the
Jo~J ~ QoSPl LudeoJ
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\ I.\- +e.. 'day of !to<J~~ '\9~€:.. between
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as LANDLORD and . \\.!Ele0 W~Q.\cJ.i;- Imp fAP\Ilj_
.. TENANT.
By this agreement the LANDLORD 1uses to the TENANT the housel apartment
at \'110. Srf-t;J<o l2.t> ('tt(t-(L':(~) ~use...6~(lC~i (?l\ 1'7G\~ . to be
, .
used as a residence and for no other purpose for the term of One year
beginning the first day ot ~, One 'l'howoand Nine Hundred and
.NQJrl71 c\CoHr _" (19.18.> and ending the~ last. daY' of J h h1 ,
One 'l'housand Nine Hundred and Jj"l..!~::t4 lkaJE (19.l..'('ZJ at the rent of
~ .
:;?e.tJ'€A ~(.~ -n..:c ~~ ($..Z dO(), Y2 Dollars per term. paYable
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in advance monthly on the first day of each month 1n equal monthly
installments of - 0\ ',(: ~~ :($_ ~Otl ~ J . Dollars
to J~~.u ~ LGd..DorJ -:JfL / \910 SfRl1U{,12..D. ~ & 1101'3 at
~ ~PrO;s.C~i-\ A- or ~y other place which the
~NmLORD may designate. Rental payment for a partial month of occupancy
..,)ay be prorated as ~O~l.oy:;:
Days at $_
per day frQlll
to
Amount Due _
.
.
The LANDL~ acknowledges receipt frQlll the TENANT of _ s; x ~reJ. ;.J
($ fooD, ) Dollars as a aecud ty depos1 t to be held by the LANDLORD
for the rental tera in accordance with the provisions of the Pennsylvania
Landlord Tenant Act of 1951 as amended. NO PART OF THE SECURITY DEPOSIT
IS 'l'O BE CONSIDERED AS THi LAST RENT PAYMENT DUB lJNDER THE TERMS OF 'l'HIS
LEASE. . '
Rent shall be considered overdue if not received hy the day specified
above. and if the overdue continues for five days or IDOr't th~ TENANT
agrees to pay a lata charge of $ 10% ot monthlY rent .. _'00,- .
A check that is retuned without paymant by the bank will not be
considered payment for the rent. and all coata of that check will ~ the
responsibility of the ~~T.
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TENANT INITIALS , DATE
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Page 2 of 5
At the end of the term stated in this lease, either the LANDLORD OR THE
TENANT may terminate this lease by giving the other party wri tten notice
of at least thirtv days. Without such notice this lease shall continue
under the same terms and conditions in force at the end of the term for
a further period of thirtv davs an so on from month to month until
terminated by either party giving the other thirtv davs written notice.
If the TENANT moves with the consent of his LANDLORD prior to the
termination date set forth in this agreement.. or any renewal thereof, the
TENANT must give one JIIOJ1th'a written notice in advance, all rent must be
paid prior to the moving date, and one months additional rent must'
be paid at the time of giving notice of the early termination.
If the rent is not paid when due, or in case of a breach or evasion or an
attempt to break or evade any part of the agreement, or if the TENANT
engages in illegal activities on the premises, the entire rent for the
fUll term of the lease shall become due and payable, and the LANDLORD may
terminate the lease and repossess the premises without any. notice
wha~soever. '
If the LANDLORD accepts any of the rent at any time after it has become
due, after default has been made iJi the payment of the rent, or fails to
enforce any of the rights of the LANDLORD or any of the penalties
included, the LANDLORD is not waiving the right to enforce those rights
or penal ties at any other time. Attempts to collect the rent by cne
mElans does not waive the right to collect it by any other means.
It the TENANT becomes insolvent, makes an assignment for the benefit of
creditors, commits any act of bankruptcy, files a voluntary petition in
bankruptcy; or.~f a jud~t is entered or an involuntary petition of
bankruptcy is filed against the TENANT, all the rent for the full term of
the lease shall become due and collectable immediately.
Tr.NAllT has nc right to assign or sublease the premise$~,
If the LANDLORD gives,one month's written notice prior to the end of any
term of his intention to change the terms and conditions of the lease and
the TENANT remains in possession of the property after the effective date
of this notice, the TENANT will be considered as a TENANT under the tems
and conditions of the notice. LANDLORD may make adjustments covering any
price increases in the cost of utilities or services .upon giving the
TENANT one month's notice. .
If the TENANT vacates the premises leaving behind and abandoning any
personal property after a reasonable opportunity to remove it, LANDLORD
is authorized and empowered to sell and dispose of this property in any
manner whatsoever. LANDLORD has no liability or responsibility to
account to the TENANT for the disposal of this property.
If the LANDLORD or the TENANT are members of the Armed Forces of their
respective countries on active duty and the LANDLORD receives permanent
change of station orders to return to, or the TENANT receives permanent
change of station orders to depart from, the area where the premises are
located, or if either party is relieved from active duty, or if the
-9--~tL;HIT1ALS ,/1 tJ 15
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TENANT INITIALS & DATE
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Page 3 of 5
TENANT is assigned governaant quarters, either party may terminate this
lease upon giving at least one month's written DOtice to the other party
with a copy of the official orders warranting such termination attached
to the notice. '
TENANT w11l return all keys to the LANDLORD upon the end of the term of
the lease. A charge of $25.00 w11l be made if 1:be keys are D01: returned.
TENANT shall not install any new or additional lOCks without LANDLORD's
permission.
LANDLORD reserves the right to enter upon the premises at reasonable
times for the purpose of making necessary inspection, making repairs, or
showing the premises to prospective purchasers or tenants, and to display
"for rent" or "for sal,." ligna. .
.
The premises may be occupied and "....
following peraona only;
\
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as a 1>>raonal residence by the
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Ut11ity chargea are to be paid: l14U:Vice8 and appliancf's provided as
follows:
LANDLORD TENANT
HEATING to be paid by; ')(
HEATING OF WATER 1:0 be paid b-i': "')<
. ')(
ELECTRICITY to be pai'd by:
GAS to be paid by; .
\IIATER & SEWER to be paid ];)1"; . X
TRASH REMOVAL to be paid by; X
. . .
LAWN CARE provided by:
SNOW REMOVAL provided by:
STOVE provided by: ." )(
'b .
REFRIGERATOR provided by:
WASHER provided by: ')(
.
DRYER provided by: - 'X
WASHER CONNECTION: X
DRYER CONNECTION: "/..
DEHUMIDIFIER provided by: "X
AIR CONDITIONER prOVided ];)1": ';(
~~C{ If If }1fJ
DLORD INITIAL 'DATE
;:;lLv,1j~ /tI,~lh$..
TENANT INITIALS & DATE
,
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.
Page 4 of 5
TENANT agrees to abide by MUnicipal Regulations for Trash & Recycling.
LANDLORD shall have the right to s1:op the services of any utilities,
temporarily, in the event of a malfunction or to facilitate alterations
and/or repairs.
If the premises are totally destroyed or damaged by fire, the lease ends
on the day the TENANT IIIOves out. If the damage is partial and
repairable, the TENANT may choose to stay if the damages can be repaired
within a reasonable time.
TEN~T shall not use any method of heating other than that supplied I:ly
the LANDLORD without LANDLORD'S permission.
TEN~T will pay the cost of any or all repairs of any kind whatsoever
occurring after the beginning of this lease where the individual cost of
each repair is less than $ 100 ~ . '.
The TENANT rents the premises in their existing .as is. condition. The
TENANT agrees to keep the premises in a good state of preservation and
cleanliness. No apartment hallways or stairways shall be used for any
purpose other than entrance and exit. Common areas will not be used for
storage. TENANT shall not permit objects to be swept. thrown. shaken or
hung from windows, doors or I:lalconies. TENANT. shall not use plumbing or
electrical equipment for any purpose other than those for which they were
constructed. Any damages to all plumbing equipment caused by misuse or
negligence will be repaired at the expense oJ: the TENANT. Floors will be
properly maintained aIlS! any rugs furnished by the LANDLORD will be
cleaned upon departure. ~ Washers, m~~~.pshWaSherS may be used only
with the LANDLORD'S permission.j Q~ ~ . ,
Window shades, curtains and curtain ds may be installed only with the
LANDLORD I S permission. On paneled walls, nails for hanging pictures may
onll be placed in the grooves of: the- paneling. No picture hooks, na:[lsi'
etc. larger than the nail for a 10 lb. picture hook may I:le installed
without the express pardission of the LANDLORD.
No dogs, cats, pets or animals may be kept on the premises without the
written permission of the LANDLORD.
.
No boats and no motor vehicles other than a licensed private passenger
automobile may be parked on the premises without the permission of the
LANDLORD.
TENANT shall not make or allow disturbing noise to be made within the
premises that annoys other tenants or neighbors or inti!rferes with their
right of quiet enjoyment. No instruments that create or reproduce sounds
that may be heard be~ond the confines of the premises shall be played
between the hours of 10:00 P.M. and 8:00 A.M.
~' 1114 ull~ %
~RO INITlALS , DAT~
1j~v.1J~
TENANT !NlTIALS &
t{/N}1r
DATE
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Page 5 of 5
TENANTS shall not do or allow any activities injurious to the premises,
or the other tenants, or which' will adversely aff.ect the LANDLORD's'
insurance on the property. LANDLORD shall not be lial:lle for property
damage or personal injury on his property unless the damage or injury
results directly from the LANDLOan's gross negligence.
When two or more tenant's are signing this agreement, it is understood
that if one or more of the tenant's move out anytime during the term of
the lease, the remaining tenant's or tenant will assume the agreement
till the expiration date. '
FOR ANY RENT REMAINING DUE AND UlfP,aID FOR 15 DAYS OR MORE:
A landlord tenant co.plaint will.. be filed with the District Justice to
recover the balance of rent due plus. costs.
NO ADDITIONAL NOTICE WILL BE REQUIRED TO BE GIVEN.
THIS AGREEMENT IS A BINDING CONTRACT.
.
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PATRICK F. LAUER, JR.
Attorney at Law
2108 Market Street
Aztec Building
Camp Hill, PA 17011
(717) 763-1800
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HELEN V. WARRICK,
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
:
vs.
:
: No. 2000-664 Civil Term
JOHN LUCIDON and
ROSA LUCIDON,
:
: CIVIL ACTION
AT LAW
:
Defendants :
ANSW'6({ TO &>JI1IjJL-A-I~T
NOTICE TO OBJECTIONS TO THE CLAIMS
NOW comes the Defendants and presents this responsive
pleading to Plaintiff's complaint, representing as follows:
1. Plaintiff Helen V. Warrick who currently resides at
346 East North Street, Carlisle, Cumberland County, PA 17013,
also may be referred to as Tenant.
2. The Defendants, John and Rosa Lucidon, currently residing
at 1910 Spring Road Front, Carlisle, Cumberland County, PA 17013,
also referred to as Landlord.
3. On November 13,1998, Plaintiff Helen Warrick came to
look at house for rent after speaking to Landlord Rosa Lucidon at
1910 Spring Road Rear, Carlisle, PA.
4. Plaintiff Helen Warrick expressed her satisfaction and
interest in renting the house.
5. Plaintiff Warrick offered to give Security deposit to
hold the rental house.
6. Landlord Rosa did not accept any money because there
were other people interested to see the place.
7. Defendant Rosa explained to Plaintiff Warrick that the
house will be ready for occupancy by December 1, 1998 and by
tomorrow, November 14,1998, Landlord will get back with Plaintiff
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Warrick after a decision has been made.
8. The next day, November 14,1998 around 6pm, Plaintiff Helen
Warrick and boyfriend named Sam and two children came to Landlord's
address after being informed to go over conditions and agreement on
the lease.
9. Defendants/Landlord John & Rosa read over the lease agreement
with Plaintiff Warrick item by item making sure everything was well
understood.
10. Plaintiff Warrick signed the lease dated Nov.14,1998, that
evening and handed Landlord John a check# 143 for $1235.00 where
$600.00 security deposit, $600.00 for the first month effective Dec.
1,1998, and $35.00 for down payment for water (minimum charge).
11. Plaintiff Warrick asked if she can start moving some items
to the house as well as setting up window blinds before Dec.1,1998.
12. Plaintiff also expressed that the house is looking good and
"just perfect and right for her family".
13. The next day, November 15,1998, Tenant and family as early
as 8am were in the driveway with a pick up truck and Tenant's car
hauling boxes inside the rented house. Several trips were made that
day, Sunday.
14. This got Landlord John & Rosa amazed as to how fast tenant
got packed and moved things inside the house so quickly.
15. So to say, Tenant Warrick and family got 2 weeks free of
charges from Nov.15-30 1998 living at 1910 Spring Road Rear wih
all utilities already hooked up previously except for the telephone.
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16. On Dec. 1,1998, Landlord John & Rosa mentioned to Tenant
Warrick that they have 30 days to make a list of anything that might
need to be fixed or overlooked so Landlord John can take care of it.
17. Tenant Warrick did not submit any list of items need to be
fixed.
18. Some time the middle of January,1999, Tenant Warrick left a
message in Landlord's answering machine that there was a leak under
the kitchen sink.
19. That same day, in the afternoon, Landlord John looked at
the said complain and called Gene Quigley, Plumber from S Bedford
st. Carlisle and replaced the kitchen faucet to a brand new one.
20. Early spring of 1999 was when Tenant Warrick told Landlord
John of a leak in the roof.
21. Tenant's boyfriend Sam offered to fix the leak since he
claims that he did roofing jobs before.
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22. Landlord John supplied Tenant's boyfriend with materials:
caulk.
23. Landlord John had an understanding with Tenant's boyfriend
that if there was still a leak after this repair, then to inform
Landlord John so other measures may be needed done.
24. Landlords have not heard any more complaints on the roof
leaking, not until September,1999.
25. In the meantime, Between February to July. landlord John &
Rosa had replaced Tenant's refrigerator two times.
26. It is therefore not true that Landlord John & Rosa Lucidon
do not take care of repairs needed in the rental house.
27. Landlord John Lucidon,Owner of his own business PARADISE
LANDSCAPING & CONSTRUCTION keeps his property clean and in order
and has his own workers doing landscape work and construction.
28. Tenant Warrick never asked Landlord John or Rosa for
permission to have a dog in the premises.
29. Tenant Warrick did not receive any written permission to
keep a dog in the premises.
30. Landlord Rosa would sit down with Tenant Warrick in tenant's
kitchen each time bills like the water/sewer and garbage bills were
due. Most often, at the end of each month.
Tenant Warrick would make payments by the 31st of the month or by
the 1st of each and adding a portion to the rent was a quarter of the
bill for water/sewer, so when it was due, quarterly at that time, it
was not too much to pay.
31. Landlord did not charge Tenant Warrick for late payments
in the water/sewer bill.
32. Landlord John & Rosa supplied Receipts to Tenant Warrick
when bills were paid.
33. Tenant Warrick discussed with Landlord John that if it
was possible to rent on a month to month after their lease will be
up on November 14.1999.
34. Landlord John said he will discuss this matter with his
wife Rosa Lucidon.
35. On or about August 16,1999, Defendant Rosa Lucidon received
a phone call from a PPL Rep. Mr. Barry Myers in reference to a complaint
from Tenant Helen Warrick.
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36. Mr. Barry visited Landlord's property that afternoon to
check Landlord's deck, see what's inside (hot tub, small portable
refrigerator)'.and where the power source was coming from.
37. Mr. Barry Myers informed Landlord Rosa that he needed to
get in touch with the owner of the property - Mr. Leon Morrison,since
Landlord have a sales agreement on the property and just recently
purchased this house six months ago, approximately November 3,1998.
36. This electrical issue with Tenant was resolved with proper
guidelines and instructions by PPL.
37. On August 31,1999, Landlord John & Rosa hired Ryan's Custom
Electric to correct the problem.
38. Tenant Warrick was informed by leaving messages in tenant's
answering machine as to what will be done, and when electrician will
come inside Tenant's house to unplug the necessary wires.
39. Tenant Warrick did not at any time confront Landlord John or
Rosa before or even after PPL rep. Mr. Barry Myers visited the property.
40. It is not true what Tenant claims in items 23,24,25,26,27,28.
41. On August 19,1999 Landlord John sits down with Tenant Warrick
and her boyfriend Sam in Tenants' living room to apologize for the
electrical problem that occurred and Landlord John offered to pay the
extra charges for several months this occurred.
42. PPL claimed that Landlord will be receiving a bill for this
calculated amount approximated for the cost of running the hot tub &
the portable refrigerator.
43. According to Mr. Barry Myers effective the day he visited our
property in 1910 Spring Rd., August 16,1999 the electric bill of Tenant
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Warrick living in 1910 Spring Rd Rear will be billed to Mr. Leon
Morrison, being the owner of the said property, until the problem
gets corrected with proper paper work signed and inspected by an
electrician, licensed in PA.
44. Landlord John & Rosa received a PPL bill for $472.88,
giving credit to Tenant Warrick.
45. Landlord John or Rosa Lucidon never demanded Tenant at
any time to move out.
46. It is also not true that Landlord John brought people to
look at the rental house while Tenant Warrick was occupying the
property on a one year lease agreement.
47. On Sept.6,1999 Sunday evening at 9:15pm, raining very
heavily, Tenant's boyfriend Sam demanded to talk to Landlord John
over the phone.
48. Sam, talking with a loud annoying voice, insisting Landlord
John to fix the leak in the roof because it is destroying a box of
clothes.
49. Landlord John repeatedly answered that he will check and fix
the problem first thing in the morning, since it is dark & raining
at this time.
50. Boyfriend Sam insisted which caused Landlord John to go over
and see the intensity of the leak.
51. Landlord John or Rosa was not allowed by Tenant to look or
even go inside the Tenant's house.
52. Tenant's boyfriend harass landlord John saying bad language
and slammed the door on Landlord's face.
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53. Landlord John Lucidon therefore proceeded to the North
Middleton Township Police station to file a complaint of harassment
by Tenant and Tenant's boyfriend named Sam.
54. Landlord John Lucidon was therefore informed by Police
Officer Thomas Kibler that this Sam, boyfriend of Tenant Helen V.
Warrick living in 1910 Spring Rd. Rear is under probation and there
fore, if any more untoward incidents occur in the premises, the
police authorities can arrest him.
55. In the several months that Tenant Warrick has been living in
this address, Landlord has seen several police officers visiting their
premises.
56. It is not true that Landlord informed Tenant at any given time
to "get the hell out."
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57. On Sept.10,1999 Landlord sent Tenant Warrick a letter in
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reference to their lease which will expire on November 14,1999.
58. Landlord Rosa attempted to get in touch with Tenant Warrick
on many occasions but Tenant Warrick either refuse to answer the phone
since Tenant has caller ID or Tenant's boyfriend Sam would talk to
Landlord Rosa and say " Helen will talk to you when she wants to and
when she feels like it."
59. After this, Landlord Rosa posted a letter addressed to Tenant
Warrick regarding proper conduct and behavior in the property and
addressed all matters concerning their lease to be discussed only by
the person who signed the lease, who is only Helen Warrick.
60. Also posted on Tenant's door was a notice to remove Sam's
dog in the property in 10 days.
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61. On the night of Sept. 1 3,1999, Monday, as Landlord John
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was coming in the driveway, around 8pm, Landlord John saw tenant's
main door wide open, lights all bright, the whole living room covered
with boxes stacked high.
62. As soon as Landlord John tried to look for Tenant Helen Warrick,
someone slammed the door. Landlord tried to knock and the door was
never opened.
63. Landlord ROsa proceeded to attempt to call Tenant by phone and
again Tenant never answered.
64. Landlord therefore proceeded and called North Middleton Police
to ask what to do on this situation. Only to be informed that Police
Authorities cannot stop any person from leaving or do anything unless
Tenant was harassing or harming someone.
65. Since Tenant had paid rent for the whole September, Landlord
Rosa did not check the rental house till after Sept.30,1999.
66. Landlord John or Rosa did not hear anything from Tenant, did
not receive any notice for Tenant's forwarding address, no keys were
returned. Landlord waited 5 days, from Oct.1-5 1999.
67. The next two weeks, Landlord Rosa Lucidon, on her days off
inspected the rental house, checked for all damages and repairs needed
caused to the house beyond normal wear and tear of the property.
68. On Oct. 21,1999 Landlord Rosa mailed a letter to Tenant Warrick
listing the repairs and damages to the property and that the $600.00
security deposit cannot be returned due to repairs needed to to bring
the rental house in the same condition as when moved in.
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69. Landlord Rosa Lucidon checked with Post Office In Carlisle
to see if Tenant Helen Warrick had a forwarding address to their
old address in 1910 Spring Rd Rear. Landlord Rosa was informed by
Post Office person to go ahead a address the letter with the old
address and they will see to it that it will Deach Tenant's new
address.
70. In the hearing last January 3, 2000 with Judge Correal,
Landlord Rosa Lucidon was given the keys to the property at 1910
Spring Rd. Rear by Judge Paula Correal.
71. After the hearing, Tenant Warrick returned black shower
curtain to Landlord Rosa.
72. Tenant Warrick never made any attempts to contact Landlord
John or Rosa Lucidon since Tenant left and vaccated the premises at
1910 Spring Rd. Rear, Carlisle,PA.
73. Tenant violated the lease agreement in not informing Landlord
of her moving out.
74. Tenant violated the lease agreement in not informing landlord
of having a dog in the premises. Dog was kept inside at most times,
thus, caused alot of stains in the carpet.
75. Tenant also violated the lease agreement in not surrendering
the keys to the property prior to their leave.
76. The security deposit of $600.00 cannot be returned to Tenant
Helen Warrick because based on the TENANT-LANDLORD HANDBOOK page 36
paragraph 3, the tenant must give the Landlord her forwarding address
in writing at or before the time the tenant actually moves out.
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77. Also in reference to the security deposit, Landlord sent
Tenant Warrick a list of repairs, and damages within 30 days from
the time tenant moved out. But since Landlord was not informed of
date tenant moved out, Tenant paid Sept.'s rent therefore Landlord
started counting from Oct. 1,1999 since no more rent money was received
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nor did Landlord hear anything from Tenant Warrick.
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78. It was clarified in the hearing last Jan.3,2000 with Judge
Correal that no money will be paid to Tenant for electric billing of
overpayment since Landlord was shouldered to pay $472.88 and since
August 16, Tenant Warrick was not billed for her electrical usage until
even after she already moved out.
79. Also discussed in January's hearing the reason that no trash
money can be re-embersed back to Tenant because according to Mr.Dennis
Brehm, Code Enforcement Officer in North MIddleton Township, Landlord
has to register every tenant in the Township. And if one year isthe
lease agreement, therefore, the trash service will bill for that'whole
year. And Even if Tenant leaves, Landlord will continue to pay the fee
for trash. Unless indicated that tenant is on a month to month agreement.
80. In addition to this Landlord John and Rosa Lucidon have
numerous insights to prove that Tenant Helen Warrick violated rules in
the lease agreement signed by Tenant last November 14,1998.
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VERIFICATION
The foregoing averments of facts are true and
correct to the best of my knowledge, information and
belief. I understand that false statements made herein
are subject to the penalties of 18 Pa. C.S.A. Section
4094, relating to unsworn falsification to authorities.
~~Jx, L~ l't.
JOHN M. LUCIDON,JR.
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ROSA LUCIDON
March 24, 2000
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PENNSYLVANiA
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LEASE AGREEMENT
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This agreement 1. made the 14 ~ day of .t!OU~~ . t9 ~€:.. between
-..kl-\-J. ~ ~5Pl Ll.lci~r0 aa LANDLORD and _ \-\teleJ W~1C-1c..l<:- ItNp' ~AI'\~k')_
a. TENANT.
By this agreement the LANDLORD lease. to the TENANT the house/ apartlllent
at \<1 \0 , spe.10<o R-t> (~e~':C~) ~use..Cm1.~1 ~'\ 1'7GI~ . to be
, ,
used as a residence and for no other purpose for the term of One year
beginning the ft rat day of ~, One Thowoand Nine Hundred and
Jl~iJ~j( E'tCoHr _' (19.1a) mid ending t~ last. day' of _pJj }ti1 ' ,.
One Thousand Nine Hundred and ~lll..!...::t4 0lUE (19..l... C( '{) at the rent of
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-?e..ueA ~,..!~ ~ l-k-.~ ($....4.10(), rD. Dollars per term, payable
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in advance monthly on the first day of each month in equal monthly
installments oi . - 0' "'. ~~ .'($_ <Oat ~ J '. Dollars
'Co Jt'l~.0 }--\. LGdJID,.YJ-lL / 1<1(0 SRU~Q.(). ~ ~ n~(3at
~ 'AOPrcg.s..(Jcnrvt;t.\ Jl.. or ~y other place which the
~NIDLORD may designate. Rental payaent for a partial month of occupancy
~ay be prorated as ~0~~OY2:
Days at $_
per day from
AlIlaunt Due _
to
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The LAND~ acknowledges receipt from the TENANT of ~ So ~ X ~r~ .J
(S ~() , ) Dollars as a security deposit to he held by the LANDLORD
for the rental term in accordance with the provisions of the pennsylvania
Landlord Tenant Act of 1951 as amended. NO PART OF 'rHE SECURITY DEPOSIT
IS TO BE CONSIDERED AS THi LAST RENT PAYMENT DUE mmaR THE ~ OF THIS
LEASE.
Rent shall he considered overdue if not received by the day, specified
above, and if the overdue continues for five days or mor'l tJ:1~ TENANT
agrees to pay a late charge of $ 10% of monthlY rent .. _"'0,- .
A check that ia returned without paymant by the bank will not be
considered payment for the rent, and all costa of that check will ~ the
responsibility of the NT.
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TENANT INITIALS & DATE
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LANDLORD INITIALS , DATE
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Page 2'of 5'
e
"for
an so on from month to month until
er party giving the other thirty davs written notice.
If the TENANT moves with the consent of his LANDLORD prior to the
termination date set forth in this agreementr- or any renewal thereof, the
TENANT must give one month 's written notice in advance, all rent must be
paid prior to the moving date, and one months additional rent must'
be paid at the time of giving notice of the early termination.
If the rent is not paid when due, or in case of a breach or evasion or an
attempt to break or evade any part of the agreement, or if the TENANT
engages in illegal activities on the premises, the entire rent for the
full term of the lease shall become due and payable, and the LANDLORD may
terminate the lease and repossess the premises without any. notice
wha"!:soever. .
If the LANDLORD accepts any of the rent at any time after it has become
due, after default has been IlIade in the payment of the rent, or fails to
enforce any of the rights of the LANDLORD or any of the penal ties
included, the LANDLORD is not waiving the right to enforce those rights
or penalties at any other time. Attempts to collect the rent by one
means does not waive the right to collect it by ilIDY other means.
If the TENANT becomes insolvent, makes an assignment for the benefit of
creditors, commits any act of bankruptcy, files a voluntary petition in
I:lankruptcy; or. 'if a judgment is entered or an involuntary petition of
I:lankruptcy is filed against the TENANT, all the rent for the full term of
the lease shall become due and collectable immediately.
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TENAllT has nc right to assign or sublease the premise$~.
If the LANDLORD gives,one month's written notice prior to the end of any
term of his intention to change the terms and conditions of the lease and
the TENANT remains in possession of the property after theeffeqti ve date
of this notice, the TENANT will be considered as a TENANT under the terms
and conditions of the notice. LANDLORD may make adjustments covering any
price increases in the cost of utilities or services .upon giving the
TENANT one month's notice.
:tf the TENANT vacates the premises leaving behind and abandoning any
personal property after a reasonable opportunity to remove it, LANDLORD
is authorized and empowered to sell and dispose of this property in any
llIam1er whatsoever. LANDLORD has no liability or responsibility to
account to the TENANT for the disposal of this property.
If the LANDLORD or the TENANT are members of the Armed Forces of their
respective countries on active duty and the LANDLORD receives permanent
change of station orders to return to, or the TENANT receives permanent
change of station orders to depart from, the area where the premises are.
located, or if either party is relieved from active duty, or if the
S}.-~L;Nlt1ALS .u L{~ q~
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TENANT INITIALS &
II kL(!~t
DATE
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TENANT is aSsigned governaant quarters, either party may terminate this
lease upon giving at leaat one month'. written DOtice to the other party
with a copy of the official order. warranting such termination attached
to the notice. ,.
=u~.~......,~"",;,"r'~~a'1z1~1I"i!"'t!'D,",~i!'i~1t!;!!...~~
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L". t~T 1"I~""*~u.J"~~{'!JA11i,,'.','i~Q"tlmJir-"m1lt~'^~"'l!lF..III"-e&5J'ft,~,r--~lre
."",.l'....._. !...... ,.,.."''\t'l'J..''"Pd........e8, ':"f"'~I<:4Elt..a_ea_T ,h.e........'..gn:" IIIl!.kf~'.~~r
~~'"'~Pam4.~~W'''Pl!I*!~'''...........4eQants, ~~y
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The premises may be occupied and ......
following persona only:
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as a DAraonal residence by the
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Utility charges are to be paid: 88rVicaa and app11ancf's provided as
follows:
LANDLORD TENANT
HEATING to ,be paid by: )<
HEATI~G OF WATER to be paid by: "')<
. ')(
ELECTRICITY, to be pai'd by:
GAS to be paid I:ly:
\IIATER & SEW~ to be paid by: . X
TRASH REMOV",L to be paid by: X
, .." .
LAWN CARE provided I:ly:
SNOW REMOVAL provided by:
STOVE provided by: . 'I<
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REFRIGERATOR provided l)y:
WASHER provided by: ')(
. . 'X
DRYER provided by: .
WASHER CONNECTION: X
DRYER CONNECTION: "/..
DEHUMIDIFIER provided by: "X
AIR CONDITIONER provided by:" ';(
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DLORD INITIAL 'DATE
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TENANT INITIALS & DATE
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'1IfillM'N'1l,"apeess"'etf'''~'''_'"~~,B@SI',Jil1l.LliUl.,~"'',~:'',;&";dI_", ll!'!lfft~
LANDLORD shall have the right to stop the services of any utilities,
temporarily, in the event of a malfunction or to facilitate alterations
and/or repairs,
If the premises are totally destroyed or damaged by fire, the lease ends
on the day the TENANT IIIOves au1:. If the damage is partial and
repairal:lle, the TENANT may choose to stay if the damages can be repaired
within a reasonal:lle time.
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TENANT shall not use any method of heating other than that supplied by
the LANDLORD without LANDLORD'S permission.
TENANT will pay the cost of any or all repairs of any kind whatsoever
occurring after the beginning of this lease where the individual cost of
each repair is less than $ 100~ . '.
.:l:1:1e .!Mfi',.nreft'N,".~8'P!'emRi'S""~6-~... '....8lb'fl9...,!'8B"~~. ~
1~.i'.~l!@!! C....~__..~l._ J111~!S.a._ .1_ .a.. ~.s._.4 _CoALe. Ill' 'ile4__ .~H..... ~hu
...,---'.i.....s. No apartment hallways or stairways shall be used for any
purpose other than entrance and exit. COIIDDon areas will not be used for
storage. TENANT shall not permit Objects to be swept, thrown, shaken or
hung from windows. doors or balConies. TENANT shall not use plumbing or
electrical equipment for any purpose other than those for which they were
constructed. k':l!l....::'IagU....."..w'J!I'Pr':'-: ~~~ A h.. -....1____ Sir
.1=..!!:._ee"JIQJJ..~mBi1l;r"d..a;t",:Mt: '..-- - >r:~'"'~ne 'J:~'l'. Floors will be
properly mainta.ined ans,\ any :di!JP ....-i ..hAd eo" mr ",....._~iJlII1...&1\f;.,',.,.l-...'~
~-""'~aJi,t..,w;a.. \ Washers,'" , . d shwashers may be used only
with the LANDLORD'S permission.J
Window shades, curtains and curtain ds may be installed only with the
LANDLORO's permission. On paneled walls, nails for hanging pictures may
onl:f be placed in the grooves of. the. paneling. No picture hooks, nai"ls.;'"
etc. larger than the nail for a 10 ll:l. picture hook may I:le installed
without the express perdission of the LANDLORD.
ll;i :s~.:,,~.....~~,...... lU,_,...'titem'P.........l_"w~~..,f,!ilme
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No boats and no motor vehicles other than a licensed private passenger
automobile may be parked on the premises without the permission of the
LANDLORO.
TENANT shall not make or allow disturbing noise to be made within the
premises that annoys other tenants or neighbors or interferes with their
right 'of quiet enjoyment. ~o instruments that creat~ or reproduce sounds
that may be heard beyond the confines of the premises shall be played
between the hours of 10:00 P.M. and 8:00 A.M.
,r 4'~ 11 \\'f 9~
ORD INITIALS & DATE
1j~01)~
TENANT INITIALS &
,liNker
DATE
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Page 5 of 5
TENANTS shall not do or allow any activities injurious to the premises,
or the other tenants, or which will adversely af:fect the LANDLORD's'
insurance on the property. LANDLORD shalL not be lial:lle for propexty
damage or personal injury on his property unless the damage or injury
results directly from the LANDLO~'s gross negligence.
When two or more tenant's are signing this agreement, it is understood
that if one or more of the tenant's move out anytime during the term of
the lease, the remaining tenant's or tenant will assume the agreement
till the expiration date. '
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FOR ANY RENT REMAINING DUB AND UNP~ID FOR IS DAYS OR MORE:
A landlord tenant COIIPlaint will be filed with the District Justice to
recover the balance of rent due plus costs. .
NO ADDITIONAL NOTICE WILL BE REQUIRED TO BE GIVEN.
THIS AGREEMENT IS A BINDING CONTRACT.
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TENANT.
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POLICE REPORT - Dated Sept.6 1999
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#.99-C-02562
COMPLAINT REPORT
Page No. 1
11/18/1999
COMPLAINT NUMBER -> 99-002562
Received by: THOMAS KIBLER
Date/Time received: 09/06/1999 @ 21:40 How received: STATION WALK ON
Time dispatched: 21:40
Time arrived:
Time cleared: 21:48
COMPLAINANT -> JOHN LUCIDON
Address: 1910 SPRING RD.
City: CARLISLE State: PA Zip: 17013
Phone: (717) 245-2099
TYPE OF COMPLAINT -> HARASSMENT
Nature of
complaint
LANDLORD-TENNANT DISPUTB THAT ESCALATED INTO HARASSMENT. A
SAM CLARK (TENNANT) HAS BECOME DISGRUNTLED WITH THE LANDLORD
OVER SOME ISSUES AND HAS BEGUN TO VERBALLY ASSAULT COMPL.
LUCIDON WANTED THIS ON RECORD IN CASE OF ADDTIONAL INCIDENTS
How handled: Officer visit
Location code: ZONE3 Location dispatched: 1910 SPRING RD.
Officer dispatched: THOMAS KIBLER
TIME ANALYSIS
.
Queue time
Travel time
Response time
Action time
<time
<time
<time
<time
received to dispatched> ~
dispatched to arrived> ~
received to arrived> ~
arrived to cleared> =
o minutes
o minutes
o minutes
o minutes
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NORTH MIDDLETON TOWNSHIP
RENTAL PROPERTY REGISTRATION FORM
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FORM RP-0992
lJORTH HIDDLETOlJ TODSHIP
"STATUS OF OCCUPANCY REPORT"
RENTAL PROPERTY REGISTRATION FORM
OWNER
MAILING ADDRESS
TELEPHONE NUMBER
-<->
MAlJAGER OR CONTACT
PARTY
ADDRESS
TELEPHONE NUMBER
II
PER THE REQUIREMENTS OF ORDINANCE # 92-1 REGISTRY OF ALL RENTAL
PROPERTIES MUST OCCUR WITHIN 30 DAYS, CHANGE OF OCCUPANCY, OR
VACANCY TO BE REPORTED, MUST OCCUR WITHIN 15 DAYS.
RETURN TO:
lJORTH MIDDLETON TOWNSHIP
211 NORTH MIDDLETON ROAD
CARLISLE, PA. 17013
DATE RECEIVED
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LETTER TO TENANT HELEN WARRICK
Oct.21,1999 List of Repairs/damages
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October 21, 1999
To: HELEN WARRICK
1910 Spring Road Rear
Carlisle, PA 17013
This is to certify that as of October 1, 1999 the rental
property at 1910 Spring Road Rear Cprlisle, PA has been vaccated.
You had signed a lease last November 14,1998 and to expire on Nov.
14,1999. You did not give us notice as to when you will move. Also
in the lease ~greement you are suppose to give us a forwarding
address in writing and return the keys of the rental property. Because
all these have not been done, I will be filing charges against you
for breach of contract and damages to the property. Unless yoU get
in touch with me and settle this. matter I will persue this action
in court.
Below are a list of damages and repairs inspected and needed
to bring the property in the same condition as when you moved in.
Bathroom:
Rug stained &
Materials
Labor
Shower curtain
liner
shower rings
torn/rug removed & replaced
$ 131.60
120.00
(black 45.00- ~ J~, 5 ~
2.99
1.99
Kitchen: carpet stained, severe fowl odor
14 ft. by 16 ft. $ 125.00
Living Room:
,
severe pet stains & carpet damage
cleaning, SHAMPOO AND STEAM $ 175.00
uneven painting of living room
labor
Materials (paint)
hole in living room ceiling
120.00
26.91
40.00
Bedroom down:.carpet stains
shampoo, steam and deodorize 125.00
1 ceiling tile broken & repaint 75.00 ·
1 cover outlet missing 3.50
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Bedroom upstairs smaller one: one ceiling tile cracked
repair and repaint $ 35.00
Shed: Area where storage shed was placed
top soil & reseeded straw
labor & materials
Dog area outside by Spruce tree
top soil & reseeded straw
2 garden lights bent & ruined
materials 40.00 each
1 table lamp left at room downstairs
keys of rental property not returned
TOTAL repairs and damages
120.00
120.00
80.00
25.00
25.00_ ~ J.vt-c.3
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$ 1,396.99
less security 600.00
deposit
balance
NOTE:
Water & Sewer is paid from the
money you pay extra in the rent
checks that you give us. But the
last bill I paid was service from
6-8-99 to 8-19-99. So currently, you
will have a portion of water & sewer to
pay - from 8-20-99 to 9-30-99. That
amount is $ 76.50.
$ 796.99
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JOB INVOICE
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TOTAL MATERIALS
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NOTICES POSTED TO TENANT'S DOOR
-
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.
Sept. 9, 1999
To: Helen Warrick
1910 Spring Road
Carlisle, PA 17013
( Rear)
Dear Helen,
This is to inform you that your lease will be up on
November 14, 1999. We have no intentions of renewing this
lease.Therefore we expect the property to be cleaned and
vaccated by the 13th of November, 1999. This is more than
enough time for you to look around and find your place. Your
security deposit will be mailed to you after full inspection
of the property and all rents and utility bills3 cleared.
Any further questions please call me. All matters will be
dealt with me.
Sinc;re~
osaMaria Lucidon
Landlord
p;AM
10, jqqj
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-
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Sept. 9, 1999
Dear Helen,
I am not pleased with how problems have been handled
these past few weeks. I will not tolerate any acts of threats
and harassment by you or any member of your family, including
any third party in my premises. I further inform you that any
questions and problems will be directed to me and only discussed
by the person responsible for the lease. Any more untoward
incidents in my property will automatically become a police
matter.
This issue is of utmost importance to maintain a good
and sound environement to live. I expect we all handle things
in a mature level. Thank you.
Sincer~lY ~, ~
Ro aMaria O. Lucidon
I. ;:t /3 (9'17
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Sept. 9, 1999
Tenant: Helen Warrick
1910 Spring Rd. Rear
Carlisle, FA 17013
We are informing you that we are giving you ten (10)
days to clear your pets from the property. According to
our lease agreement, you have not provided us with a written
consent allowing you to have all the pets you have presently.
We see your pets posing damages to our property, inside
and outside. If the pets are not out by 10 days after this
notice, we will per sue immediate eviction proceedings.
~~
Landlord
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HELEN v. WARRICK,
Plaintiff
: IN THE COURT OF coMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2000-664 CIVIL TERM
JOHN LUCII)ON and
ROSA LUCII)ON,
Defendants
NOTICE OF ARBITRATION HEAtUNG
As Chairman of the Board of Arbitrators appointed in the above captioned case, I
have fixed Tuesday, August 8, 2000, at 1 :00 0' clock, P. M., in the 5th Floor Hearing Room
of the New Courthouse, Carlisle, Pennsylvania, as the time al1dplace for the hearing.
July 17,2000
cc: David A. Greene, Esquire
)8 South Pitt Street
/' Carlisle, PA 17013
Arbitrator
Debra benison Cl1I1tor, Esquire
2331 Market Street
Camp Hill, PA 17011
Arbitrator
Matthew J. Esheltnan, Esquire
21O~ Market Street
Camp Hill, PA 17011
Attorney for Plaintiff
John tucidon
Rosa Lucidon
1910 Spring Road
Carlisle, PA 17013
Defel1dants
Office of Court Administrator
1 Court House Square
Carlisle, PA 17013
BulIetin Board
-
"
.. "
Turo Law Offices
www.TuroLaw.com
28 South Pitt Street
Carlisle, Pennsylvania 17013
(717) 245-9688
(800) 562-9778
Fax (717) 245-2165
RON TURO, Esquire
ROBERT J. MULDERIG, Esquire
LISA M. GREASON, Esquire
DAVID A. GREENE, Esquire
FAX COVER SHEET
PLEASE DELIVER THE FOllOWING PAGES TO:
TO:
John M, Eakin. Esauire
FAX# 717-691-3281
FROM:
RE:
David A. Greene. Esauire
Arbitration
TOTAL PAGES: -L
DATE: June 29. 2000
COMMENTS: Followina are dates that I am not available for Arbitration, If vou
have anv Questions or if I can be of anv further assistance, olease do not hesitate to
contact me, July 20.21.22.26.27.28.29.30.2000 and Auaust 3. 4. 5. 6. 7.10. 13.
2000.
PLEASE CALL OUR OFFICE AT (717) 245-9688 IF YOU DID NOT RECEIVE THE
COMPLETE FAX TRANSMISSION. THANK YOU,
****************************************************************************************************
CONFIDENTIALITY NOTICE: This facsimile contains confidential information, which
may be legally privileged and which is intended only for the use of the Addressee(s)
named above, If you are not the intended recipient, or the employee or agent
responsible for delivering it to the intended recipient, you are hereby notified that any
dissemination or copying of this facsimile, or the taking of any action in reliance on the
contents of this telecopied information may be strictly prohibited, If you have received
this facsimile in error, please notify us immediately by phone and return the entire
facsimile to us via the U,S, Postal Service, Thank you,
****************************************************************************************************
,
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*************** -COMM.JOURNAL- ******************** DATE JUN-29-2000 ***** TIME 12:12 *** P.01
MODE ~ MEMORY TRANSMISSION
START=JUN-29 12:07
END=JUN-29 12:12
FILE NO.= 186
NO.
COM ABBR/NTWK STATION NAME/
TELEPHONE NO.
PAGES PRG. NO.
PROGRAM NAME
001
OK a
6913281
001/001
- TLJRO LAW OFF I CES
************************************ -LAW OFC.RON TURO- ***** -
717 245 2165- *********
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NOTICE OF JUDGMENT/TRANSCRIPT H
CIVILCASE . !
PLAINTIFF: NAME and ADDRESS 1-
IwARRICl{, HELEN V I i
346 E NORTH ST i
CARLISI.E, PA 17013 i
L ~
VS,
,
,.
COMMONWEALTH OF PENNSYLVANIA
'COUNTY OF: . CUMBERLAND
Mag. Dist. No.: . ., '
DJ.!'lai'r:le::Hon.
PAUltAc P . CORREAL
M~~~~~ST,WING;-. CO~THOUSE
.... .1 .. CoURTHOUSE SQUARE
. CARLISLE; PA
Tel.ph?", (717) 240-6.5.64. 17013-0000
DEFE..;DANT:
c. .
'LTTCIDON, JOHN, ET AL.
191:.. SPRING RD
CARLISLE, PA 17013
L
NAMe and ADDRESS
I
HE;[,EN V.WARRICK
346ENORTH ST .
CARLISLE, PA 17013
Docket No,: CV-0000556-99
Date Filed: 10/22/99
~
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THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PT,ATN'I'TFF
~ Judgment was entered for: (Name) Wl>.RRTr.lr. HRT.RN V
00 :Judgment was entered against: (Name) T,nr.TnoN, R()RA
in the amount of $
6An 6" on:
(Date of Judgmelll)
1 /n6 inn
. .
o Defendants are jointly and severally liable,
...:0 Damages will be assessed on:
(Date & Time) _
,0. Amount of Judg,ment Subject to .
... Attachment/Act 5 of 1996 $
~~.~unt of Judgment $ 600.00
Judgment Costs $__JI0.65
I1terest on Judgmert $ .00
Attorney Fees $ .00
Total $ 680.65
Post JUdgment Credits $
p ~st Judgment Costs $
============
Certified Judg::1e;n T olal $
o This case dismi~sed without prejudice.
..: D Levy is stayed for
days or D generally stayed,
.... ';DObjection 10 levy has been filed and hearing will be held:
. .Date: .
Place,
.t
__'--; District Justice
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.
Time:
.....:... ....
OF JUDGMENT BY FILING A NOTICE
PLEAS, C!VII.,pIVISION, YOU
WJTH YO!JR NOTICE OF APPEAL.
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'1/6'/ob Oat. ...____,DistrictJustice
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i <:.oMiaoi'NWEALTH O. PENNSYLVANIA
COURT O. COMMON PLEAS
NOTICE OF APPEAL
FROM
JUDICIAL DISTRICT
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. .;2.006 - i./...4 ec.>J~
NOTICE OF APPEAL
Notic;e is given th"t the' appelr.;,nt h"s filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the
date and ;in. the ca5ll' mel)tjoned below.
L t/.CJ DO j\/
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IMA(;D~tNQORO~~ -tJ /
f!4 STATE /70/3Z1PCOOE
GL5 N V.. L K ('A1J (}IV (J~!I ~ /? CKfI-
SIGNATURE OF APP8.lANT OR HIS ATTORNEY OR AGENT
~~'~
Signature of Prothonotary or Deputy
If appellant was CLAIMANT (see Pa, R.CP,JP, No.
1001(6) in action before District Justice, he MUST
FILE A COMPLAINT within twenty (20) days after
filing his NOTICE of APPEAL.
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
IThis section of form to be used ONLY when appe/fant 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 served upon appe/fee).
PRAECIPE: To Prothonotary
Enter rule upon J-/ r;- Lfi /If V r W A- R R I CI< , appellee(s). to file a complaint in this appeal
/J Name of appeIfee(s)
(Common Pleas No. :li"!.o,,- LL'f ('t",'C'ZC.olt:Jl within twenty (20) days after servi e of rule or s
RULE: To
1-16 Lc rJ v: W ItRR (Gf<. appellee(s),
Name of appeI~s)
(1) You are notified that a rule is hereby entered"upon you to file a complaint in this appeal within twenty (20) days after the dale of
service of this rule upon you by personal service or by i:e(lified or il.gislered maiL
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU,
(3) The dale of 5Ilrvice of this rule if service was by mail is:the dale of mailing. p ~ 1
Date:;:-~ ~ ,t9~ . $f L2/J~~ n:~)~
N:JPC 31:;2-84
COURT FILE TO BE FILED WITH PROTHONOTARY
:#j;@t'#1[lli'lli'~~fI~!IlOI~j~_&;lleiIp"~~~~: 1"~
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PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE F.lLED WITHIN TEN (10) DA YS AFTER liIing Ihe notice 01 appeal. Check applicable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ; ss
AFFIDA vrr: I hereby swear or affirm that I served
a copy of the Notice 01 Appeal, Common Pleas No. , upon the District Justice designated therein on
(date of so(vloe) 0 by personal service 0 by (certified) (registered) mail, sender's
receipt altached heretc, and upon the appellee, (name) , on
, 19__ 0 by personai service 0 by (certified) (registered) mail, sender's receipt attached hereto.
o and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to whom
the Ruie was addressed 011 " , 19~ 0 by personal service 0 by (certified) (registered)
meil, senders receipt attached hereto.
SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS
DAY OF ___,19__
Signature of affiant
Signature of official before whom affidavit was rrl8dG
Title of official
My commission expires on
,19--
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NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CAS~
PLAINTIFF: I\i'l,--E 2,1~ A.DDt'lESS
'wARRICK, HELEN V .,
346 E NORTH S~
CAkLISLB. PA i7013
L ~
- !"~
,..... ',,,:r-
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND
Mag. Dis\. No.:
09-2-01
OJ Name: Hon.
PAULA, P. CORREAL
Add"" EAST WING - COURTHOUSE
1 COURTHOUSE SQUARE
CARLISLE, PA
T",pho", (717) 240-6564 17013-000~
VS,
DEt':~NDAI" I t r": ,:-w' :,[I"'.'~' ,~":
lLUt"IDON ,:TOHN . ET AL.
197,1 S?RLNG iJ.D
':ARLISi,r.;, Ph ~:'u13
L
.- - .- .----. -- '---l
r)OCK8t Nv.: c..v - 0000556 - 99J
D,:.tp FL~: 10/22/99
--- -- - ,..--.-
ROSA LUCIDON
-1910 SPRING RD
CARLISLE, PA 17013
THIS IS TO NOTIFY YOU THAT:
"Judgment:
~-p:..:.AI~.::2r-::.:'_.
[i]
[i]
Judgment was entered for:
(Name)
WllRRT~K. HRT,F.1\T V
Judgment was entered against: (Name)
T,TTCTDON. ROf!lI
.,
~
(nate of ,iudg'nenl)
in the amount of $
fiRO fi'l on:
1 /Ofi /00
,
D Defendants are jointly and severally liable.
(D...... T;'l.o'
..... .'. I I:..., _n_
D
D
------
I," .1'J'lr:t eJf ...!~jdgment
,"j,j.~i.n(J',t ~(".~~;-
: :r I )' 8S't cr ,J:",-i(..}ment
i Att'jr~E.Y re0s
.1'Ot\:l1
1I'-05t Judgm8n! -: ;'edits
',-Jsl Judgment Costs
l ~::i!leti ~~dgmen~~o~1
Damages will be assessed on:
This case dismissed without prejudice.
D
D
D
AmoJnt of Judgment Subject to
AttachmenVAct 5 of 1996 $_
Levy is stayed for
days or D generally stayed.
Objection to levy has been filed and hearing will be heid:
Date:
r~';
--
$ 600.00
$ 80.65
$ .00
$. --- .00
, 680.65
<>-,--
i>
$
------------
--.----------
$
- - __ - _.__. n_.___"__" __..
__On _._..~_, __n__.________
Time:
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ;;t\TR" 'J" JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOT RY/CLERK OF.TflE CQtfRT OF GOMr.J)ON PLEAS, CIVIL DIVISION. YOII
MUST INCLUDE A COPY OF THIS NO CE OF JUDZ' NTf:R6\;:SCf-'PT F "tl~ WITH ',;;.'>'1 Nm ICF' OF APPEA'_.
, ! 1: //1" /
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1/~/IjO Date .. I) ..",-!.~j/,~,! _. /,:, ___::.'~,Dlstnct.Jubtlce
-~-.... .. ". ..,...-. " ",;-- ....-.. " "",,'
I certify lhatthisis a t\t1'~ andC. 0 ;eClPOpyq(ihe~ec r.~r6t;';".r.p""eedi 9.7/cnf~'.,0in..g the jU.dgment~. . .
{ '/ / J i' / / 1..-/,. ~ .. .
l/f../no Data,,, ,I ' .vi.. \. "l ~~t .:.vj,'". -' ., .~__n_' District Justice
... _-/ -
. -
My commission expires first Monday of Jan~ary,
AOPC 315.99
20;;5
SEAL
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6'"-''' i-:(,.. .' '~-:;'.~ .:. .
. "COMMONWEAL TH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND
09-2-01
NOTICE OF JUDGMENTITRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
'wARRICK, HELEN V I
346 E NORTH S'll
CARLISLE, PA 17013
Mag. Oist. No.:
OJ Name: Hon.
PAULA., P. CORREAL
Add".,,,. EA,ST WING - COURTHOUSE
1 COURTHOUSE SQUARE
. '.,Tc:ARLISLE"PA
T"~ihO"' (717)240"6564 17013-000~
L..
-.J
VS,
ROSA LUCIDON
1910 SPRING RD
CARLISLE, PA 17013
DEFENDANT: NAME and ADDRESS
fi.UCIDON, JOHN, ET AL. I
1;iln clE':J:NGRD
CARLISLE, PA 17013
L -.J
l::cket No.: CV - 0000556 - 91_.. .........
Date Filed: 10/22/99 _ c, ':
: i:
TfflslS TO NoflFY YOU THAT:
.'T"'Jao\jfTTimt: . ~
.--. - '-' ----'~ - ----
.. - FORPTiATNTIFF.
".
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[iJ
Judgment was entered for:
(Name)
WlIRRH'R"
.
HRT,Rl\T V
Judgment was entered against: (Name)
T,TT~TnON
.TOHN
in the amount of $
IiElO Ii" on:
(Date of Judgment)
1 101i 100
. .
D
o
D
Defendants are jointly and severally liable.
(Date & Time)
D
D
D
Amount of Judgment Subject to
Attachment/Act 5 of 1996 $
Levy is stayed for __ days or D generally stayed.
Po
Po
,
nuunt Sf ,Iudgment $ 600.00
dgmenJ COote S 80.65
terest on Judgment $ .00
torney Fees $ .00
tal $ 680.65
sl Judgment Credits $~-~
st Judgment c;osts $
------------
------------
ertilied Judgment Total $
Damages will be assessed on:
-
I~~
Iln
This case dismissed without prejudice.
At
TO
c
Objection to levy has been filed and hearing will be held:
. ~ -, ~- "
'-..
__=--:....~__-=--_..=_~......:l____.'---~_
Date:
--ll PI."
Time:
ANY PARTY HAS THE RIGHT TO AeP.J;.8..L WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
.-,,- --... -
OF APPEAL WITH THE PRQ:1'f/ONOTARY/Cl.ERK 9F'THn,pUlJl.OF COMMON,PCEP-S, CIVIL DIVISION. YOU
.~USTINCLUDEA.,. COPi16F THIS NOTI: ~FifD:MENYf~A~~:~)T FOR.1:~.iH YOUR:,9~1~,~~F~.P~EAL.
. ,.' ..1l6/00.......Date\ .. ./U.l~t-..': ~ L,,<ut.,,-u ,., ._... ~.,D'stnctJustlce '.
'- ., -::' '..' . .-':' _, ?',' , ,'__ ''''. --:-~ ','-<" i _' "
I certify that this is a tr~e ~nd c 'rrectcoP~6f the ~~.9G~6,6i,'ih,e proceedi~S ~ontainin~ the judgment.
1/6/00 Date \, /II..../ f'~, (~, ',:....i.j~'"c,_"~-~, District Justice
My commission expires first Monday of January,
AOPC 315.99
2006
S!;AL
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HEL~JIl V. . W~IC~,
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IN THE COURT OFCO~MON PL&AS OF
CL~IBERLAND COUNTY, PENNSYLVM,IA
NO.2000-'664 CIVIL TERM
vs.
JOHN LUCIDON and
ROSA LUCIDON,
Defendants
RULE 13l2~1. The Petition for Appointment of Arbitrators shall be substant~ally
in the following form;
PETITION FOR APPOIN111ENT OF ARBITRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
M:AIJIIJIII'J;"W.T
R~JI'J;"TMl\'" ,
.
, counsel for the plaintiff~t~ in
the above
1-
2.
action (or actions), respectfully represents that:
The above-captioned action (or actions) is (are) at issue.
The claim of the plaintiff in the action is $3614'.82 + cost,s.
TIle counterclaim of the defendant in the action is 0-
The following attorneys. are interested in the case(s) as counselor are other-
wise disqualified to sit as arbitrators: ~at-rid~F. 1.auer; Esq..
.Tames K. Jones. Esa.. Kirstin M. Garrett. Esa.. Marlin L. Markley, Esq.
WHEREFORE,your petit:!.onerpraysyouI' Honorable Court: to appoint three()) ,
arbitrators to whom the case shall be submitted.
ORDER OF COURT
AND NOW. ~;;( , . J:9 ;J.;nJ,
foregoing petition, ~ ;::~
Esq., and lf~ ;f LA./, osCh-tJhK fl ~
Eshelman, Esq.
in consideration of the
Esq., Yhhd)/~~#<<0
,Esq., are appointed arbitrators in the
above-captioned action (or actions) as prayed for.
P. J.
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NOTICE OF APPEAL
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C.OMMoNWEALTH OF PENNSYLVANIA
COURT OF cOMMoN PlEAS
FROM
JlUDICIAL DISTRICT
DISTRICT JUSTICE JUDGMENT
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NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Commcm Pleas 011 oppeol from the judgment rendered by the District Justice en the
dale and in the case mentioned below,
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Thi. block win be ~gned ONLY when this notation i. required under Po. R.cP JP. No.
1008B.
This Notice ef Appeal, when received by the Distric,t - Justice, will operate as a
SUPERSEDEAS to the judgment for possession in this ccis~
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Signature at Prothonotary or Deputy
If appellant was CLAIMANT (see Pa, R.GP.J.P. No,
1001(6) in action before District Justice, he MUST
FILE A COMPLAfNT within twenty (20) days after
filing his NOTICE of APPEAL
(ThIs section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P, Ijo.
IF NOT USED, detach from cOpy of notIce of aPPeal to be SeNed upon appellee).
PRAECIPE. To Prothonotary
PRAECIPE TO ENTER RULE TO FILE COMPLAINt AND RIJLEtO FILE
1001 (7) in action before District Justice.
I-/E'LE JJ V, WAR 8 I CJ< . ,oppellee(.), ta fiie 0 complaint in this oppeal
/J re:;.f appellee{s)
(Cammon Pleas No. ,2 000 - f.,,1..l./ Civ,'( {,[,'411 within twenty (20) day... cifter.er~.of rule or, ''1)er ept'] of jUdgm.. ent of non pro~
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HE Lc rJ v: WA RR I (/{ ; , . ~abJebl "-.an} dr hisaWxney",--,
, appellee(.),
Name of appe//f>e{sl
Enter rule upon
RULE. To
(1) You are notified that 0 rule is hereby entered upon you to file 0 complaint in this appeal within twenty (20) days after the dt;:tte of
service of J}iis rule upon you by per~.?I. ~,.viQ!' or ~ c~i,fjed or registered mail ".
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(2)11 you do not file a <;9iripfalnt within this time; a J'UDGMENT OF NON PROS WILL 8E ENTERED AGAINST YOU,
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(3) The date_~f servi~~rthi~ rule ifservi~ was &y-"mail~s the date ef moiling.
Date:):"",4 1./, ,J3.qOQ~:7':,.~ :~:C-
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NJPC312..s.4
COURT FILE
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PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) DA YS AFTEF1li1ing the notice of appeal. Check applicable boxes)
COMMONWEALTH OF PENNSp
COUNTY OF ~/h1.bll
; S8
AFFIDAVIT: I hereby swear or affirm that I served
o a copy of the Notice of Appeal, Common Pleas No. J.,&1J1) ~ {; G If ,upon the DjJlIri6tJustice designated therein On
" (date of service) , 0 /Ii per~nal service O1ly (certified) (registered) mail, sender's
. receipt attached hereto, and upon the appellee, (name) _ . 121 E IV WIl- R R IfK , On
, 19_ 0 by personal service 0 by (certified) (registered) mail, sender's receipt attached hereto.
o and further that I served the Rule to File a Complainl accompanying the above Notice of Appeal upon the appellee(s) to whom
the Rule was addressed on , 19~ 0 by personal service 0 by (certified) (registered)
mail, sender's receipt attached hereto.
SWORN ~ED) AND SUBS IBED BEFORE ME
THIS DAY 0 . ;;l ()(f 0'
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Sign;;;}O'affiCid;b'f:"~.~
Tiil. 01 OI1:f!#
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My commission e
ires on
NOTAIlIAL 8IiA1.
FRANCES Q, ROSE, NOTAIlV PUBLIC
. CAIlLlllI.E BORO, CUMBEIlI.AND CO.
1l!'I'-1I1ON IlCPIIIE8 NO__:l2,_
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We do solemnly swear (or affirm)
the Constitution of the United States
wealth an~ that we will discharge the
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In The Court of Common Pleas of
Cumber],and
l.o\.oY:
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County, Pennsylvania
If. J 'Z-O,:t eJ
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OATH
that we will support, obey and defend
and the Constitutio~ of this Common-
duties 'f our--office with ~lity..
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C aJ.
AWARD
We, the undersigned arbitrators, having been duly appointed and sworn
(or affirmed), make the following award:
(Note: If damages for delay are awar~ed, they shall be
separately stated.)
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. Arbitrator, dissents. (Insert name i:
applicable.)
f IJ'd UX?0
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Date of Hearing:
Date of Award:
NOTICE OF ENTRY OF AWARD
Now, the fj'.fh day of Al'.J.L.-l'S'r , M'~ at 4:04, f2-.l1., the above
award was entered upon the docket and notice thereof given by mail to the
parties or their attorneys.
Arbitrators' compensation to be
paid upon appeal:
$ ,;('1'0.00
/s/ e~ (-d(~
' prothonota;y
By: ~JH'u-a Illf. ~ >>f"f
Deputy
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