HomeMy WebLinkAbout00-03333
",". , .~ ~
,- "'~ ,- .w~q
,
, ,\
Johnson, Duffie, Stewart & Weidner
By: Edmund G. Myers
I. D. No. 20558
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Plaintiff
C.A. Hempt Estate, Inc.,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
CNIL ACTION - LAW
Susquehanna Mortgage Bankers Corporation
31~ ':? CNIL 2000
Defendant
NOTICE TO DEFEND
To the Defendant:
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 and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defense 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 TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
134123.3
,.w -I,.
.',
"",,-i,_,,",
~ >
; ;.
Johnson, Duffie, Stewart & Weidner
By: Edmund G. Myers
1. D. No. 20558
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Plaintiff
C.A. Hempt Estate, Inc.,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
CNIL ACTION - LAW
Susquehanna Mortgage Bankers Corporation
MJ - 33 flY!> CNIL 2000
Defendant
COMPLA1NT
NOW comes C.A. Hempt Estate, Inc., through its attorneys, Johnson, Duffie, Stewart & Weidner, and
states the following Complaint:
1. The Plaintiff is C.A. Hempt Estate, Inc., a Pennsylvania corporation with an office at 205
Creek Road, Camp Hill, Cumberland County, Pennsylvania 17011.
2. The Defendant is Susquehanna Mortgage Bankers Corporation, a Pennsylvania corporation
with an office at 3255 Cape Horn Road, Red Lion, Pennsylvania 17356, and a post office address of P.O. Box
124, Red Lion, Pennsylvania 17356.
3. By Lease dated April 15, 1998, Plaintiff leased to Defendant space on the second floor of
Plaintiffs real property at 3045 Market Street, Camp Hill, Pennsylvania, a copy of which Lease is attached
hereto as Exhibit A and made a part hereof.
." ~- ~
"..,',.._,.
",.
r~~;~:1
> '
4. Defendant failed to pay the monthly installments ofrent each in the amount of $1,528.88 for
the months of October, November and December 1999, and January, 2000.
5. Defendant failed to pay Plaintiffs invoice to reimburse Plaintiff pursuant to Paragraph 18 of
the Lease for insurance expenses in the amount of $122.86, a copy of which invoice is attached hereto and
made a part hereof as Exhibit B.
6. Plaintiff notified Defendant of Defendant's default by letter dated January 7, 2000, sent
certified mail, return receipt requested, a copy of which is attached hereto as Exhibit C and made a part
hereof.
7. Defendant failed to cure its defaults and abandoned the premises.
8. Plaintiff has made reasonable efforts to mitigate its loss of rent by attempting to relet the
premises, and has secured a short-term temporary tenant as of May 15,2000.
9. Pursuant to Paragraph 3 of the Lease, Defendant is liable to Plaintiff for monthly installments
of rent each in the amount of$I,528.88 for the months of February, March and April, 2000 and for the period
May 1-15,2000, plus the 1999 insurance and tax reimbursements due to Landlord in the amount of $91.01 as
shown on the reimbursement schedule for Defendant, a copy of which is attached hereto as Exhibit D and
made a part hereof.
10. Defendant tendered a security deposit to Plaintiff in the amount of $1,462.52 at the
commencement of the term, which security deposit (less the cost of trash removal and cleaning ofthe space at
$585.00) Plaintiff has applied against the sums Defendant otherwise owes to Plaintiff.
11. Plaintiff is entitled to be paid the sum of $10,802.95 by Defendant as a result of Defendant's
Breach of the Lease.
'1.
. "_r'.. ,'" "" ". hi
'~.I," ',..._ "
- ~,~U"!
, '
WHEREFORE, Plaintiff demands judgment in its favor and against Defendant in the amount of
$10,802.95, plus costs and interest.
Respectfully submitted,
JOHNSON, DUFFIE, STEWART & WEIDNER
BY:~~
Edmund G. yers
134123.3
,--
,--
-<-'1- -,-"
~~-
,
,
VERIFICATION
I verify that the statements made in this Complaint are true and correct to the best of my knowledge,
information and belief. I understand that false statements made herein are made subject to the penalties of 18
Pa, C.S.A ~4904, relating to unsworn falsification to authorities.
Date:
Mflb. 00
Ger . Hempt, Secret
C. A. Hempt Estate, Inc.
:134123.3
LEASE
TffiS LEASE dated this IS day of f1fA-',\ ,1998 between C. A. I1EMPT ESTATE, INC., a
Pennsylvania corporation having its principal place of business at 250 Hempt Road, Mechanicsburg, Pennsylvania
(Lessor), and SUSQUEHANNA MORTGAGE BANKERS CORPORATION, a Pennsylvania corporation having its
principal place of business in Red Lion, Pennsylvania 17356 (Lessee).
WITNESSETH:
Lessor hereby leases and demises to Lessee office space in the building at 3045 Market Street, Plaza 55 Complex, Camp
Hill, Pennsylvania. (hereafter "Building") consisting of 1,359 square feet on the second floor of said Building, shown on
the floor plan attached hereto and made a part hereof (hereafter "Premises"), to be used for a mortgage banking office for a
term of three (3) years beginning on May 1, 1998 and expiring on April 30, 2001; ata rental of $1 8,346.50 per year which
Lessee agrees to pay in equal monthly installments in advance without demand and without offset or abatement, each in
the amount of$1,528.88 on the first day of each calendar month during the term. Rent for any period less than a whole
month shall be prorated according to the actual period of occupancy by Lessee during such month.
~
I~
I,'
1
I,
L
i'
I',
All rent due or to become due hereunder shall be paid to the Lessor at 250 Hempt Road, Mechanicsburg, Pennsylvania
17055 or to such other place or payee as Lessor shall designate by written notice to Lessee.
The parties hereto further covenant with each other as follows:
1. Use: Waste. Lessee will pay the rent and Additional Rent (defmed hereafter) at the times and in the manner aforesaid
and at the expiration of the term will peacefully yield up to Lessor the Premises in as good order and repair as when
delivered to Lessee, except for ordinary wear and tear and damage by fire or other casualty (including, without limitation,
damage by war, insurrection, riot, or public disorder, by act on the part of any governmental authority, and by the
elements). Lessee covenants that no waste or damage shall be committed upon or to the Premises, that the Premises shall
be used for the purposes herein before stated, and shall not be used or permitted to be used for any other purp<!ses without
the prior consent of Lessor; that the Premises shall not be used for any unlawful purpose and no violations of law or
ordinances shall be committed thereon; that nothing shall be done or suffered or any substance kept in said Premises
which will operate to increase the fire hazard or to cause the insurance rates thereon to be increased; that Lessee will not
~~
~
..'.
~. -.
-''''"j""
""""',IIi;1-"I!d~\JrJ
/ ...,' ,--.,-:,~,,-:-:i2T:'.~"-;:;+;
affix or cause to be affixed to any part of th B 'Id' '. ' ,',.".":::;~..:..'..,j:'"., ;.
e UI lUg any Sign, advert'sementor notice withoutth"""'i. <'.",'"
Lessor, except that Lessor agrees to permit Lessee to pi . I" ..' ~pnt)I'i,~,,';:
. ace a Sign or 'stlUg advertlsmg occupancy'ofthePrell\" , .~;
dlrectOlY board of the Building, and, in such lettering and colors as Le I .''''~,
ssee may se ect, on or adjacent to the door Or doors
entering the said Premises.
2. Assignment, This lease may not be assigned, or the Premises underlet, without the prior written consent of Lessor.
3. Default: Termination. If Lessee shall default in payment of the rent or any installment thereof for 30 days after notice
by Lessor to Lessee of such default, or default in the prompt or full performance of any provision of this lease on Lessee's
part to be performed and such default shall not be remedied by Lessee within 30 days after notice by Lessor to Lessee of
the specific default, Lessor may lawfully enter into the Premises or any part thereof and repossess the s~e, and expel
Lessee and those claiming under and through Lessee and remove Lessee's effects, without being deemed guilty in any
manner of trespassing, and upon entry as aforesaid, this lease shall terminate and wholly expire (in which case Lessee
waives any notice to quit under the Landlord and Tenant Act of 1951 as amended) and Lessee warrants that in case of
such termination, Lessee will indemnify Lessor against a1Iloss of rent which Lessor may incur by reason of such
tezmination during the balance of the tenn hereunder, provided Lessor shall have made every reasonable effort to mitigate
such loss by reletting the Premises to third persons. In the event Lessee is declared a bankrupt or insolvent by a court ,
this lease shall, at the option of Lessor, tenninate upon 30 days notice.
4. Damage:' Destruction. If the Premises or the Building shall be so damaged by fire or other casualty (including,
without, limitation, damage by war, riot, or public disorder, by act on the part of any governmental authority, and by the
elements) as to be substantially destroyed, or if any authority having jurisdiction shall order the demolition or removal of
the Building or any substantial part thereof, then this lease shall thereupon cease and come to an end and any unearned
rent paid in advance by Lessee shall be refunded to Lessee.
If the Premises or the Building shall be partially destroyed by fire or other casualty (including, without limitation,
damage by war, insurrection, riot, or public disorder, by act on the part of any governmental jurisdiction, and by the
elements) the rent shall forthwith abate according to the extent to which the Premises shall be rendered untenantable or
declared unsafe, provided, however, that if the same is not restored and put in proper condition for use or occupancy
within 90 days of the event, or if such event shall occur within 90 days of the expiration of the term specified herein or any
renewal term hereof, Lessee may cancel this lease and thereupon any unearned rent paid in advance by Lessee shall be
refunded to Lessee.
I
~
2
,
..
I, '
,-,-.~'
- ~ - "',:k
-----~'r"~'T":,~. . -,_
.' ,',', "::;_:_:-'/;>:!t:t,::_-,:,.:~~/o~~,>'"
If all or any portion of the Premises Or th B 'Id' 001 . , "i<:v"lr~ '
, . '. e ill mg, s I be condemned or taken by lawful authori '., Let"'~{"<
Its option, may cancel or termmate this lease at any time after final d f d' .'.. ty. ~'~j
, . or er 0 con emnation or taking, and ai'ly tinearried'
rent paId m advance by Lessee shall be refunded to Lessee. .
5. Chang~ in Permitted Use. Lessor represents that the Premises may lawfully be used for general office purposes,
including, but not limited to, an office for mortgage banking services. If any law, ordinance, ruling, order or regulation
now exists or is hereafter enacted prohibiting the use of the Premises for any of the foregoing purposes, then Lessee, at its
option, may terminate this lease and all of its liability hereunder shall cease from and after the date when such law
, ,
ordinance, ruling, order or regulation becomes effective, and any unearned rent paid in advance by Lessee shall be
refunded to Lessee.
6. Holdover. It is agreed that a holdover beyond the expiration of the term specified herein or any renewal term
hereunder shall operate as an extension of this lease from month to month, provided that Lessee is not otherwise in default
hereunder.
1
i
7. Common Areas: Parking. Lessee's employees, customers and invitees shall have the right to use the elevators, (i
stairways, halls, entrances, parking facilities and other similar or related facilities in and about the Building in common I
with Lessor's other tenants. Ci
8. Damage: Indemnification. Lessee agrees to be responsible for damage to the Premises and the Building resulting
from the use of said office space by Lessee, except ordinary wear and tear, damage by the elements and as otherwise
'I
provided herein, and Lessee shall indemnify and save Lessor harmless from any liability to any other person for damage I
"
to person or property resulting from Lessee's acts or omissions in connection with its use of the Premises, except for injury ~
fj
to a person or damage to property which may be due to the negligence of the Lessor or defects of the Building. "
,
,
I
i
I
l;
9. Maintenance. Except as otherwise provided herein, Lessor will maintain the Premises and the entire Building in a!
good state of repair, including, but not limited to, the roof and exterior of the Building, its structural parts, perimeter and I
interior walls, ceilings, floors, windows, the electrical and lighting System, the duct work and heating systems, pipes andl
plumbing, ventilating system, air conditioning system, elevators, stairs and halls, and all necessary apparatus, accessories
and fixtures pertaining thereto, Lessor may at reasonable times during normal business hours enter the Premises for the
purpose of inspecting, maintaining, and repairing the same.
3
j
..
. -~
~"Iti4.jn.lliE1Jw!,
,,'
10. Fixtures. Lessee shall retain title to anything it m 1 ' . ',.:
. . ay p ace or Install In the Premises including, withoUlliriUtatl
counters, carpets, trade fixtures, funuture, eqUIpment and business machi d" ': .', .,,', " ":,~:,
. . nes, an ,at Its Option, may removethasameJii{
any lime dunng or at the conclusion of Lessee's occupancy of the Premises provided, h tha '
, owever, t Lessee shall
reimburse Lessor for any damage to the Premises occasioned in the removal of the same.
II. Loss Covered by Insurance. Notwithstanding any other provision of this lease, Lessee shall not be liable for loss or
damage caused by fire or perils covered by the Lessor's extended coverage provisions in its insurance policies, except such
loss or damage caused by Lessee.
12. Notices. All notices to be given hereunder by either party shall be in writing and given by personal delivery or shall
be sent by registered mail addressed, if to Lessor, to the place where rent payments are to be mailed hereunder, and if to
Lessee to the Premises, and notice thus given shall be a sufficient service thereof and shall be deemed given as of the date
when deposited in any post office regularly maintained by the federal government, postage prepaid.
13. Alterations. Lessee shall make no major alterations, changes in, additions or improvements to the Premises without
the prior consent of Lessor. Lessor shall, at Lessor's expense, prepare and maintain said space for Lessee's use to include
the renovations as shown on Exhibit "A", sketch of floor plan.
14. Utilities: Services. Lessor agrees to furnish at Lessor's expense the following services in connection with Lessee's
use of the Premises:
(a) Janitor service in and about the Building (but not including the Premises), including, but not limited
to, dusting, sweeping and/or mopping, and disposal of waste basket trash,
II
(b)
(c)
(d)
(e)
(f)
Window washing and dusting of venetian blinds, as necessary,
Water, heat and air conditioning.
Electricity and all utilities except telephone.
Adequate elevator service and rest room facilities,
Parking facilities maintained by Lessor for tenants of the Building, of which Lessee's employees and
visitors may have use for parking of private cars in common with Lessor's other tenants.
15. Completion of Improvements. In the event that the Premises are not prepared as herein pro\~ded and ready for
Lessee's occupancy at the beginning of the term, (a) the rental provided hereunder shall abate proportionally to the day on
which it is ready, and Lessor shall not suffer any other liability whatsoever, except as set forth hereinafter; and (b) Lessee
agrees to take possession within 5 days after it receives written notice from Lessor that the Premises are ready for its
4
"
-,
~,~.~
L."
.~_~." ~.~J
~, ",-'.~
--
. - '''''-~-''~:::'~~''7',.,.!;.,,: ,-,.~""r.:,,~~t'" 'L;.,'~,,:~_~._.;,~,';~
occupancy; provided, however, that if the Premises are not r d d ' ," '..,,'.. '
, . ea y an actual possession tendered to
after the begmnmg of the term Lessee may, at its option gl've Lessor Ii" f' ' ,',.,: ':"::":,:,' i:;:
. ' no ce 0 Its withdrawal troIi\"'thISJ
case thiS lease shall be null and void and all sums paid by Lessee to L . .,"'" "'.
, ' essor on account of this lease shan ,be ~;lo
Lessee. Lessor agrees to use Its best efforts to have the Premises ready fior Les ' " ' ',' " '.,
. see s occupancy pnor to the beginning of
the term, and lfLessee does occupy the Premises prior to the beginning of the term Lesse h II I fi '
, e s a pay renta, or the period
of occupancy prior to the beginning of the term at the rate as specified herein.
16. Insurance Obtained by Lessee. Lessee shall procure and maintain policies of insurance, at its own cost and
expense, including the following:
a. Public Liability Insurance. Lessee shan obtain insurance insuring Lessor and Lessee from all claims,
demands or actions for injury to or death of anyone person or more than one person or damage to property in
anyone occurrence in an amount of not less than One Million Dollars ($1,000,000.00), made by, or on behalf
of, any person or persons, firm or corporation arising from, relating to or connected with the Premises. The
Lessee shall be named as the insured and the Lessor shall be named as the additional insured. It Lessee
increases its limits with respect to said coverage, Lessor will be named as an additional insured with respect to
said increased amount.
~_;i
b. Worker's Compensation. Lessee will obtain Worker's Compensation Insurance for its benefit
insuring Lessee from all worker's compensation claims.
c. Lessee's Contents. Lessee shall obtain insurance on all of its contents, to include trade fixtures,
machines, equipment, furniture and furnishings in the Premises under Standard Fire and Extended Coverage
Insurance, including without limitation, vandalism and malicious mischief and sprinkler leakage endorsements.
d. Form of Insurance. The aforesaid insurance shall be with companies and in form, substance and
amount, if not herein provided, reasonably satisfactory to Lessor, Lessee, and any Mortgagee of Lessor, and
shall contain standard mortgagee clauses or judgment clauses satisfactory to Lessor's mortgagee or judgment
holder if required by same. The aforesaid insurance shah not be subject to cancellation except after at least
thirty (30) days prior written notice to the parties. The original insurance policy or certificates thereof
satisfactory to the parties together with evidence of payment of premiums thereon shall be deposited with the
parties.
5
""",1IiMIilIIlIItij~1"'"
...........
> ~"
~~~
/
/.
.' '
17. Mutual waiverpf Subrogation Rights: Whenever (1) any loss, cost, damage or expense from fire, explosion
or any other casualty or occurrence is incurred by either of the parties to this Lease, or anyone claimed by, through or
under it in connection with the Premises, and (2) such party is then covered in whole or in part by insurance with
respect to such loss, cost, damage or expense required under this Lease to be insured, then the party so insured or so
required to be insured hereby releases the other party from any liability which the other party may have on account of
such loss, cost, damage or expense to the extent of any amount recovered by reason of such insurance or which could
have been recovered had such insurance been carried or so required and waives any right of subrogation which might
otherwise exist in or accrue to any person on account thereof, provided that such release of liability and waiver of right
of subrogation shall not be operative in any case where the effect hereof is to make invalid such insurance coverage or
increase the cost thereof.
18. Insurance Insuring Against Liability in Common Areas. Lessor will obtain public liability insurance
insuring Lessee and Lessor against liability occurring on or arising out of use of the common areas of the Building.
Lessee will reimburse Lessor 11.82% of the total cost therefor. In 1997, Lessor's premium was $744.00.
19. Additional Rent: Taxes and Insurance.
(A) Subject to the defmitions herein set forth for the purposes of this paragraph, Lessor shall bear and remit
all Applicable Taxes and Excluded Taxes; provided, that Lessee shall, within the limitations herein provided, reimburse
Lessor for the full expense of Excess Taxes. Excess Taxes shall be borne by Lessee only in the proportion that the
number of days in the calendar year, or part thereof, included within any term of this Lease, subsequent to the Base Year,
bears to the total number of days in the calendar year. Applicable defmitions are as follows:
(1) "Applicable Taxes" shall mean only those ad valorem real property taxes assessed and levied
against the entire land and Building of which the Premises are a part, which are for and pertain to the calendar year in
which occurs the tax status clay (also called the "tax day" or "assessment day") used in the determination of said taxes.
(Applicable Taxes shall not include 'Excluded Taxes' as defmed herein);
6
"ofllii\1,'c:
'>"~" "", ,;-,,:..
(2) "Proportional Applicable Taxes" shall mean only that rt'. , , .. " .. <: <:-\',y"
, . po .on of Applicable TaXti!l,ihat~X'
rentable area In the Prem.ses bears to the total net rentable area in the entir B 'Id' ' . ',:',."""CC.'" '.
. e Ul mg. Lessor represents that such total lid,
rentable area IS l.lm square feet, and agrees to notify Lessee promptly of any change; ,
(3) "Excluded Taxes" are real estate taxes imposed upon any improvement or addition to the said
Building of which the Premises are a part other than improvements or additions (a) to the Premises, or (b) which would
directly benefit the Premises;
(4) "Base Year" shall mean the year 1998;
(5) "Excess Taxes" shall mean the amount by which Proportional Applicable Taxes for each
calendar year, or part thereof, included within any term of this Lease, subsequent to the Base Year, or any renewal or
extension thereof, exceed said taxes for the Base Year. Lessee shall reimburse Lessor, in accordance with the above
provisions, promptly upon receipt from Lessor of a computation of the claimed reimbursement together with receipted
copies of applicable tax bills.
All special assessments applicable to the Premises ,shall be borne and remitted by Lessor. Taxes, if any, on personal
property shall be borne and remitted by the owner of the personal property taxed.
Lessor agrees that Lessee shall have the unrestricted right to contest and appeal from any assessment of real estate taxes
affecting the Premises, either in its own name or in the name of Lessor should this be required by law or regulation.
Lessor further agrees to cooperate in all reasonable ways to further any such procedure by Lessee.
(B) Lessee further agrees to pay its proportionate share, detennined in accordance with the fonnula set forth
in 19{A){2) supra, of any excess cost to Lessor in any year, or part thereof, included within any term of this Lease,
subsequent to the Base Year, of insurance and electricity expense. Base Year, for purposes of electricity expense, shall
mean the first full year of Lessee's occupancy.
(C) Lessor shall, within 60 days following the close of any year after the Base Year, and within 60 days
following the tennination of this Lease, give written notice to Lessee of any payment due hereunder, which notice will
include a computation of such payment, in reasonable detail, prepared and certified to by a certified public accountant for
Lessor, and Lessee shall make payment of such amount within 30 days following receipt of such notice. At any time after
receipt of such notice, Lessee shall be entitled to inspect the pertinent books and records of Lessor at the offices of Lessor,
7
;
-..-
-"-~-----"._--'"-----"''''-'~- ,
, ".,.,-
20, Consents.
. :', ->:~:?.'~"';
Lessor covenants that any consent of Lessorrequired, h . h . " "h.',,;,
erem s all not be wIthheld unreasonably.'
21. CovenantofOuietEnjoyment. Lessor warrants that Lessee onpayingth t th Add"
e ren , e llional Rent and performing
the covenants aforesaid, shall and may have, hold and enjoy the Premises peacefully and quietly for the term aforesaid.
22, Lease Binding. The covenants and agreements contained in this Lease are binding upon and shall inure to the
benefit of the parties hereto and their respective heirs, executors, administrators, successors, legal representatives and
assIgns.
23, Option for Additional Three-year Term. Lessee shall have an option to lease the Premises for an additional term of
three (3) years provided that Lessee shall not be in default under this Lease at the time of exercise of said option, and
provided further the Lessee shall give Lessor no less than one hundred twenty days (120) written notice of Lessee's
intention to renew for the additional term, such notice to be in writing in accordance with Paragraph 12 hereof. The terms
and conditions of this Lease during the additional term shall be identical to the terms and conditions in this lease, except
that the rent shall be increased by 3% in the first year of the additional term, an additional 3% over the prior year during
the second year of the additional term; and 3% over the prior year during the third year of the additional term.
Accordingly, the amount of annual rent shall be in additional year one: $18,896.90, payable in equal monthly installments
of $1,574,74; in additional year two annual rent in the amount of $19,463.81, payable in equal monthly installments of
. $1,621.98; and in additional year three annual rent in the amount of $20,047.72, payable in equal monthly installments of
$1,670.64.
If Lessee renews for the additional three-year term within the time period aforesaid, this lease shall tenninate,
unless sooner terminated, on April 30, 2004.
,
"
IN WITNESS WHEREOF, the parties hereto have caused this instrument to be duly executed in duplicate as of
the day and year first above written.
Signed, Sealed and delivered in
presence of:
LESSOR:
C. A. HEMPT ESTATE, INC.
By: ;?Jta~JV (~~fl'~'
Title
8
~"
.........
~=; *",i@aj{
,
.<'-.'",
LESSEE:
SUSQUEHANNA MORTGAGE BANKERS CORPORA nON
_Cl ~-<~
BY~~
Title
!:
~
eE.o.
i
r I
.1
I.
I
i:
I
i 1,1\,
f II
? I:
, I:
!r
~
,~.
>
:',
/
I
r
l~
9
",',"..
~;;::' -)~;:~.~t.:ff~~:i~,;~::::~~J;~~['RJ~~0i;F~J~7r;;.;i;s~~X7::;~i{~';~~-: ~
;'~.~.;:\\~;;~:il:.~~~;)I~'~~ ~::;:~;!0~~~~<i[r;,:mf!:~' ~~:?~i?in{~:~
.. ,- ," --
(:.' ( ;..::.- '( ;i. .'f<.. ::j,{:<'),f~~;', .).~''''7; :~,;:~ .~(
" .
, ,
"EXHIBIT A"
" '
, ,'. 'd~'4!
!', ..: l' .
lc
,
II .
1 L..
\ : _ PoaIL
o~.
3 .'
o~AJ f""/(o
Ip6d11 -
J II.
j I
Kt j~~
-/) ~
~ '5?1IJl(
I .
erlJiG N
I.lttt{,tfT
--r41J= lJI'l.'1
Wftl(
/)
al.A5~~Il.
, '" - ,
.' -"
1I'i''''';;
L.J .0 r- F 1<:: Ii "i:. r
K I rCI.J6.N /i.7I6....
-SK~(CH )JLft-t'J (-o/C
i3tt 1 L 1.::> 0 u "{ f}--;-
ao 4-~ m A-~/i;f "S-;--
1000 ?>r / S6ct!/l/;~ PL..oo iZ-
.~"-
-
-
,
~ ~
. _ o~
-~~'!!f:h;
UTILITY SCHEDULE
""001",
c;.~TF2757
,,Jame
Address
C. A. Hempt Estate, Inc.
250 Hempt Road
Mechanicsburg, PA 17055
Social Security or
Identification No.
Year Ended
19_
Form
Schedule
_ Lme __.~_____
Year
1998
SUSQUEHANNA MORTGAGE BANKERS CORPORATION
INSURANCE INSURING AGAINST LIABILITY
IN COMMON AREAS (Paragraph 18)
" Pol icy Year P011CY Year
'11/11/97 - 11/11/91 11/11/98 - 11/11/99
'''MTifers Mut'u'aT"Yfi'surance
t.~~liierCiiiiPoii~i""
1'01 No 102152
C()lI1P~ny
.. ...... ,....
I
....p.~.~.~.~.c.....~i~~i~.I.ti...~.n~.lJ.r.a.nc.~ ..pr.~lI1i.\j.~..
.. '. ..... ... "$14400
'$644 '00
.Es.Cj~~hii;;;;~;s "s'hii~~"%"
...S.~,~:~~:~:h~:~:~:~"l:.~ s hare ~,~?~n,~
......
11 si( ....,... 1182
87 , 94 I
....... I.
~;;
.........=T..'.:~'~.~: :'i'~
j
,
i6ii
P~i.~~~.i~ a.se.i.e~iJ~iiis .. ill'poli.~i ..i~ar ......
....36S}36.S.
::':::::'::.:::~~;~~~:~:~~~~:i ~ ... pr~r~i:~cl... ~h.?r~..:""" ..
, .....,.,... ,... .. ........."............ ,.... .. . . .., . . .. , ~ ..
...X.Cl...1;>.E!...:r.E!.illl\)\l.:r.~_ecl...J.() C o.A HE!mpt .l!.ga te.... Inc
......l?y...~ \l~.q1J.!l 11."!)!H!.~()J.: tg"g E!B" 1) k!lX a .Co:rpo:ra t() n
.-.. ..............~i2i. 86
......... .......
.....
......
...... ........
I..
. ..
.....
@ I"'. r.K CRICKET f'U8L1SHI~G CO.
~~~~
-' "1 ~i:"
"
JERRY R. DUFFIE
RICHARD W. STEWART
C. ROY WEIDNER. JR.
EDMUND G. MYERS
DAVID W. DELUCE
RALPH H. WRIGHTo JR.
DAVID J. IANZA
MARK C. DUFFIE
KEIRSTEN WALSH DAVIDSON
MICHAEL I. CASSIDY
LAW OFFICES FilE COpy
JOHNSON, DUFFIE, STEWART & WEIDNER
A Professional Corporation
301 MARKET STREET HORACE A JOHNSON
P. O. BOX 109 OF COUNSEL
LEMOYNE, PENNSYLVANIA 17043-0109
WEBSITE: www.jdsw.com
TElEPHONE 717-761-4540
FACSIMILE 717-761-3015
E--MAIL mail@jdsw.com
WRITER'S EXT. NO. 20
E-MAIL egm@jdsw.com
January 7, 2000
Susquehanna Mortgage Bankers Corporation
3045 Market Street
Suite 2
Camp Hill, P A 17011
VIA CERTIFIED
AND REGULAR MAIL
RE:
C.A. Hempt Estate, Inc.
Our File: 2876-17
Dear SirlMadam:
Please be advised that we have been retained by the C.A. Hempt Estate, Inc. with respect
to your lease dated April 15, 1998 for the premises Suite 2, 3045 Market Street, Camp Hill,
Pennsylvania. You are in default under the lease. You failed to pay the rental installments for
the months of October, November, December, 1999 and January, 2000, each in the amount of
$1,528.880 In addition, you failed to reimburse C.A. Hempt Estate your portion ofthe insurance
expense in the amount of$122086, detailed in the Estate's letter to you dated January 21, 1~99.
If you fail to cure the default within thirty (30) days ofthe date ofthis letter, C.A. Hempt
Estate, Inc. has the right to enter the premises and repossess the same, expel Susquehanna
Mortgage Bankers Corporation and terminate the lease.
We trust that you will take appropriate remedial action promptly.
Very truly yours,
JOHNSON, DUFFIE, STEWART & WEIDNER
Edmund G. Myers
EGM:klt: 130295
cc: Mrs. Eileen Conners, Office Manager
Mro Gerald L. Hempt
""..'-
"
ur--
-- -'--('to.
Ol
."
iii
Ol
~
Ol
>.
l!!
Ol
:5
c
o
."
Ol
~
D.
E
o
"
Ul
Ul
Ul
a:
c
c
~~~,
"--""~.~
.
'.
SENDER:
I also wish to receive the follow-
Ing services (for an extra fee):
o Complete ite'i"ls 1 and/or 2 for additional services.
Complete items-3,--4a. and 4b,
o Print your nar'nl:! and address on the reverse of this form so that we can return this
card to you, ,'_u_ __ , .'
o Attach. thilll form to the front of the mailpiece. or on the back if space does not
permit. '
o Write "Relum Receipt Requested" on the mailpiece below the article number.
o The Return Receipt will show to whom the article was delivered and the date
delivered.
3. Article Addressed to:
1, 0 Addressee's Address
2. 0 Restricted Delivery
4a. Article Number
Susquehanna Mortgage
Bankers Corporation
3045 Market Street
Suite 2
Ccmp Hill, PA
Z 070 768 774
4b. Service Type
o Registered
o Express Mail
o Return Receipt for Merchandise
~Certifjed
o Insured
DeCO
:; 6. Signature (~q'dreSSfle or Agent)
g,
.!!l
.,
" 'I i
.jl.
PS Form 3811, DeCernber 1994
. ,1____1..;.,.. :...
102595-99-8-0223 Domestic Return Receipt
"~~
,
.1
~I
~(
~I
"-
"ill
&!r
~I
~i
",i
c'
.~ I
l51
gl
...
... '
c'
..
F
~'"
~~
'I
',"
UTILITY SCHEDULE
.
"'ao"~"
Cfll:~.n TF 27'57
Name
Address
Co Ao Hempt Estate, Inco
250 Hempt Road
Mechanicsburg, PA 17055
Social Security or
Identification No. ._.__
Year Ended ~'_"__'~_'.______~ 19_,,~
Form
Schedule
SUS UEHANNA MORTGAGE RANKERS CO
Total
REAL ESTATE TAX REIMBURSEMENTS Assessed Value
Line
ll'iiiikrOfHce..lliiiT<rii'ig............. ...... .............. ........... ......... ......$'1'06.;..810
. ......p iirkiiig"X mpr ovemeilt's" ..... .... ...... ...... ........... ... ...... ......... . ........... '''8';''560'
..""..,.,,,,,, ,...",."",'....""".."..""",,,.,...,,..,, "..',.,...".."""",,,,,,'.....,,,,,,, ".".....',,,...,.,.,...
Land .......................................... .............5..~.,..3.~.Q.
:::~{~~~~~?y:~~~{i~Irig::::::.::............... ...... 17 , 750
........... ....T.<?.t.'i.1.~........................................................ ...... $192.500..
,
.........il .
........11.
, . , , " '.,' i " .
......I......
...".,..
...............1
......:::ii~:~k./qf.f.{c.~.:.~~.{1.~IiiX:o.f.:.i<?.~~I...A~~.~i~.~.4.:.: i~~~::::....::::.:.
.COMPUTATioN..oFRE'IMBiiRsEMENT..DuE'......................... ...............
..::f~:q~...~V~QV~~;;;~~;;;..~q:~:i.~~q~~;;;~~~~~:..~9ii\;9.~ iiQ~L::..........:...
TO Co Ao HEMPT ESTATE INCo
.)ii:~i;,cy:~~~~Ji~~J9.9.*......
,.,.", "" ,.,.," f'
:...::..::.~.ii~.~/~(f.~c.~...:..~~~\~~~.i:::~..:..:::::::.....
roo
30
)Q
,
"'1'
..
..1..
I
..1
.!..
,
.$
565
%
Bank/Office
BId 0 Amt.
$106,810
2,5681
...17...8.11+....
....",. "r"
i'"
I.
95
.. .... ..... '66:7%"
"..."."
.... ..X~~!.~~ii~.ApjiX~~ii~(~:~<>.:.~ii.~q(){ Xc.:~:)~m {~......
siisiii~~ii ~~~ .~?!.~~.ii:~~ ~::%.::'. ((~?:s~/i:f.:;~~>:ii:ii: ::Xi.:::X:::::" ..... ..
J
"
!
".. . ,.,""",.,",.,',.........,.."",.,.,.,.,,...,....,......'.T'.'.."......,............. ,................".......
Susquehanna Mortgage s share t be
. "'Reiiiiours'eo"f6 e:"K:' Heiii:ptEs' ife;...tnc:....
,,,,,,,,,,,,,..,.,,,.....,,,.,,,..,,,,,,,,,,,,,.........,,,,,,,,,,,,,,,,.,,,,,,.,....,.. ."....."..".."..,.,..'",
.i
I
"''''1''''
.1................
,
.............1
.. ,... .""..""...""..."'.."..",,...,. ,....,..,...,..."."".,......",........ ""....,.""",.",.."....,.....""
@ ,'61 PsK CIW::KET PU9\..ISHlfl.lG co,
q$
373 "92
!.
J
,ll...
i!
. "j.,
Ho~i%
i
I
1
..... .......1
... 44 "'2"
I
""
.'"
~ ~~~
<< ',--
UTILITY SCHEDULE
~~
CRIiS~P TF <'757
Name
Address
Social Security or
Identification No. __' .__..____'_._~,."._,_..._____~_.
Ve.r Ended _______.__ 19"_
,"-'-_.___.0_-
_."_ Ve.r ____1,9~~__.___
CORPORATION
Pol icy Year
11111199 - 11/1110
Co Ao Hempt Estate, Inc.
250 Hempt Road
Mechanicsburg, PA 17055
Form Schedule
SUS UEHANNA MORTGAGE
INSURANCE INSURING AGAINST LIABILITY
IN COMMON AREAS (Para rah 18)
Line
BANKERS
'::Hi;n:~.~~~~:~~~Li~~:~i~~~:~:::~~:;;~P~:~y::::::::::::::::::.:::: ::::::::::::::::::::.:::.::
...ql?~~~.':"();I!}..X()l.i.",y'.............. .............. .._.. ....................._..... ...............................
Pol. Noo 102152
Ii
I
"'1'
'$39606
::~~~(~<T~.a.~~i~~i.:::~~s.:~;:.i.~c.:~...P:;:~~:~~~::...::::::::.:::.::::::.:::::::::...
..::~:~:s.:~:~~:~a.~~a.:r~:::~~i.~~:::~:::::::::::::.:::'..::::::::.::::::::::::::.:::::: :::::::::::::::::.::::.::::::.:.. .
1102%"
S~sq~~~~~~~:~:s.:s.:~~;:<a.~?~n.~::..::':::::: :::::::::'.':':::::.::::': ... '.. . ..... '4681
........... ............... ............1.
ji~~:~.3Tl: :~::~~~i~~~.~:~~~~::~~.P~~i,.c~~~~'..::.:::..:.::::::::.:::. '..1'.36513.65 ....
....................:........~~s.q~e.h.:~.!l:r..~.~.~...p.,()'~~~~...~h.:~.,~ ........... ........................... 46 81
....T~.:::~.~.::.~~:i~~~i9.~.~.::t.(,::::Q::.:..:~;.::W~mp~.:::~:9...~.~~.~..~..:::i~. '.~::::::::'.'.::::::':.::::'.....
..:::.::~.Y .~~.~.q~ ~ h.:l!l.!l:ll~..l1l?':"J.gl!g~ .I1!lTl~.ex .~... q()XP()E!!t ()Tl..... .......... ........
J
,
'..,....",,,,..,,......,..,...,,..... .,,,......,,.,.,,"',..,.,.,,,,.....,.,,j..
.1.
@) uu PlliK CRICKET PUBI.ISHING CO,
I..
I
,
,
.;."
1\
"."1,,,,
,
.'1'
.."....
!i
I
I
1
J
.....,,,....1,,..
i
.L."
I
.........+
I
............1....
, .. ....,.,.., ,...
.............1
, ' .. ,...,..., '['
,
.:....
,
4681
'......'.).'.
",^.~
\",,-,. SHERIFF'S
~'YC{~E NO: 2000-03333 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUM8ERLAND
C A HEMPT ESTATE INC
VS
SUSQUEHANNA MORTGAGE BANKERS
R. Thomas Kline
["'"
" ",,,,;'~'!I
RETURN - OUT OF COUNTY
duly sworn according to law, says, that he made a diligent search and
, Sheriff or Deputy Sheriff who being
~nd inquiry for the within named DEFENDANT
SUSQUEHANNA MORTGAGE BANKERS
but was unable to locate Them
deputized the sheriff of YORK
, to wit:
CORPORATION
in his bailiwick. He therefore
County, pennsylvania, to
serve the within COMPLAINT & NOTICE
19th , 2000 , this office was in receipt of the
On June
attached return from YORK
Sheriff's Costs:
Docketing
Out of County
surcharge
DEP. YORK COUNTY
18.00
9.00
10.00
26.50
.00
63.50
06/19/2000
JOHNSON, DUFFIE,
mas Kline
ff of Cumberland County
STEWART
Sworn and subscribed to before me
this C. IE day of q,.t7(
~ A.D.
Y-'1fl1 C> 'h,~f;.. #-
. Prothonotary
CDUNl'YOF Y€JRK
OFFICE OF THE SHERIFF
SERVICE CALL
(717) 771-9601
28 EAST MARKET ST.. YORK. PA 17401
------,--- - - ------- --,-
SHERIFF SERVICE INSTRUCTIONS
PLEASE TYPE ONLY LINES 1 TO 12
PROCESS RECEIPT, and AFFIDAVIT OF RETURN DO NOT DETACH ANY COPIES.
1. PLAINTIFF/SJ 2. COURT NUMBER2 0 - 3 3 3 3 Civil
C.A. Hemot Estate Inc. 4. TYPE OF WRIT OR COMPlAINT
3. DEFENDANT/Sf Notice &
Susquehanna Mort~age Bankers Cor~. Complaint
SERVE 5, NAME OF [NOI [DUAL. COMPANY, CORPORATID ,ETC, TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD,
. Susquehanna Mortqaqe Bankers Corporation
6, ADDRESS (STREET OR AFD WITH BOX NUMBER, APT NO., CITY. BORO, TVl/P., STATE AND ZIP CODE
AT 3255 Cape Horn Road, Red Lion, PA 17356
Q PERSON IN CHARGEIKOEPUTIZE Cumdl>GEI!ilJillilld
---19 _I, SHERIFF O~ COU
v n r k COUNTY to exec
to law. This deputation being made at the request and risk of the plaintiff.
s, SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE:
Q PERSONAL
osrEn CI OTHER
eriffof
cording
7. INDICATE SERVICE:
NOW
ciU-NTY
Cumberland
OUT OF COUNTY
CUMBERLlIND
ADVANCE FEE PAID BY CUMBERLAND COUNTY SHERIFF
NOTE ONLY APPUCABLE ON WAIT OF EXECUTION: N.B. WAIVER OF WATCHMAN. Any deputy sheriff levying upon or attaching any property under within writ may leave
sama without a watchman, in custody of whomever is found in possession. after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any
plaintiff hereln_ f.oJ any loss, destruction, or removal oJ any property before sheriff's sale thereof.
9, TY~AME ~NQ ADDRESS of ATIPANEY/ORIGINATOA and SIGNATURE
~amuna G. Myers, t:Bq.
301 Market St., PO Box 109, LeIno he . Penna 1 vania 17043-0109 717 761-4540 5 31 00
12, SEND NonCE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed it notice is to be mailed).
10. TELEPHONE NUMBER
11, DATE FILED
CumberIand County Sheriff
--, SPAC!;BELOW EOR_USE OF "(HI;; SHERIFF ONLY -PO NOT WRITE Bi:LQW THIS LINE
SIGNATURE OF AUTHORIZED CLERK 14. Dale Received 15. Expiration/Hearing Date
13. I acknowledge receipt of the writ
or complaint as indicated above.
RESIDENCE ( )
J. Ludwig
POSTED (
POE}(L
6/5/00
SHERIFF'S OFF ( )
6/30/00
16. HOW SERVr:::O: PERSONAL ( )
OTHER ( I
SEE REMARKS
Int.
Notarial Seal
james V. Vangreen, Notary Public
........ York. York County, PA
fY) My CQmmission Expli-es Jan. 22, 2001
t,t~"
41 ~ AfFl.RM~":ana sUQ,scribed to before me this
--' C - "~~~.iC/~.:-'_ -~.:"'une
42\.d'ayof '-'~___;-'.".<::l.J'_,
--, ,'.<. - ~ --.'~" ~
-'r-'.~':~ ';;:Oi--
47,0 e
4B.Dal
~o
:'43. .'.
Hose
6/14/00
~ ~ otary Public 'I 46. ignature 0 ore gn
f EXPI l::s p!-77-C: Goun Sheriff
50.-4 ACKNOWLEDGE RECEIPf OF THE SHERIFF'S RETURN SIGNATURE
Of AUTHOR1ZFD.l.$$UING AUTHORITY AND TITLE
L'\,lVli,frr -J~Tng';uthorftY 2. PINK 4 Attomay 3. CANARY -Sheriff's Office 4. eWE ~ Sheriff's Office
.. , ~_... #'<t-, ..:...'C'
~ 'd V-' . '- .
.'~'~_J';--'
49. Date
51, Date ReceIved
M
-~~lJL~ "
ijrrK~
"'~
"RECEIVED"
OfFICE OF SHERifF
YORK. PA
'00 JUN 5 P{7 1 11
t.:
- ,
~
-. ~W;,,''''''ffl::'...:rr,,;MWl;'(,--1\'~!','f-W!lm~i~,L, __ - ,_
[r~~
~~l
!~m~
,~!i!'f.'j.,*-.;~;rq,.V'L,,,,'-'1",,'-~-";'\'.-'Flo;;-l'#W1_, _
,"l\'l~
n~,
\.-
~,,' COUNl'tOF-YVRK
- OFFICE OF THE SHERJFF
. SEIWICE CALL
(717) 771 -960 1
j,
28 EAST MARKET ST,. YORK, PA 17401
'i
;;-.
$HERIFF SERVICE
PROCESS FlECElPT;and AFFIDAVIT OF RETURN
1. PLAINTIFFISI
C.A~ Hempt Estate~ Inc.
3. DEFENDANT/Sf Not ice &.
Susouehanna Mort -a e Ban.k~rs Cor '" Complaint
SERVE { 5. NAM, E,OF ,INDIVI,D,UAL. COMPANY, CORPORATION. ETC. TO SERVE O,R DESCRIPTION OF PROPERTY TO BE LEVIED. ATTACHED. OR SOLD.
i". Sus,cru:e,hannd.' fvclortgage Banker:.3 Corpora t i':)n
6. ADDRESS (STREET OR RFD WITH BOX NUMBER. APT NO.. CITY, BORO, TWP.. STATE AND ZIP CODE
AT 325~:' Cape Horn Road, Red LiDn, pi, 17356
7. INDICATE SERVICE," i:I PERSONAL QPERSON IN CHARGE l!i DEPUTlzECuml::ieBRl:<iIIIl\IIU i:llST CLASS MAIL i:I POSTED i:I OTHER
NOW ' b! .[ / UU '19:~ I,SHERIFF OlK:!COOII<''GOUNTY, PA, do'!lereby dl\putize the sheriff tlf
','York ' , ' , COUNTY to execute this Writ and make return thereof according
to lawo This deputatipn being made atthe request and risk of the plaintiff. ~X)f
- SHERIFF OF _ OUNTY
8. SPECIAL INSTRUCTIONS,OR onlER INFO,RMATION THAT WILL ASSIST 1M EXPEDITING SERVICE:' C umbt~ r. 1 -€l n d ",
OUT OF' COuNrY
CUMBEPJ~ll.ND
1"" ADVANCE FEE FAID BY CUMBERLAl\1D COUNTY SHERIFF
'.'
.,'>'
~. ,.' . ,
. NOTE ONLY APPUCABLE ON WAit OF ,EXECUTION: 'N.B. WAIVER OF WATCHMAN - Any deputy,.sheriff levying upon 'or atlachlr.rg aJlY property under within writ may leave
same without a watchman, jQ.;c~,~~o,dy.of Wh()me~~r is 'fol,lnd ,in posse~sion, afier notifying person_:9f'l~vy-:~Qf~atta;.~With~l,lHrabilityflfi the part of such deputy or the sheriff t9 any
plaintiff~herein for any Jo~s;dettruption, or ,removal ,of anyprop,erty before sheriff's.sale the\e~t ~,- <<_.__, /:.. ...- , /'"
9'~M~~ttf.A~~sO;l\J~~EY<pRIGINAT9Rll.n~.SIGNATl/RE iE"'-"'~"" _.. .< ~!iIL 11 O~TEFILED
301 Market st., POI30l{'~09,LeIiioyne,Pennslvarii /17043-0109 '717 761-4540 5 31'00
12. SEND NOTICE OF SERVICE COPY- TO NAME AND ADORESS BELOW:: (T~iS'area mu~,.,1:1e completed if notice is ,to be mailed).
Ct~...r land C.ounty Sheriff ' ,,/'
, /
16. HOW'SERVED: PERSONAL ( )
RESIDENCE ( )
:!'OSTED (
POE)Q
6/5/00
SHERIFF'S OFF ( )
iI/lO/OO
OTHER ( )
see REMARKS
M...+It\\aJ
,/'.
_ O\.o"t-,;,..c ~-Mi).j",;;.,,-aCv
!
22. REMARKS: f) \
,~ <:. .'Or"
--:a -,&
-
!vj
43.
.----pro~rytNolary Pubfi~ _,:J'>~ .~ / 46. ~gnalure of Foreign
MY COMMISSION EXPIRES ,:)! ",' ~'Coun Sheriff
50.1 ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE
OF AUTHORIZED ISSUING AUTHORITY AND TITLE
1. WHITE .'lssuingAuthority 2. PINK. Attorney 3. CANARY - Sheriff's Office' 4. BLUE - Sheriff's Office
.f. f
Hose
/-:'So ANS
~1
, ,
</'.". /"
"'/:"7~;"""..).~"'_'
47.D,8le, "" i,"J
t, 11:). .....\,.
48. Dale
/n/j.;:"i..j
14th
44. Signature of
De . Sheriff
~ 200( 45. Signature of York
County Sheriff
, ,<C, W.illiam 1;.1..
6/J.4/00
41. AFFi~MED and' subscribed to before me this
42. day of
June
49. Date
51. Date Received
I, '
^"",--,,-->
'..l"
',..-
i'~a
002876-00017/07. 1O.00/EGMlKLT/136291. 1
f '~
;
"
C. A. Hempt Estate, Inc.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
Plaintiff
NO. 2000-3333
v.
CIVIL ACTION -l.A W
Susquehanna Mortgage Bankers Corporation
Defendant
PRAECIPE TO ENTER JUDGMENT BY DEFAULT
TO: The Prothonotary
Please enter judgment in favor of the Plaintiff, C.A. Hempt Estate, Inco and against the Defendant,
Susquehanna Mortgage Bankers Corporation in the amount of $10,802095 plus costs and interest, Defendant
having failed to plead or otherwise respond to the Complaint. In accordance with Pa. R.C.Po 237.1, we certify
that written Notice of Intention to File the Praecipe was mailed on June 30, 2000, and a copy is attached hereto.
Respectfully submitted,
JOHNSON, DUFFIE, STEWART & WEIDNER
By:
~
Edmund G. Myers
Attorney I.Do No. 20558
301 Market Street
Po 00 Box 109
Lemoyne, PA 17043-0109
Telephone: (717) 761-4540
Attorneys for Plaintiff
DATE: '7({J(Oo
i~~
- -- ~
"' ~ ~..
- -~
~...c,
~ ~,. '~ 'liJ,,-l:
".~ 002876-00017/6.30.00/EGMIKLTI136098.1
J ~
.~
.,
FilE COpy
C. A. Hempt Estate, Inc
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
Yo
CIVIL ACTION - LAW
Susquehanna Mortgage Bankers Corporation
No. 2000-3333
Defendant
TO: Susquehanna Mortgage Bankers Corporation
3255 Cape Horn Road
RedLion,PA 17356
DATE OF NOTICE: June 30, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOu. UNLESS YOU
ACT WITHIN TEN (10) DAYS FROM THE DATE OF TillS NOTICE, A JUDGMENT MAY BE
ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TillS NOTICE TO A LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
Cumberland County Courthouse
1 Courthouse Square
Carlisle, P A 17013
(717) 854-8755
< .~ ,~ -- "
~' ^
,---~
""
.h
~'M',)\'!
00_# 002876..{)Q017/6.30.00/EGMIKLT/136098.1
.~
>
'(
JOHNSON, DUFFIE, STEWART & WEIDNER
By
fLJJt--
Edmund G. Myers
Third and Market Streets
P. O. Box 109
Lernoyne,PA 17043-0109
(717-761-4540
Attorneys for Plaintiff
Certified Mail Return Receipt Requested
And Regular Mail