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Home My WebLink About00-03852 ~~ -', "~!l1I~, KOLLAS AND COSTOPOULOS, t/a REGENCY WOODS NORTH MOBILE HOME PARK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 00-3852 v, MICHAEL FORRESTER, KERR! A FORRESTER, and MARGARET FORRESTER, Defendants CIVIL ACTION-LAW PRAECIPE FOR ENTRY OF JUDGMENT OF DEFAULT To the Prothonotary: Please enter judgment for default in favor of Plaintiff, Kollas and Costopoulos, t/a Regency Woods North Mobile Home Park, and against Defendants Michael Forrester, Kerri A Forrester, and Margaret Forrester for Defendants' failure to plead to the Complaint in this action within the required time. The Complaint contains a Notice to Defend within 20 days from the date of service thereof. Pursuant to Pa,R.C.P,DJ, No, 1005 D, Defendants were served with the Complaint via first class mail on July 18, 2000, and Defendants' Aoswers were due to be filed on August 7, 2000, Attached as Exhibit "II:' is a copy of Plaintiff's written notice of intention to file praecipe for entry of default judgment, which I certify was mailed by regular mail to all Defendants on August 10, 2000, which is at least 10 days prior to the filing of this Praecipe. Furthermore, attached as Exhibit "B" is a copy of Plaintiff's written notice of intention to file praecipe for entry of default judgment, which I certifY was mailed by regular mail to the Defendant Margaret Forrester on August 15, 2000, which is at least 10 days prior to the filing of this Praecipe, ~" .' ~,,- ~. Please assess damages in the amount of$1778,68, being the amount demanded in the Complaint. RESPECTFULLY SUBMITTED: KOLLAS AND KENNEDY DATED: r/2-'i/.:;O ~~~ .q'ames W. Kollas, Esquire Supreme Court ill 81959 Kollas and Kennedy 1104 Fernwood Avenue, Suite 104 Camp Hill, PA 17011 (717) 731-1600 ATTORNEY FOR PLAINTIFF ;,'~ .-. 'f-''l''i@;-", : KOLLAS AND COSTOPOULOS, tJa REGENCY WOODS NORTH MOBILE HOME PARK, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 00-3852 v. MICHAEL FORRESTER, KERR! A. FORRESTER, and MARGARET FORRESTER Defendants :CIVIL ACTION-LAW (') c ~ -'- "0 CD nlrn Z:T1 Zr' cl5 'r.-. -<::::: eel -n :?;c- :1,,- ,sd Pc - ~ ~ Margaret Forrester 509 Barry Court Mechanicsburg, PA 17055 o c:> J> \.-.. (7) o -n ::::! r:il;I! n~--;rn <r~ - - 2J ;~2~') ;:'.:)' n );:! :;;:;J -< TO: Kerri A. Forrester 17 Regency Woods North Carlisle, PA 17013 Michael Forrester 17 Regency Woods North Carlisle, PA 17013 DATE OF NOTICE: August 10, 2000 IMPORTANT NOTICE YOU ARE IN DEF AUL T 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 10 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORT ANT RIGHTS. YOU SHOULD TAKE THIS 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: DATE: rJO/e?O Cumberland County Lawyer Referral Service 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 BY: ~#;~' t/ James W. KolIas, Esquire KOLLAS and KENNEDY ill No. 81959 1104 Fernwood Avenue Camp Hill, PA 17011 (717) 731-1600 ATTORNEY FOR PLAINTIFF EXHIBIT I A ,. "~ I' ~ 1 c__ , .'ill;>> ii ii .' I,; KOLLAS AND COSTOPOULOS, t/a REGENCY WOODS NORTH MOBILE HOME PARK, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 00-3852 v. MICHAEL FORRESTER, KERR! A fORRESTER, and MARGARET FORRESTER Defendants :CIVIL ACTION-LAW CERTIFICATE OF SERVICE I, Carole A Rose, of the Law Offices ofKollas and Kennedy, hereby certify that I have this IOID day of August, 2000, served a true and correct copy of IMPORTANT NOTICE by depositing same in the United States mail, first class, postage prepaid, addressed to the following: Kerri A Forrester 17 Regency Woods North Carlisle, PA 17013 Defendant Michael Forrester 17 Regency Woods North Carlisle, PA 17013 Defendant Margaret Forrester , 509 Barry Court Mechanicsburg, PA 17055 Defendant LAW OFFICE OF KOLLAS AND KENNEDY By:CUWLLQ. WK Carole A Rose " ~ "",' - , " KOLLAS AND COSTOPOULOS , t/a REGENCY WOODS NORTH MOBILE HOME PARK, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 00-3852 v. MICHAEL FORRESTER, KERRI A. FORRESTER, and MARGARET FORRESTER Defendants :CIVIL ACTION-LAW 0 0 0 c 0 -n :=;'"., "'" :~J -::::lC-=-' c: ;llfR tTl1T, en Z:T.J -,..,'" Iii ~2 ~~_~ c,.... (.:J , . ',:-'~ (~) ~c--' ---0 "r-T, ~C' -... ;::'-):!.! '::-,-C) ;':;E co>,) ('Scn ::;:-1 ::?.:: (-'> 5J =< .l=" -< TO: Margaret Forrester 42 W. Allen Street Mechanicsburg, PA 17055 DATE OF NOTICE: August 15, 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HA VB 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 YOUACT WITHIN 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 IMPORT ANT 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 Lawyer Referral Service 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 . tfi1," // // ------ BY: .?...-/ '4';:' /~ . //James W. Kollas, Esquire KOLLAS and KENNEDY ill No. 81959' 1104 Femwood Avenue Camp Hill, PA 17011 (717)731-1600.. ' ATTORNEY FOR PLAINTIFF DATE: ~-\~-OO EXHIBIT I b I I I I'~ ~'" , 'l KOLLAS AND COSTOPOULOS, t/a REGENCY WOODS NORTH MOBILE HOME PARK, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 00-3852 v, MICHAEL FORRESTER, KERR! A. FORRESTER, and MARGARET FORRESTER Defendants :CIVIL ACTION-LAW CERTIFICATE OF SERVICE I, Carole A. Rose, of the Law Offices ofKollas and Kennedy, hereby certifY that I have this IS-!:!l day of August, 2000, served a true and correct copy of IMPORTANT NOTICE by depositing same in the United States mail, first class, postage prepaid, addressed to the following: Margaret Forrester 42 W. Allen Street Mechanicsburg, PA 17055 " LAW OFFICE OF KOLLASAl':mKENNEDY ,~i"': BY: ~ iDJ) I;. ,{l. 20JL Carole A. Rose . - ~- CERTIFICATE OF SERVICE I, Dawn E. Barefoot, of the Law Offices ofKollas and Kennedy, hereby certify that I have this 2- "I~ day of August, 2000, served the foregoing PRAECIPE FOR ENTRY OF JUDGMENT OF DEFAULT, by depositing same in the United States First-Class mail, postage prepaid, addressed to the following: Kerri A Forrester 17 Regency Woods North Carlisle, PA 17013 Michael Forrester 17 Regency Woods North Carlisle, PA 17013 Margaret Forrester 42 W, Allen Street Mechanicsburg, PA 17055 LAW OFFICE OF KOLLAS AND KENNEDY BY: D~f(:~ , J;~'" ~l1lIioIIIr!! - . to'-_! COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL FROM JUDICIAL DISTRICT DISTRICT JUSTICE JUDGMENT COM_N PLEAS No. tJ 6 - 31?Od Cu";JJ NOTICE OF APPEAL Notice is given that the appellant has filed in the above Caurt af Camman Pleas an appeal from the judgment rendered by the District Justice an the date and in the case mentianed bel"", CV 12 tT __ (,}(){)()1IJ;3-rr> This black will be signed ONLY when this nato~an is required under Pc. 10088. This Natice af Appeal, when received by the District Justice. will aperate as a SUPERSEDEAS 10 the judgment far possession in this case. Signature of Prothonotary or Deputy /lant was CLAIMANT (see Pa. R.GP.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 (This section of form to be used ONLY when appellant was DEFENDANT (see Pa, R.C.P.J.P. No. 1001 (7) in action before District Justice, IF NOT USED, detach from copy of notice of appeal to be served upon appellee), PRAECIPE: To Prothanot7:" ~ "1},'-' ~ IV Ii>,e f-; 1Yl. H. P , Enter rule upan ~ ~~5 to I> , " Name of appeI~ (Cammon Pleas Na.~~~ within twenty (20) days after RULE: ToA17KtUJ'/t, hJ~.p;.,~~ () Name of awel"''''s) rce.1elU"T IV<>a.+-"- (\0\,)-1, P. (1) You are na~fied that a rule is hereby entered upon yau 10 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 certified or registered maiL . appellee(s), to file a camplaint in this appeal . appellee(s). (2) If you do nat file a camplaint within this ~me. a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. Date: ",.................""',..... - "'..."....... ~ d (p.-~I_,1W~. ' GJ~ fiDPC 312-84 COURT FILE TO BE FILED WITH PROTHONOTARY FI\!jj1r n""[;WlIi T '-"V"":~.,,-M,~~l#~'~~!!!>~ilIllkj!Uliflli.lI'Il' -jf~Uljf " ""'1\'if~~~ , _~J.,l,rrl _, .... ]>."'. ri I I PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof 01 service MUST BE FILED WITHIN TEN (10) DA YS AFTEA fifing the notice 01 appeal, Check applicable boxes) COMMONWEALTH OF PENNSYL,VANIA ' , COUNTY '; Slii AFFIDAVIT: I hereby swear or affirm that I serl/ed o a copy of the Notice 0/ Appeai, Common Pleas No. _ , upon the District Justice d~nated therein on (d.le 01 service) 0 by personal service by (Gerti/ied) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) , on , 19__ 0 by personal service 0 by (certitied) (registered) mail, sender's receipt attached hereto, o and further ttlat I served the Rule to File a Complainl accompanying the above Notice 01 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 (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF ,19__ Signature of affiant Signature of official before whom affidavit was made Title of official My commission expires on ,19_-" f f r- f it CJ C) o "',1 () c: s: '"'Oee [I;J [}~ ~-~ ,Zj~< ~2: ~Cj 4C1 -!-:=C> )>e: Z; =< ~- ::;;.: -0 ...,.." i= -';~8 ' -"i:j ,L) ~,l.~, >~,~ .~n r2:~ ~ 55 '< F-..) ....J , - , . t'l1 09-3-03 ""~ '-' ~- PQJ-311o.;)~ NOTICE OF JUDGMENTITRANSCRIPT PLAINTIFF RESIDE~.!!~AhR~s~ASE 'REGENCY NORTH M. H. P. -, 7099 CARLISLE PIKE CARLISLE, PA 17013 L ~ ,..,..,~",....-.,,, ~ - ~ , COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag.Olst.NO,: OJ Name: Hon Address. SUSAN'K. DAY 229 MILL STREET, BOX 167 MT. HOLT~Y SPRINGS, PA VS. T,I'phoo" (717) 486 -7672 17065 DEFENDANT: NAME and ADDRESS 'FORRESTER, MICHAEL, ET AL. 17 REGENCY WOODS NORTH CARLISLE, PA 17013 L Docket No.: LT- 0000103 - 00 Date Filed: 5/09/00 -, KERRI FORRESTER 17 REGENCY WOODS N CARLISLE, PA 17013 -.J THIS IS TO NOTIFY Y9U THAT: Judgment: FOR PLAINTIFF 1:':1 . . ~ Juagment was entered for: (Name) REGENCY NORTH M.H. P. r::l Judgment was entered against FORRESTER, MICHAEL lXJ Landlord/Tenant action in the amount of $ 1. 778.68 on 5/23/00 The amount of rent per month, as established by the District Justice, is $ The total amount of the Security Deposit is $ . 00 " in a (Date of Judgment) .00, , Total Amount EstabliSh{d ~8~J Less' Security Deposit AP~Wd = Adjudicaled~~ounk RentmArrears $, .05 -$ . = $ ,.0 Physical Damages Leasehold Property $ . 00 $ . 00 $ . 00 Damages/Unjust Detention $ .00 - $ .00 $ .00 Less Amt Due Defendant from Cross Complaint - $ .00 Interest (if pr0vided by lease) $ 00 0 UT Judgment Amount $ 1.683.05 Attachment Prohlbited/ Judgment Costs $ 9.5...Jil Victim of Abuse (Act 5,1996) Attorney Fees $ 00 0 This case dismissed without prejudice, Total Judgment $ 1,778.68 [!J Possession granted. Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ Possession granted if mane jud ment is nOl saUSlleu 0\' lime 01 eVICLlon. B o o y g y o Defendants are jointly and severally liable. Possession not granted, Levy is stayed for days or 0 genera~!)' stayed. Objection to Levy has been filed and hearing will be held: Date: Place: Time: IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUOGMENT FOR POSSESSION WITHIN TEN OAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS OF THE COURT OF COMMON PLEAS,CIVIL OIVISION, THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUOGMENT, IF ANY. ,IN OFlOER TO OBTAIN A SUPERSEDEAS, THE APPELLANT MUST DEP9SIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF THREE MONTHS RENT OR THE RENT ACTUALL YINARREAflS ON THE DATE THE APPEAL IS FILED, IF APARTYWISHE'S to APPEACbNLY THE M0NEY POR:nON OF A JUDGME,tH INVOLVING A RESIElENTIALLEASE, THE PARTY HAS 30 DAYS AFTER THE DATE OF 'ENTRY OF JUDGMENT iil'WHICH TO. FILE A NOTiCE OF APPEAL WITH THE, PROTHONOTARY/CLERK OF couRrs OF THE COURT OF COMMON PLEAS,'CIVIL DIVISION. \ .',' THE PIIRTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NGlTtGEOF JUDGMENT/TRANSCRIPT FORM WITH THE NOTICE OF APPEAL. ''.1" ) Date ' """ , District Justice IS IS a true an correct copy 0 li1gs containing t e JU gment. Date '-.. '. :' , District Justice My commission expires first Monday of January, 2004, Anpl:<\1,'iA_(0lQ SEAL ~Jl'i ""'''''''-'illl,,~s~~U!':~_~tii;&'i'';''fl.'''':"'-'-'-"~''.''~'"'t,"@.jj&_,L.Jii.llm~<' "iIIIIi'- '='~H 0;' ~~l1li\W.1i!!iIj o C Vf~ nli':~ :z:t_,:,,! [i/:- IE ....-:: =2 ~~ ~ ~ --1 ,....-1 -l:::: ~ . Q.) OJ iItr~..........,~.=-"""",," & ~-i , ,~ ~--:::.: ~, C) "J'i (-- :~~ I"",,' "~I ,\-:1 "";() ;:j;~ ~j .iJ -< " ~~~" C'. no _1iJ ~"!IiIUillllllll.~,1l\1!Pl.Jlm~~~IlII~"'~~I*I!III<:iI,.rIl\l~f,.,!~;JliI!~L~ql\\"""" COMMoNWEALTHOF'PENNSY~VANIA NOTICE OF APPEAL , " COURT OF C '~N PLEAS FROM JUDICIAL DISTRICT DISTRICT JUSTICE' JUDGMENt COMMON PLEAS No. , ()()-~~ NOTICE OF APPEAL Notice is given th<!l 'If)e appellant has filed in:the abOve Court, of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case mentioned below. I MAG 'Or ~3:'03 STATE .41 ~ , CV 1\1 tT'" O()(x)/IJ3-4X> This block will be ,signed ONLY when this notation is required under Po. 100Ba , This Notice of Appeal, when received by the d District Justice. will operate as a SUPERSEDEAS to the judgment for possession in this case. Signature of Prothonotary or Deputy ellant was CLAIMANT (see Pa, R.CP.JP. No. to01 (6) inaction before District Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. ", PR,AECIPl TO ENTER RULE TO FILE COMPL,A, INT AND RULE TO FILE . , c. -.' , (This section of form to be used ONLY wheh appellant was DEFENDANT (see Pa. R.C.P.J.P. No. " ',~ IF NOT USED, detiK;~trom copy of notice of appeal to be served upon appellee). PRAECIPE: Todll.," :.,'-,.... ,,":\l!W> .,' "'~M/J ' "~ I I} tiP Enter rule upon_"fi~'~5:i tat!'tJfJt., :rfl m . . '7' ~..I , Name 01 appel e(S) (Common Pleas N~'"!i;~~ within twenty (20) days after ' 1001 (7) in action before District Justice, . appellee(s), to file a complaint in this appeal RULE: Ta _ 1l;zP&x{fj/JJtiit,!l! fifJ' -: ('''J ',::!,/ ~0I awe'/fle(s) , '0, ,dppell~s)."'" 'of- ,;',[, ,:f " (1) You are notified ;ilqt a rUI~~;hereby entered~Pen you "" file a c~laint in this apj)'eal within twenty (20) days t.lter the date of service of this ru!~ ~~ you -1?x persoi;_~~~service or by certified or registered maiL ''ll;, '._ ... ,-""; -~~I"":'-~;~', ~~'~\\;, ) ',: , >-"-@;~:~~d~':fI\~~~i!;()IT1pIQint w~hin this time. a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOu. -A';'::~',"~ ,,:~~"t"f::t:;:;..:. '- ;\ri.I, \.::- f,{,f:~,~~),",T,';:'~"" ',f,f,',' ,.':,.",""'_..._"'""'"'......~~,~" _' d' k)L~" " 2' (.~k~""" t, ~ 1f;1 '-f --. """,'O.,p,"-' '..~ . W(", " ~...:-.,.. .'~ -I,,, '. {, ~ ' . ;.<: ',~'J :~;~ '" '\ ~ -\'~" if, .-/ ~:' Signature of ,,1 - .t, ,~. -!1J'~~,,:"~;.&~; -;; "'" .~' _:,:~ ~ ':,,_, '_' ".,"5i.._(<.'T."',-.;;._'~t~ '.-' ;;.1 ':~~, . __, '\'<< . ~-f' .~ ~::;.,.",~. ,{;$':!iE,,' Il,' r",,:\, ' "".1, ...---: "1~}\"//,>,' "-"". ,"-,'\f':;"'~~~ "..iii:, .~'% (.;,..,'-"', ~ '~f:.,'~;\~;~~",,~J;ik;irE "', , -;10' ~,. ., __M N:JPC 312.84 COURT FILE ',0....'-"""'"_-,._'"',_<"',""""...'<>,"'",,.,, """,' ..,., ", "',.H',",'C"'" ,,,,,,,",,,,,",,,,...~-,,, .' '-"', , ,",,--~~..:. - """"".i;"".""...~",,,-,~.--,,,.,,,~~, '_'J <"- , ".i~ffi:,.jii_Iil!Jj<~lllij~i,~"''''''''-<i?i'i'';B'''-\,~j;;i;.#:~]jUJil'~;il~~~~~~-,::"'11/-",:,;:'r~:~~, lC ,,_~.[,-ll!;:: .,"'0'''':''7' ,-',,-t '1- n,~l:J" ~ ., ~o .~,-'~-i;l&j~r-ji'j~~~J~~~,..:,'~',''''V"~""~< -:1, :~ PROOF OF SERVICE Of NOTICE Of APPEAL AND RULE TO FILE COMPLAINT (This proof 01 service MUST BE FILED WITHIN TEN (10) DA YS AFTER filing the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYlVANIA COUNTY OF I':...vM.13 ~t..--A-NJ) , ;.. AFFIDAVIT: I hereby swear or affirm that I served, " '( [if a copy of the No~ce Qj ApP'*!,'ff.o~rTJFW,fleas No. ~""32;5,;(Q.Vl upon the District Justice designated therein on (dat~ of service) . J(,I fie <l-9 I d:S1W. " JZf ~ personal servic ,Db tilied) {registered) mall, sender's receipt attac~g ]lereto, and upon the appellee, (name) :J5f!jPnc , on ,~ex,!",,::: , }ff;;M1/IL JZf by personal service 0 by (certitie (registered) mail, sender's receipt attached hereto, and further Ulat I served the Rule to File a Complaint accompanying the above Notice ot Appeal upon theappeilee(s) to whom the Rule was addressed on , 19_,0 by personai servioe 0 by (oertified) (registered) mail, sender's receipt attached hereto, SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS ~'7 r!2. DAY OF ::r.:JNL , 'J'S.-<ilwo My commission explf8s on ~)O\ll:.M-OwtZ ,~3 ,0 ~ -OW mrn Z::o ~S; ~e5 ~8 )>c: ~' , Notarial Seal Public "_~~ GouIfef. ~and CountY . ~~1:=Nov.17.200S MembOr, ""rlnsyIVanla A~ at Nota~es ~-, ~-^, ""'",~"'~~'^---- .___C o o C- c: :z t,l) o ~ --0 :x ~ N -' ~~:n . " -'jm :i::J0 oh :2+i 06 Zm o ?E -< , , - 'i'-,',&':'-;*,,!<""''>-,~''1-- s . ~~'-; ;,,1 \;'1o?i .f!<;;J - , .,.,iJiII\",',',," H,f.~ .", .... KOLLAS AND COSTOPOULOS , t/a REGENCY WOODS NORTH MOBILE HOME PARK , Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL VANIA :NO, 00-3852 v, MICHAEL FORRESTER, KERR! A FORRESTER, and MARGARET FORRESTER Defendants : CIVIL ACTION-LAW TO: Margaret Forrester 42 W, Allen Street Mechanicsburg, PA 17055 DATE OF NOTICE August 15, 2000 IMPORTANT NOTICE YOU ARE IN DEF AUL T BECAUSE YOU HA VB 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 10 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS, YOU SHOULD TAKE THIS 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 Lawyer Referral Service 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 ; p:J , /)././ ------.- BY: t~,....-/ ~~ /"James W, Kollas, Esquire KOLLAS and KENNEDY ill No. 81959 1104 Fernwood Avenue Camp Hill, PA 17011 (717) 731-1600 ATTORNEY FOR PLAINTIFF DATE 1>-\~-OO - , . . {" ~"J"r' - KOLLAS AND COSTOPOULOS , t/a REGENCY WOODS NORTH MOBILE HOME PARK, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 00-3852 v, MICHAEL FORRESTER, KERR! A. FORRESTER, and MARGARET FORRESTER Defendants :CIVlL ACTION-LAW CERTIFICATE OF SERVICE I, Carole A. Rose, ofthe Law Offices ofKollas and Kenoedy, hereby certify that I have this IS-#) day of August, 2000, served a true and correct copy of IMPORTANT NOTICE by depositing same in the United States mail, first class, postage prepaid, addressed to the following: Margaret Forrester 42 W. Allen Street Mechanicsburg, PA 17055 LAW OFFICE OF KOLLAS AND KENNEDY BY: CmlllltJJJL Carole A. Rose 1I"""""'."t,^ . . KOLLAS AND COSTOPOULOS, t/a REGENCY WOODS NORTII MOBILE HOME PARK, Plaintiff :IN THE COURT OF COMMON PLF;e\S,OF :CUMBERLAND COUNTY, PENNSYLV ANlA :NO. 00-3852 v. MICHAEL FORRESTER, KERR! A FORRESTER, and MARGARET FORRESTER Defendants :CIVIL ACTION-LAW NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief 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 Lawyer Referral Service 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 . , KOLLAS AND COSTOPOULOS, t/a REGENCY WOODS NORTH MOBILE HOME PARK, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLV ANlA :NO. 00-3852 v. MICHAEL FORRESTER, KERRI A. FORRESTER, and MARGARET FORRESTER Defendants :CIVIL ACTION-LAW COMPLAINT AND NOW comes the Plaintiff, Kollas and Costopoulos, t/a Regency Woods North Mobile Home Park, by and through its counsel, Kollas and Kennedy, and respectfully represents as follows in support of this Complaint: 1. Kollas and Costopoulos is a Pennsylvania partnership, comprised of William C, Kollas and William C. Costopoulos, whose principal place of business is 1104 Fernwood Avenue, Camp Hill, Pennsylvania 17011, and is the Plaintiff herein. 2, Michael Forrester is an adult individual residing at 17 Regency Woods North, Carlisle, Pennsylvania 17013, and is a Defendant herein. 3. Kerri A. Forrester is an adult individual residing at 17 Regency Woods North, Carlisle, Pennsylvania 17013, and is a Defendant herein. 4. Margaret Forrester is an adult individual residing at 17 Regency Woods North, Carlisle, Pennsylvania 17013, and is a Defendant herein. 5. On August 23, 1997, the Plaintiff entered into a lease with Defendants; a copy of said lease is attached hereto as Exhibit "A." ~~ - -' ~~ . -~,- DRIVEWAY MAINTENANCE 6. The Defendants have breached said lease by failing to comply with Paragraphs 10 and 18 of said lease. 7. Paragraph 10 of the lease provides: "10. The Lessee shall take good care of the premises and shall maintain the prelll1ses in good condition, and upon vacating the premises, either premises III good order and condition, wear and tear from a reasonable use thereof, and damage by the elements not resulting from neglect or fault of the Lessee excepted. The Lessee shall neither encumber nor obstruct the sidewalks, driveways or yards, but shall keep and maintain the same in a clean condition, free from debris, trash, refuse, snow or ice. Lessee further agrees to maintain the premises so that grass or other ground cover, excluding shrubs, trees and flowers, shall not be permitted to exceed three inches in height." 8. Defendants breached Paragraph 10 by failing to maintain the driveway and related area at 17 Regency Woods North, Carlisle, Pennsylvania 17013 in a clean condition. 9. Paragraph 18 of the lease provides: "18. The Lessee shall conform to all rules and regulations made by the Lessor for the use and government and management of this mobile home park to protect the entire premises of the Lessor and to further the general comfort and welfare of all of the occupants, which the rules and regulations, and any changes thereto hereafter adopted, are attached hereto and incorporated herein or reference, and made a part hereof, and are covenants and conditions of this Lease, the same as if fully set forth herein. Lessor shall furnish with notice of all changes in said rules and regulations. Lessee acknowledge receipt of a copy of such regulations concurrent with execution of this Lease." 10. On or around October 21, 1999, and in accordance with Paragraph 21 ofthe lease, the rules and regulations for Regency Woods North were updated; a copy of said rules and regulations is attached hereto as Exhibit "B." 2 l j ~ ' 11. Section 2d of the rules and regulations provides: "2d. Lessee may not encumber or obstruct the sidewalks, driveways or yards, Lessee is responsible to keep and maintain the same in a clean condition, free from debris, trash, refuse, snow and ice. Lessee further agrees to maintain the premises so that grass or other ground cover, excluding shrubs, trees and flowers, shall not exceed three inches in height. If a lot is neglected, management reserves the right to take over its care and bill the lessee for the cost of maintenance." 12. Defendants have breached Paragraph 18 of the lease, through Section 2d of the rules and regulations, by failing to maintain the driveway and related area at 17 Regency Woods North, Carlisle, Pennsylvania 17013 in a clean condition, 13, Section Sf of the rules and regulations provides: "5f Immobilized or disabled vehicles are not permitted on the premises. Lessee may make minor repairs on a vehicle on a proper parking space, but is not allowed to place the vehicle on jacks or blocks. Performing major repairs or the draining of crankcases and radiators are prohibited." 14. Defendants have breached Paragraph 18 of the lease, through Section 5f of the rules and regulations, by conducting major repairs to vehicles on the driveway and related area at 17 Regency Woods North, Carlisle, Pennsylvania 17013, causing damage thereto. 15. On or prior to March 28,2000, Plaintiff became aware of Defendants above-stated breaches and sent notification thereof to Defendants, 16. On or about May 2,2000, Plaintiff had an appraisal commissioned to determine the cost to repair damage done to the driveway at 17 Regency Woods North, Carlisle, Pennsylvania 17013. 3 17, Said appraisal cost was determined to be $1402.00. 18. Defendants owe Plaintiff $ 1402.00 to repair the driveway at 17 Regency Woods North, Carlisle, Pennsylvania 17013. RENT DUE 19, Defendants have breached said lease by failing to pay rent. In addition, under Paragraph 17 of the lease, there are corresponding late charges and attorneys fees in the amount of fifteen percent (15%) of the amount owed, As of May I, 2000, these costs totaled $561.05; however, on or around May 9,2000, Defendants did submit $280.00 toward the aforementioned total, leaving $281.05 left unpaid, due and owing. 20. Plaintiff properly posted and sent notification to the Defendants setting forth Defendants' failure to pay rent and late charges as per the lease and rules and regulations. 21. Defendants owe Plaintiff $281.05 left in unpaid rent, late charges, costs and attorneys fees. VEHICLE LACKING VALID LICENSE PLATE 22. Section 5g of the rules and regulations provides: "5g. Any vehicle not bearing a current, valid inspection sticker and license plate may not be kept in the community under any circumstances. The vehicle will be towed away and stored at lessee's expense without notification. " 23. Defendants have breached Paragraph 18 of the lease, through Section 5g of the rules and regulations, by allowing a red Chevrolet pick-up truck, without a current license plate, to be parked on the driveway at 17 Regency Woods North, Carlisle, Pennsylvania 17013. 4 ~< -0 -.. """ 24, Plaintiff properly posted and sent notification to Defendants concerning the aforementioned breach. APPEAL FROM DISTRICT JUSTICE 25. This case was heard before District Justice Susan K. Day, and judgment was entered in favor of Plaintiff in an amount of$1778.68, along with possession. A true and correct copy of said judgment is attached hereto as Exhibit "C." 26. Appeal was taken by Defendant Kerri A. Forrester, who served said appeal to Plaintiff's agent on June 29, 2000, 27. As ofJuly 18, 2000, Defendants owed Plaintiff $1778.68. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant judgment in Plaintiff's favor for payment of the sum of $1778.68 together with additional costs and damages as this Honorable Court sees fit. The Plaintiff also respectfully requests possession of the premises, RESPECTFULLY SUBMITTED, DATE: ?kP2 . .L. @~~ ~es W. Kollas, Esquire KOLLAS AND KENNEDY J.D. No. 81959 1104 Fernwood Avenue, Suite 104 Camp Hill, Pennsylvania 17011 Telephone: (717) 731-1600 ATTORNEY FOR PLAINTIFF 5 . KOLLAS AND COSTOPOULOS, t/a REGENCY WOODS NORTH MOBILE HOME PARK, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLV AN1A :NO. 00-3852 v. MICHAEL FORRESTER, KERR! A FORRESTER, and MARGARET FORRESTER Defendants :CIVIL ACTION-LAW VERIFICATION AND NOW James W. Kollas verifies that the statements made in this COMPLAINT are true and correct to the best of his knowledge, ioformation and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities, By virtue of the fact that the Plaintiff's manager, Lynde Renard, is unavailable because of an unforseen emergency and her signature cannot be otherwise obtained within the time allowed for the filing of this pleading, the pleading is submitted by counsel having sufficient knowledge, information and belief based upon the information provided him by the Plaintiff's manager. Dated: 7/;rft? z..- ~~ Japres W. Kollas . --If\:, KOLLAS AND COSTOPOULOS, tJa REGENCY WOODS NORTH MOBILE HOME PARK, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL V AN1A :NO. 00-3852 v. MICHAEL FORRESTER, KERR! A FORRESTER, and MARGARET FORRESTER Defendants :CIVIL ACTION-LAW CERTIFICATE OF SERVICE I, Carole A Rose, of the Law Offices ofKollas and Kennedy, hereby certify that I have this \8 fu day of July, 2000, served a true and correct copy of COMPLAINT by depositing same in the United States mail, first class, postage prepaid, addressed to the following: Michael Forrester and Kerri A Forrester and Margaret Forrester 17 Regency Woods North Carlisle, PA 17013 Defendants LAW OFFICE OF KOLLAS AND KENNEDY BY~~Cl.~~ ^~j CI\HI.lSI,B, 1'ImNSYI.VI\NU\ nllD 5.?-~~ _co '-fd.~~c50' . ~4t. LOT NUMIH:H 17N , " IlBGl':NCY NOH'I't1 MOIl'll.1'. IIOME PI\HK 7099 CI\RI.IBI.P. PIKI'. PIION~: : 766-1771 MI\DE THIS ;.1. 3 DI\Y 01' COSTOPOULOS, LESSOR AND k-erY\ tOrrester: LI.,I\~;: ^G\~~~:M8N,[, 4uQus-t .' 1'1 <11 , .... ' . M rivnqr(+ +o(rcs-k\', BY MID B8TWEEN I<fJLr,I\SMNIJ AND mlcM:l.1 p..nrL_ IJESSEE.: Whereas, Lessor owns and operates a mobile home park in which Lessee ~esires to occupy a mobile home site. NOW 'fillS I\GREEMENT WI'l'NES5E'l'lI, that the parties hereto, for and in corsideratlon of the mutua! covenants contained herein, and intending to be legally! bound hereby agree as follows; 1. The rent shall be day of each month. $ ::lOO per +JI./O p~~('c:. ~ ;1 ltD. month, payable p1()ve }f'1 on the first , ck+~ ~v~. ~(." JQ"f7 the first Se ,,-t, cons'trued like term 2. This Leas'~ shall be ror a term of one month, commencIng on day of S~.-t- ,19. <::\1 , and terminate on the last da~ of , 19. wJ ( , provideCl""'tliar: a holding over by the tenant: may be by the Lessor, at his option, as a renewal of this Lease fat another and condition of this Lease. 3. Occupants, 'l'enant and JJandlon1 agree the following persons and no other will occupy the leased premises. NAME I\Gl': m ichmJ fOr(cs-k', 3" Kerrt fO((t:Skr' c9'd. 'J'"bseph m. Grey :;?.s- 4. Tenants shall, upon execution of thIs Lease, deposit with Landlord as security for t:1e performance of all the terms, covenants,' and conditions of this Lease" a sum in the amount or one month's rent, to be retained by the Landlord until the end of the original term and any extended terms of this Lease. Upon termination of this Lease, by default or otherwise, ~he security deposit shall be returned to tenant, less any charge for dambge to the leased premises, rent arrearages, or charges treated as rent arrearag~s. l'enant agrees to leave a forwarding address with the Landlord upon vapation Df the leased premises to facilitate the return of the security deposit as above set forth. 5. The Lessee agrees to and shall sve, hold and keep harmless and indemnify the Lessor from and for any and all payments, expenses, costs, attorneys fees and from and for any and all claims and liabilities fat losses or damage to property or injuries to persons occasioned wholly or in part by or resul ting f rom any act or ommissions by the Lessee or the Lessee's. gues ts I licensees, invitees, or for any cause or reason whatsoever arising out of or by reason of occupancy by the Lessee. 6. If the demised premises shall be taken und~r eminent domain or condemnation proceedings, or if the l,essor conveys the said premises to any governmental authorities seeking to lake the said premises, or if there is a change in the use of the park land, or parts thereof, or termination of the park, then this Lease, at the option of the Lessor, shall terminate and the term hereof shall end as such date as the fJessor shall fix by notice. Lessee shall have no claim or interest in the compensation received by Lessor [or such taking. 7. I f the LeElsee sha 11 fa il to comply wi th any condi tlot;'s covenant~ hereof, the Lessor may perform such conditions and covenanj the cost ~nd expense of the Lessee, and the said costs and expenses s added to the next installment or rent and shall be payable as s~ch. , , , and EXHI81T ~:iL-- AI.I.-STATE~ INTERNAnO~AL - ~. <, I 8. The Lessee agrees that the Lessor and the Lessor's a ants ~~~nOt~:ss~fdother.rep~esen~at~ves, shall have the right to enter int; and' ohr any part th~~:~~~e:tc~r~"~~~~~n~tl~h~o~~~,W~~~ht~~ ~~~p~~~j~~te~:mf~f~gLeaSe t e same or mak1ng such repa' It . f th 1r or a erat10ns therein as may be necessary or e safety and preservation thereof. This clause shall not be deemed to be cOfvenant by the Lessor nor be construed to create an obligation on the part o the Lessor to make such inspection or repairs. . , 9. All goods and personal property of any kind in or upon the leased prem1ses shall be the sole responsibility of the Lessee, and in no event shall Lessor be liable for any los,S or damage to said goods or property for any reason what'soever. " 10. ~he L7ssee shall ta~e good care of the premises and shall ma.1nta.1n t~e p-:em1ses 1n good condit10n~ and upon vacating the premises, either at t~e eX~1rat1on of the term or for any reasons, shall deliver the rented prem1ses 1n good order and condition, wear and tear from a reasonable use thereof, and damage by the elements not resulting from neglect or fault of the Lessee excepted. The Lessee shall neither encumber nor obstruct the siclewalks, driveways or yards, but shall keep and maintain the same in a clean condition, free from debris, trash, refuse, snow or ice. Lessee furthe~ agrees to maintain the premises so that grass or other ground cover, exclud1ng shrubs, trees and flowers, shall not be permitted to exceed three inches in height. 11. The Lessee may not sublet the premises or any portion or part thereof. The Lessee may sell the mobile home belonging to the Lessee, but, following the sale, if the mobile is to remain in the park with a new owner, written approval of the new Lessee is required, and this approval must be obtained prior to sale. 12. Lessor shall not be liable for failure to give possession of the leased premises to the Lessee upon the effective date of this Lease. In such event, rental payment and other fees, charges or assessments shall not commence until possession is given to, or is made available to the Lessee, and the term of the Lease shall be extended accordingly. 13. Any equipment, fixtures, goods or other property of the Lessee not removed by the Lessee upon quitting, vacating or abondment of the premises by the Lessee, or upon the Lessee's eviction, shall be considered as abandoned and the Lessor shall have the right, without notice to the Lessee, to sell or otherwise dispose of the same at the expense of the Lessee and shall not be accountable to, the Lessee for any part of the proceeds of the sale, if any. 14. The Lessor shall not be liable for any damage or injury which may be sustained by the Lessee or any other persons, as a consequence of the failure, breakage, leakage or obstruction of the water, sewer, waste, or soil pipes, or the electrical, gas or oil system; or by reason of the elements; or resulting from the carelessness, negligence or improper conduct on the part of any other Lessee or the Lessor or the Lessor's or this or any other Lessee's agents, guests, licensees, invitees, sublessess, assignees or successors; or attributable to any interference with, interruption of or failure, beyond the control of the Lessor, of any services to be furnished or supplied by the Lessor. 15. The various rights and remedies of the Lessor expressed herein are cumulative, and the failure of the Lessor to enforce any such right or remed} at any time against the Lessee shall not constitute a waiver thereof. 16. Lessee shall pay all county, municipal and school district real estate taxes assessed and levied against his home and personal property, and shall furnish Lessor, when requested, with proof of payment of same. Failure to 'pay such taxes, when due shall be a violation of the Lease, rules, or regulations, if any, and constitute default thereunder. 17. The Lessee hereby confesses judgement in favor of the said Lessor for the whole amount of the rent at any time remaining unpaid, and any other. charges incurred hereunder, whether the same shall have been due or not, waiving a stay of execution, inquisition and all exemption laws now in force or which may hereafter be passed, and authorizes the adding of Fifteen (15%) per cent attorney's commission for the collection; and further does hereby, upon breach of any of the conditions of this Lease, including non-payment of rent or violation of rules and regulations, if any, authorize any attorney of any court of record to appear for him and enter an amicable action of ejectment and confess a judgement of ejectment therein for the premises herein described and ).<=s _autl~Qrize the immediate issuing of a writ of possession and execution for )st without asking leave of the court. A photocopy of the Lease moy be usedj Jr confession of judgement for unpaid rent, of for confession of judgement in jectment. Such remedies shall be cumulative, and not alternative, and may be !-exercised as necessary. lB. The Lessee shall conform to all rules and regulations made by Ie Lessor for the use and goveL-nment and management of this mobile home pork ) protect the entire pn!mises of the Lessor and to further the general 'mfort and welfare of all of the occupants, which rules and regulations, an~ 'Y changes thereto hereafter adopted, are attached hereto and incorporated "rein or reference, and made a part her'eof, and are covenants and condi tion',,' this Lease, the same as if fully set forth herein. Lessor shall furnish ,th notice of all changes in said rules and regulations. Lessee acknowledge~ !ceipt of a copy of such regulations concurrent with execution of this Lease. 19. If proceedings shall be commences by Landlord to recover )ssession under Acts of Assembly, either at the end of the term or sooner !rminations of this Lease, or for nonpayment of rent, or for any other reason !nant specifically waives the right to fifteen or thirty days' notice !quired by Act of Assembly of Aprir 20, 1983. P.L. 202, and agrees that five IYs' notice shall be sufficient in either or any such case. 20. The Lease, and the aforesaid rules and regulations, constitute Ie entire agreement between the parties and same is not subject to any oral Jdification. Further, this agr:eement shall be legally binding upon the par:ties !reto, and their respective heirs, successors and assigns. If any information ~ovided by the Lessee, whether by way of background, financial or otherwise lich has induced the Lessor to enter into this Lease, is found by the Lessor: ) be false, the Lease shall, at the option of the Lessor and upon notice ) the Lessee, be null and void and the Lessee shall be considered a tresspasser. 21. Lessor may from time to time modify, change or revoke rules [or 1e mobile home park and upon notice to the tenant, these rules shall be incor- Jrated herein with the same force and effect as though they were in force at ~e time thi~ Lease was executed. 22. Lessee agrees that he has read this Lease Agreement, under- tands its terms and the rules and regulations of the mobile home park and grees to be bound thereby. 'I'HE TENANT MUS'I' GIVE A'I' LEAS'I' 30 DAYS NOnCE IN WRITING PRIOR MOVING. IT IS 'I'HE RESPONSIBILITY OF THE 'I'ENAN'l' 'I'O PROVIDE MANAGEMEN'l' WI'I'Il L NECESSARY COMPLETED STATE OR LOCAL GOVERNMENT FORMS. IN WITNESS WHEREOF, the parties hereto have hereunder set their nd and seals the day and year first above written. ~ / {.t"L/ \ ~ DY:,~"" ~ A~ LI\N15L D , T aif/ f_ '+~ ~if~~ . NI\N'I' ~~~ - , '. __ ___0_ DISCLOSURE FOR CONFESSIONS OF JUDGEMENT I AM (WE ARE) SIGNING, THIS ~3 DAY OF /{UJU'S't: 9 "1_, A LEASE FOR A MOBILE HOME SI'I'E AT LO'I' NO. /7 fU A'i' REGENCY NOR'I'H OBILE HOME PARK FOR AN INI'I'IAL 'I'ERM OF ONE MON'I'H, AND MON'1'II '1'0 MON'rll TIIERE- F'I'ER, WHICII WILL OBLIGATE ME (US) TO A MON'I'IlI,Y RENTAL OBLIGA'I'ION OF ~';;2rD ~\-~ :\d\d) .(:P EACH, PAYABLE IN ADVANCE. INI'I'IALS: 1::.1 ,;/( C/ A REPRESEN'I'A'I'IVE OF REGENCY NOR'1'1I MOBILE 1I0ME PARK liAS EXPLAINED o ME (US) 'I'HA'l' THE LEASE CONTAINS WORDING 'I'IIA'I' WOULD PERMIT TilE LANDLORD o ENTER JUDGEMEWi' AGAINST ME (US) A'1' 'i'HE COUH'i'HOUSE FOR (1) TilE EN'I'IRE UNPAID ALANCE OF THE RENTAL OBLIGATIONS OF 'mE LEASE IN 'rHE EVEN'i' '1'IIAT I (WE) ARE N DEFAULT IN THE PAYMENT OF ANY INSTALLMENTS OF RENT OR ANY OTHER SUMS DUE HE LANDLORD UNDER THE LEASE THAT REMAIN UNPAID, AN/OR (2) IMMEDIA'I'E EPOSSESSION Of THE MOBILE HOME SITE PREMISES, IN 'mE EVEN'1' 'I'HA'l' I (WE) BREAK R EVADE ANY Of THE COVENANTS OR CONDI'I'IONS OF 'mE LEASE, WI'1'II0U'1' 'I'HE lUGHT o HAVE PREJUDGMENT NOTICE AND HEARING, WI'l'HOUT THE RIGH'1' '1'0 HAVE THE BURDEN 'F PROOF ON 'I'HE OWNERS, AND WITHOUT 'mE RIGHT TO AVOID THE EXPENSE OF OPENING IR STRIKING A CONFESSED JUDGEMEN'I', AND 'i'HA'1' 'I'HE JUDGEMEN'1' MAY BE COLLEC'1'ED /\ND :NFORCED BY ANY LEGAL MEANS. . /...1 , , -1 INI'1'IALff:t/.~. ;j;;: /If- t. If. ~.;Ji-; IN SIGNING 'I'HE LEASE, I AM (WE ARE) KNOWINGLY, UNDERS'I'ANDINGLY ,ND VOLUNTARILY WAIVING MY (OUR) RIGHTS '1'0 RESIST THE EN'I'RY OF JUDGEMEN'1' ,GAINST ME (US) AT THE COURTHOUSE, AND AM (ARE) CONSEN'rING TO '1'HE CONFESSIONS IF 'JUDGEMENT. INITIAr;s:jifj ifF /1- t: ift,_ CER'I'IFY TIIA'1' MY (OUR) ANNUAL INCOME EXCEEDS (IS LESS BLANKS IN THIS DISCLOSURE WERE FILLED IN WHEN I (WE) IT, AND 'I'HAT I (WE) RECEIVED A COPY A'I' 'I'IIE 'rIME OF I (WE) ;10,000.00, THAT THE :NITIALED AND SIGNED nGNING. WE HAVE RECEIVED A COpy OF HOME PARK INCLUDING A COpy ONE MAY BE EVICTED. THAN) L~1V[. ~ , (SEAL) LSE/\L) ..{, /f~r. ~ , ~;r(p~ . ~Jotu: (SEAL) (SEAL) ",<- '---,' h THIS LEASE HAS BEEN PRE-APPROVED BY THE OFFICE OF THE ATTORNEY GENERAL OF PENNSYLVANIA In the Opinion of the Office of the Attorney General, a pre-approved consumer contract meets the Test of Readability under 73 P.S. Section 2205 of the Plain Language Consumer Contract Act. P!eapproval of a consumer contract by the Office of the Attorney General only means that Simple, understandable and easily readable language Is used. It Is not an approval ofthe contents or legality of the contract. RULES AND REGULATIONS FOR REGENCY WOODS NORTH I. GENERAL I a, Lessee(s), members of his (their) family, his (their) visitors or servants shall not at any time make any noise, do anything or conduct themselves in any way which disturbs any other lessee or interferes with the rights, comfort or conveniences of any other lessee. Musical or sound reproducing instruments or singing shall be inaudible between 10:00 o'clock each night and 8:00 o'clock the following morning. Disorderly conduct, abusive language, noisy disturbances or disregard for the rules and regulations of the park shall be grounds for eviction. Ib, No tenant shall place or permit to be placed or maintained any sign or advertising matter or device or any roof aerial or other structure anywhere on Lessor's property. Offering homes for sale by placing one sign on the property is permitted. Sign must be of normal residential, real estate size. Ie. No peddling or soliciting is permitted in the community without prior consent of management. Lessee(s) is (are) requested to notifY management immediately ifvendors are attempting to solicit on the park premises without authorization and an issued identification card for management --:. Id, Lessee must give lessor a 30 days written notice prior to moving. It is the responsibility of the lessee to provide management with all necessary completed state or local government forms. I e. Mobile homes will have the minimum dimensions of at least 60 feet long x 12 feet wide and shall be no more than Two (2) years old at he time of entry into the community, unless exception is granted by the management. If. Mobile homes may not be brought into the park or removed except under the supervision of the management. The management reserves the right to change, without notice, the assigned space allotted to lessee for their mobile homes or vehicles. Should lessee fail to move hislher property immediately upon request from management, then management may do so at lessee's risk, Lessee hereby gives management the right to remove hislher property and releases EXHIBIT \\bll ALl-STATEI!IINTERNAiIQNAL " .'-'- .' c_ ,~ '0 .~.. -.'--', management from any and all claims or damages which may result therefrom. Ig, ~ard sales, garag~ s.ale~ or any retail activity of either service or personal property will not be penrutted unless penrusslOn IS granted by management. Management reserves the right to approve/deny said sales as determined in its sole discretion. 1~, Lessee(s) agree(s) that Lessor may change these regulations from time to time as may be required to protect the lot or Lessor's property or add to lessee(s) enjoyment of it, Lessee(s) will be advised of changes in the rules and regulations at least Thirty (30) days in advance. 1 i. All business transactions are to take place during office hours, Office hours are between 9:00 a,m, and 4:30 p.m., Monday through Friday. Complaints must be in writing, signed and dated. Ij, Any infraction oftheses rules and regulations constitutes a violation of your lease and is ground for eviction. These rules and regulations constitute part of this lease agreement. 2, MOBILE HOlvlE LOTS 2a. Management reserves the right to inspect lots. 2b. Skirting, as approved by management, must be placed around the home immediately upon set-up and before occupancy of the home or within One (1) week, as approved in writing by management. Management reserves the right to install skirting after Thirty (30) days iflessee has not done so. Lessee will be billed the cost ofinstallation and materials. 2c, Alterations gr additions to the home or lot may not be made by lessee without prior written approval of management. All skirtings, awnings, porches and other additions shall be maintained in good repair. Such additions must match the color of the mobile home. If porches and other additions are not maintained in good repair management retains the right to notifY lessee that such additions must be repaired or removed. Concrete blocks are not allowed to be used as steps. 2d. Lessee may not encumber or obstruct the sidewalks, driveways or yards. Lessee is responsible to keep and maintain the same in a clean condition, free from debris, trash, refuse, snow and ice. Lessee further agrees to maintain the premises so that grass or other ground cover, excluding shrubs, trees and flowers, shall not exceed three inches in hclght. Ifa lot is neglected, management reserves the right to take over its care and bill the lessee for the cost of maintenance. 2e. Planting of flowers, tress or shrubs must first be approved by management, due to underground wiring and piping. All flowers, trees and shrubs that have been planted must remain rooted, even jf, lessee moves. All planting must be at least Five (5) feet away from the street to " - -~" allow for snow removal. 2f. Fences are not permitted. Nothing may be fastened to any trees or shrubbery in the park. 2g, All clothes lines are not allowed, Clothes trees may be installed at the rear of the mobile home, 2h. Swimming or wading pools are not permitted. Washing vehicles, watering grass, and other non-essential water use is not permitted. A fine of $20. 00, per incident, will be imposed for all water abuse. 2i. Only one storage building per lot is allowed. They must be demountable, prefabricated storage units which are placed on concrete or wood approved platforms. Medal sheds are prohibited, Before erection of any storage unit is started, complete specifications describing it shall first be submitted to management. Written approval for such building must be obtained, 2j. AnteMas, i.e., T.V., must be placed to the rear ofthe lot and must not exceed Sixteen (16) feet above ground. They must first be approved by management 2k. Each lot must be kept neat and clean. Storage of bottles, cans, boxes, etc. and/or equipment around the home is not permitted. 21. Oil tanks and gas tanks must be kept painted aluminum or in a color that matches the home. Also, oil and gas tanks must be kept free of rust. The tanks must be placed to the rear of the home and mounted on an approved stand. Footings of cinder block or concrete may be installed at ground level to prevent sinking into ground. 2m. Lessee shall. be solely responsible to maintain tight drains to the sewer outlet. Leaking spigots must be repaired immediately or water will be turned off. Draining or throwing of waste water is prohibited. Do not flush anything that is not soluble, i.e., diapers, cloths, rags, sanitary napkins or items made of plastic or rubber, down your commode or any other drain. Clogged sewers, damage to water connection and/or electrical services must be paid by lessee. 2n. Lessee must arrange for wrapping of home pipes with thermo tape or similar material to prevent freezing. Instal1ation of a thermostat should also be employed. This work must be accomplished no later than November 1 of each year, Any damage resulting from frozen, water pipes will be the responsibility oflessee. Lessee must have main wat~ line shut off for their home other than the shutoff provided by the park. 20. Firearms, BB guns or bow and arrows are not to be used in the park at any time. 2p. Any home which has been abandoned for Thirty (30) days or more may be entered by management, Management will secure loose or moveable appliances, furnishings, materials or , , '~'! supplies and move the home to a storage area or other location. Lessor is not responsible for safeguarding the mobile home or its contents. 2q, Large.items, upon.approval of park management, such as (but not limited to) trampolines must be k?pt m good repair and not compromise the esthetic appearance of the park. Items must be stored m a shed when not in use. 2r, There will be a $100,00 fine imposed for putting snow back into plowed streets, 2s, All homes must have the lot number visibly adhered to the street side of the home, #' s must be a minimum of3". 3. SOLID WASTE DISPOSAL. STORAGE AND FIRE PROTECTION 3a. All garbage must be wrapped and placed in water-tight containers which are to be provided by lessee. Containers must be kept clean inside and out and tightly covered at all times, Place all garbage in the provided dumpsters. 3b. Large items, i.e., bedding and furniture, are not to be placed at dumpsters. Lessee shall be responsible for hauling away such items. 3c, Material that could be a fire hazard or attract insects or rodents are not pennitted to be stored under or aro'und a home, 3 d. First aid fire extinguishers for Class B & C fires shall be provided by each lessee and shall be kept on the premises and maintained in working condition. All fire extinguishers must be accessible at all times. Smoke detectors are required in all homes. 3e. Open fires are not permitted at any time. 3( Residents with wood-burning fireplaces or stoves may store fi,rewood as follows: 1. We will allow only two (2) cords of wood at any given time on site. A cord of wood measures two (2) feet wide, four (4) feet high and eight (8) feet Ion? 2. Wood must be stacked in a neat and orderly manner. No piles of wood Will be allowed. 3. Ifwood is cut on site, the area must be cleaned ofall excess debris immediately. ., " -~ 4. Wood may be stored so long as it is stacked neatly in patio areas or to the rear of the home. . 3g, Lessee is responsible for recycling bin. It will be replaced by lessor at a cost of$lO.oo, Bm must be returned to the office when a tenant moves from the park. 4, PETS . 4a. Pets are not permitted without written permission from management. Absolutely no pets will be permitted that require outside housing. 4b. Pets which are vicious in nature, for an example: Dogs - Pit Bull Terriers, are not permittjld. Pets that are considered "guard dogs" are not pennitted. 4c. Pets are not allowed to be tied outside. Pets, including cats are not permitted to roam, 4d, Dogs must be on a leash at all times. All dog droppings must be cleaned up immediately, 4e. There is a $10.00 charge, per month, for a pet. One pet per home. 5. VEIDCLES Sa, The speed limit in the community is 10 m.p.h. and must be observed at all times. We ask that drivers use their brakes instead of their horns whenever possible. Sb. No one is allowed to operate a motor vehicle in the community without a driver's license, 5c. Motorcycles used in the park must take the most direct route between the entrance and exit and may not be driven around the streets of the community. Most direct route refers to roadway. 5d. Operation or non-conventional vehicles, i.e., minibikes, snow mobiles and go-karts, within the community, is prohibited. 5e. Vehicles must be parked on the off-street parking spaces. 'Parking elsewhere is prohibited particularly in the street or on the grassy part ofthe lot. Extra parking space is available, there will be a monthly storage charge for the additional vehicle(s). Pennission must be requested for the storage of vehicles through management. Lessee must show proof of ownership. Violators will be towed, without notice, at the owner's expense. 5f. Immobilized or disabled vehicles are not permitted on the premises. Lessee may make minor repairs on a vehicle on a proper parking space, but is not allowed to place the vehicle on jacks or blocks. Performing major repairs or the draining of crankcases and radiators are prohibited, '0 "., 5g. Any vehicle not bearing a current, valid inspection sticker and license plate may not be kept in the community under any circumstances. The vehicle win be towed away and stored at lessee's expense without notification. 5h. Overnight parking of commercial vehicles (3/4 ton or larger) is prohibited, except under special written authorization from management. Si. Lessor agrees to set aside a portion of the community for the purpose of storing large items. i.e., boat and boat trailers, and campers which shall be stored at the risk oflessee, These items may be towed at the owners expense, without notice, ifimproperly stored. Lessor shall not be held responsible in case of theft, vandalism or other damage or loss of such item(s). Lessee must show proof of ownership, BY SIGNING THE RULES AND REGULATIONS, EACH LESSEE AGREES THAT THE LESSEE HAD READ AND UNDERSTANDS ALL THE RULES AND REGULATIONS IN THIS LEASE. AGENT FOR LANDLORD: LESSEE(S): DATE: IMPORTANT NOTICE REOUIRED BYLAW "THE RULES SET FORTH BELOW GOVERN THE TERMS OF YOUR LEASE OR OCCUPANCY AGREEMENT WITH TInS MOBILE HOME PARK. THE LAW REQUIRES ALL OF THESE RULES TO BE FAIR AND REASONABLE. "YOU MAY CONTINUE TO STAY IN THIS PARK AS LONG AS YOU PAY YOUR RENT AND OTHER REASONABLE FEES, SERVICE CHARGES AND ASSESSMENTS '"" , . HEREINAFTER SET FORTH AND ABIDE BY TIm RULES OF THE PARK. ENTRANCE AND EXIT FEES MAY NOT BE CHARGED. INSTALLATION AND REMOVAL FEES MAY NOT BE CHARGED IN EXCESS OF THE ACTUAL COST TO THE MOBILE HOME PARK OWNER OR OPERATOR FOR PROVIDING SUCH SERVICE FOR THE INSTALLATION OR REMOVAL OF A MOBILE HOME IN A MOBILE HOME SPACE. "YOU MAY BE EVICTED FOR ANY OF THE FOLLOWING REASONS: "(1) NONPAYMENT OF RENT, "(2) A SECOND OR SUBSEQUENT VIOLATION OF THE RULES OF THE MOBILE HOME PARK OCCURRING WITIllN A SIX-MONTH PERIOD. "(3) IF THERE IS A CHANGE IN USE OF THE PARK OR LAND OR PARTS TImREOF. "(4) TERMINATION OF MOBILE HOME PARK. "YOU SHALL ONI.. Y BE EVICTED IN ACCORDANCE WITH THE FOLLOWING PROCEDURE: "(1) A RESIDENT SHALL NOT BE EVICTED BY ANY SELF-HELP MEASURE. "(2) PRIOR TO THE COMMENCEMENT OF ANY EVICTION PROCEEDING, THE MOBILE HOME PARK OWNER SHALL NOTIFY YOU IN WRITING OF THE PARTICULAR BREACH OR VIOLATION OF THE LEASE OR PARK RULES BY CERTIFIED OR REGISTERED MAll.. AND/OR POSTING TO THE DOOR. "(I) IN THE CASE OF NONPAYMENT OF RENT, THE NOTICE SHALL STATE THAT AN EVICTION PROCEEDING MAY BE COMMENCED IF THE MOBILE HOME RESIDENT DOES NOT PAY THE OVERDUE RENT WITHIN 20 DAYS FROM THE DATE OF SERVICE IF THE NOTICE IS GIVEN ON OR AFTER APRIL 1 AND BEFORE SEPTEMBER 1, AND 30 DAYS IF THE NOTICE IS GIVEN ON OR AFTER SEPTEMBER 1 AND BEFORE APRIL 1 OR AN ADDmONAL NONPAYMENT OF RENT OCCURRING WITHIN SIX MONTHS OF THE GIVING OF THE NOTICE MAY RESULT IN IMMEDIATE EVICTION PROCEEDINGS. "(ii) IN THE CASE OF A BREACH OF THE LEASE OR VIOLATION OF THE PARK RULES, OTHER THAN NONPAYMENT OF RENT, THE NOTICE SHALL DESCRIBE THE PARTICULAR BREACH OR VIOLATION. NO EVICTION ACTION SHALL BE COMMENCED UNLESS YOU HAVE BEEN NOTIFIED AS REQUIRED BY THIS SECTION, AND UPON A SECOND OR SUBSEQUENT VIOLATION OR BREACH OCCURRING WITHIN SIX MONfHS, THE MOBILE HOME PARK OWNER MAY COMMENCE EVICTION PROCEEDINGS AT ANY TIME WITHIN 60 DAYS OF THE LAST VIOLATION OR BREACH. , . ~ ,. ,~ ' ~" ~>" ,- L "YOU SHALL NOT BE EVICTED WHEN THERE IS PROOF THAT THE RULES YOU ARE ACCUSED OF VIOLATING ARE NOT ENFORCED WITH RESPECT TO TIlE OTIlER MOBILE HOME RESIDENT OR NONRESIDENTS ON THE PARK PREMISES. "IN ADDmON, NO EVICTION PROCEEDING FOR NONPAYMENT OF RENT MAY BE COMMENCED AGAINST YOU UNTIL YOU HAVE RECEIVED NOTICE BY CERTIFIED OR REGISTERED MAll.. AND/OR POSTING TO THE DOOR OF THE NONPAYMENT AND HAVE BEEN GIVEN AN OPPORTUNITY TO PAY THE OVERDUE RENT 20 DAYS FROM TIlE DATE OF SERVICE IF THE NOTICE IS GIVEN ON OR AFTER APRIL 1 AND BEFORE SEPTEMBER 1, AND 30 DAYS IF GIVEN ON OR AFTER SEPTEMBER 1 AND BEFORE APRIL 1. HOWEVER., ONLY ONE NOTICE OF OVERDUE RENT IS REQUIRED TO BE SENT TO YOU DURING ANY SIX-MONTH PERIOD. IF A SECOND OR ADDITIONAL VIOLATION OCCURS WITHIN SIX MONTHS FROM THE DATE OF THE FIRST NOTICE TIlEN EVICTION PROCEEDINGS MAY BE IMMEDIATELY STARTED AGAINST YOU, "YOU ARE ENTITLED TO PURCHASE GOODS OR SERVICES FROM A SELLER OF YOUR CHOICE AND THE PARK OWNER SHALL NOT RESTRICT YOUR RIGHT TO DO SO. "IF YOU DESIRE TO SELL YOUR MOBILE HOME, THE MOBILE HOME PARK OWNER MAY NOT PREVENT THE SALE AND MAY NOT CLAIM ANY FEE IN CONNECTION THEREWITH, UNLESS THERE EXISTS A SEPARATE WRITTEN AGREEMENT. HOWEVER THE MOBILE HOME PARK OWNER MAY RESERVE THE RIGHT TO APPROVE THE PURCHASER AS A RESIDENT IN THE MOBILE HOME PARK. "ENFORCEMENT OF THE MOBILE HOME PARK RIGHTS ACT IS BY THE ATTORNEY GENERAL OF TIIE CO:wdONWEALTH OF PENNSYL V ANlA OR THE DISnUCT ATTORNEY OF THE COUNTY IN WHICH TIlE MOBILE HOME PARK IS LOCATED. YOU MAY ALSO BRING A PRIVATE CAUSE OF ACTION. IF YOUR RIGHTS ARE VIOLATED YOU MAY CONTACT THE STATE BUREAU OF CONSUMER PROTECTION OR YOUR LOCAL DISTRICT ATTORNEY." , . " , . . , COMMONWEALTH OF PENNSYLVANIA NOTICE OF JUDGMENTITRANSCRIPT OOUN~OF: CUMBERLAND - PLAINTIFF' RESIDENTIAL LEASE - - 51. No.: 09-3-03 . NAME and ADDRESS 'REGENCY NORTH M.H.P. I OJ Name: Hon. 7099 CARLISLE PIKE SUSAN- K. DAY CARLISLE, PA 17013 Add"", 229 MILL STREET, BOX 167 L .J MT. HOLLY SPRINGS, PA VS. DEFENDANT: NAME and ADDRESS T"'ph",; (717 ) 486-7672 17065 'FORRESTER, MICHAEL, ET AL. I 17 REGENCY WOODS NORTH CARLISLE, PA 17013 REGENCY NORTH N.H.P. L .J 7099 CARLISLE PIKE Docket No.: LT- 0000103 - 00 CARLISLE, PA 17013 Date Filed: 5/09/00 . ,....- ",-,:- "; " THIS IS TO NOTIFY YDU THAT: Judgment: " ~OR PLAINTIFF ~ Judgment was entered for: - (Name) REGENCY NORTH M.H.P. [i] Judgment was entered against FORRESTER, MICHAEL in a X Landlordrrenantactionintheamountof$ 1,778.68 on 5/23/00 (Date of JUdgment) The amount of rent per month, as established by the District Justice, is $ .00. The totai amount of the Security Deposit is $ .00 . Totai Amount Establishfd ~8~J Sess. Security Deposit Ap~~d - AdjudiCaled!imounk Rent In Arrears $' .0 - $ . = $ , 83.0 Physical Damages Leasehold Property $ .00 $ .00 $ 00 Damages/Unjust Detention $ _ 00 - $ _ 00 $ : 00 Less Amt Due Defendant from Cross Complaint - $ .00 Interest (if provided by lease) $ 00 D Attachment Prohibited/ UT Judgment Amount $ 1.683.05 Victim of Abuse (Act 5,1996) Judgment Costs $ 95.63 Attorney Fees $ 00 D This case dismissed without prejudice. Total Judgment $ 1,778.68 [!] ; Post Judgment Credits Possession granted. $ Post Judgment Costs $ D D D o Possession granted if money judgment is no sa IS Ie Possession not granted, Levy is stayed for ___ days or D generally stayed. , .- ',-" < _, .. ,- ,"'- , .' -:-1"~": . Objection to Levy has'b~enfiled and hearing'wiiibeheld: Certified Judgment Total $ Ime 0 eVlc Ion. D Defendants are jointly and severally liable. :",-',;->-'" '. t( 'i" , '" ,~'~,,,,,,,';'1, "~',' '-'" Date: Place: , Time: IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE ijlGHT'TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN TEN DAYS AfTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS ,OF THE COURT OF COMM,qN, PLEAS, CIVILDIVISION.THISAPpEAL WILL INCLUDE AN APPEAL OF THE MONEy'JUDGMENT,IF ANY. IN ,. . ORDER TO OBTAIN A SUPERSEDEAS, PPEllANT MUST DEPOSIT WITH THE PR.OTHONOTARY/ClERKOF COURTS THE lESSER OF :;, '" THREE MONTHS RENTORTHE REN ACTU LYINARREARSONTHEDATETH,EApPEALlSfILED.' " ,." ,,' . IFA PARTY WISHES TO, APPEAL 0 l Y THE ONEY, PORTioN OF A JUDGMENT 'ri LVING 'A RESIDENTIAL. lEASE, THE PARTY HAS ;,30 DAYS AFTER THE DATE OF E RY OF JU MENT IN WHICH T 'FilE A N E APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS OF THE COURT OF CO MON PLEAS CIVIL DIVISION. THE !W~-mG AN APPEA UST INC. A COPY OF THIS S (::;>k::> Date certl y t at t I IS a tru n ate <(t'. (, EXHIBIT My commission expires first Monday of January, 2Q04. Anpr.:'\1FiA-<:lA. _~ SEAL " C~ /1 'r_ _ ----..--'''--- , i t-~. ALL-STA!E~_IN~ER,NAn~NA~ .fj "'-'l..; ( ,- -J. . KOLLAS AND COSTOPOULOS , tla REGENCY WOODS NORTH MOBILE HOME PARK , Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL VANIA :NO, 00-3852 v, MICHAEL FORRESTER , KERR! A FORRESTER, and MARGARET FORRESTER Defendants :CIVIL ACTION-LAW TO: Kerri A Forrester 17 Regency Woods North Carlisle, PA 17013 Michael Forrester 17 Regency Woods North Carlisle, PA 17013 Margaret Forrester 509 Barry Court Mechanicsburg, PA 17055 DATE OF NOTICE: August 10, 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 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: DATE: rio/co Cumberland County Lawyer Referral Service 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 BY ~ #:: j&L--' 17 James W. Kollas, Esquire KOLLAS and KENNEDY ill No, 81959 1104 Fernwood Avenue Camp Hill, PA 17011 (717) 731-1600 ATTORNEY FOR PLAINTIFF KOLLAS AND COSTOPOULOS, t/a REGENCY WOODS NORTH MOBILE HOME PARK, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL VANIA :NO, 00-3852 v. MICHAEL FORRESTER, KERR! A FORRESTER, and MARGARET FORRESTER Defendants :CIVIL ACTION-LAW CERTIFICATE OF SERVICE I, Carole A Rose, ofthe Law Offices ofKollas and Kennedy, hereby certify that I have this \D-ID day of August, 2000, served a true and correct copy of IMPORTANT NOTICE by depositing same in the United States mail, first class, postage prepaid, addressed to the following: Kern A Forrester 17 Regency Woods North Carlisle, PA 17013 Defendant Michael Forrester 17 Regency Woods North Carlisle, PA 17013 Defendant Margaret Forrester 509 Barry Court Mechanicsburg, P A 17055 Defendant LAW OFFICE OF KOLLAS AND KENNEDY BY: lliwLL Q. WK Carole A Rose Caption: J<o//e;~ C7n".! ~.s,n;.I"""I.,J f/.4 1fc)t?nC'l' M4<~ A!o,,!J, /If/7 /,;It l-4-.e ~y k" // pl"'f~ -A-f+ vs. IV/ie t,"'e I ;=C;'--reJ'le r ffe"r.~4,FVr,--<Z.!:ft1?r):".., ./ A~r:JPdf IVryn-f#,,; 'J Oe=k... ./..~ rr ( Confessed Judgment ( ) Other File No. (I')()- J cf':,-2.. Amount Due .f / ;;Z:;;Zcf':,. -t P IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Interest Atty's Comm Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended, Issue writ of execution in the above matter to the Sheriff of C~,,.., !:"~r/e::-v,/ for debt, interest and costs, upon the following described property of the defendant(s) .4;,'/ ..,,/ "'// per,f<",.,,,,1 ,O,-o-=(3/..J../_ f Y' / County, PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the d~fenpant(s) in the possession', custody or control of the said garnishee(s). o (Indicate) Index this writ against thegarnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit., Attorney for: Telephone: Supreme Court ID No.: L~,~' ,/ ~""e.r W k;, If".) 1101{ n-,J-I<A/"'o/ .4':.<- C<:F......~ M-II r'A /;z.o/ I . ) pi ,,",n'.-. r;- -f..,L [7.17') 7ZJ/-/bQQ !'I qS-"f @ Date It>/;?~O . , Signature: Print Name: Address: "- 'liIU-",""-,~~,,,;,~~~~ -" , . - .~~~ - ,."d, " " Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (PaR.C.P. No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. /'1,-(;1,,,,,,,1 i ke,y,-A h)d..-.s.)e-f I;Z- KR.J8P'1 cy (..V.?,,'/f IV",..-A C,,:;/!sle J PA /70/..J \/1 j rvrreJ -/-er / -fP'J"",,.-e';- ;;-0 q iJPiY7 1-1ecl,a#o/CJ h"'-:J J t:o v,' -I- ;?iA 17Z0s-::,- iO (') C':1 0 C 0 ., Ii::. -". 0 'TIC>:, C) .T1 rrlf': : -_.~ , ...... ~ ~ 2::0 ~';.8 ~ :-zC' D :.f:l.. -rq, .... GO ,};,: ~ .~ ::~';i(~ ),., ~ . ~ -.D .~ II) -<.L, ? ~ , ~c; ." .--,-'-1', ~ 8 d 8 b ,~~") ~-~.! ).J ~3 -- ... ~(j en 0 i;? Off1 '-lJ I I , -" w 3S r cJ 1 - ~ -< -< f ... (;:l ~ , , 1- ... . . l' r- ~ , .~t , . ~ , -"\',,,..,,,,,__.,c~_< . ~~ c _ "_"~,'_,-',', - .<~_ ,'" ". ,__ "~''"~, ~. ,. . ,. ,....:t WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-3852 CIVIL ~ Term CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Kollas and Costopou10s t/a Regency Woods North Mobile Horne Park PLAINTIFF(S) from Hicmcl Ferr-e8ter aoo K€lrri A FQn;eat~,... 17 R"'J"nry WnrYI" Nm;-r, C<'lr1is1e. FA 17013 - Margaret Forrester, 509 Barry Court, Mechanicsburg, PA 17055 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell any and all personal property. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notffy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above stated, Amount Due Interest $1778.68 Atty's Comm Atty Paid Plaintiff Paid % LL Due Prothy Other Costs 7 50 $1 00 $71 7S Date: October 17. 2000 Curtis R. Long Prothonotary, Civil Division .bv: Ao.- o. 2. 7?(O<~.J Deputy REQUESTING PARTY: Name Address: James W. Kollas, Esq. 1104 Fernwood Ave. Camp Hill, PA 17011 Attorney for: Plaintiff Telephone: 717-731-1600 Supreme Court ID No. 81959 ~~~m~llA!ifiOO'~"U~"""""~'<lMlJbj\"f","",-~~,~,;jjA'~ ., ~,'-"-"'" - - -" ,. . ,,' " ~<, ., R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned SATISFIED. Sheriff's Costs: Docketing Poundage Law Library Prothonotary Service Surcharge Levy $18.00 35.57 .50 1. 00 9.92 30.00 40.00 $134.99 pd by deft. So Answer~: ~'~, ,_'l'~<;; ,y' p/-/" -r 'j ~. Thomas Kline, Sheriff Sworn and subscribed to before me This "lIM day of~ 2000, A. D .f::)~j!.L 0. ~ IrfFt · Prothonotary ByQ~ \~ D puty herifff 6 w 0<') 0.. "'" ~") ,-:; ---. <\ .-' ~- c;.:? ~ >\ \,06 uc... 6b711 /2u-. /o~''1.3)' III ,,,Ol<l..... -~- .~ l-~Ik.; -".' DISTRIBUTION ATTORNEY James W. Kollas WRIT NO. 2000-3852 Civil Kollas & Costopoulos tla Regency Woods North VS Michael Forrester and Kerri A. Forrester and Margaret Forrester Real Debt Interest Attorney's Comm. Writ Costs, Atty. Writ Costs, Pltff. Miscellaneous $1778.68 71.75 $1850.43 Sheriff s Costs: Docketing Poundage Posting Sale Bills Law Library Prothonotary Service Postpone Sale Surcharge Garnishee Levy $ 18.00 35.57 .50 1.00 9.92 30.00 40.00 $ 134.99 Defendant Paid to Sheriff Advance Costs Total Collected $1985.42 150.00 $2135.42 DISTRIBUTION Pd. To Pltff. Refund of Adv. Costs Pd. To Prothonotary $1850.43 150.00 1.50 S~S~." :<::~~ ~,. '. . . "'" - R. Thomas Kline, Sheriff BY~{)d::t~ D puty Slienff