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HomeMy WebLinkAbout97-05718 ~ ~ . f \J ~ ~ ~ ~ . \. ~ .0- .. -Q ~ U \.!) '1 " " 'I ~ , ; i I ( I ! ~ I I .... . , .::) . t"- O" .. SHERIFF'S RETURN - REGULAR CASE NOI 1997-0~718 P COMMONWEALTH OF PENNSYLVANIA, COUNTY OF CUMBERLAND GENSBIGLER JOSEPH A ET AL VS. BECKEY SCOTT ET AL . Sheri!! or Deputy Sheri!! o! CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT upon BECKEY SCOTT defendant, at 2000100 HOURS, on the ~ day o! November 19~ at 207 CONODOGUINET AVENUE APT. 8 CAMP HILL. PA 17011 WESLEY COOK was served the . .cunBERLAHD handing to JODI BECKEY. WIFE OF DEFT. AND . County, Pennsylvania, by PERSON IN CHARGE a true and attested copy o! tIle COMPLAINT together with NOTICE and at the same time directing ~ attention . to the contents thereof. Sheriff's Costs I Docketing Service A!!idavit Surcharge 18.00 8.68 .00 2.00 So an~_~~/ _ /~. r ..: '~-~1..A e H. Thoma. ~~1ne, ~her1%% .2B.bB 5NELBAKER BRENNEMAN AND SPARE 11/10/1997 by ~~~f; Sworn and subscribed to before me this 10 ~ day o! 7/ut.'<.,~~~ 19 q~ A. D. q ~ ~ b,. ( ft~ . I ro onotar ,,'..... ,"";' /- ~ c:t: ~~ l/I '+J. H! H "1:: '41 8..... ., ~' r2 " C"- t; ~ ~ ~rt.. ~ t- ,~ ~ ~ .~ / - <. .~. ~ " ~ " , , , .L ." .- ;:::; ... :t. . ~ .c < '" .. JOSEPH A. GENSBIGLER and LIZZIE N. GENSBIGLER, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 97- .!;*IIP CIVIL TERM vs. CIVIL ACTION - LAW SCOTT BECKEY and JODI BECKEY, Defendants NOTICE You have been sued in court. If you wish to defend aqainst the claims set forth in the followinq paqes, you must take action within twenty (20) days after this Complaint and Notice are served, by enterinq a written appearance personally or by attorney and filinq in writinq with a court your defenses or objections to the claims set forth aqainst you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered aqainst you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other riqhts 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 CUT WHERE YOU CAN GET LEGAL HELP. Court Administrator One Courthouse Square Carlisle, Pennsylvania 17013-3387 (717) 240-6285 LAW O'''lCE:~ SNELBAKER. BRENNEMAN a: SPARE ,. JOSEPH A. GENSBIGLER and LIZZIE N. GENSBIGLER, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT~, PENNSYLVANIA NO. 97- .~/I f' CIVIL TERM vs. CIVIL ACTION - LAW SCOTT BECKEY and JODI BECKEY, Defendants COMPLAINT AND NOW, come the Plaintiffs, Joseph A. Gensbiqler and Lizzie N. Gensbiqler, by their attorneys, Snelbaker, Brenneman & spare, P. C., and aver the followinq civil action for damaqes: 1. The Plaintiffs herein are Joseph A. Gensbiqler and Lizzie N. Gensbigler, adult individuals, who reside at 670 st. John's Drive, Camp Hill (Hampden TownShip), Cumberland County, Pennsylvania. 2. The Defendants herein are Scott Beckey and Jodi Beckey, adult individuals, who reside in Apartment 8, 207 Conodoquinet Avenue, Camp Hill (Hampden TownShip), Cumberland County, Pennsylvania. 3. Plaintiffs are the owners of a certain residential apartment buildinq known and numbered as 207 Conodoquinet Avenue located in the Township of Hampden, Cumberland county, Pennsylvania, which buildinq contains a separate part or section known as "Apartment 8", hereinafter called the "Demised Premises". LAW Ol"I"ICL!iI SNEL8AKER, BRENNEMAN &; SPARE 4. Plaintiffs leased the Demised Premises to Defendants as Defendants' private residence on an oral agreement whereby ~ Defendants aqreed to pay rent to plaintiffs at the rate of $520.00 per month in advance of each month of occupancy. said rent to be paid on or before the first day of each calendar month. 5. Based upon the aqreement aforesaid, Defendants entered into possession of the Demised Premises and continue to occupy the same. 6. Commencinq with the month of May 1997, Defendants failed to pay and became delinquent in paying the aqreed rent to Plaintiffs, payinq only $300.00 thereof, leaving a balance due of $220.00. 7. Defendants have failed and refused to pay the rent due for the months of June, July, Auqust, september and October 1997 in the total amount of $2,600.00. 8. Therefore, Defendants are presently indebted to plaintiffs in the amount of $2,820.00. 9. Plaintiffs have demanded payment of the sum of $2,820.00 which Defendants have failed and refused to pay. WHEREFORE, Plaintiffs demand judgment aqainst Defendants in the amount of $2,820.00 toqether with interest at the rate of 6% per annum since the due dates of all rent installments and the costs of this action. LAW OFFICrg SNELBAKER. BRENNEMAN 81: SPARE By: rd C. Snelbaker (sup. ct. Atty. I.D. #06355) 44 West Main street Mechanicsburq, PA 17055-0318 Date: 101/1/9'7 -2- . VERIFICATION I, Lizzie N. Gensbiqler, do hereby certify and verify that I am one of the Plaintiffs in the foreqoinq Complaint and that the facts set forth in said Complaint are true and correct to be best of my knowledqe, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 54904 relatinq to unsworn falsification to authorities. L~~ d Avv~ L zzie N. Gensbi er Date: October 17, 1997 LAw OFFICE! SNEL.BAKER. BRENNEMAN a SPARE i I I i I j I \1 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-5718 CIVIL TERM CIVIL ACTION - LAW JOSEPH A. GENSBIGLER and LIZZIE N. GENSBIGLER, plaintitfs SCOTT BECKEY and JODI BECKEY, Defendants PRAECIPE TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiffs and aqainst the Defendants in the above captioned matter for want of an answer, and assess the Plaintiffs' damaqes as follows: $2,820.00 toqether with interest at the rate of 6\ per annum since the due dates of all rent installments and the costs of this suit. It is certified that written notice pursuant to Pa.R.C.P. 237.l(a) (2) was mailed to the Defendants aqainst whom judqment is to be entered, after the default occurred and at least 10 days prior to the date of the filinq of this Praecipe. A copy of the Important Notice is attached hereto. SNELBAKER, BRENNEMAN & SPARE, P.C. By: ~ . Spare, Esqu re 44 W st Main street Hechanicsburq, PA 17055-0318 (717) 697-8528 Attorneys for Plaintiffs LAW Ol'I'ICIU SNELDAKER. BRENNEMAN 6: SPARE Date: December II, 1997 , v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-5718 CIVIL TERM JOSEPH A. GENSBIGLER and LIZZIE N. GENSBIGLER, plaintiffs SCOTT BECKEY and JODI BECKEY, Defendants CIVIL ACTION - LAW TO: Scott Beckey and Jodi Beckey 207 Conodoquinet Avenue, Apartment 8 camp Hill, PA 17011 (Defendants) DATE OF NOTICE: December 1, 1997 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 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: Court Administrator One Courthouse square CarliSle, Pennsylvania 17013-3387 (717) 240-6285 l."Aw Cl"ICI' SNZLSAKER. eRENNIEMAN a SPARE P.c. By: rd C. Snelbaker 44 West Main Street Mechanicsburg, PA 17055-0318 (717) 697-8528 Attorneys for Plaintiffs r- rr -- :: rr -:l J -i r@ .. (OJ t"" i3 (. t (j " I..) l:- < t., '. 1?.. t:;- -~ . i ffi j , (.. "" () (, 0 ~ it /, e , 0- el. , I-c. ,,/ ~ ___I '- " !"'... , , , " ...