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Home My WebLink About01-0227 FX LAW OFFICES BARBARA SUMPLE-SULLIV AN 549 BRIDGE STREET NEW CUMBERLAND. PENNSYLV~'<IA 17070-1931 PHONE (717) 774-1445 FAX (717) 774-7059 June 18, 2001 Lindsay Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 via fax and mail Re: Intreri v. The Aulson Co., Inc & Simon Arbitration No. 01-227 Dear Attorney Baird: Please be advised that the parties in the above captioned action have reached an agreement. We respectfully request that the hearing scheduled before you for June 19, 20001 at 9:00 A.M. be continued generally to allow for the execution of the documents regarding same. I will notify you once the documents are signed. If you have any questions, please do not hesitate to call. Thank you for your consideration in this matter. Barbara Sumple-Sullivan BSS/lw cc: Timothy J. Colgan, Esquire (via fax and mail) Rolf E. Kroll, Esquire (via fax and mail) Joseph U. Metz, Esquire (via fax and mail) Ms. Marianne Intreri '-^',-", 'I-T" ,""1 I' '-I BCUvdltt nSl!mf~ ~'~HIVt!~fLti6J.Uf'\e ..u .. . 51}q @vtaq,t .5+Y(~ .. ... ....... . ... ~{'~ CIUM~~~Lefl: 17070_ .. ... ....r:;.........".... . ......... .... ". '.',,' '-', $)''''1 . """., '~ ~,,_ 1, ... ..' ~I; .'_ ( . ' ,\;1.-- , m ... _.~ \\~~ 1l1J~1' ;7 ------.~---'="."""'_m:ll'?P.f~fW-,.".-..".h,""'<.~~..._".".~~,'\;.."'... _. ~~" ~~,-- - -------' ~ Jx1ileci r n n nun . . .v 'r . . flMI~15JSLmOvJ). . .. NlJI1r{t~'Wl-- - -, --",,-- '--,. .-.--'-'-'- \~tD S0\1ttd\A;U j[lV1C I~I 2DDl @ qPrA. [)\~ 'P(V : ~", r. .... c~~~(t. . ~~~~J ~bX, 11~~(t.~:~;'i~:~~.. U ';Q c '.Nr>1 plt. ~li bVilk> 'liJdw1f ilr1;lhff ((UVLA. .. MRJlWt1VJ/1! I 7X!r~d&KfS ., l "",,-, -------..-._--- \vler1 · an\UJ~fl UdWlf nli),Lkt{rv~d1~\{g iOcon'pt'Vvt (\cr\t ):tlfV12 -<:tv/lOGe. I SM\f1..fttipl1?::\1) uU (x'u('hes. dl.i 1\f(!):W\(f ..... -d@:.--- ',."- - ,;r-,". ,,' ,1<'~'-'"mRfi!i~'ff-;;ijij,-"ii;;-w-:,;- :Iii- LAW OFFICES BARBARA SUMPLE~SULLlV AN 549 Bridge Street NeW CUlltberland, Pennsylvania 17070-1931 . . PHONE: (717) 774-1445 FAX: (717) 774-7059 TO: Lindsay Dare Baird, ESq1iire SENT VIA FAX NUMBBR: 243-8110 FROM: BARBARA SUMPLUULUVAN, ESQUIRE DATE: June 18, 1001 TIME: t 30 ft'^ RE: Jntrerl VS, SllIton & the AulsoD COlltpany COMMENTS: NO. OF PAGES INCLUDlNGTRANSMITTAL SHEET: ~ ORIGINAL WILL X . IWlLL NOT _ FOLLOW BY FIRST-CLASS MAIL '- I r ,- . LAw ()PI'ICllll BARBARA SUMPLE-SULUVAN :S49 BRIDGE STRIl,B:f lfllW,CuMBERLAND. P.Bl<l<SYLVA..'I'1A17070-1931 PHONE ('17) 774..l44S F4X (7.7) "'4-70"9 June 18, 20.0.1 . Lindsay Dare BaiJd, Esquire 37 South Hanover Street Carlisle, P A 170.13 via fax and mail ReI Inb'eri v, The AulsOu Co., Ine '" Simon' Mbhration Nil. 01.227 Dear AlIomey Baird: .' . . Please be advised that t.h;e ~ies in tbe above captioned action have reached an agreement. We respectfully reqti~sl that the hearing scheduled before you for June 19, 20.0.0.1 at 9:0.0. A.M. be. continued generallY'lo allOw for the execution of the documents regarding same, . , , . 1 will notify you oncelbe dOcuments are signed. . If you have any queslions, please do not hesitale 10 call. Thank you for yourconsideralion in this matter: BSSllw , 00: Timothy 1. Colgan. Esquire (via fall 'and mail) RolfE. Kroll, Esquire (via fax and mail) Jo~ph U. Metz. Esquire (vill fax and mail) Ms. Matianne Intreri ' .,~ - ~ , 1'-'1 J, , MARGOLIS EDELSTEIN PHILADELPHIA OFFICE THE CURTIS CENTER FOURTH FLOOR INDEPENDENCE SQUARE WEST PHILADELPHIA, PA 19106..3304 215-922.1100 FAX 215-922-1772 ATTORNEYS AT LAW DELAWARE COUNTY OFFICE 216 SOUTH ORANGE STREET MEDIA, PA 19063 610-565-8311 FAX 610-565008318 POST OFFICE BOX 932 HARRISBURG, PA 17108-0932 PITTSBURGH OFFICE 1500 GRANT BUILDING PITTSBURGH, PA 15219-2203 412-281-4256 FAX 412-642-2380 STREET ADDRESS, 3510 TRINDLE ROAD CAMP HILL, PA 17011 717-975..8114 FAX 717.975-8124 NEW JERSEY OFFICE P,O, BOX 2222 216 HADDON AVENUE WESTMONT, NJ 08108.2886 609-858.7200 FAX 609..a58-1017 WRITER: ROLF E, KROLL DIRECT E.MAIL: rkroll@rnargolisedelsteln.com SCRANTON OFFICE THE OPPENHEIM BUILDING 409LACKAWANNAAVENUE SUITE 3C SCRANTON, PA 18503 570..342-4231 FAX 570..342-4841 May 16, 2001 Lindsay Dare Baird, Esquire 37 South Hanover Street Carlisle, P A 17013 RE: Marianne Intreri v, The Aulson Co., Inc, and Ron Simon Cumberland County Civil Action No, 01-227 Dear Ms. Baird: As you know, Rolf Kroll of this office has been selected as an arbitrator in the above- captioned matter. The arbitration hearing in this matter is currently scheduled for Tuesday, June 19, 2001, at 9:00 a.m. in the Second Floor Hearing Room of the Old Cumberland County Courthouse, Carlisle, P A. Unfortunately, Mr. Kroll has a conflict in his schedule and will not be able to appear for this scheduled arbitration hearing. Mr. Kroll has asked me to substitute my services for his at the arbitration hearing on June 19, 2001. Please advise whether this is acceptable, or else the arbitration hearing will need to be continued. I await your response. Sincerely, d!/,.Z::: SJM/jab cc: Cumberland County Court Administrator Timothy J. Colgan, Esquire Joseph U. Metz, Esquire Barbara Sumple-Sullivan, Esquire ',.,. -",-,~ -t.'<",""""":,c-- '-. ^~ ,> .~-- ~ ,..'" O"~I"'~ - ._,'i' ,"-"' .'1 '1 t',:' -., ~-" ~'-'~' '" -~--",-,",~--~"" ,.-",,,-,, (i I :1 1 I i 1 ;1 ," 11 ; ';1 ~ ~ ;1 -;1 " II ,I i; 1,! jj '1 {I f' tl _H ,I II :1 , ~ .11 '.-' 0' co, ,~~ '. e--'" , ~-~ .- ~"- c/) /;:"' ~ <p ":> ~ ~ '?'> -:> T IJ C,\ ,:"" -~ ~__~~]~'lIlli")'S~,'j~~~~"ffi!li~~~~ __".:r) ll<___. '.~". p' -. ~w.~,,,,. ,-,,~. ,_ ~-. "","~"","<""""".,_" h ~_~,~,"~~..."'" ,..,~..~,.~.,. "_"",~ .'" ;,_,_ """"'_"""""':'"",.""","",___."~"'_'__"_~"'__O"'~.","'" ,- , ,-,~~"" THE WILEY GROUP Attorneys at La-w- Wiley. Lenox. Colgan. Marzzacco . P.c. May 7, 2001 Lindsay D. Baird, Esquire, Chairperson 37 S. Hanover Street Carlisle, PA 17013-4240 Re: Marianne Intreri v. The Au/son Co" Inc., and Ron Simon No, 01-227 Dear Attorney Baird: I received the appointment for the Arbitration Panel on June 19,2001. I am unavailable on that date. Please advise if there are other dates that may be available for this Arbitration Hearing. Very truly yours, vnLEY,LENOX,COLGAN & MARZZACCO, P.C. by Timothy J. Colgan TJC/mar 1 South Baltimore Street. Dillsburg, PA 17019 . Phone: (717) 432-9666. (800) 682-4250 . Fax: (717) 432-0426 Offices In Harrisburg. York. Carbondale ---'--1"""" , r-"'~"'='""~--~ ~_~____.';___'___"''''C'' .----~__".,"'"'_,_~~_~_,_.' ,_,,~ Xi!f~~1it~i1f1~~\g,~~~f'i~~i~~1@&19Jt~jt€~j&~,*$,r.~~~,*,;!%l~1.%1',>!"i~';f?(.~~.1<"",.;I;;:'~,~"i!',_~,'V,'{::r;~q;(;4~'_%<_'>i--""~~_~~_,,,1O'~ _ _"'" _ ~_ "'.'~"_ __=,~_ \ , \ j \ \ \ p. :J o ~~ ~~ ~ >-: ~t' ~8 [:::'8 ~< ~ ~ f-< '" o '" l; j U d,)"' .= 0 g. ~ "'.....'<1' ~ 8_,~ ..I:l - "BCIlo .~ I'- ee ~ .-r I:Q;>~ A~P. ~~ ..!:l '" '" "Oct.5:.=: .S I'- 1a ....:i""U U r:.: - w ~Q) -~ <.1')0 w"- ~ ~ o EO:: "';:; ~oo '" :; ..r::;..D - ~ ,,= 0'- <.1')0 . 1,__: "1(--((' (' i {i i ~ f \ \ \ \ . x 0 o u c: u W'" ...J N . ~ >-'" ~:::E ~ ~ '" "" "0 u --"-'I..w"r""-';"""'f'''~''''"*''''~'''_''''<f__ I 1m ..i rll!....."".". "," '~~~ji;~BliaV,A?f~J_~&\SlJI~:fE'i<:t'f~j'ji!ii'~jr~ ,'," .~, c COMMONWEALTH OF PENNSYLVANIA COURT ,oEC,QiI1MON PLEAS (iF CUMBEflLAIK COUNTY JUDICIAL DISTRICT NOTICE OF APPEAL '.. FROM. 1/;1/1.1/, DISTRICT JUSTICE JUDGMENT COMMON PLEAS No, .0 I;" ';;,2"7" {~i",:/t1L1:"- NOTICE OF APPEAL Notice is given Ihal the appellant has filed in the above .Court of Common Pleas an appeal from the judgmenl rendered by Ihe Dislrict' Justice on Ihe date arid in the case mentioned below. NAME OF APPELLANT! The Au1son Com an MAG. DI5T. NO. OR NAME OF D.J. 09-1-01 D.J, Clement ADDRESS OF APPELLANT CITY STATE ZIP CODE 49 Danton Drive DATE OF JUDGMENT 12/l3/2000 Methuen MA 01844 IN THE CASE OF (PLAINTIFF) Intrer'j (DEFENDANT) CV YEAR L T YEAR 0000634-00 vs, SIGNA:OF APPELLANT OR ~ Simon and Aulson Com an CLAIM NO. This block will be signed ONL Ywhen Ihis notation is required under PA. R.C.P.J.P, No.1 008B. This notice of Appeal. when received by Ihe Dislrict Justice, will operale as A SUPERSEDEAS to Ihe Judgment for possession in this case, If appellant was Claimant (see PA R.C.P.J.P. No. 1001(6)) ill action before district Justice, he , MUST FILE.A' COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. .Sl{;nature of p~(Jthonotary or [}fJptJty PRAECIPE TO ENTER RUbl;TO FilE COMPLAINT AND RUL.E TOFILE ' (This section of form to be used ONLY when appellanlwas DEI'ENDANT(see PARC,P.J,P,No, ~001(7i in actioh before District Juslice, iF NOT USED, detach fr~m,eopy,of no)ice orappeai 10,be served upon'appellee, , .. , I PRAECIPE: To Prothonotary Enter rule upon (Y}ar I q h lip ~ 1re..r r , appellee(s),to file a complaint in Ihisappeal , Name of appel/ee(s)" ' (Common Pleas NO,'O 1- .2;;' '7 ('tV;) J:~n twenly (20) days after service'of rule or suffer entry of judgmentoLmii(p,.os: _ _..-7 ~ -,,~: o~, RULE: ' To fT'klnc,V1ne k ,-ye,'( / Name 01 appel/ee(s) ~ttorney oragent , appellee(s) Date:' , -" ,-' (1) You are nollfied Ihat a rule is hereby enlered upon you to liIe a complaint in Ihis appeal wilhin Iwenly(2q,j da\ls !if:!er t~date of service of this rule upon you by personal service or by certified or registered mail. ' ' . "" (2) :rf:YOUI',~" I file a complaint within this lime, a JU, DGMENT OF NQN PRO,S W, ,~L,L B,E ENTE, RE",D, ,AGAINST YOU "Bpo " ECIPE. .' '.' '(3) "f\,e i~ service <:if this rule if service was by mail is the date of Ihe m!\i1iDl'f(f!~:' "', '<';",\ii; . '\~~~,: ~- ~- .~;':;:'-:'-,? ,:~ - '~;:~~~i/~~'f' .1 . . ~, c;"":>~ /,:,\>, , ".,,,,..,,.,,, ' ; ~~. II ,Year .2M)1 ~~;-<~a~~~;~~~tiuiY . ,,>'. . /,- !\ f;:i-I,. ,-~~,.., ~c ;.: , " J White Green Yellow Pink Gold' Prothonotary Copy Court File COpy ApPEllant's Copy Appellee COpy D,J, Copy /'1 :.~, .- .L' --,'" r" ',;:- "'::'1,.,:,,"'''<......,''~,...,....-..,..:'' . Proth, - 76 ",~- "'. ,," I .Wi"':~", __ , _ ~ .~~_. "- _e " In -,=.= <+- ~ _ 1'1 PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILEDWITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicable boxes) COMMO.NWEALlH;F PENNS~LVANIA I .' COUNTY OF ':~".-f'~ Ii'" ~(:e- V' I q'?1:} ; ss AFFI DAvIT: I hereby swear or aflirm that I served rK. a copy O.f.t.he Notice.~. . 1';e"1:fo. mmon Pleas No, r ~l ~?-?- 7 . ,u.po.n the District Justice desi.gnated ther.ein on , (date of service) ~ '. ,'. / \?2 ,year ~~_, L8l'bY persona~e Dby (ce'~fied) (r.egistered) mail, sender's receipt at ached her to, and upon the appellee, (name /1/::r.r'fJ-%v1 I1P,. "tre y ..1_'-_, _' on .' jl,; , year ~i-, 0 by personal service llr by ~(registered) mail, sender's receipt att~9hed hereto. lit. and 'further that I served the Rule toJ:ife a Ico,.laint accompanying the above. Notice of Appeal upon the appellee(s) to whom the Rule was addressed on --1-/- t-L----, year _~..L, ' 0 by personal service .bYt~registered) " ~ -~~it~ send~r's receipt attached hereto. SWORN (A~rAND SUB$CRIBED BEFORE ME THlSfl_AYOF ,~/ ~'(' - .CU~' Sigoat ofofM.~1 be "whom aflt/. ' avit was made :" " ". B-uJr:0 Dc> Tit/eof'ficia/ &L ! ", .::; My commission expires on .t -t-!-, year ~ u...... ,~ . ! -', /", "-', ' ... /---" -' ~ -1 i ...I-~./..:' / - , . )......../!"'-.,;. /; I I' / i~~ - ..- _~~I( ~// ',/v c.~ ~_ l /,:' !,_r Sigrla;ur~ 0 Ament \ / ~ Q ~ , I <:.- --, :Do ?~ '-T1 ;z: .;~ .;t1~ Q) :n~ Q '" q ~ ::r; ~'-n ~ z@ 0 ,::..) ~ j~ -< MIfllA~ffGlIIy~ .",.,...,,- ""'-.; CcllIlir My~~~i;;0aL4.- . ,,' '- -'"",":~..^',; '- I"- IT) 0- 1"-' I"- ru <<J ='" Certified Fee l Return Receipt fee I a.50 lEndorsement Requlred\ f.lestncled DeJJvery Foae $0." (Endorsement ReqUIred) Total Postage &. Fee31 $ 13.7-" 11115 15 Postmark Here ;..., <:::I CJ CJ CJ CJ ='" fT1 Nama (Please Print Cie&iY) (to be completed by maiN>Jj Ki11 ion & ~letz ~ f:~tr.~!R~~?f.~~!:::::::::::::::::::::::::::::::::::::::::::::::::::::::1 t~~~j~:.1~~~~~~~ ~~~~~~~~41iWi~~~~ 0l/U1Dl I ~f~'!i~ ~ COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS uF CUJIIBERLAIJD COUNTY JUDICIAL DISTRICT NOTICE OF APPEAL FROM 1/11 j(j I DISTRICT JUSTICE JUDGMENT COMMON PLEAS No, 0/-;(.2 '1. &Vd / L<.M<- NOTICE OF APPEAL Notice is given that the 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. NAME OF APPELLANT MAG. DI8T. NO. OR NAME OF D.J. The Aulson Com an 09-1-01 D,J, Clement ADDRESS OF APPELLANT 49 Danton Drive DATE OF JUDGMENT CITY STATE NA (DEFENDANT) ZIP CODE Methuen 01844 12/13/2000 IN THE CASE OF (PLAINTIFF) Intreri vs, Simon and Aulson Com an CLAIM NO. CV YEAR LT YEAR 0000634-00 . . SIGNATURE OF APPEl"^NTOR~ This Plock will be signed ONLY when this notation Is required under PA. R.CY,J,P, No, 1008B, This notice of Appeal, when received by the District Justice, will operate as A SUPERSEDEAS to the Judgment for possession in this case, If apP'!!fant was C(flimant (see PA RC.P.J.P. No. 100i(6)) in action before district Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL Signature of Prothonotary Of Deputy . - ". - '.," .- ". . , PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE T() FILE (This sectional form 10 be used ONLY when appellant ~as DEFENDANT (see PA'R,i:;,P,J.P, No, 1001 (7) in action before DistrictJustice, IF NOT USED, detach from copy of notice of appeal to be served upon ~ppellee. ';i-J PRAECIPE: To Prothonotary Enterruleupon fY)Qrlq~np .A~(. Name of appelfee(s) . I" ",/4-0 (Common Pleas No, () 1- ,2.2 7 \....(.QU ) within twenty (20) days after service of rule or suffen entry of judgment of non pros. .-?' 'I, I .~" , appellee(s):to file a complaint in this appeal RULE: To rr'x::lnQl1ne J:, tY1eX / Name of appellee(s) attorney or agent . appellee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty(20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU UPON PRAECIPE. (3) The date of service of this rule if service was by mail is the date of the mailing, Date: ~."... f /1 , Year .2JJ.o I a While Green Yellow Pink Gold Prothonotary Copy Court File Copy Appelant's Copy Appellee Copy D, J, Copy PrOlh, - 76 -~~~~_. _ W1!1 "_~ . ~I~~,fli." ~ "-'f-"'f'O"-"'''~'"~"""""''_,,,,-==q'"''''-'-.";-'',"n''''''"'''''t''''''''''''_'~'''''''''"''''''~~="'"='''"'~,~-~~,~~_._.______ r~ '.(; ~ ..., " "'" " \lJ "; "<< . ~ " I,. ',,- ". ., ~-'-"-' ,..., , ",- " I,'~._"'<V- ,~~. "'<,"""" . -~ PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FilED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ; ss AFFIDAVIT: I hereby swear or affirm that I served o a copy of the Notice of Appeal,- Common Pleas No. , upon the District Justice designated therein on (date of service) , year ~__, D by personal service. 0 by (certified) (registered) ~ail, sender's receipt attached hereto, and upon the appellee, (name ._~______, on _' year ________. 0 by personal service 0 by (certified) (registered) mail, sender's receipt attached hereto. o and further that I served the Rule to File a Complaint accompanying the above Noti<;:~e of Appeal upon the, appellee(s) to whom the Rule was addressed on _____~_______, year ____ _, 0 by personal service D by (certified) (registered) mail, sender~s receipt attached' hereto. SWORN (AFFIRM~D) AND SUBSCRIBED BEFORE ME THIS DAY OF __' YEAR___, Signature of Affiant Signature of official before whom affidavit was made ~ Tifleofofficial My commission expires on _ " ... ..{: .c. \?\ ;--\ Q }-J ~ >-' '1'''' I~r J , year - ~''''''''''',.,''"r;;'''''''''IZ;;U''.r"'''';.td,),.,.:,,,_>,1~'1t7;'','''''''-;_'ib",,"""V"H"""'-'_"""~""'_~,"'!-"i~~~r!!,IWf!!l!:I'!\\'F" ,'" o r- Z. "lJrL, rnr-:-~ z-~-::!:' 71" CR;~-' t~(~.~ ,::....'...... b{'''" )-;;.c Z :2. -, '_J '-c, -~ ~;~ " '" ~,,- , - - - '-'''~_'I1"W t~".w ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND 09-1-01 NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFF: NAME aodADDRESS IrNTRERI, MARIANNE I 138 N. 30TH STREET CAMP HILL, PA 17011 L -.J Mag. Gist. NQ, DJ Name: HOrJ. CHARLES A. CLEMENT, JR. Add'"" 1106 'CARLISLE ROAD CAMP HILL, PA VS. T'''phoo, (717) 761-4940 17011 DEFENDANT: NAME and ADDRESS 'sIMON, RON, ET AL. 49 DANTON DRIVE METHUEN, MA 01844 L Docket No,: CV-0000634-00 Date Filed: 11/08/00 I ATTORNEY DEF PRIVATE JOSEPH U. METZ, ESQ. 214 PINE ST. HARRISBURG, PA 17101 -.J THIS IS TO NOtiFY YOU THAT: Judgment: POR PLAINTIFF [iJ Judgment was ,entered for: (Name) T1I1'I'RR1H, MJlRTJl1IThTR [iJ Judgment was entered against: (Name) THF: Am,SON ~OM'PJlNY. TNC. in the amount of $ '1,07R 40 on: (Date of Judgment) 12/1'1/00 . o Defendants are jointly and severally liable. o Damages will be assessed on: (Date & Time) O Amount of Judgment Subject to AttachmentlAct 5 of 1996 $ Amount of Judgment $ 3,005.40 Judgment Costs $ 73.00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 3,078.40 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ o This case dismissed without prejudice, o o Levy is stayed for days or 0 generally stayed. Objection to levy has been filed and hearing will be held: Date: Place: Time: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JI)O.GMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLIj;~S, CIVIL DIVISION. YOU . . , MUST INCLUDE A COPY OFTHIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR N0TIGE'OF APPEAL. . \ , ! , /} '..;,/ ,',~',_.i',": Date ",,/ , ,/> "-.....' '~-....,."-. , District Justice ;.~",. I certify that this is a true and correct copy of the record of the proceedings containj!i'9 the'judgment. './, Date , " District Justice My commission expires first Monday of January, 2002 SEAL AOPC 315-99 ~!!Il!ll'" '~"', ,. I r~ , . ~-~ ~ Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Counsel for Plaintiff J MARIANNE INTRERI, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-227 CIVIL ACTION - LAW THE AULSON CO., INC. and RON SIMON, Defendants 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 BAR ASSOCIATION 2 LIBERTY AVENUE Carlisle, Pennsylvania 17013 (717) 249-3166 .". . ":?;~;f,-;77 ~:~:-?:.,'::':t;_;~F_'1 ,-~_:::-~':'-;::~>;':{:Zi\:'J:_;",:;::_;;J:;-~c; ~;-..._:::_~ ;::: _, ; _ ,-' ':;"-;"'"' ::);~:~~~',:I':,'_"';;,__ .;'- " '-', --'''''' -, -'---'1, ,0- _"r~", '-",- "'-~' '-'~c.' ",' t _ ~,' '-, - ~.,-- " ,c__,~, - , -;"~ '_':_-,. -~ ~,~ 0_. _,,_ , V '4 Barbara Sump Ie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 Counsel for Plaintiff MARIANNE INTRERI, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-227 CIVIL ACTION - LAW THE AULSON CO., INC. and RON SIMON, Defendants COMPLAINT 1. Plaintiffis Marianne Intreri, an individual residing at 138 North Thirtieth Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is The Aulson Co., Inc., a company doing business in the Commonwealth of Pennsylvania with its principal office being 49 Danton Drive, Methuen, Massachusetts 01844. 3. Defendant is Ronald Simon, an individual whose mailing address is 49 Danton Drive, Methuen, Massachusetts 01844. 4. Defendant Simon is an authorized agent of The Aulson Co., Inc. 5. Plaintiff is the owner of real estate located at 1705 Creek Vista Drive, New Cumberland, Cumberland County, Pennsylvania 17070. .":,e __:_7:"~-!!;,~-'i',:,\~~~_L"';":-:~:'-_'-:'i:-: ~ff, ~";''',,:,~_:-:>~t~,?,,'~~'E:-:,.,..."--",,_,,,J;'''''''T"-':,--_" "0_";'"\ ',-' , ---I - - - -~' <~-, - ~,- . -'-",!\ '_ +' ,.,\_,v""',' =, ~,~"_ _c :>< ~_, _,,.,..',,._~,.= __._",~",_,ry_~'"'_''''__,"' -. _ -'?_'_"-'~"<,' , , \.( "< 6. Plaintiff entered into a written lease with the Defendants for rental of the property. A copy of said Lease is attached hereto as Exhibit "A" and incorporated herein by reference. 7. Pursuant to the paragraph 8 of the Lease, the monthly rental was SEVEN HUNDRED NINETY-FIVE DOLLARS ($795.00) per month and a security deposit of SEVEN HUNDRED NINETY -FIVE DOLLARS ($795.00) was due and payable. 8. Pursuant to paragraph 6 of the Lease, said lease term was specified through November 30, 1999 and thereafter would automatically renew for two (2) full calendar months thereafter until appropriately terminated in accordance with paragraph 7 of said Lease. 9. On July 31, 2000, Defendants gave oral notice of vacation of the property in violation of the terms of paragraph 7 of the Lease. 10. Due to their vacating the property without sufficient written notice, the lease was effective until September 30, 2000 and rental was due until that date. 11. Defendants have failed to make the payments required for the months of August and September, 2000 and the sum of ONE THOUSAND FIVE HUNDRED NINETY DOLLARS ($1,590.00) is due and owing for unpaid rental. 12. Additionally, in accordance with paragraph 8.D., Plaintiff is entitled to late fees of 2 C'-'"_'1'_"_ - -~ _.",,~!Z,-~.;-"'''',''!'t--, ",'-'-'-4._"',_ c,'-- 1"'''-'-',_':'' 'C'}"I"-'--_""-_<~- "~"-L~-"'" -' 0:,' ",_,',_'_ ~"""""",,,""_'''~ _ ~,~- < _ , " '-< SEVENTY-NINE DOLLARS and 5ol100 ($79.50) per month for the lack of payment or an additional sum of ONE HUNDRED FIFTY-NINE DOLLARS ($159.00) for past due rentals. 13. Additionally, during the occupancy, Defendants caused physical damage and destruction of the premises far in excess of any normal wear and tear. 14. The acts of damage and destruction, as well as the cost of repair paid by the Plaintiff, are as follows: A. Replace electric smoke detector; reattach ceiling light in upstairs hallway at a cost of ONE HUNDRED EIGHT DOLLARS and 48/1 00 ($108.48); B. Replace burned vinyl floor in kitchen and cut vinyl in foyer at a cost of SEVEN HUNDRED FIFTY DOLLARS ($750.00); C. Refrigerator repair; replace missing dishwasher parts at a cost of THREE HUNDRED SIXTY-THREE DOLLARS and 58/100 ($363.58); D. Clean stove; clean fireplace; remove trash and take to dump at a cost of ONE HUNDRED NINETY-ONE DOLLARS and 50/100 ($191.50); E. Repair of cracks; replace missing wallpaper; painting entire interior of house at a cost of EIGHT HUNDRED NINETY-TWO DOLLARS and 32/100 ($892.32); F. Replace window blinds in kitchen and in three bedrooms at a cost of SEVENTY- NINE DOLLARS and 18/100 ($79.18); and G. Replace broken kitchen window handle and torn kitchen window screen at a cost of ONE HUNDRED THIRTY-FIVE DOLLARS ($135.00). 15. The total repair and replacement costs incurred by Plaintiff was TWO THOUSAND FIVE HUNDRED TWENTY DOLLARS and 06/100 ($2,520.06). 3 ,. ~ --' ,""'~~~~1!'~,""""'"<-,, o. .~, 'Co ,'7"-- -(;<,,>, ,"1,_,~" 'I_"~ ",-; ""c'> _".-,~!_."",'Vf"""_, ';:'__ ,,- " . r-~_, I ~ ' - '<'" --,',-~'-"7'7'''''''''':~- ,'c "'7,'.,,,,.,,,,<-,'. '," ";,_",, --'''''';'.'1:,,-.''''''"'' , y r 16. Plaintiff applied the Security Deposit received of SEVEN HUNDRED NINETY-FIVE DOLLARS ($795.00) against said damages in accordance with paragraph 23 .F. ofthe Lease but is due an additional cost of ONE THOUSAND SEVEN HUNDRED TWENTY-FIVE DOLLARS and 06/100 ($1,725.06). 17. Further, Plaintiff is entitled to receipt of counsel fees, costs as incurred as a result of Defendant's breach of the lease agreement in accordance with paragraph 28.D. of the Lease. 18. Plaintiff has incurred Barbara Sumple-Sullivan, Esquire as counsel and has agreed to pay her the sum of ONE HUNDRED TWENTY-FIVE DOLLARS ($125.00) for her representation in this matter. Plaintiff has additionally incurred fees at the District Justice filing which are due for reimbursement. Plaintiff seeks all costs and legal expenses incurred until the date of judgment, which sum is now in excess of FIVE HUNDRED DOLLARS ($500.00). WHEREFORE, Plaintiff seeks judgment in the amount of THREE THOUSAND NINE / HUNDRED SEVENTY-FOUR DOLLARS and 06/100 ~J,97 .06), continuing legal costs and fees, as well as interest ~. I Ius prejudgment interest, Dated: January 30,2001 Barbara Sump Ie-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court J.D. 32317 Attorney for Plaintiff 4 ,~",-,,-, ~",,-"t' ""r:",,<p, ;",": "'-~""', ~_'-?-V____'_~' ,- '. ,- L . :'-~- ~ ,-_"r',"'.' -~ '--'-~-i- --, . "_~ - 1~-~: _ ,,~I-::- - .,-,^--, .-s~- ,'.,,",_. ._ <_~N___"_,,_,_..~___~_-,__,,h,. c" (' , , , , . ., ,1LITIES AND SERVICE L dl d'\I ~ 'd I ~ \I II" d / / A. an or WI I payor or provl e t Ie 0 owml! ut Illes an services: o Heat Is: - o Hot water Is:- o Electricity o Cooking Is: - " o Water is:- o Sewer Is:- o Trash removal 18I Association Fee o Furnace Contract o Annual furnace cleaning 18I Lawn & shrub care including grass cutting, trimming, edging, weeding, raking, watering, & debris removal. 18I Snow removal o Sidewalks o Parking lot o Driveway o Private lane o Sail for water softener OOther : - B T t '\I ~ 'd II f II t'l'lI d i !I !I enan WI I payor or provl e Ie 0 OWIIll! u I I es an serv ces: 18I Heat is: -ELECTRIC-HP /P P & L - 1-800-342-5775 18I Hot water is: -ELECTRIC .... 18I Electricity 18I Cooking is: -ELECTRIC 18I Water is: - PA AMERICAN - 1-800-717-7292 18I Sewer is: -OWNER WILL BILL 18I Trash removal -OWNER WILL DILL o Association Fee o Filter replacements o Lawn & shrub care including'grass culling, trillJll1ing, edging, weeding, raking, watering, & debris removal. 18I Snow removal 18I Sidewalks o Parking lot o Driveway o Private lane o Salt for water ~ofiener 18I Telephone-BELL ATLANTIC - 1-800-660-7111 [gI TV cable-SUBURBAN - 540-8900 o Other: - Cost of any and a\l repairs where the cost of each repair Is less than $-50.00 !i 16. APPLIANCES, IMPROVEMENTS, AND PERSONAL PROPERTY INCLUDED WITH PROPERTY: A. The following is a list of personal property of the Landlord which is included with the Property. These items are provided for Tenant use. Tenant must tell Landlord if any of these items are no longer useable. Landlord has the right to decide whether to repair, replace or remove the item: - B. The appliances/items marked off below are provided for the Tenant's use. Landlord Is responsible for the repair or replacement of these items. Tenant must tell Landlord if any of these items are not working properly. l8Irefrigerator l8Irange/slove l8Idishwasher l8Igarbage disposal Owasher Odryer Olawn mower Ofreezer o 0 Owindow unit air conditioners # C The appliances/items marked off below are provided for the Tenant's use. Landlord Is not respouslble for the repair or replacement ofthese items: If repairs are needed, Tenanlmay decide to repair these items at the Tenant's expense. Landlord still owns these items. Tenant must tell Landlord if any item is not working properly. Landlord has right to decide whether to remove the item: Orefrigerator OwMher Dwindow unit air condiLioners # \7. SPECIAL CLAUSES: Ifit is found that any part of this lease is void b<:ccause of any law. it will void only that part and not the entire lease. A. Tenants will have the carpets professionally cleaned at the end of the lease and must provide a receipt to Landlord, Odryer o Dlawn mower o Ofreezer o 13. - C. - D. - Rev. 10/97 Page 2 of 5 "<r"'ll!!~II9'1!ll~''''I~~ ~; ~" l ~" " n ~_,e..---------,. (-'-"', '......,'. '" ("') RESIDENtIAL LEASE I. DATE of Lease: -NOVEMBER C)~, 1998 2. PARTIES TO LEASE AGREEMENT: TENANT: (list all Tenants over 18 years old) Name: -THE AULSON CO" INC, Name: -c/o RON SIMON" Name: - Name: - 3. LANDLORD: (list all Landlords) Name: -MARIANNE INTRERI Work #: . Name: - Work #: - Contact Name: - Work #: - Mailing Address: -138 N, 30TH STREET, CAMP HILL, PA /7011 4. AGENT FOR THE LANDLORD is JACK GAUGHEN REALTOR If Managed by Jack Gaughen Realtor, managing Agent is: - Agent's office telephone #: - Agent's direct dial telephone #: - 5. PROPERTY ADDRESS: Landlord agrees to rent to Tenant the following Property: - 1705 CREEK VISTA DRIVE, NEW CUMBERLAND, PA 17070 of -LOWER ALLEN Township and of - CUMBERLAND County,Pennsylvania. 6. TERMS OF LEASE: A. Term oCU,ls Lease: -ONE YEAR AND 22 DAYS B. Starting Date: This Lease starts on-NOVEMBER 10, 1998 C. Ending Date: This Lease ends on -NOVEMBER 30, 1999 7. RENEWAL TERM: This Lease will automatically renew for continuous and consecutive tenns of -2 full calendar monihs at the Ending Date unless: A. Tenant gives Landlord -60 days written notice before Ending Date or before the end of any Renewal Tenn, OR B. Landlord gives Tenant -60 days written notice before 'Ending Date or before the end of any Renewal Term, OR C. Landlord and Tenant negotiate a new lease and terms at the Ending Date or before the end of any Renewal Term. D. Tenant agrees that a full montl,'s rent is dne for any month in which there is partial occupancy. 8. RENTAL AMOUNT: A. The total amount, of rent due over the term of this Lease is . . . , . . . . . . . . . . . . . . . . . . , . . . . . . . . B. The rental amount due and payable in advance monthly is . . . . . . . , . . , . . . . . . .. ............. C. Rent is due on or before the first day of each month. . D. Tenant will be charged a late charge of 10% if rent is more than 5 calendar days late equal to .. ,. Landlord's acceptance of the late charge does not waive the Tenant's obligation to pay on time. E. Tenant will pay a $25.00 fee for any check which is returned by any bank for any reason. F. Tenant is to make all rent payments and other charges payable to: - MARIANNE INTRERI and mail or deliver to: -138 N, 30TH STREET, CAMP HILL, PA 17011 9. PAYMENT SCHEDULE: Due DatelPaid A. Security Deposit, on deposit with: - LANDLORD DUE $ 795,00 B, First full month's rent iu the amount of. . . . . . . . . . . . . . . . . . . . . . . . . . . . . DUE $ 795,00 C. Part ofa month's rent if Tenant takes possession after the first day of the 1110nth. Forperiodfrom-12/10/98 to-12/31/98 - DUE 12/1/98 D. Pet Deposit: - E. Other:- Total amount due before Tenant moves in. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10, USE OF PROPERTY & AUTHORIZED OCCUPANTS: A, Tenant will use Property as a residential dwelling only. Tenant will not use the property for cOl11mercial uses. B. Not more than - 2 people will live on property. List all names here: -RON SIMON & -BILL MELENDEZ C. Guests are permitted. A guest is a visitor for two (2) weeks or less. . D. Tenant will not use the Property for any unlawful or illegal purpose. II. PET POLICY: 'l't'l' . A. No pets or animals of any kind are permitted on or within the leased property except as described below: -N/A B, Pet Clause attached as part of this lease: 12, DISCLOSURES: Landlord has made the following disclosures regarding the property, which are attached and made a part of this Lease agreement: [8J Lead Paint [8J Radon D Water Portability D Other: D Other: 13. REPAIRS TO PROPERTY BEFORE MOVE IN, IF ANY: Tenant understands that Landlord will make no repairs, additions, or changes to the property except as follows: -N/A Work #: - Home #:- Work #: -1-800-457-2366 X 627 Work #: - Home #:- Work #: - Horne #:- Home #: -737-4858 Home #: - Home#: - $10,104,00 $ 795,00 $ 79,50 $ 564.00 $ $ $1590,00 DYes [8JNo DSeptic 14. SUBLEASING AND TRANSFER: A. Landlord may transfer this Lease to another landlord. Tenant agrees that this Lease remains the same with the new landlord. B. Tenant may not transfer this Lease or sublease (rent to another person) this Property without Landlord's written pennissioll. Rev. 10/97 Page I of 5 ~X"",,'lI';1"O-""'f''''~;' ''''~~~''.~~'';:';':~' I ': i - ',:' '" I; ~ 'I 1-- ~r~ ~~ o '......;~. ' c, .... \, :ij '", '. i 18. LANDLORD'S RESPONSIBILITIES: A. Landlord will I. Keep Ihe P~operlY and cO'9r.on ar~as in reasona~le condition and as required by law. , 2. Be responsible for any and all repairs 10 Ihe exlenor of Ihe Properly and also agrees 10 be responsible for all repairs to Ihe inlerior of the Properly including Ihe heating, mechanical, plumbing, and electrical facilities which are part of the Properly, excepl as listed in paragraph 15.B.(Tenanl's Responsibilities). 3. Keep Properly reasonably free of pests, rodents and insects (excepl for single-family properlies.) 4. Supply ulilities and services as lisled in paragraph 15.A. (Utilities and Services) of this Lease, unless the service is inlerrupled by circumslances beyond Ihe Landlord's conlrol. 5. Pay alllaxes, assessmenls, insurance, mortgages, and ulilities thaI are Ihe Landlord's responsibilily. B. Landlord will not: I. Pay Ihe cosl of any repairs necessary because oflhe Tenanl, Tenanl's family or guesls' willful, careless, or umeasonable behavior. 2. Increase renls, decrease services, or threalenlo go 10 courllo evict Tenanl because Tenant: a. complains 10 a governmenl agency or 10 Landlord aboul a building or housing code violation. b. organizes or joins a Tenanl's organizalion. c. uses Tenanl's legal righls in a lawful manner. 19. TENANT'S RESPONSIBILITIES A. Tenanl will: I. Tell Landlord immedialely of any repairs needed. 2. Pay 10 repair any damage to the Properly or 10 any item in or onlhe Property Ihal Tenanl, Tenanl's family or guests cause. 3. Keep Ihe Property clean and safe. 4. Get rid of all trash, garbage and any olher waste materials as required by Landlord and Ihe law. 5. Use care when using any of Ihe electrical, plumbing, or olher mechanical facilities, or appliances on the properly. 6, Pay Ihe cosl of all ulilities and services including any lale charges and penalties as Iisled in paragraph 15.B. (Ulililies and Services) of this Lease, when due and on demand. 7. Mainlain and lesl regularlY all smoke deteclors onlhe Property. 8. Nolify Agent or Landlord of any broken smoke deteclor(s). ..... 9. Pay for any damage 10 Properly if Tenant fails 10 mainlain smoke delectors. 10. Return the'Properly to ils former condition or betler, al the lerminalion oflhe Lease, wilh Ihe exceplion of ordinary wear and lear or for causes beyond the Tenant's control. B. Tenanl will not: I. Keep any flammable materials on Ihe Properly except in a closed, cerlified container. 2, Deslroy or deface any parI of the Property. 3. Dislurb Ihe peace and quiel of other lenants. 4. Make any changes 10 Ihe property, such as painting or remodeling, without the written pernlission of Landlord, 5. Change any locks or keys without Landlord's wrillen approval. 20, RIGHT TO ENTER: A. Tenant must let Landlord or Landlord's representatives enter Ihe Properly al reasonable hours to inspect, 10 repair, or to show Ihe Properly to possible buyers and possible tenants. B. Landlord or Landlord's Agenl will give Tenanl reasonable advance nolice of dale and time for Ihe visit. C. In cases of emergency, Landlord or Landlord's represenlalives may enter Property without notice. 21. INSURANCE: A. Landlord will insure the properly against fire and olher casualty, including liability coverage for injury or damage occurring within cOl111l1on areas of the properly. --, B. Landlord is not responsible for loss or damage 10 Tenant(s)' properly on or aboullhe properly. ..... C. Tenanl(s) are advised io oblain a "RenIer's Insurance Policy" for Tenanl(s) prolection. 22. RULES AND REGULATIONS: A, All Rules, Regulations, and Reslrictions established by Ihe Landlord(s) are conlained in or attached 10 this lease. B, Associalion bylaws Ulal apply to the Tenant's use of the Properly are attached, if applicable, C. Tenanl(s) and Tenant's family agree 10 obey the rules and association bylaws provided. D. Tenanl(s) and Tenanl,'s falJ1il~ agree 10 obey Ihe laws oflhe goveming bodies with authority inlhe region that the Properly is localed and Ihal apply to thM Tenant's occupancy and use. E. Landlord calUlot cha'lge Ihe Rules unless the change benefits or improves the health, safety, or welfare of Tenants and olhers, or if challge in Rules is required by law. 23. SECURITY DEPOSI~: A. The securily deposil,is provided by the Tenant as a guarantee for Ihe performance orlhe lenlls of this lease, B. Landlord must keep deposils of more Ihan $100 in a special bank accounl (escrow accounl) and musl provide Tenan\ wilh Ihe name and location of the bank. Tenant is not entitled 10 any eamed inleresl on the deposil for Ihe Iirsll1No years oCthe Lease. . C. At the end oCthe secpnd year (ifTenanl continues 10 lease Properly), Landlord must deposit the security deposit in escrow acel Ihat earns inlerest. 1!enanl is entitled 10 interest earned onlhe securily deposit less 1 %, which is payable allhe end of Ihe Ihird year of occupancy. j..andlord is allowed 10 keep one (1) percent oflhe interesl for handling. ! D. When Tenant moves'from the Properly, Tenant must retum all keys and give Landlord writlennotice of Tenant's mailing add I where Landlord is 10 relurn Ihe securily deposit or any balance due the Tenant. i E. Tenanlmay not use recurily deposit as lasl monlh's rent. F. Landlord will prepa~~ aysl ofch~rges for damages beyond nonnal wear and tear and unpaid rents. Landlord may deduct Ihes'. charges from Ihe sepunty depOSIt. G. Landlord musl r~lur security deposil plus any inleresl due Ihe Tenanlminus any charges 10 Tenanl wilhin 30 days of the Tenanl's move ou~ of Ihe,Property. Rev, 10/97 Page 3 of 5 I~r:~f;~r~~ ,. " ;,: ";--';~~!II'lr""-\: \ ;~ o " f) A. POSSESSION A. Tenant may move in (take possession of the Property) on the Starting Date of this Lease. B. If Tenant cannot move in because previous tenant is still there or because of property damage, Tenant can 1. change the starting da\e,ofthe Lease to the day when Property is available. Tenant will not owe further rents until Property is available; OR 2. end the Lease and have all money already paid as rent or security deposit returned. 25. RENT INCREASES A. If the Tenant continnes to occupy the Property beyond the inilialterm (Renewal Term), Tenant agrees to pay any increase 01 lienable municipal charges such as water, sewer, and/or trash charges that are included in the rent and apply to Tenant's use. B. If Tenant's aclions cause an increase in property insurance, Tenant will pay the amount of the increase. C. Landlord may raise the rent when the lease ends with proper wrillen nolice. 26. FIRE OR OTHER DAMAGE A. If the Property is accidentally damaged (fire, flood, etc.) I. Tenant may continue to live in the livable part of the Property and pay a reduced rent as agreed to by Tenant and Landlord until the damages are repaired; OR 2. If the property is not livable as certified by an insurance company or govenunent agency, Tenant mustnolify Landlord immediately and must move out within 24 hours. B. If Lease is ended due to the above circumslances, Landlord will return any unused security deposit or advanced rent to Tenant. C. If Tenant, Tenant's family or guests cause damage by fire or by other means, this Lease will remain in effect and Tenant will continue to pay rent, even if Tenant call11ot live in the Property. 27. NOTICE TO END LEASE A. After Tenant or Landlord has given wrillennolice to end this Lease, Landlord must be allowed to show Property to possibl, tenants or buyers. Tenant must allow showings of Property to possible tenants or buyers during reasonable hours and with advance nolice of any showings. B. Landlord may put up For Sale or For Rent signs on or near Property. C. Tenant agrees to move out peacefully when Lease is ended. D. A full month rent is due In any month where there is partial occnpancy. 28. IF TENANT BREAKS LEASE: A. Tenant breaks this Lease ir: I. Tena~t .does not pay rent or other charges. 2. Tenant leaves Property perntanently before tile end of this Lease. 3. Tenant does not move out when supposed to. 4. Tenant fails to obey any of the tenns agreed to in this Lease. B. Non-Payment of Rent: If Tenant breaks Lease by not paying rent or other cbarges, Landlord must give Tenant TEN DAYS wrillen nolice describing the amount Tenant owes for rent and/or other charges, prior to filing a lawsuit. This means that if Tenant has not paid all balances due before the eleventh day after Landlord has given Tenant the wrillen nolice, Landlord can file a lawsuit for a money judgment against Tenant, evict tile Tenant, and/or take back possession of the property. C. Other Lease Violations: If Tenant breaks any other term of this Lease, Landlord must give Tenant wrillen nolice describing the violalion and give Tenant TEN DAYS to correct the problem. If Tenant does not correct the problem before the eleventh day after the Landlord has given Tenant the wrillen nolice, Landlord can file a lawsuit to evict the Tenant and/or take back possession of the property D. If Tenant Breaks Lease for any Reason, Landlord may: 1. File for a lawsuit for money and/or file to take possession of the Property against the Tenant, 2. Include in the lawsuit against Tenant all the legal fees, filing fees, and the reasonable costs of the Landlord and/or Landlord's Agent, including a re-renling fee. 3. Include in the lawsuit against Tenaut all rents and charges unpaid, and for rents and charges for the rest of the Lease Term, and for the cost of any physical damages to the Property. 4. Keep Tenant's Security Deposit, other deposits, any interest due, and any advance rents prepaid, if unpaid rents, charges, fees, and/or damages are equal to or exceed their total. 29. IF GOVERNMENT TAKES PROPERTY: A. A government or other public authority can take private property for public use. The taking is called condemnotioll. B. If any part ofthe Prope..,.:!, is taken by the govenuncnt, Landlord will reduce Tenant's rent proportionately. If all the Property is taken or is no longer usable, this Lease will end and Tenant will move out. Landlord will return to Tenant unused security deposit or advance rent. C. No money paid to Landlord for the condemnation of the Property will belong to Tenant. 30. TENANT HAS FEWER RIGHTS THAN MORTGAGE LENDER Landlord may have a mortgage on the Property. Ifso, Landlord agrees to make the mortgage payments. The rights of the mortgage lender come before the rights of the Tenant. (Example: If Landlord fails to make mortgage payments, the mortgage lender could take the Property and end this Lease.) TENANT UNDERSTANDS THAT IF THERE IS A FORECLOSURE, A NEW OWNER WILL HAVE THE RIGHT TO END THIS LEASE. Rev 10/97 Page 4 of 5 ',- . ~ . 1':'>...... V', l ~. . n, 31. MEDIATION A. Mediatioll is a way of resol~ing problems. A mediator helps the dispuling parties reach an agreeable solution without having to involve the courts. B. Landlord and Tenant may agree to take any disputes arising from this Lease to a mediation program offered by the local association of REALTORS or to another mediator. Landlord and Tenant can agree to mediation as part ofthis Lease (by signing a mediation form to attach to this Lease), or they can sign an agreement to mediate after a dispute arises. 32. CAPTIONS: The headings in this Lease are meant only to make it easier to find the paragraphs. 33. ENTIRE AGREEMENT This Lease is the entire agreement between Tenant and Landlord. No spoken or wrillen agreements made before are a part of this Lease unless they are included in this Lease. 34. NOTICE BEFORE SIGNING THIS LEASE IS A LEGAL CONTRACT. IF TENANT HAS LEGAL QUESTIONS, TENANT IS ADVISED TO TALK TO A LAWYER BEFORE SIGNING THIS LEASE. IN SIGNING THIS LEASE, TENANT CONFIRMS THAT THEY HAVE A THOROUGH UNDERSTAND;rG OF THIS LEASE. LANDLORD'SSIGNATURE ~~ ~J...)..,; DATE 1/-9-Y t' LANDLORD'S SIGNATURE DATE MANAGING AGENT'S SIGNATURE DATE DATEjl~~( DATE \. - . LISTING AGENT'S SIGNATURE TENANT'S SIGNATURE I I, RENTING AGENT'S SIGNATURE i ~~? ~A:r,~ / DATE DATMh/7'P- TENANT'S SIGNATURE "1"11' Rev 10/97 Page 5 of 5 ',W~l!f"!!Fli'fI'1""T ,~~ 1 e /-1 'I ~ ~ " Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 Counsel for Plaintiff MARIANNE INTRERI, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 01-227 CIVIL ACTION - LAW THE AULSON CO., INC. and RON SIMON, Defendants VERIFICATION I, MARIANNE INTRERI, hereby certify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to authorities. DATED: /~;2,&-()/ 111~~~ MARIANNE INT RI ','?;'-:":'"'" ,'- '"""'";":\'^'--i'F:~,,~_,_,.,_,,<:',~,~"'j': ~- F'-""".""_'.',,,," _""",n>,I"~"-'-'~'''-".~,'''''''''_'______N'''''!i''";~,__~ "",_~,,,,,,^,:,,,._,,_ ~~_ _,~ ",. "" '. _~ = ( . . "\ Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 Counsel for Plaintiff MARIANNE INTRERI, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-227 CIVIL ACTION - LAW THE AULSON CO., INC. and RON SIMON, Defendants CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing Complaint, in the above-captioned matter upon the following individual by first class mail, postage prepaid, addressed as follows: Joseph U. Metz, Esquire 214 Pine Street Harrisburg, PA 17101 Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court J.D. No. 32317 DATED: January 30, 2001 _--'_'-,0". ,,-","," , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA MARIANNE INTRERI, Plaintiff vs. NO. 01-227 CIVIL ACTION - LAW THE AULSON CO., INC. and RON SIMON, Defendants ANSWER AND NEW MATTER L Admitted. 2. Admitted. 3. Admitted however, m addition, Ron Simon was acting as an agent of Ecosphere Corporation at all times relevant to this action. 4. Denied. To the contrary, Defendant Simon is not an authorized agent of the Aulson Company but is an employee of Ecosphere Corporation of Hayes Street, Elmsford, New York 15023. 5. Admitted. 6. Admitted that Plaintiff entered into a written lease with Ron Simon. Denied that said lease was also with the Aulson Company. 7. Admitted as stated in the lease. 8. Admitted as stated in the lease. 9. Admitted and denied as follows: Admitted oral notice of vacation of the properly was given before July 9, 2001. Denied that said notice violated any provision of :1",~. ~, ,. ...~ <~"'_"~_'_'~ ". =I-~I "I the lease. To the contrary, said vacation of the premises was accepted by Plaintiff and agreed to at the time it was given. 10. Denied as a conclusion of law and further denied in that said vacation of the property was accepted by Plaintiff. 11. Denied as a conclusion of law and further denied factually that any such sum is due based on the prior paragraphs of this Answer. 12. Denied as a conclusion of law and further denied as previously set forth in this Answer. 13. Denied that Defendant Aulson Company or any authorized representative thereof caused any damage beyond ordinary wear and tear to the premises. 14. Admitted and denied as follows: Admitted that Plaintiff paid the amounts set forth for the items listed in A through G. Denied that those expenses were reasonable expenses to be expended for the products and services set forth. Further denied that such expenses as are listed to the degree they exceed $50 are the responsibility of any of the Defendants under the lease. Further denied that said items are the result of any damage beyond that of normal wear and tear under the circumstances and that authorized representatives of the Aulson Company had anything to do with such damages. 15. Admitted the total repair and replacement cost paid by Plaintiff was as set forth. Denied that said amount was reasonable or would not have been incurred anyway under the reasonable circumstances than existing. 16. Admitted Plaintiff applied the security deposit but denied Plaintiff is due any further money under the lease for any other reason. 17. Denied as a conclusion of law. 2 :Jt"_~ . ,'".-1r - '-",' "",.,. ' '"'.''T'", I. ~- 18. Admitted those expenses have occurred and said expenses are reasonable. Denied that Defendant Aulson Company is responsible for those amounts. WHEREFORE, Defendant The Allison Co., Inc. respectfully requests that judgment be granted in its favor. CROSS CLAIM AGAINST DEFENDANT RON SIMON 19. All items complained of in Plaintiffs Complaint are the responsibility of Defendant Ron Simon and his employer, Ecosphere Corporation, and not the Allison Company. WHEREFORE, The Allison Co., Inc., requests judgment in its favor and against Defendant Ron Simon. NEW MATTER 20. Defendant Allison Company incorporates the defenses to this action set forth in the lease including but not limited to the following: a. All substantial repairs are the responsibility of the landlord and not of the tenant. b. The lease in question was signed by Ron Simon, an employee of Ecosphere Corporation with no authorization to bind the Allison Company. c. No adequate written notice of a violation of any terms of the lease was given by Plaintiffs. 21. The damages complained of are normal wear and tear or maintenance for which recompense cannot be sought. 3 '-","",,!", '1'/1:' ',c' I: -~l '--, 22. Plaintiff agreed to the early vacation of the promises and cannot now attempt to claim paid rent for the post-notice time period. 23. Defendant Aulson Company is not responsible for the damages alleged. Respectfully submitted, Date:!,/ s; q 4 )!:, " - . ,. ~,- -. 'd- ,~ n I"~'} VERIFICATION I hereby affirm that the authorized representatives of the defendant Aulson Company are outside the jurisdiction at the present time and that I am making this verification based on information and belief in their absence. J~#Jff} ;if_:~:~)_ h _~ _l_,_~l'_' ,_' ...,- 7~, _1_1 -".,< .'IT-> . . CERTIFICATE OF SERVICE And now, this s:1E1 day of March, 2001, I hereby certify that I have served a true and correct copy of the foregoing Answer and New Matter upon the person in the manner indicated below: Service by first class mail, postage prepaid, on this date addressed as follows: Barbara Sumple-Sullivan, Attorney 549 Bridge Street New Cumberland, P A 17070-1931 <;~g~ -:----. , , "--, >-+ ~ ,- , ''''' Barbara Sump Ie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 Counsel for Plaintiff MARIANNE INTRERI, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-227 CIVIL ACTION - LAW THE AULSON CO., INC. and RON SIMON, Defendants REPLY TO CROSS CLAIM AND NEW MATTER 19. Denied. Paragraph 19 is denied as a conclusion of law to which no responsive pleading is due. It is further averred that if Defendants Simon and Aulson were separate entities, copies of the Cross Claim should have been served on Simon and his employer, Ecosphere, by Defendant Aulson. It is further averred that Aulson has paid all the rentals relative to the premises and has also had sole use and occupancy of the premises at various times during the tenancy for its employees. It is further averred that it was Defendant Aulson who clearly delivered the property to Plaintiff. Defendant Simon was an agent of The Aulson Company and had the authority to bind The Aulson company. 20. Denied. Paragraph 20 is denied as a conclusion oflaw to which no response is due. The lease is a written document which speaks for itself and Plaintiff denies the characterization of the lease made by Defendant. 21. Denied. It is denied that the damages to the property were wear and tear. It is asserted that . J ' ..''''''t ,<,,,,, ;_'~' :,-.c>n" ""~-:"-, ,,...,,~:,,j,,,,,,,.', .:..:~ "',~, _"::}_~'I",ct"',f-~'<~,;,;- ,. ,_<~ _, '~"""_.-:'_1~ 'F''''' ~ l ";'.<t.:___;':,~ ,-- "";_" '_""oj ~, .,,,,,,,,,,, ,,_,.e.,..'.' ,-"._._ ,,-, """".-' burning holes in flooring, removing wallpaper pieces, smoke detectors, nailing wiring into walls, etc., far exceeds normal wear and tear. 22. Denied. It is denied that Plaintiff agreed to an early vacation of the promises(sic). It is asserted that Defendant did provide oral notification that it was leaving the premises which Plaintiff received. It is averred that said notice was not in accordance with the terms of the lease or that Plaintiff, at any time, ever modified the lease requirements relative to termination. 23. Denied. Paragraph 23 is denied as a conclusion oflaw. Respectfully submitted, Dated: March 19, 200 I ,~ "" ;' ~<;. , ( Barbara Surnple-Sullivan, Esquire 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 Supreme Court J.D. 32317 Attorney for Plaintiff 2 '", " >-, -< ','~~:"'-!?-~f7\';:""~_-"'", """':"_'~"" ;'~",' -''(:::_'2:!:'::~I~ ~I~' ,,>-~'~ry;-t_'r' <,,): ;~c ' ,_'0" ,r I - -: ", - '--<1'1!'~(_1, -:'7'.-"'1",.' _":,,m :',~,~",_,- ~ ~, ,f' .',",,,n,.-,,, ,_, ,,,~ '., .'~'~~" -"_~ . . Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 Counsel for Plaintiff MARIANNE INTRERI, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-227 CIVIL ACTION - LAW THE AULSON CO., INC. and RON SIMON, Defendants VERIFICATION I, MARIANNE INTRERI, hereby certify that the facts set forth in the foregoing Reply to Cross Claim and New Matter are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to authorities. DATED: ,1 -j ~-(JI - ~~ MARIANNE INTRE ' i~~~-,-,,-- - '\ _"-.__;_c,_-,-,k'_~"E'",g_'_"~"."F~.-'___'__' _, .- .','h,H, '-""-I.-c"" _r,-,~,_"",,,""'''''''_,'__~T'''',,",,,,,.,. r---._-,'_"~___:I ' '~.-"'--, . .,- ,- ""~om, .",_,,,"....,.,". "' ~"7_ ,_.",-, Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 Counsel for Plaintiff MARIANNE INTRERI, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-227 CIVIL ACTION - LAW THE AULSON CO., INC. and RON SIMON, Defendants CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing Reply to Cross Claim and New Matter, in the above-captioned matter upon the following individual by first class mail, postage prepaid, addressed as follows: Joseph U. Metz, Esquire 214 Pine Street Harrisburg, PA 17101 Mr. Ronald Simon c/o The Allison Co., Inc. 49 Danton Drive Methuen, Massachusetts 0184 DATED: March 19, 2001 Barbara Sumple-Sllilivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court J.D. No. 32317 '\~~ . ""-" ,':" o,"f!';r';'~>~:'\f;, '_'Ue"_,-,."_ "',,_e"jj:'~_,~ "'lO ~-:"I}? ~'<' _"'~'-"'~~'!_'_,,1 ___.o''"'-'.''.-- ' --'I-~~"-' ,"_'\ ~ , '''.' _ ,~ 7 " ,,~,__, ,- ',' _~ .~ "_ , '. MARIANNE INTRERI, . Plaintiff vs. '. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-227 CNIL l/:ll. THE AULSON CO., INC. AND RON SIMON, Defendant RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Barbara Sumple-Sullivan , counsel for the plaintiff/~ in the above action (or actions), respectfully represents that: 1. The above-captioned action ~) is ~ at issue. 2. The claim ofthe plaintiff in the action is $ 3,974.06 plus co.ntinuing legal The counterclaim of the defendant in the action is 0 fees and interest. The following attorneys are interested in the case(s) as counselor are otherwise disqualified to sit as arbitrators: Barbara Sumple-Sullivan, Esquire and Joseph U. Metz, Esquire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Barbara Sumple-Sullivan, Esquire ORDER OF COU T AND NOW, ,~ in consideration of the Esq., ~~ ~~ , Esq., are appointed arbitrators in the a ve captioned action (or Esq., and actions) as prayed f BY~~ PJ. '_:~, . - - ry . Y. 'T~' ,"" ,~- 1-, I r -, " I~ - . ". .< '" .'. , ~ ~', J.- ;,~ "1<;" {{, ' ,,- " ,', ; "\!l\\""" j; ~' ... ;__ v~~, ~~r", ,~p \iINVA1ASNN3d ALNnOO Or,I\f1H18V1Jn:J \ LG :6 HV 1 Z o\H~ 10 '\l:NlONCCUUilc :J'" - ',j 3Jl.:UO""Gjlj~j ~~__~_ ~ ,_~v ~~ . ~" r" ~---- "~ .~~ '~'I-"'" - ...~, ".,..,...I"m~~1;!1:111!~J!!'<llfflf'l'f''''_''''!;%l'fflIlW~~~1j:j'~tt',~V~~~~l'l~iI!\~~,,!II!~~ c' . Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 MARIANNE INTRERI, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-227 CIVIL ACTION - LAW THE AULSON CO., INC. and RON SIMON, Defendants CERTIFICATE OF SERVICE I, BARBARA SUMPLE-SULLIV AN, ESQUIRE, do hereby certify that on this date, I served a true and correct copy of the Petition for Appointment of Arbitrators, in the above- captioned matter upon the following individua1(s), by United States first-class mail, postage prepaid, addressed as follows: The Aulson Co., Inc. c/o Joseph U. Metz, Esquire 214 Pine Street Harrisburg, PA 17101 Mr. Ronald Simon c/o The Aulson Co., Inc. 49 Danton Drive Methuen, Massachusetts 01844 DATE: March 19, 2001 . Barbara Sump Ie-Sullivan, Esquire '- 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court J.D. 32317 Attorney for Plaintiff ~'-{~, r,-. ,--, ~,~ ~_, ,'-,"ry-"'''_~'')''!it .""'0'"." ~ "'1~'2.'''~'' ,,- ,c"'e_'~_,'I'~i'1M"_~><<:_9"__~ """")~"',r_ _ ,~, ,- ,_,_-_ I'""M,,' ',' . ,'.. " ,_,..\._,,,, _'''"''. 0'"._ ",_~_' v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-227 : CIVIL ACTION - LAW MARIANNE INTRERI, Plaintiff THE AULSON CO., INC. and RON SIMON, Defendants To: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 Attorney for Plaintiff Joseph U. Metz, Esquire 214 Pine Street Harrisburg, PA 17101 Attorney for Defendants NOTICE OF ARBITRATION HEARING YOU ARE HEREBY NOTIFIED thatthe undersigned arbitrators, appointed by the Court in the above captioned malter, will meet for Ihe purposes of their appointment on Tuesday, June 19, 2001, beginning at 9:00 a,m.in the Second Floor Hearing Room of the Old Cumberland County Courthouse, Carlisle, Pennsylvania, at which time and place you may appear to be hears, together with your wilnesses and counsel, if you desire, Lindsay Dare Baird, Esquire - Chairperson Timothy J. Col9an, Esquire Rolf E, Kroll, Esquire Sent: May 3, 2001 cc: Court Administrator Arbitration Panel ~ ~\) ~~~D\ ~ \ 'i 'DI'" ~~-~~, -r'~' - I ' ~ I' 0' ~.. ~, ~!!!\-~ MARIANNE INTRERI, Plaintiff V. THE AULSON CO., INC., and RON SIMON, Defendants IN RE: ARBITRATION : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA 01 - 227 CIVIL ORDER OF COURT AND NOW, June 1, 2001, the appointment of Rolf Kroll, Esquire to the above-captioned arbitration panel is vacated, and Stephen Banko, Jr., Esquire is appointed in his stead. Lindsay Dare Baird, Esquire Chairman Court Administrator ~-,,;-~~-~ "f ~. I r,'," I ., ',' d,' -, ,-~_-,,-, , _" By the Court, Ge4JJMtl Lcrpiw l,-,-Ol n ,,_. ,_,_,_ P.J. " >- - CI:: 1= :<C ...:i r- eS ~ wQ fE5~ oS:: "'- (JZ ~-~ ;" "'" Cl~ .._,J!-.~, 6['~ ;;5= LJ~', ::J.~ ;~, z CCz :::> lUt,u J me.. ~ 0 0 :s (J "~ "'" ~"1l!' ~ I ~, \ .'k ~ ,'~- -.'-~' _ " '" '~',k\-'I"_; -~.', -"-f'~-~-,c,o_- ,'. ,,... ~_~__~ ~_ff!)I~~~.__"1.,.__,~~~~-N;;tI'a,~~~r'i'~I!lI\4-~,_, .,. - ,--,'-"_""',\.1, ~if:1('1fRllii'rily';"-:':"'l':-"'---"i'ifi,\t"'lff"'-- . ;!1,~e;~M~'L _'<', '..' _,,~._,,('-~~~ < MARIANNE INTRERI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. 01 - 227 CIVIL THE AULSON CO., INC., and RON SIMON, Defendants IN RE: ARBITRATION ORDER OF COURT AND NOW, June 1, 2001, the appointment of Rolf Kroll, Esquire to the above-captioned arbitration panel is vacated, and Stephen Banko, Jr., Esquire is appointed in his stead. By the Court, /IMAAIV\ Ge~')-'Hftir:U 1 P.J. Lindsay Dare Baird, Esquire ~/ Chairman Court Administrator ... 'DtlO!lllil j- -r" __~ , '~., r1^ /' MARIANNE INTRERI : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVIA v. : 01-227 CIVIL TERM THE AULSON CO., INC. and RON SIMON IN RE: ARBITRATION ORDER OF COURT AND NOW, July 19, 2001, the Court having been informed that the above-case has been settled, the panel of arbitrators previously appointed is vacated and the chairman, Lindsay Dare Baird, Esquire, shall be paid the sum of $50.00. By the Court, P.J. Lindsay Dare Baird, Esquire '. /J Chairman &rt ~ Court Administrator '7- ~ 'f- 0/ C} ;"!ili"..,, :'~ .,_",,,~.,"O-"'~"Y!~_ _ --)_-~_-;I we. '_'"" .~,,,' '1" - . 'r~"~" "'"-" '.'U' "n'" " t..Jdb/O' ~ c?~ -fv ~.;., C/.-d~M ;,... ,~,- C"J }-.':: -.-;: -,;' ~r"-r ~. "~~-~""",""'."!< , . ,-I""" 1IT] """'>'~~~ -, ",~- ,- ..,"" ..,..' ",,- " "'~" '..'oLk -;'1""', '-,",',""""..">~=,,,,,,~,", '.'.~,...'-~-< '~'W"""'''jillr _W~~!<~'l'iWl'-!'l!_~f'I'ri'~~_",_ !,...U'fI~l'l~)'t~~\I!l~$I;~Dl1J,""1'O: ; ... Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 MARIANNE INTRERI, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 01-227 CIVIL ACTION - LAW THE AULSON CO., INC. and RON SIMON, Defendants PRAECIPE TO SATISFY TO THE PROTHONOTARY: Please mark the above-captioned matter settled and satisfied. Dated: September 12,2001 arbara Sumple-Sullivan, Esquire 49 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court J.D. 32317 Attorney for Plaintiff \ Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 MARIANNE INTRERI, Plaintiff v. THE AULSON CO., INC. and RON SIMON, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA NO. 01-227 CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing Praecipe to Satisfy, in the above-captioned matter upon the following individual by first class mail, postage prepaid, addressed as follows: DATED: September 12, 2001 i ' ',,~ " - -,,'" ''"'<-'<1'' '.' .~" "~-.~:'-:'_:.J~-') - ..', ~ Joseph U. Metz, Esquire 214 Pine Street Harrisburg, PA 17101 Mr. Ronald Simon c/o The Aulson Co., Inc. 49 Danton Drive Methuen, Massachusetts 01844 bara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 '_~C,' '1'.'",; - I I"," ,.~",'."o>".'".'''''' ...n,'..,=,...""~"",,w" ... .. . ~,~ _,_ _,~^_ "0 ~_- .,,,,, , ,~-,"_,_-. 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