HomeMy WebLinkAbout01-1877 FX
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ORCHARD APARTMENT,
ASSOCIATES, t/d/b/a
ORCHARD APARTMENTS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001 - 1877 CIVIL
v.
CIVIL ACTION - LAW
DOWAYNA LUCAS,
Defendant
ORDER
AND NOW, this
day of
, 2001, after
review of the annexed Petition and upon the motion of
Jordan D. Cunningham, Esquire, it is hereby ORDERED that
the prothonotary of Cumberland County, Pennsylvania,
distribute to the Plaintiff, Orchard Apartment Associates,
t/d/b/a Orchard Apartments, any and all amounts being held
in the Prothonotary I s rent escrow account in the above
docketed case.
BY THE COURT:
J.
II
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COM~WEALTIj OF PENNSYLVANIA
COURT OF COMMON PLEAS
NOTICE OF APPEAL
FROM
JUDICIAL DISTRICT
.
DISTRICT JUSTICE JUDGMENT
COM_NPLEASNo. 0 J . J 55 77 c i IIi L
NOTICE OF APPEAL
Notice is lliven that the appellant has filed in the abave Caurt af Camman Pleas an appeal fram the judgment rendered by the District Justice an the
date and i~ the case mentianed belaw.
NAME Of APPELlANT
Dowayna Nakeya Lucas
ADDRESS OF APPEUANT
2206 Cedar Run Drive Apt. L
IN THE CASE OF (Plaintiff)
MAG. DIST. NO OR NAME OF QJ.
harles Clement, Jr
OTY
Camp Hill
STATE
Zl'CODE
PA
17011
I>>.re JlJDGMENT
3/20/01
(Defendant)
O.AIM NO
'IS. Dowayna Nakey
SIGNATURE OF APPELLANT HIS ATTORNEY OR AGENT
hilip C. Briganti
CV12 idpenn Legal Services
LT 19 LT-00001 47 01 Irvihe Row .
This black will be signed ONLY when this natatian is required under Po. R.C.PJ.P. No. If appellant was CLAIMAI'iIT (see Pa. R.CP.JP. No.
10088. '
This No\ice af Appeal, when received the District Justice. will aperate as a 1001(6) inaction before District Justice, he MUST
SUPERSEDEAS to the judg lot pass ian i this case. FILE A COMPLAINT within twenty (20) days after
filing his NOTICE of APPt:AL.
Orchard Apartments
Lucas
f'..
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO IiILE
(This sectibn of fomJ 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 ccpy of notice of appeal to be served upon appellee).
PRAECIPE: To. Prathanotary
Enlef rule upan Orchard Apartments ,appellee(s), to file a complaint in this appeal
Name of appelJee(s)
(Comman Pleas No. ~I - J <g 1 r; C i vi l ) within twenty (20) days after s
RULE: To.
Orchard Apartments
Name of appeI/fre(s)
, appellee(s).
(1) You are natified that a rule is hereby enlefed upon you to file a complaint in this appeal within twenty (20) days altet the date af
service af this rule upan yau by penanal service Of by certified Of registered mail
(2) If you do nat file a complaint within this time, a JUDGMENT OF NON PROS Will BE ENTERED AGAINST YOU.
Date: 03~ 30
, lItiLJ
or Deputy
(3) The date af service af this rule if s",vice was by mail is the date af mailing,
N:)PC 312-84
COURT FILE TO BE FILED WITH PROTHONOTARY
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PROOI= OF SERVICE OF NOTICE OF APPIEAL AND RULE TO FILE COMPLAINT
(This prool of servioe MUST BE FILED WITHIN TEN (10) DA YS AFTER liling the notice 01 appeal, Check applicable boxes)
COMMONWEALTH C'F PENNSYLVANIA
COUNTY OF____
; S5
AFFIDAVIT: I hereby swear or affirm that I served
o a cooy of the Notice 01 Appeal Common Pleas No, , upon the District Justice designated therein on
(elate ot service) D by personal service D by (certified) (registered) mail, sender's
receipt attached hereto, and upor the appellee, (name) , on
_ , 19__ by personai service 1:1 by (certified) (registered) mail, sender's receipt attached hereto,
o and :'urther that I served the Ruleto File a Complaint accompapying the above Noticeo! Appeal upon the appellee(s) to whom
the Rule was addressed on " 19-:-r-' q by personal service 0 by (certified) (registered)
mail, senders receipt attached hereto . '
SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS ____~, DAY OF __~
__, 19~_
Signature of affiant
Signature of offlCi,,1 be/ora whom affid<:1II1'f was made
Title of official
My commission G:J(pjre~; on
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03/29/01
14:45 FAX 717 761 8580
D J CLEMENT
141002
09'1.01
01- /'l77 Civ; L
NOTICE OF JUDGMENTITRANSCRIPT
PLAINTIFF' RESIDENTIAL LEASE
IoRi'!Iim APAR~~;ACCAESS
2204 CEDAR RUN DlUVE
CAMP BILL, PA 17011
L
VS.
DEFENDANT: NAME and ACCRess
ILUCAS, DOWADIA NAXEYA
2206 C!'RnAR RUN DR. APT.#
CAMP BILL, PA 17011
L
'\
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: COMBEKLAND
.
M;J.g.DISLNg,;
~ OJ Nama: Hcl'l,
;: . :::',CHAlUrES A. CLEMENT, .JR.
..."",s: 1106 CARLISLE ROAD
" ' CAH1? HILL, PA
,T~.,h,","(717l 761-4940 17011
.J
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DOWADIA N. LUCAS
220'6 (,E1'Ill~ RUN DR. AP'1'.# L
.CAMP .BILL. PA 17011
.J
Docket No.: L'1'.0000147-01
Date Filed: :3/09/01
,
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLADllTl:PF
[!] Judgment was entered for: (Name) ORCBAIID APARTMENTS
r::1 Judgment was entered against LUCAS. DOWA'fNA NAKEYA
00 LandlordfTenantactionintheamountOf$ 1.061.50 on 3/20/01
The amount of rent per month, as established by the District Justice, is $
The total amount of the Security De osit is $ .00
. Total Amount Established b\L DJ Less' Security Deposit APD.lield = Adjudicated A~u8t
Rent In Arrears $ 657.00 -$ .'00 = $ 657. 0
Physical Dan:ages Leas,ehoJd Property $ .00 $ . 00 - $ : 00
Damages/Unjust Detention $ 12:3 nn $ no $ 321. on
Less Amt Due Defendant from Cross Complaint - $ . 00
Interest (if provided by lease) $ 00
LIT Judgment Amount $ 980.0 n
Judgment Costs $ 81 C; n
Attorney Fees $ n n
Total Judgment $ 1.061.50
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
y Ime 0 eVI Ion.
D Defendants are jointly and severally liable.
in a
. (Date of Judgment)
278.00.
D Attachment Prohibited!
Victim of Abuse (Act 5, 1996)
.0 This case dismissed without prejudice.
[!] Possession granted.
B Possession granted if money judgment is no sa IS Ie
Possession not granted.
o Levy is stayed for_days or 0 generally stayed.
o Objection to Levy has been filed and hearing will be heid:
Date:
Place:
Time:
CORRECTED DOCUMENT
IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM ~.lUD~U~ FOR POSSESSION WITHIN
TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH T~~. f\ROT~flOi'AIjY/CLERK OF COURTS
OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAl'OfTHE MONE.Y ~UDt;,.,ENT.IF ANY. IN
,ORDER TO OBTAIN A SUPERSEDEAS, THE APPELLANT MUST DEPOSIT WITH THE PROTHOtlOTARY/CLERK OF COURT,'! THE LESSER OF
THREE MONTHS RENi ORTHE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL $ FILED. . " ,<'.
IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVIN\tA RESIDENih;HEASE. TfIEj:>ARTY HAS
30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPP.L WITH THE PROTHONO\",RY/CLERK OF
COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION, ..., ...., ';". >'~~'. '.'
THE PARTY FiliNG AN APPEAL M~ J!CLU9l'. A C,q'Y NO~ MENTIT~NSCRII'T ""."" WITH Ti.li:"'''T'f.''' o~ A~~'"^'-
3/20/2001 Date ~ \,,{. ,DistrictJustiCe
cert tat IS IS a true an correct copy 0 t e recor 0 t e procee lOgS contalOlOg e jU gmenL
Date . District Justice :.'l>. '.
My commission expires first Monday of January, 2002. SEAL
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ORCHARD APARTMENTS
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
DOWAYNA NAKEYA LUCAS,
Defendant
OJ-I'!']?
NO. CNIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Dowayna Nakeya Lucas, Defendant, to proceed in forma pauperis.
I, Philip Briganti, attorney for the party proceeding in forma pauperis, certify that I believe the party
is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit
showing inability to pay the costs of litigation is attached hereto.
p&/~.
Attorney for Defendant
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ORCHARD APARTMENTS
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
DOWAYNA NAKEYA LUCAS,
Defendant
NO. o....lnbvIL TERM
AFFIDAVIT IN SUPPORT OF PETITION
FOR LEA VB TO PROCEED IN FORMA PAUPERIS
1. I am the defendant in the above matter and because of my financial condition am unable to pay the
fees and costs of prosecuting, defending, or appealing the action or proceeding.
2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of
litigation.
3. I represent that the infonnation below relating to my ability to pay the fees and costs is true and
correct.
(a) Name:
Dowayna Lucas
Address:
2206L Cedar Run Dr
Camp Hill. PA 17011
(b) Social Security Number: 199-58-4082
If you are presently employed, state
Employer: Pinnacle Health
Address: 101 Filbert Street
Mechanicsbur~. PA 17055
Salary or wages per month:
$860/month (net)
Type of work:
Certified Nursin~ Assistant
If you are presently unemployed, state
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-
Date of last employment:
Salary or wages per month:
Type of work:
(c) Other income within the past twelve months
Business or profession: N/A
Other self-employment: N/A
Interest: N/A
Dividends: N/A
Pension and annuities: N/A
Social Security benefits: N/A
Support payments: N/A
Disability payments: N/A
Unemployment compensation and
supplemental benefits: N/ A
Workman's compensation: N/A
Public Assistance: N/ A
Other: N/ A
(d) Other contributions to household support
(Wife)(Husband) Name:
If your (husband) (wife) is employed, state
Employer:
Salary or wages per month:
Type of work:
,..~ ~ _I,
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Contributions from children:
(e) Property owned
Cash: $0
Checking Account: NI A
Savings Account: $10
Certificates of Deposit: NI A
Real Estate (including home): N/A
Motor vehicle: Make N/A Year
Cost
Amount owed
Stocks; bonds:
Other:
(f) Debts and obligations
Mortgage:
Rent:
N/A
N/A
$278.00
Loans: Student loans $50
Monthly Expenses: Groceries $130: Electric $68: Tell4'hone $35: Gas (heat) $78: TV cable $70
Daycare $100: Transportation $120: Clothimr $.100: Miscellaneous expenses $50:
(g) Persons dependent upon you for support
(Wife) (Husband) Name:
Children, if any:
Name: Kayla Lucas
Age:
4 years
1 year
1)ranna Warren
1'yree Warren
10 months
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4. I understand that I have a continuing obligation to inform the court of improvement in my
financial circumstances which would permit me to pay the costs incurred herein.
5. I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to
authorities.
Date: 3 -8'D :-o(
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ORCHARD APARTMENTS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
v.
: CUMBERLAND COUNTY, PENNSYL VANIA
DOWAYNA NAKEYALUCAS,
Defendant
: NO CIVIL TERM
01- HI!?
AFFIDAVIT
1. I am the defendant in the above-captioned action, which is an appeal from a judgment
rendered by District Justice Clement on March 20, 2001, awarding Plaintiff possession of the
apartment in which I reside.
2. My rent for this apartment, located at 2206L Cedar Run Drive, Camp Hill, Cumberland
County, Pennsylvania is $278 per month and is due by the 5th day of each month.. My rent is
subsidized by HUD.
3. I verifY that the statements made in this Affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to
unsworn falsification to authorities.
Date:
3/3D/a I
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. ...... ..... .' ." '. . NOTICE OF AltPEAL .
COMMO~\ivE~~'rHOF PEN~~'I'~Y!,N'i\ .
COllli' OF COMlIiIOtlpLEAs
~ t Wi'r,;,1!):.l~~.~.6~';';::"".
FROM
JUDICIAL DISTRICT
DISTRICT JUSTICE JUI)GMENT
COMMON PLEAS No. 0 J -/ 'IS?7 C l;j I L
NOTICE OF AIlPEAL
Nofice is g"':en that tile appellant !)as filed in the abave Court of Common Pleas an appeal from the judgment rendered by the District Justice on the
date aocj in thO case inenfioned Delow.
NAME OF APPELLANT,'
Dowayna NakeyaLucas
ADDRESS OF APPEI.1:AN1'
2206 Cedar Run Drive Apt. L
MAG. D1ST. NQ OR NAME OF OJ,
harles Clement, Jr
OTY
Camp Hill
STATE
Pl\.
ZIP CODe
17011
Dr'TE~T
, i"' '01
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Q.AJM NO
(Defendant,
"" Dowayna Nakey
SlQ~TUR~ OF APPELlANT OR HIS ATTORNEY OR AGENT .It
pn1L1p C. Briganti
CV12 Midpenn Legal Services
LT 19 L'1'-0000.14,7-01 8 Irvine Row Carlisle PA 17013
This block will be sjgne<!UNLY wl)i;n this'llOtafiqn is required under Po. R.C.PJ.P. No. If apPellant'was' CLAIMANT (seePa. R.C.P.JP. No.
10081l. . \.".. . .... ". '.
lhiS.. No.' tic.eof APP....e~I., w. .rec. ..er~ve.. ....d. ...t~'~istrict JUstiC. e, will operate a.s. a. 1001 (6J.. in.act.iQn bf'ifore District../liStice, he MUST
.;SUP. ~RllI'DEAS to t~e)"'jg . fQrpo ". on I t.hlS. c.ase. " . . F~LE A COMPLAINT within twenty (20) days after
,: -,- . ll. . , .. filing his NOTICE of APPEAL.
.) Signature' of Pro notary or
::':.'t"LI\(,."!:!):i:f1
," ,:.,.p.EciPE;:TO:ENTER RULE TO FILE COMPLAINT AND RULE TOFII.E
"'.' ""\:\.
(This sectionoi'Yonn tei be used ONLY 'when appellant was DEFENDANT (see Pa. HO.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).
PRAECIIlE: To Prothorlolary
Enler rule upon Orchard Apartments ,appellee(s), to file a complaint in this appeal
Name of appellee(s)
(Common Plea. s No. ~I.'/ g 17 . C i V i l ) within twenty (20) days after ~e of rule or s~ffer
. ...., '. ffh (~
Signa/we
RULE: 'To
9r(;)l),~rd
Apar,tmet;lts
Nathe of appeJJoe(sJ
, appellee(s).
hat'a rule ish",,!I;>)."~ntered upon you to file a complaint in this appeal within twenty (20) days afler the dale of
. al seivici,~Or.by .certified or registered mail ..
\, . .
within this fime, a JUDGMEN-T OF NON PROS WILL .BE ENTERED AGAINST YOU.
or Qeputy
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AOPC312-84
C.OURT FILE
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PROIOF' 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~.M h.p/,~.od-.._____ ;..
AFFIDAVIT: hereby Swe~r or affirm lhall served
/~- I 7 (, .r
B a copy 01 the Notice ot ,~ppeal. Common Pleas No. C2l:::-, g 7 '1/, I ,upon the District Justice designated therein on
(date of service) /h Q("t::l. ..'<:0. ,;ldtJ J , [J by personal service rn1iy (cerlified) \l<lffli51Clca) maii, sender's
atfached hereto, and upon the ~ppellee, (name) (/(' C;harrl./}oQ/'fmp'n-f:r , on
_,L!'J QrcA 50 ,~..2adl 0 by personal service G:l15Y (certified) ~"""edt mail, sender's receipt attached heret'\:
!B....a~ld furtner th&t ! Si;;rved the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) \0 whom.
the Rule was addressed on /?I q.... (,< .50 . , 1'" ?NJ/ 0 by personal service O-rsy(.;ertiiied) (,.~im ~. '1'-
mail, sender's receipt attached hereto, /7 \
SWORN (AFFIRMFD) AND SUBSCRIBED BEFORE ME
THIS ______ DAY OF ___._._~ , 19_
Signature of officuH beiore whom Mfidm,jt was m&(!o
Title of oUicial
My commission ex;)ire~: on _________ , 19__
I verify that the statements made in this Affidavit are true and correct. I
understand that false statements herein a.re made subject to the penalties
of 18 P.S. Section 4904, relating to unsworn falsification to authorities.
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ORCHARD APARTMENT
ASSOCIATES, t/d/b/a
ORCHARD APARTMENTS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2001 - 1877 CIVIL
DOWAYNA LUCAS,
Defendant
CIVIL ACTION - LAW
NOTICE
TO DEFENDANT NAMED HEREIN:
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 j~dgment 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, PA 17013
Telephone: (717) 249-3166
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NOTICIA
Le han demandado a usted en la corte. Si usted quiere
defenderse de estas demandas expuestas en las paginas
siguientes, usted tiene viente (20) dias de plazo al partir
de la fecha de la demanda y la notificacion. Usted debe
presentar una apariencia escrita 0 en persona 0 por abogado y
archivar en la corte en forma escrita sus defensas 0 sus
obj eciones alas demandas en contra de su persona. Sea
avisado que si usted no se defiende, la corte tomara medidas
y puede entrar una orden contra usted sin previa aviso 0
notificacion y por cualquier queja 0 alivio que es pedido en
la peticion de demanda. Usted puede perder dinero 0 sus
propiedades 0 otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO
TIENE ABOGADO OSI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL
SERVICIO, VAYA EN PERSONA OLLAME POR TELEFONO A LA OFICINA
CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJOPARA AVERIGUAR DONDE
SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717) 249-3166
Date:
~;;I
P.C.
. Cunningham, Esquire
.D. 23144
2320 North Second Street
P. O. Box 60457
Harrisburg, PA 17106-0457
Telephone: (717) 238-6570
(Attorneys for Plaintiff)
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
ORCHARD APARTMENT
ASSOCIATES, t/d/b/a
ORCHARD APARTMENTS,
Plaintiff
NO. 01 - 1877
v.
CIVIL ACTION- LAW
DOWAYNA LUCAS,
Defendant
COMPLAINT
AND NOW comes the Plaintiff, ORCHARD APARTMENT
ASSOCIATES, t/d/b/a ORCHARD APARTMENTS, by and through its
attorneys, Cunningham & Chernicoff, P. C. and files this
Complaint in ejectment and in assumpsit and in support thereof
avers the following:
1. Plaintiff, ORCHARD APARTMENT ASSOCIATES, t/d/b/a
ORCHARD APARTMENTS, is a limited partnership which is
registered with the Pennsylvania Department of State having a
registered address of 2204 Cedar Run Drive, Camp Hill,
Cumberland County, pennsylvania.
2. The Defendant, DOWAYNA LUCAS, is an adult individual
who resides at 2206-L Cedar Run Drive Ext., Camp Hill,
Cumberland County, pennsylvania.
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3. At all times material to Plaintiff I s cause of
action, Plaintiff, ORCHARD APARTMENT ASSOCIATES, t/d/b/a
ORCHARD APARTMENTS, has been the legal owner of the tract of
land on which the building in which the Defendant resides is
sited.
4. On or about February 26, 1999, Defendant executed a
Lease Agreement by the terms of which the Defendant leased
from the Plaintiff an apartment located at 2206-L Cedar Run
Drive Ext., Camp Hill, Cumberland County, Pennsylvania for an
initial term beginning March 1, 1999 and ending March 31,
2000, after which initial term, the Lease continued on
successive terms for one (1) year each. A true and correct
copy of the Lease Agreement for 2206-L Cedar Run Drive Ext.,
Camp Hill, Cumberland County, Pennsylvania is attached hereto,
made part hereof and is marked Plaintiff's Exhibit lip-ln.
5. The Defendant agreed to abide by the terms set forth
in the Lease Agreement which specifically states in paragraphs
3 and 5 of the Lease that rent is due and owing on the first
(1st) day of each month and if rent is not paid by the fifth
(5th) day of each month, a late fee of Twenty and 00/100
Dollars ($2.00) is owed, together with One and 00/100 Dollar
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($1.00) per day for each additional day after the twentieth
(20th) day of the month the rent remains unpaid during the
month it is due.
6. Plaintiff receives rent subsidies under the
provisions of the Fair Housing Act of 1937 for qualifying
tenants, under a program commonly referred to as the Section
8 Program. The amount of rent subsidy received for each
tenant and the tenant's share of the rent is based upon the
tenant's income and household composition.
7. The Defendant failed to pay monthly rental payments
in a timely manner in the month of December, 2000.
8. The Defendant failed to pay the monthly rent for the
month of December, 2000.
COUNT I - IN EJECTMENT
9. Plaintiff incorporates paragraphs 1 through 8 of the
Complaint as if more fully set forth herein.
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10. The Plaintiff's agent, Debbie Anstine, after a
review of the Defendant's rental history, reached a decision
to terminate the Defendant's Lease Agreement and/or not renew
the Defendant's Lease Agreement for the following reasons:
(a) Defendant's failure to pay rent in a
timely manner in accordance with Paragraphs 3 and 5
of the Lease Agreement for the month of December,
2000, all which, in the opinion of the plaintiff,
represents a substantial violation of the terms of
the Lease Agreement, Rules and Regulations of the
apartment complex and HUD Regulations, specifically
paragraphs 3 and 5 of the Lease Agreement and
section 4-18 of the HUD Technical Handbook,
Transmittal 4350.3. The Defendant's actions also
represent a material non-compliance with the terms
and conditions of the Lease Agreement as defined
under HUD Regulations and Paragraph 23 of the Lease
Agreement.
(b) The Defendant's failure to pay rent for
the month of December, 2000, which in the opinion
of the plaintiff, represents a substantial
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violation of Paragraphs 3 and 5 of the Lease
Agreement, the Rules and Regulations of the
apartment complex, and HUD Regulations set forth in
Section 4-18 of the HOD Technical Handbook,
Transmittal 4350.3, all of which constitutes a
material non-compliance with the terms of the Lease
Agreement as that term is defined under Paragraph
23 of the Lease Agreement and the applicable HOD
Regulations.
11. The
Plaintiff
not
has
defaulted
in
its
responsibility to provide a habitable premises to the
Defendant and is of the opinion and therefore avers that the
premises being occupied by the Defendant are in such a state
as not to violate the applied warranty of habitability owed by
the Defendant to the Plaintiff.
12. On December 6, 2000, the Defendant was properly
served by the Plaintiff, at the Defendant's residence, with a
Proposed Notice to Quit.
The Proposed Notice to Quit was
served in accordance with HOD Rules and Regulations and the
Pennsylvania Landlord/Tenant Act. A true and correct copy of
the Proposed Notice to Quit is attached hereto, made part
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hereof and is incorporated herein by reference as Plaintiff's
Exhibit "P-2".
13. On December 18, 2000, the Defendant was properly
served by the plaintiff, at the Defendant's residence, with a
Final Notice to Quit. The Final Notice to Quit was served in
accordance with HUn Rules and Regulations and the Pennsylvania
Landlord/Tenant Act. A true and correct copy of the Final
Notice to Quit is attached hereto, made part hereof and is
incorporated herein by reference as Plaintiff's Exhibit "P-3".
14. The Defendant, although requested to do so by the
plaintiff, has refused to surrender 2206-L Cedar Run Drive
Ext., Camp Hill, Cumberland County, pennsylvania, to the
Plaintiff and has since the time that she received the
Proposed Notice to Quit and Final Notice to Quit, has
continued to remain in possession of said apartment.
WHEREFORE, Plaintiff demands entry of judgment against
the Defendant, DOWAYNA LUCAS, and in favor of the Plaintiff on
the issue of material non-compliance with the terms of the
Lease Agreement, Rules and Regulations of the apartment
complex, Pennsylvania Landlord/Tenant Act and HUD Regulations;
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and Plaintiff further demands it be granted possession of
2206-L Cedar Run Drive Ext., Camp Hill, Cumberland County,
Pennsylvania, together with costs and interest.
COUNT II - IN ASSUMPSIT
15. Plaintiff incorporates by reference Paragraphs 1
through 14 of the Complaint as if more fully set forth herein.
16. During the Defendant I s tenancy, various repairs have
been made to correct damages beyond normal wear and tear.
Damages are to be paid within thirty (30) days of invoice. To
date, the outstanding balance for invoiced repairs equals
Sixty and 00/100 Dollars ($60.00).
17. The total monetary damages sought by the Plaintiff
as against the Defendant are as follows:
Damages:
$
60.00
Rent Arrearage:
August, 1999 $
August, 1999 (late fee)
December, 2000
December, 2000 (late fee)
January, 2001
January, 2001 (late fee)
February, 2001
February, 2001 (late fee)
387.00
30.00
47.00
30.00
47.00
30.00
47.00
30.00
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March, 2001
March, 2001 (late fee)
April, 2001
April, 2001 (late fee)
278.00
30.00
278.00
30.00
TOTAL .................. $1,324.00
18. Defendant has failed to pay rent due for the months
of August, 1999, December, 2000, January, 2001, February,
2001, March, 2001 and April, 2001. The rent for the month of
August, 1999 was Three Hundred Eighty Seven and 00/100 Dollars
($387.00). The monthly rent for the months of December, 2000,
January, 2001, and February, 2001 equalled Forty Seven and
00/100 Dollars ($47.00) per month.
Due to an increase in
Defendant's income, rent for the months of March, 2001 and
April, 2001 equalled Two Hundred Seventy Eight and 00/100
Dollars ($278.00) per month.
19. The Defendant's rent is subsidized by the federal
government under a program commonly known as the Section 8
program and Defendant's rent is presently Two Hundred Seventy
Eight and 00/100 Dollars ($278.00) per month, however, if
during the pendency of this litigation Defendant receives an
increase in wages or loses her employment then, in that event,
Defendant's rent may be increased or decreased.
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WHEREFORE, Plaintiff demands entry of judgment in favor
of the Plaintiff and against the Defendant, DOWAYNA LUCAS, in
the amount of One Thousand Three Hundred Twenty Four and
00/100 Dollars ($1,324.00) and any further rent and late fees
that may be incurred and unpaid from the date of this
Complaint to conclusion of this litigation, together with
costs and interest.
Date:
(~~I
Respect~ul submitted,
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By:
unningham, Esquire
# 44
2320 orth Second Street
P. O. Box 60457
Harrisburg, PA 17106-0457
Telephone: (717) 238-6570
(Attorneys for Plaintiff)
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X, Deb AnStine, Site Managezo, OZ'chaZ'ci 1I;paZ't1llents, verify
that the statc:lIeuts lIIade in the fo:r:egoiDg C01llplaint are true
lUld ec::reet to the J)est of Illy knoWledge. 1nforDlation and
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~elief. I understand. that false statementa herein are made
8~ject to thelPenalt188 of 18 Pa. C.B.A. '4904, relatiug to
unsworn falsification to authorities.
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Orc:hud A;lut1lleZlts
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.RESIDENtiAl lEASE AGREE""ENT
1. PARTIES AND DWELliNG UNIT:
Orchard
Dowayna
Apartment
Lucas
The parties to this Agreement are
to as the landlord, and
as the Tenant. The landlord leases to the Tenant unit number
localedal Camp Hill, Pa. 17011
Orchard Apartments 2204 Cedar Run Drive, Camp Hill,
, referred
,referred 10
??Ofir. C:~if.~r 'Rlln Or;n"" ('.::Imp Hi 11
in the project known as
Pa. 17011
2. LENGTH OF TIME (TERM):
The iniliallerm 01 this Agreement shall begin on
Mi'lrchl1. 2000
of one year
March 1,
1999
and end on
. After the initial term ends, the Agreement will continue for successive terms
each unless automatically terminated as permilled by paragraph 23 of this Agreement
3. RENT:
The Tenant agrees to pay $ for the partial month ending on
$ _ 2.61 . 00 . per month. This amount is due on the 1 s t
Run-DRlve, Camp Hill, Fa. 17011
The Tenant understands that this monthly rent is less than the market (unsubSidized) rent due on this unit. This lower rent is available either because
the mortgage on this project is subsidized by the Department of Housing and Urban Development (HUD) and/or because HUD makes monthly pay-
ments 10 the Landlord on behalf 01 the Tenant. The amount. If any, that HUD makes available monthly on behalf of the Tenant is called the tenant
assistance payment and is shown on the "Assistance Payment" line of the CArtifir.;:!tinn and RAr:F!rlilicalion of TAnS"I Flinihflitv Form which is
Atlachment No, 1 10 this Agreement.
. Afler that. Tenant agrees to pay a rent of
.__ day of the month at 2 2 O_~_ Ceda~_____....~
4. CHANGES IN THE TENANT'S SHA.RE OF THE RENT:
The Tenant agrees that the amount of rent the Tenant pays and/or the amount of assistance that HUD pays on behalf of the Tenant may be changed
during the term of this Agreement if:
a. HUD or the Contract Administrator (such as a Public Housing Agency) determines, in accordance with HUD procedures, that an increase in
rents is needed;
b. HUD or the Contract Administrator changes any allowance for utilities or services considered in computing the Tenant's share of the rent;
c. The income, the number of persons in the Tenant's household or other factors considered in calculating the Tenant's rent change and HUD
procedures provide that the Tenant's rent or assistance payment be adjusted to reflect the change;
d. Changes in the Tenant's rent or assistance paym'ent are required by HUD's recertification or subsidy termination procedures;
e. HUD's procedures for computing the Tenant's assistance payment or rent change; or
I. The Tenant lails to provide information on his/her income, family composition or other factors as required by the Landlord.
The landlord agrees to Implement changes in the Tenant's rent or tenant assistance payment only in accordance with the time frames and admin-
istrative procedures set forth in HUD's handbooks, instructions and regulations related to administration of multi-family subsidy programs. The
Landlord agrees to give the Tenant at least 30 days advance written notice of any increase in the Tenant's rent except as noted in paragraphs 11,
15 or 17. The Notice will state the new amount the Tenant is required to pay, the date the new amount Is effective, and the reasons for the change
in rent. The Notice will also advise the Tenant that he/she may meet with the Landlord to discuss the rent change.
5, CHARGES FOR LATE PAYMENTS AND RETURNED CHECKS:
If the Tenant does not pay the full amount on the rent shown in paragraph 3 by the end of the 5th day 01 the month, the landlord may collect a fee of
$20.00 on the 6lh day of Ihe month. Thereafter, the landlord may collect $1 a day after the 20th day of the month for each additional day the rent
remains unpaid during the month. The Landlord may not terminate this Agreement lor the failure toj)~y lcUe charges, but may terminate this Agreement
for non-payment of renl. as explained In paragraph 23. The Landlord may collect a lee of $ :l:> . U 0 on the first or any additional time
a check is not honored for payment (bounces). The charges discussed in this paragraph are in addition to the regular monthly rent payable by the
Tenant. '
6, CONDITION OF DWelLING UNIT:
By Signing this Agreement, the Tenant acknowledges that the unit Is safe, clean and in good condition. The Tenant agrees that all appliances and
equipment in the unit are in good working order, except as described on the Unil tmmAclinn RA-nnrt which is Allachment No.2 to this Agreement.
The Tenant also agrees that the Landlord has made no promises to decorate, alter, repair or improve the unit, except as listed on the UnillmmAcllon
Boll<>tl.
7. CHARGES FOR UTILITIES AND SERVICES:
The following charts describe how the cost 01 utilities and services related to occupancy of the unit will be paid. The Tenant agrees that these charts
accuralely describe the utilities and services paid by the landlord and those paid by Ihe Tenant.
a. The Tenant must pay for the utilities in column (1). Payments should be made directly to the appropriate utility company. The items in column
(2) are included in the Tenant's rent:
(1)
Put "X" by any Utility
Tenant Pays Directly
X
X
X
(2)
Put "X" by any Utility
Included In Tenant Rent
Type of Utility
Heat.....................
lights, Electric..
Cooking..
Water
Other (Specify) Trash, Sewage..
Phone. ... ....................
Cable
All Utility Hook-ups.
X
X
X
X
X
X
8. SECURITY DEPOSITS:
The Tenant has deposited $ 1:?1 no with the landlord. The Landlord will hold this security deposit for the periOd the Tenant
occupies the unit. After the Tena\\t has moved from the \1\\1\, Ihe lar\dIOld will determine whether the lenan\ is e"g\h\a lor a ralum:! 01 any or all 01
the security deposit. The amount 01 the refund will be determined in accordance with the following conditions and procedures:
a. The Tenant will be eligible for a refund of the security deposit only If the Tenant provided the landlord with the 30-day wrillen notice of intent to
move required by paragraph 23, unless the Tenant was unable to give the notice for reasons beyond hisfher control.
b, Aller the Tenant has moved from the unit, the landlord will inspecl the unit and complete another tlnit InsaBcllon Reoorl. The Landlord will
permillhe Tenant to participate in the inspection, if the Tenant so requests.
c. The landlord wilt refund to the Tenant the amount of the security deposit (plus interest computed at %,
beginning ), less any amount needed to pay the cost of:
(I) unpaid rent;
(2) damages that are not due 10 normal wear and tear and are not listed on the Uni1JnsDection Renort;
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(3) charges for lale payment of rent aDd returned ~hecks, as d'ilscribed in pi:lIagraph 5; and
'(4) charges lor unreturned keys, as described in paragraph 9.
d. The landlord agrees 10 refund the amount computed in par<!graph Be Wil,hin' ----3-~. days after the Tenant has permanently moved
out 01 the Unit, returned possession of the unllto the Landlord, and give his/her new address to the landlord. The Landlord will also give Ihe
Tenant a writ1en list of charges thai were subtracted from the deposit. If the Tenant disagrees with the Landlord concerning the amounts
deducted and asks to meet with the landlord, the Landlord agrees to nieet with the Tenant and informally discuss the disputed charges.
8. If the unJI is rer11ed by more than one person, the Tenants agree that they will work out the details of dividing any relund among themselves.
The Landlord may pay the refund to any Tenant identified in paragraph 1 of this Agreement.
The Tenant understands that the Landlord will not count the Security Deposit towards the last month's rent or toward repair charges owed by
the Tenant in accordance wIth paragraph 11.
9. KEYS AND LOCKS:
The Tenant agrees not to install additional or different locks or gates on any doors or windows of the unit without the written permission of the
Landlord. If the Landlord approves the Tenant's request to install such locks, the Tenant agrees to provide the Landlord with a key for each lock.
Whe~thit ~greem~nt ends, the Tenant agrees to return all keys to the dwelling unit to the Landlord. The LandlOfd may charge Ihe Tenant
$ . tor each key not returned. (Naito exceed what locksmith charges for each key not returned.)
10. MAINTENANCE:
a. The landlord agrees to:
(1) regularly clean all common areas of the project;
(2) maintain tl1e common areas and facilities in a safe condition:
(3) arrange tor" collection and removal of trash and garbage;
(4) maintain all equipment and appliances in sale and working order;
(5) make necessary repairs with reasonable promptness;
(6) mainlain e:<terior lighting in good working order;
(7) provide exlermination services, if necessary; and
(8) maintain grounds and shrubs.
b. The Tenant agrees to:
(1) keep the unitctean;
(2) use all appliances, fixtures and equipment in a safe manner and only lor the purposes for which they are intended;
(3) notliller lhe grounds or common areas of the project:
(4) not destroy, deface, damage or remove any part of the unit, common areas, or project grounds;
(5) give the landlord prompt notice of any defects in the plumbing, fixtures, appliances, heating and cooling equipmenl or any other part of
the unit or related facilities; and
(6) remove garbage and other waste from the unit in a clean and safe manner.
11. DAMAGES:
Whenever damage is caused by carelessness, misuse, or neglect on the part of the Tenant. his/her family or visitors, the Tenant agrees to pay:
a. Reasonable charges for all damages to the premises (including equipment and/or appliances supplied to the premises) and reasonable charges
for damage to the project buildings, facilities, or common areas negligently or intentionally caused by Tenant or Tenant's household or guests.
Said charges arEl to be made according to the curren! Schedule of M;linlFmllnce Chams,!; posted in the Management Office, and Tenant agrees
that payment of ,all such charges shall be made within thirty (30) days of the date charges are billed.
b. Rent for the period the unit is managed whether or not the unit is habitable. The Tenant understands that HUD will not make assistance pay"
ments for any period in which the unit is not habitable. For any such period, the Tenant agrees to pay the HUD.approved market rent rather than
the Tenant rent shown in paragraph 3 of this Agreement.
12. RESTRICTIONS ON ALTERATIONS:
The Tenant agrees not to do any of the following without first obtaining the landlord's written permission:
a. change or remove any pari 01 the appliances, fixtures or equipment in the unit;
b. paint or install wallpaper or contact paper in the unit;
c. attach awnings or window guards in the unit;
d. allach or place a(ly fixtures, signs, or fences on the buildlng(s), the common areas, or the project grounds;
e. attach any shelveS. screen doors, or other permanent improvements in the unit;
I. install washing machines, dryers, fans heaters or air conditioners in the unit; or
g. place any aerials, antennas or other electrical connections on the unit;
h. no water beds.
13. GENERAL RESTRICTIONS:
The Tenant must live in the unit and the unit must be the Tenant's only place of residence. The Tenant shall use the premises only as a private
dwelling for himselflherself and the individuals listed on the Certific;:Ition ;:Inri Rer:F!rtificalion of Tenllnl Flioibilitv. The Tenant agrees to permit other
individuals 10 reside in the unit only after obtaining the prior wrlllen approval of the Landlord. The Tenant agrees not to:
a. sublet or assign the unit, or any part of the unit;
b. use the unit for unlawful purposes;
c. engage in or permit unlawful activities in the unit, in the common areas or on the project grounds;
d. have pets or animals of any kind in the unit without the prior written permission 01 the landlord; or
e In the even! that during the term of the lease the Tenant should require the assistance of a Live-in-Aide, in accordance with the HUD
Regulations, the aide shalt not be allowed to remain in occupancy should the Tenant terminate this Lease Agreement nor shall the Live-in-Aide
have rights to survivorship of the unit.
Notwithstanding ,any other provision of this lease, the Tenant, members of the Tenant's household, guesls of Tenant and other persons under
Tenant's control shall not engage in unlawlul activity, including drug-related criminal activity, in the Tenant's unit or on the project premises, and
such unlawful activity shall be cause for termination of tenancy. "Drug-related criminal activity" means the Illegal manufacture, sale, distribution,
use or possession of a controlled substance as defined in Section 102 of the United Slates Controlled Substances Act. 21 U.S. Code Section
802. Criminat conviction under Federal, state or local law shall not be a precondition for termination of tenancy.
g Tenant shall not pursue or conduct any business on the premises, nor shall Tenant display any signs of any type of description.
h. Tenant shall refrain from and cause Tenant's household and guests to refrain from destroying, defacing, damaging, or removing any part of the
premises 01 project
Tenant shall not oreate or permit any disturbing noises in or about Tenant's dwelling unit by himself, his family, or guests; nor shall he, his family,
or guests inlerel@re with or materially diminish the rights, comforts, or convenience of other Tenant's or surrounding neighbors. Neither Ihe
Tenant, his family, nor his guests shall engage in any activity that would constitute an offense against persons, properly, pubiic order, or public
health or decency, or that involves fraud, deception, firearms, or other weapons.
j. Tenant shall not refuse the extermination services for rodent or insect infestation.
k. II heat is 10 be supplied by the Tenan!, Tenant agrees to execute a third parly notification with Landlord, whereby the landlord will be formally
notified prior to me discontinuance of utility service by the utility supplier. Tenant agrees to furnish sufficient heat to the premises \0 prevent
damage to the premises. If, lor any reason, Tenant is unable to maintain sufficient heat, Tenant shall immediately notify landlord. Tenant shall
pay for any damages to the unit resulting from Tenant's negligent or intentional failure to maintain sulficient heat or to notity landlord of Ihe lack
of sulficient heat due to any cause beyond Tenant's control.
Tenant agrees to comply with Landlord policies and directives, as well as the regulations and laws of all Federal, state, municipal and local
governments regcarding Ihe collection, sorting, separation and recycling of waste products, garbage, refuse and trash.
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14. RULES:
The Tenant agrees to obey the House Rules which are Attachment No.3 to this Agreement The Tenant agrees to obey additional rules established,
after the effective date of this Agreement if: '.
a. the rules are reasonably related to the salety, care and cleanliness of the building and the safety, comforf and convenience of the Tenanls; and
b the Tenant receives written notice. of the proposed rule at least fhirty (30) days before the rule is enforced.
15, REGULARLY SCHEDULED RECERTIFICATIONS:
Every year around the t ~ day of \:)e:,f'E, lY t~ the Landlord will request Ihe Tenant to repor! the income
and composition of the Tenant's household and to supply any other information required by HUD for the purposes of determining the Tenant's rent
and assistance payment, il any. The Tenant agrees to provide accurate statements of this information and fo do so by the date specified in the
LandlOfd's request. The landlord wlU. verify the information supplied by the Tenant and use the '1erilied infnrmat\on to recompute the amount 01 the
Tenant's rent and assistance payment, if any.
a. If the Tenant does not submit the required certification information by the date specified in the Landlord's request, the Landlord may impose the
following penalties. The Landlord may implement these penalties only in accordance with the administrative procedures and time frames
specUied in HUD:s regulations, handbooks and instructions related to the administration oj mult\-lamily subsidy programs.
(1) Require the Tenant to pay the higher, HUD-approved market rent for the unit.
(2) Implement any increase in rent resulting from the recertification processing without providing the 3D-day notice otherwise required by
paragraph 4 of this Agreement.
b. The Tenant may request to meet with the Landlord to discuss any change in rent or assislance payment resulting !10m the fet.efl\licat\on
processing. II the Tenant requests such a meeting, the landlord agrees to meet with the Tenant and discuss how the Tenant's rent and assis-
tance payment, il any, were computed.
16. REPORTING CHANGES BETWEEN REGULARLY SCHEDULED RECERTIFICATIONS:
a. If any of the following changes occur, the Tenant agrees to advise the Landlord immediately:
(1) Any household member moves out of the unit.
(2) Any adult member of the household who was reported as unemployed on the most recent cerli/ication or recerlification obtains employ-
ment
(3) The household's income cumulatively increases by $40 or more a month.
b. The Tenant may report any decrease in income or any change in other lactors considered in calculating the Tenanrs rent. Unless the Landlord
has confirmation that the decrease in income or change in other factors will last less than one month, the Landlord will verify the information
and make the appropriate rent reductiof\. However, il too Tenant's !rIt:ome will be partially or tully resl{)red within two mOl"'lths, lhe LamllOJo may
delay the certification process untillhe new income is knOWn, but the renl reduction will be retroactive and the landlord may nol evict the lenant
for nonpayment of renl due during the period of the reported decrease and the completion of the cerlification process_ The Tenant has thirty
(30) days after receiVing written notice of any rent due for the above described time period to payor the Landlord can evict lor nonpayment of
rent (Revised 3/22fB9.j
c. If the Tenant does not advise the Landlord of these interim changes, the Landlord may increase the Tenant's rent to the HUD-approved market
rent. The Landlord may do so only in accordance with the lime frames and administrative procedures set lorth in HUD's regulations, handbooks
and instructions on the administration of multi-family subsidy programs.
d. The Tenant may request to meet with the l.andlord to discuss how any change in income or other lactors affected his/her rent or assistance
payment, if any, If the Tenant requests such a meeting, the landlord agrees 10 meet with the Tenant and explain how the Tenant's rent or assis-
lance payment, it any, was computed.
17. REMOVAL OF SUBSIDY:
a The Tenant understands that assistance made available on his/her behalf may be terminated if events in either Hems (1) or (2) below occur.
Termination of assistance means thatlhe landlord may make the assistance available to another Tenant and the Tenant's rent will be recom-
puted.ln addition, if the Tenant's assistance is terminated because of criterion (1) below, the Tenant will be required to pay the HUD-approved
market rent for the unit.
(1) The Tenant does not provide the landlord with the information or reports required by paragraph 15 or 16 within ten (10) calendar days
after receipl of the Landlord's notice or intent to terminate the Tenant's assistance payment.
(2) The amount the Tenant would be required to pay towards rent and utilities under HUD rules and regUlations eQuais the Family Gross Rent
shown on Attachment 1.
b. The Landlord agrees to give the Tenant written notice of the proposed termincltion. The notice wilt advise the Tenant that, during the ten (10)
calendar days following the dale of the notice, he/she may requeslto meet with the landlord to discuss the proposed termination of assistance.
If the Tenant requests a discussion of the proposed lermjnation, the Landlord agrees to meet with the Tenant.
c. Termil\alion of assistance sha.1t not aHeet the Tenant's other rights under tl1is Agreement, including tile right to occupy the unit. Assislance may
SUbsequently be reinstated il the Tenant submits the income or other data required by HUD procedures, the Landlord determines the Tenant is
eligible for assistance, and assistance is available.
18. tENANT OBUGAT10NTO REPAY:
If the Tenant submits false information on any application, certification or request for interim adjustment or does not report interim changes in lamily
income or other factors as required by paragraph 16 ollhis Agreemenl, and as a result, is charged a renttess than the amount required by HUD's
rent formulas, the Tenant agrees to reimburse the Landlord for the difference between Ihe rent he/she shOUld have paid and the rent he/she was
charged. The Tenant is not required 10 reimburse the landlord for undercharges caused solely by the Landlord's lailure to follow HUD's procedures
for computing renl or assistance payments,
19. SIZE OF DWELLING:
The Tenant understands that HUD requires the Landlord to assign units according to the size of the household and the age and sex of the house-
hold members. If the Tenant is or becomes eligible for a diflerent size unit, and the required size unit becomes available, the Tenant agrees to:
a. move witl1in thirty (30) days after the landlord notifies him/her that a unit 01 the required size is available within Ihe project; or
b. remain in the same unit and pay the HUO-approved market rent.
20. ACCESS BY LANDLORD:
The Landlord agrees 10 enter the unit only during reasonable hours, to provide reasonable advance notice of his/her Intent to enter the unit, and to
enter the unil only aller receiving the Tenant's consent to do so, except when emergency situations make such notices impossible or except under
paragraph (c) below. .
a. The Tenanl agrees to permit the Landlord, his/her agents or other persons. when authorizeO by the Landlord, to enter the unil for the purpose
of making reasonable repairs and periodic inspections.
b. After the Tenant has given a notice 01 lnlentto move, the Tenant agrees to permit the landlord to show the unit to prospective tenants dur"lng
reasonable hours.
c. If the Tenant moves before this Agreement ends, Ihe landlord may enter the unit to decorate, remodel, alter or otherwise prepare the unit lor
re-occupancy.
21. DISCRIMINATION PROHIBITED:
The Landlord agrees not to discriminate based upon race, color, religion, creed, nalional origin, sex, age, handicap, membership in a class, such
as unmarried mothers or recipients of publiC assistance, or because there are children in the family.
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22. (fHANGE IN.RENTAL"AGRl:EMENT:
The landlord may, with the prior approval of HUD, change th~ terms and conditions of this Agreement. Any changes will become effective only at
the end of the initial term or a successive term. The Landlord must notify nie Tenant 01 any change and must offer the Tenant a new Agreement or
an arnendmenllo the existing Agreement. The Tenant must receive the notice at least sixty {GO) days belore the proposed effective date of the
chang,e. The Tenant may accepllhe changed terms and condilions by signing the new Agreement or the amendment to the existing Agreement and
returning it to the Landlord. The Tenant may reject the changed terms and conditions by giving the Landlord written notice lhal he/she intends to
terminate the tenancy. The Tenant must give such nolice at least thirty (30) days before the proposed change wil! go into effecl. lithe Tenant does
not accept the amended Agreement, the landlord may require the Tenant to move from the project, as provided in paragraph 23.
23. TERMINATION OF lENANCY:
a To terminate this Agreement, the Tenant must give the landlord thirty (3D) days written nolice before moving from the unit. If the Tenanf does
not give the full 3D-day nolice, fhe Tenant shall be liable for rent up the end of the thirty (30) days for which notice was required or to the date
the unil is re-rented, whichever date comes first
b. Any termination of this Agreement by the landlord must be carried out in accordance with HUD regulations, state and loca/law, and the terms
of this Agreement. The landlord may terminate this Agreement only for:
the Tenanl"s material noncompliance with the terms of this Agreement;
the Tenant's material failure to carry out obligations under any State landlord and Tenant Act; or
criminal activity that threatens the health, safety, or right to peaceful enjoyment of the premises by other tenants or any drug-related crimi-
nal activity on or near such premises, engaged in by a tenant, any member of the Tenant's household, or any guest or other person under
the Tenant's control; or
other good cause, which includes, but is nollimiled to, the Tenanl"s retusalto accept the landlord's proposed change to this Agreement.
Terminations lor "other good cause" may only be effective as ot the end of any initial or successive term.
the term material noncompliance with the lease includes: (1) one or more substantial violations of lhe lease: (2) repeated minor violations
of the lease that (a) disrupt the livability 01 the project, (b) adversely alleclthe heallh or salety 01 any person or the right of any lenant to
the quiet enjoyment of the leased premises and related project tadlWes, (c) interefere with the management of the project, or (d) have an
adverse financial ellecl on the proiect {3\ failure of the Tenant to timely supply aU required information on the income and composit\on, or
eligibility factors, of the tenant household (including, but not limited to, failure to meet the disclosure and verilication requirements for Social
Security Numbers, or failure to sign and submit consent forms tor the obtaining 01 wage and claim information from State Wage Information
Collection Agencies), or to knowingly provide incomplete or inaccurate intormation; and (4) non-payment of rent or any other financiai oblig-
ation due under the lease beyond any grace period permitted under state law. The payment of rent o( any other financial obligation due
under the lease after the due date but within the grace period permitted under stale law constitutes a minor violation.
c. It Ihe Landlord proposed to terminate this Agreement, the landlord agrees to give the Tenant wrillen nolice of the proposed termination. If the
landlord is terminating Ihis Agreement for "other good cause:' the termination notice must be mailed to the Tenant and hand-delivered to the
dwelling unit in the manner required by HUD at least thirty (30) days before the date the Tenant will be required to move Irom the unit. Notices
of proposed termination for other reasons must be given in accordance with any time frames set forth in state and local law. Any HUD-required
notice period may run concurrently with any notice period required by state or local law. Allterminalion notices must:
specity the dale Ihis Agreement will be lerminaled;
state the grounds lor termination with enough detail for the Tenant to prepare a defense;
advise Ihe Tenant that he/she has ten (10) days within which to discuss the proposed termination of tenancy with the landlord. The to-day
period will begin on the earlier of the date the notice was hand-delivered to the unit or the day after the date the notice is mailed. If the
Tenant requests the meeting, the Landlord agrees to discuss the proposed termination with the Tenant: and
advise Ihe Tenant tlf his!l1er righl ttl defend lhe action m court
d. If an eviction is initiated, the landlord agrees to rely only upon those grounds cited in the termination notice required by paragraph (c).
24. HAZARDS:
The Tenant shall not undertake, or permit his/her family or guests to undertake, any hazardous acls or do anything that will increase the project's
insurance premiums. Such action constitutes a material non-compliance. lIlhe unit is damaged by fire, wind Of rain to the extent that the unit can.
not be lived in and the damage is not caused or made worse by the Tenant, the Tenant will be responsible for rent only up to the date of the destruc-
tion. Additional rent will not accrue until the unit has been repaired to a livable condition.
25. PENAl-TIES FOR SUBMITIING FALSE INFORMATION:
Knowingly giving the Landlord false information regarding income or other factors considered in determining Tenant's eligibility find rent is a male"
rial noncompliance wilh the lease subject to termination of tenancy. In addition, the Tenant could become subject to penalties available under
Federal law. Those penalties include fines up to $10,000 and imprisonment fo( up to five (5) years.
26. CONTENTS OF THIS AGREEMENT:
This Agreement and its Attachments make up the entire agreement between the Landlord and the Tenant regarding the unit. If any court declares
a particular provision 01 this Agreement to be invalid Of illegal, all other terms of this Agreement will remain in ellect and both Ihe Landlord and the
Tenant will continue to be bound by them.
27, ATTACHMENTS TO THE AGREEMENT:
The Tenant certifies that he/she has received a copy of this Agreement and the following Allachments to this Agreement and understands that these
AUachments are part of this Agreement:
a. Allar:hment Nn 1-Form HUD-SOOS9, Certification and Recertification of Tenant Eligibility
b. AlIachment No. 2-Unitlnspeclion Report
c. Allar:hmp.nt Nn 3-House Rules (if any)
28. SIGNATURES:
TENAJ
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LANDlORD~ORCHARD APARTM
By:
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PROPOSED NOTICE TO OUlT
TO: Dowayna Lucas
2206 L Cedar Run Drive Extn.
Camp Hill, Pennsylvania 170 II
DATE: December 6,2000
YOU ARE HEREBY NOTIFIED that as of this date, your lease agreement is being considered
for termination because you have committed various substantial and minor violations of the lease
agreement, applicable Housing and Urban Development (HUD) regulations, provisions of the
Pennsylvania Landlord and Tenant Act, and of the rules and regulations of Orchard Apartments, all of
which constitutes "material non-compliance" which term, as outlined in Paragraph 23 of the lease
agreement, is defined in part as: "material non-compliance" includes, but it not limited to, non-payment of
rent beyond the grace period available under state law; failure to reimburse the landlord within thirty (30)
days for repairs made under Paragraph II of this agreement; repeated late payment of rent; permitting
unauthorized persons to live in the unit; serious or repeated damages to the unit or common areas; creation
of physical hazards; serious or repeated interference with the rights and quiet enjoyment of other tenants;
failure to repay unauthorized assistance payments; and giving the landlord false information regarding
income or other factors considering in determining the tenant's rent". .
The substantial and repeated minor violations of your lease are as follows:
(I) Failure to pay rent for the month(s) of: December, 2000 in the amount of Forty-Seven and
00/100 Dollars ($47.00) plus late fees, in violation Paragraphs 3, 5 and 23 of the lease
agreement and Paragraph 4-18 ofHUD Transmittal 4350.3.
(2) Failure to pay rent in a timely manner by the first day of the month and no later than the fifth
day of the month as required by Paragraphs 3, 5 and 23 of the lease agreement and Paragraph
4-18 ofHUD Transmittal 4350.3.
As a result of the above acts and actions, the landlord is of the opinion that you have breached the terms of
the lease agreement, rules and regulations of Orchard Apartments, and applicable HUD regulations, and
have forfeited your right to continue possession of your apartment unit.
Page One oiiThree
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THEREFORE, YOU ARE HEREBY NOTIFIED to remove from and deliver possession of the
leased unit you now occupy at the above address, within the complex know as Orchard Apartments within
thirty (30) days from the date of service ofthis Notice, but in no event later than January 31, 2001. In the
event you remain in possession of the leased unit beyond January 31, 2001, the date specified for
termination herein, and fail to deliver the possession of the leased unit to the landlord, the landlord can
seek to enforce the termination of the lease agreement and secure your removal from the leased unit only
by initiation a judicial action as required by HUD Transmittal 4350.3, Paragraph 4-21. If a judicial
proceeding for and eviction is instituted, you may, at that time present a defense.
Department of Housing and Urban Development (HUD) Regulations provide that you ten (10)
days within which to discuss the Proposed Notice with the landlord. You may discuss this Proposed
Notice by telephoning the office, visiting the office, or by writing a letter.
Served this 6th day of December, 2000.
Assistant Manager
A TTENCION: Si vd no entiende esta noticia por favor venga ha mi offencina y se 10 explicare.
Page Two of Three
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AFFIDAVIT OF SERVICE
The undersigned does hereby verify that he/she served the Proposed Notice to Quit by placing the
Proposed Notice in the United States mail, postage prepaid, first-class, endorsed with a proper return
address, on the 6th day of December, 2000. I understand that false statements herein are made subject to
the penalties of 18 Pa. C.S.A. ~4904, relating to unsworn fi sification to Or! ies.
(
The undersigned does hereby verify that he/she serve e Proposed Notice to Quit by one of the
two methods set forth below:
Personally handing the Proposed Notice to Quit to the tenant or an adult person
answering the door at the tenant's apartment on the 6th day of December 2000.
1t
By placing Proposed Notice to Quit under or through the tenant's door on the 6th
day of December 2000, and/or Posting the Proposed Notice to Quit on the tenant's
door.
(Method of service employed evidenced by checked box.)
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A.
94904, relating to unsworn falsification to authorities.
, Assistant Manager
Page Three of Three
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FINAL NOTICE TO QUIT
TO: Dowayna Lucas
2206 L Cedar Run Drive Extended
Camp Hill, Pennsylvania 17011
DATE: December 18,2000
YOU ARE HEREBY NOTIFIED that as of this date, your lease agreement is terminated because
you have committed various substantial and minor violations of the lease agreement, applicable Housing
and Urban Development (HUD) regulations, provisions of the Pennsylvania Landlord and Tenant Act, and
of the rules and regulations of Orchard Apartments, all of which constitutes "material non-compliance"
which term, as outlined in Paragraph 23 of the lease agreement, is defined in part as: "material non-
compliance" includes, but it not limited to, non-payment of rent beyond the grace period available under
state law; failure to reimburse the landlord within thirty (30) days for repairs made under Paragraph II of
this agreement; repeated late payment of rent; permitting unauthorized persons to live in the unit; serious
or repeated damages to the unit or common areas; creation of physical hazards; serious or repeated
interference with the rights and quiet enjoyment of other tenants; failure to repay unauthorized assistance
payments; and giving the landlord false information regarding income or other factors consid~ring in
determining the tenant's rent".
The substantial and repeated minor violations of your lease are as follows:
(1) Failure to pay rent for'the month(s) of; December 2000 in the amount of Forty-Seven and
00/100 Dollars ($47.00) per month plus late fees, in violation Paragraphs 3, 5, and 23 of the
lease agreement and Paragraph 4-18 ofHUD Transmittal 4350.3.
(2) Failure to pay rent in a timely manner by the first day of the month and no later than the fifth
day of the month as required by Paragraphs 3, 5 and 23 of the lease agreement and Paragraph
4-18 ofHUD Transmittal 4350.3.
As a result of the above acts and actions, the landlord is ofthe opinion that you have breached the terms of
the lease agreement, rules and regulations of Orchard Apartments, and applicable HUD regulations, and
have forfeited your right to continue possession of your apartment unit.
.
Page One of Three
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THEREFORE, YOU ARE HEREBY NOTIFIED to remove from and deliver possession of the
leased unit you now occupy at the above address, within the complex know as Orchard Apartments within
thirty (30) days from the date of service of this Notice, but in no event later than January 31, 2001. In the
event you remain in possession of the leased unit beyond January 31, 2001, the date specified for
termination herein, and fail to deliver the possession of the leased unit to the landlord, the landlord can
seek to enforce the termination of the lease agreement and secure your removal from the leased unit only
by initiation a judicial action as required by HUD Transmittal 4350.3, Paragraph 4-2 I.
If you fail to heed this Notice, and remain in the leased unit beyond the date specified for
termination herein, I shall be compelled to proceed against you as the law directs, To enforce termination
of this lease agreement, and secure your removal from the leased unit, I shall be required to initiate a
judicial action as required by by HUD Transmittal 4350.3, Paragraph 4-21. If a judicial proceeding for
eviction is instituted, you may at that time present a defense.
Served this 18th day of December, 2000.
.-,,/
y on! Assistant Manager
ATTENCION: Si vd no entiende esta noticia por favor venga ha mi offencina y se 10 explicare.
Page Two of.Three
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AFFIDAVIT OF SERVICE
The undersigned does hereby verify that he/she served the Final Notice to Quit by placing the Final
Notice in the United States mail, postage prepaid, first-class, endorsed with a proper return address, on the
18th day of December, 2000. I understand that false statements herein are ade subject to the penalties of
18 Pa. C.S.A. ~4904, relating to unsworn falsification to authorities. '
The undersigned does hereby verify that he/she served the Final Notice to Quit by one of the two
methods set forth below:
son, Assistant Manager
-
Personally handing the Final Notice to Quit to the tenant or an adult person
answering the door at the tenant's apartment on the 18th day of December, 2000.
xx By placing Final Notice to Quit under or through the tenant's door and/or posting the
the Final Notice on the 18th day of December, 2000.
(Method of service employed evidenced by checked box.)
I understand that false statements herein are made subject
~4904, relating to unsworn falsification to autho 'ties.
e penalties of 18 Pa. C.S.A.
. Tyson, Assistant Manager
.
Page Three of Three
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ORCHARD APARTMENT
ASSOCIATES, t/d/b/a
ORCHARD APARTMENTS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2001 - 1877 CIVIL
DOWAYNA LUCAS,
Defendant
CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I do hereby state that I served a true and correct copy
of the COMPLAINT in the above captioned matter by placing the
same in the United States mail, first-class, postage prepaid,
in Harrisburg, Pennsylvania on April 20, 2001 addressed to:
Philip C. Briganti, Esquire
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(Attorneys for Defendant)
Respectfully submitted,
CUNNINGHAM & CHERNICOFF, P.C.
Date: APril 20. 2001
MAl
e A. Morr1son, Secretary
o Jordan D. Cunningham, Esquire
.D. #23144
2320 North Second Street
P. O. Box 60457
Harrisburg, PA 17106-0457
Telephone: (717) 238-6570
(Attorneys for plaintiff)
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ORCHARD APARTMENTS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
NO. 2001- 1877 CIVIL TERM
DOW A YNA LUCAS,
Defendant
CIVIL ACTION - LAW
NOTICE TO PLEAD
TO: Orchard Apartments
You are hereby notified to file a written response to the attached Preliminary Objections
to Plaintiff's Complaint within twenty (20) days from service hereof or a judgment may be
entered against you.
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Date
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Counsel for Defendant
MIDPENN LEGAL SERVICES
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
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ORCHARD APARTMENTS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2001- 1877 CIVIL TERM
DOW A YNA LUCAS,
Defendant
CIVIL ACTION - LAW
PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT
COMES NOW the defendant, Dowayna Lucas, by counsel, Philip C. Briganti, Esquire,
MidPenn Legal Services, and files the following Preliminary Objections to Plaintiffs Complaint:
Motion to Strike Off Comolaint for Failure to Conform to Rule of Court.
1. Count I of Plaintiffs Complaint seeks the ejectment of Defendant.
2. Pa. R.C.P. No.1 054, governing actions in ejectment, provides as follows:
(a) The plaintiff shall describe the land in the complaint.
(b) A party shall set forth in the complaint or answer an abstract of the title upon
which the party relies at least from the common source of the adverse titles of the
parties.
3. Plaintiffs Complaint does not properly describe the land.
4. Plaintiffs Complaint fails to set forth an abstract ofthe title upon which the plaintiff
relies at least from the common source of the adverse title of the parties.
WHEREFORE, Defendant requests that Plaintiffs complaint be stricken for failure to
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conform to the Pennsylvania Rules of Civil Procedure.
Respectfully submitted,
Philip C. riganti
Counsel for Defendant
MIDPENN LEGAL SERVICES
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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ORCHARD APARTMENTS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
NO. 2001- 1877 CIVIL TERM
DOW A YNA LUCAS,
Defendant
CIVIL ACTION - LAW
VERIFICATION
The above-named defendant, Dowayna Lucas, verifies that the statements set forth in the
foregoing pleading are true and correct. Defendant understands that false statements herein are
made subject to the penalties of 18 P.S. 94904, relating to unsworn falsification to authorities.
Date: 5 -~-ol
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CERTIFICATE OF SERVICE
I, Philip C. Briganti, hereby certify that I am this /tJ ~ay of May, 2001, serving a
copy of the foregoing Notice to Plead and Preliminary Objections to Plaintiffs Complaint upon
Plaintiff, by mailing a true copy of the same to Plaintiffs counsel at the following address by
first-class U.S. mail, postage prepaid:
Jordan D. Cunningham, Esquire
CUNNINGHAM & CHERNICOFF, P.C.
2320 North Second Street
P.O. Box 60457
Harrisburg, PA 17106-0457
Philip C. riganti
Counsel for Defendant
MIDPENN LEGAL SERVICES.
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
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ORCHARD APARTMENT,
ASSOCIATES, t/d/b/a
ORCHARD APARTMENTS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001 - 1877 CIVIL
v.
CIVIL ACTION - LAW
DOWAYNA LUCAS,
Defendant
PETITION TO RETURN RENT ESCROW
1. The Plaintiff, Orchard Apartment Associates,
t/d/b/a Orchard Apartments is a limited partnership which
is registered with the Pennsylvania Department of State
having a registered address of 2204 Cedar Run Drive, Camp
Hill, Cumberland County, Pennsylvania.
2. The Defendant, Dowayna Lucas, is an adult
individual who previously resided at 2206-L Cedar Run Drive
Ext., Camp Hill, Cumberland County, Pennsylvania.
3. On March 30, 2001, an appeal was filed by the
Defendant, to which a Complaint was filed by Orchard
Apartments seeking the eviction of the Defendant.
4. There remains a balance of escrowed rents
deposited with the Prothonotary in the amount of $1,491.00,
representing rent deposited by the Defendant on behalf of
the Plaintiff.
1
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5. The issues raised in the Complaint relating to
ej ectment are moot as the Defendant had abandoned the
apartment unit and the Defendant's whereabouts are unknown
to the Plaintiff.
6. Plaintiff, in light of the fact of Defendant's
abandonment from the premises, is due and owed the monies
being held in escrow by the Prothonotary of Cumberland
County pursuant to the Local Rules of Court and the Rules
of civil Procedure for District Justices.
WHEREFORE, plaintiff respectfully prays that this
Honorable Court direct the prothonotary to distribute to
the Plaintiff all monies being held in its rent escrow
account on behalf of the Plaintiff.
Respectfully submitted,
Date: Seotember 11. 2001
P.C.
rda D Cunningham, Esquire
I.D. #2 144
2320 North Second Street
P. O. Box 60457
Harrisburg, PA 17106-0457
Telephone: (717) 238-6570
(Attorneys for plaintiff)
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ORCHARD APARTMENT,
ASSOCIATES, t/d/b/a
ORCHARD APARTMENTS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001 - 1877 CIVIL
v.
CIVIL ACTION - LAW
DOWAYNA LUCAS,
Defendant
ORDER
AND NOW, this t"1 day of ~
, 2001, after
review of the annexed Petition and upon the motion of
Jordan D. Cunningham, Esquire, a Rule is hereby issued
against the Defendant to show cause, if any she has, why
any and all amounts being held in the Prothonotary's rent
escrow account should not be distributed to the Plaintiff.
Rule Returnable
10
days from the date of service.
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ORCHARD APARTMENT,
ASSOCIATES, t/d/b/a
ORCHARD APARTMENTS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001 - 1877 CIVIL
v.
CIVIL ACTION - LAW
DOWAYNA LUCAS,
Defendant
PETITION TO MAKE RULE ABSOLUTE
1. The Plaintiff, Orchard Apartment Associates,
t/d/b/a Orchard Apartments is a limited partnership which
is registered with the pennsylvania Department of State
having a registered address of 2204 Cedar Run Drive, Camp
Hill, Cumberland County, Pennsylvania.
2. The Defendant, Dowayna Lucas, is an adult
individual who previously resided at 2206-L Cedar Run Drive
Ext., Camp Hill, Cumberland County, pennsylvania.
3. On March 30, 2001, an appeal was filed by the
Defendant, to which a Complaint was filed by Orchard
Apartments seeking the eviction of the Defendant.
4.
There remains a balance of escrowed rents
I
deposited with the Prothonotary in the amount of $1,491.00,
1
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representing rent deposited by the Defendant on behalf of
the Plaintiff.
5. On September 12, 2001, Plaintiff filed a petition
to Return Rent Escow.
6. On September 17, 2001, this Court entered a Rule
to Show Cause against the Defendant to show cause why the
Petition to Return Rent Escrow should not be granted, Rule
returnable ten (10) days from the date of service. A true
and correct copy of the petition to Return Rent Escrow and
Order are attached hereto, made part hereof, are
incorporated herein by reference, and marked as Exhibit "P-
111.
7. On September 18, 2001, a copy of the Order and
Petition to Return Rent Escrow was served on Defendant's
,
counsel.
A true and correct copy of the Plaintiff's
correspondence to Defendant's counsel is attached hereto,
made part hereof, are incorporated herein by reference, and
marked as Exhibit "P-2".
8. A response to the Rule and Petition has not been
filed as of the date of this petition.
2
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WHEREFORE, Plaintiff respectfully prays that this
Honorable Court direct the Prothonotary to distribute to
the Plaintiff all monies being held in its rent escrow
account on behalf of the Plaintiff.
Respectfully submitted,
Date: October IS, 2001
P.c.
D. Cunn'
#23144
20 North Second street
P. O. Box 60457
Harrisburg, PA 17106-0457
Telephone: (717) 238-6570
(Attorneys for Plaintiff)
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ORCHARD APARTMENT,
ASSOCIATES, t/d/b/a
ORCHARD APARTMENTS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001 - 1877 CIVIL
v.
-, CIVIL ACTION - LAW
II DOWAYNA LUCAS,
!I Defendant
j'
ORDER
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AND NOW, this 17~
day of -1. ~-c..... 1,,, .
,
, 2001, after
review of the annexed Petition and upon the motion of
Jordan D. Cunningham, Esquire, a Rule is hereby issued
against the Defendant to show cause, if any she has, why
any and all amounts being held in the Prothonotary's rent
escrow account should not be distributed to the Plaintiff.
days from the date of service.
!I
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Rule Returnable /0
AN1 A/VS"-'e..- .f.'/uI sJ1/JII be..
(') b th.. PteolhONOfIJ1
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BY THE COURT:
An
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fRUE COPY FROM RECOrO
In Testirtlony when.n11, t ht.lre ;}nto Sf~t my h;.::;nd
and the s.eai of sa~d Gm,u .:1 CJ,i'j::5,!t\ Pa.
This 17 /b' day of .2hJ I
ctt" Q 'nA,/h -,J~I'V
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Prothonotary
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ORCHARD APARTMENT,
ASSOCIATES, t/d/b/a
ORCHARD APARTMENTS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
!!
NO. 2001 - 1877 CIVIL
v.
CIVIL ACTION - LAW
DOWAYNA LUCAS,
Defendant
ORDBR
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AND NOW, this
, 2001, after
day of
"
,
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review of the annexed Petition and upon the motion of
Jordan D. Cunningham, Esquire, it is hereby ORDERED that
the Prothonotary of CUmberland County, Pennsylvania,
distribute to the plaintiff, Orchard Apartment Associates,
t/d/b/a Orchard Apartments, any and all amounts being held
in the prothonotary I s rent escrow account in the above
"
docketed case.
BY THE COURT:
J.
- ~,
ORCHARD APARTMENT,
ASSOCIATES, t/d/b/a
ORCHARD APARTMENTS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
i[
I
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II
NO. 2001 - 1877 CIVIL
v.
CIVIL ACTION - LAW
DOWAYNA LUCAS,
Defendant
PETITION TO RETURN RENT ESCROW
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II
II
II
11
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1. The Plaintiff, Orchard Apartment Associates,
t/d/b/a Orchard Apartments is a limited partnership which
is registered with the Pennsylvania Department of State
having a registered address of 2204 Cedar Run Drive, Camp
Hill, Cumberland County, Pennsylvania.
ii
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2.
The Defendant, Dowayna Lucas, is an adult
"
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individual who previously resided at 2206-L Cedar Run Drive
II
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Ext., Camp Hill, CUmberland County, Pennsylvania.
3. On March 30, 2001, an appeal was filed by the
Defendant, to which a Complaint was filed by Orchard
Apartments seeking the eviction of the Defendant.
!i
:'!
4. There remains a balance of escrowed rents
;!
deposited with the Prothonotary in the amount of $1,491.00,
representing rent deposited by the Defendant on behalf of
the Plaintiff.
1
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5. The issues raised in the Complaint relating to
ej ectment are moot as the Defendant had abandoned the
apartment unit and the Defendant's whereabouts are unknown
to the Plaintiff.
!:
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6.
Plaintiff, in light of the fact of Defendant's
abandonment from the premises, is due and owed the monies
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being held in escrow by the Prothonotary of CUmberland
County pursuant to the Local Rules of Court and the Rules
of Civil Procedure for District Justices.
"
WHEREFORE, Plaintiff respectfully prays that this
! Honorable Court direct the Prothonotary to distribute to
the Plaintiff all monies being held in its rent escrow
account on behalf of the Plaintiff.
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Respectfully submitted,
P.C.
Date: September 11. 2001
rda D Cunningham, Esquire
I.D. #2 144
2320 North Second Street
P. O. Box 60457
Harrisburg, PA 17106-0457
Telephone: (717) 238-6570
(Attorneys for Plaintiff)
2
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JORDAN D, c'tiNNINGHAM
ROBERT E. CHERNlCOFF
MARC W. WITZIG
HENRY W. VAN ECK
CUNNINGHAM.& CHERNICOFF, P.c.
ATTORNEYS AT LAW
P.O. BOX 60457
HARRISBURG, PENNSYLVANIA 17106-0457
HERSHEY lELEPHONE
(717) 534-2833
IRS NO. 23-2274135
lELEPHONE (717) 238-6570
FAX (717) 238-4809
Street Address:
2320 N. 2nd Street
Harrisburg, PA 17110
September 18, 2001
Philip C. Briganti, Esquire
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
Re: Orchard Apartments v. Lucas
Our File No. 408501
Dear Phil:
Enclosed is a Rule to Show Cause, returnable within ten (10)
days with regard to the above captioned matter. The Rule was
issued pursuant to my filing of a Petition to Return Rent Escrow.
Also be advised that Ms. Lucas abandoned the apartment unit
sometime in August, 2001. I believe the issues raised by the
Complaint in Ejectment are now moot. If you have no objection
to the money being held in rent escrow to be distributed to
Orchard Apartments, would you please file a responsive pleading
as soon as possible so that I can remove the money from rent
escrow.
Thank you for your attention to this matter.
Very truly yours,
, P.C.
. Cunningham
JDC/bam
Enclosure
cc: Orchard Apartments
,
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ORCHARD APARTMENT
ASSOCIATES, t/d/b/a
ORCHARD APARTMENTS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2001 - 1877 CIVIL
DOWAYNA LUCAS,
Defendant
CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I do hereby state that I served a true and correct copy
of the PETITION TO MAKE RULE ABSOLUTE in the above captioned
matter by placing the same in the united States mail, first-
class, postage prepaid, in Harrisburg, Pennsylvania on October
~, 2001 addressed to:
Philip C. Briganti, Esquire
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(Attorneys for Defendant)
Date: October
IS,
2001
By:
J D. Cu
#23144
320 North Second Street
P. O. Box 60457
Harrisburg, PA 17106-0457
Telephone: (717) 238-6570
(Attorneys for Plaintiff)
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ORCHARD APARTMENT
ASSOCIATES, t/d/b/a
ORCHARD APARTMENTS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2001 - 1877 CIVIL
DOWAYNA LUCAS,
Defendant
CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I do hereby state that I served a true and correct copy
of the PETITION TO RETURN RENT ESCROW and ORDER in the above
captioned matter by placing the same in the United States
mail, first-class, postage prepaid, in Harrisburg,
Pennsylvania on September 18, 2001 addressed to:
Philip C. Briganti, Esquire
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(Attorneys for Defendant)
Respectfully submitted,
Date: October 8. 2001
~~COFF' P.C.
B!'/ .~
I B-anche A. Morrison, Secretary
to Jordan D. Cunningham, Esquire
I.D. #23144
2320 North Second Street
P. O. Box 60457
Harrisburg, PA 17106-0457
Telephone: (717) 238-6570
(Attorneys for plaintiff)
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ORCHARD APARTMENT,
ASSOCIATES, t/d/b/a
ORCHARD APARTMENTS,
Plaintiff
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENWSYLVANIA
v.
NO. 2001 - 1877 CIVIL
CIVIL ACTION - LAW
DOWAYNA LUCAS,
Defendant
ORDER
AND NOW, this 1'1;- day of /)eJ1~
, 2001, after
review of the annexed Petition and upon the motion of
Jordan D. Cunningham, Esquire, the Rule issued against the
Defendant to show cause why any and all amounts being held
in the Prothonotary's rent escrow account should not be
distributed to the Plaintiff is made absolute.
The Prothonotary is directed to distribute any and all
amounts in its escrow account to the Plaintiff.
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14431211012001
PYS405
Cumberland County ~rothonotary's Office
Manual Release Check Reglster
Accounting
Escrow
Amount
Page 1
11/01/2001
Date
Release
Distribution
Case No
Tran
Date
-------+------------------------------------------------------------------------
2721 GRCHARD APTS Check Date: 11/01/2001 Check No.: 1253
RENT 2001- 01577 PYMT/CHECK 360.00 3/19/2001
RENT 2001- 01577 PYMT/,MONEY ODR 120.00 4/'04/'2001
RENT 2001- 01577 PYMT/,CASH 120.00 5/'04/'2001
RENT 2001- 01577 PYMT/,CASH 120.00 6/'04/'2001
RENT 2001- 01577 PYMT/MONEY ODR 120.00 7/10/2001
Payee total:
840.00
Grand total:
840.00
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