The URL can be used to link to this page

Home My WebLink About01-2505 FX I. COMMONWEALTH OF PENNSYLVANIA _ COUNTY OF' CUMBERLAND Mag_ Dlsl. No 09-2-01 OJ Name. Hon PAULA P. CORREAL Addeo" 1 COURTHOUSE SQUARE CARLISLE, PA T,I,pho", (717) 240-6564 17013-0000 KATHLEEN BARR 227 W POMFRET ST CARLISLE, PA 17013 THIS IS TO NOTIFY YOU THAT: Judgment: NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS fBARR, KATHLEEN ., 227 W POMFRET ST CARLISLE, PA 17013 L ..J VS. DEFENDANT: NAME and ADDRESS [JENSEN, DENISE, ET AL. 141 W LOUTHER ST CARLISLE, PA 17013 L Docket No.: CV- 0000019 - 01 Date Filed: 3/19/01 CROSS COMPLAINT 001 ., ..J Judgment was entered for: (Name) FOR DEFENDANT Wll.T.T.ll.r.R FRll.Nr.TNR [i] [i] Judgment was entered against: (Name) 00 on: Rll.RR, Kll.THT.RRTiI (Date at Judgment) l/?R /01 . . in the amount of $ . D Defendants are jointly and severally liable. D Damages will be assessed on: D This case dismissed without prejudice. D D D Amount of Judgment Subject to AttachmenVAct 5 of 1996 $ Levy is stayed for days or D generally stayed. Objection to levy has been filed and hearing will be held: Date: Place: Time: (Date & Time) Amount of Judgment $ .00 Judgment Costs $ .00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ .00 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ * * See attached ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOT ARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTIT SCRIPT FORM WITH YOUR NOTICE OF APPEAL. 3/28/0t Date I certify that this is a true 1/28/01 Date My commission expires first Monday of January, Aope 315.99 '_~-:"~ ""'1~,,,,",,,,..~,,,",~1'I!lIj" __~ .t:~ i '" I-I'" . District Justice g the judgment. . District Justice 2006 SEAL ~ 0 COMMONWEALTH OF PENNSYLVANIA ~(. COUNTY OF: CUMBERLAND . ..1 Mag_ Dist. No 09-2-01 OJ Name: Hart PAULA P. CORREAL Add"" 1 COURTHOUSE SQUARE CARLISLE, PA T"'phoo, (717) 240 - 6564 17013 - 0000 KATHLEEN BARR 227 W POMFRET ST CARLISLE, PA 17013 THIS IS TO NOTIFY YOU THAT: Judgment: . [!] Judgment was entered for: (Name) [!] Judgment was entered against: (Name) NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS I 'BARR, KATHLEEN 227 W POMFRET ST CARLISLE, PA 17013 L -.J VS. DEFENDANT: NAME and ADDRESS !JENSEN, DENISE, ET AL. 141 W LOUTHER ST CARLISLE, PA 17013 L Docket No.: CV-0000019-01 Date Filed: 3/19/01 CROSS COMPLAINT 001 ., -.J ..",.,' . '\li~: . , FOR DF.FKNDAN'I' .TRl\T!'lRl\T nRl\TT!'lF. . nn on: RARR, KATHT.F.Rl\T (Date at Judgment) 'I /?R /n1 . in the amount of $ o Defendants are jointly and severally liable. o Damages will be assessed on: o This case dismissed without prejudice. O Amount of Judgment Subject to Attachment/Act 5 of 1996 $ o Levy is stayed for days or 0 generally stayed. (Date & Time) Amount of Judgment $ .00 Judgment Costs $ .00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ .00 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ * o Objection to levy has been filed and hearing will be held: * See attached Date: . - Place: , , Time: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS. CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TR SCRIPT FORM WITH YOUR NOTICE OF APPEAL. 3/28/01 Date I certify that this is a true a 3/28/01 Date My commission expires irst Monday of January. AOPC 315-99 '~~~~-~".,"-~-=-> -"~~~- . "-~'~r"'lll I, ,. , District Justice ontaining the judgment. , District Justice 2006 SEAL - - ~ 'III . / COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND 09-2-01 NOTICE OF JUDGMENTITRANSCRIPl CIVIL CASE PLAINTIFF: NAME and ADDRESS IJENSEN, DENISE. ET AL. 141 W LOUTHER ST CARLISLE, PA 17013 L Mag. Dist No. DJName: Hon. PAULA P. CORREAL Add"" 1 COURTHOUSE SQUARE CARLISLE, PA VS. T,"p"''"' (717) 240-6564 17013 - 0000 DEFENDANT: NAME and ADDRESS IBARR, KATE 227 W POMFRET ST CARLISLE. PA 17013 L Docket No.: cv- 0000019 - 01 Date Filed: 1/05/01 'I -! ..,~ ",'"..",',..,. ~ KATE BARR 227 W POMFRET ST CARLISLE, PA 17013 THIS IS TO NOTIFY YOU THAT: Judgment: FOR .DEFF.NDAN'I' [i] Judgment was entered for: (Name) RlIRR, R'lITR [i] Judgment was entered against: (Name) ,TRN!'lRN, nRNT!'lR, RT AT, in the amount of $ nn on: (Date of Judgment) 1/?'R/n1 o Defendants are jointly and severally liable. o Damages will be assessed on: (Date & Time) O Amount of Judgment Subject to Attachment! Act 5 of 1996 $ Amount of Judgment $ .00 Judgment Costs $ .00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ .00 . Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ 1~ o This case dismissed without prejudice. o o Levy is stayed for days or 0 generally stayed. Objection to levy has t;>een filed and hearing will be held: * See Anached ,. Date: '. Place: . , . 1 Time: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COpy OF THIS NOTICE OF JUDGMENT/T SCRIPT FORM WITH YOUR NOTICE OF APPEAl. J!2IJ/Ol Date ~/ , District Justice "--- nyl1ning the judgment. /' . District Justice My commission expires first Monday of January, AOPC 315.99 2006 SEAL - - - s_" ~ ~" ..... "-I..... - .. j'-IC81b- COMMONWEALTH Of PENNSYLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL FROM JUDICIAL DISTRICT DISTRICT JUSTICE JUDGMENT COMMONPLEASNo.6/- :l.,(";)t:: NOTICE OF APPEAL e()Ll'y~ Notice is gi_ that the appellant has filed in the abave Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the ,case menffoned below. :ful'" """",.. Of APPE~ 22 3-2 O.AIM NO ""TE NT Bel r f" w, Po s+. \i.cd..e. I MAG DlST.NO O'NAME OF;1 _~ -61 STATe ZIP CODE J CV 12 -/!)/ LT 19 This block will be signed ONLY when this nataffon is required under Pc. R.C.P J.P. No. 10088. This Noffce of Appeal, when received by the District Justice. will operate as a SUPERSEDEAS to the judgment for possession in this case. ~~ Signature of Prothonotary Of Deputy If appellant was CLAIMANT (see Pa. R.C.P.JP. No. 1001(6) in action before District Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appelfant was DEFENDANT (see Pa. R.C.P.JP. No. 1001 (7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appelfee). PRAECIPE: To Prothonotary Enter rule UPOIL]) en; s e, J e:n..c;en ~ F ranr.:/nc, Watht;t'.,ppeuee(s). to file a complaint in this appeal ~,,!:':"'Iee(S) (Common Pleas No. ~ / -.:/.s'lOt; G.;o i ( F.:/L.fw'tin twenty (20) days ~e:&::: entry of judgment of non pro~ . F rq.nci n~ WcJ 6ce.. Signature of awe//ant (J( his attomey (J( agent RULE: To 'DehISe> J enc;enj e.-,j..=",'/ .appellee(s). Name of awe/Iee(s) (1) You are natified thot 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 nat file a complaint within this time. a ,JUDGMENT OF NON PROS WILL 8E ENTERED AGAINST YOu. (3) T~ date of service of this rule if service was by mail is the date of mailing. ;.", ,P ,,", ~ Date. ()~_.'I,:2'1 ,......'")'^'"") '-- a'fkJ~ ~~~ ~ .~..~ ,'. Signatureol DtJ Of POPe 312--84 COURT FILE TO BE FILED WITH PROTHONOTARY PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT COMMONWEALTH OF PENNSYLVANIA (This proof of service MUST BE FILED WITHIN TEN (fO) DAYS AFTER filing the notice of appeal. Check applicable boxes' COUNTY OF -;n 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) . .0 by personal service 0 by (certified) (registered) mail. senders receipt attached hereto. and upon the appeilee. (name) ,on , 19_ 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 Cnmplalnt accompanying the above Notice of Appeal upon the appellee(s) to whom the Rule was addressed on . 19--., 0 by personal service 0 by (certified) (registered) maU, sender's receipt attached hereto. SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF ,19_- Signature of oft1fJ'<1/ oefore whom 8f!idavit was .made TlffG ofofflc;faf My commission expires on .19-. ~ "'- ~ VI ~ \ Signature of affiant ,. . ~ ~~ '1 8 ~ (\::J I \ r ~ ~i ~ (") C .,,~ ~ =~ ~.o i~ ~.. Q) o o -n . ,... .." "" N -.J :::l F.l~ :xf;3 , 06 ::::i.d 6~ &fi ~. .." 3- r- COMMONWEALTH OF PENN5YLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL FROM JUDICIAL DISTRICT DISTRICT JUSTICE JUDGMENT I COMMONPLEASNo.6/- :l.t:;(":,C; NOTICE OF APPEAL eu~l.~~ 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. """'" ;''7Pf'sr-NT ~CQTe BClrr ADDRESS Of APPEll.ANT 22 W, Po '" JU>GMENT 3 N<l I MAG OlST.Na OR NAME Of;;'T _~ -6 j ~A~ ZFC~ J PA (Defendant eh5~n) W:>l CV 12 -0/ LT 19 This block will be signed ONLY when this notation is required under Po. R.CP JP. No. loo8B. This Notice of Appeal. when received by the District Justice. will operate- as a SUPERSEDEAS to the judgment for possession in tIlis case K~~ Signature of Prothonotary or Deputy If appellant was CLAIMANT (see Pa. RC.P.J.P. No. 1001 (6) in action before District Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This sectIOn of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notic.e af appeal to be served upon appellee). PRAECIPE: To. Prothonotary Entenule uponJ') en ;"5e, Je:n..<;eh k~ Francln" h!alk,e..wellee(s). to. file a complaint in this appeal ~~~e(S) (Common Pleas No. {'\ I -;;)_~C; (2;u i f. JaZ,fw't'in twenty (20) days ~f, s~vice af ,ule or suffer entry af judgment af non pro~ baiL ~ , Frqnc;n~ WcJ6cc:.. Signatureof_tarhisa""",eyaragent RULE: To. 'De.)) IS e> Jen.<;eh) r~=~ 'I .C1PPellee(s). Name of appeJ~e(s) ( 1) Yau are notified that a rule is hereby enle<ed upon you to file a complaint in this appeal within twenty (20) days after the date af service of _this rule upon you by personal service or by certified or registered moil (2) ff you do. not file a complaint within this time. a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. Date: ~~ d;;f rer.~;::;le if ser~ce wasby ma~ is the date ~~ma ~ / P ~~~ N:JPC 312-64 COURT FILE TO BE FILED WITH PROTHONOTARY -""'="-~''"'''''''''-''''J~~'~'~~)._;''''';'~F''':~~:"~~='''-"''''':'''-'""'''"'~' '"',~""--"" '\-C-:--'7:''''---' "'\'t:~-" ",'00 -, .,,- "ii'-=_~!";""f,,'-;-":-- -,,"', -;,. ~"",_~_"_,_ A,~~ :-"'-"I!IIiI..i[~ittli~~,i>lLl\""lA;i.W~Il;;>I~OII!i~r__i PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DA YS AFTER filing the notice of appeal. Check applicable boxes) COIIIIl'lONWlo.J\LTH OF PENIIIIlYl Ii JlNIA COUNTYOF.l1/lJi)berlaod___. ;so AFFIDAVn': I swear or affirm that I served ~ a copy of the Notice ot IIppeal, Common Pleas No. . 0 I - a.5 0.') ,upon the District Justice designated therein on (d/lte ot service) 5 - q:: 0 L_ by ~~rsonal ~ervlce D by (certified) (registered) mail, sender's recei~t atta~he!l herelD, ami upon the appellee, (name) e., e. ~ fl"' n .,., Mo." q ., -;roOOl:>I ' :>y personal service l8l by (certified) (registered) mail, sender's receipt attached hereto, I2!l and further that I served the Ruleto Filea ComplainlacGompanying the above Notice of Appeal upon fhe appellee(s) to whom Ihe Rule was addressed on _ i'^a.y 'I , ",i1fJCi D by personal service IS by (certified) (registered). mal!, sender's receipt attached hereto, SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS _,!].Jh ___, DAY ~~_., fSA ._. ~ '+1~ ____, Signature of ,';dlh:;h~! before, whom affIdavit ~ J/iithhYV~~ Signature of affiant fiNa (,f Ofl [<t: - ~ . NICOI,~{:FR\'. Notary Public My (,)m",' .'on eOllllili~ CumllerlandCoun '9._ My C\lmml~onEltPlres April 18, 2005 ,"-"- ,- (') 0 0 c: -n s:: :x ~ ""00:; Do ~-T1 morn -< -"~I Z::Co Z" I -o)iTi CI.l:!?" u:> >.::;0 ~L ;~~~~ ~o -0 ~o -'" :;m 5'>g ~ ~rn L; 3. U'l ~ ...,j -< " pRoTHONOTARY CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 17013-3381 Jillm . , 1 J ,'~'~ ',-_~<,__" ,,-~_.,. ~,'-,= .,~_>;c,.",,^ ""-.C'_; -." -'. U.S. Postal Servige" - ; -; _. ,;;, CERTIFIED MAIL RECEIPT ; , . ] (Domestic Mail Only; No Insurance Coverage Provid#f!l.: _ ~ I 'n J LrJ =t' <:J ...lI ".. $ ...lI Postage LrJ ,." Certified '~ee' r'l fulturll Receipt Fee ru (Endot:semen! Required) <:J _ Res.triclad ~Ii\lary Fee <:J (Endornemen\ A~\,I11etl) 0- $ 0 Total Postago & Fees ...lI C 0 0 0 f'- .. ~ - U.S. Postal Service .. ":"- -- ~ CERTIFIED MAIL RECEIPT ;- .-.: (Domestic Mail Only; No Insurance Coverage ProvidedJ I l -' ,,," co ,." o ...lI ".. ...lI LrJ ,." r'l n.I <:J <:J ?ostage S Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) <:J <:J ...lI t:J .~~-1r~~:Oe:i~:G:~~~~__~__.__n_"~~_~~_____~~_____' c:J Street Apt, No.; ot PO Bt No. ~ _cn;.nJ JZiP1-~- 04-:;-<:'1", 0 Total Postage & Fees $ - , PRAECIPE FOR WRIT OF EXECUTIOIII (MOIIIEY JUDGMENTS' P.R.C.P,. 3101 ,to 3149 ..... FRANCINE BRAX'IDN WALLACE ........................................... ........................................... IN THE COURT OF COMMON PLEAS OF ~ COUNTY, PENNSYLVANIA CUMBERLAND VS. 01-2505 T 19 Judgment No. ..... . . . . . . . . .. erm, KATE BARR a/k/ a ........................................... KATHLEEN BARR ........................................... PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (I) (2) Directed to the Sheriff of. . . . .. ... ~. . . . . . . . . .. . . . .. County, Penna.; Kate Barr a/k/ a Kathleen Barr against ...................................... .. . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . (3) (4) ............................................................................. Defendant(s); and against. .. .~..'?~. ~~~~.. . . . .. . . . . . . . . . .. . .. . .. . . . .. . . . . . . . . . . . . . .. . . . . .. Garnishee(s); and index this writ (a) . Kate Barr a/k/ a Kathleen Barr . agamst. . . . . . . . . . . . . . . .. .. . . . . . . . . . . . . . . . .. .. . .. . .. . .. . .. . . .. . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . Defendant(s) and . Bank of Landi'sburg agamst. . . . . . .. . . . . . . . .. .. . .. . . . . . .. . . . . . .. . . . . . . . . . . . . . . .. . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . (b) . . . . . . . . . . .. . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . ... . . .. . . . . . . . . . .. . . . . . . . . . . . . . Garnishee(s), as a lis pendens against the real property of the DeFendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property)' all bank accounts (5) Amount due $. .1,.1.6~:~~........... Interest from Total . .1.~ ~~~:~?......... Pluscosls. 5-7- f)Z- Dated....................................... . NOTE Under paragrarh (I) when the writ is directed 10 the sheriff of another county as 3tllhori7.cd by. Rule 310.1(b), the counly shpuld be indicated. Under Rille 3J03(c) a writ issued on a ltallfcrrred judgment may be'directed lothe sheriff (If the counly in which issued. Par"graph (3) above should be conlplcled Ol1l~'-if 3 nallled garnishce tS 10 be included inlhe wril. Paragraph (4) (a) above should be compleled only if indexing of the execulion in the county of issuance. is desired a.~ authorized by Rule 3104(a). Whenlhe wril issucs 10 anolher county indexing is required as of course Inlhat county by Ihe nrothonolary. See Rule 3104{b), . Parttgrallh (4) (h) should be completed only ifreal property in Ihe nllme of the garnishee is lIt1ached and indexing as a lis pendes is desired. See Rule 3104(.:), o('~m-_I _ ~"O ~~f~l! .' , ~ o r- ~ Lt ~ -.,J) '::sfQ: ~~ :3("y,P- Sl~ lr:f O!: ~ ~- ~~" A ] '1j ~ J ~r-~ ~~. ,~ ~ 0J ~ t" C? 0\ E " f-: ~ -~, --~ - ,~~~" ,- ~,- . "'",-- -~- ~ ~ -- ~ , t " ~Ji 3 rI '-'~ ~~ J ~ J ~~ P- . I-. .t: 0 - '0 00< .0; <- :0: IIlZ :.E ....l< .~ p...> z .. . E z....l 0 U :2 0>- 1= - ;:; :< :E~ ::> ~ 0, (.) i:i .,. :EZ " w w E ,., 01Il II. X B vi U w '" U":, > w u. -g <3 1-.>- <I: 0 ..., Of-< a: ~ ,., ,., II. " ~ f-<Z ii: " 0 ~ t>:::J :ii: 6 ~8 a: '" u.;:.: f2 "- lIlt>:: :1:0 f-<>- Z - J~ - ~ ~ ~ - J - " ~ 2: ~ ';) .J) >~ .-. ~ , , , ::: {9 ~ 0.' Z , " , t" ~""', J ~l~?:~ 2: ;~:~ (L 0 -.) ....,.-- ':--<2' ( I I -I cY c.C~'~ - :':~3 8 l:J , \) "6 'J_:- ..- () \l ~ ~ - "fJ(.- ,..-- :;:rr> ~ Q () ~ 0 ]; CJ~ '" .'.lZ Lj ~ ~ 1; ;~_. .:'-Z 0:- .,0--: . :.:-~1 ;;:Pi ;LiCO t1 :::r .....:. -...;. .:r "" L.l_ -', CLl C1- 1>,- i'f)- 0 -, ~. -.... 0- """ tJ~ '" :::J -fry- 0 .c.:> 0 ua^!~ aJpON %. uo!ssajUOJ Aq paJalua ou Iuaw~pnf uo!ssajUOJ ACfpaJaluajuaw8pn f lBiJlM!lIl!milffi!'jPilV__-"~'l'",~_.. _~,,~;. ~~ __....,~~"JIDW!J rm- !1ft~~''l'i'_''':lm',-,'''''''-c("'' _"",j,"l"'-"_'\\" . . -., ,;".",~,\,~,O:;;;;;OP!;{<~,>;!';lJj_-;;lI,~,<r~j:- _;",",,-q,;nIT~}"'il~T''f~~f'1,ij;i\!i;,,,"'I' ..,.... '" DENISE A. JENSEN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01-2505 CIVIL TERM KATE BARR a/k/a KATHLEEN BARR CIVIL ACTION - LAW FRANCINE BRAXTON WALLACE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01-2505 CIVIL TERM KATE BARR a/k/a KATHLEEN BARR CIVIL ACTION - LAW INTERROGATORIES TO GARNISHEE To: Bank of Landisburg (Garnishee) You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you: 1. At the time you were served or at any subsequent time did you owe the Defendant any money or were you liable to her, on any negotiable or other written instrument, or did she claim that you owed her any money or were liable to her for any reason? Answer: 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the Defendant? Answer: 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the Defendant or in which Defendant held or claimed any interest? Answer: '~~"-.."".,-,.-._-,, ,,1""1_, >L ~ ... "~~I,IIT1, . 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the Defendant had an interest? Answer: 5. At any time before or after you were served did the Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefor? Answer: 6. At any time after you were served did you pay, transfer or deliver any money or property to the Defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the Defendant against you? Answer: 7. State the name of the owner or authorized signators of any accounts which you have in the name of Defendant, the number of each such account, and the amount in such account at the time of service of these interrogatories and at the time of answering of these interrogatories. Answer: GLENN C. VAUGHN By ~/dfF= Attorney for P4iiiti ID No. 07484 ~, -J"!'I, _ ' 0--- " ~ WRIT OF EXECUTION and/or.ATTACHMENT . . COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 01-2505 Civil CML ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FRANCINE BRAXTON WALLACE, Plaintiff (s) From KATE BARR A!K/A KATHLEEN BARR, 227 WEST POMFRET ST., CARLISLE, PA 17013 (1) You ate directed to levy upon the property of the defendant (s)and to sell (2) You aTe also directed to attach the property of the defendant(s) not levied upon in the possession of BANK OF LANDISBURG, 5125 SPRING ROAD, SHERMANSDALE, P A 17090 - ALL BANK ACCOUNTS GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $1,164.80 Interest Arty's Comm % LL $.50 Arty Paid $94.25 Plaintiff Paid Date: JUNE 27, 2002 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) Prothonotary n .Bv: a~~,. ~ Deputy 7rzrn/>.At. r-- REQUESTING PARTY: Name GLENN C. VAUGHN Address: 22 SOUTH BEAVER ST. 'YORK, PA 17401 Attorney for: PLAINTIFF Telephone: 717-845-9689 Supreme Court ID No. 7484 ~"-~-i , il ,-, ,~- ,-,~- ,~ ,,~, , - 1<oth lec:n 13Qf'r- ~2. 7 w' YO?'Y\ki- .3+. C-Q..-t;.sl~ l PA /1013 {o.-ppeliant) :De n-tse. Jense Y) I'-I{ lrJ, Loutheyst Carl;S/€.-1 PA llol3 (4 ppe.llee) N (').\.t c.e.- \' 0 'D e te Yl cJ Dcd::J # Q U -oCOCdlq -61 ~;w/ # o{-J.505 F yo nCi n e \Nol[ac-c: '25 FChnerl-on Rd. \=)ao li J PA N3D I ( Appe.flee.) 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 (201 DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILING IN WRITIJIfG WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. OU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED W -HOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU B~ THE COURT W T~OU~ FURTHER NOTICE FOR ANY MoNEY CLAIMED IN THE COMPLAINT OR R ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU' Y LOSS HONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. . .. YOU DO OR THE HELP. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF NOT HAVE 1\ LAWYER OR CANNOT AFFORD ONE, GO TO THE TF.LEPHONE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL / Cl.MBERLAND CDUNTY' BAR ASS<X:IATION 2 LffiERl"f AVENUE CARLISLE PA 17013 717 249 3166 ~oJJJ KQ-M Ie.en Bqrr -^'-'J:q:"'~~-"-r- 1'" 1""1,-,' '1 'I I "1 COMPLAINT Kathleen Barr 227 W. Pomfret St. Carlisle, PA 17013 (Appellant) Docket # CV-0000019-01 Denise Jensen 141 W. Louther St. Carlisle, P A 17013 (Appellee) Civil # 01-2505 Francine Wallace 125 Fennerton Rd. Paoli, PA 19301 (Appellee) 1) In response to the original complaint filed against me at Docket # CV -19-01 before District Justice Correal (D. J. Correal), I attest that the above appellees broke written contracts for room, board, triUlSportation and supervision for the students Sasha Edleman (age 15) and Ashley Wallace (age 14), students at the Central Pennsylvania Youth Ballet (CPYB). Exhibit 1 and 2 2) These students were removed from my home by their above named parents on November 11, 2000, without notification prior to that date. 3) Furthermore, there was no notification whatsoever, of any dissatisfaction with their placement in my home. 4) Said contracts were for the school year, September through June 2000-2001, with monthly payments of $800 each, and a security deposit of $800 each. 5) D. J. Correal determined in her attachment to Notice of Judgment dated 3/28/01 that the (Jensen) contract was flawed and the (Jensen) addendum was not enforceable. 6) D. J. Correal determined that all parties failed to adequately communicate. 7) D. J. Correal awarded zero dollars in damages to either party. 8) Although I have attempted to place other tenants in my home to recover lost income, I have been unable to do so. 9) This bas resulted in considerable financial distress. ':t ,I", ,- , , f. ,,"__, ,_ _ ~ '" ",~_o_ .- ,,, ,_, '!!!II!."".,_, '''''.'",""" .",~, ,'." , "_ _,. ,_"-,, " , ,. <,,,-,+, '"I 10) On the afternoon the girls were removed from my home (November 11, 2000), I was shocked and stunned by the written accusations brought against me. Exhibit # 3 11) At that time I was informed by Mrs. Jensen that I had broken the contract and the girls would be removed from my home immediately. 12) In good faith, I provided a home for Sasha Edleman and Ashley Wallace, through the terms of the contract for board, room, transportation and supervision. 13) There was ample opportunity for dissatisfaction to be brought to my attention, to wit 13 a.) Both girls communicated frequently with their parents. 13 b.) Sasha Edleman had free access to e-mail through my personal computer and she frequently spoke with her mother by phone. 13 c.) Ashley Wallace spoke daily with her family on her own private phone line, paid for by her family and located in her room. 13 d.) Mrs. Wallace was in my home nearly every weekend, September through November 11th 13 e.) Mrs. Edleman and I spoke several times by phone. 13 f.) Mrs. Edleman visited in my home two weekends prior to November 11th, spending over two hours in conversation with me on one occasion. 13 g.) I was told by Mrs. Edleman that Sasha had made an excellent adjustment and was doing the best she had ever done in school. 14) At no time was I told by either parent or child that anything was wrong, but received only positive comments from parents. 15) On several occasions, I spoke with each girl privately and asked if there were any problems. 16) At no time were any problems expressed, with the exception of Sasha' s complaint of her bedroom being cold, for which I was taking steps to alleviate, and told her of those steps ( extra bedding, the offer of a temporary electric, micro furnace and the covering of an exposed window area with plastic). 17) It must be noted that several written complaints (Exhibit 3) occurred during the two to three weeks prior to November 11th, during which the seasons were changing, it being warm one day or a part of one day and chilly during another. 18) Furthermore, during this same time, the girls Sasha and Ashley were extremely busy with their school and dance schedules, (Ashley having added more dance hours to her schedule), and both girls were absent from my home while visiting with parents on the weekends, returning late Sunday evenings, thus limiting time available to talk among ourselves. 19) I had no opportunity to attempt corrections, as I was unaware of any complaints beyond Sasha's, ofa cool room. .,"" - '" ,-"", ~,~ <_ ,'_""!-'_ ':'_~"""ij~I''''__ -''',,",_"];,0'$.,,,,,= ~~"'_.."" "".";_, "',~'" "'''_~ ,~ -ct - - '" -~- ~ ,- 20) Written complaints regarding my daughter's action of visiting with two male friends in her room, in early September, reflected a one-time incident which I discussed with her and which was never repeated. 21) On one occasion, a young man known to my daughter and myself from regional church events, spent a September night in my home with my permission and supervision, as I judged he was certainly no threat to anyone living under my roof. 22) Sasha Edleman and Ashley Wallace had no contact with the young man other than exiting the house in the morning, as we all left for school. 23) When Sasha Edleman and Ashley Wallace entered my home, both families were aware that I was and am a single parent and was raising a 17 year old daughter, which requires considerable juggling of time and energy. 24) Both families were aware that I was employed full time as a primary school teacher. 25) As such, there are specific times of the year when my professional duties are more intensive and time consuming. 26) At no time did I fail to provide food, board, transportation or supervision. 27) I regularly sat with the girls as they ate, so that they would not be alone at the table; I provided opportunities for shopping trips and a visit to the P A Renaissance Faire; I also provided special Halloween decor and special favors; and during my most busy time, I assisted Ashley Wallace in developing and constructing a project for a class at school. 28) My home was thoroughly cleaned on a regular weekly basis, with the short-term exception of the time period two to three weeks prior to November 11, during which housekeeping was erratic due to the extremely busy schedule we were keeping. 29) When Mrs. Jensen and Mrs. Wallace arrived on the afternoon of November 11th, my daughter and I were in the midst of a thoroughly cleaning our home. 30) The written statement of complaints (Exhibit 3) presented to me by Mrs. Jensen was later addressed, point by point and copies sent to both Mrs. Jensen and Mrs. Wallace. Exhibit 4 31) The majority of complaints in (Exhibit 3) seem to apply to SashaEdleman only. """ -_~ e. _ I' . r -,'-'_~ -',_1-'-'-7, _ = _ ,.,~,_ _ _,_,_,-,.,,,,,_./"%~,,I!!!I!!,,,,,~,~,_ <' ',' c_ _ ,,, _~~ '," _'~,.N< RELIEl<' REQUESTED I request that the appellees, Denise Jensen and Francine Wallace, honor their contract and reimburse the appellant Kathleen Barr the amount of $7,900 (seven thousand, nine hundred dollars), which reflects only part of the income owed her for the time period of November 11, 2000 through June 30, 2001. Had the appellees honored their contracts, the appellant Kathleen Barr would have received $5, 600 ({rYe thousand, six hundred dollars) from each, for a total of $1l, 200 (eleven thousand, two hundred dollars) December 2000 through June, 2001. Further, the appellant, Kathleen Barr asks that she be reimbursed for the costs incurred by her for this litigation, as set out in the contracts. Exhibits 1 and 2. These costs are as follows on this 18th day of May, 2001: 02/09/01 Initial Consultation, Killian and Gephart 04/27/01 Cumberland Co. Prothonotary's Office 05/09/01 Post Office, certified mailings $200.00 $ 45.25 $ 7.48 $252.73 I state that the facts set forth in this complaint are true and correct to the best of my knowledge, information and belief. J d1zti1 --./) 'j'JffA( ~ CJ/u.-r/ I f;, c1tH I Kathleen Barr - If '^""'- q'I" < ~-;,;' ,-~; ."^'''''",,r''I'--~-'-''' ",,~,,_""-,,=<" - ',~',,-.'- ,.' -I <;-. ".. ,-- - - t)(h'\b t'f '. i#o{,/x.. CONTRACT FOR BOARD AND ROOM SCHOOL YEAR 20 CD TO 20~ r This is an agreement between Kathleen Barr and D e 1) I 5 'e., . . J ens e VI the parenti s of S as "'CL. td e.1 rna!'lto provide a private room, board, transportation, and supervision for the school year, beginning Septemb~ and ending .51000 June~20co. By signing this agreement, '1)., n' ~e.. J e '() s e VI . is/are commirti;;g t~~':f ~s financially to a total of $8,000 for the above time period. * $1600 First payment upon reserving the room, which includes: *$800 September's rent, . *$800 Deposit for the following purposes: *for damage to structure, furnishings, and appliances, caused by the student beyond the normal "wear and tear" of occuparion. Parents are to be notified when such damage comes to my attention. Receipts for repair or replacement will be provided and funds deducted. The parent/swill be ,esponsible for any and, all excess costs necessary to effect r~r or replacement. . *an emergency reserve for unplanned or emergency expenses of the srudent. *Late payment fee. Please see below. *The parent/swill be notified if funds from the deposit are used. Receipts will be provided for each expense. All unused funds will be returned when the student leavesthishoUsehold;after<-~ ~ inventory and inspection of the student's room is performed. If repair and/or replacement of items is in process; the balance of the unused funds will be returned within 30 days.' ' *Monthly payments of $800 are due by the first of each month (unless otherwise arranged): October, November, December, January, February,M~,April,lyfay and June. '... Since I depend on these fees to help pay food, transportation, service arid energy costs, it is necessary that they be on time., A 5%Jeeof$40,,,,ill~e.,' charged if the monthly payment is late without a five day notifi~ati611:~l1ally. the 25th day of the previous month. This will be deducted from the deposit . and the parenti s notified by phone and receipt. . "' -r'r'--""~'-"-"-'-""-'-" . --~'~"~""~"''''~fW C-'''''-c"''T'''''-~.T'-''''''~-' ",_~e.~~ -- ~"" -'--~=---'i'=,,,~,-_~....,,w~_ ," 'I"'" Please note, I am committing a portion of my home' and my time and energy toward the support of your daughter for the term of this contract. I expect your commitment of the $8,000 fee for the same time. If your daHghter leii'. 0 tl.~ C,.dl,..:!. 1'011...... Y Otltl. B.J1...l fN any rtlason, all rcma:iri;ng',;;oht!jj\',001J'l .!:ndboanhnust 13e paid at th@ time sfle..leaves-:-A refund is p533tbk only if lHl~~ffit-ef-the-school-wou--efltff-my-he~er. TI,p refund 'l~ 6tia be:, ror. Lt.:' ';~~_~'~~ ~'-li6el, that :Ae,~rJrr_,~_,pnr '.~;0111d b~ l~'{7~ng ~r ~r .residcnee: If-eM balmee ~ Hul pM.! at the time your daught~; rfii.~ht ~r\Clll.l.t\;lrcl) ka'l€, J)pY\; ",p l<!..-.~,<! . \ we~d 8130 be. '~3pofJSible for any court/lawyer exp€nse~ ne("(,5saryr-for Kathl.......H l3.udu H:....U,errne l'Cmainingbalance. See A.bbe.v1d1ln1 OBLIGATIONS, OF KATHLEEN BARR .' Meals and Nutritional Guidance: As a trained Home Economist recognizing the nutritional needs of a teen in a very demanding physical training program, I will endeavor to provide an appropriate meal pattern and diet for your child, This will include consultation, monitoring, adjusting and advising. It is understood that there may be conflict between the demands if the program for a minimum standard of weight and the needs of the student's body for optimum nutrition. If an adequate diet pattern is not followed, injuries will. The conflict may also lead to eating disorders. Concerns in this regard will immediately be taken up the student and parents. Healthy, well-balanced meals/snacks willbe served with consideration to food likes/dislikes. If a meal is not acceptable to the ~tudent, she may use leftovers from a previous meal, or make herself an alternative (with my ok) from food in the freezer or pantry. Breakfast will be "make-your-own" from a variety of accessible choices .I expect boarders to be up early enough to eat a reasonable breakfast. Lunches may be carried to school in a thermal container I will provide. These are to be made by the student on the previous night. Alternatively,the student may chose to buy her lunch at school, in which case I will provide $2.00 a day. Dinners will be provided according to the student's schedule. This will be a hot meal available at the dance school to be warmed up, or upon the student's return home after her last class. Transportation: The Carlisle Community of schools expect the majority of.students to walk. My home is within 8-10 blocks of both Lamberton Middle School and Carlisle High SchooL Morning transportation can be provided if the student can be independently prompt, as Imust also meet a schedule in the morning. The dance barn and warehouse are within walking distance of Carlisle High School and busing is available from Lamberton Middle SchooL Transportation will be provided to return home from dance classes. Transportation to and from practices and special events is provided within the greater Carlisle/Harrisburg areas. This includes transportation to the Harrisburg International Airport or to the Harrisburg Train/Bus Station. Transportation outside a 35 mile radius of Carlisle will be charged at $.25 a mile. Day trips to Philadelphia, Baltimore and Washington D.C. and environs . are acceptable. I do not travel to N.Y.C. or to PittsbUrgh; Train and bus service is available from Harrisburg for these cities. . ""1 - --'-,-~ -,n -"",'," '1--- ,-" - -., rTI"~"--' o-'",,'=''-~'"'~'-'~_''''''_''''''"~'''--,''' "-'''''-T'''''~'''''l'''''''''"W''"''V'''''''''---'--'-''-'''- 'n'-,"T"_,~==''''1''':'''_=_'",,,~''1''~'~'~_____' .,~ <: Communication: Students enterili.gCPYB are embarking on a; strenuous and taxing stage ()(their lives, not only physically, but academically and personally. It is my job to help the student meet these new challenges in a supportive family setting. I will support and c()unsel each student as needed and provide a regular family council time to help the student integrate as easily as possible within this new life, away from her family. Your child will be welcomed as a complete member of this family. I respect each student as an individual, and !require from each student a . respect of self, of other students living here, and of myselJll,ridmy family. . '.' . I expect to be in contact with parents on a regular basis, especially in the beginning of the year and to express and concerns to parents and student. E-Mail is available. The student may choose to have a private line established in her own room at her own expense. The downstairs phones are available for use with a calling card. . .- .- - -,'., - . . . Housekeeoing: Bedspread, blankets, sheets and towels are provided. Sheets and towels are laundered weekly; blankets and bedspreads as necessary. Nails, screws or other such fixtures may not be added to walls or doors, nor moved without my permission and supervision. A bulletin board, laundry hamper and mirror, and wastebasket are provided in each room. There is access to a vacuum, mop and dusting tools. All trash is to be placed in appropriate receptacles by Thursdaynight. Laundry facilities are in the basement and include washer, dryer, ironing board and drying rack or clothes line. The student must provide her own iron and flat-rack drying system. Space for bicycle storage is available. It is strongly suggested that bikes have a strong lock and it is imperative that a helmet is worn. STUDENT OBLIGATIONS *The student will respect herself, other girls in the household and Kate. Our dogs, Puma and Russell B. are to be treated kindly. *The student may not drink, smoke, or take other than prescribed prescription drugs. *It is the student' sresponsibilityto keep her room in order by vacuuming and dusting weekly. Equipment and supplies are provided. *Thereare to beno candles, incense, matches or lighters in the student's room. *Guests oftheopposite sex may be entertained only in the first floor common rooms. *Carlisle has acurfewpolicy, requiring all students under the age of 18 to be home by lIpm. When the student is out of the house other than at dance classes or activities, I expect to know where the student expects to be and the approximate time when she will return. For a student to attend a partY or activity at any home, I must be provided with a home address and the phone number of the parents hosting.( I will contact these prior to the party or activity, to be sure there will be active supervision and a no alcohol/drug policy in effect.) '~--''''?~''''"'''.; --~-"'~""-,~""'- rei""" """"'~-~''C'r='D~n'O'~''=::~'1'~''=''l'''''''=''1''''=-'r~~~?''.o'''''''-'-''="i",","~""""''''''''~-''~''''~ -, ,'~c_,'_'__~~_ , .~ ~~""".......__,~_",..,"= _~ ~~""""""''''I!'""''''''~'_''''=_~''''''''_'''''.J>lI_>'=l._~''',,",~_ _~_"~,__~..~il'il~~,." '1;; .v y " *The student is expected to pick up after herselfintl1ecomm.onllreasofthehpme: returning personal Items to her room, placing recyclable items in appropriate containers, returning food containers to the refrigerator and placing used dishes in the appropriate containers, *Wet clothing must not be left on floors or furniture, *Lights and other electrical appliances are to be turned offwhen thestudeilt is leaving an area. This is especially important when the stu~ent is the last person to leave the roomlhouse. *The student is to be provided with her own spending all()wance and to purchase her own personal supplies, including laundry detergent. *The student will be responsible for her personal laundry. She will be assigned a scheduled personal laundry day after a family council discussion. Non-assigned days will be available on a first-come, first-serve basis. *Each evening the student is responsible to make her own lunch or to notifY Kate that she will need money to buy a lunch the following day. *The student is responsible for wakening independently and for leaving the house in a timely manner in the mornings, *The student is responsible for common kitchen tasks: + emptying and cleaning herthermallunch container and returning the cooler packs to the freezer. + keeping soiled dishes and glasses off the counter-tops and out of the sink area.. + refill ice cube trays and water filter pitcher as they are used, + wash and refill a juice pitcher when the last serving has been used, Kathleen Barr, S4Sk l:dd /nO Y'\ (student)and Tlc-nlse.. j,\')<;eY) (parentis) agree to abide by the above contract. Signed ~ Date: (j"" CJ.4,,,Jooo o Witnessed If()tf-7R -S'J'O 1 Date: 8 - Z ~ - ~ 0 0 0 --".-,~-,"--; "-"'--""'''-''--,--'----''--''''"~.,.,c-w-c.'::.=Fr'"~.,''..~,..,-^'~''''.-~'"t;"""~'""...,'"'"~'''''''-1''~-'''fP--n''''I'~''''''''''''"''''''''''1''''''1I'r~,,~'l''~'''''~-.'',.T'''''''c---c., . ..7 . -.. lllJ De;;;-';;::;' I I ./ '-~" . ThE +eY<VVl o-r+h,'s GJn-/-l2f1d .ih1u pUf2po'se ~,e JM.hA- FJe/mdll ~e~idl';:;~"'IA"tlJ/QII'sI€ )'S (,t2.sf) 10 A i~e;,1d. (!/JR ')S Ie... P.lb /I'C ~:t}Sre;jk~f')L;~;~ t:n~" "y~~t' ~:cr:,:1.' ,to 1R!,," :r expfifcfT'.SftiAA' +1l'CO/11 p Ie I e -He -h II t:,J,oo I te;em J ,4-f tAR I,s J~)~t~L~' hOD I fl n DR"'" .+10 '" 'j 0 U Rho m "- ,), <In d ),thll+ 41t11e. ' - ~" ,HD.W&Q~'Jr:.r;:f~fJ$hlti'UJtru.1d b~ u.l1Co/YIrolCfll/;/~) due-l-o 'stt?esstul ReIA-I/ol1~Alps WI.)f,I/M YOUR home :r f(eseRtle J ",-the RI~h!-fD(!!l11c€-I+AJ's COnfRftetltn,d. PR/hftJA&AA-Aom€. ::IfduR.'ng- -the -JeJem oFfh,'s CtJfI-IRAC+; S4,d"A would JeAue C€A1fR/l1 PA Youfh SA/Jef -r(}/~ P.eA~tJn of IlljVRl.() " II,,,. , 0 ~ i u sf no f uJ4flfl"j fo cOl1hn"~ b. lie'! f ~ A 111171 } bu + Wo (L III Jj +,11 be A b Ie ..fIo A-NeMd CJlle II '$ Ie Ugh ~Joo J I +Ais. C(Jn1f2.lJo! Wou.1d f(6;iJ1A/J1 /n err-cd) fIJ i~e €Mcl of 111 e ~cj,&o / yef1R . . Tn Hte eU0l1+ tl+' seR.lou-s //lhe~5) I~Jf/J(1 OJ( (!Jl+Asf/2iJfie.. "11 ~ftSAAS It'Fe) I /2eS(!,etJe. H.e RlgA+ftJ hR/fla ~f/~l4 h 0 m e Itvl.O( C A-r1 eel Hus C& J1 -I f!;1 c- -f . 'J'J G 1\}1 At:.d oO.'Y'f\^m ""0'_'" '-'--0'-.__' 'T..T'...~..,......,.. ~"-.~~~ '" 'I' '~I'~ r_ ~ tx'h'lb;+-lt2 CONTRACT FOR BOARD AND ROOM SCHOOL YEAR 20_ TO 20_ ('. I n.<:> ,'0' . ," d' , or ^ I 'n \, I - ',IClCe.. This is an agreement between Kathleen Barr and' (" "1 v i I -\\.:'.D _ .V\J (Ll the parent/sofAs h I eLj W o-Xk,,_e..to provide a private room, board, transportation, and supervision for the school year, beginning SeptemberDC' and ending June-,--,> 20-aJ. By signing this agreement,~i ne..>", ~ f)fa~~Y\ 'is./ are committing themselves' financially to a total of $8,000 for "theltove time penod. * $1600 First payment upon reserving the room, which includes: *$800 September's rent, *$800 Deposit for the following purposes: *for damage to structure, furnishings, and appliances, caused by the student beyond the normal "wear and tear" of occupation. Parents are to be notified when such damage comes to my attention. Receipts for repair or replacement will be provided and funds deducted. . The parent/swill be responsible for any and all excess costs necessary to effect repair or replacement. *an emergency reserve for unplanned or emergency expenses of the student. *Late payment fee. Please see below. *The parent/swill be notified if funds from the deposit are used. Receipts will he provided for each expense. All unused funds will be returned when the studeilt leavesthis household, after, . an inventory and inspection of the student's room is performed. If repair and/or replacement of items is in process, the balance of the unused funds will be returned within 30 days. *Monthly payments of $800 are due by the first of each month (unless otherwise arranged): October, November, December, January, February, March, April, May and June. . Since I depend on these fees to help pay food, transpottation, service and energy costs, it is necessary that they be on time. A 5% fee of $40 will be charged if the monthly payment is late without a five day notification, usually the 25th day of the previous month. This will be deducted from the deposit and the parenti s notified by phone and receipt. '-"~-~~-T'~-;""rT'F-'''' ';~""'-~7_"V' '_ ""'''-'''''T'T~'''l'''''~''<<-'l''''''?''T--''~' ,- ~-, r-'~-~'-_~___',,, "'-",""~~"")__T"-"'_~__ -" ' ,''!_;'' K"-'C~ , ~ase note, I am commiuing a portion of my home and my time and energy toward 'rt of your daughter for the term of this cbntracr. I expect your commitment of the e for the same time. If your daughter leaves the Central Penna. Youth Ballet tor 1., all remaining months' room and board must be paid at the time she leaves. A possible only if another student of the school wbitld enter my home asa boarder. ld woitld be for the time period that new student would be living at my residence. me is not paid at the time your daughter might prematurely leave, C J n eo a Vlcl/ hJ would also be responsible for any court/lawyer expenses necessary for Barr to recover the remaining balance. ' . OBLIGATIONS OF KATHLEEN BARR j Nutritional Guidance: As a trained Home Economist recognizing the nutritional , teen in a very demanding physical uaining program, I will endeavor to provide ,riate meal pattern and diet for your child. This will include consultation, 19, adjusting and advising. It is understood thattheremay be cbnflicr between the' the program for a minimum standard of weight and the needs of the student's body 'm nutrition. If an adequate diet pattern is not followed, injuries will. The conflict may o eating disorders. Concerns in this regard will immediately be taken up the student s. althy, well-balanced meals/snacks will be served with consideration to food ,es. If a meal is not acceptable to the student, she may use leftovers from a previous lake herself an alternative (with my ok) from food in the freezer or pantry. Breakfast ,ake-your -own" from a variety of accessible choices .I e~pect boarders to be up early eat a reasonable breakfast. Lunches may be carried to school in a thermal container I ie. These are to be made by the student on the previous night. Alternatively, the lY chose to buy her lunch at school, in which case twill provide $2.00 a day. Dinners ,vided according to the. student's schedule. This will be a hot meal available at the )01 to be wanned up, orupoll the student's return home after her last class. ttion: The Carlisle Community of schools expect the majority of students to walk. My ithin 8-10 blocks of both Lamberton Middle School and Carlisle High School. :ansportatioJi can be provided if the student can be independently prompt, as I must 1 schedule in the moming. The dance barn and warehouse are within walking distance . High School and busing is available from Lamberton Middle School. Transportation JVided to return home from dance classes. msportation to and from practices and special events is provided within the greater lrrisburg areas. This includes transportation to the Harrisburg International Airport or :isburg TrainlBus Station. Transportation outside a 35 mile radius of Carlisle will be $.25 a mile. Day trips to Philadelphia, Baltimore and Washington D.C. and environs clble. I do not travel to N.Y.C. or to Pittsburgh. Train and bus service is available from ; for these cities. ,~" ""'0;" , Communication: Students entering CPYB are embarking on a strenuous and taxing stage of their lives, not only physically, but academically and personally. It is my job to help the student meet these new challenges in a supportive family setting. I will support and counsel each student as needed and provide a regular family council time to help the student integrate as easily as possible within this new life, away from her family. Your child will be welcomed as a complete member of this family. I respect each student as an individual, and I require from each student a respect of self, of other students living here, and of myself and my family. I expect to be in contact with parents on a regular basis, especially in the beginning of the year and to express and concerns to parents and student. E-Mail is available. The student maychoose to have a private line established in her own room at her own expense. The doWnstairs phones are available for USe with acalliilg card. Housekeeping: Bedspread, blankets, sheets and towels are provided. Sheets and towels are laundered weekly; blankets and bedspreads as necessary. Nails, screws or other such fixtures may not be added to walls or doors, nor moved without my permission and supervision. A bulletin board, laundry hamper and mirror, and wastebasket are provided in each room. There is access to a vacuum, mop and du~ting tools., All trash is to be placed in appropriate receptacles by Thursday night. Laundry facilities are in the basement and include washer, dryer, ironing board and drying rack or clothes line. The student must provide her own iron and flat-rack drying' system. Space for bicycle storage is available. It is strongly suggested that bikes have a strong Jock and it . is imperative that a helmet is worn. . STUDENT OBLIGATIONS *The student will respect herself, other girls in the household and Kate. Our dogs, Puma and Russell B. are to be treated kindly. *The student may not drink, smoke, or take other than prescribed prescription drugs. *It is the student's responsibility to keep her room in order by vacuuming and dusting weekly. E<juipJ,l1eIlt and supplies are provided. *There are to be no candles, incense, matches or lighters in the student's room. *Guests of the opposite sex may be entertained only in the first floor common rooms. *Carlisle has a curfew policy, requiring all students under the age of 18 to be home by llpm. When the student is out of the house other than at dance classes or activities, I expect tolmow where the student expects to be and the approximate time when she will return. For a student to . attend a party or activity at any home, I must be provided with a home address and the phone number ofthe parents hosting.( I will contact these prior to the party or activity; to be sure there will be active supervision and a no alcohol/drug policy in effect.) "r '--"'^"'"-T1'r-''I'.,".-"".~"",,,,,F";='':"'"~''''~;''r'''"''~l'''"''"'"'"''f'~'F'''""-~='-"'f==~",~7~"'",,'1'='""17"""""'~>1<"''=''''''"-'''-- - ~ ~. , *The student is expected to pick up after herself in the common areas of the home: returning personal items to her room, placing recyclable items in appropriate containers, returning food containers to the refrigerator and placing used dishes in the appropriate containers. *Wetclothing must not be left on floors or furniture. *Lights and other electrical appliances are to be turned off when the student is leaving an area. This is especially important when the student is the last person to leave the roomlhouse. *The student is to be provided with her own spending allowance and to purchase her own personal supplies, including laundry detergent. . *The student will be responsible for her personal laundry. She will be assigned a scheduled personal laundry day after a family council discussion. Non-assigned days will be available on a frrst -come, first-serve basis. *Each evening the student is responsible to make her own lunch or to notifY Kate that she will need money to buy a lunch the following day. *The student is responsible for wakening independently and for leaving the house in a timely manner in the mornings. *The student is responsible for common kitchen tasks: + emptying and cleaning her thennallunch container and returning the cooler packs to the freezer. . + keeping soiled dishes and glasses off the counter-tops and out ofthe sink area. + refill ice cube trays and water filter pitcher as they are used. + wash and refill a juice pitcher when the, last serving has been used. Kathleerr Barr, A .3 hi eLj \^'alJaee.. Signed ~"i3aAJ., ./ ?f.W~, . ~ ~'LL e. \tVl1I \ CUJl. _ (s, tudent,) and e l ne ~~ . .,qg-' 5b- 4-J .'. (parentis) agree to abide by the above contract. , ~~hn Date: ,Q 1J7 ~O I r::)086 Witnessed Date: .' --<n:"c-,-",~""_ 'l--T<'~""~-f1'-"-;-=-'?"""'-'''T,"''''"_.'~r,,"- ".'~,!,r<' "~'-'l"""-~'"-T''''' ~''''''--'--,''' ~ ~=~~,,,,,~~;,^,, ." ,,: '-~-_' _.: .~--- Ke ' '~ ... ~ ./ . .' . ,. -r d,'J 5;"",~/J?~',,z...>!, _'1 ,~1'~ '-;:::" 2.,<.~k-~ hdCln: nv.<,~c",-// ;""~-"'."~''''~,';'''-:->'''I'n~<'~/,~ -fd/;;;';,1-;~i/;'c.i..-' "r .::::.:" ~'- 'P - P OU-":rr ~. ~ k'-t.--'- - t:...;; - <-- - - /-. - ...- - u; " . L,,' ~L' ,e,Il:.:;c..tL), ",c/,- r/u.. A, m~u,,-. ' I < .~- rL 'kuJ.. ~/ A/a-<' .!-3':!.\, I Jl-'WC-...~ " - 7V.../ r _:} U_iA""':;\- d. Ct4~_~ "~'}.v./ - . -:1. lJ J 1__ "I' c......,r...rli.!-i.:'t- Ju.J _... tl' ~l.u.- ,'" e,'.'y/,/ =".. ',' I . Tit .J:, /. I'U.' u,,,-, . "~/' " ',e. "~"'" ~. t c2.H.~""nec>.dr (/I ..... '''''.' (1:1,." r-1 ("<~/s-t..,,-?->u4. "L. "".~ (C?L-f,.",+<-.I d"",;.-I:"'L~)~..:::c'I" . ~,".t..' -f1, "),./U'ln S. !l';J["M,t/ewJil-e /q/~ . '-.r;-, , * .(.,.1' ~l.' \..'\. \\':(..u'- '.<: .c-~ v -- ~-,/ .v1@ fo:'-i~ed ;a-i~o fi/'#1S1c/A'vid/517;~h;eClt/:b:Sk :c~/ .€Xfft?1.~J :r. W,.fS Io/,f fiO/ce, /N S<p"~".o~/ Yd<< tUe;(e I,4K/7 t!A~e.-<JF /:f . d ~J. T,IISStllneo!. /1 6ALJa.,e/1.IAA'en C.lMe dr. Uf'&'.I1 fiTr 1'e/ttA'/71<1 -!'.Ie. t?/eA/ -i"Z ::L A.>/<'eJ' ,5A.s:hA ;r:she;l )/I<lAMf/4y5'/~nJ- s./e /;'-/b-f/nJ /lId /la. . - . 'i i 'PL::iiCaf dC>ri:=- a.-t s~k.'-t'! -4...1 /.;':l~1- I .s/:;:;u~/ t'3"iJ""r.5 ,-1-." t_ <:: /1-a....'I'i....c:r. J, J c,.,.l,,~/: ' - + S~a'..s...{"'.._ /-t'.+-f.. !k ~~?r.s ~d ~~J?1..R..-1-- .CI '~-(.~: I~- - u.. -r::r. pI.... ......_ft,,~ . -/ , -- - -- - - . + :c d <' +......Jl S/lSA/l l~fOl!/IIt!''/ me... !-)<:. -AcG'se /5 . sd1.c!cd ,vAen d<... Cl7ftl~ A"me V,f,..,:,E!J1'\bt+ ,......,..J ):",0l ",d'-'S;;;id/J/ s-fe P./If/lr!s- -fer! eMI ;911/ !!/;;oes. V,(e/1:L A$,A',,/ j~~. /r ,fe-e .&Ohl :tt3 ~Jk~" , - 1!~5 co..<4t !'""7s /VM/Yl AI/1'j,{11 $/", //l!O.fm,.,( me $4e ske/s /~ ",.,a/I:;dk. /.l!tjMS pr '~"'-~'I:-.~t~0.:;: ~',{;IAes A/1d .J~4 jiAM",ls~1A-;'/rELJIM wh/!! f..{e4eA--';drJs/;'/e~ \i:l.hl ....., ",c.:.. 1ft/om /r.Je/t..e /&eIl1t'tI. c51e.~/d me sfe. IaMef,~ 6ob/Jq/lcfr;( fJe /;~'1/IC/.R<::' L OJ .1_. .f ,I f / ,. ...-~~... u-~'"""",-<:,-z.... ~~.. - _ - _... ()/ hl(f C4t/kI/;li7 /lO//e... [I/J/<I S;'~jA 10 1~//p'~..5k tt/17S Cd;{;/'/ yea IdU 1F~: yl:Jr;~) J;dlo feAt/e Aef'[tkM~bn A!.mj-f/. $A$M. tt//}s CMC~4t'o-fAL3':/,,-///e /\:5~, v.1',;;-,,~1;\c.-~&M Cij/1)/i'1 Iii 'jeLb;~ - y~a kll 1M' )'''a~ 47'" d~ ~1!I//7.s&,;/{IS - j, l~tfJ _ (/. I' " fd5I~ . A()coed-M fie JdC/Se.JOU q#,lse../lJ.lj). Nt! //f'IP/lC/j/ .t;.I/~4f;{e~~-c'cy.e-n /i1A/~s 1/1///7 Utb dee;; c/ill/cuIJ. Y,jt.ll,4,cJ.e.Jlitce/;dt?/~'/ ."M&ffi .-- wt".J;, II ,j/rlA/1 eled~/c. je;9/e;e., ,.)eeAu,5'~ #fe.. (;tbSRIIS /I() l/h,aa44,/, ,n _W~~YM_~oe f/f!!/~~:~~~~f:n~~~ ~~:;~1"/~:f~5;[~Ac~~:~~ ::;1:( L:;::h~:; "~t7r'~,,(;;:.. 'cDsL 'j\.lj{;.kriJ:;~c;g7.'1~ .a...ua'/..,//"" -r; r..ty ;!::./icP....uJdjt. iir 5LL':!'S b. tCS<[/ Y jl7ai", /1nd ;J.s./Ie'1 ttJue le,em/I/d It! .s/~ J1/'he r.<tJm d:ck/J ( Iff /f {/(Idlt'jl ~~u._~oe-<_~~ ~ /.!JeI!AiI$1! /.Ityf6/ue/t/t'f'J ...d.e ;OUoi?-._~> " '--IJfLlii.";:1/;;e/ned tfF-M/s ,~<r~ 1ft; s W4~.$ '-/p ~~ J,d~J * U ) r.u. '/~. -rlu "~';.J <""J I"", -k/ ,z~<d ",Jc.fJl- -r;....,.. ,ia<<rs c;<C/fl"';; 7J{.c:.... j ~ If /,- 7A.i.. OlriJ. (:; u v__, - '^/)~"" , . P .. f- b';' j - V ?,-t:V \~' ~ C'fivvi 1iJ,1 _4-.q!s,... Ji}r;f.~. Y'k--?-b~'Y/!_ct=;."'5 d _ 7/Z-?/ r-fS~'-'Sr rl/7',--L~_..s.c dcup -b 4."-FtI ;'?5su;;"d'f;:L<~/r!:i t<..,?-<d../ 4'flvl-' 1/ -f;{j 5. ftN<J 4:. pNPLr-L.-' '("'te-a',;;' . 0. 01.4&/11) 1I/);5/JeLled. Ahj.1pc< -1/Oc.t:e/C 117id;;/.[J-c ;f:/e. ;fo//~ II"? .10)'~:::~:~~,~~/~'. PM/C-s' l fu /.O1)1/.& U1/11 ,$je ~A--es.4 /~jlu>>.&j<jtJc/c'e/:!o a...l,,,J- d._ WA/): ff} scJ4#/;'/') . TAe IdMlje"e is: DIN /1/1'/ w.111 h #ef//; ... 5<t~I;,,, ",l":,, CdclM. !f;(/!//fl/j jlj. Je,qvy CpAI}e kJM/J. .l3"jkJl'Il /JIJ c~C.K&;Me. hl.!;.':.r';;-:':..~ tf)/ltt!d h%ct!.,f C1A".ey fee&,4,4/) -OAt;- l' clI/le/. /JJ;? ;J/~r~-t{J;!t!Ji!';':'.' 9E</;,!MC e 4/f.fOI=.h.e ( 6'..1' ff;j/;4'1~_.re" 1 -Ie 0~" 5:./)q,<] I/d h _ t~~~,~l, '/ ,;'1/J,., -,;;;---- ,~--- ... <._. ~. "j"':.r;./-:;.~:';, . . ;.; lie 1l.5.5C1RO me -INs j1f?oJ/ern to()q U je I/J-<'Gn (!AA3e ilr CJ# /YJdND!HjJ 1//~/<70 . \ "s$dI_H @'v -:I.N .5e.f1IC#1.Jor.. ,-.6dJ' ..:S/i;.h.A An:;! .i, /'J$./<'eol/N3<7cr1, 'Y,?t-{ (,q/r'/Il;f- .~~......->>-f'''':''~'''''''cSMA.4 -fi;;e .ske +h4'/~' . !J;,s lJetl<<' (Yt:Ctl/2R~;;' fit?/€' lA/lei ~~/~~~ . ~/~/~.s: A1;e A;Ie~ :9tf# Je!e /$/4,t>s,{,es 19;eeck1t!~ !s flj .f;,;/ ~ , _ J M~.tJh~r-a;;~Ij"Jl-'fi~n i'~~k ~i:-:&:}U;tj::;!f';t:e ;~7:;rJ;/:;"?~~~( #(k,. . .... d z;,-t.r.-- d t/s"~, J l'" -rt.-<. ~ L2-r-6:L--. 11.,[".:;+ '" TU<"-'.-,.,,::tl (J/'<""CU.!," ry"""'''', ':"' .-V '.u (n...-V'~ dr-L- Yl-O a . -"_',- ....1) c., \ ! . ;0 "J~' u.(...(..Y<- vQ ).; \. -" ,,-' . ",1<..."",-, a:.171"-"-' i:V' Ht<U.:-<:.- ",,<O;v~^"'_ ~~,<. ~<-<-., . .t. '4 . ~w~ ~(y~~7/:lci J:J;:;)~l~~k~~~/~#~";/~';)/11~~:'~~a;::;:+~aLru~w'~ tJ-f ;1!eJAfl ~, tof/s. IM/lulk/:t, .skeyJdtl6e M fje$oM. .0'.. c& /1.:11 /(;.,PlU P;h4 fits ~~/) is ,101 .(:e()/'rl AI'ryC04/ t!{Js:::.ei/!/PY/ HdJ'71 l;(etF',els - ,4 rReAl'- II/Ii-h h=<( cI~hs flNb A b4pe IAA'.1,A l.4ci.R'je-. c-f 1/5 /Jd;e 1 (i<om da!,K I()eo/) - (!) :1;</ h-I. 10 !,fe 6dlll.l/!c-f - .Re Sfud81tf rJJ%/r/;;;;JS' '7 ~lIesk ~ lie "I/"slle $ey:: m.4l.; /;e en.Je.eIAtfte/. Mitt /~ He .(;Jtsl ,clao,( CMlmm td~;IS .- " '..- _ ' . '.' .5/!.sAA liJ.fiJ/!.rYle/ us ,UflOl') h-el!. . /relu/ln /;lIe OM!' /I/~f- -F,e()/n Pft/'ll Pv,se-'s'=- AOl/&el Sje /lJef fl12rVl And .fwd i!Jfclve /'Illlks/I] lie --~~f(P'-;K.._/J..IlJ~wA<t, CIJJYllnJ c&W?l .fRtJm ;JJffMs ~ ~ -flo.~ kJ.ecom,., /J--l.]lt~ hr00;c. ff-<- ~k i -k.~ u..Jo r.u.; fu.~'0.d!."j'--' . .~~C """ c- . (j);#"1e aJ/Jlbus ~rJF. jlltl~CkM'~ - -U,am-dCt,tC Y {JJ~if l(/f}s.. A ..sAoC/C. . ))/.R1y ~/f2c1cAJeJ d1*aes /fl f!t~AIJcj(t".Rd /f-/ld. ~jJpWA!K 1 }h~icle #~p/fle, elulle.A.. <JJ? etJt!.etj fM4~fitJ&/C / /11 .etJe:<1;etJl}/l']. ~ckl( fi:3J1l IAe 01'/1 jlJ,1e evMyttJ4e~ _J.4I1.&itJIn; ;(, f~, J)//(Ij .eflJ'81'11&Yif u%{eRe lie MuJlclbj fAct'lthe.s- Atf!!? . I .." .; ,. ..' - "? t--i'C~~.<~r>_u.P-( ''''.j W Cl.-:) Cl./\JC~'VJ..{,~& -;,K. ~ :e_~~r-i (:j:--~ tUJ ~.J ,.~\,t'4'l _/.~ /l~U~.tlo ./~.'-~t.d ^LC.-- (..~ .J..(~,!.L..- ) &-it.~.!--,~-:,:~ - t/t.1.. t4./~t }'V4'-'~-L~_ "j :,,-o;i.~:z'L,{ . ...._--=""',,~..,,... . .. .. ., " --=-_.-",---:"_",,,-"--,-~-':--=~-'~- . . . ~ _~:::-~~~P'~--::-~~~:~~~~~~~~" ~~;~''''.~; -. ~;':-' "~:;:< ::;.~_..,. Ae 11.5.5t1RO me 1-1;:5 !j2fJjlem If.)(JC{ jf .pe 1;9):'fh1 l'/1/fe (Jr (7.# /YldND.A-iJ) l;j~ jtJO . @ XIV Je;;lunke.. f .60/,1 .5~JA 19~ 1. f fW<'e7,963tJerl- Il.tlU. l/llr'f~ cS~A-'l ..fOr< she '{/Nf~' 7/71$ /Jel/<<:' tJJCCMRe'cI. !-Ie,<? JA/Ic/ &/jY/~ rfl9~ j"les -9J!# Je/2 /CI",fs,f,es t91Pe~Ad"_ 1J.s Je/ .(;tJ! hAS Ifter?itl:J !~tVn J die -M.e4 "?.k -C:; -/;.e .s,f&~s; ,(/~aJ. (j) .f.f15!i/l /hId ~dlet; liJ.r;,RIJId- tI~ A l'j YR t/7c( I1tAle... f /iJ7/!jUA-JI!I-,f-nce.. tiE /lJer1f)S, foR:> IJflUn/lld'(' .sk~fJtlue. M Me~dA. &Ie t4 /Jdl j(;,PC<J tol. lil, ~"".is / Jul-r4/l1 A;'r.:tc.,;/ t!(1s::.et,iJf/PI1 Hdt'11 l1feJ/ds - ,4 f'ReA~ 1Q/-fA ~ZZ!f vI~ks /lNP fl Pope I/Jl:dfll. .f4e- i.Rije- of 1/5 1itJ>e. J fRom tJaf p.f !Qeo/) . (ff) :1#..fef. 10 .Me (!,?A~/!c-f - Re S/ude..f t!Jh}"'/;MS' - tJ/leds ".F /he djJ/"sJ!e sey: YI1Mj oe fJiJ.Je.e//llftd ~1I4 14 He .(;itsl 110M C',MIJI1tl'/ btJnJS . 5/f.sA.4 illlil.eme) itS f Ufor> h-e..e A'elufln /;lIe ,we /1;gA-fF,f(J~ 17r1J'J' Pe/tse's hOl/se; sje /he! ;JJ2tl'l I!nJ -fwd t!lfcje;e mAles in Me ~1d -f(pO,t' /JIJlluJlktJ COfY/1d cl&W/I -ftftJm r1JffAtls 3 ~ .fIdOj/! W/?dom, (j)'lffe tJjll;bus 4,< dF jl)tlJeCkM/~ - I/iM1 dC//( /if {//~/-f ttJ/Js. ,4 ..sAoC/~. . j)il!~ 6iRdCAje) d, Fe.ees f/1 f~ bJJcj:'1/ff!d /1-/1/. ~jJeuJAII( ,ltJ,;,.irle 14~!/1-Ie, eluffet<-. tJ/1 eu~ Idle f Ht>M_./ /It .eJJ~((IJ&r't1_ ~d#J( lj~m IAe obas; /;f}//C ev~aJ-'<<f: - j,4/;/&I&/11/ f{, f~. 'JJM!j /Jllt81"1le;nf WJeee He l.4tt/lclbj fAc/lthec ~e. , . (cU.). _ (/vGn+\JL( t<~ tLf1L"7/.,i h<l.L<.L lu..v-~ AV4 .pe-kc,,--, '9CV\~L- ~.' i hr:FYl'j -5~,,--> ~,.y -rk .s-kU:lLD ,.No.-+1 cv.J w-4-C- pu::r Uf'. J b a-/!. .""'" 4u,~; o..uJ"...Q.J-fLu ro. sL-e... . 5~ '7U...L>:-"-'.r -*,-2J,.,-o.-<-<- r ~:j:1,~~"1 ~.g'"'!50":""'~'<' ",.... .,;,..~" . -r- -. -, .. dD 6. ll);j.!.dd tb--wJ.- .-k [M.D_;;LL \1~v. ._-~.. --"'--. _.~ ._- --------- .. '.... ;',/ ~__'_...c--;'=~_~_ - ." -==-=-.0 -.-".' h~~ ~---'~ ~ -~,""""",",,"" ':;',;-"-" .-..........;::>:- --+~~. r'-"':"';~",.' :,- . .-' .'. :;".-~~ ". r :'~~,--"""'. _~..,___o-,oJo- _ .'~~->::-':-. ""::.-.~<---~,-"., .. -~- - tv/fA ,e~A-~;j fa fAe /f8Me... - lie CtJ/lI/CAdM.s keJ}. PRO.K/DV iy '/dt{/ %#Te g/J-f;e. IJ.sJ l&j /}NLJ 5/1S4A w/IJ k /J1DO/~ (J~.f m/IA .4/i dF -IA'e/;e. ". -h ft..RaiJ/IIf: ~1o!'f;i1s I ;Vdll&iJl.be-e.. /fj/~ j.wlf.1 yoa.e . Ga/1/24J)'fJ Rig1fS , : /b:h~ !t?;/hce-:n./ ~/$/;f Eck/;n:n leMl/t1AI-;1f' (I lle-ftLJlg{ 11-r eI ]~.~ Idi< Me .femAI/J/17 R Dtk; 'S I tV /I/(){I~bere I fJJ'/bf.1e..J $t/(J ~ d7P"'~/f / Ii hh I of .!./1 ~ /;}.tJ, ~fld;/s. EXjJ.er!-leol_.tlJlliJII. 3tJoiA-tjs .f?ilY> 1001-'0, N/JtI&t1/kL /ql;J/~ f 117/1) 10 hlJ'vC/NE ItlA/I/rce..-' ])6#/5", :rg-;vs~-'.- :z~ .;J/J:s C/iN~o+ he../lJ7t1~ItI/;. Ag~e{!2 iI/I1N/ /l kt,4/ cIA-Ian t{)11! /;e -!rIeL ;:}gAiNsf YOk~N /)1.dl<.l~1 C"e f" . I + hAS been n-.1>.+uA 1)'1 ""ap-eecL +he CbN+f:t."',,-+ -0 R f?~6"".J- Dbhkt> r-r-r ~~;J.I UJul-:J>oVY\rrr,,-f. .s+.CAR J,'s/e. eA.u be-hueen . . J. . Ki>h" :BMr-f)1\1l De-ruse :Jens~ .', is.vol'r.::, .-F<<;1'>'"' .t\r~~e>7">kr.l~,~, < _~ __~. _ "~,.. _-,_~",._~~.~_..."".....,==-----=-.~_.____.._._,_., W'_"~"'.'._'-'''''~ ~__- " ". __ ,__ _ _ _. }.Jr, +ultThe. \!.JAtl'h5 orz. .Adiol'"> ~)'lJ be /l1A-De.f~m e.11-{.,~~ PItR;I-kp// qjjv A j) 'j-" ,J ~, .':?1 .. ... ,(Iu..~lLv 11/'-::1:/' ~.AJ/r. pJ.vtt . ( t- /' .,..r' f Pi:" t- " ;',' A pCJ(""j,W' ~"t./bj jjcY . . -~~ U)y:-- ~UJ ;J;-;,.~,P/311 ~ G -t\\ St. ,uP- ,r-(/?' .r) \;;>,. . . ,.' r,r 'j 1".& rJ.-V'j JAt""' , ~ cU::.t...'^+1.-C '-!'Y.J .th aM c,{ (A{..~i1 a}( -lvv 1 ~ilit LaLL .~. ," ...._;,~,..~f..'..... ',' '...., '. ~-~ . .--- -'.-- ._---.-=-.-,---;-. - . --. - & ~r <, (\.- ., ":::!'l",,~.:::, '. . r F"o-o-".{ "-'_<<,.jJ I '.' . . . --c:>.' <,n 'j)d ." i.u-V<,'..4IJ.~(....,.U L";o-"'~u.J . - t5.......0 I. . t ,........ -, ,Zz' U -r? /' ~.. .. , ,~..,.... f ' I ~ .-- l:i..a.. -Jlvy_z:l, .1\) (9-' iC-P"'--f'.l..k,'''-c_'-,.nL C,r--'-'-< ".' t-c:--r.. ~ ~- ",' l<<,lI <' 1t-.;<. -< r" ..~ ';l ~ />-:;-1 .L'-t /-1._ v--'" .~ ~"..'~ -<.4,,,-/,.,,,..1 -.d.ac... """,Jot. - /h. -r- - " .1. 7/;' / J + ;/~. .. -~ --, _ tt...z. ............t. ~l.';-"_ ~brc.e",fO..:f.~7/-<- t'"c...."(J. c--G-/...~~.-r- c..?-.._<- ~~--"--~~~)~'v..~.. '2-.?"....~'- ~Q..4:.~'t_O .b _.a- ~.1' . ~ " " ~ _ ~.O ",,-yo. ' , . . [' /l<,k}}v?d - I pi,) oj, ,j, . rjJVM t " t) i vU 0'~ ./&0'0-' ~~f '~.ftux;cJwvch~&,ctj;-..at-r ,L~~0~ "j . <', > ~f-~"'VJ.'t- "-,,,,<.<> -"V'-7!U~J I /Yl.-C- M/Z;~ () 4-'""""1 -1J;:~ ~J-::t'.A..~ .u/. ~, klUi-'M ~ -41'4vvP~ ~/t):;{h-~J--h (U'~f;";~~~~'-f {lJJL ~ J.fi.-c( J/,.Let--uL ~..k-d ,4i--&, ~,'I'~/U'1~ U~4;~ ~!.J.-i-,--,..-c-A-u ~€6 ~~~ t-W 4~~ f Ib.L.J~ , I/J.~ 'JU;f TI> ~4-J W..:J ,w. '.ryrv1.-< ,tx<l. .fJ1-0 ..c....'tLC,~.......,'-"". ,LVu-u.<z-, jJu.Nv'..o U<.0 t>_ -f3::~( -- .---........-.~--~ I {j'?/ IJ.vVv f" ..L ,,,,' v , U c.-?!.rO...J ~'1..vnlr . ;1)' J-' 7jf&-t/ /.l/'iV1 ,~U1-..LL- ~ ..d~~'a4 ~~b;;~<J" ~~ 'f -1::tt..UuI fl}.itl .iL- ''}<I\-&.v jj~ /itux''-' -'~ ~/Vt--d 4rt.dc.~..J;..;-rl...'--6+ . .p~......"l_"..i Ju,f .'"U>1j V.~W.if /~ :?b ;I1..~-~U "'. ~cJ.-cA <Jd.Q~ ,,,,,-,,J- "';:.' ,- d _ -CLu )tLif- ;f,~ _ .l."li, - "", 1:;::;':",-' "~'-1"'1- " -- - I" .,.".,- - ~.,.. txh'\ba"~/-/ ., Dear Mr. and Mrs. Jensen and Mrs. Wallace: To say that I was shocked at yoUr appearance on November 19th, complete with a list of ways in which you felt 1 violated our contract, is an under~tatement. Accusations were pres~nted . by Mrs. Jensen. During our recent conversation when you first returned to Carlisle from the West' Coast, you were full of praise for Sasha's state of mind and excellent school record. After Mrs., .' and Mr. Jensen had spent around a half hour with my daughter, you said youfeltthatMeghan's".. presence contributed to Sasha's positive outlook. During a later phone conversatiOll with you, I , was told that the decision had been made for Sasha to remain in Carlisle for the rest of her High School years and to attepd the CPYB during that time. You were very positive about her , experience and seemed to suggest that she would remain in my home, At no time was there any concern or question raised. Mrs. Wallace has been in my home nearly every weekend since school started. At no time did she voice any concern. I am going to address each of your written concerns, some of which Ibelieve pertain to Ashley Wallace and most to Sasha Edleman. As these were addressed to me in a single document, I will respond in a like manner. I feel that there were some instances in which I failed to communicate with a parent but that there were also mitigating circumstances. 1. I had been asked to find a physician for Sasha Edlemall,,,,ho did not and does not, as .' ,." -', '--- '- -'--'--" - of November 19th, have health insurance. I did speak with Mrs. Jensen on at least two occasions regarding this. She said that was the next thing on her list as soon as there were funds. During . one phone conversation I gave her the number for Pennsylvania's KIDS medical insurance program. She told me at a later date that she had called the nwnber and that that number was inoperable. Within the last two weeks, I again gave her the nwnber and Mrs. Jensen commented that she had recorded the original nwnber wrongly. I had called two Doctor's offices. Neither was willing to take Sasha, as an umelated student, without health insurance. SinceSashawas in good health, I did not pursue this. We have two sources for "emergency" treatment in Carlisle: ,. the emergency rOom of Carlisle Hospital and Health South. I made the determination that these would be adequate. A physical is made available at Carlisle High School. I recently signed:the paperworkforthisand hand,-delivered it to the school, as Sasha hadleftJhesepapers, plussQ.ll1e " . others which lookedfi!tp<>rtantfor ner, on:the table. . .'. .,' . ... , '., ,.'>',;c;::. .- - '" - 2. I turn the heat back in our house during the day when we are not home. It has never been below 66.degrees as seton the thermostat. Granted, this is too cool for comfort. I expect the thermostat to be turned up when people re-enter the home. My daughter, Meghan regularly did . this when she returned home,usuallyatound 3 pm. This was also atimeoflate Fall fluctuating temperatures, someda.ys.cchilly, some days wMm:' Sasha never informed me that there was a problem, or that she was uncomfortable. Had'shedone so, I would have told her to turn up the'" thermostat up<>n arriving home....::?;.;;,.. . ,,- :."......-"""_"""i.b"..- There is a heating duct under the'nght'srde of Sash a's bed. This does tend to be a cool room as it has two walls on the outside of the house. Meghan and I had spent several hours on Saturday, November 18th, placing plastic over the screen area on the sleeping porch to provide some protection on that side. Sasha had told me her room was cold. I suggested leaving her door 1 ""~~~"" ",'''W~i\iijf.f1-1'-- --:- "~-"", ," ,".~,,-,>-:;. ',',' :J I' -f ._""'-'-~,,: -,.'- "" ,-~:- :,-.-- ,.'-'~ -,,: '''','__,,'-'0_- - open a little a night. There is also an upper transom win~()w~hich,~()uld havebt:~l1:,twpe~.t(). .. allow air circulation. Sashanever mentioned household noise being a problem; IaIso o~ed . her an electric, ceramic disk, micro furnace, which my daughter used last year.I also told her to keep her closet door closed as the closet is uninsulated in my 100+ year old house. Warmer clothing could have been obtained by taking her clothes out of the closet the previous night. The micro furnace was never used in her room, to my knowledge. This weekend, I offered her flannel sheets, as the nights have turned cold. Sasha refused these. I was not ignoring this problem. I was offering appropriate remedies. 4. (There is no 3.) I was home from my school on Friday, November 10, after completing two days of conferences for the parents of my 2nd graders. When I got up to get the girls off1 noticed that both Sasha and Ashley were extremely tired. Theirbody movements were lethargic and facial attitudes were less responsive and animated that normal. 1 told both girls that I feared for their health if they continued without sleep. I said I felt it was time for a health day before they would become ill. I checked to see that they had no school work, tests, or projects due which they assured me they didnot. (Since they had been visiting and traveling with you for several weekends, after dance classes were over, the girls had not been getting their Sunday of . relaxation which was so important to their physical functioning. Ashley was maintaining a new, more rigorous dance schedule.) Both girls returned, a little reluctantly, but it seemed with obvious relief, to their rooms and slept until afternoon. Both girls went to dance classes that afternoon and returned home in high spirits. Sasha was dancing around the dining room chortling about how well she felt and saying "This is how it feels to have enough sleep!" I had planned to. talk with each set of parents about the active schedule the girls were keeping and the need for more sleep. I made sure my schedule was clear on Sundayafternoon and evening (Nov. 19) as I wanted to bring this up when you returned with the girls. I never thought. to call, ,as this was no . emergency, but within the range of daily decisions whichI felt was normal to make. I assume that at least one of the girls mentioned this. If it was a problem, I would have expected to hear , from a parent after Sunday, Nov. 12th, or earlier, as both girls were in frequent, often daily, ..'.' contact with their families. 5. I believe Sasha may have mentioned she had to carry her books long distances. My . " ". ',',. ,. '.' daughterdid too last year. Sasha couldeasily have stopped at the. school office andmadeher d' " ~c,c',;,;o'<'lack of a locker known, or asked me specifically tocalfJd1d'6bseiV;:;hef~eanng a.lighfjacket,' . but I also observed her wearing a heavier one. The afternoons have only this last week (Nov. 13-17) turned cold. Previously the afternoons have been frequently warm. Some mornings, when Sashahas been downstairs on time, she has ridden to within 2 blocks of the school. This is a regular routine. Frequently, teens do not like to wear heavy outer garments. At age, 15, I assume a girl is able to make the decision over what weight coat she needs. . '.',.. ,. Sasha has been coming down late in the last two to three weeks. I normally fix a hot '~'~f;~reakfast for the girls two to three times during the week. I have not been able to do this recently because theY,l:1ave been down so late. Sasha has walked a number oftimes in the morning because she coUld not be ready between 8:15 and 8:20. I have checked several morningsto make .> .sure both girls were up, because both had expressed ~ey were so tired. Getting lip on time is a girl's responsibility. This is stated in the contract. . . 2 . ~R~;\Li , ,',. . -- -~~""I 'I' I' --- - - :i~~",. - ~t'"''!,);;~';;''-';'--'' ,~;-, - .." -, -~-' ~- - > '_"".. 'of ,'.." , J. '~.. _,' -,'-,--,-" ._",,___,,",_,:o,._.~ -,' 6. I contactedCPYBin Septernber ask:ingwhere shoes could be fitted. I was told there were no longer any I(}cal (CarlislelHarrisburg) businesses doing this. I was told that girls usually mail-ordered these. I believe I mentioned this to Sasha. Sasha did receive a pair in the mail. They were returned because they did not fit. I made the mistaken assumption that another pair would be ordered and tried. I should have followed up on this. However, I just became aware that two companies do come to the CPYJJ to fit shoes. There have been five opportunities since September/or such fittings. Each has been posted by flyer at the Warehouse. The company representatives do fittings between approximately 4-8:30 PM.. Sasha never mentioned this to me, and obviously did nottake advantage of the opportunity. I had no way of knowing this, since I was rarely in the Warehouse. 7. A male friend ofMeghan's did spend one night on the couch in our living room on a one-time only basis. He had come from out-of-state to attend the Renaissance Faire with my daughter's church youth group. This group does have other "odd-looking characters" as well as "normal-looking" teens involved. I honor our churchfor being willing to ,accept these young people. I did not want him, as a fairly inexperienced young driver, to drive home'to Virginia. I probably should not have allowed this. I did sleep with my door open and he left as we did in the morning. I knew the boy weiland did not feel he would create a problem. I must note that this happened in late September. If it was of great concern to either girl, it should have come up before now, as each was in regular contact with her family. This young roan does look decidedly odd. In our home, however, we emphasize judging people based on who they are, not on how they look. Having lived through the "hippie" era I had, my share of being judged on "looks". Some teens rebel by acting out, drinking, doing drugs, having early sex, or dressing in weird ways. I believe that weird dress and a decent person underneath far outweigh other choices. I try to maintain high personal standards. Meghan is very , vehement about her standards. She is not a follower. She sets the standards and she has lost a lot of friendships because of this. Please note that when you both came back to the house on , . Saturday evening, November 18th, there were abllut 25 teens carpeting two roomsfllr Megimfs: 18th birthday party. They were calm and orderly and having a good time. There was normal teen behavior, and they were being supervised. There were both weird and' normal' looks in dress, 8. Again, in September, there was one incident ofMeg having two young men friends upstairs in her room. I had returned home from an umemembered errand, but do remember buzzing Meg in her room over the intercom. She told me she had two friends, naming them, in her room and I reminded her of the house rule and told them to come downstairs. I had discussed.. with her previous to taking young girls, that it was especially important that there be no males . beyond the first floor. She made one mistake. She was reprimanded. It hasn't happened since: 1 may add, that even though there, is an item in the contract barring young men above the ground floor, I would not have "thrown your daughter out of the house" for breaking this rule, Rather, it would have been an occasion for discussion between us. . f_ 9. I must admit that my housekeeping has not been good over the last month. Cohference" time is the busiest and most demandiIig time of the year in the Elementary scho~1. I have been' , putting my time at home into the girls, not the house. I frequently put in 18-20 hour days between my teaching position and seeing to the tra,nsportlition and good meals for, your girls. I 3 ,,..,,, , ,. .~ ~ ~ " -~ .~-'.. -.. '" still made.it a point to have a sit-down meal for Ashley and Meghan shortly after Ashley came home from dance. I also usUally sat with Sasha while she ate, although I know a couple of nights I collapsed on the couch. After both girls had eaten, I cleared up food, and prepared for the next day. I often napped, then would get up around 2 or 3 am to continue work on my school paperwork. I felt it was important not to break the girl's routine, because mine was particularly demanding during this time. On the weekends, I was taking my daughter to college open-houses in preparation for college application. Vacuuming and dusting were .on low priority during this period. ]f either of you would have asked, ] could have explained that this was of short duration. My cocker does have an allergic skin problem and he has a strong odor. I've been taking him to the vet, but he hasn't beenbathed as much as he should, during this period. At the . present time, he has healed. My conferences were finally over and I did major cleanup work the weekend of the 18th and 19th. weekend. The house was vacuumed prior to Meg's party and as you entered to voice your displeasures, Meghan and I were in the act of a major clean-up. My house does tend to get cluttered, but this does not interfere with safety. If the house was a 'shock', it was NEVER mentioned and both families have been in and out of the, house frequently, My cellar is typical of, the old "finished" basements in this area. The stone walls are mortared" with a sandy combination that sifts down onto the edges of the floor in some areas, most notably the laundry area. It's one ofthe things I want to improve, but have not yet gotten to it. I recently gave the laundry area a good vacuuming. I had bought a rug, which I attempted to put down last weekend, but it was slightly too large. I had not yet bought a replacement. The washer and dryer, table and top of the freezer are wiped on a regular basis. Please note that] have attempted improvements. I have recognized the sidewalk with dog feces as a problem. ] have a gate partly put together in my basement to bar them from this area. I did try to keep this cleaned up daily, but I know there was some problem. The time between arriving home and picking up Ashley was filled with errands and the preparation of the evening meal. 1 sometimes didnot have the time to check the sidewalk, Or honestly forgot, in the rush to get things done .The dogs were not regular about using that area. When I returned home with Ashley and the bike, I know I had asked her several times to wait until I could clean up the walk. This involved my opening the house and walking through to the back door for a trowel and plastic bag. At no time did she wait for me to ' do this. I repeat, neither family expressed a concern over any of this prior to the 19th. If ] had been questioned.] would have replied in the manner above, and would have again asked her to wait until] had cleaned up the walk. -' ....,. On looking over the contract, I find that the only specific violation was by my daughter having males above the 1st floor one time. InegIecte,dto inforwSasQa'spll!ellts about.the problem with the doctor and the lack of shoe fitting services. These were not contractual matters. I have made it a point to try to sit down with the girls when they return honiefrom dance and' either eat with them or, in Sasha's case, have a cup of tea and talk with, her While she ate. I know. I asked several times if things were going okay. Early in their stays, Itbldbothgirls that I was not a mind-reader. They would have to tell me if there was something wrong. Earlier inthe year, I counted on Sunday to be a "down day" when I could spend a little extra time with them. Since both girls have been out of the house on weekends lately, this time has n()t been available.' '. " '4 II I .' -~ T I- , " , ! , , .,- .--;~" .-,"- .'- ,',-- -," _.;";'--~..-- - ,,',,- --. --" IqJI, ',,, UTi""';i""":,:,!,, ,- I received nothing but positive comments from both sets of parents and no indicationsJ),~;i.':'~' concern until the afternoon of Sunday, Nov. 19th. 1 felt 1 was under attack. Mrs. Jensen ' . announced as she came through the door that the girls were going to be removed from. my home immediately. Mr. and Mrs. Jensen remained standing as Mrs. Jensen delivered her tirade, even though I asked all of you to be seated. This was ail obvious psychological ploy to intimidate. I do feel that ifSasha and Ashleyhad been willing totalk with me, or if parents ha( made known their dissatisfaction, then things might have been different. I do feel that' expectations on both sides were different. J also feel that minor events were blown up out of proportion. My signature on the notes of the 19th attests to the fact that I read the document and discussed it with you both. I do not agree that this is a fair document or that I violated our contract. In fairness, I had no knowledge of your concerns, nor was not givenachance to make, e any changes. . .' In good faith, I have maintained a home for both girls. I have put effort into making a home-like atmosphere. I took Ashley and a school friend to the Renaissance Faire and encouraged her to have friends over. I spent several hours, during my conference preparation time, showing her how to build a "Jamestown" house for her social studies project. Both girls showed an interest in counted cross stitch in the fall and I provided fabric, threads, scissors and pattern books for their little projects. None of these were returned when they left my house. . During Halloween, I provided Halloween mugs and treats for the girls. Sasha regularly bOrrowed ' from our collection of VCR tapes to take next door to watch movies with her friend next door. I felt the conversation on November 19 to be an attackon m.e. Idon't believe I deserved' such an attack. I do believe that communication, or lack thereof, was at the root of the problems expressed. I also know that my few weeks of work overload contributed to the problems. At the same time, during this period, both girls were leading an active life with their parents and I did not have the opportunities I might have had tobe with the girls in a relaxed time period to discuss concerns of theirs. As we talked on the 19th, a lot was made of Sash a's "being still a baby". I do not consider a 15 year old, boarding away i[om home to be a "baby". Ido expect a teen in my home to be able to take care of basic needs herself. Some of what I was verbally accused of neglecting to right, were personal concerns of the girl. As a parent of a teenager who has been through alot emotionally, I have workedveiyhardto}:!elpherbecOlne strong, sacrificing some of my own choices in life so that this could happeif PethapifSashil" still' needs some of that sort of time, before she is ready to be on her own. I have the distinct feeling that this was carefully planned, based on Mrs. Jensen's displeasure, as Mrs. Wallace hardly said a word during the time in my living room.. AsI had said earlier, to go from being heartily praised to this kind of an attack was very disconcerting. I am ' not a person comfortable with attack. I try, in my work and in my persortallife to settle disputes by consensus. Again, without knowing anything was wrong, or being given the opportunity to change, I feel the contract was broken by you. Please see my attached letter directed to each family. 5 '1-!"'!\1fI!I\1"1mf'iT1 . , ~ I I '1' " ~ -~ ;~~11tf!W~~~J@'lf~~ "?" S\e 'fFl , ~ -~ " ,lI!fl!IillRlt ~ -'.'. ~~ - ., ,,~~ - .?,",~~~~"""l_~ . ~"_n'_"_""", ". p, -,' ,'" .,. <--, -,"""",",.-,'"~,,,'''''''"''.'' - ',' '-V--f,< "-"s ,'. ,~ ,---' Q ~.-~ "- .'~ .ir' :F1_iI!il\l~\lji~!!Jllll~~'jiJt'1W!"-"/""""-,,,p'i'n,'),~'J,,,,,-,I';'F<:" "''''1 III (") :1 ,~ ". (j .~~ '1 '1 t)') , .~ ." ()" ,'~~ t'__ <~ _o~~ ~ 'DENISE A. JENSEN vs, KATE BARR a/kJa KATHLEEN BARR NOTICE You have been sued in Court. If you wish to defend against Ihe 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 wrinen appearance personally or by an anomey and filing in writing with lhe 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 judgement 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 1H1S PAPER TO YOUR lAWYER AT ONCE. IF YOU DO NOT HAVE A lAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE 1HE OFFICE SET FOR1H BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. , . IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-2505 CIVIL TERM . CIVIL ACTION - LAW AVl!'lO l Le han demando a: osted en la corte. Si Dsted quiere defenderse de estas d~mandas expuestas en la paginas siguientes, usted tiene veinte (20) dias, de plazo el partir de la fechs de la demaJlda y la nolificacion. Hace faila asentar una comparencia escrita 0 en persona o con un abogado y enlregar a la corte en forma escrita sus defensas 0 sus objeciones a las demandas en cOntra de sus persona. Sea avisado que si usled no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 nolificacion. Ademas, la corte puede decidar a favor del demandante y requiere que osted cwnpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propieqades u olras derichos inportanles para usted. ll.EVE ESTA DEMANDA A UN ABOGADO IMMEDlATEMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFUCIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA 0 ll.AME POR 1ELEFONO A LA OFlCINA GUY A DlRECCION SE. ENCUENTRA ESCRITA ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENClA LEGAL. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 or 1-800-990-9108 ;""~"'~~~~ ~~ 11..' -q ~ '! ~ . ill DENISE A. JENSEN IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO, 01-2505 CIVIL TERM KATE BARR a/k/a KATHLEEN BARR : CIVIL ACTION - LAW COMPLAINT AND NOW this ~l\J day of May, 2001, comes Denise A. Jensen, and by her attorney, Glenn C. Vaughn, Esquire, files the following Complaint pursuant to a Rule issued on April 27, 2001, and served upon her on May 10, 2001: 1. The Plaintiff, Denise A. Jensen, is an adult individual who resides 141 West Louther Street, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant, Kate Barr a/k/a Kathleen Barr, is an adult individual who resides at 227 West Pornfret Street, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and the Defendant entered into a contract for board and room under which the Plaintiffs daughter, Sasha Edelman, a 15 year old female child would reside in the home of the Defendant while attending Carlisle Senior High School and the affiliated Central Pennsylvania Youth Ballet program, A true copy of the contract, which began on September 1, 2000, is attached hereto with an Addendum dated August 25,2000, as Exhibit "A", 4, Sasha Edelman moved into the home of the Defendant on or about September 1, 2000, and began to reside with the Defendant. 5, The contract was terminated by the Plaintiff on or about November 19, 2000, for numerous valid reasons as itemized in Exhibit "B", attached hereto. 6. The Defendant agreed in Exhibit "B" to refund the $800,00 deposit and $320.00 " -- I"'c- -," "n- , "'t.,-.1'1 prorated rent for November, 2000, and to release any further claims or actions against the Plaintiff, all as set forth in Exhibit "B", 7. Exhibit "B" constitutes a valid and binding Settlement Agreement and a novation of the contract. 8. The Defendant has, upon demand by Plaintiff, failed and refused to pay the $1,120.00 promised to the Plaintiff and owing as a result of the breach of the original contract by the Defendant and the justifiable termination thereof by the Plaintiff. WHEREFORE, the Plaintiff requests judgment in her favor and against the Defendant in the amount of$1,120.00 plus interest and costs of suit. Respectfully submitted, .~~ Glenn C, Va'Ug , squire Attorney for Plaintiff ill No, 07484 22 South Beaver Street York, PA 17401 (717) 845-9689 1-" -' ,;;,-;' "' "- 1""'1'-" " ,'" " ,~- ,~, ,,'., '-.< I' ,-I " 1 I am pleased to be able to offer two spaces in my home for students of the students of the Central Peni1sylvania Youth Ballet. Two fully furnished private rooms are available, one with a double and the other with a three-quarters bed. The students share 1 Yo, baths with my daughter and myself My location allows students easy access to the downtown area of Carlisle and is within walking distance of two libraries, the movie theatre, shopping and cultural sites. I am within 8-10 blocks of both the Middle and the High schools. My family consists ofMeghan, age 17 and a Senior at Carlisle High School, two dogs: Puma and Russell, and a parakeet named Marquee. My son Matthew does not live with us, but visits regularly. We have moved to Carlisle a little over a year ago. I am busy restoring our yard and adding bits of paint, paper and fixtures to the downstairs of our 100 year old home. Meg and I enjoy reading and movies. We have quite a library of videos. We also camp and are trying to spend more time in our kyaks. Meghan is active in our church, writes poetry and works at a local restraurant. I sing in our church choir, am an active needlework stitcher and e~oy participating in Canoe Club activities. I have had a great deal of experience working with young people. I am presently a second grade teacher, but have also worked to the middle and high school levels. For the last two years, I provided foster care for the private agency, Mentor. In a previous career, as a Home Economist for Pennsylvania State University, I worked closely with the teens in the 4-H program. I very much enjoy young people. I also have a strong background in nutrition, and experience in creating "special needs" diet patterns. I expect students in my home to be part of the family. I will try to supply support and guidance for your daughter and to make her feel at home here. ~~ 5 .J-. ~~, - VvVJ, r Ct-,~. . ' -=r. cA .uvv-.;Ul ~'ro- ,. !./. (JL.UJ<D-'{ ", c1I.. .J c,,- c0 ~ ~\ vv\;-u- eX.\-\\B \T 1\ ~ " "'~j;J.., __~ ,_ ~.- Ii" I ' " - CONTRACT FOR BOARD AND ROOM SCHOOL YEAR 20_ TO 20_ This is an agreement between Kathleen Barr and benise-- J-e.YlseYl the parentis of SCb5h~ t:.delma Yl to provide a private room, board, transportation, and supervision for the school year, beginning September 9t. and ending R.;ODO June.3il,200t? 1'\ J h e.v-se.l f- By signing this agreement, .uenise- 'tn&:1'l islare commirting ffiemselves financially to a total of $8,000 for the above time period. * $1600 First payment upon reserving the room, which includes: *$800 September's rent, *$800 Deposit for the following purposes: *for damage to structure, furnishings, and appliances, caused by the srudent beyond the normal "wear and tear" of occupation. Parents are to be notified when such damage comes to my attention. Receipts for repair or replacement will be provided and funds deducted. The parent/swill be responsible for any and all excess costs necessary to effect repair or replacement. *an emergency reserve for unplanned or emergency expenses of the srudent. *Late payment fee. Please see below. *The parentis will be notified if funds from the deposit are used. Receipts will be provided for each expense. All unused funds will be returned when the srudent leaves this household, after an inventory and inspection of the srudent's room is performed. If repair andlor replacement of items is in process, the balance of the unused fUnds will be returned within 30 days. *Monthly payments of $800 are due by the first of each month (unless otherwise arranged): October, November, December, January, February, March, April, May and June. Since I depend on these fees to help pay food, transpottation, service and energy costs, it is necessary that they be on time. A 5% fee of $40 will be charged if the monthly payment is late without a five day notification, usually the 25th day of the previous month. This will be deducted from the deposit and the parentis notified by phone and receipt. '1::'WiN;_~4 _ I ~ ,- ., l'r.I' Please note, 1 am committing a portion of my home and my rime and energy toward the support of your daughter for the term of this contract. 1 expect your commitment of the $8,000 fee for the same time. If l'''"r ..1ought€t l@il'fes the Ceflti'M Penm.. Y ot:lth BJ:l.d tdf ~nl' rpo<gB, all remaining mon"t>o' rn"m on.;! board FfI\iIst be raid .J.t thc-time-shei:eaves...A \phmrl i~ fgs:;~Ll" vuly if aflem& SWd€nt 9' "hI" or!'",,1 w,,"1c1 pn"pr my neme-as-rloarder-o Jhp rphm..1 ",,,,,1.1 1.: for the time pllriod that new sttldpn" would be l;"ing at my resiuCflce. Jf "h€ balaRce iJ Ret paid at the time Y'r,r r1011ghrpr might premalxudy I"",,,, be.n'to "- -.J ~"f.S~" would "Lo be r€l:p9,,~ibl€ for any ccLHt/lawyer =pelI>it::> ULCCSSary--fer .K.athl,-ul D~... LB F@<:"........-.-7P-F ....hp t"P.","lI;....:~g "bElhl't . "', OBLIGA TlONS OF KATHLEEN BARR Meals and Nutritional Guidance: As a trained Home Economist recognizing the nutrirional needs of a teen in a very demanding physical training program, I will endeavor to provide an appropriate meal pattern and diet for your child. This will include consultation, monitoring, adjusting and advising. It is understood that there may be conflict between the demands if tbe program for a minimum standard of weight and the needs of the student's body for optimum nutrition. If an adequate diet pattern is not followed, injuries will. The conflict may also lead to eating disorders. Concerns in this regard will immediately be taken up the student and parents. Healthy, well-balanced meals/snacks will be served with consideration to food likes/dislikes. If a meal is not acceptable to the student, she may nse leftovers from a previous meal, or make herself an alternative (with my ok) from food in the freezer or pantry. Breakfast will be "make-your-own" from a variety of accessible choices .I expect boarders to be up early enough to eat a reasonable breakfast. Lunches may be carried to school in a thermal container I will provide. These are to be made by the student on the previous night. Alternatively, the student may chose to buy her lunch at school, in which case I will provide $2.00 a day. DiooeTs will be provided according to the student's schedule. This will be a hot meal available at the dance school to be wanned up, or upon the student's return home after her last class. Transoortation: The Carlisle Community of schools expect the majority of students to walk. My home is within 8-10 blocks of both Lamberton Middle School and Carlisle High School. Moming transportation can be provided if the student can be independently prompt, as I must also meet a schedule in the morning. The dance barn and warehonse are within walking distance of Carlisle High School and bnsing is available from Lamberton Middle School. Transportation will be provided to return home from dance classes. Transportation to and from practices and special events is provided within the greateroCarlisle/Harrisburg areas. This includes transportation to the Harrisburg International Airport or to the Harrisburg Train/Bus Station. Transportation outside a 35 mile radius of Carlisle will be charged at $.25 a mile. Day trips to Philadelphia, Baltimore and Washington D.C. and environs are acceptable. I do not travel to N.Y.C. or to Pittsburgh. Train and bus service is available from Harrisburg for these cities, <~~ - , ~ I I'. "- " Communication: Students entering CPYB are embarking on a strenuous and taxing stage of their hves, not only physIcally, but academically and personally. It is my job to help the student meet these new challenges in a supportive family setting. I will support and counsel each student as needed and provi~e a regular family council time to help the student integrate as easily as poSSIble W1thi.n this .new hfe, away from her family. Your child will be welcomed as a complete member of this famtly. I respect each student as an individual, and I require from each student a respect of self, of other students living here, and of myself and my family. I expect to be in contact with parents on a regular basis, especially in the beginning of the year and to express and concerns to parents and student. E-Mail is available. The student may choose to have a private line established in her own room at her own expense. The downstairs phones are available for use with a calling card. . Housekeeping: Bedspread, blankets, sheets and towels are provided. Sheets and towels are laundered weekly; blankets and bedspreads as necessary. Nails, screws or other such fIxtures may not be added to walls or doors, nor moved without my permission and supervision. A bulletin board, laundry hamper and mirror, and wastebasket are provided in each room. There is access to a vacuum, mop and dusting tools. All trash is to be placed in appropriate receptacles by Thursday night. Laundry facilities are in the basement and include washer, dryer, iro",ng board and drying rack or clothes line. The student must provide her own iron and flat-rack drying . system. Space for bicycle storage is available. It is strongly suggested that bikes have a strong lock and it is imperative that a helmet is worn. STUDENT OBLIGATIONS *The student will respect herself, other girls in the household and Kate. Our dogs, Puma and Russell B. are to be treated kindly. *The student may not drink, smoke, or take other than prescribed prescription drugs. *It is the student's responsibility to keep her room in order by vacuuming and dusting weekly. Equipment and supplies are provided. *There are to be no candles, incense, matches or lighters in the student's room. *Guests of the opposite sex may be entertained only in the first floor common rooms. *Carlisle has a curfew policy, requiring all students under the age of 18 to be home by 11 pm. When the student is out of the house other than at dance classes or activities, I expect to know where the student expects to be and the approximate time when she will return. For a student to attend a party or activity at any home, I must be provided with a home address and the phone number of the parents hosting.( I will contact these prior to the party or activity, to be sure there will be active supervision and a no alcohol/drug policy in effect.) ~"'~ . ~- , - - *The student is expected to pick up after herself in the common areas of the home: returning personal items to her room, placing recyclable items in appropriate containers, returning food containers to the refrigerator and placing used dishes in the appropriate containers. *Wet clothing must not be left on floors or furniture. *Lights and other electrical appliances are to be turned off when the student is leaving an area. This is especially important when the student is the last person to leave the room/house. *The student is to be provided with her own spending allowance and to purchase her own personal supplies, including laundry detergent. *The student will be responsible for her personal laundry. She will be assigned a scheduled personal laundry day after a family council discussion. Non-assigned days will be available on a first-come, first-serve basis. *Each evening the student is responsible to make her own lunch or to notifY Kate that she will need money to buy a lunch the following day. *The student is responsible for wakening independently and for leaving the house in a timely manner in the mornings. *The student is responsible for common kitchen tasks: + emptying and cleaning her thermal lunch container and returning the cooler packs to the freezer. + keeping soiled dishes and glasses off the counter-tops and out of the sink area. + refill ice cube trays and water filter pitcher as they are used. + wash and refill a juice pitcher when the last serving has been used. Kathleen Barr, Sa..shw Ed.ell\\o~student)and 1)PY1ISe- Jensen (parentis) agree to abide by the above contract. Signed~ L(3a.>J\../ Date: D...ud-' Q)1, QCCO Date: '''~.'''''''f'l'~ , , , . JJ j) De/ncl /iIVVl 8/~1C7D The fOzm o( +1Jrs CfJfJhl/c + !}nd :p1,lt2pose FoR S NAil ~de/YYltLn. r<.esirli,o- 111 (11J/'<. hs/e.. )'.s .(/I2S+) Jo, /l-U0MJ.. CARlisle. :Pab/J'c.. H1ah ~ko / As A (ull f-Ime :3+ucl8nf) secgJIfJJ -/-0 +leAJYt ()JI-I-h C0nf;e,41 Pf.j jtJufJ, :BA lief . 1. e'f.-ppc+ ~ft.l.Afl +0 C.tJfI1plefe- +he .full .:;.cACJ() / ,fet<.rn J 41 eM lis/e. l-I'Bh ~//{)o I find RerwllJ'n /flyo{j~ hOMe dURJllfr ..J-h.4f ..J-iJ1le. Howeuete) (( S/i~hA WOtlld he L/J1C()fYI(b;QffJl.Jk..; d/{e +0 J1;2e5s.(ul f?ellff/on.dJps to/lAin YO(j!! home.- ) :r r?eS'eR.rJe. +Ae RIgA+ +0 C;4Y1ce / fh/s ~/dj{J;4c--f t']-J1c1 bRjn0 ~1J~,{4 home. If rJ11J1</~ft- fAe feie m Df fAts C~)1'fl2.Acf) ~fi6.AA /JJ(}(j lei Ie-live C6n fJ2,4! fiJ \)eJUII1 BAile! -(tJ;2 !2eIfS()n df 1~'tll!f) I //ness) 0 Rj(jJf i1~fj t()/fJ1-f/t1fJ fo Cf)/)h~l.(e- hit/lei +f.4ihl/J1- .bu.f- wou!e/ s.f//rbe fjple. +0 IJ-f/f/nd CftR-/iiJle, ) HI~h JcAd& /)1111'5 ~/J-he/tc.i IJJtJC1/J f20YY11t//l ill e~.red) fo fhe 0nd (}-F +!ie &cAtJiJIJeIfR. . :Lh fAe eU0vt+ iJf $e;<HJ/AS I'//nessj I!7JCl~ (}!( CIJ7AS fRopi e 1/) ~fJ~AfI's /ife. :1: Re.seJetJe .fie ~~A";- +0 b/C/~ ~AJAt:j hOlYie ~of CAYlcel HlI:S LJJ/11/2f1Cj.. CjJ~J~~ .:1~~~ // \~~. ~'f'''''"' -~ - -, 1'1'" r" " - "'" MI/em~ JIll ~ @ fou ,ICed /o.fiNO A fJlil'I21AN 1M 511ShA /'M t:/I,e/Is/e SCAn I .l'X/IYn. :t tVAs 10/./ 1-t.t.JJce I /N 5ef"'~'tJP~1 Y"l/. t(}Me I.4KI, {!/I,fe of 1/. r /I S5tt/J1eL /1 hAJJ k/1 h-JA'en C/9Jfe "f". o/P/l /71'1 k/lLlfl'llo lie 'MeAl :f A5Ke,! ,)/iSJA /I" s1",;/ -?1It1 ~elC f~S,i:tl/- s4e 1;'/OA'hlJ /fIe J1(j. () oS/lSht/ ,~fo/(/}Jt''/ /1Je. ,tk. JOt/oS€. /s s,? t!o!L alAen .:;:,/~ Cd,me s kme ;;t""1 scAoo/ s/e JZ/M;!:f ,de;!: C'tI/l1 AJI! ;/tJOl'S . vie",.z m/f'J j~.<. d ,fe/f' &~,.,., /; IVMm A/ /1tj,{.f/ sie //JfQ,fm".{ me. .$/e ske,r;s /~ /11uI10k. //o/MS I1r cIoIA{}$ /I;1d J - <I j /;fInK,,!s" .I A.s.lrELJ it}/( wke lie je/fl ~ch 1/1 Ae--e tfdtJm ,VUe he;i1t'd. eJle ~1tI me ~/e hM€..tJ / EtJBYJ q/J,h/f lie /#,(/1/16'/'<:::'1 /;1(1 C4t/V fliJ! lIalle... I 1,,/,/ .s>U.hA 10 Ie/I JP&t. .sk /.tills c,ld/ Yt?u Id:l };t!.~ fo / I?Ailfl .he~ ~"'A' re.n AI /ljl;-. 5/J,fk WlJs CMC M//".,( A~tf/(..f fie oI~.$ CNI}li Iii le,< /""/11 - 1161 #U k-e 'yoa:d .1'ery #&111 tht<//l.sid?s - A&W8J~ Me httse},1U 4Nse /WJ) Nt! /,f/I//lc'1/ /O/j-i fle~M~ /J1A)'~ s /ii/Ii, h .$1e"'fJ o/JllIcu/l. Y~tI j/lV{! cJ/itCe./tf(jC//~.,( .M",IA WI/;' 1I,s/11A// e.lt'c.!l!Jc. jelllve.. ,)e(!At/$~ He {!/;$R-/ /s /1,1 I /~aH4/.ea!, AeJf c/t;~/jj /$ (',1/J //7 !Ie. AttM/I/'l" r!)) jllJ.I/J Ih1d Ilslle'1 tJ}#-lCe /Mm/lJ,d III "s/~ l,me. r..<tJm ';:cha 111 /1 MidA1' jJ;iJVmOe.< /<} ~ / /;et!lJR~e //!f /tiMe !tltt''/' lie IOM~ lJeOtte /iJIdJfm&1 If Mis . @ j.4&)A ~flS /Jet/M /Jt"$~""/ -1 /Oct:elC /lISdp/ (i~ !Ie J'er/11J #-r PM/r'$. r/-,/t,e to/Jllu Cdld. ,$Je 1IItA.-U /J l~jltf}€&jl../lJc/c'el rid WAlk 10 sckg//J) - T,fe v./t.4lJeA'. is: CdU /J/I,/ 10/11 h cfel.//:f tIle/tIC 1111//(/11 je.fi. it4tJ1 C41/Ibe kJllIIl/. }q/-kJ//l /JiJ ~c,.eeif;de, tl)V't/1d hive .,f C9A"~ fa&II-1/1/) bAt;. :I cAIN/' /J1iC. ;l/~r~fJ 1Ct/(/A/Jc.e CiilJJat!k/C'..j &/V F,(/#lfl fe: Me /<1~ s.;'!ttn!/'jI1. ..:. <:fJ. ~ l- e[) ::E ill --~ ~'1?". . '/ I" "' 11" .~ o=m, ""':"- fie ASSURer- me fiis ff.?pJhm tOOl(!cI Je 1f}j:'fh1 t?/1!fe of 0.# /Yl1N()fl.t;) II /~ /tlO . @ '1/./ Je;;IU1tJM I .bplA .5,uAA mr1 :t: I ~eol ,.9.9tl(/l-, ytlu. 1111r'/~ .,)MAr'l .(O;e she '{/f.li~. 1J;'$ /Jel/<<(J~tl/Ue/. Hf!Ie JAlk-! oS 1j1/ees tfl/~ j"IeS J9,!# )e/2 jJfJkfsl,es /f~e ~A/ !l.s je~ .(;,;/ );/1,$ j(tt!e"/~ !~tlJn / die /K~.L... & k..r;:; -k.e ,slr;es/ ,(/'w. (J) .2f15hji /hId j}J/~ 1~~.I?IJ)eI.. tf~ A /9 YR ~ 1tI1J1/f1e. I /in IJp",4/n!,f11ce. tJ.f iJJer-n $, 1of/5 fM/I1/II...I1" SleefllJvu: M Me $~. /tie ~ Adl Jl;.pw tpld //;'$ ~d/JU / Otll.(41't1 Afhr~c.A! rI~t/flpr, FLdrn l~eJ;'ds - II F~e,41"- JQ/lh hZZif I~~s !IN/) Ii Pdpe IA~,,/' .fhe. JR/,e. tlf lis j}()>e J f,RP/Yl daf If' f()f.()1) . (j) ::1#,.eel. Ii) IAe Cdnf.tl/c..f - Rt! ,$f<<oIe.,f t?Jh)ItIIbI1S - !lllesk ttF He ~~rl.:' se;c rYIA-1j be &nfet€IAI"pj tfII~ /~ fie .(;itsl f'loo,.e ('.?A/11IM flJtJnlS . SlJsAA- /iJfiJi!_me/ I/.S I llfOn he!? A'e-k;/ln /;lIe tiNe II/f'f .{R(l/>1 17tJn' Pelfse ts /;ot)!'e, Sje /)leI- fl/2rYl find Md (j/Je;e tnA/es in Me ;I'!!i f1po~ AA/I<<I~J COft/1d cMwn fRPm ;JJffAnS 3 ~ ..(ldOtf /;MJ't1om / (j);tf/e IJJ'/Jbus /.4c,.e I7F jOtlJ'ecIeMI1- !/rom (laIC M tI/~i-f ttJ/Js. /J .sAoClr:. j)/~4r ~iRrlcA;eJ d1'.Fe.aes 1/'1 lite. ~JlcK,/A,RoI,4/id f.iclew A I K.) I h~/rJe #~JI!-k I elttll-vt 1M et/Utt j die / Houe../ / it W~j(I)&ff/. ~ddJ( .f.R~;rtlje ohdsJ !;/}//C ev~u;d-e;e~- hl:l~l11/ j(d~. J)M!j !;/Js81t1&nf aleee l1e 1.4t;/1/4j IAc,lthe". ~I? , "''''~ . ~ ~-' '-1-1-' '1 - tolJA t'lA-.RtJ IQ fAe /f t9Me.. - lie CIJN'I;eAd- I.1s ke.~ btOlr'EN dy ,/dt<, j(8T~ .8/UfC. lI.;.i /&j fJ/oItJ 5AsJA will &,. /I1IJo/i>j (j~.f ")'IiI, All dr Ijelie. flRat71),t: klo"'!/l1$ I AltJ/l61n.be,.e: fiJ/~ /. w/1It Ydt/.I? . Gt/M~'I RJglf.s fo? Ib-hh; II/'?/hce 1J1// $h;iA Etk.//J11/n 1e.R17l,nA-J;l' fJ !,Je.fClJlri {/f "' J.>>.~ f4.R -Me ..ee.mA/iJI1J 2 D/h; S /If/ /l!toWP& I f}/I" IAe- J tdtJ ~ d'9';,.(/I/ ,q hili I of .!J ~ JJ.tJ,~Il~;'s. EXf-releoL trJlf,{/n .3~oIA-tts H.1/Y'> lool~, NtJrJ&mia_ /CjI;1/~ 1 ,M/l> 10 hANe/NE /(JAIIAce - j)6}/;Se J€/VsW-:-- :r~ .JAfS.CfiNNOf be. /llIa~It/11. IJg~ee"- tI/dN/ Il kf,,4/ c41fln t()/I! !Je f, JilL IJg/iINsf you... /N bId/? le-l ClIi f . I+ hAS been n--",h",,)'1 AJtzeecL +Ae CoN+P.P.c:.+ -Hi'< fC6Y7\.J- bbl'rR\) A-r- ),)./ CUe,+ ~Oln'\f"lre:!" 05+. CAR h'sle. /A. be+we€(1 K~~t" J3Arr- ~1IT) ))0\'\Ise Jensey.. is UOI\:l-FRo....... ^IDVe<mbe~l~,;l<1co. ;J c> -FuRTher- dAj'''''5 o~ AdioY> 0,"0 be PlA'De FRDm ed-hf}R.. p/rR.~. ~..~ ;ftlifud~ f~UU( vi v(L, 13t1 ttKiM WaJ t a,{L -:' ^ ,-~q ~-I '" "'~" ,. .--' II VERIFICATION I, Denise A. Jensen, hereby verify that all of the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C,S. Section 4904 relating to unsworn falsification to authorities. Date: f;!aC),)O( ',<'- > ,-, <1"_ 'h~' ~'" - ''<~ ~"~"_'" , -,' n-'H, .". ",_ _''''~i",', _..,",~,,~, "'_', ,~_' n.'" FRANCINE BRAXTON WALLACE IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs, : NO. 01-2505 CIVIL TERM KATE BARR a/k/a KATHLEEN BARR : CIVIL ACTION - LAW NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an 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 TIllS 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. A VISO Le han demando a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en la paginas siguientes, usted tiene veinte (20) dias, de plazo el partir de la fecha de la demanda y la notificacion, Race faita asentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de sus persona, Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion, Ademas, la corte puede decidar a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. U sted puede perder dinero o sus propiedades u ostras derichos inportantes para usted, LLEVE ESTA DEMAND A A UN ABOGADO IMMEDIATEMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFUCIENTE DE P AGAR TAL SER VICIO, VA Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL, Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 or 1-800-990-9108 " FRANCINE BRAXTON WALLACE : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 01-2505 CIVIL TERM KATE BARR a/k/a KATHLEEN BARR : CIVIL ACTION - LAW COMPLAINT AND NOW this ~ day of May, 2001, comes Francine Braxton Wallace, and by her attorney, Glenn C, Vaughn, Esquire, files the following Complaint pursuant to a Rule issued on April 27,2001, and served upon her on May 23,2001: I. The Plaintiff, Francine Braxton Wallace, is an adult individual who resides at 1100 Lafayette Road, Wayne, Montgomery County, Pennsylvania 19087. 2. The Defendant, Kate Barr a/k/a Kathleen Barr, is an adult individual who resides at 227 West Pomfret Street, Carlisle, Cumberland County, Pennsylvania, 3, The Plaintiff and the Defendant entered into a contract for board and room under which the Plaintiff s daughter, Ashley Wallace, a 14 year old female child would reside in the home of the Defendant while attending Lamberton Middle School and the affiliated Central Pennsylvania Youth Ballet program. A true copy of the contract, which began on September 1, 2000, is attached hereto as Exhibit "A". 4, Ashley Wallace moved into the home of the Defendant on or about September I, 2000, and began to reside with the Defendant. 5. The contract was terminated by the Plaintiff on or about November 19, 2000, for numerous valid reasons as itemized in Exhibit "B", attached hereto, 6. The Defendant agreed in Exhibit "B" to refund the $800.00 deposit and $320,00 """"!!'I""'" '. , ".__-_~i" --", 1""1- _ ,0 , ,,,".7_ -'I" _, 'P_' "' prorated rent for November, 2000, and to release any further claims or actions against the Plaintiff, all as set forth in Exhibit "B". 7, Exhibit "B" constitutes a valid and binding Settlement Agreement and a novation of the contract. 8, The Defendant has, upon demand by Plaintiff, failed and refused to pay the $1,120.00 promised to the Plaintiff and owing as a result of the breach of the original contract by the Defendant and the justifiable termination thereof by the Plaintiff. WHEREFORE, the Plaintiff requests judgment in her favor and against the Defendant in the amount of $1,120.00 plus interest and costs of suit. Respectfully submitted, /' G enn C. V ,squire Attorney for PI . tiff ill No. 07484 22 South Beaver Street York, PA 17401 (717) 845-9689 "",~-. " . """ i ,_ ,~ ~,-" -., -co , 1""'1- -----1-" '---j,.'_1 ' ,-~,' CONTRACT FOR BOARD AND ROOM SCHOOL YEAR 20_ TO 20_ This is an agreement between Kathleen Barr and e / f) 6 Q () cI .JO h 11 1AJa/ fa c c:... the parenti s of Ash 1 f~ to provide a private room, board, transportation, and supervision for the school year, beginning September CO and ending June~ 20W By signing this agreement, C" ne., and John IAlailadS! are committing themsdves financially to a total of $8,000 for the above time period. * $1600 First payment upon reserving the room, which indudes: *$800 September's rent, *$800 Deposit for the following purposes: *for damage to structure, furnishings, and appliances, caused by the student beyond the normal "wear and tear" of occupation. Parents are to be notified when such damage comes to my attention. Receipts for repair or replacement will be provided and funds deducted. The parent/swill be responsible for any and all excess costs necessary to effect repair or replacement. *an emergency reserve for unplanned or emergency expenses of the student. *Late payment fee. Please see bdow. *The parent/swill be notified if funds from the deposit are used. Receipts will be provided for each expense. All unused funds will be returned when the student leaves this household, after an inventory and inspection of the student's room is performed. If repair and/or replacement of items is in process, the balance of the unused funds will be returned within 30 days. *Monthly payments of $800 are due by the first of each month (unless otherwise arranged): October, November, December, January, Febtuary, March, April, May and June. Since I depend on these fees to hdp pay food, transportation, service and energy costs, it is necessary that they be on time. A 5% fee of $40 will be charged if the monthly payment is late without a five day notification, usually the 25th day of the previous month. This will be deducted from the deposit and the parenti s notihed by phone and receipt. EXHIBIT "A" :~-I I-I' '" - Please note, I am committing a portion of my home and my time and energy toward the support of your daughter for the term of this contract. I expect your commitment of the $8,000 fee for the same time. If your daughter leaves the Central Penna. Youth Ballet for any reason, all remaining months' room and board must be paid at the time she leaves. A refimd is possible only if another student of the school would enter my home as a boarder. The refimd would be for the time period that new student would be living at cr; residence. 1~e balance if not paid at the time your daughter might prematurely leave, nt", a nc/ n ~Ct llQC.e... would also be responsible for any court/lawyer expenses necessary for Kathleen Barr to recover the remaining balance. OBLIGA nONS OF KATHLEEN BARR Meals and Nutritional Guidance: As a trained Home Economist recognizing the nutritional needs of a teen in a very demanding physical training program, I will endeavor to provide an appropriate meal pattern and diet for your child. This will include consultation, monitoring, adjusting and advising. It is understood that there may be conflict between the demands tj' the program for a minimum standard of weight and the needs of the student's body for optimum nutrition. If an adequate diet pattern is not followed, injuries will. The conflict may also lead to eating disorders. Concerns in this regard will immediately be taken up the student and parents. Healthy, well-balanced meals/snacks will be served with consideration to food likes/dislikes. If a meal is not acceptable to the student, she may use leftovers from a previous meal, or make herself an alternative (with my ok) from food in the freezer or pantry. Breakfast will be "make-your-own" from a variety of accessible choices .I expect boarders to be up early enough to eat a reasonable breakfast. Lunches may be carried to school in a thermal container I will provide. These are to be made by the student on the previous night. Alternatively, the student may chose to buy her lunch at school, in which case I will provide $2.00 a day. Dinners wilt be provided according to the student's schedule. This will be a hot meal available at the dance school to be warmed up, or upon the student's return home after her last class. Transportation: The Carlisle Community of schools expect the majority of students to walk. My home is within 8-10 blocks of both Lamberton Middle School and Carlisle High School. Morning transportation can be provided if the student can be independently prompt, as I must also meet a schedule in the morning. The dance barn and warehouse are within walking distance of Carlisle High School and busing is available from Lamberton Middle School. Transportation will be provided to return home from dance classes. Transportation to and from practices and special events is provided within the greater CarlislelHarrisburg areas. This inclUdes transportation to the Harrisburg International Airport or to the Harrisburg TrainlBus Station. Transportation outside a 35 mile radius of Carlisle will be charged at $.25 a mile. Day trips to Philadelphia, Baltimore and Washington D.C. and environs are acceptable, I do not travel to N. Y. C. or to Pittsburgh. Train and bus service is available from Harrisburg for these cities. ';;~-~ 1-' --1'1'1'1' -1 -1 , . . Communication: Students entering CPYB are embarking on a strenuous and taxing stage of their lives, not only physically, but academically and personally. It is my job to help the student meet these new challenges in a supportive family setting. I will support and counsel each student as needed and provide a regular family council time to help the student integrate as easily as possible within this new life, away from her family. Your child will be welcomed as a complete member of this family. I respect each student as an individual, and I require from each student a respect of self, of other students living here, and of myself and my family. I expect to be in contact with parents on a regular basis, especially in the beginning of the year and to express and concerns to parents and student. E-Mail is available. The student may choose to have a private line established in her own room at her own expense. The downstairs phones are available for use with a calling card. Housekeeping: Bedspread, blankets, sheets and towels are provided. Sheets and towels are laundered weekly; blankets and bedspreads as necessary. Nails, screws or other such fixtures may not be added to walls or doors, nor moved without my permission and supervision. A bulletin board, laundry hamper and mirror, and wastebasket are provided in each room. There is access to a vacuwu, mop and dusting tools. All trash is to be placed in appropriate receptacles by Thursday night. Laundry facilities are in the basement and include washer, dryer, ironing board and drying rack or clothes line. The student must provide her own iron and flat-rack drying system. Space for bicycle storage is available. It is strongly suggested that bikes have a strong lock and it is imperative that a helmet is worn. STUDENT OBLIGATIONS *The student will respect herself, other girls in the household and Kate. Our dogs, Puma and Russell B. are to be treated kindly. *The student may not drink, smoke, or take other than prescribed prescription drugs. *It is the student's responsibility to keep her room in order by vacuuming and dusting weekly. Equipment and supplies are provided. *There are to be no candles, incense, matches or lighters in the student's room. *Guests of the opposite sex may be entertained only in the first floor common rooms. *Carlisle has a curfew policy, requiring all students under the age of 18 to be home by 11 pm. When the student is out of the house other than at dance classes or activities, I expect to know where the student expects to be and the approximate time when she will retwu. For a student to attend a party or activity at any home, I must be provided with a home address and the phone nwuber of the parents hosting.( I will contact these prior to the party or activity, to be sure there will be active supervision and a no alcohol/drug policy in effect.) ";C"~, ,~, __~" eN ,", ,'1"1 t" t.,.-. ,] *The student is expected to pick up after herself in the conunon areas of the home: returning personal items to her room, placing recyclable items in appropriate containers, returning food containers to the refrigerator and placing used dishes in the appropriate containers. *Wet clothing must not be left on floors or furniture. *Lights and other electrical appliances are to be turned off when the student is leaving an area. This is especially important when the student is the last person to leave the room/house. *The student is to be provided with her own spending allowance and to purchase her own personal supplies, including laundry detergent. *The student will be responsible for her personal laundry. She will be assigned a scheduled personal laundry day after a family council discussion. Non-assigned days will be available on a first-come, first-serve basis. *Each evening the student is responsible to make her own lunch or to notify Kate that she will need money to buy a lunch the following day. *The student is responsible for wakening independently and for leaving the house in a timely marmer in the mornings. *The student is responsible for conunon kitchen tasks: + emptying and cleaning her thermal lunch container and returning the cooler packs to the freezer. + keeping soiled dishes and glasses off the counter-tops and out of the sink area. + refill ice cube trays and water filter pitcher as they are used. + wash and refill a juice pitcher when the last serving has been used. Kathleen Barr, AshleLj WnJlace.. Signed ~h.i..~ c{jd/j /').../' 'If f.Wa1l~ (student) and Cl~~ and Jdh VI (parentis) agree to abide by the above contract. Date: ~. 30 I J-HHJ Witnessed Date: I.-I ~ -~ r, 1_ - Mv~ /q/~ (!) (()u a; /fed fo .fiND /i ?iys/cIA,IIItd/f 5/1.,;/"'7 fo~ t:A,r/is/e S~,jN / ,EX/fm . :t lUllS lo/.,{ ftO/ce IIN Se;:>'~'>1P.ve, y"'(. <<.JeJ(e 1,411'1, C'IUe of" 1/ . I/lsSu/J1eoL /1 !JAIJ a.en .fAt'en CI9/te ,-F. U;wll 171'{ k/lLtf/J td -I.Ie t:1fi'eA, ::r /I$Ketl j,q"AA ;r .she;! Aile! Ae"e IAr.5II:t:l./ - S-1e /A.fblfmJ lite no. (}J SAsAII t~fo~/)Jt'j 11)e. Ik )()f/s,;? /.5 St1 c!dd ,;oAe/l .s:A<. {'d/Hes Jo/J1e P"/11 scA",,/ sf., IZId/ltl!5" )e,e C'dlll/l17/;lorJ"s. tV/ell ,ZA,$/{'Jie,e.tf le,e &,,"'" I~ vMm Illl1tj,{l/ sle. t!JlO~m,./ /lJe. S,(e .s~;os /n ftJu//~k l/ltte,es pr clolAes .~Md J. </ J/,qnK"fs. .:I /If/r'ELJ ,fe,< whe fie ./eA-ldrc/s I;' Jete f(()ti/lJ ttJ.e;(~ ~MI{'c1. .J/e!"U me .sle !&dKE..t> / EtJfh1 tlhoktf fie /'<<tf/fII4'tf'e.1 hl(l CduY I/lJdIlOIle-. I fold S4S.J04 10 Ie/I ftltt .;,f WI/S CdU/ yu( Id/L !id fp I &Av'e /Je"e ~M d/bn AI/lj,ff- ' $/),,1+ Wits t'Me t'/f/ll"~ 1l6tf-r.f lie ctb!.$ eM}'; Iii 1&,,( 1'#t7/11 - yta !dl/ft( 'yt/u;d ,.fer 11&11-1 ~t'I//I.su/t?s ~ A~ttJetjM Me )iJ(.I~ddd 4Nse /WL> Nil ///I/IIC,;/ I(f/~h lIet:hM~ 111~J'I'S 1/;/1/1 IP de"fJ o/;(l/cl//l. Yt1u Jllv.e ,s//tce/tftJcJ//e'/ St?.,;;t, 10//;' ;l.~/rIA// ded,elc JeMuc.. )eeAtl$~ He ~~$d /5 /lol/;;.su.4l-t>oS Ae;e e.101l1/1f /$ ('()Id 1/1 lie /IIM/II'i' (} jl/ai~ &d !l$/le'1 tLJiICe ;M/lJ/#d 1/7 .$J~ ),me r,(om cf.ch,,/ If /1 (/(idA1/ j};tJPAnOeA:. /I'J ~ / IJetJllIIJ.e IIty /tiMe ~J?(lJ dJg iCJU~ JJftJlIf. /iJid..emE'd rJf' M/s . @ J.4~)A W/lS /JetlM ;J~$jl/RcI -1 IOc.ee/C Alsch.? / {i~ !Ie ~o//J,(/-I" P.1M$. .; Ju to/JlI-e..e CtJ,d. .$/e tt/I.4tfs.4 /;jiIM[jJf.../llc/c'e.I:!d WAif 1.1 .sck4/1') . T,fe (()Mlit'/e. is: Cd,6/ /1/101 w/II h cfel//1f C,U-t/C t;ttl//(/1j Je.1!. ie4tJ1 C.1;flbe kJMI1. JII-hJI'rf10iJ !t1c):'er;.Me. l1Jt1u/d h/r;e & CM".ey I~(!MI /9// ~At;. .7 C'AI/e/ /}j,e. ;J/~r~'s 9CililAJ1~e (!#fI/J~eJ;IC/ &Jlt F.R/dAlf/ fe: lie -0C}f:'€.A" s.;!tt,q(ltfh. '" LYl t: (t) ~ ill o,~ !~~~ "1~1 r ' /;e f)55C1RO /lJe flis l/?pJIern tOtJf/U ie 1,9J:'Bn {lAA?e tiF CI.# /Yl1N{)fi.f.J/ 1/ /.:Jd /~O . @ Xfi/ Jo/lunkc. I b~.JA 3t%A,<} IJrri :z; I f.J$J<'eol /?~dul / )'e9Col 1f)j(/~ J~Arl .(o;e ..slue +/Ni";i' 7:1/s /Jet/<<' . tNCMRe/. fit!;€' IA/Id ~/1/~~ tfll/lf! A,les 11'/# jetejJtJ/tJf$./,~s ~eth,4/. fb Je/-Go! hils /(tt~/? !.t'tiuJ" J die ,*.('4 ~ k-C:f .,t;.e $~e..s/ .P~uJ. (J) .f~A;I Ihd IlJIet; /4.ft,ft'I)}fJ.l tf~ Il fCj Y/f ~ It! /11AIe.. I An II }MlillA-11ce.. ,,; /ilegAn 's, fof/$. IM/I1/lletI It, .skefl"tl~ 1'/1 Me ~~. ft/e ~ //41 /ft.pw!plp 11t's ~"/Ji.s I i(d .(4;/11 Alhr~6A/ t/{JX-etjl/PI1 FLdrn j,feJ/.ds - .4 F",.ee,4~ /(//111 hZ4f tI~k.<:5 flNb II 6"pe. fA~,/' IJe. j,(11e. tI'f lis 1iIl>e, J ANn tJl1f p-( ftJe()f; . rJJ ;J,v.fef. 10 -Me t:.1J'Jf.tl/c-f - l't! Slt/oIeA/lllhj414'1s -gilds ,11" -#e ~fl"5/I\! .>ey: mA-lJ be erl'k~,-IA/jI~ Mitt J;' fie .(;it.sl 1"100;( ('III/AIM fMnJS . .5//.sA-4 }~f#.efYJe/ tiS I lifon h-el!!. t?e.,t;/ln IAle tINe /l1~1.f F,(~fI1 /7,Jh' felfse's AOl/sej ,sAe fI1ef ;JJ2rYl And Mo o/de;e tnA/es JIJ Me ;z~ f'(po~ /Jill/wAtt! c.oJ'Y/(nJ ckwlI {,(pm ;JJffAn~ ~ ~ -F/d4;e k!J'ttom, (j);I(le tJitJ/tJus ~,( dr, jOtl$'eCkM/~ - fflJ/YJ dC/ie M (l/'s:;f t1Jl)s. f) ..sAoCK. . ))//?!.tr o/((rlcAje; d1'kaes III I~ ~/kK'1/1,RtI /111tl ~iCIet,.()AIK I /fJ~irle #.f1Ifk / c).;lfeA.. ()II e.v~ Idle / fio&/C.,/ j/f W~j(()IJI'Y/. ~cid~ f:e!11i lie d':iS / .1f}lk ev~IIl~~ - J.4IIM'JII1/ J(I fek. JJMIJ f;f)J/31t1e-n1- ulIeRe lie kJld4j lAeiltltes- Al3e_ , 'F,~ III] . I - -~ ,-. - - tvl#' ,e'l/l/CtJ If! fAe If 8tfdt?.. - lie CtJA/I/CAd MS ke.J1 ho;rEN Jy Ydtt., /('I1Tt: ~/U/C. /lsi /ty /JNIJ 5f1sJA /dill k m()(Jli~ (j(t.! /(J'I'.fA 1111 (J.f /Jelie. ft.Ra~/I~: be Io,,! 17f$ J AltltJt!1l1 bet: fiJ1 ~ /. WIfA. )/elt/-e _ GIAM~1jl R;gil:s I" IW>~ ftI41hce 1f1I/ .J.~/;i Eok/#I1fr1 leRl1lll/AI;1' fJ l?ettllJtA I1f ~ 3.JiJ,~ 1M hie ..eemAliJl1? R D,rys /N /I/ttlt1ttO~ I f)1'I~ ,Me. <if tdd ~ d~;',,"111 ,C) -hIli I elF .1/ ~ lJ.q~ficJ,lS. EX/-€f!./eol wlH/.n 3t101A-1js H.?/h lelolA-et, NtJ()~lk,e, /qtJ/~ 1 PIJJ.o 10 FtANCINE ItJAIIAce _ fl&.AIt$& J"l3"NSW;-- :z~ .}jl)'s..C/JNNOf be. /llIa~/t1(1. Ii~~e..of tlfltJ#, If k!.J}! c4/Qn t(JIII 6{J -tIeL t:Jgl!iNsf YOll.. IN bls!I<,C.1 CCl~ f. I + hAS been fhIA. h", "'1 A~~ee"L +J.." CDN+Fl.f'.c:.+ -H 1< f:d6,.,.,.J- bMR~ A-+- )).'7 CUed- ~O\fr\f"tr~t- .5+. CAR 1I's1e. eA, be+ween . I Kp.~e ~.Al'I- flll1) DenIse Jens~ is Va i~ -fRo",", ^'GVE/n"l he,. 1~1 ;lc1c:10. ;J 0 -FuRThe.r ~IAI'rr-.s o~ Adiov> 4)I'/J be /l)A-De tI2D/YIe.,fheR- plrR.~. ~~ ;ftMPuJ~ fitMlA'~13t7a)(fM Wt1llCVLL r, ..'II" I. ., . VERIFICATION I, Francine Braxton Wallace, hereby verifY that all of the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ~u'~ <:C~-ze{)<;~ \A1u[tuL Francine Braxton Wallace Date: 5Ids/O( "~I' ~,,~r'_~c' -~ ~., ^<-~" '-".I-!I!II."",''''''-''''--'' '--I" "-'Tr -" - - T'_ ,--. -..--- . ~ DENISE A. JENSEN : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 01-2505 CIVIL TERM KATE BARR a/k/a KATHLEEN BARR : CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Tina Strausbaugh, secretary to Glenn C. Vaughn, Esquire, do hereby certify that on the 25th day of May, 2001, I mailed a copy of the Complaint via certified mail, addressed as follows: Ms. KatWeen Barr 227 Pomfret Street Carlisle, PA 17013 Tina Strausbaugh, Secretary Glenn C. Vaughn, Esquire 22 South Beaver Street York, Pennsylvania 1740 I (717) 845-9689 :>:w~~_,.J!. . ,-,,-;-, __1"'1,1 ".__,A__," -"J -"'1-""_"" '" '" ,e".- ", ~" ' ~ f". . """ "" III ~, ..~. .~ . "< ".' ~.~-~- .,_IIl"~I~ ""- ,~ .,-~ ~'~--~ - ..- i" _J "n.i1imrr 0 ._..l '.~ C " < "1J [;c rnr;--: Z::T ZL"' - (j (,oX -<"" <o- r ~C; C' .- ~t:J '-I ..;.'">,--.- Z'"" .'-~ C") __(1 '''-~~rn >c w \..../ Z ::--j .:J1 .'" :<! .D OJ -< _'~"""'"""" ._~;l";JM!~~~iJ~iI{~~~~~~~~Jfi!!il"~_~,,7"'~'I1 ~, _"f1.-.; FRANCINE BRAXTON WALLACE : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA vs. : NO. Ql-2505 CIVIL TERM KATE BARR a/k/a KATHLEEN BARR : CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Tina Strausbaugh, secretary to Glenn C. Vaughn, Esquire, do hereby certifY that on the 8th day of June, 2001, I mailed a copy of the Complaint via certified mail, addressed as tallows: Ms. Kathleen Barr 227 Pomfret Street Carlisle, P A 17013 Tina Strausbaugh, Secret Glenn C. Vaughn, Esquire 22 South Beaver Street York, Pennsylvania 1740 I (717) 845-9689 '<'] j- -'>_-"'~~,"f~d;m~~".-,'"f'"'!":l,,,,,~"""~,"_l-'_'?'''',',,,"'c '>c'_~ .'1""1 ,_, ~_'__, ~-,,, ,. _". _" ,,^-,_'t, ". I ""_.''''." ,_^_, _. - ~ ~ ". ~< ~ 0 0 CJ r;:: -, I s: -0("',,] c:: ..- rnn~ z 1--" 2:::1.'.i -,;-^Tl zc;.: ~- z_1~s ~Z \::=0 -n .-,- I, -,:o..;.:-n ~o -- 1;~ 0 w 5'>c ..-{ ~ U'l S5 co '< \ DENISE A. JENSEN : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA vs. : NO. Ol-2505 CIVIL TERM KATE BARR aJk/a KATHLEEN BARR : CIVIL ACTION - LAW CERTIFICATE OF SERVICE 1, Tina Strausbaugh, secretary to Glenn C. Vaughn, Esquire, do hereby certify that on the 20th day ofJune, 2001, I mailed a copy of the Complaint via regular mail, addressed as follows: Ms. Kathleen Barr 227 Pomfret Street Carlisle, PA 17013 She refused to claim it by certified mail after notices on May 29, June 4 and June 13, 200l. ~&O-ub Tina Strausbaugh, Secretary Glenn C. Vaughn, Esquire 22 South Beaver Street York, Pennsylvania 17401 (717) 845-9689 '.T,,~, !_-'~,. "_:,"_~__".~_,_.,,~ '_,-i'"_'_"~__h_ '''-'<:''IO!!''l _~_, _, _~ -',.1 '" '-'- -,-, ~ '1Z~~~"'."'T~ " FRANCINE BRAXTON WALLACE : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01-2505 CIVIL TERM KATE BARR aJk/a KATHLEEN BARR CIVIL ACTION - LAW PRAECIPE FOR JUDGMENT Enter judgment in favor of Plaintiff and against Defendant, Kate Barr alk!a Kathleen Barr, for want of $1,120.00, plus eight months' interest to July 19,2001, at the legal rate, for a total of$I,164.80. (X) Assess damages as follows: Debt Interest from TOTAL $1, l20.00 $ 44.80 $1,164.80 (X) I cert:iJy that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. (X) Pursuant to PaRC.P. 237 (Notice of praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to hislher Attorney of Record, (X) Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to hislher Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. DATE '7-Z-7--(JI Glenn C. Va sqUire Attorney for PI ntiffs 22 South Beaver Street, York, P A 17401 (717) 845-9689 Supreme Court ill No. 07484 NOW, (JuJ:f ~ ,2001, JUDGMENT IS ENTERED AS ABOVE. Prothonotary/Clerk, Civil ' '--.l3v M(Vt....C- ~ ~~"Ii. ) Deputy r~ I 1-1. ",- '"1 VI " " 'II I , I I:' i< ! )~'-~-~~'"-I __~",~ . FRANCINE BRAXTON WALLACE : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA 'IS. : NO, Ol-2505 CIVIL TERM KATE BARR a/k/a KATHLEEN BARR : CIVIL ACTION - LAW To: Mrs. Kate Barr 227 Pomfret Street Carlisle, P A 17019 Date of Notice: July 10,2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN TillS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF TillS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTIffiR IMPORTANT RlGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Lawyer Referral Service of the York County Bar Association 13 7 East Market Street York, Pennsylvania l7401 (717) 854-8755 cc: Francine B. Wallace -~,~ <, T' - 1~lJ. , - "._. ,,, , . .,,-. '." ~ . 0"> t1 ~l 0 I~ I'- r< ~ ~I ~ H WI'- ~ ~gj Z I 5 .. ~ III to :J 00 <: <( ~ Z ::J> 00" 9 ffi :J & . ~ )- 0000(1) ;; 00 z :5 ;:: z Z "w g II Z ~ ",' ill No: ..J 0 C) >- a -- o \ ~ ,1 ----<' ,-> - . ~, ~ ,~ . ,-""1 :;-~ - _m~~ _,. ~~i'l1JI!!l "nl!'l . ~ " " '<~ ,- - ",'~ . ,~. ~,,~ -~ ~ #- ,. ,~" ,. Iff . " c ~ [ o4Q. :-0 2- 0 () c..:> <:; c 'TI ~ 0 :<:: ~ .-, -occ "" ~ ~ ~fT1 ,:;5 il1pl ~ ::r.i I --(')rn ~ Zl):" ::-i6 ~ cJj " r......) ..... ~z 0 -.J !<,C -Q : r~:8 2-, - -1- Zl" --"~ ;~;~~ ~ 5>0 :...:> c ~ ~ ::> "' :;:J <l' -< ~..~iIMll:l.: ~~, ~lil! ~~~~~;;:''''''-h;",?,'''~<f:r?):~'''~''''''''1i-''il''''"''!'~'ilO!!'''lVm.f~.~~,r'ti':'Wil;'!P~:~"""",,^~wm;!l::--1~P!.Tt!l1!~!\I,~~If!1ii; FRANCINE BRAXTON WALLACE : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA vs. : NO. Ol-2505 CIVIL TERM KATE BARR a1k/a KATHLEEN BARR : CIVIL ACTION - LAW NOTICE OF FILING JUDGMENT (x) Notice is given that a Judgment in the above captioned matter has been entered against you in the amount of $1, 120.00, plus eight months' interest to July 19,2001, at the legal rate, for a total of $1.l64. 80 on fJ,. 1<' do-:<'" ' 2001. (x) A copy of all documents filed with the Prothonotary in support of the within judgment are enclosed. Prothonotary Civil Div, ~o P7r;~ If you have any questions concerning the above case, please contact: NAME: Glenn C. Vaughn. Esquire ADDRESS: 22 South Beaver Street York. PA 17401 TELEPHONE NUMBER: (717) 845-9689 (This Notice is given in accordance with Pa.RC.P. 236.) Notice sent to: Ms. Kate Barr 227 Pornfret Street Carlisle, PA 17019 ,. ^ ~ '-"-f'S--i-- I~"; "-",. ,- . ~ 1-1 l' ,. . , DENISE A. JENSEN : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. Ol-2505 CIVIL TERM KATE BARR a/k/a KATHLEEN BARR CIVIL ACTION - LAW PRAECIPE FOR JUDGMENT Enter judgment in favor of Plaintiff and against Defendant, Kate Barr a/k/a Kathleen Barr, for want of $1,120.00, plus eight months' interest to July 19,2001, at the legal rate, for a total of$I,164.80, (X) Assess damages asJollows: Debt Interest from TOTAL $1,120.00 $ 44.80 $l,164,80 (X) 1 certifY that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. (X) Pursuant to Pa,R.C.P. 237 (Notice of praecipe for fmaljudgment or decree), 1 certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. (X) Pursuant to Pa.RC.P. 237,1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. DATE: g- ;i!-fJ/ ~~ Glenn C. Vau quire Attorney for Plam 1ft'S 22 South Beaver Street, York, PA 17401 (717) 845-9689 Supreme Court ill No. 07484 NOW, {)U'1 L::. ,2001, JUDGMENT IS ENTERED AS ABOVE. <!b': :i1~ I' ",,",, r J~' ,.. '1, I , . , ',. DENISE A. JENSEN : IN THE COURT OF COMMON PLEAS OF : CUJ\.1BERLAND COUNTY, PENNSYLVANIA vs. : NO, Ol-2505 CIVIL TERM KATE BARR aJkJa KATHLEEN BARR : CIVIL ACTION - LAW To: Ms. Kate Barr 227 Pomfret Street Carlisle, P A 17013 Date of Notice: July 19, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (l 0) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TIllS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Lawyer Referral Service of the York County Bar Association 137 East Market Street York, Pennsylvania 17401 (717) 854-8755 ~/ 'k<Y'r 'J. ~;, squire 22 South Beaver Street York, Pennsylvania 17401 (717) 845-9689 cc: Denise A. Jensen -,-,.." '.' '.,h~_'-' ~_ " ,_,!'l"'I, - ,'r __ ." - .,. .. ... fY) ~5 fil r-- gi ..... IUl~ ~I~ . r-- t;3 ~gJ5 z ~ I ~ CJ f- ~ :J tlJ <( <( go z "' "',c ~ > ffi ~ u: ~ >- ~ O' wen "' Z 3: I Z :\ Z 5 w o C. Z ~ 'X" W ~ 0: -I ~ CJ - CJ cs- - '\'"" ~ 'd =2 :1,"~_."'" ~ _ , < ~ ,,,,~,, -. --, "1l[ - ~,,~~ .-.. .( / ~ GJ 'iQ.. 0 c, 0 t C TI ..0 s: no ~ , ",,(Jr.!:; c: B mn'_ G"> 2:1: ;-.:.: 2C I r ""-. C/)-d-:~ 0'> ~ -<-". ~ ~ <C:' -;;1 ~Q ~ ~ .::0 p~ C:? (.~! -'-I .....::::.. ::> ,~ - 1 =<! \.0 ::0 [: -< is '<t' _l'lII'P'I)'lIl'W.",_~,~m"''''''''4 O~ ,~ _1I!'_!i!II!!~,"_!ll!l,~I~'iIT!l-ml\~j~<\,>,~,,~,,",,~M>'lN','~Y~~I!ml'l!'~l)~'f!ll1!W~>l:..')fffl~~~~I!~'! II ,fi, A ~ PRAECIPE FORWRITOF EXECUTlbN (MONEY JUDGMENTS) P,R.C,P. 3101 to 3149 DENISE A. JENSEN ........................................... ........................................... IN THE COURT OF COMMON PLEAS OF ~ COUNTY, PENNSYLVANIA CUMBERLAND VS, , 01-2505 Judgment No, , , , , , , , , , , , . . . ,Term, 19 KAn;; BARR a/k/ a ........................................... KATHLEEN BARR ............................................ PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (I) Directed to the Sheriff of. " .. , ,~~ , , , , .. , , .. , , ,. , . , , County, Penna,; (2) against, . . ~:t;e: ,J?~:r: . ~!~/.<l;. ~:t?~~ ,~!-'. , , , , , , , . . . , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , ,. , . , , , , , , , , , ,.,. " , , , , , , , , , , , , , , , , , , ., , , , , , , , . " , , , , " ,. , , , , , , '.' , , , , , , Defendant(s); (3) and against. ., ,~,9~,~~~9.,.. '" ,."",., '..'""""""""",.",..",. Garnishee(s); (4) . and index this writ (a) , Kate Barr a/k/ a Kathleen Barr . agaInst. , . , , , , , , , , , , , , , , , , , , , , " , ,. ,. , , , , , , , , " ,." , , , , , ' , , , , , ' , . , , , , , , , , , . , , , , , . , , , , , , , , " , (b) , .. , , , , , , , . , , , , , , , , , , , , .. , .. .. , . , , , , .. , , , , , , , , , , . ,. . , , , , , , , , , , , , , , , , , , Defendant(s) and , Bank of Landisl:iurg agaInst. , ,. , , , , , , , . , , , . . ,. , . , , , , . , , , , , , , . , , '. .. , '. . , , , , , , , , , , , , , , , . , , , . , , , , , , , , , , . , , , , , , , . , , , :,1,2~. SR:r:-0~, !'l:~,', .S~~~7~,l,':~ . ~~ ,~?~?~ , , , , " , , ,.", ,.,,'.. , ,.. Garnishee(s), as a lis pendens against the real property of the Oefendanl(s) in the name of the Garnishee(s) as follows: (Specifically describe property)' all bank accounts (5) Amount due $, ~ ! ! ?~:~,O, , , , , , , , , , , Interest from Total ,~!) ?~:,8,~ , , , , , . , , , , Plus costs, Dated, , , , , , , , , , ., ,f?J:~,~ , , , , , , , . '. , NOTE Under paragrarh (I) when the writ is direCled 10 the sherirf of anOlher COunly as 81llhori7.cd by Rule JIOJ{b). the counly sll.ould be indicated. Under Rule JI03(c) a wril issucd on a Iranrcrrred judgmcm may be-directe.d 10 the sherifr of lhe counly in which issm:d. P<\,agtaph (J}above Sl\1,)\l!rl be complelul only if a namc:-d garnhhee is 10 be included in the "'ril. Paragraph (4) (a) above should be COlllplelcd only iriudexillg of Ihe e:<eculion in lhe counly ofissutmce. is desired as authorized by Rule 3104~a). Whenlhe writ issues 10 anothercollnly indc:<ing is required 3S of course in that count-y hy the rirothonotary. See ~ule 3104(b), ' Paragraph (4) (b) should be compleled only irreal properly in the namc or the garnishee is allached and indexing as a iis pClldes is desired. See Rule 3104(c). " "-~, -~ ~, ~- .-11I.. ~ ,__v.,~ .,'. ",.~~. .-.,'~- ,,~ - -~ - ,~ .-~- ~ ~ ~ , '- ~ , .::: ~~ , J ~~ ~~ ~ .'" ~ ~ ~ . . ~-=t' \J"~ G .,.. 0' ~ 0:; <t: .....' 6 ::1~ t.\..~Q r)~ ~~ .<'> ;L bZ ~"2 <C ~.:::'l: :::13 ~- --......- t::) --:,,, en 'j-:-~ ~ N J~ :::LL .- ~- L.UUJ , . .cr.. CD Cl_ - ~~ ;~"-J ::) (:) 0 0 '" J1. o en< <- UlZ ...:1< A.:> Z...:I 0>- ::a~ ::aZ OUl UA. J1.;":- Of-< l;25 58 u,:.: Ul": :1:0 f-<>- Z - e ... " 1; o z ~'r:J ~~. ~rl- ~~ ~ :J '~ p~J en :> \l'..l ' GJ(h '/j' ~l ~ "-l" ~....... .J ~ gg 0; ~ ~ :\3 r-- ~ '" v~...... '< , . jQ.> QJ 'U ~r!.q ~ C\) ~ t:: 1l u,^!ll 'J!1ON --.J ri 10!SS'JUOJ.{q p'J'IU' ou IU,wllpnr \.!; f1.,J! UO!SS'JUOJ.{q P'JOjU, IU,wllpnr --~ " ~ ,> ~- d' .. "'.,~. f;; "'l Vi Q ~ . ~ ,~ , - C ." :0:: :.9 ~ z v 0 U ' E f:: ;:; :.9 ::> ~ '" :~ u ;: '" W " w E '" l1. >< g U OIl W 'C W U. " (3 c( 0 ..... a: I- " '" l1. " ",; it " 0 :i!: 6- u a: ..: 0 A- u. '___:<!i~J_"fF"-'~il!'''~~,~N~~I~~~F'-W'if'''9':!.'~'''':'''- i;P_'-__-.,<.,__~,._S_t;p;1lJ!-lf~.q~'("1;tf"":n",~I'\l'i","IM!I,,"liP''''''!1;i,W'!J\f'lq'1l','f''ll'-f~~r: , , ~i 8 (J " L, ~1Yf. -J) ~ 'fu c.J I ~ ~ -...: 0.;, -s,.. WRIT OF EXECUTION andlor ATTACHMENT "..,.~" COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 01-2505 Civil CIVIL ACTION - LAW TO THE SHERlFF OF PERRY COUNTY: To satisfy the debt, interest and costs due DENISE A. JENSEN, Plaintiff (s) From KATE BARR AIKIA KATHLEEN BARR, 227 W. POMFRET ST., CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of BANK OF LANDISBURG, 5125 SPRING ROAD, SHERMANSDALE, P A 17090 - ALL BANK ACCOUNTS GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attaclnnent has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) [fproperty of the defendant(s) not levied upon an subject to attaclnnent is found in the possession of anyone other than a named garnishee, you are directed to notify himiher that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $1,164.80 Interest Atty's Comm % Atty raid $81.25 Plaintiff Paid Date: MAY 20, 2002 L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary, Civil Division REQUESTING PARTY: Name GLENN C. VAUGHN, ESQillRE Address: 22 SOUTH BEAVER STREET YORK, PA 17401 Attorney for: PLAINTIFF Telephone: 717-845-9689 Supreme Court ill No. 7484 '- By: ~IJ~" f? .7t;ov""JJ;DF-6 "1i'W ,. , 1~'1 IT . . ~~'~~If'!lIb'1 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DENISE A, JENSEN NO. 01.2505 CIVIL TERM vs, KATE BARR alk!a KATHLEEN BARR CIVIL ACTION - LAW FRANCINE BRAXTON WALLACE NO. 01.2505 CIVIL TERM vs, KATE BARR alkla KATHLEEN BARR CIVIL ACTION - LAW NOTICE OF FILING JUDGMENT (x) Notice is given that a Judgment in the above captioned m~er has been entered against Garnishee, Bank of Landisburg, in the amount of$ 2.328,60 on J~ l~ ,2002, upon the admissions ofthe Garnishee in answers to Interrogatories. (x) A copy of all documents filed with the Prothonotary in support ofthe wit ' are enclosed, Prothonotary Civil Div, '-- By ffi"-1- p ~F? ~'X'...r-- If you have any questions concerning the above case, please contact: NAME: Glenn C, VaU!!hn. Esquire ADDRESS: 22 South Beaver Street York.PA 17401 TELEPHONE NUMBER: (717) 845-9689 (This Notice is given in accordance with Pa.RC,P, 236.) Notice sent to: Bank of Landisburg 5125 Spring Road Shermansdale, P A 17090 "I~I"I ,., ~ ,,' , '" . , CF1___r "_I DENISE A. JENSEN : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-2505 CIVIL TERM vs. KATE BARR aIkIa KATHLEEN BARR : CIVIL ACTION-LAW FRANCINE BRAXTON WALLACE : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-2505 CIVIL TERM vs. KATE BARR aIkIa KATHLEEN BARR : CIVIL ACTION-LAW PRAECIPE FOR ENTRY OF JUDGMENT UPON ADMISSIONS OF GARNISHEE Please enter judgment in favor of Plaintiff, Denise A. Jensen and against the Garnishee, Bank of Landisburg, for the amount of $ll64.S0 plus costs of Court and enter judgment in favor of Francine Braxton Wallace and against the Garnishee, Bank of Landisburg, for the amount of $1l64.80 plus costs of Court.fa. " tvl8i jtttlr;mee.t af $1229. ~Q fJltts ~~.:)b vf CVI.U L. Judgment entered in favor of the Plaintiffs individually in the amount of$1164.80 ~n,' { _ uul jt.dgmel'lt af !!Jiliif .[0 "Ius costs of Court against Bank of Landisburg, Garnishee. DATE:, ri!!:;/liY$ ~ . - I~I' " , " " ." '- ~ ~ - - ( DENISE A, JENSEN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, NO. 01-2505 CIVIL TERM KATE BARR alk/a KATHLEEN BARR CIVIL ACTION - LAW FRANCINE BRAXTON WALLACE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs, NO, Ol-2505 CIVIL TERM KATE BARR alk/a KATHLEEN BARR CIVIL ACTION - LAW INTERROGATORIES TO GARNISHEE To: Bank of Landisburg ( Garnishee) You are required to file answers to the following interrogatories within twenty (20) days after service upon you, Failure to do so may result in judgment against you: 1. At the time you were served or at any subsequent time did you owe the Defendant ~ money or were you liable to her, on any negotiable or other written instrument, or did~cla'im n-."'T" ( that you owed her any money or were liable to her for any reason? __: ~:: ':: -_._ r- Answer: NO -.J c:5' c:' ~:; E",::- ~ ---11", ,.<tl' '::"" "r .:::- 2, At the time you were served or at any subsequent time was there in your posses;;:&n, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the Defendant? Answer: NO 3, At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the Defendant or in which Defendant held or claimed any interest? Answer: NO "-', '~"- '--, ~,-,~ ~ ,- . ~ ,,!JIL ~.~ _" _ - '" l ~.;;c _ '.. 4, At the time you were served or at any subsequent time did you hold as fiduciary any property in which the Defendant had an interest? Answer: YES 5. At any time before or after you were served did the Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefor? Answer: NO 6. At any time after you were served did you pay, transfer or deliver any money or property to the Defendant or to llny person or place pursuant to his direction or otherwise discharge any claim of the Defendant against you? NO Answer: 7, State the name of the owner or authorized signators of any accounts which you have in the name of Defendant, the number of each such account, and the amount in such account at the time of service of these interrogatories and at the time of answering of these interrogatories, KATHLEEN L. BARR 3605345 $ 326.61 as of 7/23/02 KATHLEEN L. BARR 366922331 $5.776.13 as of 7/23/02 Answer: GLENN C, VAUGHN By ;~/~ Attorney for ~ti ID No, 07484 f'. I~>'- <_ -. , ,,- " .'_ " ,q~l, ," " , '" - ,.,w,.'.o."''', ~" ;i:;7 . '" ,'~~ . ,'_"', 0" .'" .~,' ''"''->''' ~~"'-~_~'" " - ';1. t - , t~~ ~ ~- '- t 8 r l.J jlJ o ~ ~ ~ lI} \ ~ f t p [:~ 0 0 (:J C I~<:) "n ~" :.n ~'"., -:-.1 -0 ;-;. :-"1 lTl r;;, -0 z 1.,,2 "7 c. <- ( ,- . G.) , c ~:~ - --,l - r - :;;c.. ;-..) j :"':-1 ',;,. .- :'l.~ r ,.j ~, ~ ~r r --tJ ~ frr ~. F ...<1 ir_.!Ii,~_,~~,4. 4',~JI!I!!ll",,,,,, ~,._"" ~ 'r-" . ~l'i/lf,RWi!l~~cr'-,,::r::~'l,";J:'!'~ii"'f''',.'';'';,'!'W~,\'''I;~~~~8l'_'F'f.,",-'l,.ft"r,~nt!!ij[<lj;!f~f!\iKl~jlIQ!I;'!l~~ Lt',.""C,,;;", -,'_ ,n",'" ~ ~."----,"~ '., .. . .r '~ , / Francine Braxton Wallace IN THE COURT OF COMMON PLEAS OF THE 41st JUDICIAL DISTRICT OF PENNSYLVANIA, PERRY COUNTY BRANCH Versus Kate Barr a/kal Kathleen Barr Garnishee Bank of Landisburg No, 01-2505 SHERIFF'S RETURN And now July 19 .2002: Served the within name The Bank of Landisburg the defendant(s) named herin. personally at her place of residence in Landisburg Borough Perry County, PA. on July 19.2002 at 8:30 o'ciockAM by handing to Tom Cook. Executive. an adult member of family, 1 true and attested Vice President copy(ies) of the within Writ of Execution, Interogatorries and made known to him the contents thereof Sworn and subscribed to before me this (1.f.11 day of S u..ly , :Joo'J- 7nCl1fitw:t ':/.1kLtr ~ 6~-f" PI1'III~II",lMy , " NOTARIAL SEAL , lIAAGl\REH fliCKINGER. NOlARY PUBLIC BLOOMAao BORO"I'<RR'fCOUi'l1Y COMMISSION EXPIRES FEB. 16 2004 So answers James 't-\Bennett ~~AHe&? ~1A Deputy Sheriff of Perry County -;'i1Ii'j!,~- . , ~ C" i'- - 1_'1 ", "_ , <~ - , "'F'I'~~~ Ii II !, I, I,j I' i ~ " i '~ 'I i'l !J I' Ii I; !, I:, I"" I .~____ 'j""~''':;'~,:?;:S ;'~'::0!.1',:X:~gc;)1R':i'?i'~"':':{:;::5:"::~; '<i": "~';;'%f~;;:\'O-~'1ti;V;\;;2,:,';i;;~~ _'( '.C'"",'" -"'",""" ~" 'B,"".' ,~;.,,",,=~. -,. ~.,,~,_ ~.,~" ",= () C ~ -Ow n1.IT ~~-,: <J)~ --<[ r::::r: =--- ~- ,J> ___, 7"r' s;s:! Z --j -, " :t C::J 1'0 U) r'1 -0 !I to o ," ,-' "-i~j;~ "nrn ~;j~~ -0,-" -~~(~5 ~~fTl ~p2 ~'q =< -;~"] :;,!: :'J1 --,'" ~[, -A "''"''''"'l....'IljI!1Np~~1IIl'/!1!':'I@'.'W'*'''1!i'''i1te,-'n'''!''..''''''~''\.mk'ilil'.Pi""fJl"!'\-=",~~'~,(f~~I'l'l!J'\!!l~\"Ii!'''!!fif.<'-'~R'ffl!il1;!l~llll'iJ'~\''lm ,.., ~ .t , IN THE COURT OF COMMON PLEAS OF THE 41st JUDICIAL DISTRICT OF PENNSYLVANIA, PERRY COUNTY BRANCH Denise Jensen Versus Kate Barr a/kal Kathleen Barr Garnishee Bank of Landisburg No. 01-2505 SHERIFF'S RETURN And now July 19 , 2002: Served the within name The Bank of Landisburg the defendant(s) named herin, personally at her place of residence in Landisburg Borough Perry County, PA, on July 19,2002 at 8:30 o'clock AM by handing to Tom Cook, Executive, an adult member of family, 1 true and attested Vice President copy(ies) of the within Writ of Execution, Interogatorries and made known to him the contents thereof Sworn and subscribed to before me this /lJJr , day of , c70od- \?",-,"":'-;.,.,-,,- I ,'-->'^ ,-"'-" r "''"''''I~lt- '" I So answers JarneJ!=tett r~ ~ I Deputy Sheriff of Perry County , ~ ;;s.~'~ . g-- /r"p ..--- ,-< <~-".~._.~ '.'.' _ u. ";~'" ~~ .,",'l:Il;I1~1,~.~_"~. Wf'l!l"l'i~ n ""'e. ,'~ <' .~ ,_ ",".~ ~~ ',".,-- V~_, (") Co' :? ifift 2:-; ;.:-.:c (/L ;:$;;' .....C ~c:: 2:("''. ::r.;: ~.c' .. c: 2: -~ -< '--:",.,~' ~.'\M _'J ""'! " ""'" .... f 0'- f'\.) C"" r'1 "10 o 'T, :.:-1 --;1 ~:!1 1~ .~. ----;..4 ~I~' \.[.) " :t; ~< , _^.,._IIllV~f!ll'~;_~~',:g"'!?''''!"'''fF'!'f<'''''''I-'"1;'-.V,'v''<'t'ilfi-W~J!!'!o/P;pflifflf"i!"1'l'Jf'I!:<'il'~~;'""'!E'\H"'~"'~-;l'~'m'trt!l'1l~'W!J'~'~