Loading...
HomeMy WebLinkAbout01-04658COMMONWEALTN 06PENNSYLyAN1A COURT OF COMMON PLEAS JUDICIAL DISTRICT NOTICE OF APPEAI. FROM ~'~ 3-D ( DISTRICT JUSTICE JUDGMENT COMMON PLEAS No () I - V l..S P C r V. I T~,r f^' NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case mentioned below c,~A~...r i e.. ~ -~ r `7h '~ I Tr'~f ~ ~~e~~,r-~ ~. ~ ~`ZS"~f~~J.~~f i `~~' ~efl9~'14 ~1~'u~t CY 19 LT 19 ~~ "" 1008& V "V This Notice of Appeol, when received by the District Justice, will operate as a SUPERSEDERS to the judgment for possession in this case Signature of Prothonotary a Deputy (see Pa. R.C: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. !F NOT USED, detach from copy of notice of appeal ro be served upon appellee). PRAECIPE: to Proppth`~oratary (~ C, ~ Enter rule upon 1`-' '~~~ 1"• ~" ~'~n~ W r~, q ~~ , appefke(s), to file a complaint in this appeal Name of appellee(sJ (Common Pleas Na ('J I - 4L 5 ~ e.!'4. ( Tar nn )within twenty (20) days rvice of ru1le,a suffer entry of judgment of non pros. q`_ S7gnature of appellant a his attorney a agent RULE: To~~~'~~ ~' ~Q ~^: Ir'~oppellee(s). Name o/appeflpe(sJ ' (1) You are notified 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) X you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of service of this rule if service wos by mail is the date of mailing. /~ 1- pate~Li~`~ Ca3 , 19_. ~ ~.e~ l~ ,JCL novcatz-ea COURT FILE TO BE FILED WITH PROTHONOTARY C~9~~~3F C?F ~~~~6~~ CiF !V~'fBG~ ~F AFPEA~ AAl~ ~iCiY.~ 7'~ F~L~ ~6~~19RLAtlhi'T (This proof of servioa Mt157 SE F1LEC7 WlTh'iN TEN (ip) DAYS Af-7ER fiting the notice of appeat. Check applicable boxes} Cf1Afl~4NW~ALTH UP P~hdNSYLVAW9A AFFI~A~~1": !hereby swear or affirm chat I seared ~1 a ogpy of the Notice of Appeal, Common Fleas No. _.. ,upon the €3istrict Justice designated therein qn {dais of serutoa) ~ Cl lay pens<mat seru'sge f~ by (certified} {registered) mai4, sender's receipf attached hereto, and upon the appellee, (namo) _ .___~_ .~ ~._, qn 99____.. C~ by personal service 0 by (certified) {registered) mail, sender's receipt attached hereto. C1 and further that I served the Rule to Fiie a Complaintagcgmpanying the above Notice of Appeat upgn the appe'.tee(,j to whom the Rule was addressed on _____ , 99®..._, ~ lay personal serv(oa [~ by (certified) (registered) mail, sender's reoaipt atiaahed hereto. SWORN {AFFIRMED) AND SiJBSCRlBEL} BEFORE ME 7HI5 DAY OF 99...._...~ 5ignatr}ra of atf9ant Signature of atftctal 4efpre whom at±idavit was ;~rrerfa Title of official My commtssia~E expires or ~ ~. ~'. ~ >, ~ ~ '.L ~~~-rr~~~~ ~~ ~.r-=, ~ ~ Z%`~ D --~C7 ~ ~' } t~ V ~ Ct ~' :~ a ~ ~ 't~+N U ~~~ '^"' U~ [~- ~ ~ '` v V ~~ ' -~..~:., -- --- -- : ~. _.. <-~~z~ u.~. ~,.a,.r: ~,--v=~a,~~satfi~gF~~. t sx .a.~~:~'~~t~~€.tarN. ..R 'kE xis ~ ~~ ~ _ V ~ • COMMONNPEALTH OF PENN;S:YLVANIA~,tx "NOTICE ®F JUDGMENT/TRANSCRIPT r.nl inlrv nF~ cDrIDSRLr,Nn RESIDENTIAL LEASE Mag. D15~. No ' 09-3-05 DJ Name. Hon. GAYLE A. ELDER Atl~fB551 507 N. YORK ST. MSCHANICSBURG, PA reiepnane:(717) 766-4575 17055 PLAINTIFF: NAME and ADDRESS ~ •rWRIGHT, NORMAN F, ST AL ,, 184 RONHAUS ROAD MECHANICSBURG, PA 17055 L J VS. DEFENDANT: NgMEandgoDRess rHRUBACHAR, VALERIE ~ ' 99 W PORTLAND ST APT.# 2 M13CHANTCSBURG, PA 17055 L J VALERIE HRDBACHAR 99 W PORTLAND S'P APT.# 2 DocketNo.: liT-0000201-01 MSCHANICSBURG, PA 17055 Date Filed: 7/13/01 THIS IS;~'O NOTIFY YOU THAT: Judgment: FOR PLAINTIFF Judgment was entered for: (Name) WRIGHT NORMAN F, ST AL. Judgment was entered against HRDBACHA&, VALERIE in a Landlord/Tenant action in the amount of $ 926.50 on 7/24/01 (Date of Judgment) The amount of rent per month, as established by the District Justice, is $` . 00. The total amount of the Security Deposit is $ .00 Total Amount Established bb DJ, ess • Security Deposit Ap lid = Adjudicated Arr~oun Rent in Arrears $ 50.0 - $ .~~ _ $ 590.0 Physical Damages Leasehold Property $ .00 - $ .00 = $ .00 Damages/UnfustDetention $ :00-$ _00 - $ =00. Less Amt Due.Defendant.from Cross Complaint -,$ _ 00 „ Interest, (if provided by,lease) $ :: 00 `- L/TiludgmentAmount $ 590.00 AttachmentProhibitedf JudgmenNCbstS $f; 86=50 Victim of Abuse (Act, S, 1998) Attorney Fees $ 250 _00 This case dismissed without prejudice.+ ,( Total Judgment $ '926.50 0 Possession granted. Post Judgment Credits $ ^ Possession granted if money judgment is no sa Is ie , y ^ Possession not granted. ^ Levy is stayed for -days or ^ generally.stayed. ^ Objection to Levy has been filed and hearing wilt, be held: ^ Defendants are jointly and severally liable: IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS ,tA BY FILING ATHE RIGHT _TO:APPEAL~FROM A JUDGMENT FOR POSSP$SION WITHIN ' NOTICE OF APPEAL WIT TEN DAYS , FTER THE DATE OF ENTRY OF JUDGMENT„ ~ ~MLL INCLt7D'E'AN AppE ~H THE PROTHONOTARY/CLERK;OF COURTS OF, THE COURT OF COMMON PLEAS; QIVIL D!VlSION: THOS APPEAL ~ AL OF THE MONEY JUDGMENT, IF AMY. IN ORDER TOOBTAIN A SUPERSEDERS, THE APPELLANT MUST DEPOSIT WITH THE PROTHO,jJOTARYI~CLERK OF COURTS ITHE LESSER OF THREEMON7HSRENT-OR THE RENT AC7UALi-Y-IN ARREARS ON THB~DATE THE-.APPEAL IS.FIOED: :~.. - IF A PARTY WISHES TO APPEAL ONLY THE MONEYPORTION OF A JUDGMENT INVOLVING:~ARESIDENTIAGLEASE;~THE PARTY'HAS 30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TOFILE A NOTICE 6F APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS OF THE COURT OF COMMON PLEAS, CIVIL_DIVISION. -~ - ~ ~ , - ~ ~. - . - - ~ - - THE PARTY FILING AN APPEAL MUST INCLUD,ECA~COPyoF THyr~~/NOT CE OF'JUDGMENT/TRANSCRIPT FORM WITH THE NOTICE-OF APPEAL; f ~ - f; a~;_ "~ Date / +/!• f V ~~ District Justice erti y t a Thls Is a true an correct c pv o e recor o t e Drocee Inos contamma tFe iu amd ent. 1 Date Post Judgment Costs $ .Certified Judgment Total $ Distrtct Ju. My commission expires first Monday of January, 2006 • SEAL q~ar. aieq-ec ~ - . ,~, ~~ -. ~ ~ ' r i ~; ~s ,_ h _ ~ ~ ~2 ~ Zr p ~~ , r ~ ^. ) ~3 `' ~~• ~ t_~ ACC ~ ;ern 1 ~7 -G ~.:~:.. ... .-w~x,~,,,,au fxR .,°]!. _.~s+rw~iact•!g s:er"~- .... _..._ VIWY~~ .. r.xax_c ~-maws Rksti Wdrw. F *Fl:?c? .mx rt. .. COMMONWEALTH OF PENNSYLVANIA -- - nnl InITV nF~ CUMBERLAND Na: 09-3-05 DJ Nama: Hon. GAYLE A. ELDER Ada,ess: 507 N. YORR ST. MECHANICSBIIRG, PA Telephone: (717 )766-4575 17055 LANDLORD AND PLAINTIFF: TENANT COMPLAINT r NAME and ADDRESS NORMAN F. WRIGHT and SUZANNE C. WRIGHT 184 Konhaus Road ~-Mechanicsburg, PA 170SS VS. DEFENDANT: NAMEarMADORESS r VALERIE HRUBACHAK 99 West Portland Street, Apt Z Mechanicsburg, PA 17055 L Docket No.: LT-201-01 Date Filed: 7/ 13/01 1 p,. Amount Date Pai asks judgment together wish costs against you for the possession of real property and for: Lease is ~ Residential ^ Nonresidential. Damages for injury to the real property, to wit: Filing Costs $ S6.S0 7 /13 Al Service Costs $ 30.00 7 /13 bl Total $ / ~ J -~ J in the amount of: $ Damages for the unjust detention of the real property in the amount of $ ® Rent remaining due and unpaid on filing date in the amount of $ 5..40 !~_ ~ ~F-d--i And additional rent remaining due and unpaid on hearing date $ 'a5©~ THE PLAINTIFF FURTHER ALLEGES THAT: Total: $ 1. The location and the address, if any, of the real property is: qg WPCt nor ~ Rnd s >• P Anr 2 2. The plaintiff is the landlord of thaf property. 3. He leased or rented the property to you or to under whom you claim. 4. ®Notide to quit was given in accordance with law, or _ x^ No notice is required under the terms of the lease. 5. ~ The term for which the property was leased or rented is fully ended, or ®A forfeiture has resulted by reason of a breach of the conditions of the lease, to wit: pay rent as agreed in lease Rent reserved and due has, upon demand, remained unsatisfied. 6. You retain the real property and refuse to give up its possession. failure to I Norman F. Wright verify that the facts set forth in this complaint are true and correct to the best of my knowledgge, information and belief. This statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA. C. S. § 4904) relat' g to unsworn falsifica ion Lo authotities. Snelbaker, Brenneman & Spare, PC ~ Philip H. Spare 44 W. Main St. Mechanicsbn~i~ ti (PlaintiffsAtiorney) (Address) (hone) IF YOU HAVE A DEFENSE to this complaint you may present it at the hearing. IF YOU HAVE A CLAIM against the plaintiff arising out of the occupancy of the premises, which is in the district justice jurisdiction and which you intend to assert at the hearing, YOU MUST FILE it on a complaint form at this office BEFORE THE TIME set for the hearing. IF YOU DO NOT APPEAR AT THE HEARING, a judgment for possession and costs, and for damages and rent if claimed, may nevertheless be entered against you. A judgment against you for possession may result in your EVICTION from the premises. If you aredisabled and require assistance, please contact the Magisterial District otfice at the summary o, iesumpny may c~ c; ~' c a- ~~ w~ ~, rr~c,,-a.. ., <`n~ ~ -r r~l _,1' :Sy ``~ T' y .. w -< ~_ ~xsf ~_ - •rWMrfuwieLTN Di VENNSYEVANIA °' COURT OF COMMON PEEAs JUDICIAL DISTRICT:. NOTICE OF _, FROM ~-C~3~oi .~ DISTRICT JUSTICE JUDGMENT COMMON PLEAS Na. t; ' ~• '~d L5& ~ L~U+ ~ 1 ~ (J"~' NOTICE OF APPEAL Notice is given that the appelhnt has.fik:d in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and im the case mentioned below NAME OF APPELUM ~,J MAG D15T NO. OR NAME OF DJ. ~~ ~~ ~ C" 1 ~,.. ~-°~ i' Ua~C3X."'~~C~..,'1 Chi- ~; , ~ _ ~ ~ .,_.. . ADDRESS OF APPELLAM _ OTY STATE ZR CODE DATE O~,JIAGMENT IN THE CASE OF (PIaIM~flJ ~ _ ., a.Als, NO - SIGNAT E OF APPELLAM OR HR ATTORN OR AGENT I CV 19 p LT 19 ~-- L ~ N~ w~Cs=~ J_ t.~~r This bock, will be signed ONLY when this notation is required under P R Na f appellarlf w LAIMANT (See Pa. R.C.P.J.P. No. 1008B. This -Notice of Appeal, when received by the District -Justice, will ,operate as a _ 1001(6) in action befixe District Justice, he MUST SUPERSEUEAB to the judgment for possession in this case FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. Signature o/ Prothonotary or Deputy ~ P,RAECIPE TO ENTER RULE. TO FILE COMP~LA4NT AND RULE_ TO FILE ,` .~ (This section of form 1o be used ONLY when appellant was DEFENDANT (see Pa: R.C.P.JP. No. 1001(7) in action before District Justice. IF R;(OT USED, defach from copy of notice of appeal to be served upon appellee). PRJ~ECIPEs To ProNTOratary Enter rule upon''`"~~~~# "~ ~ • ~~~rTa(~(~ ~~ ~ ~~~ appellee(s) fo ~ile~~q complaint in this appeal ' Name o/ appellee(s1 (common Pleas Nn ~ 0 I ' ~ (e S ~ ~ L 41 ~ TC t M )within twenty (20) days wce of rule or suffer entry of judgment bf non pros: _ ~q S,igrlaGne o/appellant a his attorney or agent RULEt To'4-~siY~,~'+ ; ~,,.~•S"Y1G`t~. l,~r'.lg~`~appellee(g) . ` Name of appellDels) ~ ~ •w (1) Youare notified That a rule is hereby entered upon you to file a complaint in This appeal within twenty (20) days after The date of service of This rule upon you by personal service or by certified or registered mail. ,,~ '.~:`:e. , - z 'F'; (2) If. you do no4 fiile a complaint within this time, a JUDGMENT OF NON PROS (3) The date of service of This rule if service was by mail is 4he date of mailing. Date: ~(- ~~C~ C..~ -•.a , 19-. - ~~~ 4 iwnrn to and SUd~~rja~d be~~'!@ ale- ihls I? -day of 2t~?~'1° ,~ - Hampden Township, ~9a~it~ tvty Commission Expires Nov. 8. l ~ ~=~~~a1_r~ i• y ,T , ~(' 'Ii or t AoPCa,z-a. - - ~ ;CE>URT FILE" - ~ki~~F ~F S~~~1~~ ~~ iV~T~G~ ~F A~PEd4L A~~ RULE 'ft~ ~~L~ ~tliUliPi,&41N'C f Fhls FiroaJ of service MUST 8E F/tED WtTN1N TEN (70, )PAYS AFTER tiiirrg the noflce of appeat. Ghaok appiicabts boxes) CQPetR9~NWEAITfF9 `QrFyP~ENNSYLVANIA COUNTY QF~~ `~ ~ Q~~ , us , aaa~F1A$/tl"e I hereby swear or affirm that I served G~;1 `~.arrr. C~ a espy of the Plots .e of Appeal, Comman pleas hlo C~.1 _~~L S~ "upon the~District Justice designated therein or (date of service) ~ U G ~~ Z<nG 1 C] by personal service ~! fJy (Certified} registered) mail sender's r c Ept ached hereto, and upon the appellee, {name; ° i'~~M(b]'~ ~ ~.~ ~C~Ya,.~ ~~'' an #82~51)~ by personal servic rs ;r~{{certified} {rag"sster2d) maif, senders receipt attsahad hereto. Ca and turtherthatlservedtheRuletoFileaOomplain4acornpanyingttteaboveNotiaeofAppeatupon#heappet(ee{s)tawhorn Yh6 Rule was addressed on ~.~ ____.____., .___._ , i9._...~... ; ~( by personal service C-] by {certified'M (registered} mail, sender's receipt attached h®reta. SWORN {AFFIRMED} AND SUSSGFiIUESJ BEFORE ME pp THIS ~~ DAY OF ..~ _ ~2COJ \~L__._~` ` ~`.~ ~ ~ Signature of affiant d ~ L `,FqL ' fi?ta of otticia ~"aTP~`~Ot'r°i'~~- C~ ~~ ~HatitpdenTovi~ ',, t~I:ni:'.tlandCcb' ~~ ~ M'. My cammissran expir s tlN ~4rfliTiS~i~:,~Wi.~~. ; ~ , ;~~pV. B. ~ ~ r~~ '~' ~T` ;."~ _, ,~ C. r ` ~' P13 ~~ L.;~ M J ~~ :~ r .~ n _a ~~ ~~ ~r ih `~ ,,. T,_., E,.-,._ .. ,.,w ~. ..: .v ,. za.;,,:~:ax ~.~~q,~~.ry~,«~•r~~ut~r¢~t~~~rv~r.~~a~.ti~=ra~t~iu~r~",nr~~-~ ... _ . ~ h .e ~~~.,~ X( .. m IIEg4N11 PA 17056 a T' `~' Certifletl Fee { .~ ~ ;d} ~ ~le.~ m t ' Retum Receipt Pee §\&i 'yi ~ ~(sndoiaemeM Required) G ?Q~ ~~~ ~ Resldotad Delivery Fee ~•~ ~ 0 (EndorsemaM Requirerp ~~ y ~ e Total Postage & Fees {a.~ f_'.1"'~ y iO fl.l flB{,lp(¢nY3 NelnB (Please not CManyJ (TO be completed by malle~)- `" N O .__.__.C7I3.1Ka..~PrA~___.__. _1~6~2'~_______________________________....._. Street, Apt. Ne.; or PO Box N.o.`, t ~~- OB}k State. 9P+9 . (....................._..._... ~~ I NORMAN F. WRIGHT and SUZANNE C. WRIGHT, Plaintiffs vs. VALERIE HRUBACHAK, Defendant TO: Valerie Hrubachak 9 West Portland Street Apartment 2 Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 01-4658 CIVIL TERM APPEAL FROM DISTRICT JUSTICE , NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with a 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 maybe entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO 'NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717}249-3166 LAW OFFICES SNELBAKER, BRENNEMAN & SPARE SNELBAKER, BRENNEMAN & SPARE, P.C. By P ' ip H. are, Esquire Attorneys for Plaintiff NORMAN F. WRIGHT and : IN THE COURT OF COMMON PLEAS OF SUZANNE C. WRIGHT, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO: 01-4658 CIVIL TERM vs. VALERIE HRUBACHAK, Defendant APPEAL FROM DISTRICT JUSTICE COMPLAINT AND NOW, come the Plaintiffs, Norman F. Wright and Suzanne C. Wright through their attorneys, Snelbaker, Brenneman & Spare, P.C., and aver as follows: 1. Plaintiffs are adult individuals residing at 184 Konhaus Road, Mechanicsburg, Pennsylvania 17055. 2. Defendant is an adult individual residing at 99 West Portland Street, Apartment 2, Mechanicsburg, Pennsylvania 17055. 3. Plaintiffs Norman F. Wright and Suzanne C. Wright ("Wrights") are the owners of a certain apartment house known and numbered as 99 West Portland Street, Mechanicsburg, Pennsylvania. 4. Defendant Valerie Hrubachak is a tenant in Apartment 2 of the property known and numbered as 99 West Portland Street, Mechanicsbrug, Pennsylvania, by virtue of a written lease dated June 1, 2001, a copy of which is attached hereto as Exhibit "A" and incorporated herein by reference. 5. The Lease term starts on June 1, 2001 and ends on the last day of June, 2001. LAW OFFICES s"E`aANER. 6. Defendant Valerie Hrubachak has failed and refused to a the full rent due under BRENNEMAN P Y & SPARE the terms of the Lease. 7. Under the terms of this Lease, Tenant waived her right to receive a Notice to Quit. 8. By letter dated June 6, 2001, a copy of which is attached hereto as Exhibit "B", Defendant and other occupants of 99 West Portland, Apartment 2 were given notice to vacate the premises by June 30, 2001. Past-due rent remains due and owing from Defendant. 10. Plaintiffs are entitled to possession of the premises known and numbered as 99 West Portland Street, Apartment 2, Mechanicsburg, PA. 11. The Lease provides that "Tenant agrees that Landlord may receive reasonable attorneys fees as part of a court judgment in a lawsuit against Tenant for violation of the agreements of the Lease." 12. The term of the Lease is expired. WHEREFORE, Plaintiffs Norman F. Wright and Suzanne C. Wright, respectfully request your Honorable Court to enter judgment in their favor and against Defendant Valerie Hrubachak for all amounts due and owing under the terms of Lease, plus costs and reasonable attorney's fees and to issue an Order for Possession of the premises known and numbered as 99 West Portland Street, Apartment 2, Mechanicsburg, Pennsylvania. SNELBAKER, BRENNEMAN & SPARE, P.C. By. Philip H. Sp e, Esquire 44 West Main Street P.O. Box 318 LAW OFFICES SNELBAKER, BRENNEMAN $ SPARE Mechanicsburg, PA 17055-0318 (717)697-8528 Attorneys for Plaintiffs Norman F. Wright and Suzanne C. Wright -2- LEASE THIS IS A RESIDENTIAL LEASE. IT IS A LEGALLY BINDING CONTRACT BETWEEN THE LANDLORD AND EACH TENANT. EACH TENANT SHOULD READ THIS LEASE CAREFULLY. THIS RESIDENTIAL LEASE CONTAINS WAIVERS OF YOUR RIGHTS AS A TENANT. EACH TENANT SHOULD NOT SIGN THIS LEASE UNTIL EACH TENANT UNDERSTANDS ALL OF THE AGREEMENTS IN THIS LEASE. 1. NAMES OF LANDLORD AND TENANT /yorm~n F Grrri' /~f ,~ ~tizahne ~; ~h,~~t~ ti>S " Name of the landlord: Name(s) of the tenant(s): l/a lerie ru a c a 2. LEASED PREMISES The leased premises is the place that landlord agrees to lease to tenant. The leased premises is: „_ , , 1 n_,1,/ _ ~ rl n_3- This lease starts on S- / t -~rle ~Ob/ This lease ends on /a r// ~ r~ zoo / 4. RENT The amount of rent is: Fire ~/"na,'~~,'/U,~e1r,~t$S9O_; ~ Dollars each month. /s~'" Tenant agrees to pay the monthly rent in advance on or before the ~##-day of each month. Landlord does not have to ask (MAKE DEMAND UPONI tenant to pay the rent. Tenant agrees to pay rent by first class mail postage prepaid to landlord at the place specified by landlord. Tenant agrees to pay a LATE CHARGE of Five ($5.00) Dollars per day if tenant does not pay the rent on timed If fenant mails the rent to landlord, the date of payment will be the date the letter is postmarked. yea ~T,~/ L'/~~2~l~ e ~ .'s sa6 f f~ a i+~e ~i~da ~yrac~ ~e~io•l .ir ~r~or- qL' 9 . C~0 owerer, :h ~e`~~et+est rEii~n~,ezceeds sai~1 ~~3/c~/Qys~ 7f /ofc c%ro e .rria// E RITY DEPOSIT PeYert buc/< /~ ~// ~~t ~Qy /Q~ d,~~~ ~¢S,/% ~o~t has ~~,cxe/Geen tied.~eq ((J~/`~. no) Tenantaga:s~te-Fa~j~a security deposit of ~Ye~~d~~~~%x~ {$ .5~~ . Dollars has e Tenan4 the security deposit to landlord before the lease starta~and before landlord tt~ possession of the leased premises to tenant. Landlord can take money from the security deposit to pay for any damages caused by tenant, 4enant's family and tenant's guests. Landlord may take the security deposit to pay for any unpaid rent. After taking out for damages and unpaid rent, landlord agrees to send to tenant any security deposit money left over. Landlord will send the remaining security deposit money to tenant no later than 30 days after the lease ends and tenant leaves. Landlord also agrees to send to tenant a written list of damages and amounts of money taken from the security deposit. (S„ -h£e e~nt plant hus not ao'~ua~e~ c/eaneda.- fiadac~u Tenant agrees to give landlord a written forwarding address when tenant leaves e%u~ed • and the lease ends. aPP/.ie~e¢S 7~en_ •-~ Tenant may not.sase the securit;~ deposltas-payment of the last month's rent. /A„~//n„~slx//Le 6. LANDLORD'S DUTY AT THE START OF THE LEASE G~nfi~.~~kNIY~+oc ¢~/af/-ee al~/lS• as Pic-r~,yreec/ . Landlord agrees to give tenant possession of the leased premises on the / ~d~~ starting date of the lease. The (ease will start even if landlord cannot give tenant b possession of the leased premises because the prior tenant is still in the leased premises a~Qirrayrs ~: or the leased premises is damaged. IF LANDLORD CANNOT GIVE TENANT ~` cosfa,~ POSSESSION, TENANT DOES NOT HAVE TO PAY RENT UNTIL THE DAY ~~"~ LANDLORD GIVES POSSESSION OF THE LEASED PREMISES TO TENANT. ~ u'a~neJ EXHIBIT A 3. STARTING AND ENDING DATES OF LEASE AGREEMENT b `d 7. DAMAGE TO LEASED PREMISES Tenant agrees to notify landlord immediately if the leased premises is damaged by fire or any other cause. Tenant agrees to notify landlord if there is any condition in the leased premises that could damage the leased premises or harm tenant or others. If tenant cannot live in the whole leased premises because ii is damaged or destroyed, tenant may: 1) live in the undamaged part of the leased premises and pay less rent until the leased premises is repaired. OR 2) end the lease and leave the leased premises. Tenant agrees that if the leased premises is damaged or destroyed and tenant ends the lease, landlord has no further responsibility to tenant. ~~ 8. INSURANCE Landlord agrees to have insurance on the building where the leased premises is located. Tenant's own properly is not insured by landlord's insurance. Tenant is responsible for tenant's own property that is located in the leased premises. 9. ASSIGNMENTS OR SUBLEASES BY TENANT ASSIGNMENT (OR ASSIGN) is the legal term for a transfer of the lease from the tenant to another person. This other person then becomes the landlord's new tenant and takes over the lease. Tenant agrees not to transfer (assign) this lease to anyone else without the written permission of landlord. A sublease is a separate lease between the tenant and another person who leases all or a part of the leased premises from the tenant. Tenant agrees not to lease (sublease) all or any part of the lease premises to anyone else without the written consent of landlord. Tenant agrees that if tenant transfers this lease (assigns) or leases all or a part of the leased premises to another (sublease), tenant has violated this lease. 10. RESPONSIBILITY FOR DAMAGE TO PROPERTY OR INJURY TO PEOPLE Landlord is responsible for. all damage to property or injury to people caused by landlord (or landlord's representatives) intentional or negligent acts at the leased premises. Tenant is responsible for all damage to the leased premises and injury to people caused by tenant, tenants family or guests. Tenant agrees that landlord is not responsible to tenant, tenant's family or guests for damage or injury caused by water, snow or ice, that comes on the leased premises unless landlord was negligent. 11. USE OF LEASED PREMISES Tenant agrees to use the leased premises only as a residence. Tenant agrees to obey all federal, state and local laws and regulations when using the leased- premises. Tenant agrees not to store any flammable, hazardous, or toxic chemicals or substances in or around the leased premises. Tenant agrees not io do any activities in or around the leased premises which could harm anyone or damage any property. f6Gr~yda-~3~ Tenant agrees that tenant will not allow more than people to occupy the leased premises without the written permission of landlord.~Lend/o~d ~ l~~o~a,'r/u/tuj4,° 12. RULES AND' REGULATIONS Names °{ awlkor~acd oCC~uant) •4 Tenant agrees to obey all rules and regulations for the leased premises. If tenant violates an rules or regulations for the 1 ased premises, tenant violates this lease. (r~ ee/~ o~ wb~c! i,f af/aclpd 6ierefn~ 13. LANDLORD'S RIGHT TO MORTGAGE THE LEASED PREMISES (SUBORDINATION) Subordinate and subordination are legal terms that mean that this lease does not have any effect upon the rights of the landlord's mortgage company. In other words, tenant's rights under this lease are subordinate to landlord's 2 mortgage company. If landlord does not make the mortgage payments, the mortgage company may have the right to end the landlord's ownership of the leased premises. If the mortgage company sells the leased premises at a mortgage foreclosure sale, the lease may end. Tenant agrees that landlord has the right to mortgage the leased premises. If landlord has a mortgage on the leased premises now, or if landlord gets a mortgage in the future, tenant agrees that ihis lease is subordinate to the landlord's mortgage. This lease contract binds subsequent owners. 14. CARE OF LEASED PREMISES Tenant is responsible for, and will take good care of, the leased premises and all of the property in and around the leased premises. Tenant agrees to pay for any damage caused by tenant, tenant's family and tenant's guests. Tenant agrees to turn over possession of the leased premises to landlord when the lease ends. 15. LANDLORD'S RIGHT TO ENTER LEASED PREMISES Tenant agrees that landlord and landlord's representatives have the right to enter the leased premises at reasonable times. Landlord and landlord's representatives have the right to inspect, to make repairs, to do maintenance, and to show the leased premises to others. 16. UTILITY SERVICES Landlord and tenant agree to pay for the charges for utilities and services supplied to the leased premises as follows: Charge or Service: Paid Bv: Television Cable 8 Phone 7cN/auT Electric to Premises Tc/y~rNT Water Service [ANDLnR.D Natural Gas ~- Refuse Collection _,y,~ ~,¢yoLB,~ L.fNO[o21~ other: Minor repairs Other: windows broken by tenant - -'~ - /YBT/F'Y L~PNOLO.fD Pest Control Charges-~'0T/FY L.S:NDLO.Y~ Lawn Maintenance LANDLORD HVAC REPAIRS (71`N.fNT 78 /~i/T U1N~La~aJJ 7b G'YANGE F/L7t~ZS ~S°•PBX. /.Y /Ilp. Roof Repairs L.S~NVCO.C~ Siding & awning repairs due to wind L,o-NDLO.LD and damage Building Insurance~Noi oNTElu.9NTs /°i+oo~Exrl') L.~Nn~o/zD Real estate taxes G,vvaco~y stem Nf~ (W-e~~H-- N//~ L.{-NOGr.tp td/CC 7Ar~E C,.Rs¢E o~c G/~y0otd CLEAN/.v6 !~ ~~ ~~7r~TL6'9`/~~5_ !+~'rYDL-B.CO ~r//r1 ~.F.eE' CAxeE'oF G9ipPETs Landlord has the right to turn off temporarily any utility or other service to the leased premises in order to make repairs or do maintenance. 17. GOVERNMENTAL POWER OF EMINENT DOMAIN. ~^ Eminent domain is the legal name for the righ4 of a government such as the state or county or city to take private property for public use. The government must pay fair compensation to anyone who has any right in the property that is taken by the government. If all or any part of the leased premises (or the building within which the teased premises is located) is Taken by eminent domain, ihis lease will end automatically. Landlord and tenant agree to release each other from any responsibility because leased premises is taken by eminent domain and the lease has ended. 3 18. VIOLATIONS OF THIS LEASE WHEN EITHER LANDLORD OR TENANT DOES NOT DO SOMETHING THAT THEY HAVE AGREED TO DO, IT IS A VIOLATION OF THIS LEASE. IF TENANT VIOLATES THIS LEASE, TENANT MAY LOSE TENANT'S SECURITY DEPOSIT. IF TENANT VIOLATES THIS LEASE, LANDLORD ALSO CAN SUE TENANT FOR OTHER EXPENSES AND MAY SUE TO EVICT TENANT. EACH TENANT SHOULD NOT SIGN THIS LEASE UNLESS EACH TENANT HAS READ AND CLEARLY UNDERSTANDS THE- INFORMATION IN THIS SECTION ABOUT LEASE VIOLATIONS. THIS IS A JOINT AND SEVERAL LEASE -THIS IS NOT A JOINT AND SEVERAL LEASE IF THIS IS NSLZ A JOINT AND SEVERAL LEASE, THEN THE LANDLORD CAN ONLY SUE ONE TENANT FOR THAT TENANTS VIOLATION OF THE LEASE. IF THIS IS A JOINT AND SEVERAL LEASE IT MEANS THAT ALL THE TENANTS .AS A GROUP AND EACH OF THE TENANTS AS AN .INDIVIDUAL ARE RESPONSIBLE TO LANDLORD FOR ALL OF THE AGREEMENTS OF THIS LEASE. FOR EXAMPLE, IF THE RENT IS NOT PAID, LANDLORD CAN SUE ALL OF THE TENANTS (JOINTLY) FOR ANY UNPAID RENT. OR, LANDLORD CAN BRING A SUIT AGAINST ANY ONE TENANT SEPARATELY (SEVERALLY) FOR ALL OF THE UNPAID RENT. TENANT VIOLATES THIS LEASE IF TENANT: 1) FAILS TO PAY RENT OR OTHER CHARGES TO LANDLORD ON TIME OR, 2) LEAVES (ABANDONS) THE LEASED PREMISES WITHOUT THE LANDLORD'S' PERMISSION BEFORE THE END OF THE LEASE OR, 3) DOES NOT LEAVE THE LEASED PREMISES AT THE END OF THE LEASE OR, 4) DOES- NOT DO ALL OF THE THINGS THAT TENANT AGREED TO DO IN THIS LEASE. IF TENANT VIOLATES THE LEASE ,EACH TENANT AGREES TO WAIVE NOTICE. TO QUIT. THIS MEANS THAT THE LANDLORD MAY FILE A COMPLAINT IN COURT ASKING FOR AN ORDER EVICTING' EACH TENANT FROM THE LEASED PREMISES WITHOUT GIVING EACH TENANT NOTICE TO QUIT FIRST: LANDLORD DOES NOT HAVE THE RIGHT TO THROW TENANT OUT OF THE LEASED PREMISES (SELF-HELP EVICTION). THE LANDLORD CAN ONLY EVICT TENANT BY COURT ACTION. THE LANDLORD DOES NOT HAVE THE RIGH~t SUE IN COURT FOR x EVICTION UNLESS A TENANT HAS VIOLATED THE AGREEMENTS IN THIS LEASE. EVEN THOUGH EACH TENANT IS WAIVING NOTICE TO QUIT, EACH TENANT WILL HAVE A CHANCE IN COURT TO CHALLENGE THE LANDLORD'S CLAIM FOR EVICTION. IF TENANT VIOLATES THE LEASE AGREEMENT, THE LANDLORD MAY SUE EACH TENANT IN COURT: 1) TO COLLECT OVERDUE RENT, LATE CHARGES AND MONEY DAMAGES CAUSED BY TENANT'S VIOLATION OF THE AGREEMENTS IN THE LEASE. 2) TO RECOVER POSSESSION OF THE LEASED PREMISES (EVICTION). 4 3) TO COLLECT FOR UNPAID- RENT UNTIL THE END OF THE LEASE OR UNTIL ANOTHER PERSON TAKES POSSESSION OF THE LEASED PREMISES AS A NEW TENANT. Tenant agrees that landlord may receive reasonable attorneys fees as part of a court judgment in a lawsuit against tenant for violation of the agreements of the lease. 18a. HOLDING OVER uNL ESS E/7NE~ T~N~4NT oR L,gND~o~ G/~'ES i7/E~ oT~S'~/'r ~o DfF{/S /1'b77~E OF riYTE7VT To CH.¢/y6E 02 i~/ir'/fT~' TiY6'L~ /7' SH9~L .FSc D~~ ~ BS ,S~GG/~E7YYEwjNb orr/ ~ /Gto~f/i// To ~lovT~Y~•9s/s. 19. OTHER AGREEMENTS BETWEEN LANDLORD AND TENANT Landlord and tenant agree that: CT/2NNT~R~y-IA~LLNE~,pj-fSALLOWED-cCNCESS Lv,~/77~7/ Pte////SS/oN /S 20. LANDLORD'S LEAD BASED PAINT DISCLOSURE ATTACHMENT (LPDA) IS ATTACHED HERETO AND IS PART HEREOF. Receipt whereof is acknowledged by our signature hereon. Laced/or.~ h¢s /to ~inw/~9e a{aity ~aa//Qxo~~ii~f ire r TEN/}NT /~G2~~ T P~4Y ONE ~kT/1f1 !??DNTNS /ZEJV? .fr--T %h~F SS/6/Y/~1'G /Yr7ZE~ BY SIGNING THIS LEASE AGREEMENT, EACH TENANT AGREES'~~ THAT TIDE TENANT HAS READ AND UNDERSTANDS ALL OF THE AGREEMENTS IN THIS LEASE. DATE SIGNED BY LANDLORD: t5 ' ZS ~ ~ ~ ~.r y19~Y. C~NOLoav .SN/tLf TitfiLS At,~v/fYs ,~F vNE ~p/VTy ANT /il/ ffav~CF As /f- S~f=~7y C/~.sH/oil LANDLORD: ~` ~ _ f, ~ , r~ DATE SIGNED BY TENANT(S): ~ - ~ J TEN.A.NT(S): .~- ~ J~~2Ey CoD,t , as doy~.ea~~ ~iaa hee.~ ~a~%re~s ~ ,~.-sotia// ~~zrrz.,re ,~~y/~e~t ~ eac~r nroh~i s /ref f,~ ~~nd~rsfitna's ~f ,~;s means :>~h~.s ~r.,ar~/ /'e~1.tSes ~ ~~' }~ /-c°r7f o/' iS unah/e ~ ~a~ die re.~f l~r arzy ~°~rsoir fie rs OLLb/~RfeA/ asQ,~ara~1`o~- ~ ~.~~ ~f ~o ~s awe ds ~~~ r~u9~ fre /11a y /10f hc~ ~ lea a ~ f a /` ~ /Si~u. / ? ~ooK e rme orces, is o e e CHARLES E. SHIELDS, III ATTORNEY-AT-LAW 6CLOUSERROAD Corner ofTrindle and Clouser Roads MECHANICSBURG, PA 17055 GEORGE M. HOUCK (1912-1991) June 6, 2001 TELEPHONE (717) 766-0209 FAX (717) 795-7473 To: Valerie Hrubachak and the other occupants of 99 West Portland St., Apt 2 Copy via certified mail to Jeffrey Look, guarantor Dear Ms. Hrubachak: Please be advised that I have been instructed by my clients, Norman F. Wright & Suzanne C. Wright, his wife, your landlord, to advise you that you must vacate the premises by midnight June 30, 2001 . The agreed terms of the new lease were that three (3) months rent were to be paid immediately. Upon request by Mr. Look, the period was extended to the 5th of June, 2001 ,which has now come and gone. Also, the list of the occupants likewise has not been furnished. Thus, the agreement has not been fulfilled. Mr. & Mrs. Wright could give you a shorter period than the 30th, but will give you the entire month. However, if you do not vacate the premises as directed, the Wrights will take legal action to compel you to do so and will seek attorney's fees in connection therewith. Thank you. Very truly yours, _ r ~.r!yrr'a_'v ~ LV r~ Norman F. Wright, for hi self and for Suzanne C. Wright, his wife Charles E. Shields, III J EXHIBIT B ..~~„ AFFIDAVIT OF SERVICE I, the undersigned adult individual, having been duly sworn upon my oath state that I did serve a copy of the attached letter notifying tenant to vacate the premises upon ~' ~ t _2l G. L~-n_y?~ ~cf~ K. ,the Tenant, by personally handing him/her a copy of said letter at the Leased Premises, 99 West Portland Street, Apartment 2, Mechanicsburg, Cumberland County, PA on 7 J iJ.N v d 1 , at i CLr- ~, ~ "'~.. Subscribed and sworn to before me the Undersigned Notary Public on the _~ day of , ~. My commission expires: Notarial seal Charles E. Shields III, Notary Public Monroe Twp., Cumberland County My Commission Expires June 20, 2004 Member, Pennsylvania Pssociatfon of Notaries i VERIFICATION I verify that 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. § 4904 relating to unsworn falsification to authorities. Norman F. Wright Date:~u~ , 3~ , 2001 LAW OFFlOES SNELBAKER. BRENNEMAN & SPARE CERTIFICATE OF SERVICE I, PHILIP H. SPARE, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Complaint to be served upon the person and in the manner indicated below: FIRST CLASS MAIL POSTAGE PREPAID. ADDRESSED AS FOLLOWS: Valerie Hrubachak 99 West Portland Street Apartment 2 Mechanicsburg, PA 17055 Philip .Spare, squire Snelbaker, Brenneman & Spare, P.C. 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055-0318 (717)697-8528 Attorney for Plaintiffs Norman F. Wright and Suzanne C. Wright Date: ~~'jp,2001 LAW OFFICES SNEL6AKER, BRENNEMAN & SPARE Y NORMAN F. WRIGHT and IN THE COURT OF COMMON PLEAS OF SUZANNE C. WRIGHT, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO: 01-4658 CIVIL TERM vs. LANDLORD/TENANT VALERIE HRUBACHAK, APPEAL FROM DISTRICT JUSTICE Defendant PRAECIPE TO TERMINATE SUPERSEDERS TO: THE PROTHONOTARY AND NOW, come the Plaintiffs, Norman F. Wright and Suzanne C. Wright by their attorneys, Snelbaker, Brenneman & Spare, P.C., and respectfully requests you to terminate supersedeas in this matter based upon Defendant's failure to deposit with the Prothonotary a sum of money equal to the monthly rent which becomes due the period of time the proceedings upon appeal are pending. Since this appeal was originally filed on August 3, 2001, Defendant has failed to make the required rent payments. Kindly mark the supersedeas in this matter as terminated and pay the deposit of rental to the Plaintiffs, Norman F. Wright and Suzanne C. Wright. Respectfully submitted, SNELBAKER, BRENNEMAN & SPARE, P.C. By LAW OFFICES SNELBAKER. BRENNEMAN & SPARE Date: September 5, 2001 September 5, 2001, Upon confirmation of failure of the appellant to deposit the monthly rent for more than thirty (30) days, the supersedeas is terminated. Philip"H. Sp',~re, Esquire Supreme Court ID No: 65200 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055-0318 (717) 697-8528 Attorneys for Plaintiffs Norman F. Wright and Suzanne C. Wright Curtis R. Long, Prothonotary .. r i CERTIFICATE OF SERVICE I, PHILIP H. SPARE, ESQUIRE, hereby certify that I have on the below date, caused a copy of the foregoing Praecipe to Terminate Supersedeas to be served upon the person and in the manner indicated below: FIRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Valerie Hrubachak 99 West Portland Street Apartment 2 Mechanicsburg, PA 17055 Philip H. pare, uire Snelbaker, Brenneman & Spare, P.C. 44 West Main Street P.O. Box 318 Mechanicsburg,PA 17055-0318 (717)697-8528 Attorney for Plaintiffs Norman F. Wright and Suzanne C. Wright Date: September 5, 2001 LAW OFFICES SNELBAKER, BRENNEMAN & SPARE ,_ NORMAN F. WRIGHT and SUZANNE C. WRIGHT, Plaintiffs vs. VALERIE HRUBACHAK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 01-4658 CIVIL TERM LANDLORD/TENANT APPEAL FROM DISTRICT JUSTICE ORDER OF COURT AND NOW, this ~ day of 1, upon consideration of Plaintiffs' Motion for Release of Escrow Account, it is hereby ORDERED and DIRECTED that the Prothonotary of and for Cumberland County, Pennsylvania shall release the $926.50 being held in escrow in this matter to the Plaintiffs, Norman F. Wright and Suzanne C. Wright. BY THE COkJRT, J. V~'~' n ~~/, 55 LAW OFFICES SNELBAKER. BRENNEMAN & SPARE tiiMv7~l,8\N3~ (!' ~Gu 'J i-f~ ~~:{ ;`;i ,~~~~L ~~ ~ I_~ .~ ~ _ NORMAN F. WRIGHT and SUZANNE C. WRIGHT, Plaintiffs vs. VALERIE HRUBACHAK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 01-4658 CIVIL TERM LANDLORD/TENANT APPEAL FROM DISTRICT JUSTICE MOTION FOR RELEASE OF ESCROW ACCOUNT AND NOW, come the Plaintiffs, Norman F. Wright and Suzanne C. Wright, by their attorneys, Snelbaker, Brenneman & Spare, P.C., and file the within Motion based upon the following: On or about August 3, 2001, Defendant Valerie Hrubachak filed a Notice of Appeal from the underlying District Justice matter. 2. Pursuant to the applicable Rules of Procedure, Defendant paid $926.50 to the Prothonotary at the time of the filing of her August 2, 2001 appeal. 3. The Defendant failed to make the required rent payments to the Prothonotary during the pendency of this case, resulting in the undersigned counsel filing a Praecipe to ,Terminate Supersedeas on September 5, 2001. A copy of said Praecipe to Terminate is attached hereto as Exhibit A and incorporated herein by reference. 4. The District Justice issued a new Order for Possession and Defendant has now LAW OFFICES SNELBAKER. BRENNEMAN & SPARE the rental property. Plaintiffs are entitled to return of the $926.50 held by the Prothonotary pursuant to R.C.P.D.J. No. 1008. WHEREFORE, Plaintiffs Norman F. Wright and Suzanne C. Wright respectfully request your Honorable Court to order and direct the Prothonotary of Cumberland County to release the amount of $926.50 being held in escrow in this matter to Plaintiffs. Respectfully submitted, SNELBAKER, BRENNEMAN & SPARE, P.C. By: 'lip H. Spaz ,Esquire Supreme Court ID No: 65200 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055-0318 (717)697-8528 Attorneys for Plaintiffs Norman F. Wright and Suzanne C. Wright Date: September ~ ~ , 2001 LAW OFFICES SNELBAKER, BRENNEMAN & SPARE -2- NORMAN F. WRIGHT and IN THE COURT OF COMMON PLEAS OF SUZANNE C. WRIGHT, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs : NO: 01-4658 CIVIL TERM vs. ~, ~:_ LANDLORD/TENANT `-_ ~.~ VALERIE HRUBACHAK, ~=''~:. APPEAL FROM DISTRIC"P7USTI~E - Defendant =~ PRAECIPE TO TERMINATE SUPERSEDERS ~> `• TO: THE PROTHONOTARY ~'"~'"""~'~ f' -. AND NOW, come the Plaintiffs, Norman F. Wright and Suzanne C. Wright by their attorneys, Snelbaker, Brenneman & Spare, P.C., and respectfully requests you to terminate supersedeas in this matter based upon Defendant's failure to deposit with the Prothonotazy a sum of money equal to the monthly rent which becomes due the period of time the proceedings upon appeal are pending. Since this appeal was originally filed on August 3, 2001, Defendant has failed to make the required rent payments. Kindly mark the supersedeas in this matter as terminated and pay the deposit of rental to the Plaintiffs, Norman F. Wright and Suzanne C. Wright. Respectfully submitted, SNELBAKER, BRENNEMAN & SPARE, P.C. By: LAW OFFICES $NELBAKER. BRENNEMAN 8t SPARE Date: September 5, 2001 Philip"H. Sp'afe, Esquire Supreme Court ID No: 65200 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055-0318 (717)697-8528 Attorneys for Plaintiffs Norman F. Wright and Suzanne "C. Wright Exhibit A Page 1 of 2 CERTIFICATE OF SERVICE I, PHILIP H. SPARE, ESQUIRE, hereby certify that I have on the below date, caused a copy of the foregoing Praecipe to Terminate Supersedeas to be served upon the person and in the manner indicated below: FIRST CLASS MAIL POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Valerie Hrubachak 99 West Portland Street Apartment 2 Mechanicsburg, PA 17055 Philip H. pare, uire Snelbaker, Brenneman & Spare, P.C. 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055-0318 (717) 697-8528 Attorney for Plaintiffs Norman F. Wright and Suzanne C. Wright Date: September 5, 2001 LAW OFFICES SNELBAI(ER. BRENNEMAN & SPARE Exhibit A Page 2 of 2 CERTIFICATE OF SERVICE I, PHILIP H. SPARE, ESQUIRE, hereby certify that I have on the below date, caused a copy of the foregoing Motion for Release of Escrow Account to be served upon the person and in the manner indicated below: FIRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Valerie Hrubachak 99 West Portland Street Apartment 2 Mechanicsburg, PA 17055 LAW OFFICES SNELBAKER. BRENNEMAN & SPARE Date: Septembers ~ 2001 Philip .Spare, squire Snelbaker, Brenneman & Spare, P.C. 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055-0318 (717)697-8528 Attorney for Plaintiffs Norman F. Wright and Suzanne C. Wright ~~ C~ L ._ _~ ~'°' r ry G~''~~;~ '"3 r r- n ~_- "T (-~ L-t yi ~ _ t,} ~.~ ~. ' (.__ ~;i L 1 `. -~ _ r':i 7.J „'~ __ '1' ~i l`_,1 r~~ _~ -C