HomeMy WebLinkAbout01-05256ORCHARD APARTMENT, IN THE COURT OF COMMON PLEAS OF
t/d/b/a ORCHARD APARTMENTS, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
TANISHA DENNIS
Defendant
CIVIL ACTION - LAW
01-5256 CIVIL TERM
AND NOW, this 24th day of September, 2001, upon
consideration of the complaint filed in the above-captioned matter
and following a hearing, the record is declared closed and the
matter is taken under advisement.
Jordan D. Cunningham, Esquire
2320 North Second Street
Harrisburg, PA 17110
For the Plaintiff
Tanisha Dennis, Defendant Pro Se
2202 D Cedar Run Drive Extended
Camp Hill, PA 17011
pcb
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By the Court,
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A~' f ~ ~ ~ ,,,~ ~~„ .. ~.
CHARD APARTMENTS ~ ~ ''r
'"""'"'"-""" `^""""' r RESIDENTIAL LEASE AGREEMENT '
+. PARTISSAxoowEtL+NCUxLT: ORCHARD APARTMENTS
Tha parties to this Agreement aze , rererre0
to as me Landlord. antl DENNIS TANISHA , referred Io
as the Tenant. The Landlord leases to the Tenant unit number 22 0 2-D CEDAR RUN
located at 2201 CEDAR RUN DRIVE, CAMPHZLLr PA 7?Oli
in the pfojed known as
GHCHARD APARTMENTS
1. LENGTH OF TIME RERM):
• The initial term of this Agreement shall begin pit FEBRUARY 11 r 2000 and and on
MARCH 31 , 2 001 .Attar Ne initlal term ends, the Agreement will wntinue Tor sumeasWe terms
of one MONTH each unless automatical terminated as
ty permidetl by paragraph 23 al (hu Agreement.
]. RENT:
The Tenant agrees to pay E 19.0 0 for the partial month BMing an 2-2 9-20 0 O , q(tar that, Tenant agrees to pay a rent of
E 31.00 per monla. Tau amount is due on the FIRST day of the month at 2204 CEDAR RUN DR.
_CAMPHILL, PA 17011 RENTAL OFFICE
The Tenant understands that Ines monthly rent is IeSa than the market (unsubsidized) rant due on this unit. This lower rent is araAade aimer because
the mortgage an Thu project la aubsidhrM by the DeparuneM pl Housing and Urban Devebpmenl (HUD) and/or because HUD makes rmnlhty pay-
ments to the Larbbrtl on behad al Me Tenan4 The amount it arty, That HUD makes avallade mOnlhty on behalf of Ne Tenant Is celled the temm _
assistance payment and u snovm On ma "ASSiatanpe PeymMP aria of me r`+nd~.•non ant Reperelkaflon of Tenanl~l'nih'IM Form which B
_ Attachment No. 1 to 1hi4 Agreement.
4. CHANGES IN THE TENANT'S SHARE OF THE RENT:
The Tenant agrees Thal the ampunl of rent the Tenant pays and/or Ina ampunl of assisnnc0 Thal HUO pays on bBhall of the Tenant may DB Manged
during the term of mis Agreement il:
a. HUD or the Cpn(ract Atlminisualor (such as a Pudk Mousing Agency) determines, in accordance with HUD procedures, foal an increase in
rents is neetletl:
o. HUD pr the Contract Administrolor Menges any allowance for utilities or servkes considered in computing the Tenant's share of the rent;
) c. The income, the number of persons in the Tenant's.twusehoW or aNer laden cpnsideretl in calculallrg the Tenanys rent Mange and HUD
procedures provide that the Tenant's rant a assistance payment ae a0)usted to relied Na Mange;
' tl. Caanges in me TemaM's rent w assiatanoe paymenl'ara requ'aed ty HUD's raparliBWlipn or Subsidy termination procedures;
• e. HUD's Procedures for wmputing Ne Tenant's assutara;e payment of rent Mange: or
I. Tae Tenant tails to pravitle Inbrmalbn an hismer irvome, remit' composXbn or other tailors as required oY the Landlord.
The Landlord agrees to implement Merges in the Tenants rent or tenant assunrlce payment only in accoMance with the time Irames ant admin-
istrative procedures set br(h in'HUD's handbooks, instrucWre ant reguladona related to atlmbisaadon of mullMamay subsidy programs. The
Landlord agrees to give the Tenant al least ]0 days atlvar(ce wrigen nolke of arty Increase In the Tenants rent esCapl as noted b paragraphs t 1,
f 5 or 77. The Notice will stale tae new amount the Tenant is required to pay, Ne dale the new ampunl is allecllve, and (Ile reasons br the change
in rent. The Notice will also advise the Tenant Nat aB/5he may meat wish NB LandbrO to diswss Tha reel change.
5~ CHARGES FOR LATE PAYMENTS AND RETURNED CHECKS:
II me Tenant dyes not pay the hAl amount on lea rent shown in paragraph 3 by the end d Tha Slh day d the manor, ma LaMllaM may maect a lee of
E20.00 an the 61h day pl tae nanN. Thareaker, the LaMlwtl may calbd Et a day altar da ZON day of tae monN for each addilllwl day Ne rent
remains unpaid during Ore rtronN. Tae Landlord may not Mrrninare thu Agreement for Ne fa3are ro pay laze Merges, but may temanare tlruAgreemenl
lornon-payment d rent, as exptained'm paragraph 2]. Tae Landlord may mmtd a lee of E~ 5 .0 0 on the tint or arty atldillbnal Ihne
a Menk is not hprgretl far payment (bounces). Tae charges discuued in this paragroptl are in addigon ro the regular monthty rent payable by the
Tenant.
6• CONDITION OF DWELLING UNR:
By signing this Agreement, the Tenant admowledges that the unit u sale, dean antl in gootl condition. The Tenant agrees Thal all appliances and
equipment in (tie unit are in gootl working order, except as dascnbetl on Tha UnN Inseecfien Renon which is AaachmMl No.2 to Isis Agreement.
The Tenant also agrees that the laMlorO has made no promises to decprote, alter, repair ar improve me uML azcepl as lisletl on the I ba In•md'mn
BBg4[L
7. CHARGES FOR UTILITIES AND SERVICES:
The bllowing charts describe how the mat of utilities arN sarvbes related to oaupanq of the unX witl be paid. The Tenant agrees (hat these charts
accurately tlesvi6a ma utilities ant services paid by the Landlord antl those pant by Tae Tenant.
a. The Tenant must pay br tae utilities in column (7 ). Payments should ba matle diractty to the appropriate utility wmparry. Tha items In coumn
(2) are included In Ina Tenant's rent:
(tl l2)
Pul "X" by any Ullllry Put "X" by any Utlllly
Tenant Paya Directly Type of Utlllly Included In Tenant Rant
B. SECURITY DEPOSITS:
Heat ....................................................
Light. Elrxtnc ....................................
Capkirg ...............................................
Other (Spedry) Trasn, Sewage..........
All Uuliy Hpok-up4
PLAINTIFF'S
EXHIBIT
~~
The Tenant has deposited S 9 / • U U wrtn the Landord. Tae tanAbM oval aob tMS secwity deposit for the period tae Tenant
pmu0~e5 the unit. Atler Ina Tenant has moved from Ina unit. Ina Untllortl wtll determine whether the Tenant i5 91giWe far a reluM of any or all of
Tha security Oeposlt. The amount of Tne refund will be dalermmrM in accoroanc0 with the bllowirg wntlitiona and procedures:
a. Tne Tenant will oe eligide br a relurW of the security depovl only if the Tananl prowdad the Ldrldlore with 1hB ]0-day written notke of intent to
move requred W paragraph 23. unless foe Tenant was unade to give the n01be br reaspna beypnd hislher cnnlyd.
b. Alter Tne Tananl nay moved Irom the unit Tne Landlord will inspect Tne unit and complete anpther Unit Inseection Reoprt. The Landlord will
perms Tne Tananl to paracipale m ;he inspection, d the Tenant so requests.
c. Tne Landlord wJl refund to Tne islnant the ampypl pl fbV ;@£unly deppSlt IRlub ~MerV;l computed at .,
WI cnarges br Wta payment of rk.., antl reNrned MBCW. as dBSwi08tl in peragraptt 6: arw
cal cnarges br unremrned keys, as deun0ed in paragraph 9. '
d. Tne Lantllortl agrees to refund roe amount computed in paragraph & within days aver Ina Tenant has permaneMy moved
out of the unn, returne0 possession of Ina unit to the Lantllortl, arW give hismer new address b the Lantlortl. The LarM10M wiX also give the
Tananl a wrnlen list of cnarge9 That were Su0tracte0 Irom TDB deppsit. II IDe TBNnf dlsayees wiN Tne Lantllortl Cdncerning Ina amounts
deducted antl a9k5lo meal with fhe landlord, Ina Landbrtl agrees ro meal whh the Tananl and inbrmalry discuss Ina disputrq charges.
e. II Ina unn is rented by more Than one person, the TBdanW agree that may wgl work out the tlaWils of drvblrp arty reluM among tlremseMS.
Tne Larblord may pay the reluM t0 any Tenant identified in parregrapn 1 OI Ihi3 Agreement.
I. Tne Tenant underetantls that the Landlord wig not count the Secuny Deposit rowards the last month's rent or towaN repak charges owe0 by
fhe Tenant in accortlance with paragraph 1 t.
9. KEYS AND LOCKS:
The Tenant agrees not to inslarl atltliti0nal w tlillerenl locks or gates On arty doors w wlMOws of the antl wilhow the wriaen permission of the
Landlord. II the Landlord approves the Tenant's request to install such IOCBA IhB Tenant agrees ro provitle the Laddord with a kry br Bach kxk.
$ hen t95. Aga ement ends. the Tenant agrees to return all Ney9 to Ne tlwellirg oral ro the Landbre. Tne LarMbN may Marge Ina Tenant
6 br each key not rebrned. (Not ro mcsetl what bcksmiN Merges for eats key rwl reNrned.)
10. MAINTENANCE:
Tne Landlord agrees ta:
1 t) r¢gularly Clean all common areas 01 the project:
(21 maintain the common areas ant facilities in a sale wMilion;
(7) arrange br conedton antl removal o11raM ant garbage;
(a) mamlain all equipment and appliances In sale antl working order,
(6l make necessay repaks with reasonade promptness:
(6) maintain eaterbr IgDUnq in good worlurp oMer;
PI provioa eatarmination servkes. it necessary; arq
(el maintain grourMS arw shrubs. _
The Tananl agrees lo:
(t) keep the unit clean;
(2) use all appliances. fixtures antl equipment in a sale manner and only br the Wrposes for which IDry era inlentled:
(7) not tiller the grountls or wmmon areas of the project;
(4) not destroy, deface, damage or remove any part of the unit, wmmon areas, w protect grounds;
(61 give the Lantllortl prompt notice of any detects in the plumbing, fixtures, appliances, heating and coolirp equipment or arty other part of
Ina unit or related facilities: antl
(61 remove garbage ant other waste Irom the unit in a Uean and sate manner.
11. DAMAGES:
Whenever tlamage is caused by carelessness, misuse. or neglect on the part of the Tananl, hi9mer lamlly or vuhore, the Tenant agrees to pry:
a. ReasOnaNe charges for all damages to the premises (including equipment and/or appliances supplied to the premises) and reasoneNa Marges
lOr damage to the project W ibings, facilities, w common areas negfyantly or intentionally cawetl by Tananl w Tenant's household or quests.
Said charges are to be matle aaOMing to Ina current Schedule of Mainrenanee Charoea oosta8ln the Management OKke, antl Tenets agrees
that payment of all such Merges Shall be made within Thirty (70) tlaya of the date Maryes are biged.
b. Rent for the period the unit i9 managtM whether w not IDe unit is habitable. The Tenant unaeretarMs that HUD will no~ make asaislarxe pap
ments for any period in which Tne unit is hat habitable. Far any such period, Ne Tenant agrees to pay the HUD-approved market rent reNer dtan
IDe Tananl rent shown in paragraph 3 at this Agreement.
12. RESTRICTIONS ON ALTERATIONS:
The Tenant agrees ml to do any of the lolbwing wilhpul firs) Mlaining the LaMbM's written permission:
a. Mange or remove any pad of the appliances. futures Or equipnanl in th ung;
b. paim or install wallpaper w Wn1aU paper in the unit;
c. octant awnings w wirMOw guards in Ne unit:
tl. anacn w place any fixtures, signs, Or fencas on the buibing(s), Ue cpmmon areas, w the project grounds;
e. at1aM any Shelves. saaen doors. w other permanent improvements in Ote unit;
f. install washing machines, dryers, tans healers w air mMgioners in Ne unit; w
g. place any aerials. antennas or Other electrical cannectbns on Tne unit:
h. nO water beds.
17. GENERAL RESTRICTIONS:
The Tenant must live in the unit and the unit must be Tne Tenant's ony place of resitlerre. The Tananl shall use Ne pemise9 ony as a privaro
dwelling for nimsellmersell antl the indvitluals fi5letl on the Cerlfication ant Redang'tcafmn of Tananl Elimhillrv, TM Tananl agrees b permit other
intlivitluals to reside in the unit onry after obtaining the prior wrigen approval of the LaMbM. The Tenant agrees rot to:
a. sublet or assign TDB unit. or any part of the unit:
0. use the unit tar unlawful purposes:
c. engage in or permit unlawful atlivilies in the unit. in IDe camman areas ar On the project grpuMs:
d. have pals or animals of any kind in the unit without the prior wriden permsson of Iha Laupord; or
e. In IDe event that during the term of Ne lease the Tenant should require the a55i9lanca of a Liva-imAitle. in acwrtlance with the HUD
Regulalion9, the aide shall not be allowed Ip remain in occupanry shouts Tne Tananl terminate this Lease Agreement mr shall the Liva-in-Aitle
have rights to survivorship of the unit.
I. Nolw~thSlandinq any other provision of This lease, Ina Tananl, members of the Tenant's hous0nob, guests Of Tananl and other persons under
Tenant's control shall not engage ~n unlawful actNity, including Orug~relatetl criminal ackviry, in the Tenant's unit w on Ne projeU premises, ant
such unlawful activity shall be Cause for termination 01 tenanry.'Orug-related cflminal aUwily' means Ih0 illegal manulaCture. 9818, dlslriDution,
use ar possession of a conlralled substance a9 defined in Section 102 of gre Uniletl Stales Controlletl Substances Act, 21 U.S. DOdB $BCII0r1
602. Criminal conviction under Federal, slate Or local law shall not be a preWMilbn br terminalbn 01 Tenancy.
g. Tenant shall not pursue or rnntluct arty W SinesS on Tne premises, nor shall Tenant display any signs of any type of tlescdplbn.
n. Tananl shall retrain Irom and cause Tenant's househob and guests la retrain Irom desvoying. tlelacing. damaging, or removing any part of the
premises of project.
i. Tenam shall not create ar permit arty disturbing noises in or about Tenant's dwelling unit Dy himselL his family. or guests: nor shag he, his family,
or guests imerelere wnn or materially diminish Tne riynts, comforts, or convenience OI other Tenant's pr gurroundirg neghbors. NMlher the
Tenant. his family, nor his guests shall engage in any activity that would rnnstitute an offense against persons, property, Wdlc ortleA or pudb
health or decency. Or that Involves fraud, deception, firearms. or olhen weapons.
1. Tenant Shrill np( fBIU9B IhB BxlBrmin811p0 98fvK¢9 lpr trident pr in9Bpt inIB9IalI0o.
k. II neat is Io be supplied by the Tenant, Tenant agrees to execute a Inud party notiliwtion with Lantllortl, whereby the LaMlore will be brmyly
nehnetl prior to the tlisconlinuanCB of utility servwe by Iha utility supplies Tananl agrees Ip famish 9uflicienl heal to Ne premises to prevent
Damage to the Oremises. II, for any reason, Tenant is unable to mainlam sulliUenl Deal Tenant shall immediatay noliry Landlord. Tananl shall
pay for any damages to me amt resulting Irom Tenant's negligent Or imemional failure to maintain sudkient neat or to notiry Landbrtl 01 the lark
pl sull¢ient neat Due t0 any cause beypnd Tenant's conlrpl.
I. Tenant agrees to comply wnn Landlord pplipes and dnecuves, as wall as IDe regulations ant laws of all Federal. slate. municipal and feral
governments regaroing Tne ccileceon, sorlmg, separauon and racytlmg of waste products, gamage, refuse and Irasn.
to RULES:
The Tenant agrees to obey the House Rules whbh are AtrecDment No.3 ro Mi9 Apraemanl. Tha 7enanl agrees t0 obey additional Klee Bsladishetl .
alter Ise eoective Dale 01 Ibis Agreement il:
a. Ine rules are reasonady relaletl to Ine salary, care and deanliness of Me builtlMq and Me salary, dombrt and wmrenienca of the tenant; antl
0. ine Tenant reserves wnnen police OI the proposed rule at least INrty (30) days before Ine rule is enhuced.
15. REGULARLY SCHEDULED RECERTIFICATIONS:
Every year around Ine FIRST day al NOVEMBER Ine Lanaortl wig rpuest ine Tenant to repel Me irmama
and compos~tan of ine Tenant's nousanaltl and to supply arty ether inbrmalion required by MUD br Ine purposes of delarminng me Tenant's rent
and a35i51ahce payment it any. The 7enanl agree4 IO pravitle acarrete adieman4 al INS inbrmali0n end to do so by' IM date specigetl in Ine
Landlord's request The Lanaortl will verity Iha inbrmalion supplied by the Tenant ant use MO verified inlamatbn Io recompute dro amount a Ina
Tenant's rent and assistance Daymenl, if any.
a. II ine 7enanl does not submit Ine required celafiWiial inbrmalion by Ina date Spedlied in Ine lzna0rd§ request. the LanaoM may impo68IM
following penanies. Tne Landlare may implement MBSB penalties only in attoreallCg vnlh Me atlminisUDiive procedures and Time dames
specilietl ~n HUD's regulations, handbooks and instructions raatetl to the aaminiatratbn of multi-lemiry subsidy programs.
(t) Require Ine Tenant tO pay the nigneq HUD-approved market rent br the unit.
(T) Implement any increase in rent resulting Iram Me recartilicaeon processing witnem provbing Me 30-day mite otnarvdse required by
paragraph 4 of IDis Agreement.
o. Tne 7enanl may request to meet wiM the Landlord b discuss arty Mange in rent ar asstsfance payment rewlDlp from MB recertgicaiion
processing. II Ine Tenant requests such a meeting, Ine Lantllore agrees to meet with Ine Tenant arld d'awss how the Tenant's rent and assis-
tance payment. it arty, were computed.
16. REPORTING CHANGES BETWEEN REGULARLY SCHEDULED RECERTIFICATIONS:
a. II any of IDe Wlbwing changes ~q<cer, IDe Tenant agrees Io advise ma LarMbre immeaelely:
(1) Any h0uSanoW member moves oN 01 Ma unit.
(T) My adun member of the household who was reportetl as unampby,M on ma most recent certifieatbn a recardliragon obmirrs ampby-
meni.
f31 Tne Musehoftl's irkome cumulalivary increases by f40 or more a manor.
b. The Tenant may report am/ decrease in income pr arty change in other tadofs mnsbered in calculating me Tananl§ rent Unless Me LanObrtl
pas cOnlirmalion Ihal IDs decrease in income Or change in slier latlore wig IaSt lass Ihan one monM. Iha Wntlbrd wig venry dN inbrmalion
and make :he appropnale rent reduction. However, it Ih0 Tenant's iMOme will ba parllaly or lolly restored wgllin Iwo monW. g10 Len0lare may
delay Me <ertilication process until the new income o known, but me rent radudion will M relroadiw ant the l.antlbN mry not avid me Tenant
lOr nonpayment of rent due during the period of Me reported decrease ant Me completion of Ma certgicauon process The Tewn has Miry
(30) Days agar receivirp written police of any rent due br Me above described time periotl to pay a IDe Landlom ran avid br nonpayment of
rent. IReviseti 32?/89.)
c. II the Tenant does not advise the Landlord of these interim changes, the landlord may inuease me Tenant's reel to Me HUPapprovetl marWt
rent. The larldbrd may ao so only in aaordarlce wgn the time Irames arW atlmiMSiradva procedures sal kxM M HUD's ragulatons, RaMbooks
antl instrucdons on the atlminis(ration of multidamily wbsidy programs.
d. The Tenant may request to meet with Me Largbrd to tlisau how any Change in income or other feddm agectea hismer rant a assistance
payment, a any. If me 7enanl requests such a meeting. Me tantliord agrees to meal with the 7enanl and ekplain hoe the Tananys rent a assig-
tance payment, it any, was camputetl.
17. REMOVAL OF SUBSIDY:
a. The Tenant urWerstantls mat assistance made available on hislher behalf may be lerminaletl it events in eimer~ilems (1) or (T) below Occur.
Termination of assistance means oral the Landlord may make the assistance available to another Tenant ant Ih0 Tenant's rent wig be recan-
puled. In adtlition, it the Tenant's assistance L5 ierminaled because al uiterbn (I) below, Me 7enanl wig be required to pay Iha HUD-approved
market rent mr Ine unit.
(/) The Tenant OoeS not provitle the LarMlord wiM the inbrmalion or report required M paragraph 15 or 16 wghin ten (t0) calendar tlays
abet receipt of the LarWl0rtl's polka or intent Io Ierminat0 IDs Tanant'S asslSWMa payment
(2) The amount Ine Tenant would De required to pay Iawartls rent ono ualiges under HUD rules and ragulaaons squab the Family Gross Renl
shown on Attachment 1.
b. TDB lantllortl agrees Io give me 7enanl written n0lice of Iha proposed Iarminagon.The notice wig advise Me 7enanl oral, during Me tan (10)
calendar Days bibwing the tlate of the police, he/ene may request to me6l wgh the Landlord to dluusa me proposed termination of assuilanq.
11 Ine Tenant requests a tliwusslon of me proposed terminadon, the Larldldrd frees b meet wgn Me 7enanl.
c. Termination of assistanc0 shag not arced me Tenant§ oilier rights urMer mis Agreement, IMWtlirrg tM dgtH re axupy ttre und. AssrsMrxx may
subsequemly Da reinstated if me Tenant submits the income or other dew required by HUD procedures, me LaMbrd tlelarmines me Tenant is
eligide for assistance, and assistance is availabe.
1B. TENANT OBLIGATION TO REPAY:
0 the Tenant wbmits false inbrmalion on arty applicatbn, Certification or request for interim adlustmant a does not report interim changes in farrliry
income or other Yxnors as required a/ paragraph 1g of Inis Agreement, and as a rewg. is dlarged a rent K9s Bran gie amount reglreatl by HUD§
rent formulas, the Tananl agrees IO reimWrse ma UMIOM br Me tlitterence DeDwean dle rent he/SM should have paid ant ells rant hehlla was
charged. Tne Tenant is not required to reimburse the LaMIOM for urMercharpea caused solely by Me LaMWrd's h9ure b below HUD§ procedures
for Computing rent or assistance payments.
19. SIZE OF DWELLING:
The Tenant untlerslantls oral HUD requires Me Lanaard to assign units aaoMirp to Me size of IDg househok ant me age ant sex of Ma house-
hold members. It Ine 7enanl is Or becomes Olyide br a OilNrenl site unit, and Me required arse unit bewmes availabe. MB Tenant agrees m:
a. move within Ihirry (70) days alter the Landlord nolilies himlher Thal a unit of ine required size is availabe within Ine project; or
6. remain in Ine Same unit ant pay the HUD-approved market rent.
T0. ACCESS BY LANDLORD:
Tne Landlord agrees to enter the unit only during reasanade hours, to provide reawnade advance polka of hivher intent to enter Me unit, and to
enter the urnt Onry aver receiving Ine Tenant's cOmenl to do so, a.<apl when amergenty s,luati0na make auto nabs imposside a except uMer
paragraph (c) Delow.
a. The 7enanl agrees l0 perms the Landlord. nismer ogres a OMer persons, when auMOnzed by the LantlbM, to enter the one br foe purpose
of making reasonade repairs and permdk inspections.
b. Aner the Tenant has given a notice of intent to move, the 7enanl agrees m permit ma Landlord to slww ine unit Io prospective tenants during
reasOnade hours.
c. It Ine Tenant moves before this Agreement ends, me LarMlortl may enter the unit Id decorate, remodel, alter or otherwise prepare iM unit for
ra~occupancy.
T1. DISCRIMINATION PROHIBITED:
ine Lara]lord agrees not to 6scrimmale Dosed upon race, colon relgion, tread. national origin, Sex, spa, handicap, mem0srsmp m a class, such
as unmarred m0lhers or recipients of pudk assistance. Or because Ihare are chikren in IDe family.
2Z. CHANGE IN RENTAL AGREEMENT:
The Landlortl may, vAlh the pr'ror approval of HUD, Uarge Ina terms arM coMiibns of M4 Agreement. Arty [bargee win hecwne eflectiva omy al
Ma and al the initial term pr a successive term. The Landortl must noliry Me Tenant of arty charge ant must Offer MB TBneal a new Agreement w
an amendment to Ina eaisting Agreement. TM Tenant muss receive Ine rlolke at leas) suty (601 days Mbre IM propMetl apewM dale of Me
change. The Tenam may accept Ina cMnged terms and coMitiona by sgning IM new Agreamenl w IM ameMmenl to the esisfirg Agreamenl arw
returning it to the Landlord. The Tenant may reject Ine charged terms and mrtditbns by givuq the Landlord wri0en nolke Hut harshe infanta to
termmale Ine Ienanry. The Tenam must give such notice at leas) thirty (301 days babre the proposed change wiH go into eHed. 11 the Tenant does
not accept the amended Agreement. Ine Landord may regatta Me Tenant to more Iram IM projeU. as provbed in paragraph 23.
23. TERMINATION OFTENANCY:
a. To larminale this Agreement. IhB Tenant mu91 give the Landlord Ihirry (30) days wrHlen slice Mbre moving Iram IM una. II the Tenant does
not give Ine lull 30-day Mli[e, the Tenant shall M Iiade br rent up tM end of the Mbty (30) days tar whbh notice was required w to Me dale
the unit is re-rented, whichever dale comes firs/. -
b. Any termination al this Agreamenl by me Landlortl must be carried out in accprtlance with HUO reguWtbna, stale and local bw, and Me /arms
of Ihis Agreement The Landlord may larminale This Agreement only tar:
• Ina Tenant's material noncompliance with the terms at this Agreement;
• Ine Tenant's material /ailura to carry out obligations urMer any Slala LarMlord and Tensnl Ad; ar
• criminal activity that threatens the health, solely, or right to peacelW enjoyment of IM premises by other Ienanls or any Ong-related wimi-
nal activity on or near such premises, engaged in M a tenant, ant member of Me Tenant's Musehob, or any guest ar other person under
Ina Tenant's control; or '
• other good cause, which includes, but is net limited to, the Tenant's refusal to accept the Landlord's proposed change to This Agreement.
Terminations lor'olher good cause' may only M ellective as al Me erld of arty initial w waessNe term.
• the term material noncompliance wile Ina lease Includes: (1) one w more subsgntial oblations d the lease; (2) repeated minor vlelatibrl9
cl Me lease Mal (a) disrupt Me fwabitity of the projeU. (b) advarsey affect MB health w sabty of arty person w Ine rghl of arty tenant to
the quiet enjoyment ql the leased premises arM related project larJ7dles, (e) intarelare wHh the minapemenl of Me projeU. w (df have an
adverse OnanUal effect on Ine pojew: (3) /allure m Me Tenant to tlmery Guppy as required Inl0rmatlOn on Me Hlwme arq compositlon, w
- eligibility /ewers, of Ma Ienanl houseMb (includng, Grt n011imited b, bihue to mrlN Ilu 6aClesuM and verg¢alion requkemeMS br 5o[iet
Security Numhere, w failure to sign and wbrnil consent forms Icr Hu abuiMng of wage arM claim klbrmation from Sate Wage Imwmalion
C[Ilection Agandes), or to Mnowingry provide incomplete pr inaccurate inbrmadon;and (4) non-payment w rem or arty other HnarKWl oMiy-
aticn due under the lease heyontl any grace paned permilla0 urMar sate law. TM payment of reM w arty other fuunclal oMigalbn due
under the lease aflar Me due dale Mrl within the grace period pwmiged under sate 18w consfitulas a minor violation.
c. II Iha Landlord proposed to terminate Mis Agreement, the Landlord agrees ro Bh'e the Tenant wrMen nonce of Ma proposed lerminalion. II tM
Landord is lerminaling Mis Agreamenl brother good cause; the termination notice must De mated b Me Tenant and Mnd-dellvere0 b MB
dwelling unit in the manner required by HUD at leaf Ihirry (30) days bebre Me dab Me Tenant will De required 1o move hom MB unB. Notl[Bs
of proposed termination br other reasons mull be given in accomance with arty tlme lames sal brM in yule arM Iecal law. Arty HUD-regWred
notice period may run rnncurrenlly with any notice pedod required by Stale or local law. Atl IarminatiM rows must:
• speuty Me dale this Agreamenl will be IerminalBd:
• stale the grounda br termination with errough devil br Me Tenant to prepare a defense:
• advise the Tenant That hwsha has ten (70) days within which 10 discuss Me proposed termination d IenarKy with Me Wntllortl. TM 10-0ay
period will begin on the earlier of the dale the notce was hand-0eYrvered b the oral or Me day alter Me date Me notice b mailed. II Ine
Tenant requests the meeting, Me Landlord agrees ro discuss the proposed termination with the Tenant; ant
• advise the Tenant of hisMer right to defend MB action in court.
d. It an eviction is iniliafed. Me Wwllord agrees to rely only upon (hose grounds riled in the lerminalion WI'Ke required W paragraph (c).
Z4. HAZARDS: '
The Tenant shall not underuke, pr permit hismer family ar guests to uMeruka, any hazardous azts or do am/Ming tMl will irxueaze the project's
insuunce premiums. Such action canstllules a material non-compliance. II Me unit is tlamagetl M Nre, wind w rein ro IM ertienl Mal the urdl an-
nol Mlived inand Iha damage is nal roused a made worse by the Tenant, Me Tenant wig De rasponsble br reM onty up to IM tlala of the daStruc-
tion. Atltlilional rent win not aarue until Ine unit has Dean repaired to a livable condition.
25. PENALTIES FOR SUSMRTING FALSE INFORMATION:
Knowingly giving the landbrtl false information regarding inwme or other /actors consbered in delarminirg TenanYS elgibility ant rent 5 a mate-
rial noncompliance with the lease suhjew Io terminaton of lenartcy. In aWition, tM Tenam could Oecome sul>jew to penalties avaibNe under
Fetleral law. Those penalties inUude lines uD Io 510,000 ant imprisonment br W to live (5) years.
26. CONTENTS OF THIS AGREEMENT:
This Agreement and its AHaUments make up the entire agreement Mnveen Ma Lantllom ant Me TeruM regading the unit If any [curl declares
a particular provision of Ihis Agreement ro M invalid er illegal, all oHler terms of Mis Agreement witl remain at allect and boM Me Larldbm and Uu
Tananl will continue to be Mund by them.
27. ATTACHMENTS TO THE AGREEMENT:
The Tenant certifies that he/she has received a copy of this Agreement and Me IUbwirg Ailazhmanu b Ihis Agreamenl arM understands Mat Huse
Altachmenls era part al Ihis Agreement:
a. Anaehmant No. 1-Form HUD•50069, Cark6[atbn and Retertificalbn el Tenant Eligibairy
b. Anachmenl No. 2-Unit InsDawlon Report
c. Anachmem Na. 9-House Rules (il any)
28. SIGNATURES:
TENANT
ay:
Oa1e Signed
Dale Signed
Dale Signed
LANDLORD-ORCHARD APARTMENTS
Sy •
,-
1R-103 PUPA
5/82 4/98
RL'NEIJAL 'l0 RL•SIDENTIAL LEASE AGI2EEMEN'r
TfiIS REN$WAL TO T}IE R/esid¢ntial Lease Agreement (Lease) is made
this ~-i-~day of ~f~ L[ /L ~, 10'0_ /~, by and between
ORG HARD APARTMENTS (Landlord) and /,4.ViSh.H ~N/.$ (tenant) .
NOW 1'tIE BEFORE, IN CONSIDERATION oC the Landlord entering in L•o the
Residential Lease Agreement- with Tenant, the independent promises and
covenants of each to the other and the rent reserved, and intending to
be legally bound, Landlord and Tenant enter into this Renewal to L-he
Residential Lease Agreement and agree as follotas:
1_ Tenant, upon signing this Renewal, agrees L-ha l- the L•erm oP the
.Residential Lease Agreement shall- be £or (I) year beginning on the Ist
day o/£ Klt/T 20~ and ending on the g~~~day. o£
._b IL ~. t9 y ~~~~ or until terminated according to the terms and
conditions of't-Ite ResidetLial Lease Agreement. MONTH TO MONTH
~I 2. Tenant, in the event he desires to terminate the Residential
Lease Agreement, shall tender to the landlord written notice of Tenant's
desire to vacate the premises and said notice shall be tendered to the
Landlord at least thirty (30) days prior to the date Tenant intends to
vacate ttte premises. If Tenant fails to tender the required thirty (30)
day written notice, he shall be liable for the monthly rental-payment
for that tltirL-y (30~ day period of time together with any other damages
provided for in the Residential Apartment Lease.
3. Tenant and Landlord agree that upon signing this Renewal, the
monthly rental amount ,for Rental Unit No,.-7.~1~ shall be_S
Of the. Local rent, S 9~ ~ shall be payable by the Pennsylvania
!lousing Finance~}Agency as housing assistance payments on behalf of the
Tenant and ; r~~~ shall be payable by the Tenant in the following
manner:
(a) ~ as the estimated monthly utility cost for electricity.
The Tenant i~ responsible for paying the-apartment electric bill to the
utility company.
9
(b) _ ~~ ` as the monthly rental payment to the Landlord.
These amounts shall be subject to change by reason of changes in
the Tenant's family income, family composition, or extent of exceptional
medical or otltnr unusual nt housing and Urban Development; or by reason
of adjustment by the Pennsylvania Housing Finance Agency or any applicable
A1lowancr. for Utilities and Other Services. Any such change shall be
effective as provided for in the Renewal.
IN WITNL'SS WfiE REOF Tenant and Landlord have hereunto set their _.
hands and seals all as o£ the day and year first above wri en.
F7ZTNESS:
/~y:, ~ "" ~ (seal)
~LC,ILJ/~~/ Reside anager
._~ Olove (. r ~. ! 11 lt2t S r..... i t
~~ J
FROM IRM RT ORCHRRD RPTS FRX N0. :7177309323 Sep. 06 2001 09:07RM P2
Tp: Tanisha llennis
,.-
rltorash:n ~a~rlcr To o~rr
2202 ll Cedaz Run Drive F.xtcnded
Camp Bill, Pennsylvania 1701 I
DAT)r: August 28, 2001
YOU ARE HERESY iVOTIFIED that as of this date, your lease agreement is being considered
for termination because you have committed various substantial and minor violations of the lease
agreement, applicable Housing and Urban Development (HUD) regulations, provisions of the
Pennsylvania Landlord and Tenant Act, and of the rules and regulations of Orchazd Apartments, all of
which constitutes "material non-compliance" which term, as outlined in Pazagraph 23 of the lease
agreement, is defined in part as: "material non-compliance" includes, but it not limited to, non-payment of
rent beyond the grace period available under state law; failure to reimburse the landlord within thirty (30)
days for repairs made under Paragraph I1 of this agreement; repeated late payment of rent; permitting
unauthorized persons to live in the unit; serious or repeated damages to the unit or common areas; creation
of physical hazazds; serious or repeated interference with the rights and quiet enjoyment of other tenants;
failure to repay unauthorized assistance payments; and riving the landlord false information regarding
income or other factors considering in determining the tenant's rent".
The substantial and repeated minor violations of your tease are as Fellows:
(1) Allowing unauthorized individuals to reside in the unit, in violation of Paragraph 13 of the
Lease Agreement and Paragraph 4-18 of HUD Transmitta14350.3.
(2) Use of the unit for Drug-related criminal activity in violation of Pazagraphs 13 b and f of the
Lease Agreement and Paragraph 4-18 of HUD Transmittal 4350.3.
As a result of the above acts and actions, the landlord is of the opinion that yoti have breached the terms of
the lease agreement, rules and regulations of Orchard Apartments, and applicable HUD regulations, and
have forfeited your right to continue possession of your apartment unit.
Page Qne of"three
PI.~gINTIFF'S
EXHIBIT
_~
9 R~•oi P~
SEP-06-2001 11 31 7177309323 95i P.62
-FROM IRM pT ORCHRRD pPTS FRX N0. 7177309323 Sep. 06 2001 09:07pM P3
ti
THEREFORE, YOU ARE HERT;RY NOTLFITI) to remove Irom and deliver possession of the
leased unit you now occupy at the above address, within t11e complex know as Orchard Apartments within
thirty (30) days from the date of service of this Notice, but in no event later than September 3U, ?001. In
the event you remain in possession of the leased unit beyond September 30, 2001, the date specified for
termination herein, and fail to deliver the possession of the leased unit to the landlord, the landlord can
seek to enforce the termination of the lease agreement and secure: your removal from the teased unit only
by initiation a judicial action as required by HUD Transmittal 43503, Yazagraph 4-21. If a judicial
proceeding for and eviction is instituted, you may, at that time present a defense.
Department of Housing and urban Development {HUD) Regulations provide that you ten (10)
days within which to discuss the Proposed Notice with the landlord. You may discuss this Proposed
Notice by telephoning the office, visiting the office, or by writing a letter.
Served this 28'" day of August, ?001.
AT'TENCION: Si vd no entiende esta noticia por favor venga ha mi offencina y se to explicare.
Page "!'wd of Three
SEP-06-2001 11 32 717'7309323 95i P.03
~'RfA1 : IRM RT ORCHRRD RPTS
FRX N0. :7177309323 Sep. 06 2~1 09:08RM P4
AFFIDAVIT OI' SERVIC.F
The undersigned does herehy verify that ho/she served the Proposed Notice to Quit by placing the
Proposed Notice in the 13nited States mail. postage prepaid, first-class, endorse a oper rehtrn
address, on the 28a' day of August, 2001. I understand that false statements h mare made subject to the
penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to au1;Yt6 ~ tes. j
Tyson, A~sf(iS~ant Manager
The undersigned does hereby verify that he/she served the Proposed Notice to Quit by one of the
two methods set forth below:
Personally handing the Proposed Notice to Quit to the tenant or an adult person
answering the door at the tenant's apartment on the 28`s day of August, 2001.
By placing Proposed Notice to Quit under or through the tenant's door on the 28`"
day of August 2001, and/or Posting the Proposed Notice to Quit on the tenant's
door.
(Method of service employed evidenced by checked box.)
1 undergstand that false statements herein are made sttbjec/ to~~e--penalties o $ Pa. C.S.A.
§4904 relatin to unsworn falsification to authorities. / l
W.
Pave Three of Three
SEP-06-2001 11:32 7177309323 95i P.04
SEP 0 8 200
~~[
ORCHARD APARTMENT IN THE COURT OF COMMON PLEAS
ASSOCIATES, t/d/b/a :CUMBERLAND COUNTY, PENNSYLVANIA
ORCHARD APARTMENTS, .
Plaintiff .
v. NO. ~(-V ~~-'~2
TANISHA DENN25, CIVIL ACTION - LAW
Defendant
ORDER
AND NOW, this ~ day of SEPTEMBER, 2001, upon review
of the annexed Complaint and the motion of Jordan D.
Cunningham, Esquire, a hearing pursuant to the Model
Expedited Eviction of Drug Traffickers Act, 35 P.S. §780-
164 (a) is set for the aye day of ~`~„~_,
2001, at ~.3G~ .M., in the Cumberland County Courthouse,
Courtroom No. ~ Square, Carlisle, Pennsylvania.
Notice of service of this Order on this Defendant
shall be accomplished either through the Sheriff's Office
or by any competent adult by personal service.
>- ri
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SE2U~cL_ ~y S'L.Fitr~~-' /J
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nv muu rnrrom.
i
T
ORCHARD APARTMENT IN THE COURT OE COMMON PLEAS
ASSOCIATES, t/d/b/a CUMBERLAND COUNTY, PENNSYLVANIA
ORCHARD APARTMENTS,
Plaintiff ( _//
NO. ~f~S~~IQ C'~~f~
v.
TANISHA DENNIS, CIVIL ACTION - LAW
Defendant
COMPLAINT
AND NOW comes the Plaintiff, ORCHARD APARTMENT
ASSOCIATES, t/d/b/a ORCHARD APARTMENTS, by and through its
attorneys, Cunningham & Chernicoff, P.C. and files this
action at law and in support thereof avers the following:
1. Plaintiff, ORCHARD APARTMENT ASSOCIATES, t/d/b/a
ORCHARD APARTMENTS, is a limited partnership which is
registered with the Pennsylvania Department of State having
a registered address of 2204 Cedar Run Drive, Camp Hill,
Cumberland County, Pennsylvania.
2. The Defendant, TANISHA DENNIS, is an adult
individual who resides at 2202-D Cedar Run Drive Ext., Camp
Hill, Cumberland County, Pennsylvania.
3. At all times material to Plaintiffs cause of
action, Plaintiff, ORCHARD APARTMENT ASSOCIATES, t/d/b/a
ORCHARD APARTMENTS, has been the legal owner of the tract
of land on which the building in which the Defendant
resides is sited.
4. On or about February 11, 2000, Defendant executed
a Lease Agreement by the terms of which the Defendant
leased from the Plaintiff a residential apartment, 2202-D
Cedar Run Drive Ext., Camp Hill, Cumberland County,
Pennsylvania for a term to expire on March 31, 2001 after
which initial term, the lease continued on successive terms
for one (1) month each pursuant to Lease Rider. Defendant
occupies an apartment unit which is subsidized under a
federal housing program, generally known as Section 8. A
true and correct copy of the Lease Agreement for 2202-D
Cedar Run Drive Ext., Camp Hill, Cumberland County,
2
Pennsylvania is attached hereto, made part hereof, and is
marked as Plaintiff's Exhibit "P-1".
5. At all times relevant hereto, Plaintiff is of the
belief and therefore avers that Ricky Carroll, the
Defendant's boyfriend, was a person who was a guest and/or
resided, with Defendant, at Defendant's apartment unit and
with her consent, and is a person over whom Defendant had
control.
6. On August 11, 2001, the Lower Allen Township
Police responded to a county request to search for a silver
Cadillac automobile owned by a Ricky Carroll. Mr. Carroll
was suspected of just having been involved in a robbery in
Swatara Township. The vehicle owned by Mr. Carroll was
discovered by the Lower Allen Township Police parked in a
no parking zone at Orchard Apartments, just outside of the
Defendant's apartment. The Lower Allen Township Police
Department reported the discovery. At that time, the Lower
Allen Township Police was further advised by the City of
Harrisburg Police there was an outstanding warrant for the
arrest of Mr. Carroll, for a different robbery, and were
3
requested to execute the warrant. While Mr. Carroll's car
was being observed, a search warrant for Defendant's
apartment was obtained. Upon obtaining the execution of
a search warrant, the Lower Allen Township Police
Department executed the search warrant and arrest warrant
and discovered Mr. Carroll and Defendant inside Defendant's
apartment. While processing Mr. Carroll, the Defendant and
the other occupants of Defendant's apartment, crack
cocaine, a controlled substance, as defined in Section 2 of
the Act of April 14, 1972 (P.L. 233, No. 64), was
discovered in the master bedroom of the apartment unit.
The crack cocaine was of a quantity and packaged in such a
way as to support a finding that either Mr. Carroll and/or
Defendant possessed the same with the intent to sell and
distribute the controlled substance or, in the alternative,
were involved in a conspiracy to commit such an act.
7. The crack cocaine and a marijuana "blunt" were
seized by the Lower Allen Township Police Department, field
tested, and a positive result was obtained.
4
8. The Defendant agreed to abide by the following
terms set forth in the Lease Agreement:
13. GENERAL RESTRICTIONS: The Tenant must
live in the unit and the unit must be the
Tenants only place of residence. The Tenant
shall use the premises only as a private dwelling
for himself/ herself and the individuals listed
on the Certification and Recertification of
Tenant Eligibility. The Tenant agrees to permit
other individuals to reside in the unit only
after obtaining the prior written approval of the
Landlord. The Tenant agrees not to: .
(b) use the unit for unlawful purposes;
(c) engage in or permit unlawful activities
in the unit, in the common areas or on
the project grounds; .
(f) Notwithstanding any other provision of
this lease, the Tenant, members of the
Tenant's household, guests of Tenant
and other persons under Tenant's
control shall not engage in unlawful
activity, including drug-related
criminal activity, in the Tenant's unit
or on the project premises, and such
unlawful activity shall be cause for
termination of tenancy. "Drug-related
criminal activity" means the illegal
manufacture, sale, distribution, use or
possession of a controlled substance as
defined in Section 102 of the United
States Controlled Substances Act, 21
U.S. Code Section 802. Criminal
conviction under Federal, state or
local law shall not be a precondition
for termination of tenancy.
5
COUNT I - PETITION PURSUANT TO MODEL ESPEDITED
BVICTION OF DRUG TRAFFICKERS ACT
9. Plaintiffs incorporates Paragraphs 1 through 8 of
the Complaint as if more fully set forth herein.
10. Plaintiff is a landlord who has standing under
Section 155 of the Model Expedited Eviction of Drug
Traffickers Act (hereinafter referred to as "Act"). 35
P.S. X780-155.
11. Plaintiff is of the belief and therefore avers
that Defendant's guest and/or co-tenant, on August 11, 2001
was involved in drug-related criminal activity on or within
the immediate vicinity of the leased residential premises
leased to the Defendant. Additionally, Plaintiff is of the
opinion that the individual rental unit was used by the
Defendant and her guest and/or co-tenant in a way to
further or promote drug-related criminal activity.
12. Plaintiff seeks the jurisdiction of the Court and
the expedited proceedings provisions of the Act and
~ 6
requests a hearing on this matter be heard within fifteen
(15) days of the date of the filing of the Complaint.
13. Plaintiff is of the opinion and therefore avers
that it has set forth adequate grounds for the Court to
enter an Order of Eviction and issue a removal Order as
against the Defendant, Tanisha Dennis and Ricky Carroll, ',
and all other members of her family. 35 P.S. §780-164 and
§780-156(b).
WHEREFORE, your Plaintiff respectfully requests this
Honorable Court to make a finding of grounds for complete
eviction, enter an Order of complete eviction, and issue a
removal Order to be executed by the appropriate law
enforcement agency or the Sheriffs Office of Cumberland
County, Pennsylvania.
COUNT II - IN EJECTNENT
14. Plaintiff incorporates Paragraphs 1 through 13 of
the Complaint as if more fully set forth herein.
7
15. Plaintiff's agent, Debbie Anstine, after a total
review of Defendant's history, reached a decision to
terminate the Defendant's Lease Agreement and/or not renew
the Defendant's Lease Agreement for the following reason:
(a) As a result of Defendant and/or guest
and co-tenant, on August 11, 2001, having
directly possessed, stored, distributed,
transferred, used, and sold or conspired to
possess, store distribute, transfer, use and sell
in or about the immediate vicinity of her
apartment a controlled substance which, in the
opinion of the Plaintiff's agent, represents a
substantial violation of the terms of the Lease
Agreement, specifically, Paragraphs 13(b), 13 (c)
and 13(f), HUD Regulations, specifically 4-18 of
the HUD Technical Handbook, Transmittal 4350.3,
and the Pennsylvania Landlord and Tenant Act, all
of which constitutes a material noncompliance
with the terms of the Lease Agreement as defined
8
under HUD Regulations and Paragraph 23 of the
Lease Agreement.
16. Defendant, although requested to do so by the
Plaintiff, has refused to surrender the premises located at
2202-D Cedar Run Drive Ext., Camp Hill, Cumberland County,
Pennsylvania, to the Plaintiff and has since the time that
she received the Notice to Quit has continued to remain in
I
possession of said premises.
17. The Plaintiff has not defaulted in its responsi-
bility to provide a habitable premises to the Defendant and
is of the belief and therefore avers that the premises
being occupied by the Defendant are in such a state as not
to violate the implied warranty of habitability owed by the
Plaintiff to the Defendant.
WHEREFORE, the Plaintiff demands entry of judgment
against the Defendant, Tanisha Dennis and Ricky Carroll and
in favor of the Plaintiff on the issue of possession of the
9
premises known and numbered as 2202-D Cedar Run Drive Ext.,
Camp Hill, Cumberland County, Pennsylvania.
Respectfully submitted,
& CHERNICOFF, P.C.
Date:_September 6, 2001 By
~brdan"D unningham, Esquire
I.D. # 144
2320 orth Second Street
P. 0. Box 60457
Harrisburg, PA 17106-0457
Telephone: (717) 238-6570
(Attorneys for Plaintiff)
10
FROM
IRM RT ORCHRRD RPTS FRX N0. 7177309323
' SE?-06-2p01 15:12 SeP• 06 2001 0~:01PM P1
n.
I, Debbie Anstine, site 2aaaager, Orchard Apartments,
verity that the statements made is the foregoing Complaint
are true and correct to the best of my knowledge,
ialoxmatioa and belief. I under8taad Chat fat®e statements
herein axe made aubj0ct to the pena.ltiea of 18 Pa. C.S.A.
54904, relating to unsworn falsification to authorities.
_~
nebbie Anat~ e, Site M a s
Orchard Rpartmentz
Gate: 9 ~ ~
TOTAL P.OS
SEP-06-2001 15 25 7177309323 ys,
P.ui
S B H I B I T •P-1^
~....
.;
(_
~,
CHARD APARTMENTS ~ ~ ,
'""""""°"""°° r RESIDENTIAL LEASE AGREEMENT '
1. PARTIES AND DWELLING UNIT: ORCHARD APARTMENTS
the parties to this Agreement are
referred
la as the Landlord, and DENNIS TANISHA ,referred to
as the Tenant. The Landlord leases to the Tenant unit number 2 202-D CEDAR RUN
located at 2201 CEDAR RUN DRIVE, CAMPHILL, PA 1?Oli in the project knownaz
_irRCHARD APARTMENTS
2. LENGTH OF TIME (TERM):
` The ihilial term of This Agreement shall begin on FEBRUARY 11 , 2000 and end on
MARCH 31 , 2 0 O 1 . Aber the initial term ends, the Agreement will continue tar successive terms
of one MONTH each unless aulomalicaly terminated as permitted by paragraph 23 0l This Agreement.
$. flENT:
The Tenant agrees to pay $ 19.0 0 for the partial month ending on 2-2 9 -2 0 00 ,pryer that, Tenant agrees to pay a rent of
$ 31.00 par mon7h.7his amount is due on the FIRST day of Iha month al 2204 CEDAR RUN DR.
_CAMPHILL, PA 17011 RENTAL OFFICE
Tne Tenant underslarMS Thal this monthly rent is lass Than the market (unsubsidized) rent tlue on This unit. This lower rent H aveilaWe either because
the mortgage on this project is subsidized by the.Departmenl of Housirg antl Uman Davebpmenl (HUD) and/or bewuse HUD makes mpnlhly pay-
ments to the LandloN an Dehali of the Tenant. The amount, it any, that HUD makes eveilade monthly on behall of the Tenant is rolled the tenant
assistance Dayment and is mown an Iha'ASSistance Payment' line of the Cerrgiratipn aM Rerartilicatipn al Tenant EI'pih'lirv Form whkh is
Attachment Np. t to This Agreement.
0. ORANGES IN THE TENANT'S SHARE OF THE RENT:
The Tenant agrees that the amount of rent the Tenant pays anNOr the amount of assistance that HUD pays on behall of the Tenant may ba changed
during the term of this Agreement il:
a. HUD or the Contrail Administrator (such as a PuNk Housing Agency) determines, in accordance with HUO procedures. that an increase in
rents is needed;
b. HUD or the Contract Administrator changes any alhwance for utilities or services considered in romputing the Tenant's share al the rent:
f c. The income, the number of persons in the Tenant3 householtl or ether lectors considered in calculating the Tenant's rent change and MUD
procedures provide that the Tenant's rent or assistance payment be ad)ustetl to reflect me change;
' d. Changes in lha Tananl's rant or assistance payment era required by HUD's recerlifiptbn or subsidy terminatipn procedures:
' e. HUD's procedures br computing the Tenant's azsistance payment ar rent change: or
1. The Tenant tails to provide inbrmation on hLSmer income, lamity comppsttlan ar other fazlors as required by the Landlord.
The Landlortl agrees to implement changes in me Tenants rent or tenant assistance payment only in accordance with the time Irames and admin-
istrative procedures set form in HUD's handbooks, insinxrions aM regulations relaletl to administrafion of multi-family subsdy programs. The
Landlord agrees to give the Tenant at least 30 days advance written notice of arty increase In the Tenant's rent except az noted in paragraphs 11,
16 pr t 7. The Native will state me new amount the Tenant is requiretl la pay, me sate the new amount is e0ective, and the reasons br me change
in rent. The Notice will also atlvise the Tenant mat he/she may meet with me Landlord to discuss the rent change.
5. CHARGES FOR LATE PAYMENTS AND RETURNED CHECKS:
II the Tenant does not pay the lull amount on the rent shown in paragraph 3 by the end of the 51h day of the month, the LantlloM may collect a lee of
$20.00 an the 61h day of me monm. Thereafter, the IsntlbM may collect $1 a day alter me 20m day of me monm for each atlditional tlay me rent
remains unpaid during me month. The Ladlortl may not temminate this Agreement for me fedora m pay late charges, but may terminate WsAgreement
lornpn-payment of rent. as explaned in paagraph 23. The Landlord may collect a lee of S 25 .0 0 on me first pr any atltlitbnal fime
a check is not honored for payment (bounces). The charges discussed in this paragraph are iri atldifion to me regular monthy rant payable by me
Tenant.
6. CONDITION OF DWELLING UNIT:
By signing this Agreement. the Tenant acknowledge3 that the unit is sale, clean and in good roMition. The Tenant agrees that all appliances and
equipment in the unit era in good working order, except az described on the Unit Inspection Report which is Attachment No. 2 to mi5 Agreement.
The Tenant also agrees That the Landlortl has matle no promises to decorete, attar, repair w improve iha unit except a3 listed on the Unit Inseeilipn
fiepg[l
7. CHARGES fOR UTILITIES AND SERVICES:
The following charts describe how me cast of utilites and services related to ocoupaftcy of the unit will be paid. The Tenant agrees Nat These charts
accurately describe the utilities antl services paid by the Landlortl and (nose paid W the Tenant.
a. The Tenant must pay for the utilities in wlumn (1). Payments should be matle direcly la the appropriate utility company.The items in column
(2) are included in the Tenazl'S reel:
(1)
Put "%" by any Utility
Tenant Peys Dlractty
X
6. SECURITY DEPOSITS:
Type of Utility
H e a I ....................................................
Lights. Elecrdc ....................................
Cppking ...............................................
Water ...................................................
Omer ($pedy) Trash, Sewage..........
Cable.........T ........................................
All Uliliry Hook-ups .............................
(2)
Put "X" by any Utlltty
Inoludetl In Tenenl Rent
The Tenant has tleposited $ 9 7 . 0 0 with Iha Landlortl. The Landlortl will hold This security deposit for the period the Tenant
occupies the unit. After Tne Tenant nos moved Irom the unit. the Landlprd will determine wnether me Tenant is eligible for a reNntl of any or all of
the security deposit. The amount of me refund will be determined in accordance with the following conditions and procedures:
a. The Tenant will ba eligible for a refund of the security tlaposil only it the Tenant provitlatl the Landlord with the 30-day written nolica pl intent Ip
move required W paragraph 23, unless the Tenant was unable to give Iha nolica br reasons beyond his/her ronlrol.
b. Alter Tne Tenant has moved Irom Iha unit, the Landlortl will insDecl the unit and complete another Un t Inspectpn Report. Tne Landlprd will
permit Iha Tenant to participate in the inspection, it the Tenam so requests.
c. Tne Landlord will refund to the Tenant the amount of the security deposit (plus interest computed at %,
begmmng ), Tess any amount needed to pay me cost ol:
i, .
(01 charges br late payment of rs.., antl returned checks, a4 tlescti6ed in parragraph 5; arar
(a) charges br unreturnetl keys, as described In paragraph 9. ~'
Tne Lantllord agrees to refund the amount computed in paragraph & wimin tlays after the Tenant haz permanently moved
out of Ina unit, returned possession of the unit to the Landlord, aM give hislher now address to the Lantlbro. The Lantlord will also give Ina
Tenant a written list of charges Ihal were subtracted tram the tleposil. II the Tenant dl5agrees wim the Landlord concerning the amounts
deducted and asks Io meal with the Landlord, the Landlord agrees to meal wglt Ina Tenant antl inbrmally discuss the disputed charges.
II Ina unit is rented by mare than one person, the Tenants agree Thal they will work wl the tletails of dividing any refund among themselves.
The Landlord may pay the refund ro any Tenant itlenlilied in paragraph 1 of mi8 Agreement.
The Tenant understands Thal the Landlord will not count the Security Deposit tmvards the lazt month's rent or toward repair charges owed br
Ina Tenant in accordance with paragraph 11.
9. KEYS AND LOCKS:
The Tenant agrees not to install additional or different locks pr gates on arty doors ar windows of the unit without the written permission of the
Lantllord. II the Landlord approves the Tenant's request to install such locks, me Tenant agrees ro provitle the Wndlord with a key br each IDU.
When this A reement ends. Iha Tenant agrees to return all keys 1o the dwelling uml ro the LarMlartl. The LarMloro may charge the Tenant
S 9 . D 3 for eacn key not reurned. (Not to exceed what locksmiln charges br each key not returned.)
10. MAINTENANCE:
The Landlortl dgrees to:
If) regularly clean all mmman areas of the project:
121 maintain the common areas and lacililies in a sale condition;
(3) arrange for collection and removal of trash and gamage;
(a) maintain all equipment and appliances in sale and working wtler,
(5) make necessary repairs with reasonable promptness;
(6) maintain exterior lighting in good working order;
(7) provide extermination services. if necessary; and
(B) maintain grauntls arM snruDS. -
The Tenant agrees to:
(1) keep Iha unit clean;
(2) use all appliances, fixtures and equipment in a sale manner and only for the purposes for which tney are intended;
13) ncl litter the grounds or ttmmon areas of the project;
(4) not destroy, deface. damage or remove any part of the unit, common areas, or project grcuMS:
(51 give the Lantllord prompt notice al any defects in the plumbing, fixtures, appliances, heating and cooling equipmanl ar any other part of
the unit or related lacililies; antl
(6) remove garbage and other waste tram the unit in a clean and sale manner.
11. DAMAGES:
Whenever damage Is caused q' carelessness, misuse, or neglect on the part at the Tenant, hiSAter family or visitors, the Tenant agrees to pay:
a. Reasonable charges for all tlamages to the premises (including equipmanl and/or appliances supplied to the premises( and reaWneble charges
for tlamage to the project buibings, lacililies, or common areas negligently or inlengonelly causetl by Tenant or Tenant's household or quests.
Said charges era to be made according la the current Schedule of Maintenance Charges oosletl in the Management ONice, arM Tenant agrees
that payment of all such charges shall De made within thirty (30) days of the dale charges are bfiled.
b. Rent for the period the unit is managed whether or not the unit is habileNe. The Tenant understands That HUD will no~ make aazislanca pap
ments for any period in which the unit is not habitable. for any such period, the Tenant agrees to pay the HUD~approved market rent rather than
the Tenant rent shown in paragraph 3 0l this agreement.
12. RESTRICTIONS ON ALTERATIONS:
Tne Tenant agrees not to do any al me fclbwing wimoul first abWining Ne larMbrd'S wdtten permission:
a. change ar remove any pan of the appliances, fixtures or equipment in me unk;
b. paint pr install wallpaper or conlam paper in Iha unit; '
c. altarh awnings or window guards in me unit;
tl. attach or place any fixtures, signs. or fences an the buibing(s), the commpn areas, w me project gfDUflds:
e. attach any Shelves, sueen doors. or other permanent improvements in the unit;
I. install washing machines, dryers, tans heaters or air conditioners in the unit; or
g. place any aerials. antennas or other electrical connections on the unit;
h. no wafer beds.
13. GENERAL RESTRICTIONS:
The Tenant must live in the unit antl the unit must be the Tenant's onty place of reaberKe. The Tenant shall use the premises onty as a private
dwelling for himsell/hersell antl the individuals listed on the Cerlilicalion aM Recartilbalion of Tenant ElinihiliW. The Tenant agrees to permll other
individuals to resitle in the unit only alter obtaining the prior written approval of the Landlortl. The Tenant agrees not to:
a. sublet or assign the unit, or any part of the unit;
b. use the unit for unlawful purposes;
c. engage in or permit unlawful activities in the unit, in the common areas or on the project grouMS:
d. have pets or animals of any kind in the unit without the prior written permission of the Landlord: or
e. In me event mat during Ina term of the lease the Tenant shculd require the assistance of a Live-in-Aide. in attaroance with the HUD
Regulations, the aide snail not be allowed Ic remain in ottupancy should the Tenant terminate This lease Agreement nor shall the Live~in~Aitle
have nghts to survivorship of Iha unit.
f. Nolwilhsbnding any other provision of this lease, Ina Tenant. members of the Tenant's household, guests 01 Tananl and other persons under
Tenant's control shall not engage in unlawful activity, including drug-related criminal activity. in the Tenant's unit or on me project premises, and
such unlawful activity snail ha cause for termination al tenancy'Drug~relaled criminal activity means the illegal manulaclure, sale, tlislribuaon,
use or possession of a controlletl substance as defined in Section 102 0l the UnKed Slates Controlled Substarrces Act, 21 U.S. Cade Secllon
802. Criminal conviction uMer Fetleral, state or local law shall not be a precondition br termination of lenanq.
g. Tenant shall not pursue or conduct any business on the premises, nor shall Tenant disday any signs of arty type of description.
n. Tenant shall rafratn Irom and cause Tenant's household and guests to retrain Irom destroyirg, delazing. tlamaging, or removing any part of the
premises of protect.
i. Tenant Shall not create or permit any disturbing noises 1n or about Tenant's dwelling unit by himself, his family, or guests: nor Shall he, his family,
or guests inlerelere with ar materially diminish the rights, comforts. or convenience of other Tenant's or surrountling neighbors. Neither the
Tananl, his family, nor his guests shall engage in any activity that woultl constitute an offense against persons, property. public order, ar public
health or decency, or That involves UauQ deception, firearms, or other weapons.
1. Tenant shall not refuse the extermination services for rodent or insect infestation.
k. If neat is to be supplied by the Tenant, Tananl agrees to execute a Ihirtl party notification with Landlord. whereby the Landlord wtll be banally
notified prior to the discontinuance of ulilily service by the ulilily supplies Tananl agrees to /urnish suflicienl neat to the premises to prevent
damage to the premises. II, for any reason, Tenant is unable to maintain sufficient heat, Tananl shall immediately notify Landlortl. Tananl shall
pay tar any damages to the unit resulting Irom Tenant's negligent or inlantional failure to maintain sulticienl heat or to noliry Landlord of the lack
of sull¢ianl heal due to any Cause beyond Tenant's Control.
I. Tenant agrees to comply with Lantllord policies and directives, as well as the regulations and laws al all Federal, stale, municipal antl local
governments regarding the collection, sorting, separation and recycling al waste pratlucts, gamage, refuse antl (rash.
14. RULES: '
TAB Tenant agreaz to obey the House Rules which are Attaznmenl No. 31o This Agreement. The Tananl agrees la obey additional rules esWdished ~~
after Ina eHazfive dale of Ibis Agreement il:
a. the rules are rea3onady related to Ina salary, care antl cbanllness of me Ouikfing and the salary, combrl and comaniance of the Tenants; and
D. Ina Tenant receives written notice of Tne proposed rule al least Thirty (30) days bebre the rule is enl0rced.
16. REGULARLY SCHEDULED RECERTIFICATIONS:
Every year around me FIRST day of NOVEMBER me Landlord will request the Tenant to report the income
and compositron al the Tenant's household antl to supply any other inlormalion required Oy HUD br Ina purposes of tlalermining the Tenant's rent
antl assistance payment, it any The Tenant agrees to provitle accurate statements of this information antl Io eD so by the tlate specified in Iha
Landlord's request Tne Lantlbrd will verity me inlormalion supplied by me Tenant and use the verilie0 inbrmalon to recompute the amount of me
Tenant's rent and assistance payment it any.
a. II the Tenant does not submit the required cenificatbn inbrmalion by the dale spazilied in the Landlord's request, me Lantlbrd may impose Ina
following penalties. The Lantllard may implement Inese penalties only in accordance with the atlministrelive procedures ant time frames
specified in HUD's regulations, harMboaks arW instructions related to the admini3tratbn dl multi-/amity subsidy programs.
(/( Require Tne Tenam to pay the nigher, HUD-approved market rent for Ina unit.
(2) Implement any increase in rent resulting Irom me recertification processing without providing me 30-day entice otherwise required by
paragraph a of rots Agreement.
b. Tne Tananl may request la meet with Ina Lantllard to discuss any change in rant ar assistance payment resulting Irom Iha razertilicalian
processing. II Tne Tenant requests such a meeting, the Lantllard agrees to meet with the Tenant and discuss haw the Tenant's rent and assis-
tance payment, it any, were computed.
tfi. REPORTING CHANGES BETWEEN REGULARLY SCHEDULED RECERTIFICATIONS:
a. II any al the blowing changes occur, the Tenant agrees Io advise the LantlloM immediately: '
(1) Any nou3enold memoer moe9S Oul 0l the unit.
(2) Any adult member of the household who was reported a3 unemployed an me most recent cerliylWtion or recertification obtains employ-
ment.
(3) The household'3 income cumulatively increases by HO or mare a month.
b. Tne Tenant may report any decrease in income ar arry change in other ladore considered in calculating ma Tenants rent. Unless the Lantlbrd
has canlirmation that Ina decrease in income or change in oNer fazlors will last less Nan one monm. me Landlord will verity the information
antl make Ina appropriate rent reduction. However, it the Tenant's inwme will De parllally or lolly restored within Iwo months, me Lantllard may
delay the certification process until Ina new income ib known, but Ina reel reduction will DB relroadive and the LantlloM may not evil me Tananl
tar nonpayment of rent tlue during ma period of the reportetl decrease and me completion of me cerUlicalbn praess Tne Terunt has Thirty
(30) tlays aver receiving written notice cl any rent due br the above tlescribetl time pedod to pay or Iha Lantllartl can evin /or nonpayment of
rent. (Revise0 32TJ69J
c. II the Tananl does hat aovibe the Landlord of these interim changes, the LaMbrd may increase the Tenant's rent to the HUD-appravetl market
rant. Tha Landlord may do so only in aacrtlance wile the tuna frames and administrative procedures sal brth in HUD's regulations, harMbooks
antl instrucfiore on the adminibbation of mulll-family subsidy programs.
d. Tne Tananl may request to meal with me LarbloM to tllazuss how any change in income ar other Iedore aHeded hismer rent ar assistance
payment. it any. If me Tenant requests such a meeting, me Landlord agrees to meet with Ina Tenant and explain how the Tanams rent w assis-
tance payment. it arty, was wmputed.
17. REMOVAL OF SUBSIDY:
a. The Tenant urWerstands that assistance made available on his/her behalf may ba terminated it events in eitherjgems (t) or (2) below omur.
Terminaticn of assistance means that the Landlord may make the assi3tance available to another Tenant and me Tenant's rent wig De recom-
putetl. In addition, it the Tenant's assistance lc terminated because of criterion p) below the Tananl will be required to pay the HUD-approved
market rant forme unit.
(1) The Tenant does not Drovide the Landlord with the inormation ar reports required by paragreph 15 or 16 within ten (f0) calendar days
alter receipt of the Landlord's notice or intent to terminate me Tenants asslstanra payment.
(2) The amount the Tenam would be required to pay towards rent antl utilities oNer HUD rules and regulatbns equals the Fatuity Gross Rent
shown on Attachment i.
D. The Landlord agrees to give the Tananl written notice of the proposed termination. The notice will advise the Tenant mat, during me ten (70)
calendar tlays bllowing the date of the notice, he/she may request to meat whh Ina Landlord to dlsass the proposed termination of assistance.
II the Tenant requests a tliscussion of the proposed Ierminatbn, me LandloM agrees 1o meal with me Tenant.
c. Termination at assistance shall not affect the Tenant's other rights under this Agreement, including the rlghl to occupy me unit AssisMance may
subsequemhy be reinstated it the Tenant submits the income or other tlala required by HUD procedures, me Lantlbrd determines me Tenant is
eligible for assistance, antl assistance is availabe.
16. TENANT OBLIGATION TO REPAY:
II the Tananl Submits false inbrmalion on arty application, Cerfilicalion Or request br interim atljusttnenl Or Boas not report interim changes in family
income or other facture as required by paragraph f 6 0l Ihis Agreement, ono as a rewtt, b charged a rent less Nan the amount roquke0 by HUD's
rant brmulas. the Tananl agrees to reimburse ma Ladlortl tar me tli0ereaze between me rent he/she sMUld have paid end me rent he/she was
charged. The Tananl is not requiretl to reimburse the LandloM br undercharyas caused solely by Ina Landbrd's bgure to blow HUD's procedures
far computing rent or assistance payments.
19. S2E OF DWELLING:
The Tananl untlarstands Thal HUD requires Ina Landlortl la assign units according to Ina size of Tne ncusehold and the age arM sex of the house-
hold members. II the Tananl is or becomes eligibe for a dillerent size unit ant Ne required size unit becomes availabe. the Tenant agrees lo:
a. move wimin thirty (30) days alter the LarMloro notifies himiner That a unit al the equiretl size is available wimin Iha project: or
b. remain in the same unit and pay the HUD-approved market rent.
g0. ACCESS BY LANDLOflD:
Ths Lantllard agrees to enter the unit only during reasanabe hours, to provide reasonable advance notice of his/her intent to enter me unit, and to
enter Ina unit only aver receiving Ina Tenant's consent to tlo so, except when emergenty s,IUalions make such notices imposside or except under
paragraph k) below.
a. Tha Tenant agrees to permit the Lantlbrd, his/her agents ar other persons, when authorizetl M the Landlord, Io enter me unit br the purpose
of making reasonade repairs and periodic inspections.
b. Alter the Tenant has given a notice of intent to move, me Tenant agrees to permit the Landlortl to Show the unit to prospective tenants tlurirg
easonabe hours.
c. II the Tenant moves before this Agreement ends, Tne LarMIOM may enter the ung to tlecoral9. remodel, alter or otherwise prepare the unit for
re~occupancy.
Z1. DISCRIMINATION PROHIBITED:
Tne Landlord agrees hat to tliscriminate Dasetl upon race, mbr, religion, creed, national origin, sex, age, handicap, membersmp in a class. such
as unmarried roomers or recipients of public assistance, or because mere are cnikiren m me family.
1
22. CHANGE IN RENTAL AOREEMEN'% `•~
The Landlortl may, with tae prior approval of HUD, change me terms and condalons of this Agreement. Arty changes will become effective only at
the end of the initial term or a successive term. The L.arMbrtl must mlity me Tenant of arty charge aM must otter the Tenant a new Agreamenl ar
an amendment to the existing Agreamenl. Tae Tenant must razeive the notice al least 5ixry (60) days beldre the proposetl e1lecNve dale of Iha
Change. Tha Tenant may acceDl the charged Iarms arts corMitians by signing the new Agreement or tae ameMmanl la tae existing Agreamenl and
returning it to the Landlortl. The Tenant may reject Iha charged terms and contl0ions W giving tae Lantllord writen notice Thal he/she inter143 to
terminate the tenancy. The Tenant must give such noltta at leas) thirty (30) days before the proposed charge will go into 911ect. II the Tenant does
~nol accept the amended Agreamenl, the Lantllortl may require the Tenant to move Tram tae prolazl, as Wm'bed in paragraph 23.
20. TERMINATION OF TENANCY:
a. To terminate this Agreement. the Tenant must give the Lantllortl thirty (30) days written notice ba/ore moving Irom the unit. II the Tenant does
not give Ina lull 00-day nctice. Iha Tenant shall be Iiade for rant up tae end cl the Thirty (30) days br which notice was required or to the tlale
the unit is re-rented, whichever tlale comes Nrsl.
b. Any termination of this Agreamenl by the Landlord must be carried out in axortlance with HUD regulations, stale and local law, and the terms
of this Agreement. The Wndlore may terminate mis Agreement only br:
• the Tenant's malarial noncompliance with the terms of this Agreement;
• the Tenant's malarial failure to tarry but obligations uMer any Stale Landlord and Tenant Act; or
• criminal activity That Threatens the health, safety. or right to peaceful enjoyment of the premises by other tenants or any drug-related crimi-
nal activity on ar near such premises. engaged in by a tenant, any member of the Tenant's houseaold. or any guest or other person under
the Tenant's control; or '
• other goad cause, which inGUdes, but is not limited to, the Tenant's refusal to accept the Landlord's proposed change to This Agreamenl.
Terminations for `other gootl cause' may only be ellective as of the and of any initial ar wcoessive term.
• the farm material noncompliance with the lease incllMes: (1) one or more substantial violations of the lease; (2) repealed minor violations
of the lease That (a) disrupt the livability of the projeM, (b) adversely ellect the health or safety of any person ar the right of arty tenant to
the quiet enjrymenl of the leased premises and related project lacililies. (c) inlerelere with the management of the project, or (d) have an
atlverse linanpal ellect an the protect (O) failure of ine Tenant to fimely suppty all required information on the income antl composition, or
eligibility factors. of me tenant aouseholtl (inclutlirg, but not limited lo, failure to meal the disclosure antl verilicallon requirements br Social
Security Numhars, or Iailure to sign and submit consent forms for me abtainirg of wage antl claim InMrmation Irom Stale Wage Inbrmalion
Collection Agencies), ar to knowingly provide incomplete or Inaccurate information; and (<) nompaymenl of rent w any other Ilnancial eNig-
ation duo untler the lease beyontl any grace period permiltetl under slate law. The payment of rent or any other financial obligalian due
untler the lease after the duo tlate but within me grace period parmilletl untler stale Ww constitutes a minor violation.
c. II Tha Lantllortl proposed to terminate this Agreement the Landlord agrees to give the Tenant wriden notice of the proposed termination. II the
Landlord is terminating this Agreamenl for `other good rouse; the termination notice must be mailed to the Tenant and harts-tlelivered 10 the
dwelling unit in the manner requiretl by HUD al least thirty (30) days before the dale the Tenant wiN be required to move from me unit. Notices
of proposed termination for other reasons must be given in acooreance wile arty time Irames set Icrlh in state and local law. Arty HUD-requiretl
notice period may run concurrently with any notce pertatl required by stale or local law. All lerminalion notices must:
• speuty Iha dale this Agreamenl will be lerminalod:
• stale the grounds kr lerminalion with enough detail for the Tenant to prepare a defense;
• advise the Tenant that he/she has ten (10) days wihin which to tliswss the praposetl lerminalion of tenanry with the Landlare. The 10-day
period will begin an the earlier of the dale the notce was harM.lelivered to the unit or the day aaer the dale the notice Is mailed. Ii the
Tenant requests the meeting, the Landlord agrees to discuss the proposed termination with the Tenant; and
• atlvise Iha Tenant of hiNher right to delaM tae action in court.
tl. II an eviction is Wualed, me Wndlocd agrees to rely only upon moss grounds ctted in the termination nadce requketl by paragraph (c).
2d. HA2AR05:
The Tenant shall not undertake, or permit htslaer family or guests to untlarlake, any hazareous acts or do anything that will increase the project's
insurance premiums. Such action constitutes a malarial non-compliance. II the unit is damaged by fire, wind ar rain to the extent that the unit can-
not be lived in antl the damage is not caused or made worse by Ne Tenant, the Tenant will be responsible for rent only up fo the dale of the Oeslruc
lion. Additional rant will not accrue until the unit has been repaired to a livable coMition.
25. PENALTIES FOB SUBMITTING FALSE INFORMATION:
Knowingly giving the Landlortl false information regarding income ar other factors considered in determining Tenant's eligibility and rent is a mate-
rial noncompliance with the lease subject to lerminalion of tenanry. In atltligon, NB Tenant could become subject IO penalties available uMer
Federal law. Those penalties include lines up to $70.000 antl imprisonment for up la five (S) years.
26. CONTENTS OF THIS AGREEMENT:
This Agreement antl its AOachments make up Iha entire agreement bemeen the Landlord ant the Tenant regarding the unit. II arty court declares
a particular prmision of this Agreement to be invalid ar illegal, all other terms of leis Agreamenl will remain in e6ec1 and both the Landlord ant me
Tenant will continue to be bound by them. ,
27. ATTACHMENTS TO THE AGREEMENT:
The Tenant cerlilies that he/she has received a copy of mis Agreamenl and the folbvring AaazhmenLS to mi3 Agreamenl and untlemtantls Thal these
Attachments are part of this Agreamenl:
a. Anachment No. t-Farm HUD-50059, Ceriifiwtion and Recerltlicalion of Tenant Eligibility
b. Anachmenl No. 2-Unit Inspection Report
C. Attachment No. 3-House RUIee (if any)
26. SIGNATURES:
~( TENANT
Data Signed
2.
Date Signed
~.
Date Signed
LANDLOPD-ORCHARD APARTMENTS
By' •
a' //~O~
Date Signed
zR-zo3 PuFA
x/82 9/98
RL;NEWAL '1'O IiESIDENI'IAL LEASE AG1iEEMEN'i'
0
1'fiIS ItENc'I4AL TO TIIE Residential Lease Agreement (Lease) is made
this ~~
~'y- day of l[ Q , 20200 / b1ky and bettaeen
OItC11A12D APAlt1'DtEN'fS (Landlord) and /q.,(yis{~~J /k~ViV/S (tenant).
NOW 1'IIERE['ORE, IN CONSIDERATION of the Landlord entering into tlfe
Residential Lease Agreement• with Tenant, the independent promises and
covenants of each to the other and the rent reserved, and intending to
be legally bound, Landlord and Tenant enter into this Renewal. to the
Residential Lease Agreement and agree as follows:
1. Tenant, upon signing this Renewal, agrees thaL• the term of the
.Residential Lease Agreement shall be for (1) year beginning ort the 1st
day of 'L~~L[/)' 20~ and ending on the ~~day of
-`tLtc.A '~xi or until terminated according to the terms and
conditions of'the Residential Lease Agreement. MONTH TO MONTII
~I 2. Tenant, in the event he desires to terminate the Residential
Lease Agreement, shall tender to the landlord written notice of Tenant's
desire to vacate the premises and said notice shall be tendered to the
landlord at least thirty (30) days prior to the date Tenant intends to
vacate ttte premises. If Tenant fails to tender the required thirty (30)
day written notice, he shall be liable for the monthly rental payment
for that thirty (30) day period of time together with any other damages
provided for in the Residential Apartment Lease.
3. Tenant and Landlord agree that upon signing this Renewal, the
monthly rental amount for Rental Unit No.J1 shall be $~.
Of the total rent, $ .`Z shall be payable by tl>e Pennsylvania
housing Finance Agency as housing assistance payments on behalf of the
Tenant and $ c~'J•~ shall be payable by the Tenant in the following
manner:
(a) $ l~i,.`=' as the estimated monthly utility cost for electricity.
The Tenant is responsible for paying the apartment electric bill to the
utility company.
(b) - ~~ ,o as the monthly rental payment to the Landlord.
These amounts shall be subject to change by reason of changes in
the Tenant's family income, family composition, or extent of exceptional
medical or other unusual of dousing and Urban Development; or by reason
of• adjustment by the Pennsylvania Housing Finance Agency or any applicable
Allowance for Utilities and Other Services. Any such change shall be
effective as provided for in the Renewal.
ZN WITNL'SS WltEREOF Tenant and Landlord have lie reunto set their
hands and seals all as of tiie day and year first above writ -en.
WITNESS: NUIg1
~v:, (seal)
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APARTMENTS
2204 CEDAR RUN DRIVE FJCrENDED
CAMP HILL, PA 17011
(717) 763-0937
FAX (717) 730-9323
TDD (800) 497-3843
NON-INCOME AFFIDAVIT
h ~ ~ N~ S~y. J_~A~~ S ,residing at; 22 o a , Cedar Run Drive, Camp Hill, PA
17011, do hereby sweaz and affirm that I DO NOT have any income. This includes but is not limited do
income from any of the following:
1. Wages, Public Assistance/Welfare (ADC, GR, etc.), Social Security, SSI, etc.;
2. Child Support or Alimony.
3. Regular monetary gifts from family or friends, etc.;
4. Assets (homes, stocks, etc.; this includes inherited property);
5. Interest income from Savings, Checking, Christmas Club and other bank accounts, IRA's,
Certificates of Deposit, Money Market Funds, Credit Unions, etc.;
6. U.S. Savings Bonds, Stocks or Bonds of any kind;
?. Pensions, Annuities, Retirement Funds, etc. (this includes benefits you may receive from being
a beneficiary of a life insurance or retirement plan);
8. Real Estate Property, etc.;
9. ANY INCOME, EARNED OR UNEARNED.
WARNING: Section 1001 of Title 18 of the U.S. code makes it a criminal offense to make willful false
statements or misrepresentation of any material fact involving the use or obtaining of Federal Funds.
Atso, Paragraph 25 of your Lease Agreement states: "Knowingly giving the landlord false information
regarding income or other factors considered in determining tenant's eligibility and rent is a material
noncompliance with the lease, subject to termination of tenancy."
~~,~Glll~l~ ~:Llcccs
Resident/Applicant Signature
Signed this, the ~g~'day of
~ 2~2 , 2001.
READ THIS BEFORE YOU COMPLETE AND SIGN THIS FORM.HUD; 50059
PRIVACY ACT STATEMENT. The Department of Housing and Urban Development (HUD) is
authorized to collect this information by the U.S. Housing Act of 1937, as amended (42 U.S.C. 1437 et.
Seq.); the Housing and Urban-rural Recovery Act of 1983 (P.L. 98-181); the Housing and Community
Development Technical Amendments of 1984 (P.L. 98-479); and by the Housing and Community
Development Act of 1987 (42 U.S.C. 3543). The information is being collected by HUD to determine an
applicant's eligibility, the recommended unit size, and the amount the tenant(s) must pay towazd rent and
utilities. , HUD uses this information to assist in managing certain HUD properties, to protect the
Government's financial interest, and to verify the accuracy of the information famished. HUD or a Public
Housing Authority (PHA) may conduct a computer match to verify the information you provide. This
information may be released to appropriate Federal, State, and local agencies, when relevant, and to civil,
criminal, or regulatory investigators and prosecutors. However, the information will not be otherwise
disclosed or released outside of HUD, except as permitted or required by law. You must provide all of the
information requested, including the Social Security Number (SSNs) you, and all other household family
members age six (6) years and older is mandatory; not providing the SSNs will affect your eligibility
Failure to provide any information may result in a delay or rejection of your eligibility approval.
TENANT(S)' CERTIFICATION. IlWe certify that the information in Parts II, III, and N of this form are
true and complete to the best of myfour knowledge and belief. I/We understand that IlWe can be fined up to
$10,000, or imprisoned' np to five yeazs, or lose the subsidy HUD pays and have my/our rent increased, if
UWe furnish false or incomplete information.
OWNER'S CERTIFICATION. I certify that this Tenant's eligibility, rent and assistance payment have
been computed in accordance with HUD's regulations and administrative procedures and that all required
verifications were obtained.
WARNING TO OWNERS AND TENANTS. By signing in part VIII of this form, you are agreeing with
the applicable Certification.
FALSE CLAIMS STATEMENT. Warning: U.S. Code, Title 31. Section 3729, False Claims, provides a
civil penalty of not less than $5,000 and not more than $10,000, plus 3 times the amount of damages for any
person who knowingly presents, or causes to be presented, a false or fraudulent claim; or who knowingly
makes, or caused to be used, a false record or statement; or conspires to defraud the Government by getting a
false or fraudulent claim allowed or paid.
PUBLIC REPORTING BURDEN. The reporting burden for this collection of information is estimated to
average 1 hour per response, including the time for reviewing instructions, searching existing date sources,
gathering and maintaining the data needed, and completing and reviewing the collection of information.
Send comments regarding this burden estimate or any other aspect of this collection of information,
including suggestions for reducing this burden, to the Reports Management Officer, Office of Information
Policies and Systems, U.S. Department of Housing and Urban Development, Washington, D.C. 20410-3600;
and to the Office of Management and Budget, Paperwork Reduction Project (1502-0204), Washington, D.C.
20503. Do not send this completed form to either of these addresses.
x~yxGU1~Gs- ~ ~Ccics
Tenant Signature
~~~8-~J
Date
Form HUD-50059 (8/87)
Ref. Handbook 430.3
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
ORCHARD APARTMENT
ASSOCIATES, t/d/b/a
ORCHARD APARTMENTS,
Plaintiff
v.
TANISHA DENNIS,
Defendant
NO. 01-5256
CIVIL ACTION -LAW
ORDER
AND NOW, this ?~ day of September, 2001, after hearing having been held on
Plaintiff s Complaint filed pursuant to the Model Expedited Eviction of Drug Traffickers
Act, judgment in favor of Plaintiff, Orchard Apartment Associates t/d/b/a Orchard
Apartments, and against Defendant, TanishaDennis, for possession ofthe premises known
and numbered as 2202-D Cedar Run Drive Ext., Camp Hill, Lower Allen Township,
Cumberland County, Pennsylvania is hereby GRANTED. Defendant and all members of
her household are completely evicted from the premises known and numbered as 2202-D
Cedar Run Drive Ext., Camp Hill, Lower Allen Township, .Cumberland County,
Pennsylvania.
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The Prothonotary is hereby directed to accept and docket a Praecipe for Writ of
Possession and transmit the Writ ofPossession to thel,Sheriffof Cumberland County. The
2v~~~lac~> 2l IO~~~'s~~~f cx~Jc~sc>
Sheriff of Cumberland County is d~eeteA to effect the eviction of the Defendant and all
members of her household immediately. The Sheriff shall serve the Writ ofPossession on
the Defendant either by personal service or by posting the Writ ofPossession on the most
public or conspicuous portion ofthe premises known and numbered as 2202-D Cedar Run
Drive Ext., Camp Hill, Lower Allen Township, Cumberland County, Pennsylvania.
BY THE COURT:
//,
~~ ~
~n~~t.~U ~~~~~~6 ~~
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-05256 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ORCHARD APARTMENTS ASSOCIATES
VS
DENNIS TANISHA
RICHARD SMITH Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
DENNIS TANISHA
DEFENDANT
the
at 0018:10 HOURS, on the 17th day of September, 2001
at 2202-D CEDAR RUN DRIVE
CAMP HILL, PA 17011 by handing to
TANISHA DENNIS
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 10.40
Affidavit .00
Surcharge 10.00
.00
38.40
So Answers:
09/18/2001
CUNNINGH
Sworn and Subscribed to before By:
me this ,2p~ day of
D A.D.
rothonotary
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By virtue of this writ, on the FTFTI-I day of OC'1'OBER 2001
I caused the within named ORCHARD APARTMENT ASSOC, T/D/B/A ORCHARD APARTMENTS , to
have possession of the premises describe 2202 D. CEDAR RUN DRIVE EXT.
CAMP HILL, PA 17011.
Advance Costs: 150
S 18.00
Ill~ffi~
Sheriff's Costs
l~9/00~6'
1 'session 30.00 ,,.~_~~ Refunded to Atty 10/8/01
~harge 20.00 t: l ` ~+p ~., ,, ,, _ ~t.~~;
Sworn and subscribed to before me this ~~ ,,,.3;~0: ~~~
k. Ik~~" ~ ,dam ~_~„
day of /~ ((1ct~._. dB~! ,1345!&~V~;->i~,+,,.=~-~'
eriff /
~t ~.eC/a.. By 9.
Prothonotary ~ _ _ ~ ~ c~2 3ti ~' ~
y~.-• /l7GGs
WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160 - 3165 etc.)
Orchard Apartment Associates
t/d/b/a Orchard Apartments
vs.
Tanisha Dennis
2202-D Cedar Run Dr. Ext.
Camp Hill PA 17011
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 01-5256 Civil Term
No. Term
Costs
Atty. $ 98.90
PI'ff (s) $
Prothy: $ 1.00
To the Sheriff of CUMBERLAND County, Pennsylvania
(1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the
following described property to:
Orchard Apartment Associates t/dJb/a Orchard Apartments
Plaintiff (s)
being: (Premises as follows):
2202=D Cedar Run Drive Ext.
Camp Hill, Lower Allen Township
PA ;17011
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defen-
dant (s) and sell his/her (or their) interest therein.
CURTIS R. LONG:
Dace October 1, 2001
(SEAL)
Prothonotary, Common Pleas Court of Cumberland County, Pennsylvania
i -
By: t~C~
Deputy
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORCHARD APARTMENT
ASSOCIATES, t/d/b/a
ORCHARD APARTMENT,
Plaintiff
NO. 01-5256
v.
TANISHA bENNI5,
CIVIL ACTION -LAW
PIBAECIl'E FOR WRIT OF POSSESSION
TO THE PROTHONOTARY:
Issue Writ of Possession against the Defendant and in favor of the Plaintiff in the
above stated action. for premises known as 2202-D Cedar Run Drive Ext. ,
Lower Allen Twp., Camp Hill PA 17011.*
Respectfully submitted,
P.C.
Date: ~ ~ ~,
*Per telephone cornressation
with Atty Jordan Cimni~nyha<n
on 10-2-O1. ~~
~2,ie~d-- r~ C~~e.~ IPec~ ~v. C~
Lei c.,~~-r ~c~~v~ zwp~
7q~an D~Cu~gham, Esquire
~j #23144/
2320 North Second Street
P. O. Box 60457
Harrisburg, PA 17106-0457
Telephone: (717) 238-6570
(Attorneys for Plaintiff)
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