HomeMy WebLinkAbout01-05999
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CARLISLE PIKE ASSOCIATES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
01 - 5999
:
CIVIL ACTION - LAW
KATHRYN M. GETZ,
Defendant
:
: EVICTION
NOT ICE
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take action
within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by attorney
and filing in writing with the court your defenses or objections
to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may
be entered against you by the court without further notice for any
money claimed in the complaint or for any other claim or relief
requested by the plaintiff. You may lose money or property or
other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
By:
ANDREW C. SHEELY,
Pa. I.D. No. 62469
127 S. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
(717) 697-7050
Attorney for Plaintiff
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CARLISLE PIKE ASSOCIATES,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
01 - 5999
CIVIL ACTION - LAW
KATHRYN M. GETZ,
Defendant
EVICTION
COMPLAINT
plaintiff, Carlisle pike Associates, by and through counsel
of Andrew C. sheely, Esquire, hereby files this complaint and
respectfully states as follows:
1. Plaintiff is Carlisle Pike Associates with an address of
155 Salem Church Road, Mechanicsburg, Cumberland County,
Pennsylvania and also having a Post Office Box Number of 124,
Carlisle, pennsylvania, 17013.
2. Defendant Kathryn M. Getz is an adult individual with a
current address of 6280 Carlisle pike, Lot 309, Mechanicsburg,
Pennsylvania Pennsylvania 17055.
3. Plaintiff is the record legal owner of certain real estate
being improved with a mobile home park, being known as Salem Acres
Home Park, having been acquired by Deed dated March 18, 1997 and
recorded April 1, 1997.
5. Plaintiff acquired an immediate right to possession and
ownership of the leased premises by virtue of the deed as referred
to in paragraph No. 4 hereinabove.
6. Defendant is presently residing in a mobile home and
occupying Lot No. 309 of the Salem Acres Mobile Home park, said
lot being situated on Plaintiff's real property as described
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above.
7. On or about April 18, 2000 Defendant executed a lease with
Plaintiff and Defendant has continually resided in the park since
April of 2000. A copy of the lease agreement is attached hereto as
Exhibit "A".
8. On or about April 18, 2000, Defendant executed Rules and
Regulations with Plaintiff and has continually resided in the park
since April of 2000. Copies of the park rules and regulations are
attached hereto as Exhibit "B".
9. On or about July 10, 2001, Plaintiff directed a Notice to
Quit to Defendant by certified mail advising Defendant of her
failure to pay timely rent and failure to comply with rules and
regulations regarding the payment of rent.
10. The July 10, 2001 Notice was delivered to Defendant by
certified mail and posted on the property.
11. On or about September 25, 2001, Plaintiff directed a
second Notice to Quit to Defendant by certified mail advising
Defendant of her failure to pay timely rent and failure to comply
with rules and regulations regarding the payment of rent, as well
as violations of rules and regulations number 6 regarding
subletting and rule number 20 regarding conduct of guests within
the mobile home park.
12. The September 25, 2001 Notice was delivered to Defendant
by certified mail and posted on the property.
13. Defendant has repeatedly failed to pay timely rent within
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a six (6) month period.
14. Defendant has repeatedly failed to comply with park
rules and regulations regarding the payment of rent, conduct and
behavior of her guests and subletting to persons not on a lease.
15. Notices informing Defendant to quit the leased premises
were provided to Defendant at least thirty days in advance of the
filing of this action for eviction.
16. Defendant continues to violate park rules and regulations
by allowing her guests to cause disruption within the park.
17. Plaintiff is entitled to evict Defendant as a matter of
law for repeated rule violations.
WHEREFORE, plaintiff requests that this Honorable Court enter
judgment against Defendant and in favor of Plaintiff, and
(1) direct that Defendant immediately remove herself, her
belongings and the mobile home from Lot No. 309 of the mobile home
park; and
(2) enter an Order of Court directing Defendant to pay for and
assume Plaintiff's court costs, legal costs and fees;
(3) Any other relief deemed just and equitable.
Date: November 14, 2001
ely,
Attorney for Plaint
127S. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
717-697-7050
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VERIFICATION
I verify that the statements made in this Complaint are true and
correct. I understand that unsworn statements herein are made subject
to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn
falsification to authorities.
DATE: November IS' ,2001
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EXHIBIT "A"
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Salem Acres I Six Links Mobile Home Parks
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.1. Lease. .
This agreement is entere int thIs ~ day of 1':1 ~,. ,I 190 D between Saiem Acres / Six Links Mobile H me
Parks as landlord, and' r \d ~II promises and agreements made by both parties hall
be contained in writing wi h t e ental Agree nt and Rules and Regulations.
1. ~C~:lion of Premises: L~ndlord hereby agrees to rent to tenant, Space # iJJL\C'~, the mailing address of which is: Spa e #
, Salem Acres Mobile Home Park, 6280 Carlisle Pike, Mechanicsburg,'PA.7i7055 or Space # , Six Links M bile
Home ark, 155 Salem Church Road, Mechanicsburg, PAc 17055
2. Manage t: e na d address of the authorized manager is:
Name: -
Address: 0 i , s / Six Links M.H.P.
Mechanicsburg, 17055
Telephone: 717/766-8641 () f -
3. Terms of Agreement: The term of this agreement is month t~~o~, commencing ~ f j.8'" (\,
4. Rental Charge: The Tenant agrees to pay a total rental of $ I per month, payable n advance on or before the first (1st day
of each month during the term of this agreement. The rent shall be paid at the office of the park. A late charge of 3.00 a day sta ing
the sec~nd(2nd) day of each month ~i11 ~e charged until the rent is paid. To cover administrative costs, a ser~ Ch rge
of $25 Will be made for each check which IS not honored by the bank. The above rental consists of a base rent of $ . , hich
is based on Four(4} occupants per mobile home space, and Two(2) vehicles per mobile home space plus any additional mo thly
charges as listed in Paragraph #5. Rental increases for a month to month tenancy shall be preceded by a 30 day written noti e to
such increase to which automatically amends the agreement in that respect without any other act of the parties.
PARTIAL PAYMENT: No payment by Resident or receipt by Park Owner of an amount less than 1he monthly rent herein provi ed,
or a statement on any check, nor on any letter accompanying any check or payment for rent, shall be deemed an accord and
of such rents or pursue any other remedy provided in this Agreement or by law. . .d '"'
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5. Fees and Charges: In add'. n.to the base rent specified in Paragraph #4 above, the following additional fees will be assessl'd: U
A. More than four(4) cuparlts - $15.00 per person per month
B. Security Deposit - 99.00 atti e of signing this lease. 1 JL
c. . Initiar#r
6. Services: / Lrr..
A. Landlord: will provide to the Tenant the following services to the point of connection to the mobile home at ground level: Water
and Sewer, at the outside electrical meter Electricity.
B. Landlord: will pay the monthly costs of the following services: water, sewer and garbage collection. Landlord reserve~ the
right to pass through any cost increase(s) by use of a surcharge for these services.
C. Tenant agrees to pay for those services marked "yes"
Sewer No Garbage No
Electricity Yes TV Cable Yes
Fuel Yes Phone Yes
Water No Other Any other services subscribed to by Tenant is their responsibility.
7. Assignment or Subletting: The Tenant is prohibited from assigning this agreement or subletting the space rented hereunder, or
any part thereof.
8. Tenants Obligations: Tenant agrees to comply with the terms of this agreement and the Rules and Regulations, a copy of which is
attached to hereto and made a part of this agreement, as well as any additional rules and regulations which may from time to time
be issued by the Landlord. Tenant is responsible for seeing that members of the tenants household abide by the rules and regulations
throughout the entire duration of their occupancy in the Park. In addition to other agreements, terms and conditions herein, the
tenants shall have the following affirmative obligations:
A. To keep that part of the park which they occupy and use, clean and sanitary.
B. To dispose in manner provided all rubbish, garbage, and other wastes in a clean and sanitary manner.
C. Not to permit any person on the premises, with Tenants permission, to willfully or wantonly destroy, deface, damage, impair or
remove any part of the facilities, equipment or appurtenances thereto, nor will they do any such thing.
9. Pets: New pets are not allowed in the park. All pets presently in Salem Acres are allowed to remain subject to the rules of the
parle NOVISITING PETS ALLOWED. Any pet running loose in the park will be impounded. There will be a $50.00 lee for impoun~f)'\ t
plus any charges from the pound. There is a $10.00 pet fee per month. '
Initial: J
10. Lessee may not place or continue in place from this date forward any aboveground or underground storage tanks on the Pren]is s (.
without the express prior written consent of the Lessor. It shall be the Lessee's sole responsibility to comply with all existing, and
future statutes, rules, regulations, ordinances, and ordrs related to the storage tanks (including pipes and equipment connected
thereto) on the Premises, and to keep and maintain the tanks in good condition and repair, such that they do not leak or present any
harm or threat of harm whatsoever to the Premises, the public safety and welfare, or the environment. Lessee shall indemnify and
hold harmless Lessor from and against any and all expenses, liabilities, or costs of any kind or nature, including attorney's fees,
arising out of, caused by, or related in any way to Lessee's installation, ownership, operation, maintenance, or closure of the storage
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11.
tanks. Upon the termi~ation of.this Lease, Lessor may at its sole discretion require Lessee to remove the tank~ and clean u~and
restore the Premises to background conditions. A viol~tion of this paragraph shall constitute a material breach of, the leas . In
addition .to any 6ther remedies avaliabie, upon Lessee s laliure to comply with this paragraph or obtain the Lessor s appro rl to
maintain the tanks on the Premises, Lessor may, but is not obligated to, (1) order the Lessee to remove or repair the tank and
restore the site, (2) without waiving its right to indemnification or to pursue any remedies available, remove or repair the tanks and
restore the property itself at the Lessee's expense, and/or (3) terminate this lease. Lessor shall have the righl to inspec Ihe
premises, to ensure compliance with this paragraph. . I
$ale of Home:
A. Tenant has the right to sell their home and it must be removed from the park except with prior written consent 0 the
Landlord.
B. Prior Approval: A home will be permitted to stay in the park only if it is structurally sO.und and presents a neat, clean and
safe appearance inside and outside, and passes Managements inspection before the home if offered for ale.
Management is to be the sole judge of whether the home meets the standards to remain in the park, and the Tenant ag ees
to accept Managements judgement as final. Management will, if possible, give recommendations as to what should be one
to the home to put it into condition to remain in the Park. If these recommendations are not completed prior to the sale 0 the
home, it can not remain in the Park.
C. New Tenant in an existing Home: All new Tenants must be APPROVED by Management PRIOR to taking possession of a
mob.ile home that Management has approved to remain in the Park. If someone buys a home in the Park, and is not appro ed,
the home must be removed from the Park at once.
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12. Termination of Tenancy:
By Tenant: Upon at lease 30 days notice in writing.
By Landlord:
A. By giving Tenant not less than 30 days notice in writing if the tenant violates a law or ordinance which relates to the Ten nts
conduct as as mobile home tenant or violates a rule or regulation duly imposed as a condition of occupancy: provided, how ver,
thatTenant shall be advised ofthe reason(s) tor termination ofthe tenancy and provided furtherthatTenant may avoid termin tion
of the tenancy by correcting the violation within the 30 day period specified in the notice. However, if a second violation 0 the
rules occurs within 6 months, Management may terminate the tenancy as prescribed by law.
fl. By giving not less than 90 days written notice if Management intends to cease operations of the mobile home park, or any
portions of it. , I
C. For failure to pay rent. If not so paid, the landlord may terminate the tenancy and institute eviction proceedings in court.
D. For cause materially affecting health and safety of the Landlord/Management and/or other Tenants and doing damage(s) or
threatening damage to the Landlord's property or to other properties in the Park. .
E. 'If tenant breaks the lease, each tenant agrees to give up the right to have a Notice to Leave, also known as a Notice to Quit. This
means that the Landlord may file a lawsuit in court asking for a court order evicting each Tenant from the leased propf'rty
without giving each Tenant Notice to Quit first. Landlord does not have the right to throw Tenant out of the leased property. :The
landlord can only evict Tenant by court action.
The Landlord does not ha~e the right to sue in court for eviction unless a Tenant has broken the agreements in this Letse.
Even though each Tenant IS giVing up Notice to Qwt, each Tenant Will have a chance In court to have a judge decide on
Landlord's claim for eviction.
II Tenant breaks 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 breaking the agreements in the Lease.
2) To get the leased property back (eviction).
3) To collect for unpaid rent until the end of the Lease or until another person moves into the Leased property as a new
Tenant.
If Landlord wins a lawsuit against Tenant, Landlord can use the court process to take Tenant's personal goods, furniture,
motor vehicles and money in banks.
Tenant agrees that Landlord may receive reasonable attorneys fees as part of a court ruling in a lawsuit against Tenant for
breaking the agreements of this Lease. ,..-1/(1,(
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13. Tenant to pay certain costs: If a mobile home or other personal property is abandoned by Tenant and rents are two (2) months t
delinquent, Management may sell the mobile home or other personal property permitted by law and may deduct from the selling
price all delinquent rents and charges and all costs and expenses legally incurred by Management in moving and storing a mobile
home, including reasonable storage charges.
14. Costs and Disbursements: In any suit or action arising out of this agreement, or the interpretation of its terms, reasonable attorrey
fees may be awarded to the prevailmg party in both the tnal and appellate courts as part of costs and disbursements. I
This agreement also includes all ru and regulations of Management attached hereto and which are made a condition of occupa~cy.
In Witness whereof, th,e par' s ha Qned this agreement :
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Landlord \JJ . Date "\ - \ 1, - D V !
By ~~ ~:~
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Date l-f-/6-o (J
Date~
Revised 7-7-97
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Salem Acres / Six Links Mobile Home Parks
8/24/93
Rules and Regulations
Objective: To provide our Tenants with a clean, quiet and attractive Park in which to Hve.
1. Rent must be paid monthly in advance on or before the first of each month. A daiiy charge of $3.00 a day starting on th~
second (2nd) day of each month Will be charged until the rent is paid. A service fee of $25.00 will be charged for any returne~
checks. \
2. There will be a charge of $5.00 per day for guests staying longer than fourteen (14) days. ,
3. There i~ a $10.00 monthly charge for storag~ of boats, boat trailers, tent campers, pick-up campers, R. V. trailers or any othef
recreational vehicles. The Manager Will adVise you of the area where the item may be stored. Parking of such vehicles, 0['
commercial vehicles, tractors or trailers on grass or in the street is prohibited.
4. Tenants must pay all real estate taxes assessed and levied against their mobile homes to the appropriate governmental
agency. I
5. Under Pennsylvania State Lawall residents must be registered w~h our Manager. Before removing a mobile .home from th~
Park, a removal permit must be obtained from the Township Tax CollectOr and shown to our Manager. All Tenants must notify
the Manager 30 days in advance when planning to move from the Park, or forfe~ their Security Deposit. All rents and other
charges must be paid before the Manager will give permission to the Mover to move your home. I
6. NO SUB-LETTING IS PERMITTED. Only those who have signed a lease are permitted to live i.~ Salem. Acre!llSix Link~
Mobile Home Parks. If a mobile home Is sold, both the HOME and PURCHASER ".user BE' AiPPRQVED B'(
MANAGEMENT PRIOR TO THE SALE, If seller wishes to have the home remain In the Pa~k after th~
sale. . .
7. Sale of Home:
A. Tenant has the right to sell their home and it must be removed from the park except with prior
written consent of the Landlord.
B. Prior Approval: A home will be permitted to stay in the park only if ~ is structurallY' sound and presents s
neat, clean and safe appearance Inside and outside, and pas.es Management's Inspedtlon 'before
the home is offered for sale. Management is to be the sole judge of whether the home meets' the, standards to
remain in the park, and the Tenant agrees to accept Mariagement~s judgment as final'. Management will, if
possible, give recommendations as to what shoulc:l be done to the home to put it into condition to remain in the Park. \j
these recommendations are not completed prior to the sale of the home, ~ cannot remain In the Park.
C. New Tenant in an Exlsllng Home: All new Tenants must be approved by management prior to taking possession
of a mobile home that Management has approved to remain in the Park. If someone buys a home in the F1ark, and Is
not approved, the home must be removed from the Park at once. ~ /, ,
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6. After any home is abandoned in this Park for 30 days or more, Management is hereby given permission .to en..'~",
have the home moved to a storage area. The owner of the home will be responsible for all costs incurred. ' . /
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9. Any equipment, fixtures or goods or other property of the Lessee (Tenant) not removed by Lessee quilling, vacating or
abandoning the premises, or upon the eviction of Lessee shall be considered abandoned and Lessor (Manageme~t) sh II. have
the right, without any notice to the Lessee, to sell or otherwise dispose of the same. t:<:: /
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10. II a mobiie home is substantially damaged by fire, or is beyond economic repair for whatever reason, Management will ask the
home owners to remove it. Thirty (30) days thereafter, Management may consider the home abandoned, and dispos~ of it as
junk, at the owner's expense. '
Initial
11.
12.
Management reserves the right of access to yards and equipment spaces for inspection and
maintenance.
Residents shall not conduct any business whatsoever from their mobile homes, including babysitting services, moving or
yard sales.
SoHelting is prohib~ed without the express consent of Management. Please notify the Park Manager of vendors are attempting
to soHelt
Residents of the Park must be quiet alter 10:00 PM and before 7:00 AM. Loud stereos, or ioud talking that can be
heard outside of the mobile home and which resuIJs in complaints will be grounds lor an eviction notice.
Open fires are permilled only in a conventional outdoor charcoal or gas unit.
No unHcensed vehicles, no motorcycles, motor scooters, go-carts, mini-bikes, 3-wheelers, etc. may be operated in Park, nor
may immobiiized or disabled autos with or wilhout vaHd registration plates be parked In the Park. !
P,ets: New pets are not allowed In the park. All pets presently in Salem Acres are allowed to remain subject to the
r,ules of the Park. No vlslllng pats sllowed. Any pet running loose in the Park will be impounded. There will be 0.00 fee
lor impoundment plus any charges Irom the pound. There is a $t 0.00 pet fee per month. . .' ''f (..
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13.
14.
15.
16.
17.
18.
Please park only in the two (2) spaces in Iront of your home, and do not park on the grass.
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19. Whe" in use, 'children's wading pools must be placed only on the patio. Piease do not ever place them on the grass. When th
are not in use, please Keep them in a storage shed. The location of individual swing sets must be approved by Management.
Tenants will be held responsible for the conduct and damage caused by their children and/or guests.
Residents must keep their homes clean, painted and skirting repaired. Yards must be neat and mo,wed at "II times. No debri ,
lumber, boxes, tires, r"frigerators,broken furniture or loose paper will be stored outside a storage. shed. Fences of approve
types are permitted. Any tenent considering a fence MUST get approval from the Management BEFORE any installation 's
undertaken.
Management reserves the right to mow any lawn that is negiected, or to cut weeds, for which Tenant will pay a service charg
of $20.00.
Plantin.g of flowers and shrubs is e.ncouraged, but before digging, please see the Manager because of the underground wiri
and pipes. Plants may be wa,tered only with buckets and sprinkling cans, and cars may be washed using buckets only. N
hoses are alloWed. Please keep the parking area in front of your home clean.
22. Utility sheds approved by Management as to size, construction and location are permitted.. The shed must be properl
anchored and insured.
23, Cabanas and awnings of approved manufactured types are permitted. Please see the Manager Jar approval. Sell-mad
cabanas and canvas awnings are not acceptable. Please use only umbrella type outside clothes dryers. Clothes lines sr
not permitted.
24. All mobile homes must be skirted, using manufactured type skirting approved by the Manager, within 30 days of entering Pa
When installing skirting, an opening must be made at the sewer and water connections for servicing. Any home wittiout skirtin
in excess of thirty (30) days will be assessed $100.00 per month until skirting is installed. '-If. ~. .
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25. Objects such as sanitary napkins, Tampax, disposable diapers, paper towels, rags, newspap rs an~
Kleenex are not to be flushed down the toilet or other drains, as this causes the sewer to clog and back u~.
Residents will be chllrged for labor and other costs involved in cleaning the sewer line if the problem is caused by any if
the above objects. '
No outside faucet for water will be installed on the Park water system. I
Please keep trash and garbage in water-proof plastic or galvanized containers with tight lids. These are to be put out on piC~-
up day which is currently every Monday. Please put the containers away after pick-up, so they are inconsp,icuous, at the rea,r
of your home. Refuse which will not fit in a trash container, such as mattresses, chairs, tires, etc. should be disposed of ~y
the owner. II Park Manager has to dispose of these items, there will be a $50.00 labor charge, in addition to all other cosls
incurred. '
28. . Tenant is responsible for keeping his own water and sewer connection from leaking or freezing from the ground or valve up to
where it connects to the mobile home. Outside water lines must have electric heat tapes and protective insulation installed
and ready for use by October 31 st. .
29. Owners may make minor repa,irs to their own vehicle, in an area provided by the Manager, at no cost to Tenant, but the placing
of vehicles on jacks, blocks or ramps, and performing major repairs, or draining of motor oil is prohibited. I
30, The speed limit in the Park is 5 miles per hour. This is for the protection of our elderly tenants, and children who play or I
the Park streets. Please watch for the speed bumps. ,
31, All mobile homes are required to keep their running gear attached, such as axles, springs, tires and rims, so that mobile home
can be moved if necessary.
32 Sidewalks and car parking spaces must be cleared of snow as soon as possible, and no later than 24 hours after the snowfall.
33, The Owners/Management/Manager of Salem Acres/Six Links Mobile Home Park shall not be liable br responsible for any
damage, injury or loss by accident, theft or fire to either property, person, or guest which may be sustained ,as a consequence
of the failure, breakage, leakage or obstruction of the water and sewer system, electrical, gas or oil system or from
negligence, or improper conduct on the part of any resident or guest. Residents are urged to obtain the necessary
fire and liability Insurance against these contingencies. Any signatures affixed to the rental agreement or to
these Rules and Regulations by the residents shall constitute an obligation upon all members of their immedi~te family and
guests.
34. Ma~agement reserves the right to canc~1 or change any of these Rules and Regulations, and to make such other regulations,
as In their Judgement may from time to time be necessary for the safety, maintenance and proper operation of the Park. Such
changes, when so made, and when notice thereof is given to the resident, shall have the same force and effect as if originally
made a part of this agreement.
35. If, for any reason, any portion of these Rules and Regulations should be declared invalid, the remaining portions of thesf'
Ruies and Regulations shall remain in full force and effect.
These rules have been written for the benefit of all. They are not meant to restrict your personal IIbertle'i
but becau. se we are a close community, we must be careful that our activities will not Infringe unPleaSantlr'
on others.
I halfe read these rules and regulations dated August 24, 1993, and accept and agree to them as a conditiOn
for my residing at Salem Acres/Six Links Mobile Home Park. I
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CERTIFICATE OF SERVICE
I, Andrew C. Sheely, Esquire, hereby certify that I am this day
serving the foregoing Complaint upon the following named individual this
day by depositing same in the United States Mail, First Class, postage
prepaid, at Mechanicsburg, Pennsylvania, addressed as follows:
PHILIP C. BRIGANTI, ESQUIRE
MID PENN LEGAL SERVICES
8 IRVINE ROW
CARLISLE PA17013
Date: November 15 2001
n rew C. Sheely, Esquir
Attorney for Plaintiff
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~ -." JUDICIAL DISTRICT
NOTICE OF APPEAL / (), I g" () /
FROM
COMf'!!ONYt,~TH OF PENNSYLVANIA
COURT OF COMMON PLEAS
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. 0/-.11 qq 9
NOTICE OF APPEAL
fJUbl
Notice is given that the appellant has filed in the abave Caurt of Common Pleas an appeal from the judgment rendered by the District Justice on the
date and in the case mentioned bel"",
NAME OF APPfLLANT
Kathryn /!1l. Getz
ADDRESS OF APPEllANT
6280 Carlisle pike Lot 309
MAG. DlST. NO O' NAME OLl>4,
Thomas A. l'.Lacey
aTY
Mechanicsburg
~t{"
1 7 0 5"6 COOE
~TE OF NT
10-9-01
INTH CASEQF(Plairrtiff) ar 1.S e
Salem Acres Mobile Home Park
"'-
SIGNATURE OF APPEU.ANT OR HIS ATTORNEY OR AGENT
hilip C. Briganti
idpenn Legal Services
Row Carlisle PA.17013
If appellant was CLAIMANT (see Pac 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.
(Defendant)
Kathryn M. Getz
CV 111
LT I~T-0000483-01
This block will be ~gned ONLY when this nota~on is required under Po. R.C.PJP. No.
10088.
This Notice of Appeal. ..' n received by the District Justice, will operate as a
SUPERSEDEAS to th~ < gm nt for
('.
WlM NO
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before District Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPE: To Prothonotary
Carlisle Pike Associates t/a
Enter rule upon:=::" 1 E'r~qr"'q5 MOJ;>i~;'~P~Ie!srrk ,appellee(s), to file a complaint in this appeal
(Cammon Pleas No. () {- (J I ~\h\ r-) within twenty (20) days after
RULE:
Carlisle Pike Associates t/a
fuSalQm AcrQs MgbilQ~gmo Park
Name of appeJ s)
. appellee(s).
(1) You are notified that a rule is hereby entered upon yau to file a complaint in this appeal within twenty (20) days after the date of
service of this rule upon you by personal service or by certified or registered maiL
(2) If you do not file a camplaint within this ~me, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of mail'
Date:
IO-/~-(j1 .~_.
AOPC 312-84
COURT FILE TO BE FILED WITH PROTHONOTARY
__;J,~j{"g,,y,'"'~"_;1~)~!!,y,,jt.if_"'_-41'<_~~iIi%i!m,j(ili!1I't;"<;;>\~'''''l'il'd'k-t-w;lll;~~!fiillllii~11IE IT
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PROOF Of SERVICE Of NO'flCE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) DA YS AFTER filing the notice of appeal. Check applicable boxes)
COMMC'NWEALTI1 OF PENNSYLVANIA
COUNTY OF_____
- ; -a$-
AFFIUA VIT: I hereby ~wear or affirm that I serveo
8 copy of the Notice of Appeal, Common P'eas No, ' upon the District Justice designated therein on
(date of service) 0 by personal service 0 by (certified) (registered) mail, sender's
receipt attached hereto. and upon the appeile6, (name) , on
, 19__ 0 by personal service 0 by (certified) (registered) mail, sender's receipt attached hereto.
[J and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee{s) to whom
the Rule was addressed on , 19~ 0 by personal service 0 by (certified) (registered)
mail, sender's receipt attached hereto,
SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS ~____~___ DAY OF _~__ , 19___
Signature of affiant
Signatue of ({ft,cia! before whom affidavit \tElS mariA
Title of official
My commission expires on _______
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NOTICE OF JUDGMENTITRAN~CRIPT
PLAINTIFF RESIDENTIAL LEASE
. NAME and ADDRESS
~ISLE PIKE ASSOC. T/A SALEM ACRE
155 SALEM CHURCH RD
MECHANIcSBURG, PA 17050
L
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'COMMONWEALTH OF PENNSYLVANIA
aD.lclNTY OF: CUMBERLAND
. ,"
,. Mag, Disl. No.;
09-3-04
DJ Name; Hon.
THOMAS A. PLAcEY
A<"",", 104 S. SPORTING HILL
MECHANIcSBURG, PA
RD.
-'
T"'phoo" (717) 761-8230 17050
DEFENDANT:
IGETZ, KATHRYN
6280 CARLISLE PIKE
LOT 309
~CHANICSBURG, PA 17050
VS.
NAME and ADDRESS
I
KATHRYN GETZ
6280 CARLISLE PIKE
LOT 309
MECHANIcSBURG, PA 17050
-'
Docket No.: LT- 0000483 - 01
Date Filed: 9/28/01
THIS IS TO NOTIFY YOU THAT:
Judgment" FOR PLAINTIFF
[!J Judgment was entered for: (Name) CARLISLE PIKE ASSOC. T/ASALEM
o Judgment was entered against GETZ, KATHRYN
iXJ Landlord/Tenantactionintheamountof$ .00 on 10/09/01
The amount of rent per month, as established by the District Justice, is $
The total amount of the Security Deposit is $ 99.00
. Total Amount Established by OJ Less' Security Deposit Apo.liild = Adjudicated Amoust
Rent In Arrears $ .00 - $ . '00 = $ . 0
Physical Damages Leasehold Property $ .00 $ .00 $ .00
Damages/Unjust Detention $ nn - $ _ nn $ nn
Less Amt Due Defendant from Cross Complaint - $ _ 00
Interest (if provided by lease) $ nn
UT Judgment Amount $ nn
Judgment Costs $ _ 00
Attorney Fees $ n n
Total Judgment $ .00
Post Judgrnent Credits $
Post Judgment Costs $
Certified Judgment Total $
y Ime 0 eVIC Ion.
o Defendanfs are jointly and severally liable.
in a
. (Date of Judgment)
325.00.
o
o
[!J
Attachment Prohibited/
Victim of Abuse (Act 5, 1996)
This case dismissed without prejudice.
Possession granted.
o
o
o
o
Possession ,granted if rnoney judgment is no sa IS Ie
Possession not granted.
Levy is stayed for days or 0 generally stayed.
Objecfion to Levy has been filed and hearing will be held:
Date:
Place:
Time:
IN AN ACTIQN INVQLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TQ APPEAL FRQM A JUDGMENT FQR PQSSESSION WITHIN
TEN DAYS AFTER THE DATE .oF ENTRY .oF JUDGMENT BY FILING A NQTICE .oF APPEAL WITH THE PR.ol'HONQTARY/CLERK .oF CQURTS
.oF THE CQURT .oF CQMMQN PLEAS, CIVIL DIVISIQN. THIS APPEAL WILL INCLUDE AN APPEAL .oF THE MONEY JUDGMENT, IF ANY. IN
.oRDER 1'.0 .oBTAIN A SUPERSEDEAS, THEAPPELLANTMUST DEPQSIT WITH THE PRQTHQNQTARY/CLERK .oF C:OURTSTHE LESSER .oF
THREE MQNTHS RENT .oR THE RENT ACTUALLY IN ARREARS .oN THE DATE THE APPEAL IS FILED.
IF A PARTY WISHES TQ APPEAL .oNLY THE MQNEY PQRTIQN .oF A JUDGMENT INVQLVING A RESIDENTIAL LEASE, THE PARTY HAS
30 DAYS AFTER THE DATE .oF ENTRY .oF JUDGMENT IN WHICH TQ FI NQTICE .oF APPEAL WITH THE PRQTHQNQTARY/CLERK .oF
CQURTS .oF THE CQURT .oF CQMMQN P , CIVIL DlVISI
THE PARTY FILING AN APPEAL DE A CQPY
In-I' (": I Date
ertl y t at t IS IS a true an c rrect sqr-X" "
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1\ :. i {, l Date ,cO".-
~~r.~?,I);l~ission expires first Monday of Ja~~r~i 2004.
.oF JUDGMENTITRANSCRIPT FQRM WITH THE NQTICE .oF APPEAL.
, District Justice
Ings containing t e JU gment.
, District Justice
SEAL
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CARLISLE PIKE ASSOCIATES t/a
SALEM ACRES MOBILE HOME PARK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
v.
CUMBERLAND COUNTY, PENNSYLVANIA
No:(!jDfflcIVIL TERM
KATHRYN M GETZ,
Defendant
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Kathryn M. Getz, Defendant, to proceed in fonna pauperis.
I, Philip C. Briganti, attorney for the party proceeding in forma pauperis, certify that I believe the
party is unable to pay the costs and that I am providing free legal services to the party.
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CARLISLE PIKE ASSOCIATES t/a
SALEM ACRES MOBILE HOME PARK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
VS
CUMBERLAND COUNTY, PENNSYL VANIA
: NO.(j/-0fRCIVIL TERM
KATHRYN M GETZ,
Defendant
AFFIDAVIT
1. I, Kathryn M. Getz, am the defendant in the above-captioned action, which is an
appeal from a judgment rendered by District Justice Thomas Placey, on October
9,2001, awarding Plaintiff possession of the mobile home lot on which I reside.
2. My Tent for this mobile home lot, located at 6280 Carlisle Pike, Lot 309,
Mechanicsburg, Cumberland County, Pennsylvania is $325.00 per month and is
due by the first of the month.
3. My rent for October 2001 has been paid, and my next rent payment is due on
November 1,2001.
4. I verify that the statements made in this Affidavit are true and correct. I
understand that false statements herein are made subj ect to the penalties of 18
Pa.C.S. 4904, relating to unsworn falsification to authorities.
Date: 7oj/B/OI
'---KO--fltA~ --IfJ. -&06
Kathryn M. tz, Defendan
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COMMONWEALTH OF PEHHS"~VANIA . ..., . ., . ," . . NOTfCtOFAPl>>tAL 1(...., I <l ft AI '
COURT'OF COMMOH PLEAS FROM U 0 U,
J"'DICIAL DISTRICT
DIS1R.ICT JUSTICE JUDGMENT
COA\MOH PLEAS Ho. OI~'5 q99
NOTICE OF APPEAL
(,;uil
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Nofice is given that the api>ellanthas filed in the above CaurtofCommall Pleas an appeallrom the judgment rendered by the District Justice an the
date and in the case ~ below.
NAME OF API'EUANr
Kath,ryn M. Getz
ADDRESS OF APPEIJ.ANT
6280 Carlisle Pike Lot 309
MAG'DlSt NO. OR NAME Of.W
Thomas A. l:'.l.aCf,y
hOTV. b
[Viae an:LCS urg
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1705'eCODE
~TE OF .JU:lGMENT
10-9-01
IN T!i: C~~9~ a'{af~iff) ~ co fo.. (Defef!dant)
~il.~;enl~iA~*ef!!,}>lobile Hilllae Park vs. KathrynM. Getz
, ~ >~ ;-' '.",..1. l SIGNATURE OF,APPELLANT HIS ATTORNE! OR AGENT /fAt; " /'
,:' '~>\>, Philip C. Brigant:L r'~ {.
< CV 12 i~";:':/' MidPenn Legal Services , /
LT llif,i~~00004,83-Cl1 ':Ccf, ROW Carlis).e PA '17013
This block wil,llie' Sii1~NL Y Iwhelrthis l:1O!Cfianis,:r41:j~ireq under Po. R.CP J.P. No. If aPPellBht 'was CLAIMANT (soo Pa. R.CP.JP. No,
10088.. \ "',,'., \ , :~'.:*:i~ ,<';":' "':',,,' ',". :,'<'~~/:;; "."" ,
This Notice oIApp,~,;,;:., re~~ved iiy.theDisto;<;i; Jusfice. willaperate as a 1001 (6Jin action be(ore District Justice, he MUST
SUPERSEQEAS Ie th~~~I" ,Hal: "ssession in i~'?e. 0 FILE A COMPLAINT within twenty (20) days after
, i'\" filing hi$ NOTICE of APPEAL.
A 0 ()
C '-"{1
" :':.. PRAEC!PE T.O' ENTER :RULE TQ FILE COMPLAINT AND RUJ,iE TE c")':J}
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(This section.<;Jfform to be userJ ONLY when appellant was DEFENDANT (see Pa. R.CP.JP. No. 1001(7) id~n beklre D~ Justice.
IF NOT USeD, detach from copy of notice of appeal to be served upon appellee). <:Q '5.: ..0 ; ?, :;)
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PRAECIPE: 'To Prothonotary' '<: ,.' ~ :56
Carlisle pike Associates t/a is N ;Y'"
Enter rule upanf':""1 "m 1.I9("q"""'q" MObilN~ ~f~le.r.rrk , . appellee(S)~ a c~Plai~n this appeal
(Cammon Pleas No.' () 1- ,5 ~\J I,' t---) within twenty (20) days a~ice al rule or sui ent~ of fudgment af non pra~
. ;:
ClAIM NO
RULE:
Carlislel'Bike Associatest/a
fu~~l~W l.I("r~e Mobile Hom~ P~rk
N8me Of __lfoe(sl
. appellee(s).
(1) Yau are notified that a rule is hereby entered upan you Ie file a complaint in this appeal within twenty (20) days afler the dale of
service al ~ls~II!\\f~','r. personal s~rvice. or by certified or registered mail. ,'. .,.
~~t::t~:~'~~j~'~t_,J5~~i;:~V~~:"" ._."'" . _' <>);.~:.:',~. -:\,";::<'<~~'\\\ .
~im,.,lfrOu' dan6t:'/ile '~~~lairiiwithirrthis !i.me, a JUDGMENT OF NON PROS Wl~-!li tl'lTERED ~A~!YOU.
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PI~OOF OF SERVICE OF NO'flCE OF APPEAL AND RULE TO FILE CtJMPlAINT
(nlis proot at service MUST BE FILED Wt THIN TEN (10) DA YS AFTER tiling the notice ot appeai. Cheo!r applicable boxes)
COMI\lC'NWEIILTH OF I'EIIINSYLVAllllf,
COUNTY OF,~ Clm 6rr/t{Ad ~_____,_;..
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AFFIl)AVIT: I hereby swear or aflirm that I served r-o",/ (" 'I #e>
~",,- 01-777 IV, IIV1
E~r"'~ copy ot lhe Notice of Appeal, Common Pleas No. , upon the District Justice designated ther~in on
(date otservice) > If) -;9-01 ____, 0 bY,personal service MDY(CertlliedHrool316fOd) mall, s,ender's
receipt attached hereto. and upon the appeilee. (name!C(jr/.i/~ f"ihlks<<. ') ,J-ja S"qkm Au<,s ,4'JHP , ,on
J2L.fc~r /q _ , *'"~ 0 by personal service lB'oY(certlfledt I '.. L. GiI) mall, sender'" receipt attached hereto.
~and further that I served the Ru!e to file- a Complaint accompanying the above Notice of Appeal upon the appellee(s) to whom
the Rule was addrassad on tJ(-fr12~1' I~ , 1'!!: ..2tXJ/0 by personal service@i:1Y(certllied) \m~ielerOO}
mail, sender's attached hereto,
AND SuBSCRIBED BEFORE ME
~.~ (/j~~-
, I Signature of affiant
SWORN
THIS ~____~__ DAY OF ___.___, 1L___
..
Slgnatcre of Ofiicia! before whom affidavit W.:l$ m8!1i1
TiUe of official
My conrnissio(l f;l\pires on __~_~_____ . 19__*
I verify that the statements made in this Affidavit are
true and correct. I understand that false statements
herein are made subject to the penalties set forth under
18 P.S. Section 4904, relating to unsworn falsification
to authorities.
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CARLISLE PIKE ASSOCIATES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
01 - 5999
CIVIL ACTION - LAW
KATHRYN M. GETZ,
Defendant
EVICTION
ORDER OF COURT
AND NOW, this 11 ~day of ~
, 2002, based upon
the attached Joint praecipe of Plaintiff and Defendant, the
Prothono~ary of Cumberland County is directed to release all funds
,. held in '~scrow in the above-referenced docket, payable to
-'!"-'",~+
"<plaintiff, Carlisle Pike Associates.
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~ndrkw C. Sheely, Esquire
Attorney for Plaintiff
v/Philip C. Briganti, Esquire
Attorney for ~efendant
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CARLIS1E PIKE ASSOCIATES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
01 - 5999
CIVIL ACTION - LAW
KATHRYN M. GETZ,
Defendant
EVICTION
JOINT PETITION TO RELEASE ESCROW FUNDS
plaintiff and Defendant hereby file this Joint Petition and
respectfully state as follows:
1. Plaintiff is Carlisle Pike Associates with an address of
155 Salem Church Road, Mechanicsburg, Cumberland County,
Pennsylvania, 17055.
2. Defendant Kathryn M. Getz is an adult individual with a
current address of 6280 Carlisle Pike, Lot 309, Mechanicsburg,
pennsylvania, 17055.
3. Plaintiff and Defendant desire that all rent escrows held
by and paid to the prothonotary of Cumberland County through
January 4, 2002 in the amount of $985.00 shall be released and
paid to plaintiff, Carlisle pike Associates.
WHEREFORE, Plaintiff and Defendant respectfully request that
this Honorable Court enter
By: I!nJ~ C~
Andrew C. Sheely, lre
Pa. 1.0. No. 62469
127 S. Market Street
P.O. BOX 95
Mechanicsburg, PA 17055
717) 697-7050
Attorney for Plaintiff
January 4 ' 2002
an Order in accordance herewith.
By:
Philip C. iganti,
Legal Services, Inc.
8 Irvine Row
Carlisle pa 17013
Attorney for Defendant
January , 2002
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PYS405
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Cumberland County Prothonotary's Office" Page 1
Manual Release Check Reg~ster 1/17/2002
Distribution
Case No
Accounting
Escrow
Amount
Tran
Date
Date
Release
-------------------------------p------------------------------------------------
3803 BEl'Z I~'fIIRYlJ M C.a.rl\:!>\e iKeAssclCCheck Date: 01/17/2002 Check No.: 1265
RENT 2001- 05999 PYMT/CASH 325.00 11/01/2001
RENT 2001- 05999 PYMT/MONEY ODR 325.00 12/03/2001
RENT 2001- 05999 PYMT/MONEY ODR 335.00 12/31/2001
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CARLISLE PIKE ASSOCIATES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
01 - 5999
CIVIL ACTION - LAW
KATHRYN M. GETZ,
Defendant
EVICTION
ORDER OF COURT
AND NOW, this JdA day of ~
, 2002, based upon
the attached Joint Praecipe of Plaintiff and Defendant, the
Prothonotary of Cumberland County is directed to release all funds
held in escrow in the above-referenced docket, payable to
Plaintiff, Carlisle pike Associates.
J.
~ndrew C. Sheely, Esquire
~Attorney for Plaintiff
~hilip C. Briganti, Esquire
Attorney for Defendant
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CARLISLE PIKE ASSOCIATES,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
01 - 5999
CIVIL ACTION - LAW
KATHRYN M. GETZ,
Defendant
EVICTION
JOINT PETITION TO RELEASE ESCROW FUNDS
Plaintiff and Defendant hereby file this Joint petition and
respectfully state as follows:
1. Plaintiff is Carlisle Pike Associates with an address of
155 Salem Church Road, Mechanicsburg, Cumberland County,
Pennsylvania, 17055.
2. Defendant Kathryn M. Getz is an adult individual with a
current address of 6280 Carlisle Pike, Lot 309, Mechanicsburg,
Pennsylvania, 17055.
3. Plaintiff and Defendant desire that all rent escrows held
by and paid to the Prothonotary of Cumberland County through April
3, 2002 shall be released and paid to plaintiff, Carlisle pike
Associates.
WHEREFORE, Plaintiff and Defendant respectfully request that
this Honorable Court enter an Order in accordance herewith.
By: 1h-vi1!
Andrew C. Sheely, Es
Pa. I.D. No. 62469
127 S. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
717) 697-7050
Attorney for Plaintiff
April , 2002
By:
Phili
Legal Services, Inc.
a Irvine Row
Carlisle pa 17013
Attorney for Defendant
April / ~, 2002
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PYS405
Cumberland County Prothonotary's Office
Manual Release Check Reglster
Case No
Accounting
Escrow
Amount
Tran
Date
Page 1
4/22[/2002
Date
Release
, .
Distribution
.
3259 CARLISLE PIKE ASSOCIATES Check Date: 04/24/2002 Check No. : 1282
RENT 2001- 05999 PYMT/MONEY ODR 335.00 1/29/2002
RENT 2001- 05999 PYMT/CASH 335.00 3/01/2002
RENT 2001- 05999 PYMT/CASH 335.00 4/03/2002
Payee total: 1005.00
Grand total:
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CARLISLE PIKE ASSOCIATES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
VS. 01 - 5999
: CIVIL ACTION - LAW
KATHRYN M. GETZ,
Defendant EVICTION
ORDER OF COURT
AND NOW, this
3f>~day of J ~
, 2002, based upon
the attached Joint Praecipe of Plaintiff and Defendant, the
Prothonotary of Cumberland County is directed to release all funds
held in escrow in the above-referenced docket, payable to
Plaintiff, Carlisle pike Associates.
J.
Andrew C. Sheely, Esquire
Attorney for Plaintiff
Philip C. Briganti, Esquire
Attorney for Defendant
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CARLISLE PIKE ASSOCIATES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
01 - 5999
CIVIL ACTION - LAW
KATHRYN M. GETZ,
Defendant
EVICTION
JOINT PETITION TO RELEASE ESCROW FUNDS
Plaintiff and Defendant by and through counsel hereby file
this Joint petition and respectfully state as follows:
1. Plaintiff is Carlisle Pike Associates with an address of
155 Salem Church Road, Mechanicsburg, Cumberland County,
pennsylvania, 17055.
2. Defendant Kathryn M. Getz is an adult individual with a ;1(t1
.2" >+e,oh,." f2f7ad) Apt. leI CO.....P /fill) 1',,1 J7Cl/I~
current address of 92QQ C'irlisle pj k~, 1.91; 'JQ9, nc.e:1raRig~t"lr9',
Pc;Hu:.:Jyl.y~aRia, 1 ?QS3.
3. Plaintiff and Defendant desire that all rent escrows held
by and paid to the prothonotary of Cumberland County through
April 3, 2002 shall be released and paid to Plaintiff, Carlisle
pike Associates.
4. Upon payment of all remaining amounts in escrow,
Plaintiff shall mark the above-captioned matter settled and
discontinued.
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WHEREFORE, Plaintiff and Defendant respectfully request that
this Honorable Court enter an Order in accordance herewith.
By: ~;\l d
Andrew C. Sheely, ~
Pa. I.D. No. 62469
127 S. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
717) 697-7050
Attorney for Plaintiff
July IV , 2002
By:
Phillp C. rigant', Esquire
Legal Services, I
8 Irvine Row
Carlisle Pa 17013
Attorney for Defendant
July I?-, 2002
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10114108142002
PYS405
- .
Cumberland County Prothonotary's Office
Manual Release Check Reglster
'Distribution
3803
RENT
RENT
3825
RENT
Case No
Accounting
CARLISLE PIKE ASSOCIATES Check Date:
2001-05999 PYMT/.CASH
2001- 05999 PYMT/MONEY ODR
Payee total:
COSTOPOULOS JAMES
2002- 02883
Check Date:
PYMT/CASH
Payee total:
Grand total:
Escrow
Amount
08/14/2002
335.00
335.00
670.00
08/14/2002
225.00
225.00
895.00
Tran
Date
Page 1
8/lZl/2002
Date
Release
Check No. :
4/.29/.2002
5/28/2002
1294
Check No. :
6/14/2002
1293
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CARLISLE PIKE ASSOCIATES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
01 - 5999
. .: .~, . .
'h : CIVIL ACTION L..l\.W'
KATHRYN M. GETZ,
Defendant
EVICTION
ORDER OF COURT
AND NOW, this
11>~ day of :r v10
, 2002, based upon
the attached Joint Praecipe of Plaintiff and Defendant, the
prothonotary of Cumberland County is directed to release all funds
held in escrow in the above-referenced docket, payable to
Plaintiff, Carlisle pike Associates.
pe.fZ }iI\J~ 3hee..\rr'
Ma.1\ to ~\ m
J.
Andrew C. Sheely, Esquire
Attorney for plaintiff
Philip C. Briganti, Esquire
Attorney for Defendant
Camp,
q -J4-QO$ J. 00500
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CARLISLE PIKE ASSOCIATES,
Plaintiff
VS.
KATHRYN M. GETZ,
Defendant
- ~.~ " <--
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
01 - 5999
CIVIL ACTION - LAW
EVICTION IAPPEAL
PRAECIPE TO SETTLE AND DISCONTINUE
To: Curtis R. Long, Prothonotary
Cumberland County Courthouse
One Courthouse square
Carlisle, PA 17013
In accordance with paragraph 4 of the Joint Praecipe of
Plaintiff and Defendant filed on July 25, 2002, kindly mark the
above-captioned case settled, satisfied and discontinued, with
prejudice.
~~e
Attorney for Plaintiff
127 South Market Street
P.O. Box 95
Mechanicsburg, PA 17055
717-697-7050
Date: August ~17' 2002
"'" ~', ,.
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CERTIFICATE OF SERVICE
I, Andrew C. Sheely, Esquire, hereby certify that I am this
day serving the foregoing praecipe upon the following named
individual this day by depositing same in the United States Mail,
First Class, postage prepaid, at Mechanicsburg, Pennsylvania,
addressed as follows:
PHILIP C. BRIGANTI, ESQUIRE
MID PENN LEGAL SERVICES
8 IRVINE ROW
CARLISLE PA 17013
Date: August j- 7 2002
~q,~
Attorney for Plaintiff
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