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HomeMy WebLinkAbout99-02906 rS? hi L ?1(l?9 1'^ ISCr, >7r?2q 'd 4! ?rk `x wl (tj I(ir't a *rr L4 ei.y iy`, coax L f, ,, V Qi: (-i,1 - 1.. III facsirnile THE INFORMATION CONTAINE=D N TI+:S "ACS;'•IiLE I-IC55AGE 15 PRIVILEGED AND CONFIDENTAL .AND IS INI NDF' J Fi R l+ I ?.F iiF TriF ADDRF SFF i ISTFD ABOVE IF YOU ARF NEf-HER TIiF INTFNCED RFC;I. IP:r.^ NCIR IIIF Fh?- l c:i!'L CIR 4GCr?I' RF SPONSIP.t. F: FOR DELIVERING THIS MFSSAGE TO TH; IIJiENCTE RLCIPIr.YOU ARE HEREBY NOrIFIrD THAT ANY DISCLOSURE, COPYINC; DISI-R RLITICnrl OR T?IF I-AKI-NC, Dc' 4N)' 4CTION IN RF.UANCE ON THE CONTENTS OF 17115 TFLFCCIRI S INFURr: i?^J 1F, 5TT:1<:T, Y PR()HiBF ED IF YOU HAVE RECEIVED THIS FASCIM!LF IN FRR(IR. PI CASE NOTIFY US IINIEDIATELY VIA TELEPHONE TO ARRANGE FOR THE RETURN CR 71` FDPAI OF --HF to: c- ; re: pages (incl. cover): fa x #: Messilge: `5 I ? {l 4 1 .7 .. ?- C; ?. F From (hc desk or... ??' ? , l r?• I `•'? Jane Adams, Esquire 117 S. I IJlnncer St. Carlisle, Va. 1701.1 %nice (717) I•ti-SSOS ra% (717) 243-S338 b. 1, I i . . 1 a6OA0l K HOUCK (1917.1991) Rt• o+Qn?Crs r y?1h1lf Ll? ?/ir??u/ ?iaccr Scc// D:nmrr J nr rr qws 12:210 CHARLES F,. SHIELDS, III ATIORNFY•A7••4AW 6 C1.0U V:A N OAp Can cf Trlndk and C"w, Ru«G MECHANICSHUAG, PA 17055 TRUPHONB (717) 766-0209 PAX (717) 795.7473 %atifz y9 z9ao C','v, ir?m• M-x 737-To,?S r? 37-?Gjf Ax '04 ;?G/• 534/ alax, P4. le, iAhs X45- 85 !8 ?!. ="?S-?S7Jr?' Gz? v f %ani Aledx' k ?risqqj /oOG .S . ?D /OR-?rl y?`'!l//%I!J ?0/1? / 1f?P..?ci C?DU/fd+o/f?P, rf4s ?"??1 .ref ?o/"?' ?J Ike Q/ /rlR07"0- L+ \J j 1a IF 111E I ! -1 r1? } _ S Ova ri co -S ?y` ?• -... ? ,, ®-`- ?? 4 i ?. 5 Ci 'r t j,_ i Dia E. 1 l F-. FF C 1.[L I ?. ?. 4 1?,.,_?F. .,..?,,::. ,,;, .,. is-r: ?eSlc.'i "?lr_ _ ? . I r, ? ? ?5 CHARLES E. SHIELDS, III ATTORNEY-AT-LAW 6CLOUSER ROAD Corner ofTrlndk and Clown Roadr MECHANICSBURG, PA 17055 OBORGE X HOUCK (1912.1991) TELEPHONE (717) 766.0209 PAX (717) 795-7473 Gentlemen & Madam: I have been Apptd Chief arbitration and Jane Adams aad Scott Dinner have been appointed Co-arbitrations in the case of sanders vs Yontz, 99-2906. Please Advise me to any open times or dates from November 1 thru Nhvenber 5, November 8 or 9. Please fax a response at your earliest convenience so as to make this scheduling process as easy as possible. Thank You Charles Shields III Jim Bach 737-2035 Scott Dinner 761-5008 Jane Adams 245-8538 Sam Andes 761-1435 ,I i 1 _j r __ _, I i r:;?. ;.;!r:: ; ..? ? I F<.,,: [:?L?i i', 1 ? - I _., ?? I -. i i , ? ?, CHARLES E. SHIELDS, HI ATTORNEY-AT-LAW GEORGE M. HOUCK (1912-1991) ?Q?IX21v g /%: 6 CIAUSER ROAD Comer ojTrbsdk and Clouser Roads MECHANICSBURG, PA 17055 31 A,? 49 TELEPHONE (717) 766.0209 PAX (717) 795.7473 21Z,01 lVe 99 - 2906 . 4? lwml"Z? -Am ICY Z/ &.4l 7, Bel /z / 737- ?035r&& 73 cj&&e i- 761- 5.561 r -76 / - / Y3,S JAMES M, BACH At(orncy At Law 352 S. Sp?rliilg I i fC4,_ Mccitanlcsbur PA 17055 '.! (r:7.?__'_ S? + 1e1'AX SI ?o ?zq 9 07, PERSON FAXED'ru: v --- NUMBER PAXCU'ro: 225 z? NUM19lilt OF' PAGI:S FAXL D (Including co vcr 5hcc(j; ? do not tccclt r all prtgrs o/(h(t /ax, 7.17.2 ar ljlhr+? a+e prahlruts tehh trrtntmlttlan, / Icasr roll (717J 7.17.20.7,1 for l el ra tPlNtil tal. NOTES.- 7br (nfotruatloll ranlalrird in Ihit passage it rottJide+ttlal (and lna, hr attatnry pNvllrgrdJ, inttndrd mtly jar the file of the Individual or emit, named above, ljfht lradeP of Ibis hlrtsegt It not the inlettded reclplent, yan ape hetrby notlfled that any tilt temIHjtioit al• dltttibuticn of (hit caTnlrI)MICatr'an to tnty,eue olhrr Ibau the Intruded lec!plent it strict;, pr Inked. Jl'?ou have recrlvrd TO tetalntadeallau in ntot; plra;e nolify TTl by telephrise (mmrdialrly and tritall the original ntrttage to III at the almve addict; via The US. mail. 71,arlk con. JAMES M. B ACH Attorney At Law 352 S. Sporting I lill Rd., Mechanicsburg, PA 17055,T&(711737-2033 September 2, 1999 Charles E. Shields) 111, I squiie 6 Clouser Road Mechanicsburg, PA 17055 R8: Sctrtders vs. Yontz (99.2906) Dear Attorney Shields: As pet your rcyuest, via fas, I am providing the following dates and times for possible arbitration hearings: October 4, 1999 1:30 pm October 5, 1999 1:30 pin October 13, 1999 1:30 pill October 15, 1999 1:30 pill October 18, 1999 1:30 pin October 25, 1999 1:30 pill October 27, 1999 1:30 pin October 29, 1999 1:30 pm If you need further information or assistance, please contact this office. Re,sprcyt}(,dry, lAhlk.'S.11, RACH Attorney At I+irr ?U ]MB/dlu) CC: File facs imiIc THE INFORMATION COIJ TA,INE.C Ld lY,iy' EF, i:S,hlll E: MFSSA(ic IS PRIvI-EGED AND CONFIDENTAI ANC .S IrJTLNDFD (^ 7 THE LISF OF THE ADDRFS:iEF_ USIEO ABOvE. IF YOU ARE NEITHER T}IF tNTENDED RECIF'ENT NOR THE CWPLOYE: Cr, AGENT RESPONSIBLE FOR nELIVERING THIS MESSAGE Trl THE INTFNC,FCI RECIPIFNT YOU AR.F HEREBY NnnI`IF:Ct I'HAT ANY DISCLOSURE, COPYING, I7)I57RIH(JtFON, OR T}tF TAKING OF ANY ACTION IN RELIANCE ON THE" CONTENTS OF'Ht$ T7.1 FCOPIE i INFORMATION 19 STRICTLY PRf ,HIBITFD IF YOI.I HAVE RECEIVED THIS FASC.irrIILF.. IN FRRC,R, PLEASF NOTFY US IMMEDIATULY VIA TELEPHONE TO ARRANGE FOR THE RETURN OR DIS'OSAI. Or '}IF COPY t0: rc: N t 2 1 lei ~2. q O G date: f,? '.,1 ?C1 1`1 J pages One]. Coo erl: I fits #: ._. 1k I, -? message: L 1,2-1 Oc;?" I SS f I ?? t rc From the deal, of... June •Adams,'Rsyuirc 117 S. liaamer tit, Ctnli.le, Iru. I7013 %oke (717) 24i-8i(19 fa.. 4717) 24:•S538 V.- I AI'P01/NE) Al l.AN' 1:b NO It : 11 :'1r 1y01Iit ,•r01. ra 0 HlIx WB 1 Y.M f)5'K1:, I'Y.NN:;VLA'ASIA 001'.1 1 "41 TC: 1'YIIO N! 'll/ Itll LJn1 M,n S )It. lei W1 31 August 1999 Via Fgx-793-74731 Charles E. Shields, III, Lsquire 6 Clouser Road Mechanicsburg, PA 17055 Dear Charlie: Al the present time I am available the following times October 5, '1999 -• after 3 00 pm October 7, 1999 P M. only October 12, 1999 - P M. only p 13 October 13, 1999 - P.M only October 14, 1999 - A.M. only October 15. 1999 - A.M. only Sincelely, Samuel L Andes amh e e CHARLES F. SRIELDS, III ATTOANEY•AT•d AW co...4TFU b.d cam Rood, MICHANrsauaC. PA IM ODM(JaM HOUCK 31 Au y9 MAMMA (711) 7WO209 (1912.1991) PAX {7171 797.7473 t .>?., 9 'I: cod eh'Q? Q.rbi lra.Pon ??,e?¢` ,(?.49w1. ??CUr.-?c,,.?".? Go -?,f?v?z?r4.•*? r?C 74wz4u, t! r ?,?? a 9 19cK - fwd !2. GL'eLl2,a /v214, Q iL?i?vn ac ?L? ?cc? ?etvi-114 !?<f?l?x?tnr ? ?-GOCC.f?'..??,,t?r CLj r. Ts f i (.;yn 737- A?03S(?ct?;?•3j ???' /s?1?loG?`fe;uJ c o , ,>dcZnt G Tl ?- 5.31 Ax -7« l / 43S All A4+es u?ft a?- cVI/Z?11 o-k, i F SOMM 3117c?ustriNt ?erue CAMP .1til, in I.-011 I CHARLES E. SHIELDS, III ATTORNEY-AT-LAW OBDROE M. HOUCK (1912-1991) Re. cSapalers r c4mes /? &"4 c2imue/ Aaer Scott ), nl7er f ne 19:?,qMs 6CLOUSERROAD Comer ofTri dk and Cimm Roads MECHANICSBURG, PA 17055 90 seat. me? r %ay 1z 99- 2*6 C,'v. Term. 4x '737-2a3-5' A-x 741- 1-?Too? a qs- Fg.?8 TELEPHONE (717) 766-0209 PAX (717) 795.7473 r4• 737-2033 P4. 7/a /- S-361 p?. 76 r.,s-,qoc p,l. z4s-8S-a? P/e?? de adv:set /Yav. S ? ••4(} ?? A? Ski ??aor Apm / Itle / Caurt?aouser r?1Qs Aw ref ?4 /" /At arb?frA?'v?• 1??•?au//e%d /z'?eipalL ljleQq rlj; lp; l'159 l i:li?; ri l !oiu.?.'. CHARLES E. SHIELDS, Ill ATTORNEY•AT d.AW 6CLC. VA10AD Cmw y'Truwb sd cwm Ava" WOCHADRCUUM PAIWAS C7BORpiN HOUC7C 7SWW-NS (717) 764.0209 PA?f (7N) 793.767y (19111991) i ? i Gantlmaross 6 ,yadwn: I he,.w ber_n AppW 171iei actitration aral Je17PD Aa=w ANd Scutt D?nrer have bean eplsointr+cl C.b-a::sitrotionn in the oubm of swdersi vs Yantx, 99-2906. Plewee ldvise 1M to arty open twee or dates rxun PTovetkxr 1 thru 61wtx?ber 5, Nownber 8 yr 9. Please f wA a reapon-e . at. yc7Ur eArl teem c"wa sience so av to mke this i schodulinq proee.sc eia waoy as poayilsle. i Thw k You Chw les bhlaldu li7 i ky= Bach i37-2(135 Scutt Cirlnai. 761-5009 Jwit PA^m 265-8578 swe AliBea 761 1475 All J4+ts e??c o.k.. CFHONECALL roR M (? _ DATE TIME P. 1J? PHONC__ TELEPHONED RETURN- p FAXn_ .+uniLT i? un.Niauw YOUR CALL . ^d- v _ MESS PLEASE CALL ?. i E WILL CALL AGAIN - CAME 1 TO SEE YOU _ WANTS • 006-4'z E TO SEE YOU i i IIIIIIIIIII0 JEFFREY D. SANDERS CYNTHIA A. SHEARER PLAINTIFFS IN THE COURT or COMHON PLEAS OF CUMBERLAND COUNIY, PE NSYLVANTA NO. 99-2106 CIVIL 10 99 VS. CHARLOTTE I. YONI;Z ; DEFENDANT RULE 1312-1. The Petition for Appointment of Arbitrators shnl-;. be q,ihstantially in the following form, PETITION FOR APPOINTTIENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: JAMES M. BACH counsel. for the plaintiff/defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of the plaintiff in the action is $4nQ0_nn The counterclaim of the defendant in the action is NONE The following attorneys are interested in the r_ase(,') ns counsel or are other- wise disqualified to sit as arbitrators: SAMI M_L ANDES_____, WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, ORDER OF COURT JAM M. BACH, ESQUIRE AND NOW, foregoing pet Esq., and 1999 in consideration of t1.e ,Esq., are appointed arbitrators in the above-captioYiied action (or actions) as prayed for. T U ci U r T1 ? ` ` 11 111 ;•J FcNI COfAJX6NVfEALTN OF PENNSYLVANIA COURT OF COMMON PLEAS JUDICIAL DISTRICT NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No -1"1- O9h i n l 1 Li r NOTICE OF APPEAL 5/13/g9 Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date_ord in the case mentioned below O S- Cv 1 LT V when under 10081L This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgment for possession in this case 12VA11 &C- if appellant was CLAIMANT (see Pa. R.C.P.J.P. No. 1001(6) in action before District Justice, he MUST FILE A COMPLAINT within twenty (20) days after Signature of Prothonotary w Deputy filing his NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee). PRAECIPE: To Prothonotary Enter rule upon (Common Pleas No aFl>onbalsl appellee(s), to file a complaint in this appeal _) within twenty (20) days after service of rule or suffer entry of judgment of non pros Signature of apoeJant or ns attorney or agml RULE: To , oppellee(s). Nano d appdeelal (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of mailing Dote:-, 19_. Sgnrve of Rdnarmy or CigsutY none 311a COURT FILE TO BE FILED WITH PROTHONOTARY l L r, o? ?'r (L L u w - - ' u71 f:C f G rn u 00 (P C( '--61 0o ragdxu uoissPuwoo Arj 11004N /o ollu upmu ells (IAPIIq/U it•ogn, woloq wogln in anmu61s luelpa !o oinjou6/s _ -- "-61 do AVO - - SIHl 3W 3Hone 03©IHOsens ONV (03W8IddV) NHOMS 'OlaJaq pagoelta Idlaoai sjapuas'llmu (poialsl6ol) (pailgiao) Aq ? 001MOS leuosJad Aq ? -6l ' - uo passalppe sem olnH agl wogmol(s)oapaddeagluodnleaddV;ooolloNanogeaglbulAuedwooaelumldwooeelldolalnHoglpanwsllewJOgllnlpue ? •olaJag pogoellu Idlaoal s,Japues'pew (peJalsl6al) (pa!Iluao) Aq ? volAlas leuosaod Aq ? 6l uo'- (oweu) 'aailadne ow uodn oue'olalag oauocne Idmoal s,japuas 'pew (paialsl6ai) (pappaa) A,q ? aalAaas leuosiod Aq O -- (oarao, to olep) uo walagl paleu6lsep aopsnp loulsq] agl uodn ' - ON scald uowwo0 'IeoddV (o sogoN agI to Adoo e ? paAJas I IeUl uuyfa Jo seams AGaw41 aIAVOIddV' cs ` --- ---d0 AM= VINVAIASNN3d JO HL'IV3MNOWW00 (seroq olgeoildde ggogq leodde jo nogou o4J BufN i 31. iN SA VC (Ol ) N31 WWI IA,4 03I1i 39 1 S,niv +341n?os 1O looid si41) 1NIVldW00 311:1 Ol 3inu ONV IV3ddV d0 30110N d0 301A83S d0 d00Hd i COMMONWEALTH OF PENNSYLVANIA COUNTY nP- CUMBERTAMD 09-1-02 DJ Name: Nor. ROBERT V. MANLOVE Address: 1901 STATE STREET CAMP HILL, PA Teieahona: (717) 761-0583 17011-0000 ATTORNEY FOR PLAINTIFF : NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF, RESIDENTIAL LEASE NAME am ADDRESS rSANDERS, JEFF -I 501 N MARKET ST MECHANICSBURG, PA 17055%'.. L J vs. DEFENDANT: NAME and ADDRESS rYONTZ, CHARLOTTE 1 303 PENNSYLVANIA AV CAMP HILL, PA 17011 JAMES M. BACH, ESQUIRE L _1 352 S. SPORTING HILL ROAD DocketNo.: LT-000 0155-99 _ MECHANICSBURG, PA 17055 Date Filed: 4/26/99 IM& THIS IS TO NOVY YOU THAT: Judgment: FOR DEFENDANT ® Judgment was entered for: (Name) YONTZ, CHARLOTTE Judgment was entered against SANDERS, JEFF in a ® Landlord/Tenant action in the amount of $ .00 on 5/11/99 (Date of Judgment) The amount of rent per month, as established by the District Justice, is $ .00. Damages will be assessed on: (Date & Time) The total amount of the Security Deposit is $ 00, Total Amount Established by DJ Less Security Deposit Applied = Rent in Arrears $, .00 - $ 00 = Physical Damages Leasehold Property $ .00-$- .00 = Damages/Unjust Detention $ -00-$ _ .00 = Attachment Prohibited/ Less Amt Due Defendant from Cross Complaint - Victim of Abuse (Act 5, 1996) Interest (if provided by lease) UT Judgment Amount This case dismissed without prejudice. Judgment Costs Attorney Fees D Possession granted. Total Judgment Possession granted if money judgment is not satisfied by time of eviction. ® Possession not granted. Levy is stayed for days or F-1 generally stayed. El Objection to Levy has been filed and hearing will be held: Adjudicated Amount $ .00 $ .00 $ nn $ .00 $ _00 $ _no $ _n0 $ _no $ .00 ANY PARTY HAS THE RIGHT TO APPEAL A JUDGMENT INVOLVING A RESIDENTIAL LEASE AND AFFECTING THE DELIVERY OF POSSESSI OF REAL PROPERTY WITHIN 10 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. IN ORDER TO OBTAIN A SUPERSEDEAS, YOU MUST DEPOSIT WITH THE PROTHONOTARY THE LESSER OF 3 MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED. IF YOU WISH TO APPEAL THE MONEY PORTION ONLY OF A JUDGMENT INVOLVING A RESIDENTIA,. LEAdE-,S21 GAVE 30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN1VHICH TO FILE A NOTICE OF APPEAL WITH THE P?10THONOTAAVICLERK OF COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVIS1oN p - YOU MUST INCLUDA COPY OF THIS ICE OF JUDGMEN/TIJRAN5CRIPT FORM WITH YOURIOTICE OF APPEAL. ; District Justice District Ji M?m(nlss on expires first Monday of .January, 2000. T SEAL' 11 CASE NO: 1.999-02.906 F COMMOPIWEALTH OF PENNSYLVANIA: COUNTY OF CUMBBR[,AND SANDE_ " jEpLgEY D VS. YONTL-CHMLOTTE I KATHY CLAKE CUMBERLAND Count. Sheriff or Deputy Sheriff of Ir Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT upon YONTZ CHARLOTTE I was served defendant, at 11:31 HOl1RS on the 20th -- the 1999 at 303 PENNSYLVANIA AVE ?Y of M -- r County, Pennsylvania, by -rCUMBERLAND a true and attested copy handing to CAARLO TTE YONTz of the NOTICE AND COMPLAINT r and at the eame time directing Her attention to the contents thereof. Sheriffrs Costs: DocVpkieting 18.00 Affidavit 9.30 Surcharge 6.00 03S M-JEFFRgY SANDERS 05/20/1999 Sworn and aybacribed to before me thisI ? day Of 19 .W p n' N l?F?lU/t2 - Cerole A Halkol Notarial Sa?" Harrisburg NotaCryrypPub?yIM "v Commission Exxp res M P b 2000 So answers: w Y I Z 026 626 157 Receipt for Certiticd Mail do Im..unln', 'vmv;lgn F",,% Wed U„ nul nsc I'n O,b4I,91innal Mail :+CC ravC?se ci?d.:{: ?imno-'6 mA, 11, you p•I1,,.1. ...?i?.,. ._.... _ ?. 1'aIy • O.pr N 1171 hI •?!.• 1 {?'. __._ fil _.? "? ? 1,V4! o COMMONWEALTH Of PENNSYLVANIA COURT OF COMMON PLEAS JUDICIAL DISTRICT COMMON PLEAS No ?+t- NOTICE OF APPEAL 5/13lg9 - Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the `District Justice on the date and A the case mentioned below C ?- 0a CV this block will be signed ONLY when this notation is required under PwR.Q:P.J.P. a 10081L This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgment for possession in this case if appellant was CLAIMANT (see Pa. R.C.P.J.P. No. 1001(6) in action before District Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (this section of form to be used ONLY when appellant was DEFENDANT (see Pb. R.C.P.JP. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be, served upon appellee). PRAECIPE: To Prothonotary Enter rule upon agoelkvNsl , appellee(s), to file a complaint in this appeal (Corman Pleas No ) within twenty (20) days after service of rule or suffer entry of judgment of non pos. Sure d aspeft# a ha arromay ar agent RULE: To , appellee(s). Nary of appo/befs) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rub upon you by personal service or by certified or registered mail (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of service. of this rule if service was by mail is the date of mailing Dote: . 19_. SVM6- of Ault mn fay a Dmuty. NOTICE OF APPEAL fROM DISTRICT JUSTICE JUDGMENT ADnca'1.er COURT FILE PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF- C96il-/??! 'U? _ as AFFIDAVIT: I hereby swear or affirm that I served ? a copy of thr- Notice of AUDeal, Common Pleas No. -2L-al06)(2l•SXupon the District Justice designated therein on (date of service) s-a'7- qy perso t service 2'6y (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) on = . 191 - e-by personal service ? by (certified) (registered) mail, sender's receipt attached hereto. ? 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 ? by personal service ? by (certified) (registered) mail, sender's receipt attached hereto. SWORN (AFFIRMED) AND SUHSCRIRED 13EFORE ME THI ? DAY OF /M Q fgQ Signature of affient s younuc of onrc:ef hnlom nhom afficav,t inns 11,1101 TOO of off', ntl _- My runmtiv;ia? cry,,:(, o•r'__,_ __ C) 4,,? Carole A. Haikel, Notary Public r Hernsburg. paephif County C^_ ?, t?ss?cn Expires March 2000 r ' -t ' r ?? ,tit ,• .._ _ L JEFFREY D. SANDERS ) IN THE COURT OF COMMON 501 North Market Street ) PLEAS OF CUMBERLAND COUNTY, Mechanicsburg, PA 17055 ) PENNSYLVANIA Plaintiff ) 1 vs. ) CIVIL ACTION - LAW CHARLOTTE 1. YONTZ ) 303 Pennsylvania Avenue ) Camp Hill, PA 17011 ) NO. 99 - .2906 Defendant ) IN DIVORCE DEFENDANT'S PRELIMINARY OBJECTION AND NOW comes the above-named Defendant, Charlotte I. Yontz, by her attorney, Samuel L. Andes, and makes the following preliminary objection to Plaintiff's Complaint: 1. Attached to Plaintiff's Complaint is a lease upon which Plaintiff's claim is based and which Plaintiff claims to wish to enforce. 2. The lease attached to Plaintiff's Complaint identifies the Plaintiff and his wife, Cynthia A. Sanders. 3. The Plaintiff and Cynthia A. Sanders are divorced and Cynthia Sanders is now named Cynthia A. Shearer. 4. Plaintiff's Corn plaint is defective because it does not join a necessary party, Cynthia A. Shearer. WHEREFORE, Defendant objects to Plaintiff's Complaint and requests this Court to dismiss the Complaint pursuant to Pa. R.C.P. 1028. Samuel L. An es Attorney for Defendant Supreme Court ID 17225 525 North 12"' Street Lemoyne, PA 17043 (717) 761-5361 COMMONWEALTH OF PENNSYLVANIA ) ) SS.: COUNTY OF CUMBERLAND ) Samuel L. Andes, being duly sworn according to law, deposes and says that the facts set forth in the foregoing document are true and correct to the best of his knowledge, information, and belief Samuel L. Andes Sworn to and subscribed before me this day 21- of 9"Ll 1999. JA'u' CM, Z/-4--' Notary 116blic. ??at?e. s?i, g11YmtP0.?1a N1 txro)lp BUD, f.?Sa h K+C? u?Y. PA f is (. 1 .. 1 ? I a F o h l W Z a x = a ? e ? a z s a° z F W a x ? w O C P: 0. F ? w 6 < x X N O W ------------- a a SHERIFF'S RETURN - REGULAR CASE NO: 1999-02906 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SANDERS JEFFREY D VS. YONTZ CHARLOTTE I KATHY CLAKE , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT was served upon YONTZ CHARLOTTE I the defendant, at 11:31 HOURS, on the 20th day of May 1999 at 303 PENNSYLVANIA AVE CAMP HILL, PA 17011 CUMBERLAND County, Pennsylvania, by handing to CHARLOTTE YONTZ a true and attested copy of the NOTICE AND COMPLAINT and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00%s Service 9.30 Affidavit .00 Surcharge 8.00 it. I amas -ine, 5 eri $.30-0EF20E19 SANDERS 99 by Deputy eri Sworn and subscribed to before me this .2o a day of 19 9 9 A. D. C -..z o ondtaryl 1 i; JEFFREY D. SANDERS IN THE COURT OF COMMON PLEAS 501 North Market Street Mechanicsburg, PA 17055 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. CIVIL 1TERM CHARLOTTE I. YONTZ 303 Pennsylvania Avenue Camp Hill, PA 17011 CIVIL ACTION-LAW Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20)days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with 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. COURT ADMINISTRATION FOURTH FLOOR CUMBERLAND COUNTY COURT HOUSE CARLISLE, PA 17013 717-240-6200 A JEFFREY D. SANDERS IN THE COURT OF COMMON PLEAS 501 North Market Street Mechanicsburg, PA 17055 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. CIVIL TERM CHARLOTTE I. YONTZ !9•X964 et,j T;• 303 Pennsylvania Avenue Camp Hill, PA 17011 CIVIL ACTION-LAW Defendant COMPLAINT AND NOW comes the Plaintiff, Jeffrey D. Sanders, by and through his attorney JAMES M. BACH, ESQUIRE and files the within Complaint: 1. Jeffrey D. Sanders is an adult individual residing at 501 North Market Street, Mechanicsburg, PA 17055, and the Plaintiff herein. 2. Charlotte I. Yontz is an adult individual residing at 303 Pennsylvania Avenue, Camp Hill, PA 17011, and the Defendant herein. 3. Jeffrey D. Sanders is the landlord of Charlotte I. Yontz. 4. On or about the Bch day of March, 1972, Jeffrey D. Sanders and his then wife entered into a lease contract with William H. Yonzt, now deceased, and Charlotte I. Yontz, the Defendant herein. A photocopy of the lease is attached hereto and marked as Exhibit A. 5. The lease required the tenant to pay real estate taxes on the building. 6. The real estate taxes have not been paid on the property for 1997 and 1998 as of the date of this filing. 7. Non-payment of the real estate taxes is a violation of the lease. il. 8. The amount of Two thousand ($2,056.24). taxes due and owing as of the date of filing is fifty-six dollars and twenty-four cents WHEREFORE, Jeffrey D. Sanders respectfully prays that this court enter an order granting judgement in his favor for the minimum amount of $2,056.24 with the exact amount to be ascertain at the time of trial. FURTHER, Jeffrey D. Sanders respectfully requests that all costs be entered in his favor together with attorney fees. FURTHER, Jeffrey D. Sanders respectfully requests that this court enter an order of possession effective immediately in his favor and against the Defendant Charlotte I. Yontz. RESPECTFULLY SUBMITTED: 41'??A A-"-Z ES M. BACH '' ttorney for the Plaintiff 352 South Sporting Hill Road Mechanicsburg, PA 17055 (717) 737-2033 Attorney I.D. #18727 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein made are subject to penalties of 18 PA. C.S. Section 4904, relating to unsworn falsification to authorities. J EY . SANDERS PL NTIFF Jr-12 p? N =` i'6'tt'91g4•IISIE Nada thus 8th day of March JFXFREY D. SANDMW and MITHTi1. A. SANDI-n3j his wife, y .. .1. D. 1972 hereinafter called Lessor, and WILLIAM H. YONTZ and CHARLOVE 2. YONTZ, his wife tThat thasaid Gosaor,in coleslderatlono/the rents anhlter called Lessee. daeoucnatttahereinafter mentioned does hereby ren dentine and lease unto the .-told Lessee, to be used for the purpose of 'a dwelling house Ah • houoehold furni.sungs inclllded. the premises sitnated to Ella Borough of Camp Hill, County of Cumberland and Commonwealth a/ Pennsylvania, described as follows.- 303 Pettnvylvani.a Avenue, Camp Hill, Petxnsylvaniti O J"t altlb tO Olb 'Into tire sold Lessee, subject to the conditions of this agree- ment, for the term of le of William H. Yontz & Charlotte I. Yontz commencing on the eighth day of March R. D. 1 the day of 072 and ending on s}lfvivPr of William H. pjttz and Charlotte 2. Xontz. 9.19 the death of the .llet S. SinibrrnFinat ' PtrtOf the sold Lessee agrees to pay to the said Lessor for the use of the said premises, the aunt of payable as follows, viz; Dollars, Ae. ? U. Altt5 the sold Lessee also agrees to keep the said premises in as good repair and condition as at present and at the erpiroeiat of this lens c, or any renewal of it, to surrender up satire, in like repair and condition, natural wear and darnalte by the, elements excepted; to permit no unlau ful business to be carried on upon said premises; not to permit an thine to be done which is contrary to the conditions of the politics of insurance now on the said premises or which may be, placed thereon during the teen of this lease or any renewal thereof, whereby the hazard might be increased or the insurance. invalidated; not to ttnderlet the said premises, nor assign this lease or any interest therein to any person or persons toithout written consent of the sold Lessor; and not to remove from the said premises during the torn of this lease or any renewal thereof. 1 hd sold Lessee agrees to remove alt tee and snort, from all stdeivalks, and to keep the said prernises in a clean, and sanitary condition, and to rentuve all ashes or other garbage which may accumulate upon the same during the said ternt, nr arty reneroal thereof, or failing therein to /joy to rite said Lessor double the cost of removing lite same, to be recovered the same as rent line and in arrears; and agrees to pay the rent for the lire of ruatcr, electricity and ens upon Cite said premises during the said term., or any renewal thereof, and which incy be recovered by said Lessor as rent due and in arrears; to pernie floe said Lessor to display a "for rent" or a "for sale" card upon the said prernises, and to enter the said prernises of any tittle for the purpose of makinit necessary repairs, or showing the said prernises to prospective purchasers or lessees. t.' 30 it i-s 6irtiltr ng rail that should the Lessee remove or attempt to remove frnm file said premises during the tern{ of this lease, or any renewal thereof, then the entire rent for the full terns of this /roar, shall become due and payable ne once and may forthw.dfh be collected by distress or ofheruise. Jnd any roods reutoved from said premises either before, or after the expiration o/ the said tern, while atilt portion of the said rent remains unpaid, whether due or ncl, shall renwin liable to dislrttt for such rent for lite period of thirty duels after such removal, the same as though thry rrnoined on the prnnises; and any rentoval of the roods front said premises at any tittle, elfiter by day or night, without thhe?ewt}}?rri?t?tt?e?n,rr ?ro?ntent of the said Lessor shall be considered a clandestine and fraudulent ICm Ol,al. `?'!?'aY''y.>iPItIE???it't7't'll,fll• M,tblWiMl GI x.4u ??ss ra .sr......-.___ _ _ and sneer a ""`'` rea ,'tattier. part end Klsoltis! till said Owip lies iai 7;681[ r` ?' 11ta1 i! i:t FlITI ter tt_ tCS)x !lent the ¢ccehtn>tce by the said Lessor of a`y o/the said rent at any time after the xdnte shall becosrte due, or default has beeh made in the pnynuerrt Nhrrro/ or any failure of the snit! lessor to enforce any of the rielits gained under this lease or any of the poalties, forfeitures or caudition.v herein container!, shall not in any wise be considered as a ivalver of the right to enforce the same and that such right or/orfeiture may be enforced without any noiiee rchatsori•er; and that any attempt to eolleet the. rent by oar, proceeding shall not be eorsiderrd as u ualeer of the right of the said Lex.vor to collect the same, by arty other proceeding, The said Lessee hereby waives the usual three months notice to quit and agrees to surrender the said premises tit the expiration of the said trait, or the termination alibis lease, oaniy renewal thereof, without any notice whatever, and also waives the beneflt of all uppraisement, Way and exnnplian latas, the right of inquisition oil real estate and all bnokropt or bisolur.nt ltnvv now in force or which may hereafter be passer!, upon any proceeding iPtstituted for the recovery of the most rent, either by distress or otherwise. If default shall be made in the'payment of amty rent token the same shall become dite, or if the said Lesacc shall be vold out at ,sheriff's or constable's sale or permit an,y jndgnient to be rotered against A8 or make any as.vigrunent for the beueflt of creditors, or commit any act of bankruptcy whatever, then the rent for tite balance of the term, shall at once become due and may be colleclcd by distress or otherwise. Tlie said Lessee hereby confesses jud ,t pent in favor of the snit! Lc.vsor Jot lire wholo arnocrtt of the rent at any time remain. rtfiI Td,-io-?thrr.the saute shall have bean due or Plot, wairina stay of execution, ingarsitiot hd all exemption laws in w in force or which may hereafter be nailed-mast.. 'b?lt??'1'?"lltt??': ?lttit? .'?t?"ifilifilttTt?a,ar::w>.s. r?.?:?r en.m........... mrrrgposaesstanlond'exeoatiarv for edtti UltHottt lYaficiiid ig66b I kon l 940tImmediate t'ssulnlt o/a t lib if iH Flartl?er atgrtta that if the said Lessee (with the consent of lice Lessor) shall continue in possession of the said premises after the expiration of the said term, or any renewal thereof, then this agreement stall become immediately operative for another like term, and the Lessor shall have the right to anforce ouy of the, conditions or forfeitures of this agreement, including the confession of judgment, with. the, waivers, ate„ as if a new agreement identical rvith this had been executed by the said parties for the succeeding,term or terms. The ivords "fes.var" and "Lessee'" as herein usi!d shall include the singular as well as the plural number, and shall apply to corporations as well as to natural persons, and all the terms, covenants and conditions of this !ruse shall extend to and be binding upon the heirs, executors, administrators, successors and as.siens of the Lessor and Lessee. ?a$9 ?l??ll(?$$Qsfr${ ? Prr`Vf, the parties aforesaid have hereunta set their hands and seats on the day and year first above written. :?t ?.lraan t aF a My rornminion 6r t Jan M4 6? r.y V oa`r' 1 F t\ t\ V b? c N W un crS a a of C q 'C r, JEFFREY D. SANDERS CYNTHIA A. SHEARER Plaintiffs Vs. CHARLOTTE I. YONTZ Defendant sIN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA I INO. 99_21106 CIVIL TERM TO: CHARLOTTE I. YONTZ (Defendant) DATE OF NOTICE: 20th day of JULY , 1999 ,IMPORTAlLNOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT HERE YOU CAN GET LEGAL HELP: Court Administrator Fourth Floor Cumberland County Court House One Court House Square Carlisle, Pennsylvania 17013 (717) 240-6200 DATE July 20, 1999 By JAM S M. HACii, ESQUIRE Att ney I.D.# 18727 352 S. Sporting Hill Rd. MECHANICSBURG, PA 17055 (717) 737-2033 cr- nj i- c V-- ?P (j JEFFREY D. SANDERS 501 North Market Street Mechanicsburg, PA 17055 AND CYNTHIA A. SHEARER 891 Old Silver Springs Rd. Mechanicsburg, PA 17055 Plaintiffs, Vs. CHARLOTTE I. YONTZ 303 Pennsylvania Avenue Camp Hill, PA 17011 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW q7^ NO. NOTICE CIVIL TERM You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action promptly after this Petition, Order and Notice are served, by appearing personally or by attorney at the hearing scheduled by the Court and presenting to the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the Court may proceed without you and a judgment may be entered against you by the Court, without further notice, for any money claimed in the Petition or for any other claim or relief requested by the Petitioner. 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. COURT ADMINISTRATION FOURTH FLOOR CUMBERLAND COUNTY COURT HOUSE CARLISLE, PA 17013 717-240-6200 JEFFREY D. SANDERS IN THE COURT OF COMMON PLEAS 501 North Market Street Mechanicsburg, PA 17055 AND CYNTHIA A. SHEARER 891 Old Silver Springs Rd. Mechanicsburg, PA 17055 Plaintiffs CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. CIVIL TERM CHARLOTTE I. YONTZ 303 Pennsylvania Avenue Camp Hill, PA 17011 CIVIL ACTION-LAW Defendant AMENDED COMPLAINT AND NOW comes the Plaintiff, Jeffrey D. Sanders, by and through his attorney JAMES M. BACH, ESQUIRE and files the within Complaint: 1. Jeffrey D. Sanders is an adult individual residing at 501 North Market Street, Mechanicsburg, PA 17055, and Cynthia A. Shearer is an adult individual residing at 891 Old Silver Springs Road, Mechanicsburg, PA 17055 and both are the Plaintiffs herein. 2. Charlotte I. Yontz is an adult individual residing at 303 Pennsylvania Avenue, Camp Hill, PA 17011, and the Defendant herein. 3. Jeffrey D. Sanders is the landlord of Charlotte I. Yontz. 4. On or about the 8" day of March, 1972, Jeffrey D. Sanders and his then wife, Cynthia A. Sanders, entered into a lease contract with William H. Yonzt, now deceased, and Charlotte 1. Yontz, the Defendant herein. A photocopy of the lease is attached hereto and marked as Exhibit A. 5. The lease required the tenant to pay real estate taxes on the building. 6. The real estate taxes have not been paid on the property for 1997 and 1998 as of the date of this filing. 7. Non-payment of the real estate taxes is a violation of the lease. 8. The amount of taxes due and owing as of the date of filing is Two thousand fifty-six dollars and twenty-four cents ($2,056.24). WHEREFORE, Jeffrey D. Sanders respectfully prays that this court enter an order granting judgement in his favor for the minimum amount of $2,056.24 with the exact amount to be ascertain at the time of trial. FURTHER, Jeffrey D. Sanders respectfully requests that all costs be entered in his favor together with attorney fees. FURTHER, Jeffrey D. Sanders respectfully requests that this court enter an order of possession effective immediately in his favor and against the Defendant Charlotte I. Yontz. RESPECTFULLY SUBMITTED: JAMES M. BACH Attorney for the Plaintiff 352 South Sporting Hill Road Mechanicsburg, PA 17055 (717) 737-2033 Attorney I.D. #18727 (I .?. n. x972 l?id1R0 A--?3rCC3dt4' O) .lladcttls 0th troy fit March JEFM-.Y D. SMIDIM3 nn,l CYNT11TA A. SA1101-Tis, Isla wife WIU MI N. YONT7, and CIIMLOMN 1. YOUTZ) his wife hercinaftor called Les.tnr, and hereinafter called Les+ee., ? 1? R?1Rt' xirf fGQt That tha midhossor, (it cortilderatlon of the ton to and Covenants heretrta fter nienftoned does hereby rentt de.rn(se and tease 1106 tite wrist Lessee, to be used for the purpose , of Ia dwelling house xh honnehold furnJ.nltinlp included. the premtses situated tit the Borough of Croup 111)1[ County of Cumberland and Contrrinn.iwealth. of Pennsylvania, described as follows 30J Cattnaylvani:a Avmtuot Crunp 111.11, Potutaglvawl.n d jnht tUth IA jtt(1? unto the .raid Lessee, subjrrt to tite conditions ()/(/,(A ngrce- ntertt, for the tcritt of 1iS'o of William 11. Yontz & Charlotte I. Tontz cotitntenc(ne art lite eighth day of March .9. D. 1012 , and ending on the tiny of A. D. 19 r the death of the survivpr of }lillinm ll.Altz and Charlotte 1. Yontr. n AVvlt ?it.trnlicta Itrtstf the said Lessee agrees to part to the told Leiser for the rise of the said prenri.tes,.the surt of Uolfars, payable as follows, us: '00 d?o '00210%40111. dole CA1ttl (lie said Leseca also agrees to keep (he said premtses (it as good repair arid randition cos at preterit and at the expiratiort of this leasr, or any reartunt of (t; to surrender fill sarnrt lit like repair artd condition, nulurot wear and darnagr. by flirt elements excepted: to permit nn unlnufal busfrtese to he carried on upon sold prentlers; ivrf. fit perrrtlt air thine to be done tolitch is contrary to the. eand(tions of llie poNefes of (nstrrnnee natty nit (its sold premises or tuhich trial/ tit, placed thrrean daring the terni of this irasn fir any rrarrral thereof, it-hereby the, harerd aright be Increased or the insurance invalidated; tint to underlet tits said prendies, nor ossign this tense or arty interest therr(it to arty person or peramts tcithout ivrf(ten. corrseat of (.Its sold Lessar; and not to retrieve front file said promises during the, torn[ of this lease or any rencivat thilrnof. • 1'hA said rri4tA deP. s 16 foritnnn nit (r•e mad team frnrn nit slrlrwoli•s, and to k•rrp (Ito, said promises tit a c/part road sanitary Condition, and (o remove till aslics or otter gnrbage which niay arcitniulate uport Cite Patric dinntg the said terror, nr tiny rent-wal thereof, or failing therein to lorry to the said l,rasor double tie cost of rentmirtg the satire, to ho recovered the itante as rein due and (it arrenre: nrid agrees to pay this resit for file ute of scoter, electricity and got apart the said prernOrs during the said terra, crony renrnvar thereof, and tc/dch stay, he recovered by said Lessor as rent, rlitoand (it arrears; to permit the said Lessar to dlspiay a "for rent" or a "for enfa" card upon the sold premtses, nart to enter the Po(d premtses of ant/ tittle far the purpose of nink(ng necetsory repairs, or showing the sold prernisrs to prospective purchn.srrs or lessees. A1?i1 H fs NrIftrr tfgteth i.lint ehailyd file. Lrssce rrntnve ar attempt to rentot•e front Ilse smd premtses during the ternref 11e.0 lease, or any renruml thereof, then the attire, rent for tile, /till term of this lease, shall become (rile, and payable fit once and stay fort hitdth be collected by d(ittess or of/tentisr. ,tnd any tends revitwed front tait? premises either before or after tilt expiration of ttf sold ferra, toh(tr ally porlinn of file solid rent renta(riP uripnld, whetter due err plot, shall rentnfn liable fn dlstTres fur suet r ea f for t hr prr(a<f of thhr y days oJfcr sue/t reninunt, the Perrin as trough [Aril rrnrnined nn the preralsrs: arid arty rentoral of the goods front said prernOrs fit ant) tittle, •ltlter by day er rtf•h' uithonf file writtrit consent of the said Lessor shall be considered o clandestine and fraudulent reNorvrl. 4119" #I MR '111VIRP 111INFRY112 SPHNV !Illy? RMIrTmisnsu VMsat,a rww ¦r... UPON ®nts tIP811111 thl lord IIF/INLae 1141Abtlt n WN it its furll))tr /tgttrb that the. acceptntree by the sold Lessor of mill of the saitf rent nt any time after else. saute shall become drte, at default has beets, inside tit the paytBent thereof or any failure. of t he said f wear In en farce nny of t h e riglitt gained strider Chit lease or arty of the pets Alm, forfeitures or coadifiorts hererrt contolned,.111(sll not (n, ally it-tie bra considered at a ladit•er of the rlehi Inert force the stone rural that such right or forfellure may be rn/(srced udthout any twllce whntsorrrr; and t (Iat dell attempt to collect the rent by one proceeding shall Pint be coltslderrel us it troli•ei of the right of (he snitl Lector to collect the same by any outer proceeding, The said Lesser hereby walvet else usnnl three months notice to quit used agrees to surrender the sniff preitilses rat flip expirnelnit of the said tern, or the termGaffon of this innde urmty tduttval thereof, uelthaut any notice whatever, and new evolves the belle/lt of ill oppralaemeut, stay arid exemption lanes, the rfQht of ingn(s(hon. art real estate (trill all bnnkrtrpf or btsolvetst hiwl none fu force or which may hereafter be pacsnd, upon any prorcrding frtstituled for (lie recmrery of the said rent, either by distress or otheruisc. It default shall be made fit the'pnyritcrnt of any Pont token the, taste shall bectnde due, or if (lie wld Leince tllftll be. Told 01st fit sherlff's at cortstable'x Intel or permit anti Judgmrut to be ruirrrd agaficst qg or moire tiny atsi nntent for the benrflt of crefutor.1, or commit any ads of bnnA•rupfry whatever, llirn the rent for tile, balance of tare term shall at oitce become due and shay be collected by distress or otherivite, rite, laid f rssce lweby confemes JudesInent ht favor of (lie .mid Lessar for tine uhola orrnernrrt of the. rent at any tint r. rcurniu(?g tti(Pn(d, iu rester flirt taste shall have been due or toot, Uertlrine stall of execution. lnmanfflon. pfid all rxe.m/rl((sn lams iitrru fit forre or which stay hereafter bd passed. inlet lRegtlftt'ttts?ltpre r;?' ¢b' qlL.p?r,?(ta t >sat ,?.,N,e tree ntr.ariff soil at Pia hir.nt bfeobnOne "T flier s r 1 Al See elfin desert c aN oes at ko' za.eha'tHlh ell ii it lotuInd of a YfN1S/poseieililiti" iiilleieatsEtonr for edit! Mthallt Elklnj t?JVA at tna Court. i " Cad it in E11011tr tl4mb that if the tail Lessee (welt the consent of the Lessor) shall continue in possessfnn of the said preotties after the expiration of the told tdttn, or any renetral thereof, (lien this aereentent Shull become (mmedldtety operative,, for another IM term, anti the. Lestar shall have lire right to enforce. arty of the randilions or forfeitures of this ugredihent. In clPtltlne t11e confesdan. of judentent, with (lie umlvers, ell., as if a neur ngreement ideliffedl (with this halt bent executed by the said parties for the succeeding.terin or terms. The words "be.cenr" and "hrosrtr' as herein wird shall include. the singular as tvell as the plural Plumber, (slid shalt nppty to corporations Pis well as to natural peramu. Will all the Wrist. covenants anti conditions of this lrosn shod rxtend to and be breeding uport the heirs, executarl; ddrnlitistruturs, successors and nssiens of the Lessor anti Lessee. ?at 1111)!Iueoo ?j1lecl<cnaf,file pnrtirs aforesafd have hereunto set their hands atilt seals on the day and year first above wriltert. ?n ! e ?.lregrt t uE My CommhJon 6p 1 den , , 1474 0M e ?o o- Ij t\ Q) 0. 4V r . a a I Q r A A ?• T J I I i i ?? f? >..? ,•:? _. ? .(. ?; ,. !::: cJ .?.'???.1 ?r ` .-.? CJ T. ch ? R\ JEFFREY D. SANDERS 501 North Market Street Mechanicsburg, PA 17055 Plaintiff and CYNTHIA A. SHEARER 891 Old Silver Springs Road Mechanicsburg, Pa 17055 Plaintiff VS. CHARLOTTE I. YONTZ 303 Pennsylvania Avenue Camp Hill, Pa 17011 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-2906 DEFENDANT'S ANSWER TO AMENDED COMPLAINT AND NOW comes the above-named Defendant, Charlotte I. Yontz, by her attorney, Samuel L. Andes, and makes the following answer to Plaintiff's Complaint in this matter: 1. Denied. It is admitted that Jeffrey Sanders is the Plaintiff. Defendant denies, however, that Cynthia A. Shearer is a Plaintiff or has any desire to participate in this action. To the contrary, Defendant states that Cynthia Shearer opposes this action and has no desire to bring an action against the Defendant or to deprive Defendant of her continued occupancy of the real estate which is the subject of this action. 2. Admitted. I Denied. Defendant's landlords are both Jeffrey D. Sanders and Cynthia A. Shearer and this action has been filed by Jeffrey D. Sanders without the participation, consent, or authority of Cynthia A. Shearer and, as a result, is invalid. 4. Admitted. 5. Denied as stated. The lease speaks for itself and no interpretation is necessary here. To the extent that a further answer is required, however, Defendants states that the lease between the parties only obligated Defendant and her late husband to make payment of taxes and insurance to the mortgage company and did not obligate them to make direct payment of real estate taxes. 6. Denied, the Defendant and her daughter are currently in the process of making payment of those taxes. 7. Denied for the reasons set forth in answer to Paragraph 5 above. By way of further answer, Defendant states that she is currently making payment of the real estate taxes. Defendant is not in violation of the lease. 8. Admitted. WHEREFORE, Defendant prays this Court to dismiss Plaintiff's Complaint and enter judgment in favor of the Defendant. Samuel L, Andes Attorney for Defendant Supreme Court ID 17225 525 North 12'x' Street Lemoyne, PA 17043 (717) 761-5361 COMMONWEALTH OF PENNSYLVANIA ? 1 SS.. COUNTY OF CUMBERLAND ) CHARLOTTE I. YONTZ, being duly sworn according to law, deposes and says that the facts set forth in the foregoing document are true and correct to the best of her knowledge, information, and belief. Sworn to and subscribed before me this ,Pt)t jday of ( j 1999. 4 Notary (Public NOTAWL AYYILFU UJ.WMyPdfle Lw"mBM Cwt Mad0=4, PA N7 C+m+Mrelm E?cpkH pdm. DJ, 2J09 CHARLOTTE I.YONTZ / .._ ?. ?_: e": ?- ?' .... ? ].i . (': : ' ? j.. _ ?.. 1 ??? ?1 ril ., - ? ?...1 i.J L? 7 N ? n W ? y t7 y !' ? u r C' a 6 ?--? n w p ? .7 ? ? W x ? °. w W O H a 0. ,`p F ? W '? < Z 'l. ry O 17 i w a JEFFREY D SANDERS : IN THE COURT OF COMMON PLEAS OF and : CUMBERLAND COUNTY, PENNSYLVANIA CYNTHIA A. SHEARER CIVIL ACTION - LAW V. 99-2906 CIVIL TERM CHARLOTTE I.YONTZ IN RE: ARBITRATION ORDER OF COURT AND NOW, December 1, 1999, the Court having been informed that the parties have reached a settlement, the Board of Arbitrators previously appointed is hereby vacated. The Chairman, Charles E. Shields III, Esquire, shall be paid the sum of $50.00. Charles E. Shields III, Esquire Cop, „ 4 i??o/QV• Court Administrator :ssg By the Court, 3 ti ?{ of o U