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.CORtAIONWEALTN Of PENNSYLVANIA
COURT OF COMMON PLEAS
IUDICIAL DISTRICT
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS Ne (30- 1 LI s 1 9 '
N A 4r/
" U. ville 26 17241
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E f APT2LLAN A Y_ A ! N$-lyr.L,
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LT ?99 9 LT 1 ^;E 99 P/„//, C. y /rvf„e /Pav
Ths block will be ryf Q• / J
1008& sg^°d ONLY when this notaton is mquirod undo Pa RCPJP. No, ad, f 1- ;4 /70l
Ifa llant was CLAIMANT (see Pa. R.C.P.J.P. NO.
This Notice of Appeal, when received by the District Justice, will operate as a 1001(6) in action before District Justice, he MUST
SUPERSEDEAS to the judgment far possession in this case
FILE A COMPLAINT within twenty (20) days alter
Sigrrafure u! goflronotarv N rlon,,,,, filing his NOTICE of APPEAL.
(This section Of fors to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.JP. No 1001(7)•in action before District Justice.
If NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPEt To Prothonotary
Enter rub upon - W I l l i n m a ** 3 G
Qp Na-ne o1 3ppo1bMs1 , alspellee(s), to fib a complaint in this apiled
(Con mon Pleas NO J-7 r?Vl I TQfM J within twenty (20) days after serv' a of rub cr suffer tr of
try judgment of on pos
' of egoeea t or he effmw ar V"
RULEt To w; 7 1 .lam EPA
Name of appallevs) (1) You ae notified that a rub is hereby entered upon you to fib a complaint in this appeal within twenty (20) days offer 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 rub if service was by mail is the date of maili
Dote: 7'0',,999 . 1'&A NN ? ham
sweaee Of ar o,aeyayaay
AaPC 312-U COURT FILE TO BE FILED WITH PROTHONOTARY
NOTICE OF APPEAL --?-
Notice is given that the oppellont has filed in the above Court of Comrtgn Pleas an appeal from the judgment rendered by the District luslka on the
date and in the case mentioned below
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COMMONWEALTH OF PENNSYLVANIA
C0t1NTY 0P- CUMBERLAND
No.
09-3-02
DJ Name' Mon.
HELEN B. SHULENBERGER
A0"eee P.O. BOX 155
27 W. BIG SPRING AVENUE
NEWVILLE, PA
TolaPhono (717) 776-3187 17241
NOTICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF: RESIDENTIAL LEASE
NAME and ADDRESS
rBEATTIE, WILLIAM
111 CLEMSON DRIVE
CARLISLE, PA 17013
L J
VS.
DEFENDANT: NAME and ADDRESS
FRAILOR, RICHARD, ET AL.
746 BLOSERVILLE RD.
NEWVILLE, PA 17241
LORI NAILOR L J
746 BLOSERVILLE RD. DocketNo.: LT-0000107-99
NEWVILLE, PA 17241 Date Filed: 8/16/99
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLAINTIFF
® Judgment was entered for: (Name) BEATTIE, WILLIAM
Judgment was entered against NAILOR, LORI in a
® Landlord/Tenant action in the amount of $ 5,016.65 on 8/27/99 (Date of Judgment)
The amount of rent per month, as established by the District Justice, is $ 450.00.
The total amount of the Security Deposit is $ 400.00.
Total Amount Established by DJ Less Security Deposit Applied = Adjudicated Amount
Rent in Arrears $ 4, 900.00 -$ .00 = $ 4,900.00
Physical Damages Leasehold Property $ .00-$ .00 = $ .00
Damages/Unjust Detention $ -00-$ -00 = $ _ nn
Less Amt Due Defendant from Cross Complaint - $ -00
? Attachment Prohibited/ Interest (if provided by lease) $ -DO
Victim of Abuse (Act 5, 1996) LIT Judgment Amount $ 4, 9nn . nn
? This case dismissed without prejudice. Judgment Costs $ 116.65
Attorney Fees $ -00
® Possession granted. Total Judgment $ 5.016.65
? Possession granted if money judgment is not satisfied by time of eviction.
? Possession not granted. ? Defendants are jointly and severally liable.
? Levy is stayed for days or ? generally stayed.
? Objection to Levy has been filed and hearing will be held:
ANY PARTY HAS THE RIGHT TO APPEAL A iunGMENT INVOLVING
AND AFFECTING THE DELIVERY OF POSSESSION
OF REAL PROPERTY WITHIN 10 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE
PROTHONOTARYXLERK 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 RESIDENTIAL LEASE, YOU HAVE 30 DAYS
AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARYICLERK OF COURTS OF
THE COURT OF COMMON PLEAS, CIVIL DIVISION.
YOU MUST INCLU A COPY 0 THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
Date
My commission expires first Monday of January, 2000
AnPr. 11 U.ao
District
SEAL
William Beattie IN THE COURT OF COMMON PLEAS OF
Plaintiff
V.
Richard Nailor and Lori Nailor,
Defendants
To the Prothonotary:
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- CIVIL TERM
Kindly allow, Lori Nailor, Defendant, to proceed is forma pau ris.
1, Philip Briganti, attorney for the party proceeding jn forma paup&ns, certify that I believe the party
is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit
showing inability to pay the costs of litigation is attached hereto.
Philip C riganti
Attorney for Defendant
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
William Beattie IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V.
Richard Nailor and Lori Nailor,
Defendants
NO. 99- CIVIL TERM
AFFIDAVIT IN SUPPORT OF PETITION
FOR LEAVE TO PROCEED IN FORMA PAUPERIS
1. I am the Defendant in the above matter and because of my financial condition am unable to pay
the fees and costs of prosecuting, defending, or appealing the action or proceeding.
2. 1 am unable to obtain funds from anyone, including my family and associates, to pay the costs of
litigation.
3. I represent that the information below relating to my ability to pay the fees and costs is true and
correct.
(a) Name: Lori Nailor
Address: 746 Bloserville Rd.
Newville. PA 17241
(b) Social Security Number: 208-56-9455
If you are presently employed, state
Employer: N/A
Address:
Salary or wages per month:
Type of work:
If you are presently unemployed, state
Date of last employment: 5/99
Salary or wages per month: $600.00/mo (gross)
Type of work: Counter/Cashier
(c) Other income within the past twelve months
Business or profession:
Other self-employment: N/A
Interest:
Dividends: N/A
Pension and annuities: N/A
Social Security benefits: N/A
Support payments: S ppQse to receive $50/mo hasn't received in several years
Disability payments: N/A
Unemployment compensation and
supplemental benefits: Received $607.00 from 1/98 to 9/98
Workman's compensation: N/A
Public Assistance: $403/month from 11/98 to present
Other: N/A
(d) Other contributions to household support
(Wife)(Husband) Name:
If your (husband) (wife) is employed, state
Employer: N/A
Salary or wages per month:
Type of work:
Contributions from children: N/A
(e) Property owned
Cash: - $0
Checking Account:_ N/A
Savings Account:_ N/A
Certificates of Deposit:
Real Estate (including home): N/A
Motor vehicle: Make Oldsmobile Cutlass Calais year 1986
Cost $1500.00 Amount owed_IQ_
Stocks; bonds: N/A
Other: N/A
(f) Debts and obligations
Mortgage:
Rent: $400 00/month
Loans: N/A
Monthly Expenses: r ri s $150.00 (aft r food stamps)- Electric $200,00- Garbage $19.00
(g) Persons dependent upon you for support
(Wife) (Husband) Name:
Children, if any:
Name: Christopher Coble Age: 10 years
Michael Pierce - 7 years
4. I understand that I have a continuing obligation to inform the court of improvement in my
financial circumstances which would permit me to pay the costs incurred herein.
5. 1 verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to
authorities.
Date: h/qq r?, I L - ' )(a, `'
,s
Lori Nailor, Defendant
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US Postal Service
Receipt for Certified Mail
No Insurance Coverage Provided.
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SmI to
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Street 8 Number
Box 155 27 W. B'
Steta, E
Poll Office, ZIP Code
1gpri
Newville PA 1724
Postage .4 J
Certified Fee
Fee
Special Delivery
Restricte6Ddiv6ry Fee .
Return Roc' to
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Date. It address
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US Postal Service
Receipt for Certified Mail
No Insurance Coverage Provided.
Do not use for Intsmational Mail /Sea revamat
Sent to
William
Beattie
Street 8 Number
111 Clem
son Dr
Post Otfite, State, & ZIP Code
Postage $ 33
Certified Fee
Special Delivery Fee
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COMMONWIALTN OF PENNSYLVANIA NOTICE OF APPEAL
COURT OF COMMON PLEAS
FROM
JUDICIAL DISTRICT
DISTRICT JUSTICE JUDOMENT
COMMON PLEAS Pie. 5"41-17t (tiv, Term
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice an the
dot* and in the case mentioned below.
1741
N 7 lFS.vs 1 I )
i l .
ui? ua.. s.... x<. Ksw?s-!.a_?_z_
CV 19
LT19 s -t„-., f1/„l, 7 < r,r,.?/r (u. L? 17r) '
This block will be signed ONLY when this notation is required under Pa R.C.P.J.P. NO If appellant VMS CLAIMANT (see Pa. R.C.P.J.P. NO.
10088.
This Notice of Appeal, when received by the District Justke, will operate as a 1001(6) in action before District Justice, he MUST
SUPERSEDEAS to the judgment for possession in this case FILE A COMPLAINT within twenty (20) days after
o tiling his NOTICE of APPEAL.
ianature Rothonowv a Deputy
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 <11 t i 1 , appellee(s), to file a complaint in this appeal
/L.j N,'Yne or isooAcis)
(Comnan Pleas Na 9(?- 5 L? / 3 C"V; I T (f l IY within twenty (20) days after, service of rule or suffer entry of judgment of non pros
S9VI p Of rypaeant OF his aaamey a apm/
RULE: To I', T ::. t i , oppellee(s).
Name of apperke(s)
(1) You ae ratified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the dab 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 nail is the dab of mailing.
- r,
Dater 1919
some" of Jrolnoncla'r or onager
r
JaPC31J.e. COURT FILE
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN T( -N r 101 DAYS AF rFf7 Gang the notice of appeal. Chock applicable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF_ Cumberland
AFFIDAVIT: I hereby swear or affirm Ihot I served
99-5443 Civil Term
OCa copy of the Notice of Appeal, Curmnon Ple,is No . ---- ___ upon the District Justice designated therein on
(datoofservice September 7, 1999
- -------____ JYtIY rmrs2l3eaLne st•rtifX by (certified) (pggi]QIg7p mail, sender's
I In n e
receipt attached hereto. and upon the appellee, rnamo; Hh -A
September 7 9g ? -- -- on
n 19___ L-1 by personal service 4 by Rrcrhhed) p(d{p6R'j Xma 1, sender's receipt attached hereto.
X and further that l served the Rule to Hilo, C,mplmntarr,ornpanying the above Notice of Appeal upon the appellee(s) to whom
the Rule was addressed on -September-7
1? by personal serwcr][Y by (certified)
mail. sender's receipt attachod neh•lo r
SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME i ^ /r 7
THIS DAY OF
-/f---L-_ ?_
------ -----'.---. 79.._-----. _ _/ -
L
? Signature of affiant
S,gnatu,e u' yao,ar bcruio I,?o„....F2n,, he, I1. ,
Ilea or olGCi?r
I verify that the information in this Affidavit is true and correct.
I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. Section 4904, relating to unsworn
falsification to authorities,
hili C. Br' nti
COMNIONWEAI_TI I OF PENN SFLVANIA
Helen B. Shulenberger
District Justice 09-3-02
27 W. Big Spring Ave.
P. 0. Box 155
Newville, PA 17241
CLAIM NUMBER LT 19 99 LT-107-99
- -
DATE FILED: 4 August 16, 1999 J
AMOUNT DATE PAID
FILING COSTS $ 89.50
SERVICE COSTS $ - 40.00__
TOTAL S 129.50 8/16/99
LANDLORD AND 99-5443
TENANT COMPLAINT
PLAINTIFF
.
NAME
AND William Beattie
ADDRESS 111 clemson Dr.
Carlisle, PA 17013
IN_FLNDANTISI VS.
L?IAF
AND
ADDRESS
? NAME
AND
ADD[
FSS
TO THE DEFENDANT: THE ABOVE NAMED PLAINTIFF(S) ASKS I
JUDGMENT TOGETHER WITH COSTS AGAINST YOU FOR THE POSSESSION L
OF REAL PROPERTY AND FOR: --- - - --
Richard Nailor746 Bloserville Road
Nevville, PA 17241
Lori Nailor
746 Bloserville Road
Nevville, PA 17241
® DAMAGES FOR INJURY TO THE REAL PROPERTY, TO WIT. damage to carpet, walls,
IN THE AMOUNT OF
? DAMAGES FOR THE UNJUST DETENTION OF THE REAL PROPERTY IN TI'IE AMOUNT OF
® RENT REMAINING DUE AND UNPAID ON FILING DATE IN THE AMOUNT OF
? AND ADDITIONAL RENT REMAINING DUE AND UNPAID ON HEARING DATE
doors, etc.
$1500.00
$
$3400.00
THE PLAINTIFF FURTHER ALLEGES THAT: TOTAL $4900.00
1. THE LOCATION AND THE ADDRESS, IF ANY, OF THE REAL PROPERT Y IS
746 Bloserville Road, Newville, PA 17241
2. THE PLAINTIFF IS THE LANDLORD OF THAT PROPERTY.
3. HE LEASED OR RENTED THE PROPERTY TO YOU OR TO UNDER WHOM YOU CLAIM.
4. ? NOTICE TO REMOVE WAS GIVEN IN ACCORDANCE WITH LAW, OR
? NO NOTICE IS REQUIRED UNDER THE TERMS OF THE LEASE
S. ? THE TERM FOR WHICH THE PROPERTY WAS LEASED OR REN fED IS BULLY F.NDED, OR
? A FORFEITURE FIAS RESULTED BY REASON OF A BREACII OF fl IE CONDITItiNS Of TI III LEASF, TO WIT
Damages to property and repeatedly issuing "NSF" checks to pay rent.
OR,
9 RENT RESERVED AND DUE HAS, UPON DEMAND REMAINED UNSATISFIED
6. YOU RETAIN THE REAL PROPERTY AND REFUSE TO GIVE UP ITS POSSESSIJN.
William Beattie Hereby swear
or affirm that the facts set forth in this complant an aue ;md corrl 1- Ibe b l oI toy knovAed9c inform Tien and bollef. This ereby mt is
made subject to the penalties of 18 Pa. C S. § 4904 rotating to unsworn htlsihration to authonhes
(Signature of Atluant)
rlaini s Attorney
Addwss
...Phone
LOCATION nnTr:. TIME
27 W. Big Spring Ave., Revville, PA 17241 August 27, 1999 9:30 a.m.
IF YOU HAVE A DEFENSE I, IN r ompluinl y"u n rr ores nt nth h r II YO II I At F A CI_AII i n the I nm rf nn;i,g out of the occupancy
of the premises, Which is Wtlhin th<. D.; nC .1 nn r µ rude L x v, „h ch y , e, I , tho r JI , ; rill r t T FILE A c.n - complaint form at
this office BEFORE TI IF TIME -l for 11, 1!, ,,it I; IF YOU DO r IT APP. AR sI !I It- I It .PIN,', <„on ,ind costs, and for damages
and rent it dalmod rmiy w-wrtl r I. r. A J. n,' , r l .. m w I VIrAlON horn tho premises
SERVICE OF PROCESS P'%[' LILIAII,' FF resTIMONY LIAV BF
RIi-:VHI1Lf1 UrJ R6VERSL ADL
MAILED (DATE) V
SERVED (DATE) [_i NOf SHrVFU
PROOF OF SERVICE At IACHED RFA.5O#'
183 DSi"RICT JUSI Iul, - PE HMANE NI COPY t
PLAINTIFF DID NOT APPEAR
DEFENDANT DID NOT APPEAR
DEFENDANT APPEARED Ai HEARING
REPRESENTED BY
NOT REPRESENTED
? JUDGMENT ENTERED ON (DATE)
? STAVED (DATE) _
? CONTINUED TO (DATE 8 TIME)
PLAINTIFF DID NOT APPEAR
FIDEFENDANT DID NOT APPEAR
?
t. V
Tl i , a?
' JUDGMENT PLAINTIFF
FOR
Z DEFENDANT
O Mr
1- NOTICE OF JUDGME NT 11 POSSESSION
to
O GIVEN ON (DAI E)
a AMOUNT OF JUDGMENT $
COSTS $
TOTAL $
Distn't Justice.
JUDGMENT ? PLAINTIFF -
FOR NWLJ
DEFENDANT APPEARED AT HEARING Z DEFENDANT
O w+e¢
Fj REPRESENTED BY NOTICE OF JUDGMENT 1:1 POSSESSION
GIVEN ON (DATE)
NOT REPRESENTED aAMOUNT OF JUDGMENT $
N
JUDGMENT ENTERED ON (DATE) 0 COSTS $
? STAVED (DATE)
? CONTINUED TO (DATE Z TIME)
TOTAL $
Gish ict Justice
COMMONWEALTH OF PENNSYLVANIA
r,nI INTV nn• CUMRRRT,AMn
0131 No
09-3-02
DJ Name' Hon.
HELEN B. SHULRNMRGER
Pd°1B" P.O. BOX 155
27 W. BIG SPRING AVENOR
NEWVILLE, PA
Tabphana: (717 ) 776-3187 17241
HELEN D. SHULENBERGER
P.O. BOX 155
27 W. BIG SPRING AVENUE
NEWVILLE, PA 17241
THIS IS TO NOTIFY YOU THAT:
7X ,ludgment: FOR A?-TJTTFF
Judgment was entered for: (Name) BEATTIE, WILLIAM
Judgment was entered against NAILOR, LORI in a
Landlord/Tenant action in the amount of $ 5, 016.65 on 8127 /99 (Date of Judgment)
The amount of rent per month, as established by the District Justice, is $ 450.00,
The total amount of the Security Deposit Is $ 400.00.
Total Amount Established by DJ Less Security Deposit Applied = Adjudicated Amount
Rent in Arrears $ 4.900.00 -$ .00 = $ 4.900.00
Physical Damages Leasehold Property $ .00 -$ .00 = $ .00
Damages/Unjust Detention $ .00-$ .00 = $ _on
Attachment Prohibited/ Less Amt Due Defendant from Cross Complaint - $ .00
Victim of Abuse (Act 5, 1996) Interest (if provided by lease) $ -00
UT Judgment Amount $ 4, a nn _ nn
? This case dismissed without prejudice. Judgment Costs $ 11 6 - 6S
Attorney Fees $ -00
® Possession granted. Total Judgment $ 5.016.65
? Possession granted if money judgment is not satisfied by time of eviction.
? Possession not granted.
? Levy is stayed for days or ? generally stayed.
? Objection to Levy has been filed and hearing will be held:
NOTICE OF JUDGMENT/TRANSCRIPI
PLAINTIFF. RESIDENTIAL LEASE
NAME eM ADDRESS
FBRATTIE, WILLIAM
111 CLEMSON DRIVE
CARLISLE, PA 17013
L
DEFENDANT: VS.
NAME aM ADDRESS
rNAILOR, RICHARD, RT AL.
746 BLOSERVILLE RD.
NEWVILLE, PA 17241
L
Docket No.: LT-0000107-99
Date Filed: $116/99
? Defendants are jointly and severally liable.
ANY PARTY HAS THE RIGHT TO APPEAL A JUDGMENT INVOLVING A RESIDENTIAL LEASE AND AFFECTING THE DELIVERY OF POSSESSION
OF REAL PROPERTY WITHIN 10 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE
PROTHONOTARYICLERK 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 RESIDENTIAL LEASE, YOU HAVE 30 DAYS
AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARYICLERK OF COURTS OF
THE COURT OF COMMON PLEAS, CIVIL DIVISION,
YQU MUST N 4Dfi./A COPY F HISNOTIC?C OF J?? ENWTRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
Date
mmission expires first Monday of January, 2000
AnM? coAA.AA
r.u
District
SEAL
WILLIAM H. BEATTIE, : IN THE COURT OF COMMON PLEAS OF
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
RICHARD NAILOR and NO. 99-5443
LORI NAILOR,
DEFENDANTS
NOTICE TO DEFEND
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, order 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 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
1-800-990-9108
Americans with Disabilities
Act of 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our
office. All arrangements must be made at least 72 hours prior to any hearing or business before the
court. You must attend the scheduled conference or hearing.
WILLIAM H. BEATTIE, : IN THE COURT OF COMMON PLEAS OF
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
RICHARD NAILOR and NO. 99-5443
LORI NAILOR,
DEFENDANTS
COMPLAINT
AND NOW, this_ day of September, 1999 comes the plaintiff, William H. Beattie,
and makes the following Complaint against the defendants as follows:
The plaintiff, William H. Beattie, is an adult individual residing at 111 Clemson Drive,
Carlisle, Cumberland County, Pennsylvania 17013.
2.
The defendants, Richard Nailor and Lori Nailor, his wife, are adult individuals residing at
746 Bloserville Road, Newville, Cumberland County, Pennsylvania 17241.
3.
The plaintiff rented at the property a one (1) bedroom apartment situate at 746 Bloserville
Road, Newville, Pennsylvania 17241.
1)
4.
The plaintiff rented the property to the defendants on verbal month to month lease for the
sum of Four Hundred and no/100 ($400,00) per month plus late charges of five and no/100
($5.00) Dollars per day.
5.
The defendants failed to pay rent as required for the months of February, March, April,
May, June, July, August, and September.
6.
In addition, the defendants damaged the property by damaging the front door, the front
storm door, and the carpeting. The total damage exceeds the sum of One Thousand Five
Hundred and no/100 ($1,500.00) Dollars.
7.
The rent due is as follows:
1. February $400.00
2. March $400.00
3. April $400.00
4. May $400.00
5. June $400.00
6. July $400.00
7. August $400.00
8. September $400.00
Late Charges $1,190.00
Total Rent & Late Charges $4,390.00
3
8.
Despite repeated demands, the defendants have failed to pay the balances due to the
plaintiff.
9.
The plaintiff is entitled to possession of the property.
10.
The total amount due to the plaintiff is Five Thousand Eight Hundred Ninety and no/100
($5,890.00) Dollars.
WHEREFORE, the plaintiff requests damages in the amount of Five Thousand Eight
Hundred Ninety and no/100 ($5,890.00) Dollars plus costs and interest as permitted by law in
addition to possession of the property.
Respectfully submitted,
IRWIN, MCKNIGHT
By: MarcuEA. Mc night, III, s
60 West Pom t Street
Carlisle, Pennsy a 1 1013
(717) 249-2353
Supreme Court I.D. No. 25476
Attorney for plaintiff,
William H. Beattie
Date: September 27, 1999
VERIFICATION
The foregoing Complaint is based upon information which has been gathered by
counsel and myself in the preparation of this action. 1 have read the statements made in
this document and they are true and correct to the best of my knowledge, information and
belief. I understand that false statements herein made are subject to the penalties of 18
Pa. C.S.A. Section 4904, relating to unswom falsification to authorities.
WILLIAM H. B ATTIE
Date. 7 9 1 1999
WILLIAM H. BEATTIE, : IN THE COURT OF COMMON PLEAS OF
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
RICHARD NAILOR and NO. 99-5443
LORI NAILOR,
DEFENDANTS
CERTIFICATE OF SERVICE
I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached Complaint
was served upon the following by depositing a true and correct copy of the same in the United
States mail, First Class, postage prepaid in Carlisle, Pennsylvania,
on the date referenced below and addressed as follows:
Philip C. Brigand, Esquire
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
By:
60 West Pomfret Std
Carlisle, PA 17013
(717) 249-2353
Supreme Court I.D. No. 25476
Date: September 27, 1999
IRWIN, McKNIGHT & HUGHES
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