HomeMy WebLinkAbout99-05460
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F ES 2 5 2000
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
Christine L. Plunkett, )
Complainant/Appellee, )
V. )
Michael A. Soduco, trading as )
Consolidated Properties, )
Respondent/Appellant. )
No. 99-5460 Civil Tenn
ORDER
AND NOW, yf 'w tr S 2000, in consideration of the
foregoing petition, Esq., lh ll c?sc/?
Esq., Pti1 ,6-y- are appointed arbitrators in the above-
captioned action as prayed for.
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By the Court,
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
Christine L. Plunkett, )
Complainant/Appellee, )
V. ) No. 99-5460 Civil Terre
Michael A. Setheco, trading as )
Consolidated Properties, )
Respondent/Appellant. )
COMPLAINANT/APPELLEE'S PETMON FOR APPOINTMENT OF ARBTIRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
Complainant/Appellee in the above action respectfully represents that:
1. The above-captioned action is at issue.
2. The claim of the Complainant/Appellee is $558.00. There is no counterclaim of
the Realmdent/Appellant in the action.
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators
to whom the case shall be submitted.
Respectfully submitted,
Christine L. Plunkett
Complairmt/Appellee
Dated: February 21, 2000
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
Christine L. Plunkett, )
Complainant/Appellee, )
V. )
Michael A. Seduco, trading as )
Consolidated Properties, )
Respondent/Appellant. )
No. 99-5460 Civil Term
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the within Complainant/Appellee's
Petition for Appointment of Arbitrators has been served via U. S. First Class Mail on this 21st day
of February, 2000, as follows:
Michael A. Serlmo, trading as
Consolidated Properties
400 North Front Street
Wormleysburg, PA 17043
Christine L. Phmnkett
Pro Se Appellee/Complainant
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Christine L. Plunkett
429 Garden Drive
Mechanicsburg, PA 17055
Complainant/Appel lee,
v.
Michael A. Serluco, trading as
Consolidated Properties
400 North Front Street
Wormleysburg, PA 17043
Respondent/Appellant
IN THE COURT OF COMMON
PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
No. 99-5460 Civil Term
APPELLANT'S ANSWER
1. Admitted.
2. Admitted in part and denied in part. It is denied that Respondent is a Limited
Partnership. Respondent is a Sole Proprietorship.
3. Admitted. In new matters, as required in 68 P.S. 250.512 (a) Respondent provided a
statement to Complainant on April 21, 1999 with a description of why the deposit
was being withheld. This is well within the 30 days required. Therefore, Respondent
should not be responsible to pay double the security deposit amount.
4. Admitted.
5. Admitted.
6. Admitted.
7. Admitted.
8. Admitted. By way of further answer, Respondent was trying to find out what the
intentions of the Complainant were as to remaining in the apartment. Respondent is
now just completing renovations on the apartment in question, scheduled for
completion on October 15`h, 1999. For information purposes, 14 other apartments
were completed before this unit.
9. Denied. Complainant hadn't made a decision yet because Complainant had to discuss
situation with her boyfriend.
10. Admitted.
11. Admitted.
12. Admitted.
13. Admitted.
14. Admitted.
15. Admitted.
16. Admitted. By way of further answer, this means Complainant paid a full month rent
on the first of any given month. Since the notice was until April 14`h Complainant's
rental account would be prorated - meaning Complainant would only be charged for
rent from April 1 thm April 14, 1999, not for rent from April 1 thru April 30'h.
17. Denied. Complainant was responsible until end of notice period, which was April
14th.
18. Bert Love's memory is not clear on this matter, however, one's beliefs are not always
the company's practices under the lease terns.
19. Admitted.
20. Neither Admitted nor Denied. By way of further answer, a contractor was hired and
given free rein. The office was not always notified when a new unit was begun.
Respondent has no way of knowing what date the contractor began work in the
apartment.
21. Admitted.
22. Admitted.
23. Denied. Respondent did not "offer" any option. The notice was given and
Complainant was responsible until the end of the notice term, April 14, 1999.
Date: October 13, 1999
R [fully submitted,
Michael A. Serluco
Pro Se Appel lant/Respondent
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COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
Christine L. Plunkett
429 Garden Drive
Mechanicsburg, PA 17055
Complainant/Appel lee,
v.
No. 99-5460 Civil Term
Michael A. Serluco, trading as
Consolidated Properties
400 North Front Street
Wormleysburg, PA 17043
Respondent/Appellant.
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 ajudgment 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 Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
Christine L. Plunkett )
429 Garden Drive )
Mechanicsburg, PA 17055 )
Complainant/Appellee, )
V. )
Michael A. Serluco, trading as )
Consolidated Properties )
400 North Front Street )
Wormleysburg, PA 17043
Respondent/Appellant
No. 99-5460 Civil Term
Parties - Appeal Details
Appellee/Complainant is Christine L. Plunkett, an adult individual residing at 429 Garden
Drive, Mechanicsburg, Pennsylvania 17055.
Appellant/Respondent is Michael A. Serluco, trading as Consolidated Properties, a
Limited Partnership organized and existing under the laws of the Commonwealth of
Pennsylvania with a place of business at 400 North Front Street, Wormleysburg, Pennsylvania
17043.
On August 9, 1999, the Appellee/Complainant received ajudgment in the amount of
$543.00 in favor of Appellee/Complainant and against Appel lant/Respondent from The
Honorable Robert V. Manlove of Commonwealth of Pennsylvania, County of Cumberland, Mag.
Dist. No. 09-1-02 which judgment is incorporated herein by reference.
4. The judgment is calculated as follows:
$500 = (($250 wrongfully withheld security deposit x 2 as
provided by 68 P.S. §250.512(c))
+ 43 = (Judgment Costs at Mag. Dist. Level)
$543
Allegations
5. On or about September 1, 1998, Appellee/Complainant gave to Polly Myers a check in
the amount of $250 which represented the security deposit for premises more commonly known
as 6-A College Park Apartments, Camp Hill, PA 17011 (the "Premises").
6. On or about September 1, 1998, Appellee/Complainant moved into the Premises.
7. On or about November 17, 1998, Appellee/Complainant received notification that
Appellant/Respondent had purchased the Premises, along with several other properties at College
Park Apartments, from Polly Myers via correspondence dated November 16, 1998. In this
correspondence, Appel lant/Respondent indicated that they planned to remodel these properties
and that "most work would not begin until Springtime" Sae attached at Tab A.
8. On or about December 1, 1998, and continuing on approximately a bimonthly basis,
Appellant/Respondent began calling Appellee/Complainant inquiring as to whether or not
Appellee/Complainant planned to stay and if not, when Appellee/Complainant planned to move
out so remodeling of the Premises could begin.
9. In response to the repeated phone calls from Appel lant/Respondent,
Appellee/Complainant indicated that she had not made a decision yet and that the rent was
probably increasing to an amount which was unaffordable to Appellee/Complainant.
10. Also, in response to the repeated phone calls from Appellant/Respondent,
Appellee/Complainant indicated that she would move out in compliance with the appropriate
notice to quit from AppellanURespondent as provided by 68 P.S. §250.501.
11. On March 11, 1999, Carey Twigg of the office of Appellant/Respondent called
Appellee/Complainant again inquiring as to whether or not Appellee/Complainant was staying or
moving out because AppellanURespondent needed to know as soon as possible.
Q. In response to the above-referenced telephone call from Carey Twigg of the office of
Appellant/Respondent, Appellee/Complainant again indicated that she had not made up her mind
but that she would move out upon receipt of the appropriate notice to quit from
Appellant/Respondent.
13. Carey Twigg of the office of AppellanURespondent responded to this by saying that it
was the responsibility of Appellee/Complainant to inform Appel lant/Respondent because
Appellee/Complainant wanted to move out.
14. Appellee/Complainant responded to this by indicating that this was untrue because she
had just moved in to the Premises not more than eight months ago.
15. On or about March 12, 1999, Appellant/Respordent presented a notice to
Appellee/Complainant indicating that Appellee/Complainant had to move out of the Premises by
April 14, 1999. See attached at Tab B.
16. The above-referenced notice indicated that "rent from April I - April 14, 1999 will be
prorated." See Tab B.
17. Appellee/Complainant believes and therefore avers that any such prorated rent as set forth
above is not and was not due to AppellanURespondent.
18. On or about March 13, 1999, Appellee/Complainant notified Appel ]ant/Respondent that
she believed that if she moved out by the end of March, she would not be responsible for
prorated rent from April 1 through April 14, 1999 because this would allow the
Appel lant/Respondent's contractors to begin remodeling. To this, Bert Love of the office of the
Appel lant/Respondent indicated that she agreed with Appellee/Complainant's belief in this
regard.
19. On March 31, 1999, the Premises were surrendered to the Appellam/Respondent by
Appel lee/Compiainant as evidenced by receipt for keys. Ste attached at Tab C.
20. On March 31, 1999, Appellant/Respondent accepted said surrender of the Premises
evidenced by Appellant/Respondent's contractors commencing remodeling of the Premises Y
21. On or about April 13, 1999, Appellee/Complainant notified Appellant/Respondent of her
new address by way of correspondence sent via Certified Mail/Return Receipt Request. Ste
attached at Tab D.
22. On or about April 21, 1999, Appellant/Respondent sent a Final Statement of Account to
Appellee/Complainant deducting $255 prorated rent from the security deposit of
Appellee/Complainant with a balance due of $5. Stt attached at Tab E.
23. Appellee/Complainant believes and therefore avers that the Pennsylvania Landlord and
Tenant Act (68 P.S. § 250.101 et. seq.) provisions for "surrender and acceptance of a leasehold
premises" used throughout the Act governs this case or, in the alternative, Appel lant/Respondent,
themselves, offered Appellee/Complainant the option of staying until April 14, 1999, or
1/Actually, the Appel lant/Respondent's contractors were in the Premises commencing
remodeling prior to the surrender of the Premises as Appellee/Complainant discovered that the
carpets had been ripped up and the windows replaced when she stopped by to check the mail
immediately after dropping off the keys on March 31, 1999.
prorating rent from April 1 through April 14, 1999, via notice of March 11, 1999 (See Tab B)
and the subsequent phone conversation of the parties as set forth in Paragraph 18.
Wherefore, Appellee/Complainant respectfully demandsjudgment in
Appellee/Complainant's favor and against the Appellant/Respondent in an amount not in excess
of $25,000, exclusive of costs and damages for delay, and for such other relief as the court may
deem appropriate. As the amount prayed for here is not in excess of $25,000, the amount
claimed does not exceed the jurisdictional amount for arbitration under the local rules.
Respectfully submitted,
Date: September 22, 1999 Lo-
Christine L. Plunkett
Pro Se Appellee/Complainant
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CONSOLIDATED PROPERTIES
400 NORTH FRONT STREET
WORMLEYSBURG, PA. 17043
PHONE 717-761-3558
November 16, 1998
Dear Resident:
The purpose of this letter is to advise you that on November 16,
1998 your building was conveyed by Polly Myers to Consolidated
Properties. In connection with that conveyance, your Lease
Agreement was assigned by Polly Myers to Consolidated
Properties. In addition, your security deposit was also transferred
by Polly Myers to Consolidated Properties.
Consolidated Properties has been managing properties for over
thirty years in the Harrisburg Area. We do have a full-time
maintenance crew and wonderful and friendly clerical people on
staff.
Enclosed is an information sheet for you to fill out and return to
Consolidated Properties in the enclosed envelope. All maintenance
calls are to be made to Consolidated Properties at 761-3558.
Please call early in the morning and early in the week for service.
Our answering service is available 24 hours a day for Emergency
situations.
Page Two
November 16, 1998
Our intentions are to modernize the buildings with new roofs, new
kitchens, new windows and mechanical and electrical upgrades.
We will keep you posted on how and when work begins on your
particular building, as most work will not begin until Springtime.
PLEASE MAKE YOUR NEXT MONTHLY RENTAL PAYMENT BY
CHECK PAYABLE TO CONSOLIDATED PROPERTIES. Please mail
your payments to 400 North Front Street, Wormleysburg, Pa.
17043.
We look forward to working with you. If you have any questions,
please do not hesitate to contact our office. Thank you.
CONSOLIDATED PROPERTIES
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400 North Front Street
717 7G1-366$
CONSOLIDATED
PROPERTIES
March 11, 1999
Ms. Christine L. Plunkett
6A Pennsylvania Avenue
College Park Apartments
Camp Hill, Pennsylvania 17011
Dear Ms. Plunkett:
This letter will serve as your thirty (30) day notice to vacate the
apartment at 6A Pennsylvania Avenue, Camp Hill, Pa. by April 14,
1999.
Your rent for the final thirty (30) days is to be paid on the first of
the month as usual. Rent from April 1 - April 14, 1999 will be
pro-rated.
Please contact our office two weeks prior to your physical move
date to discuss vacating procedures. Also please provide your
forwarding address in writing to us for the return of your security
deposit.
If you have any questions at this time, please call our office.
Thank you.
Sincerely,
ert Love
Consolidated Properties
HAND DELIVERED AND MAILED
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Sent Via Hand Delivery and
Certified Mail/Return Receipt Requested
April 13, 1999
Michael A. Serluco, Owner
CONSOLIDATED PROPERTIES
400 North Front Street
Wormleysburg, PA 17043
Re: 6A College Park Apartments
Camp Hill, PA 17011
Dear Mr. Serluco:
Please return my $250.00 security deposit to 429 Garden Drive, Mechanicsburg, PA
17055 for the above-referenced apartment which I surrendered to Consolidated Properties and
Consolidated Properties accepted on March 31, 1999, evidenced by contractors (working for and
at the instruction of Consolidated Properties) commencing renovations to said apartment on
March 31, 1999. Also enclosed please find a copy of Bert Love's March 11, 1999,
correspondence wherein I am advised that "rent from April 1 -- April 14, 1999 will be prorated."
Because I surrendered and Consolidated Properties accepted my surrender of said apartment on
March 31, 1999, I believe I owe no prorated rent for April 1 through April 14, 1999, and,
therefore, expect the full return of my $250.00 security deposit.
Thank you for your attention in this regard.
Sincerely,
Christine L. Plunkett
S CONSOLIDATED PROPL•'_17PIES 41b. Service Type E
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CONSOLIDATED PROPERTIES
400 NORTH FRONT STREET
WORMLEYSBURG, PA. 17043
Date: April 21, 1999
To: Christine Plunkett
429 Garden Drive
Mechanicsburg, Pa. 17055
Re: 6 Pennsylvania Avenue, Apt. A
Camp Hill, Pa. 17011
FINAL STATEMENT OF ACCOUNT
Security Deposit 9/98 $250.00
Rent 4/1/99-4/14/99
255.00
Amount Due Consolidated Properties $ 5.00
COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
Christine L. Plunkett,
Appel lee/Complainant,
v.
Michael A. Serluco, trading as
Consolidated Properties,
Appellant/Respondent.
No. 99-5460 Civil Term
I, Christine L. Plunkett, hereby state that I am the Pro Se Appellee/Complainant in
this action and that the statements of fact made in the foregoing Complaint are true and correct to
the best of my personal knowledge. I understand that the statements herein are made subject to
the penalties of 18 Pa. Cons. Stat. § 4904 relating to unswom falsification to authorities.
Date:
Christine L. Plunkett
COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
Christine L. Plunkett,
Appel lee/Complai nant,
v. No. 99-5460 Civil Term
Michael A. Serluco, trading as
Consolidated Properties,
Appellant/Respondent.
I hereby certify that a true and correct copy of the within Complaint has been
a3
served via Certified Mail/Return Receipt Request, on this day of September, 1999, as
follows:
Michael A. Serluco, trading as
Consolidated Properties
400 North Front Street
Wormleysburg, PA 17043
Christine L. Plunkett
Pro Se Appellee/Complainant
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CHRISTINE L. PLUNKETT,
Complainant/Appellee
V.
MICHAEL A. SERLUCO, trading as
Consolidated Properties,
Respondent/Appellant
TO: Mr. Michael A. Serluco
Consolidated Properties
400 North Front Street
Wormleysburg, PA 17043
Ms. Christine L. Plunkett
429 Garden Drive
Mechanicsburg, PA 17055
NOTICE OF HEARING
YOU ARE HEREBY NOTIFIED that the Board of Arbitrators appointed by the Court in
the above captioned action will meet for the purpose of their appointment on Thursday, May 25,
2000, beginning at 9:00 a.m. in the Fifth Floor Hearing Room of the Cumberland County
Courthouse, Carlisle, Pennsylvania, at which time and place you may appear and be heard,
together with your witnesses and counsel, if you so desire.
Should any party or arbitrator desire to reschedule this hearing for any reason, the person
requesting the change shall be responsible for scheduling a new date with all parties, attorneys
and arbitrators.
Daniel W. DeArment, Esquire
Arbitrator
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Jennifer C. Deitchman, Esquire
O Arbitrator
Date: March 20, 2000 By:
Stephen L. Esquire
2100 Longs Gap Road
Carlisle, PA 17013
717-249-7717
Chairman, Board of Arbitrators
cc: Cumberland County Court Administrator
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-5460 CIVIL TERM
C:% AS1ARBM ATIONS1Plunkett.not
Christine L. Plunkett
429 Garden Drive
Mechanicsburg, PA 17055
(717)791.0622
November 5, 1999
Via Fax Transmission and U.S. First Class Mail
Michael A. Serluco
Consolidated Properties
400 North Front Street
Wormleysburg, PA 17043
RE: Plunkett v Serluco t/a Consolidated Properties
PA Court of Common Pleas of Cumberland County
Civil Action No. 99-5460 Civil Term
Mr. Seduce:
By way of a copy of this correspondence to the Office of the Prothonotary, I respectfully
request my right to respond to Defendant's Answer filed October 18, 1999, and/or proceed in this
regard be preserved until such time as I have had to obtain a copy of Defendant's Answer as set
forth below and prepare to respond and/or proceed.
In connection with the above-referenced matter, please allow this correspondence to serve
as confirmation of the telephone conversations I had with your employee, Roberta Love, as
follows:
A. On November 3, 1999, I called your office to request a copy of your Answer to my
Complaint which Answer was filed on October 18, 1999, and of which I was never
served a copy. (I found out that an Answer was filed when I was preparing to Praecipe
for Default Judgment. I contacted the courthouse to see if you had answered my
Complaint and, perhaps, my copy was in transition to me.) I left two messages because
Roberta Love told me that you were out of the office. I asked that you contact me by
telephone leaving first my work number and then calling back to leave my home number;
B. On November 4, 1999, I called your offices and was told by Roberta Love that you were
on another line. I asked to hold and Roberta Love asked who I was and 1 told her my
name. She told me you would not talk to me. I asked Roberta Love if you would send
me a copy of your Answer. Roberta Love told me that she would make a copy of your
Answer and mail it to me. She asked for my address and I gave it to her;
Michael A. Serluco
Consolidated Properties
November 5, 1999
Page 2
C. On November 4, 1999, Roberta Love called me at work and told me that you told her to
tell me to go to the Courthouse and get my own copy of your Answer.
The soonest and least expensive way for me to obtain a copy of your Answer is to go to
the courthouse on the first day of my upcoming vacation, Monday, November 15, 1999, and pay
50¢ a page. This is what I intend to do to obtain a copy of your Answer.
Sincerely,
4. ?
A Z/W
Christine L. Plunkett
cc: Office of the Prothonotary of Cumberland County, PA (via U.S. First Class Mail)
COM OONWEAYTN OF PENNSYLVANIA NOTICE OF APPEAL
COUNT OF COMMON PLEAS
FROM
JUDICIAL DISTRICT
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No, qq- 546o ('LZ,',
O'jeJ•mL
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas on oWeal from the judgment rendered by the District Justice an the
dote and in the case mentioned belay
704
August 9, 1999 I Plunkett, Christine ^ vs Serluco, Michael A.
Cv 190000228-99
IT 19 Michael A. Serluco
1008&
This Notice of Appeal, when received by the District
SUPERSEDEAS to the judgment for possession in this case
Pa. R.CPJP.
Justice, will opemte as a
it 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
or Deputy filing his NOTICE of APPEAL.
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of loan to be used ONLY when appellant was DEFENDANT (see ft. R.C.P.JP. No. 1001(7) in action before Disbict Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPEs To Prothonotary
Enter rub upon
Christine Plunkett
(Canrnon P605 N, `19- 54&Q (%Cy i I MCrA ) within twenty (20) days
RULE: To rhrigtinp p1lmket+ ,oppellee(s).
Nana of appellee(s)
appellee(s), to file a complaint in this upped
of ru su entry of judgment of non pros.
a as attamey or
(1) You One 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 a by certified or registered mail.
(2) 0 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.
,5@pk . 7An vQ
Date. , 19_ ?i Mannc?,ia
Rothor alsy or Deputy
MaPC 312'M COURT FILE TO BE FILED WITH PROTHONOTARY
S `
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE HI_F(/ Wi THIN TFN ( 101 OA YS AFTER Ming the notice of appeal. Check applicable boxes)
COMMONWEALTH OF PENN5YLVAN!A
COUNTY OF.185
AFFIDAVIT: t hvrn•t,? ?;u urs`h ern that f scn cd
L_ i a r. ooy' rrl Tit, Nohce of Appeal, Comrnnn RIraS !JO upon the District Justice destynatert therein on
dan olenu gl ___ , r] by personal service [.1 by (cerhtr:d) Ireglsteredl mail, senders
Lt irtit attached hen;;t. and upor! Ito: it p(alllou inamu!
19__.___ r. by por>nnal s,mce it by Icerhtiedl (registered) mad, sender's receipt attached hereto.
? and bother that l served the Rule to Filea ComplaN ar'wnmany;ny the ahove Note ce of Appeal upon the appellee(s)towhom
the Ruh: was addrossed on by penc lal ser'Vi(e ? by (certdied) (registered)
rna;l. 5..;'.di•r C rgCnl Fr attaJhr ;bar PI
SWORN ;AFFIRIMEUr AfdD SUBSCRIBED BEFORE 11,E
THIS DAY OF
S.y n.' ? ?. .. . .,.?. it
Signature of afhant
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COMMONWEALTH OF PENNSYLVANIA
?rvuiv?T Vr: ••a..•aon4t,eflvL
Map Unl N°
09-1-02
DJ Nwm Hon
ROBERT V. MANLOVE
A°10°a 1901 STATE STREET
CAMP HILL, PA
rdnaWna. (717) 761-0583 17011-0000
MICHAEL A. SERLUCO
400 N FRONT STREET
WORMLEYSBURG, PA 17043
NOTICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF: CIVIL CASE
NAME and ADDRESS
"PLUNKETT, CHRISTINE L 1
429 GARDEN DRIVE
MECHANICSBURG, PA 17055
DEFENDANT: VS. J
NAME and ADDRESS
rSERLUCO, MICHAEL A
400 N FRONT STREET
WORMLEYSBURG, PA 17043
L J
DocketNo.: CV-0000228-99
Date Filed: 7/02/99
THIS IS TO NOTIFY YOU THAT:
Judgment: -FOR P7,anumrnF
® Judgment was entered for: (Name) _PTj1NxRmm rtmremTW . T.
® Judgment was entered against: (Name) mr.nen, MTr.HARr A
in the amount of $ 9;41 nn on: (Date of Judgment) - A/QQ/9Q
Defendants are jointly and severally liable.
Damages will be assessed on:
This case dismissed without prejudice.
Amount of Judgment Subject to
Attachment/Act 5 of 1996 $
11 Levy is stayed for days or ? generally stayed.
D Objection to levy has been filed and hearing will be held:
(Date & Time)
Amount of Judgment
Judgment Costs
Interest on Judgment
Attorney Fees
Total
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
Date: Place:
Time:
ANY PARTY HAS THE RIGHT TO
OF APPEAL WITH THE PROTHOI
MUST INCLUDE A COPY OF_THL
Date
, District Justice
I cert'fyf ttha/tttthis is a true an Zecof d, e0orof the proceedings containing the judgment.
7 r? Date ?/f? ? - G District
7 i Justice
c
My commission expires first Monday of January, 2000 SEAL
AOPC 315.99
DRYS AFTER THE RY OF JUDGMENT BY FILING A NOTICE
THEi F C MMON PLEAS, CIVIL DIVISION. YOU
CRIPT FORM WITH YOUR NOTICE OF APPEAL.
r-a
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
N6tice 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
data and in the case mentioned below
f
Michael A. Serluco/Consolicirrted Prcilerti? 10'I-1-02 F.chl_c.[ V. Man Love
00 North Front Strcct
I' A
17043
JUDICIAL DISTRICT
.. I COMMON PLEASNa t0- 5 4oc) Ct Term
NOTICE OF APPEAL
taorml?? c;bur
August 9, 1999 Piunkett, Chr ist:.:r,.- lcc<,, r;l -hdeI A.
K
CY
600U22t;_ oy
?Ni 11'101_ P.. Sur11:Cr,
-, - ?- -- ---, sin ,wsmrnxr a regmma under ra. rt.a.r.?.r. r q It appellant Was GLAIMAN7 (see Pa. R.C.P.J.P. No.
1008&
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 for possession in this case FILE A COMPLAINT within twenty (20) days alter
signature of Prothonotary a Deputy tiling 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.
I NOT USED, detach from copy of notice of appeal to be served upon appellee).
i
PRAECIPE: To Prothoratary
('i)TlsLu1e ?L)rkett
Enter rule upon , Nsma of aFwtensJ appellee(s), to file a complaint in this appeal
Tel (Comoan Pleas No. 915 L? 1 I12 (? L?l V I Ir, ) within twenty (20) days after sere of rule of suffer entry of judgment of non pros.
l S•D'atae or eRaeaant or in aUaney or agent
RULE: To Christine i'h:r,kolt appall".
Nara of appeea0s)
(1) You ore ratified that a rule is hereby entered upon you to file a complaint in this appeal wilt; s 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 ENTERr:D AGAINST YOU.
(3 The dale of service of this rule if service was by mail is the date of mailing
lp,c
Date:1 St L1' 19?
Sprsrue of flotrrMOWY a Deputy
AaPC 312.54 COURT FILE
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(Thla proof of sorvn:u mos I i3f t ILF b WI (If IN It N , h'r 1)41'; Ai IFH i'd,r n, notice oI appeal. Ch,(k app GCable boxed
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF..-Cumberland
AFFIDAVIT: I hereby weal or alhm, p:al I -;n eU
?J it ,:opy of the NobCC of Apiwal. C-.immnn Pi o.u Plu 99-,5460-Civil u
IZ6l7M Ch strict Jushra designated therein on
da[n of :;nrv,cnl _ __ kC by personal service ? by (feliiilad) (reylSlafZd) mail, sender's
rnrmpt afClrhert h9retn. and upon e app!:i4:c n,:unol - __ Chris tine
_...PLL1II$e_t _
- on
-..__-._9-10=99 . 12__ ? by Fer;;nmd servic, f by (certified) (regislered) mail, senders receipt attached hereto.
D and further that lsnrved the Rule to File a Con:Fdnnit.1, umpany:ng the above of Appeal upon the appellee(s)to whom
the -I uie wits addnassed on _
--9--1.0-------- ------- - %g9-.. y per na1 servic e by (Certdied) (registered)
(nail. Snit Cn,'d r,- eipt atleCherl norn:o
SWORN IAFFIRMEDI ANO SUBSCRIBLU BEFUHt. ME.
THIS DAY' oFSeptember_ . 1199_.
i
My C'
ssiai ??? County
9bei' ? Public
F-+tWres July 71, 2000
, Pennsylwnla Associaban of Not fW
Signature of afflant
C) l0
O
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Z 353 367 675
Us Postal service
Receipt for Certified Mail
No Insurance Coverage Provided.
ry,
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Postage JI
Special Delnery Fee
Restdded Deevery F.
m fletum?edtipl Slawipt
Wlvfi A Data?d1.9ref
;OTALP 3r'iNbs? S f
Posenad or Date
LL
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Y
CHRISTINE L. PLUNKETT.
ComplainanUAppellee
V.
MICHAEL A. SERL000, trading as
Consolidated Properties,
Respondent/Appel lant
IN THE COURTOF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-5460 CIVIL TERM J
OATH
We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the
United States and the Constitution of this Commonwealth and thaa? ??11 dirrharge the duties of our
office with fidelity. L?-?
Esquire
AWARD
We, the undersigned Arbitrators, having been duly appointed and sworn (or affirmed), make the
following award: (Note: If damages for delay are awarded, they shall be separately stated.)
Anne1 ??e M ?A,! 1 n C -
Date of Hearing: 54-2-<1-00
DateofAward: S ?S Uo
NOTICE OF F.NTRY OF AWARD
NOW, thea?ay of MZ. , 2000, at ?/? ,m., the above award
was entered upon the docket and notice Zercof given by mail to the parties or their attorneys.
Arbitrators' compensation to be
paid upon appeal: Protl ary
eputy
Arbitrator, dissents. (Insert name if applicable).
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