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C&AMONWEALTN Of PENNSYLVANIA
COURT Of COMMON PLEAS
JUDICIAL DISTRICT
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No O Q
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 on the
date and in the case mentioned below.
Mobile Estates Shippensburg PA 17257
9-14-99 Shippensburg Mobile Estates In% Janice A. Junking
SIGNATME of MPELL MATT Y A NT
Cv12 hi ip C. B iganti Legal Services Inc
LT 1999 T.T-19S_gq l 8 Irvine Row
Carlisle PA 17013
This block will be signed ONLY when this notation is required under Po. R.CPJ . No t appellant was CLAIMANT (see ft. R.C.P.J.P. NO.
10088.
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 j* t for possesst'1C n this'case
/.11 / FILE A COMPLAINT within twenty (20) days after
a
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
Enrerruleupon Shiooensbura Mobile Estates Inc a ellees, to file a com
pp () plaint in this appeal
Nana OI agpe7keys)
]] /7
(Cornmon Pleas No. ((Y 7 ' J Y?(] l,! I M ) within twenty (20) days after servi f rule or suffer ent f judgment of non pnx
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9'gvmYa 11* f a lug afrallBy or eQeA
RULE: To Shi E2nenchurg Mnhi le Estates Inc , appellee(s).
Nave or appeAws)
(1) You am 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
Date: , 19?g ??."ter 4. C of w&?
t' SiDnRune AOPC312.U COURT FILE TO BE FILED WITH PROTHONOTARY
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00,21.00 10:.15 FAS 717 532 3305
Pa 00-3-01 Id10U1
COMMONWEALTH'OF PENNSYLVANIA
COUNTY OF:_ CUMBERLAND
09-3-01
DJN'r : No.,
DAVID P. PERICINS,
A*mg,: 61 WET, BOTTOM
P-O- BOA 361
SHIPPENSBURG, PA
Telepnon,! (717) 532.7676
ESQ.
ROAD
17257-0361
DAVID P- PBRKINS, ESQ.
81 WALNUT BOTTOM ROAD
P-O• BOX 361
SHIPPENSBURG, PA 17257-0361
NOTICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF. RESIDENTIAL LEASE
rSHIPPENSBURG MOBILE ESTATES 7
10 N. CONESTOGA DRIVE
SHIPPENSBURG, PA 17257
L
DEFENDANT: VS.
AAME eid ADD 9E33
rJUN1CENS, TJ=CE A -)
230 SKE
SHIPPENSBURG, PA 17257
L J
DocketNo.: LT-0000125-99
Date Filed: 8/25/99 Aft
THIS IS;TO NOTIFY V, U THAT:
_ Judgment: FOR
PL&IMLlyy
® Judgment was entered for: (Name) SHIPPENSBURG MOBILSESTATE9
Judgment was entered against JUNKTNS JANICE A
® Landlord/Tenant action In the amount UT $ 75.10 in a
The amount of rent per month, as established by the a District Justices $/99 (doe of Judgment)
The total amount of the Security Deposit is $ OO
Total Amount Established by DJ Less Security Deposit Applied
Fient in Arrears S .00-$ .00 =
Physical Damages Leasehold Property S 00 - $ . 00 =
Damages/Unjust Detention $ -00-s 00 =
? Attachment Prohibited/ Less Amt Due Defendant from Cross Complaint -
Victim of Abuse (Act 5, 1996) Interest (if provided by lease)
E] This case dismissed without Prejudice. LIT Judgment Amount
L Judgment Costs
® Possession granted, Attorney Fees
Total Judgment
? 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:
? Defendants are jointly and severally liable.
^•• • ?..^, Ana I Hr MIGHT 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
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 ARREXRS 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 PROTHONOTARY/CLERK OF COURTS OF
THE COURT OF COMMON PLEAS CIVIL DIVISION.
YOlI MUST INCLUDE A COP7(OF
/. /"` THIS NOTICE OF JUDGMENTn'RGNSCRIPT FORM WrTH YOUR NOTICE OF APPEAL. .
District Justice
Adjudicated Amount
$ on
$ .00
$ n0
$ -00
$ nn
$ _ _no
$__?5; - 1 n
$ _n0
$ 75.10
Shippensburg Mobile Estates
Plaintiff
V.
Janice Junkins,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- SQICIVIL TERM
AFFIDAVIT
1. I, Janice Junkins, am the defendant in the above-captioned action, which is an appeal from a
judgment rendered by District Justice David Perkins on September 14, 1999, awarding Plaintiff possession of
the lot on which my mobile home resides.
2. The rent for the lot, located at 230 Shippensburg Mobile Estates, Cumberland County,
Pennsylvania, is $190.00 per month, and becomes due on the 1st day of each month.
3. My rent for September 1999 has been paid, and in y next rent payment will be due on or before
the I" day of October, 1999.
4. I verify that the statements made in this Affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unworn falsification to
authorities.
Date- '?i`?
Janice Junkins,'ijefendant
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Shippensburg Mobile Estates IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 99- q
J` I(C)IVIL TERM
Janice Junkins,
Defendant
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Janice Junkins, Defendant, to proceed in forma au eris.
I, Philip C. Briganti, attorney for the party proceeding in forma au eris, certify that I believe the
parry 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.
flip Brigan
Attorney for Defendant
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
Shippensburg Mobile Estates
Plaintiff
V.
Janice Junkins,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: 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. I 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: Janice Junkins
Address: 230 Shi ensbur Mobile Estates
Shippensbure. PA 17257
(b) Social Security Number: 075-48-7051
If you are presently employed, state
Employer: Shippensburg School District (client started job
Address: North Morris Street On 9/99 - substitute
Shippensburg PA 17257 Has worked only 4 days)
Salary or wages per month: $40.84 (so far this month)
Type of work: Substitute Classroom Aide
If you are presently unemployed, state
Date of last employment:
Salary or wages per month:
Type of work:
(c) Other income within the past twelve months
Business or profession: N/A
Other self-employment:
Interest: N/A
Dividends: N/A
Pension and annuities: N/A
Social Security benefits:
Support payments: $740.00/month
Disability payments: $473.00/month (SSI for son)
Unemployment compensation and
supplemental benefits: N/A
Workman's compensation: N/A
Public Assistance: Medical card
Other:
(d) Other contributions to household support
(Wife)(Husband) Name: N/A
If your (husband) (wife) is employed, state
Employer:
Salary or wages per month:
Type of work:
Contributions from children:
(e) Property owned
Cash: $30.00
Checking Account: $2.00
Savings Account: N/A
Certificates of Deposit: N/A
Real Estate (including home): _ 1990 Amhutst Mobile Home Value $19,000 (est
Motor vehicle: Make Oldsmobile Year 1979
Cost $1 Amount owed_$Q__
Stocks; bonds: _
Other:
(f) Debts and obligations
Mortgage:
Rent: $190.00/month (lot rent)
Loans:
Monthly Expenses: Groceries $500• Electric $150.00, Telephone $60.00: TV cable $40.00:
Clothing $50.00; Miscellaneous Household Exnenses $200.00* Taxes $40.00: Gas $40.00
(g) Persons dependent upon you for support
(Wife) (Husband) Name:
Children, if any:
Name: Robert Lute
Jamie Bogue
James Junkins. Jr.
Jordan Junkins
Age: 17 years
13 years
8 years
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. I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unworn falsification to
authorities.
Dated ?) I -r't1-l '01111
t_U r, i?'t. ri
Janice Junkins, DO endant
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COMMONWEALTH OF PINNSTLVANIA
COUNT OF COMMON PLEAS
JUDICIAL DISTRICT
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS Nn (? O - t-;)11"1 I
NOTICE OF APPEAL
i
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
dais and in the case mentioned below.
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o-rvic?s Inc
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Thu bock will be s grad
10088. ONLY when this notation is required under Pa RCP) . No / appellant was CLAIMANT (see Pa. R.C.P.J.P. N0.
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 j t for possessi in this case FILE A COMPLAINT within twenty (20) days after
filing his NOTICE of APPEAL.
E 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.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 Prathoratory
Enter rule upon -d!ti;?.; ,appellee(s), to file a complaint in this appeal
Name of a/,pErkE{ithin s)
(Common Pleas Na J`/(} _1 ' J P1 o ?! c i 7.: n ) w twenty (20) days after service of rule or suffer entry of judgment of ran pnx
' r
J% $19'ature eppeYa'iI a he aeamey or agent
RULE: To ????l appolee(sJ.
- ? :Aroma or ;ile i amt •- inc "nc or aspalge(sl
(1) Yai 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
is of; lhiriule upon you by periopal ;ervke or by certified or registered mail
$ (2) If you do7sot file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU.
(S)-The dab of service of this iule if service was by mail is the date of mailing
4s WDo*
-
312.81
COURT FILE
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of serwce h1(ISf HE 6ILFD WI FFIIN TFN ( lUI UA yS Af TER Whop Iha nobco of appeal. Check applicable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY oF_Cnmberland----- : es
AFFIDAVIT: I hereby swear orafflrrn that I serval
C cd Teri
?{ • 'I PY of the Nmice n' Anneal. Cornmrn F Iea3 No 99-5810 Civil
.. _ _ ... _ rnpun o• pwtrict Jushce designated therein on
(date of sorvice) SflRt_ember-21,1999_ _ __. . C', by personal spruce I by (certifled) (k*J1gk%l) mall, sender's
receipt attached hi and upon the Iupellee rnamol Shippensburg_Mobile-Estates, Inc , on
September_21L . 19 9__ ? by pomonal service [? by (cerhhed) kcX-?) mail, sender's receipt attached hereto.
and further that 1 served the Hulo to F,le a Cnin(4a urt vc com parr,:n9 lhr• above Noticeof Appeal upon the appeilee(s) to whom
the Huse was adorossea or Sepember --$-1--_.. 199- by p,!,Sunal service 7X by (certdied) rk ")
mail, sender's receirt attached hereto
SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS DAY OF ._.____
Signature of afhant
h to ul ou,: ral
My cnmmr?son nxpiq. _,
I verify that the statements made in this affidavit are true and correct.
I understand that false statements heritin are made subject to the
penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification
to authorities.
Date:
/-?r/5
Phili C. Brigg nti
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Us Postal Service
Receipt for Certified Mail
No Insurance Coverage Provided.
Do not use for International Mail See reverse
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SHIPPENSBURG MOBILE ESTATES,
Plaintiff
VS.
JANICE A. JUNKINS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5810 CIVIL TERM
CIVIL ACTION - LAW
PRAECIPE TO DISCONTINUE CASE
To the Prothonotary:
Please mark the above-captioned case as settled and discontinued, without prejudice.
Kindly forward all rent money held in escrow to Shippensburg Mobile Estates, 10 N. Conestoga
Drive, Shippensburg, PA 17257.
Date:
r
J rry A. Weigle, Esquire I
Counsel r Plaintiff
MARK, WEIGLE AND P RKINS
126 East King Street
Shippensburg,PA 17257
(717) 532-7388
Date: /C ?ZC ,L `'> lJC?s
Philip C. B lganti, Esqui
Counsel for Defendant
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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