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Home My WebLink About99-060640 Cl v 0 h l \ ?O h ? li F Lv l- T Q. CONIMONWEALTH OF PENNSYLV AN IA NOTICE OF APPEAL COURT OF COMMON PLEAS FROM JUDICIAL DISTR ICT DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. ?nO/ i/ A? D NOTICE OF APPEAL lOY C s? 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 date and in the case mentioned below. LISA FE T" 5169 E. Trindle Road, Lot 11 Mechanicsburg 09-3-09 PA 17055 9/2/99 KINGSBURy ASSOCIATES mss/ LISA,17PAViA Cy 19 99 0000293 LT 19 This block will be signed ONLY when this notation is required under Pa. R.C.P.J.P. No. 10088. This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgment for possession in this case. Srynature of Prpnrnnolary or onpufy 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) clays after filing his NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of torn to be used ONL Y when appellant was DEFENDANT (soe Pa. R.C.P.JP. No. 100177) 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 KINGSBURY ASSOCIATES N me olappe/le , appellee(s), to file a complaint in this appeal q etsl (Common Pleas No. 99???o 2f ) with in twenty 1201 days after sec a rule or su r o I gment of non pros. RULE: T? KINGSBMY ASSOCIATES Signatweofap lantorhisartornevoragem Nacre of appelleets) appelloe(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (201 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 WI LL BE ENTERED AGAINST YOU. (3) The slate of service of this mule if service was by mail is the date of mailing. Date: -e 24,-Z. 197Y '7C"(7!r/a!!s. /c. ,/'l?J O Signatureof or notary or Deputy AOPC 312.90 000F3T FILE TO BE FILED WITH PROTHONOTARY IL. .. t 1 -? i C. " C (?i frl -1 h; ?v y r M G M --GI 1ue/qc 1o a?muuE?g Sa U(lxa uOISSlwwoa AW 1113410 1O J/11J, ..pew sen?lmupyp•wey.•n aiol,vl lmvpn/n:unlnUbig AVO SIHI w 9L10d3f1 cismoSSOS ONV (03WkilddV) NHOMS 7 -OPOLl pa41ulie. 1dla3e1 S,lapuas'pew (pasn s,lial) (pag4ro) Aq 1..1 aMAN6 pPunsied A[I I .- - -_. - ..uu rsa.n re suns aIn I I lit I 1 1 H ayl uenlnn 01 (spalladde 141 uodn IrnddV lo n:nioN anoge aq1 limAundmu:rn, pi?rl[LuuD c 111 1 nl alnll 041 panms I teal Jaqun) pue li _.? 'olaJay 1114]1110 Idloan? s,inpu x'pnui (paialuli.n) IP"?I?I ia?; hq j s.[.a luurn i.nl M1q"-- 6l ' ---..- L_ . uU ---._.. ?___- - - -(o.ncul ': i,glatl?e'.?yl anon pue 'ul.uay p.npclle Id iaaal S, iapuns'pem (palals,fiai) (P ?9n e?nl Ay ?_ anir,ias puns mrl d..l -(o;unies 10 a1ep) uo uuu:nll paleuGisap ,nlsnl' i mot.,n .ql undo .,,d uuu1IM") 11'add V Y' ?? 11WN `10 IU Adua e p,mu 1 P'll wi,,I(. m a"'AUAgnm4l :llAVa133V AD ALNOOJ VINVAIASNN3.1 40 H1lV3MNOWW00 (saxoq algeogdde Hoagp leodde 10 aopou 2q1 liug77LILJ:? S'A.'O (01) N11 NIHLIM U3-711 39 jgnW OO?AJaS 10 Zooid slgl) 1NIVIMOO 3113 01 311111 ONV 1V3ddV d0 3011ON dO 301AM3S 40 3008d `0/09 '99 10:24 FAX 717 737 6779 DJ Placey ®001 COMMONWEALTH COUNTY OF: LTM DJ NNnv' M. THOMAS Aam.M.104 S. T.wnemc (717 ) THOMAS A. 104 S. 8P F PENNSYLVANIA NOTICE OF JUDGMENT/TRANSCRIPT IRLAND CIVIL CASE - 3 - 04 PLAINTIFF: NAME W ADDRESS rRID1t4HBURY ASSOCIATES 258 W. BALTIMORN ST PLACEY CARLISLE, PA 17013 PORTING HILL RD. L J SB17R13, PA VS. DEFENDANT: NAME am ADDRESS 1-8230 17055 rPETROW, LISA 5169 H. TRINDLE RD. LOT 11 LIMCHANICSBDRG, PA 17055 J CRY NO HILL RD. DocketNo.: CV-0000293-99 PA 17055 Date Filed: 7/29/99 Aft m t< THIS IS TO NOTI YOU THAT: Judgment: nevAailP JunatUrr Pt'P ® Judgment was entered for: (Name) MOSE^°° ASECRUATES ® Judgment was entered against: (Name) P11mr1D9r 1 TSA in the amount I $ 1 , t as v; n on: (Date of Judgment) o/n219o Defendants a Damages Will This case dis Amount of Ju AftachmenVA Levy is staye Objection to I Date: Time: ANY PARTY HAS THI OF APPEAL WITH TP MUST INCLUDE A CC 1 ) i ; D I certify that this is i 1 , 0 jointly and severally liable. assessed on: without prejudice. ment Subject to 5 of 1996 $_. for days or 7 generally stayed. has been filed and hearing will be held: (Date & Time) Amount of Judgment Judgment Costs interest on Judgment Attorney Fees Total my commission ex AOPC 315.99 Place: Post Judgment Credits Post Judgment Costs ass =>ozs Judgment Total $ RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE i PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS; 4iVI? BIV? ION. YOU _9?PEAL DY OF THIS NOTICE OF JUDGMENT/TRANSCRIPTFORM WITH 1(j9??1H,?JQ17Nkq? to _ _, Distrir$ luatlce true and correct'copy of the record of the proceedings eoleining the judgmeh(; ; to t .., DISIrfCl,JuetICS ires first Monday of January,' 2004 SEAL RECEIVED TIMESEP,30. 3:30PM COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS JUDICIAL DISTRICT DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. 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. LISA FEI'ROi4 5169 V. Trincile Road, Tot 17 ',echanic3bury PA 17055 .e.. O.2..... ,, ...........,.. 11-1111-11 9/2/99 PINGSPURY ASSOCIATFS -- CV 19 99 0000293 I // _ (- LT 19 Andre This block will be signed ONLY when this notation is required under Pa. R.C.P.J.P. No. 10088. This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgment for possession in this case. Signature or Prothonotary or Deputy 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 (201 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 Pa. R.C.P.J.P. No. 1001171 in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee). PRAECIPE: To Prothonotary :QTIGSWRY INSSOCIA'1'15 Enter rule upon , appellee(s), to file a complaint in this appeal Of appellee (S) (Common Pleas No. 99-tov?? `-`-' 1 within twenty (20) days after se ce rule ors f _ Ir ' ?ment of non pros. IOIJCSBURY ASSOCIATES Signature of ap ellanr or his attorney or agent RULE: To appelee(s) Andrew J. Ostrafski Name of appelleefs) (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 WI LL RE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of mailing. .? Date: ?!?.?i Signature of ronotary or Deputy NOTICE OF APPEAL FROM AOPC 31290 COURT PILL PROOI OF SLij j(:1 OF ,,r) 11C1: IJP :,!Tf,L f..._. ;L'!_C. rO FILE ^Oh1PLMNI COMMONV, E. A L Fi: OF PENNSY WAN It, COUNTY OF Cumberland AFFIUAVI ( X 99 6064 on October 5 99 Kingsbury Associates October 5 99 X a„«m. X % „ October 5, 99 X v - r?mn,i1 •,all "-who •s n.eelpr atT„•i :?i l,eicP, SWORN (A( rLt ICU) AiJo S J F" /('f'.1.1 I),'.I I'; L.f J i THIS__. h:.Y or _/CG 1kJi?• 62 $,9n?bue ,r dlr,. ,, b.•ba.. arz r.. ., ll, ,,.,+ l .,.., .... 7,fle or oth. My cone nls,..,.. yr.,, b; is nl n/flanr Notarial Seal Heather A. Stoner, Nolary Public Susquehanna Twp.. Dauphin County My Comrnission F:mtres Jan. 24, 2002 o- SENDER: O -0-1100141 Mania l and/or 2 fix additional wrNne. it aCompleta Berns 3,4&. and 4b. -Nix yow rams, arid address on Ow reverse or alb form w that wa can naw W. card onn to the front of the mdlpiam, or m It* back if space don not •WHO. Maoh Me e Rdc@W Roqu-aled'cn the nunpiecs below er arede numWr. § •TM Raton Receipt wsn slim to-Horn the adids was deuwmed and Medals dellvared. p 3. Article Addressed to: 0 n Hon. Thomas A. Placey District Judge 104 Sporting Hill Road Mechanicsburg, PA 17055 5. Received By. (Print Nance) c B. Sigrla - (Ad a or Agent) 0 X e PS Form 3811, December 1994 ( I also wish to receive the following services (for an extra fee): 1. ? Addressee's Address 2. ? Restdded Dellvery Consult postmaster for fee. ? Registered Certified ? Express Mail Insured ? Return Receipt for Menilandse ? COD and lee is paid) 102595 97 8 0179 NOW&RIM $ SENDER: v -Compels Hems 1 -CM 01114 a2 car aeditialal wMCea. I also wish to receive the • gele name 3, 4a, and 4b. 1,. o - Podyour nacre and etldreafan Me revere- of Ibis mart w Ihet we wn velum Ws following services (for an { Mh Wd to you. extra fee): ?' •?•+m•n ? ppbmme??yY We loan to the front of the mailpiou, or on Iho back if spew does not 1 ? Pi ar •Wma'Ralum Receipt Sh"t 1horhen The Ralum Receipt Mn rs show to o whom 01e ? delivered. 0 3. Article Addreseetl to: m n o Kingsbury Associates c 58 W Baltimore Street lisle, PA 17013 5. Racelved By: (Print Name) 6 Heg9A dre ee orAp ent)„ VW?(Ua , ecember 1994 Addressees Address Z einesae 2• ? RestddedDelivery J) Consult postmaster for fee. ?• 4a. Article Number Z 015 175 357 c E 4b. Service Type ? Registered '-CeRifled ¢` ? Express Mao ? Insured c ? Return Receipt for Merdmandss ? COD 20 7. Date of Delivery 9.Addressee 's Address (Only 1l requested T ? and lee is paid) 102595 97 0 0179 - -1,.M1 F .? ?= ?; ?? - '.' '„ ,. - - __ ? :; KINGSBURY ASSOCIATES, Plaintiff V. LISA FETROW, Defendant : IN THE COURTS OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99 - 6064 CIVIL TERM N 0 T I C E 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 against be en you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 ? ^ BY CI Andrew C. Sheely, E quire PA. I.D. No. 62469 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff KINGSBURY ASSOCIATES, : IN THE COURTS OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. : 99 - 6604 CIVIL TERM LISA FETROW, Defendant COMPLAINT Plaintiff, Kingsbury Associates, by and through counsel of Andrew C. Sheely, Esquire, hereby files this Complaint and respectfully avers as follows: 1. Plaintiff is Kingsbury Associates, a Pennsylvania general partnership, with its principal place of business located at 2920 Dickinson Avenue, Camp Hill, Pennsylvania 17011. 2. Defendant, Lisa Fetrow, is an adult individual, residing at Lot No. 11, Kingsbury Mobile Home Park, 5169 East Trindle Road, Mechanicsburg, Pennsylvania 17055. 3. Plaintiff, Kingsbury Associates, is the record legal owner of certain real estate being improved with a mobile home park, being known as Kingsbury Mobile Home Park, same being situate in Hampden Township, Cumberland County, Pennsylvania, having been acquired by Deed dated August 10, 1992 and recorded September 11, 1992 in the Cumberland County Recorder of Deeds office in Deed Book "W", Volume 35, Page 610, being bounded and described as follows: ALL THAT CERTAIN TRACT of ground situate in Hampden Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey dated August 17, 1992, Survey Book No. 1007, of Hartman and Associates, Inc., as follows: BEGINNING at a point in the center line of the Trindle Road, at the line of land now or late of Marlin Bretz, said point being located 200 feet more or less North East of the center line of Sheely Lane; thence from said Point of Beginning, by land now or late of Marlin Bretz, land now or late of William D. Hornberger, land now or late of Wilson A. Ebert, and land now or late of Monroe J. McCauslin, Sr. North 44 degrees 54 minutes 00 seconds West a distance of 455.00 feet to a point on the line of land now or late of the United States of America (Ships Parts Control Center) ; thence by the line of land now or late of United States of America North 63 degrees 55 minutes 00 seconds East a distance of 354.68 feet to a point; thence by land now or late of William C. Hall South 38 degrees 36 minutes 00 seconds East a distance of 238.90 feet to a point at or near a fence post; thence by land now or late of William C. Hall South 44 degrees 06 minutes 00 seconds East a distance of 207.64 feet to a point in the center line of the Trindle Road; thence by the center line of the TRindle Road South 63 degrees 55 minutes 00 seconds West a distance of 323.92 feet to a point, the Place of BEGINNING. SAID TRACT contains 143,752.68 square feet or 3.30 acres. SAID PREMISES having thereon erected a two (2) story frame dwelling and garage and being known and numbered as 5169 Trindle Road, Mechanicsburg, Pennsylvania, and a thirty-two (32) pad mobile home park. 4. Plaintiff, Kingsbury Associates, acquired an immediate right to possession of the premises by virtue of the August 10, 1992 deed as referred to in Paragraph No. 3 hereinabove, said being recorded in the Cumberland County Recorder of Deeds office in Deed Book "W", Volume 35, Page 609. 2 5. Defendant, Lisa Fetrow, currently resides in a mobile home located on Lot No. 11 of the Kingsbury Mobile Home Park, said lot being situated on Plaintiff's real property as described above. 6. Defendant, Lisa Fetrow, is currently the equitable and/or legal owner of the mobile home located on Lot No. 11 of the Kingsbury Mobile Home Park, said lot being situated on Plaintiff's real property as described above. COUNT I. CONVERSION 7. Paragraphs 1 - 6 are hereby incorporated by reference. 8. Defendant Lisa Fetrow moved into the Kingsbury Mobile Home Park without applying for permission to live in the mobile home park on or about April 1, 1999. 9. Defendant Lisa Fetrow never signed any written lease agreement or park rules and regulations before moving to Lot 11 of the Kingsbury Mobile Home Park. 10. Defendant Lisa Fetrow has exercised and continues to exercise exclusive possession and control over that portion of Plaintiff's property described as Lot No. 11 in the Kingsbury Mobile Home Park without a lease or other legal right. 11. Efforts by Plaintiff, Kingsbury Associates, directing Defendant, Lisa Fetrow, to remove the mobile home and herself from Plaintiff's property have been without success. 3 12. Plaintiff is entitled to immediate and exclusive possession of lands which Defendant currently occupies. 13. Defendant Fetrow has deprived Plaintiff of its right to use and possess lot No. 11 in the Kingsbury Mobile Home Park. 14. Plaintiff has not consented to Defendant Fetrow's use and possession of lot No. 11 in the Kingsbury Mobile Home Park. 15. Defendant Fetrow has no lawful justification to occupy lot No. 11 in the Kingsbury Mobile Home Park. 16. Lot rent for Lot 11 in the Kingsbury Mobile Home Park is $270.00 per month. WHEREFORE, Plaintiff, Kingsbury Associates, respectfully requests that this Honorable Court enter judgement in favor of Plaintiff and against Defendant in an amount of $1,890.00, plus additional lot rent in the amount of $270.00 per month through the date of the judgement, plus costs, an amount requiring compulsory arbitration. Respectfully sq?y itt , Date: October V, 1999 BY Aie(V /? ` Andrew C. sheely, quire PA. I.D. No. 62469 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff 4 VERI_FICATION i verify that the statements made in this Complaint are true and correct. i understand that unsworn statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. DATE: October 1999 Ro ert E. General Partner and Agent for Kingsbury Associates CERTIFICATE OF SERVICE I, Andrew C. Sheely, Esquire, hereby certify that I am this day serving the foregoing Complaint upon the following named individual this day by depositing same in the United States Mail, First Class, postage prepaid, at Mechanicsburg, Pennsylvania, addressed as follows: Andrew J. Ostrowski, Esquire Seratelli, Schiffman, Brown & Calhoon, P.C. 2080 Linglestown Road Harrisburg, PA 17110-9670 Date: October.2A , 1999 j4A Andrew C. Sheely, Esqu e C CV ? WC7 N =f `) ?L ?.i ui... cal A:LU r o C U ui L) O