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Home My WebLink About03-3440COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS JUDICIAL DISTRICT NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No, 0,~' NOTICE OF APPEAL Notice is given that the e, ppellant has filed in the above Court of Common Pleas an appeal trom the judgment rendered by the District Justice on the date and in the case mentioned below. I ADDRESS OF ~PE~T CITY This block will be signed ONLY when this notation is required under PA. if Claimant (see PA R.C.P.J.P, R.C,P.J.P, No. I008B. \ This notice ot Appeal, when received by the District Justice, will operate as \ No. 1001(6)) in action before district Justice, he ~ MUST FILE A COMPLAINT within twenty (20~ A SUPERSEDEAS to the Judgment for possession in this case.~ 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. t00t(T) in action before District Justice, IF NOT USED, detach from copy of notice of appeal ~o be served upon appellee. PRAEClPE: To Prothonotary Enter rule upon ~ ~'0 ~ '~ d~.~.J.~g,,~,.~ , appellee(s), to file a complaint in this apl: (Common Pleas No. ~ .~- ~ ? Y'O _) within twenty (20) days after service of rule or...su,,fter entry of judgment of non pt RULE: To ~o"~,~ ~/~__./~/.~¢~l/~/ ,appellee(s) (1)You are notified that a rule is hereby entered upon you to tile a complaint in this appeal within twenty(20) da alter the date of service of this rule upon you by personal service or by certified or registered mail. (2) I! you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINS UPON PRAEOIPE, Date: (3} The date of service of this rule if service was by mail i~ the date of the mailing, White - Prothonotary Copy Green - Cou~ File Copy Yellow - Appelant's Copy Pink Appellee Copy Gold - D.J. Copy PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proot of service .MUST BE FILED WITHIN TEN (10) DAYS AFTER fi~ing the notice ol appeal Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ..... ss AFFIDAVIT: I hereby swear or affirm that l served [~a copy o~ the Notice of Appeal, Common Pleas No. ___, upon the District Justice designated therein on ~'date of service) ............ year ......... [] by personal service [] by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name ..................................... on ___, year ....... [] by personaJ service [] by (certified} (registered) mail, seeder'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 .................. year [] by personal service ~ by (certifiedJ (registered) rnai~, sender's receipt attached hereto. ¥ORN (AFFIRMED) AND SUBSCRIBED BEFORE ME iS DAY OF YEAR .... , umissiofl expires on ., year ...... . COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CDMBERLAND Mag Dist No.: 09~3-03 DJ Name: Hon SUSAN K. DAY ^d~s: 229 MILL STREET, BOX 167 MT. HOLLY SPRINGS, PA (717) 486-7672 17065 DANNY KEISER 352 N. MIDDLESEX CARLISLE, PA 17013 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS FMOP, RISON, LEON ~ P.O. BOX 745 CARLISLE, PA 17013 VS. DEFENDANT: NAME and ADDRESS FKEISER, DANNY ~ 352 N. MIDDLESEX RD. CARLISLE, PA 17013 L ~ Docket No.: CV- 0000142 - 03 Date Filed: 5/21/03 THIS IS TO NOTIFY YOU THAT: Judgment: [] Judgment was entered for: (Name) E~ Judgment was entered against: (Name) FOR PT.AIMTIFF MORRTRON, T,~ON KRI~RR, DANNY in the amount of $ 4,11~. [1~ on: [~ Defendants are jointly and severally liable. ] Damages will be assessed on: E~ This case dismissed without prejudice. E~ Amount of Judgment Subject to AttachmentJ42 Pa.C.S. § 8127 $ E~ Portion of Judgment for physical damages arising out of residential lease $ (Date of Judgment) (Date & Time) Amount of Judgment $ 4,600.00 Judgment Costs $ 115.00 Interest on Judgment $ o 00 Attorney Fees $ .00 Total $ 4,715.00 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. I certify that this is a true !~'nd correct copy of the recolld of th~ proceedings containing the judgment. Date , District Justice My commission expires first Monday of January, 2004 . AOPC315-03 DATE PRINTED: 7/15/03 2:35:21 PM SEAL ~,- 3' 0 Certified Fee Return Reclept Fee (Endo~ement ReQuired) Restricted e$1ive~' Fee {Endor.~ernent ReaulreQ Postr~e, rK 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 ; SS AFFIDAVIT: I hereby swear or affirm that I served 'daCopy of the Notice of Appeal, Common Pleas No. 0.~"" ~'4'~(I/~ ~i'7/ / ~fy1 , upon the~Justice designated therein ~n teotservce)_~'~/ ~" yea~_~::~;)~., r~bypers°nalservice [~(registered) mail, senders receipt attached hereto, and upon the appellee, (name L,'~'~)/'~ 41~ ~'/'c' ~ 5;1~3~ .... on ~///~, '~.-'7..- __, year _~2-~ _~, [] by personal service [~ (registered) mail, sender's receipt attached hereto. ~and fufthe~ that I served the Rule to Fil~..a Complaint accompanying the above Notice Appeal upon of the mail, sender's receipt attached hereto. SWORN (AmR~O) ^NO SUBS~,B~O B~FOR~ U~ 'm~S Z'Z'~ D^¥O~ '3'gl~ ,y~^~Z.~3'. Uycomm~ss~on ex~ires on ~/// , Ann~ Cmmmody, Nolm~y Pub#~ J Mleflank~qlBore, O~mberland Count~ / COMMONWEALTH OF P~qNSYLVANIA COURT OF COMMON PLEAS JUDICIAL DISTRICT NOTICE OF APPEAL ' FROM ?-i / DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. 0 ~- .." '/~/LI ~,~,~ -~ .... NOTICE OF APPEAL Notice is given that the appellant has flied 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. NAME OF APPELLANT I MAG, DIST. NO. OR NAME OF D,J. bAtJ,Uft Kl 'P_r4- Hoc, Km /,J -- ADDRESS OF APPELLANT CITY STATE ZIP CODE DATE OF JUDGMENT I IN THE CASE OF (PLAINTIFF) (DEFENDANT) C~IM NO.~ ..... zr ...... This block will be signed ONLY when this notation isffequirsd under PA. If appe~nt was Claimant (see PA R.C.P.J.P. R.C.P.J.P. No. 1008B. This notice of Appeal, when received by the District Justice, will operate as A SUPERSEDEAS to the Judgment for possession in this case. 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 (sea 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 sewed upon apbellea. PRAECIPE: To Prothonotary Enter rule upon ~/_--~ ~ ~ t3_,~ / ("_/~ ~.~ , appellee(s), to file a complaint in this appeal Name of appellee(s) (Common Pleas No. .-, = -= ,~, ,,. ~ within twenty (20) days after service of rule or suffer entry of judgment of non pros. ..... SIg~'~r~ of~'a'~rf~or his afforney or agent RULE: To / ~l'J AJ ~I/Y~,~/~'*,")N , appellee{s) ~ ' N'~ o~e#~(~/ ' '~ -- (1)You are notified that a rule is hereby entered upon you to file a complaint in tills appeal within twenty(20) days after the date of service of this rule upon you by personal service or by cedified or registered mail. (2) If you'd~)' ~t~)~ iiie a Complaint within this time a JUDGMENT OF NON PROS WiLL BE ENT. ERED AGAINST YOU ~U~N J~RAEClI~E. ~' (3);' :The date of service of tl3is [ule if service was by mail is the date of the mailing. : ., : White - Pr0thoncta, rYCopy Green - Court ~ile Yellow Appelant's.C~o~,~ Pink AppelJea Cop~ Gold - D.J. Copy Proth,- 76 LEON MORRISON Plaintiff DANNA KISER-HOCKMAN a/k/a DANNY KEISER Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PEI~SYLV_ad~IA : : CIVIL ACTION - LAW : ; NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST TIlE CLAIMS SET FORTH 1N THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THE COMPLAINT AND NOTICE ARE SERVED, 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. THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 LEON MORRISON Plaintiff DANNA KISER-HOCKMAN a/Wa DANNY KEISER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CIVIL TERM 033440 COMPLAINT AND NOW, comes Plaintiff, Leon Mordson, by his attorneys, Duncan, Hartman & Douglas, P.C. and makes the following Complaint: 1. Plaintiffis Leon Morrison, an adult individual, whose address is 205 Parker Street, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Danna Kiser-Hockman a/k/a Danny Keiser, an adult individual, whose address is 352 N. Middlesex Road, Carlisle, Cumberland County, Pennsylvania, 17013. 3. The Plaintiff is the owner of a rental property located at 110 N. Middlesex Road, Carlisle, Cumberland County, Pennsylvania, 17013. 4. The Plaintiff and Defendant entered into a lease agreement in 1991, for a one year lease term with a monthly rental payment of $600.00 being due and owing on the first day of each month. 5. The Defendant is in default by reason of non paymentof rental payments in the amount of $4,600.00 plus costs in the amount of $115.00 for a total demand of $4,715.00. WHEREFORE, Plaintiff request this Honorable Court to enter judgment in his favor and against Defendant in the amount of Four Thousand Seven Hundred Fifteen ($4,715.00) Dollars, plus all cost of this suit. Duncan, Hartman & Douglas, P.C. William A. Duncan, Esquire 1 Irvine Row Carlisle, PA 17013 (717) 249-7780 ID # 22080 VERIFICATION I, Leon Morrison, make this verification being authorized to do so, state that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge. I understand that false statemems herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Leon Morriso~ / LEON MORRISON, Plaintiff DANNA KISER-HOCKMAN a/k]a DANNY KEISER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 03-3440 Civil Term : : CIVIL ACTION - LAW NOTICE TO PLEAD TO: Leon Monison c/o William A. Duncan, Esquire Duncan, Hartman & Douglas, P.C. 1 Irvine Row Carlisle, Pa 17013 You are hereby notified to file a written response to the enclosed Amended Answer, New Matter and Counterclaim within twenty (20) days from service hereof or a judgment may be entered against you. Supreme Court ID 86889 Attorney for Defendant 101 South Market Street Mechanicsburg, PA 17055 (717)790-5451 LEON MORRISON, Plaintiff DANNA KISER-HOCKMAN a/k/a DANNY KEISER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 03-3440 Civil Term : CIVIL ACTION - LAW DEFENDANT'S ANSWER~ NEW MATTER AND COUNTERCLAIM AND NOW, comes Defendant, Danna Kiser-Hockman, by and through her attorney, Christopher J. Keller, Esquire and files the following Answer, New Matter and Counterclaim to Plaintiff's Complaint. ANSWER 1. Admitted upon information and belief 2. Admitted. 3. Admitted upon information and belief. 4. Admitted in part and denied in parL It is admitted that the parties entered into a lease agreement in 1991. The remainder of the paragraph is denied as the lease relied upon is a written document and con~'act and as such, the terms thereof speak for themselves. 5. Denied. The allegations set forth in Paragraph No. 6 of Plaintiff's Complaint constitute a conclusion of law to which no response is required. To the extent that a response is required it is averred that should the Defendant be found in default, said default is not in the amount stated by Plaintiff and strict proof is demanded at trial NEW MATTER 6. Defendant, Danna Kiser-Hockman incorporates herein by reference, as if fully set forth at length, her Answer, New Matter and Counterclaim, Paragraph Nos. 1-5, inclusive, as hereinabove set forth. 7. Plaintiff and Defendant entered into a written lease for the premises located at 110 N. Middlesex Road, Carlisle, Pennsylvania on or about September 15, 1991. See attached Exhibit A. 8. The lease requires the Plaintiff to pay water and sewer utility charges. 9. The lease requires the Plaintiff to provide snow removal for the driveway. 10. For approximately the last eleven (11) years, Plaintiff has been notified of, yet failed to repair, a central support beam under the living room of the residence. 11. Failure to repair the central support beam has caused the floor to drop approximately two (2) inches or more causing the floor and wall in certain areas to not come together. 12. Defendant has had to cram insulation in the areas where the floor and wall did not meet to prevent cold air from entering the living area. 13. Plaintiff was notified by Defendant in September 1999 of sewage seeping in backyard of the leasehold premises and did not begin repairs until July 2000 which were completed around October 2000. 14. During the three (3) months that repairs were taking place in the sewage system, Defendant could not use the upstairs bathroom toilet, sink, tub or kitchen sink. 15. Since on or about October 2000, Defendant notified Plaintiff and/or his agents regarding upstairs toilet overflows and upstairs bath plumbing not draining properly. 16. The upstairs water problems since October 2000, caused portions of the dining room ceiling to come down. 17. The water from the unrepaired drainage problem over the dining room damaged the Defendant by way of warping the dining room set, and rental of rog cleaners/scrubbers and disinfecting carpeting up and downstairs. 18. Replacement cost of the dining room set is approximately $1,400.00. 19. Plaintiff was notified of leaking kitchen sink since on or about October 2000, which has never been repaired. 20. Since on or about October 2000, Plaintiff was notified of leaking kitchen pipes and tub drain and faucets but the same had not been repaired at the time of Defendant vacating the premises. 21. Dripping tub drain finally wore through causing water damage to Defendant's desk, photographs, computer, printer and telephone in the floor below. 22. Replacement cost of the computer is approximately $600.00. 23. Replacement cost of the printer is approximately $100.00. 24. Defendant had to patch a 2x2 foot hole in floor near the front door. 25. Defendant had been unable to use the wood stove for heat because the brickwork had fallen into a state of disrepair and Plaintiff failed to repair. 26. Plaintiff has not paid the water and sewer bill since on or about 1995. 27. Defendant has paid the water and sewer bill since on or about 1995 in order to maintain water and sewer service to the premises. By way of example only, nine cancelled checks are attached as Exhibit B. 28. On or about March 9, 2003 Defendant vacated the premises and notified Plaintiff of her new residence, down the street. 29. As of August 25, 2003, Plaintiffhas not returned Defendant's security deposit or provided her with a list of damages indicating why her security deposit was not returned. 30. Defendant has had to spend at least $600.00 over the last several winters having the driveway plowed because Plaintiff has failed to do so in breach of the lease terms. 31. Defendant has paid the water/sewage bill over the time period of her occupancy in the approximate amount of $2,599.84. COUNTERCLAIM COUNT 1 - BREACH OF IMPLIED WARRANTY OF HABITABILITY 32. Defendant, Danna Kiser-Hockman incorporates herein by reference, as if fully set forth at length, her Answer, New Matter and Counterclaim, paragraph Nos. 1-31, inclusive, as hereinabove set forth. 33. Defendant notified Plaintiff and/or Plaintiff's workmen or agents on numerous occasions of conditions that would render the leasehold uninhabitable, namely, leaking pipes and holes in ceilings, holes in floors, sewage problems, floor sagging more than two inches due to broken central support beam. 34. Plaintiff failed to repair defects and dangerous conditions within reasonable periods of time after notification. 35. Plaintiff's failure to repair defects and dangerous conditions within reasonable periods of time resulted in damage to Defendant's property in the approximate amount of $2,100.00. 36. 37. Defendant continued to pay full rent of $600.00 per month during those periods. Plaintiff's failure to repair said defects and dangerous conditions within a reasonable period of time after notification by Defendant is a breach of the implied warranty of habitability. WHEREFORE, Defendant respectfully requests that judgment be entered in her favor for damages incurred by Plaintiff' s breach of the implied warranty of habitability in an amount to be determined based upon a reduction in the fair market rental value of the leasehold premises during the time period such warranty was breached and in the amount of $2,100.00 for damage to Defendant's property as a direct result of Plaintiff's failure to repair and other such relief as this Honorable Court deems appropriate. COUNT 2 - BREACH OF CONTRACT 38. Defendant, Darma Kiser-Hockman incorporates herein by reference, as if fully set forth at length, her Answer, New Matter and Counterclaim, Paragraph Nos. 1-37 inclusive, as hereinabove set forth. 39. The subject lease calls for the Plaintiff to pay utilities related to water and sewer service at the leasehold premises. 40. The subject lease calls for the Plaintiff to provide for snow removal of the driveway. 41. Plaintiff failed to pay the utilities related to water and sewer since on or about 1995. 42. Plaintiff's failure to pay the utilities related to water and sewer is a breach of the contract. 43. Defendant had paid the utilities related to water and sewer since on or about 1995 through March of 2003, in the approximate amount of $2,599.84. 44. Plaintiffhas failed to provide snow removal of the driveway for approximately the last six (6) years. 45. Plaintiff's failure to provide snow removal of the driveway is a breach of the contract. 46. Defendant has provided and/or paid for snow removal of the driveway for approximately the last six (6) years. 47. Defendant's approximate cost for snow removal of the driveway for the last six (6) years is $600.00. WHEREFORE, Defendant respectfully requests that judgment be entered in her favor for damages incurred by Plaintiff's breach of contract in the amount of $3,199.84 plus interest, representing amounts paid by Defendant due to Plaintiff' s breach and other such relief as this Honorable Court deems appropriate. COUNT 3 - SECURITY DEPOSIT 48. Defendant, Danna Kiser-Hockman incorporates herein by reference, as if fully set forth at length, her Answer, New Matter and Counterclaim, Paragraph Nos. 1-47, inclusive, as hereinabove set forth. 49. Plaintiff held Defendant's security deposit of $600.00 since on or about September 15, 1991. 50. 68 P.S. §250.511 a, provides in pertinent part, "the escrow funds together with interest shall be returned to the tenant.". 51. 68 P.S. §250.51 lb, provides in pertinent part, "all funds over one hundred dollars ($100) deposited with a lessor to secure the execution of a rental agreement on residential property in accordance with section 511.1 ... shall be deposited in an escrow account of an institution... The provisions of this section shall apply only after the second anniversary of the deposit of escrow funds." 52. The two-year anniversary of the initial security deposit was on or about September 15,1993. 53. It is believed and therefore averred that Plaintiff did not deposit Defendant's security deposit into an interest-bearing account. 54. Plaintiff did not notify Defendant of deposit of escrow funds per 68 P.S. §250.511b. 55. 68 P.S. §250.512 provides that the landlord shall provide a written list of damages and~or return the tenant's security deposit, with interest, where applicable, within thirty days of acceptance of the leasehold premises. 56. 68 P.S. §250.512, provides that failure to return the security deposit shall render the landlord liable for double the sum deposited in escrow. 57. Plaintiff has failed to provide Defendant with a list of damages to the leasehold premises allegedly caused by Defendant. 58. Plaintiff has failed to return to Defendant her security deposit with interest within thirty (30) days of accepting the leasehold premises. 59. Plaintiff is therefore in violation of 68 P.S. §250.512. WHEREFORE, Defendant requests twelve hundred dollars ($1,200.00) representing statutory damages of double the security deposit per 68 P.S. §250.512; and interest at the legal rate on the $600.00 security deposit calculated from September 15, 1993 until present and other such relief as this Honorable Court deems appropriate. WHEREFORE, Defendant requests this Honorable Court grant Defendant judgment against the Plaintiff and award monetary damages to Defendant in an amount not less than Six Thousand Five Hundred Dollars ($6,500.00) and any and all other such relief as this Honorable Court deems appropriate. Respectfully submitted, Christopher J. ~eller, Esquire Supreme Court ID 86889 101 South Market Street Mechanicsburg, PA 17055 Pr. (717) 790-5451 Attorney for Defendant o,2, 1'¢~: ,' ':'" . oF P;~oP/:/<'r/ o~'':~', · / "',,~ /A,';/UO:!) ,.'~ "~( Illh~,h'i o,'~:' m(,,rbc;(~, u,( (h~' A~mod lU'LCC', O~ ~he.L~ ~_~.~pec.~iv~ ~1~ ,/Im,c (/~c ,'[.!h,[l( ~/) ' ', , L,kllPL OF, l), pc.~mi~,5(cm 0~ .~Jto l k,u~()~l)' 00~ OR t I,,~:;:: i~ i' r. u .... DANNA L. KISER 05/95 110 N MIDDLESEX RD. PH. 717-766-1967 CARLISLE, PA 17013 ~115 DOLLARS~ l, hoqo,,,h 5 ? 2 ?"' q h I, I, 5 ,,'000000 ? 500," ~-~/3~o 4 0 3 7 DANNA L. KISER 05/95 110 N. MIDDLESEX RD Pm 717'756'19~7CARLiSLE, PA 17013 ~.oreSt~tes Hamilton Bank i ,:0~0o0o~,: ~hOqO,,,hS?~?,,'qhO~? ,,'O000005000,';ml...... 3-1/310 4 2 i 6 DANNA L. KISER 05/95 110 N. MIDDLESEX RD. PH, 717-258-4513 CARLISLE, PA 17013 C ' I /~ ~:0~ ~OOOO ~ ~l: ~hO~O'"h 5 ? ~ ?"'qb ~ ~ ,,'DODO00 ? 500," DANNA L. KISER PH 717-258-4513 110 NORTH MIDDLESEX RD CARLISLE, PA 17013 Pay to the N SAVINGS BANK For ,-' 2~t ii? ~ iR ?,1 lqO00 l, SOil 4450 / I $ '/.5 hhS0 ,,'000000 ? SO0," 4787 DANNA I. KISER t10 NORTH MIDDLESEX RD 60-7238/2313 4 914 DANNA L. KISER _~_~ ~ PH 717-258-4513 ~ 11(3 NOEl~ MIDDLESEX RD ~ 19 CA~LISLE, PA 170'13 ,: B ~ i, ~, ? ;~ ~,q, ?,: ~.qOOO ~, SOp, I,," ~.h ,,'OOOOOO 8 B SD," 5033 60-?2 PH 717-258-4513 110 NORTH MIDDLESEX RD 19 CARLISLE, PA 17013 -- ....._. s.v,.os ... /1 l~ . VERIFICATION I verify that the statements made in the attached Answer, New Matter and Counterclaim are true and correct. I understand that false statements herein are made subject to the p~nalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: _ Darma I~se~[Hocl~an LEON MORRISON, Plaintiff 'Vi DANNA KISER-HOCKMAN a/k/a DANNY KEISER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 03-3440 Civil Term : : : CIVIL ACTION - LAW CERTIFICATE OF SERVICE. I, Christopher J. Keller, Esquire, hereby certify that on this date, a true and correct copy of the foregoing Defendant's Answer, New Matter and Counterclaim, were served upon William A. Duncan, Esquire, attorney for Plaintiff, by depositing a copy of the same in the United States Mail, first class postage, pre-paid, addressed as follows: William A. Duncan, Esquire Duncan, Hartman & Douglas, P.C. 1 Irvine Row Carlisle, PA 17013 Date: ~-~s(~ppher J. K411e, Esquire Supreme Court ID 86889 Attorney for Defendant 101 South Market Street Mechanicsburg, PA 17055 (717) 790-5451