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Home My WebLink About04-1161 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. D<f -11t.1 c..;vll NOTICE OF APPEAL ITI Arc./' 19, 'J.oo'-l 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 referenced below. Judicial District, County Of N~Fr;;LAN/rt' t.: 1 -:;-iA f t<l-f;,c~ MC/9T:03 - 05-1 NAMC;:''f Ie- e-L 7) e- K:. AD R OF APP1Lf}NT . f C'TY r p STATE ZIP CODE o I;) O'/.. b-:5 3 IVllF'-tl kVWt c- S I:. C-f r-i /I- 17 0 ~ -,~ - OAT OF JUDGMENT _ t I'N THE CASE oJ(~,;"td ~ 8 IIFM ~ (o.,ood.otrf - ..l....L .L - J d-.-d-S - 0 Jc~.J-Vlr1tVrr.J. ~~" 1Yl!h" ~ -hT-z..pI#-TJ--tc:.l.~ DOCKET No. SIGNATURE OF APPELLANT OR ATTOR EY AGENT I &JI-tfooo"5/?_O 3 This block will be signed ONLY when this notation is required under Pa. RC'p,D,J. No, 10088, This Notice of Appeal, when received by the District Justice, will operate as a before a District Justice, A COMPLAINT MUST BE FILED within twenty SUPERSEDEAS to the judgment for possession in this case. (20) days after filing the NOTICE of APPEAL Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONL Y when appellant was DEFENDANT (see PaR.C.PD,j 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 prothono!ar; I D Enter rule upon Jr ~ ~/l1 t''fi '" t II-- 50 rt..~;V(T"1h tr"; I Name of appellee(s) appel/ee(s), to file a complaint in this appeal (Common Pleas No, 04 -11101 (,\~,' I ) within twenty (20) days after seIVice of rule or suffer <;>ritry at J dg ent of non pros, /) RULE: T J/ nr .Ii 11 0/ t~:r ./Jre1<-'N O1'1~pel/ee(s) fJ!:!- lame of aPP6l1ee(s) (1) You are notified that a rule is hereby entered upon you to fiie a complaint in this appeal within twenty (20) days after the date of seIVice 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 MAY BE ENTERED AGAINST YOU, (3) The date of seIVice of this rule if seIVice was by mail is the date of themailing./J/laLr-.11 Date: (y}ttr-yLI1_' 20()1 ~ I1f rI!L~!J:tD.PUty YOU MUST INCLUDE A COpy OF THE NOTICE OF JUDGMENTITRANSCRIPT FORM WITH THIS NOTICE OF APPEAL AOPC 312-02 COURT FILE TO BE FILED WITH PROTHONOTARY PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DA YS;.\FTER filing nf the notice ot appear Check applicable boxe:s.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF AFFIDAVIT: ! n~:rf';by (swear) that i served ;J ,-:,:opy of Hie Notice of Appeai, Common Pieas No, upon the District Justice designater1 therein on (dale of service) ,20 by personal service by (certified) WHJistered) nl(}li, sender's receipt attached hereto, and upon the appellee, (rlBfTWf) 20 by personal service (certified) (registped)~. .'- 5-2 ;, s,(;nder's \'oce\pt hereto (SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF 20 \,2 ,~ignature of officiAl before whom affidavit was mad.) Title of official ,'<; My commission expires on 20 AOPC 312A, COMMONWEAL TH OF PENNSYLVANIA COUNTY OF: CUMBERLAND o~, ((&/ NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS IBRENNEMAN, KEN & VIRGINIA J. I 17 S.HIGH STREET MECHANICSBURG, PA 17055 Mag. DiSI. No.: 09-3-05 OJ Name: Hon. GAYLE A. ELDER Add""" 507 N. YORK ST. MECHANICSBURG, PA L -.J VS. T".phM. (717) 766-4575 DEFENDANT: NAMe: and ADDRESS IpITZPATRICK, MARGARET E. 711 S.YORK STREET APT/STE 2 MECHANICSBURG, PA 17055 I 17055 ATTORNEY DEF PRIVATE GREGORY J. KATSHIR ESQUIRE 900 MARKET STREET LEMOYNE, PA 17043 L Docket No.: cv- 0000317 - 03 Date Filed: 12/04/03 .J 1& it "1 nlls IS TO NOTIFY YOU THAT: .'- JUCfgmem:" [iJ Judgment was entered for: FOR PT,lITNTTFF . (Name) lU?R1\TlII1>.MlIlIT, lrRllT 6- VT1U::TlITTlI .T. [iJ Judgment was entered against: (Name) FTT7.PlI.'1'RTClr, MlIRC::lIRF.T E_ in the amount of $ (Date of Judgment) (Date & Time) 4,060.00 on: 2/2<;/04 D Defendants are jointly and severally liable, o Damages wili be assessed on: o This case dismissed without prejudice. 1 $ 3.955.00 $ 105.00 $ .00 $ .00 $ 4.060.00 Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Total O Amount of Judgment Subject to .AttachmenV42 Pa.C.S. 9 8127 $ O Portion of Judgment for physical ' damages arising out of residential lease $ Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ ~T'i. tli'aJ'f\f ElIG[tT TQ.API?EAL WITI:!(toI ~o DAYS AFTER THE ENTRY OF JUDGMEN:r BY FILING A NOTICE ~ ..A\A W"I\. lJ,\ '''''.''''l~,'-..Il~\~~'\"C ~J\,", ur \..v'l.....""" I"'LE."~. \"IYfL u1V'~IVf'f. lUl1 MUST INCLUOE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT 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. ;,1t!i',\~~;Jfp~.11v~'6ate ..;' './' r,.. ,.~. I certifY that this is. a true ahd correct 'copy .of the record of the proceedings containing the judgment. !,' , " >'F-(!, '.()df,~7 ','""! , District Justice Date , , District Justice My commission expires first Monday of January, 2006 , SEAL AOPC 315.03 2/25/04 DATE PRINTED: 4:13:03 PM ~ ~: "- -c "G ~ ~ I) "'tA-. ~ ~. -:::+?~ ~ . ~ v\ ~ ~ r..) c;:, c" ~ ~ ~ -T- " , r 7':. (; c~ U.S. Postal Service", CERTIFIED MAIL,., RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) r'l r'l n1 IT' D f'- f'- f'- D D D D D r'l r'l n1 n1 ~ ;:'lfi:;:r..0.'-!J;!~!I!>:.f;~L~_!l:'~Jn".mmn". ~::.~~.';,J7-"".n_Q_y'4.L_t:t..~t6....?__L..mn_.n"".. "Ut{(J.fVlc~;b' ,q. t7o.rs- Postage $ Certified Fee $2.30 0055 16 """"'... Return Reciept Fee $1,75 He", (Endorsement Required) Restricted Delivery Fee $0,00 (Endorsement Required) Total Postage & Fees $ $4.42 03/29/2004 <0 ru n1 IT' D f'- f'- f'- D D D D D r'l r'l n1 n1 D D f'- U.~. Postal Service", CERTIFIED MAIL", RECEIPT (Domestic M iI Only; No Insurance Coverage Provided) u GtAGolA L Postage $ , Certified Fee $2.30 Return Reclept Fee $1.75 (Endorsement Requli'ed) Restricted Delivery IFee $0.00 (Endorsement Required) Total Postage & F,~es $01.42 ITo 0055 16 Postmark Here 03/29/2004 PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FfLED WfTHfN TEN (10) DA YS AFTER filing of th" notice of appeal Check applicable hoxes.) ~~~~~N:EA~E~~Nd ; ss AFFIDAVIT: I hereby (swear) (affirm) that I served I a copy of lhe Nollce of Appeal, Common Pleas NoOf//~ / upon the District Justice designaled therein on . I , , (date of service) () 5 - d- '1' . 200 U, 0 by personal s,,,vice ;E9..by (certified) (registered) mail, sender's receipt att~Ghedh~r~t~, and up~n tie appellee. (name!/r::. (;;rlv 13,'i;;rLi<-<:rfH ... "J , on 0_5 - ~'l ,20 ~ Y 0 by personal service ~.~by (C~;J!liOO) (re~red) mail. sender's receipt attached hereto. , I ""-.. \ " /' 1/".:;] '>" /!/~-:,.:::::-"--'- _L~,~:-~_-..",~, LA._ G: ." ~ '. ' "( '<:') ~'~::. " ~"\ Z:Jc'::O , -y ,-' . -0- E.___ N f:!) ~~ \,0 ~O ~ ".. ~.~ ~ i5 :z; .:.:. ~ =< N -< 'fA. (SWORNl(lIFFIRMED) AND THIS q'fr-- DAY OF . .......,... "" Signatut'O of offlci/1f before whom affidavit was made Tirfjf~fL:j ~l4~ My commIssion expires on ~__ ...,~_ ,20 OC NOTARIAL SEAL CLAUDIA~: BREWBAKER, NOTARY PUBLIC '.Carllsre.-Boro, Cumberland County My Comffiis,slon Expires April 4, 2005 AOPC 312A. 02 / ""'''' , r" ~,.~~'...~ .,..~.l" ~.~..'': ""... . ,~~....,~,.. " ",~~..."'~~~_~~~~~i)'T"'T"""""~,I"<("""'"' COMMONWEALtH OF PENNSYLVANIA COURT OF COMMON PL!:AS \ NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. OY -flU c;IIi I NOTICE OF APPEAL ;T/ tl. r< h /1, 'J...()Ot.f 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 referenced below. Jlldlclal District, County Of N NAM;:' ;:. '1/<<' .p~ STATE DOCKET No, t,J/-tJooo"5/?-O 3 This block will be signed ONLY when this notation is required under Pa. R.C.P.D,J, No, 1008B. This Notice of Appeal, when received by the District Justice, will operate as a before a District Justice, A COMPLAINT MUST BE FILED within twenty SUPERSEDEAS to the judgment for possession in this case. (20) days after filing the NOTICE of APPEAL SignafUf9 of Prothonotary orDeputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONL Y when appel/ant was DEFENDANT (see Pa.R.CP.D,J. No, 1001(7) in action before District Justice, IF NOT USED, detach from copy of notice of appeal to be served upon aPfel/ee, Enter rule upon appellee(s), to file a complaint in this appeal Name of appel/ee(s) (Common Pleas No, OY -1110' ,,\~,"I ) within twenty (20) days after service of rule or suffer entry of) dg ent of non pros. RULE: T&' ,r ,w,4J , . . _..~ ame of appel/ee(s) .. ,.." ""~"\ (1) You are ~ifie;t!ttil;Il{~~~la j~ hereby entered upon you to fiie a complaint in this appeal within twenty (20) days after the date of service of this ruleuporl y~~..bY'PefSObarseNf~~ or by certified or registered mail. .. ..... '" ". '. .." ",,,' . (2) ,'If you do not file a complaint Viit/:>in this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOLJ. ;/ !"'. ' ~ -' '.' Date(3k.t ::~!~,~i:::this rUI~{trvice was by mail is the date of the mailing. ~4 $l f/:;;Ll /7.-/.r.. +,.,c,.It.,~-y. : + s,gn.tu"'ofPro~DePUty '.,?', , :., ,'/y YOU MUS~~~J"UQE ~J.~jy OF THE NOTICE OF JUDGMENTfTRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. '",,"',............ ~ ,,~* ot" ,appellee(s) AOPC 312.02 COURT FILl KEN BRENNEMAN VIRGINIA J. BRENNEMAN : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFFS : CIVIL ACTION, LAW V. MARGARET FITZPATRICK DEFENDANT : NO. 04-1161 CIVIL NOTICE 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 be entered against you by the court without further notice for nay 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 TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 KEN BRENNEMAN VIRGINIA J. BRENNEMAN IN THE COURT OF COMMON PLEAS OF : CUMBERLANH COUNTY, PENNSYL VANIA PLAINTIFFS CIVIL ACTION, LAW V. MARGARET FITZPATRICK DEFENDANT : NO. 04-1161 CIVIL COMPLAINT 1.) Plaintiff Kenneth J. Brenneman is an adult individual, sui juris, and a resident of Mechanicsburg, Cumberland County, Pennsylvania. 2.) Defendant Margaret Fitzpatrick is an adult individual, sui juris and a resident of Mechanicsburg, Cumberland County, Pennsylvania. 3.) At all times material to this litigation, plaintiff was the owner of real estate consisting of a three room apartment known as 106 W. Locust Street, Mechanicsburg. 4.) Prior to September 9, 2002, Richard G. Castle III, the son of defendant Margaret Fitzpatrick, applied to plaintiff to lease the apartment at 1 06 West Locust Street. 5.) Plaintiff refused to lease the premises to Richard G. Castle III because of his poor credit. 6.) Prior to September 9, 2002, defendant requested plaintiff to lease the premise to her son and agreed to be responsible for payment of his rent ifhe failed to pay. 7.) In reliance on defendant's's promise to guarantee the rent, plaintiff leased the premises to Richard G. Castle III by written lease dated September 2, 2002, attached as Exhibit A; defendant's guarantee dated September 2, 2002, is attached as Exhibit B. 8.) On February 1,2003, Richard G. Castle m did not pay the February rent in the amount of $495.00 and defendant paid the rent for him. 9.) On June 30, 2003, the lease for the premises was renewed for another year terminating August 31, 2004, Exhibit C attached. 10.) From October 1, 2003, to March 30, 2004, Richard G. Castle 1lI did not paid any rent nor was it been paid by others. I I.) Richard G. Castle III vacated the premises March 30,2004. 12.) Plaintiff demanded defendant pay the rent as it became due but she has refused to do so. 13.) Richard G. Castle 1lI owes rent for October 2003 through March 2004, a total of six months, at $495.00 per month, a total of $2,970.00. 14.) The lease provides for late charges of$10.00 per day; plaintiff believes $50.00 per month is a reasonable late charge and demand is made for 6 months at $50.00 per month, a total of $300.00. 15.) Plaintiff claims reimbursement for district justice costs in the amount of$105.00. WHEREFORE, plaintiff demanding judgment of the defendant in the amount of $3,375.00, plus interest and costs. _~~ fr1. t:k John . Eakm ID Ot 51 Market Square Building Mechanicsburg, PAl 7055 KEN BRENNEMAN VIRGINIA J. BRENNEMAN : IN THE COURT OF COMMON PLEAS OF : CUMBERLANDi COUNTY, PENNSYL VANIA PLAINTIFFS : CIVIL ACTION, LAW V, MARGARET FITZPATRICK DEFENDANT : NO. 04-1161 CIVIL VERIFICATION I, KENNETH J. BRENNEMAN, hereby verify that the statements off act made in the foregoing instrument are true and correct to the best of my knowl'edge, infonnation and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. ~~~. Kenne . renneman --" A ""---v . , ..11" //Ii FIllS 17 S. HIGH ST. MECHBG, PA. 17055 PHONE/FAX 717.766-3841 E-MAIL: KBVB_@HOTMAIL.COM LEASE AGREEMENT This Lease Agreement made this q day of!l1-.20p;)" by and lx,tween KENNET~~~ & ;:!Jt!~RENN~~AN, Bm;;-NNEMAN APARTMENTS, as Landlord, and ./ --: }l "i)" La I'd e Ie ses erant /,1) j., _located at.~ ~ 4-(l./A' dlJ 'j fi t -:- upon the following terms and conditivns, to wit: 1. RENTAL TE S:JAe term of . Ie I ase shall be one year beginning the /4y of -7---'}J)t1JL., And ending th~day of ,200.;( 1IfI' rOO 2. MONTHLY RENTAL: Rental sh II be paid in the amount ~~per term, payable on the first day of each month. All such rental payments shall be due without demand therefor. 3. TENANT INSURANCE: We can only suggest that you secure tenant insurance and it is strongly recommended. We can suggest our insurance company, SHINEJR INSURANCE AGENCY, 1001 S. MARKET ST., MECHANICSBURG, PA. 17055. They olfer oUJr tenants a discount. 4. A lawful continuance of the tenancy beyond said term shall be deemed a renewalthereoffor the further term of one year at the expiration thereof. You will receive a (90) nighty day notice of Landlords intent to renew or to deny new lease. SIgn to your int.mt and return within (30) thirty days. And every further lawful continuance shall be deemed a further renewal for a like term, to end in like manner. And every renewal or hvlding over shall be subject to the provisions ofthe lease. 5. No part of said term or of any renewal shall be assigned nor any portion of the demised premises underlet, without the written consent of the landlord. (IF TENANT COUNT CHANGES, LEASE MUST BE RENEGOTIATED.) 6. No waste shall be committed, and at the end of said term, or of any renewal, the demised premises shall be delivered up without further notice in as good condition as at the commencement thereof, Ordinary wear and tear and unavoidable damage by fire, tempest and lightning excepted. 7. II is also hereby agreed that the Tenant is at all times, during the term fthis lease, to keep the pavement clean vfice and snow, grass and weeds. B. LATE PAYMENT OF RENT Is an automatic eviction notice. To avoid this, please notify, BRENNEMAN APARTMENT OFFICE, on or before rent due dale with reason for being late. After (5) five days grace period, there will be a ($10.00) TEN DOLLAR PER DAY LATE CHARGE. A service fee of ($20.00) twentv dollars wtll be charlled for retunJed checkR 9. Tenant Is required to register their phone number with the rental office as soon as phone service is Connected. 10. Tenants vehicles must be registered at the office and parked in the designated area. Any vehicle that Is not being used must be stored olf the premises. No major overhauling of cars on the premises Is permitted. No vehicle washing. BRENNEMAN APARTMENT I"EASE EXHIBIT A PAGE 2 11, Ills Ute tenanl's responslblllly 10 reporl plumbing leaks. running toilets. leaky f'auce" ~d no heat to the omce hnllledlately. Uyou don'Ilnronn omce, you will be billed for repair when you leave or 800ner which ever cOllies nrst. 12. Apartmenls lIIu91 be kel.t neat and clean, 'I'h19 Includes windows, refrigerator, stove, mIcrowave, wBlIs, nOOl-o and earpels. No painting Is pennltled. A well kel"t apartment wlllln9ure a I\Jll ref\md or securlly depoell. " .. 13. Mall bolles are provIded. Upon vacallngllle apartment, the forwarding addre9s must be given to the oII1ce In onler for you to receive your security depoell 14, A ($10.00) len dollar fee will be charged 10 let a tenant Into a locked apartment, 15, If tenant Is evicted for any reason, securIty depoelt will not be ."tumed, 18, If tenant breaks Ute lease prior 10 one year, securIty depoell wlU not be returned, 17, CONDUCT OF TEN ANTi Tenantagreee not to do or to penn IIi any act whIch shall cause damage to the demised premises or stullllnterfere wIth or disturb the peaceM el\loyment or the preml8el upon tenanls by stale, county or local code9, regulations, onllnancea or statutes. Tenant shall keep leased preml8e1lln a good 9tale or repair and maintenance u at present and at the ellplrallon orthlsle-. shBII surrender the premIses In like repair and condlUon. norn~a1 wear and tear alone ellcepted. The premises are to be kept In a clean and B8IIllary condlUon and aH truh or other garballll whIch m8.Y accumulale tllereon during IIle tenn are to be removed promptly. and In case of failure to remove the 88IIIe, the Landlonlmay have IIle 88IIIe removed and collect 88lrent due and In lII'1'e8n double such Vcoet or removal, No tenant shall have guests for more than a week wIthout Infonnlng oftJce, ~. SECURITY DEPOSr, enan..ll j ~.l!ll depoelt wIth Landlonl at U~e lime of ellecullon or thIs agreement a securIty depoell of ~ 191/;00 _ to be held by landlonllo 9ecure the fallhfW compliance or ' , tenant wJUt all ternl \( ons of Ule agreemenl Ills also understood that the securIty depoelt can not be used for last monlllS rent. 19. lITILITlES: Tenant Is responsible for BII ullllty expen8e1l or 118.9, electric. phone, TV cable and ' 1l1../ A where applle,. And e s IBII be respon91ble for maintenance and minor' repaIrs to IIle heat90urce ( __Ilea.. -I-p, 1 . which Is u"UBlIy ruters. Tenant shBII spectnco.. be reoponslble lOr purchaslng'any ne&.li... tight bulbs on the premllles '" keeplnl batter1811ln sllloke detectors. If lire extingUisher Is used APARTMENT OFFICE must be nottned immedIately. 20, PETS: Landlord does not wish 10 have pels In apartment or on properly. Usuch arl8el, oII1ce mUll be nollned and security deposll and addJUonal rent must be amended to le88e In wrItten ronn, Dogs must be leashed and curbed al all times. now dirt in Ylll'lll will not be tolerated. 21. Tenant shall not hang or attach anything to the InterIor or elltedor of Ule walls or the preml8el. nor shall they paint any surface of Ute said premt8e1l wIthout the ell]Pressed approval or the Landlord. Tenant shall hot have any other subsidized heaUng un1888 approved by landlonl, . 22. LANDWRD W AR1tANTY: Landlonl h88 rented the preml8e1l1n their present -88 Is" condItion and wIthout any repregentatlon other than those steled In thlllleage. Landlord Is under no duty to make repairs. Alterations or decoratlon9 unles9 Ulat duty Is setlOrth'~n thlo agreement. 23, INSPECTION: Landlord reserve9 the rlghllo enler upon the premIses at re880nable times and In a reuonable manner to Inspect the demised preml8e1l and to detelrmlne If repaIrs are needed. upon givIng rea90nable advance notice or such Intended entry, Tenant agreeS to pennlt Landlord to show the aparbnenlto other prospective tenanls and to pennlt entry Ito prospective purchasers when the preml8e1l are offered for sale, 24. LANDWRD'S LIABILITY: Tenant asreee lIlal Landlord shall ilte liable for properly damage or personalll\lury occurring In the leased preml8e1l or el88where Oil Landlord's preml88s only where 9uch damage or Injury re9u1ls dIrectly from Lanillord's negll\l8l'lce, 25, LANDWRD'S REMEDIES: In the event tenant shalllll1l to COInply wIth any tenn or condItion or thIs lease. Landlord shBII have rIght to: a) bring a law sutt to recover pos9888lon or theleasec1 property; b) brIng a law 9Ult 10 recover the entire balance due or the rent reserved for the I\Jll term hereof and any oilIer charges due hereunder together wIth any Imd BII damaps caused by and tncurred u. , "ult of tenant'9 defaultlncludtng reasonable attorney's fees and court ooela; c) to exen:lse m.y and BII rights accrulitg fuhtm under PllnnsylvmllIa Landlord and tenant, 88 amended. 28. CONFESSION OF JUDGMENT: Thl9 lea88 Is UDOn condItion Ithat the covenants or the tenant shBII be l\Jll)' kept and perfonned; and on any breach thereof Ute eslal. demtsed ohBII at the electlon r the Landlord cease and detennlne, and the Landlord may re-enter tile demIsed preml88s wIthout PrevIous nollce or demand, And upon the ellplrallon or other d,!tennlnalIon or said Ienn, or or an)' Renew.al, any attorney may appear for the Tenant In an amIcable aellon or ejection for the demIsed ' , BRENNEMAN APARTMENT I.EASE " PAGE 3 " " " , premises, In any court having jurisdiction, and confess judlllllent therein, with C08tI. In fIlvor or the Landlord, or those claiming under said second party, But such re-entry or judlllllent shall not bar The recovery or rent or damages for breach or covenant; nor shall the receipt or rent after condition broken be deemed a waiver of forfeiture. The 1'e11l!rit confesses judlllllent for the rent reserved for said tenn, and for each renewal, with stay or execution lInW the several days orpayment; such jUdgments to be entered successively as renewals shall bike place. Any judlllllent In ejection, as herein-before provided may be entered concurrently herewith, '1:1, No portable dishwashers or washers or dryers will be permitted. 28, Tenant shall provide their own trash container with tight lid '" be responsible for trash collectIon area to be picked up and kept neat at all times. Recycle bins are Provided, All community PI UI"" ty, SUch as, trash area, laundry rooms, entrances and lawn shall be always clean and presentable. 29, TERMINATION: It Is agreed that either Landlord or Tenant may tennlnate this lease at the end or the Inlllaltenn hereof by giVing the other party written InoUce or at least sixty (60) days prior to the end or the Inltlal term. Landlord will present Intent to renew or not to renew lease for another year. Tenant must sign In the appropriate place and return to omce within (30) thirty days. In the event such nollce Is not given by Landlord to Tenant, th~5lease shall conllnue upon the same tenDs and conditions In force Immediately prior to the expiration of the initial term for another period or one year and so on from year to year unless terminated by other party giving the, other (60) sixty days written nollce of the lennlnallon prior to the expiration oCthe then current tenD. Provided, However, that If the Landlord shall give thirty (30) days written noUce prior to the expiration 'of any tenn hereby created of his Intenllon to chanll8 the terms and conditions of this lease, and the Tenant remains In the premises aller the efl'ectIve date set forth In the notice, the Tenant will be considered as a tenant under the terms and conditions as provided In such noUce. All tenDs and Condltlons In existence prior to such notice which are not inconsistent with or repealed by such notice, shall remain In full force. Provided, however, that Landlord cannot without the written consent or the tenant extend the duration or the Initial telm or any subsequent renewals as provided for In this agreement. 30. ASSIGNMENT AND SUBLE1TING: Tenant shall not aB8lllD or sublease the demised premllle8 or any part thereorwlthout prior written consent of Landlord, and Tenant agrees that apartment shall be used as a Residence only. Any Tenant having guest fOl!' more than one week, must Inform omce of Intent No pet guests. Tenant will be held responsible fill' the conduct and dllll18ll8 caused by themselves or by any guests. 31. SEVERABILITY: In the event any provision of this 1_ shall be declared invalid by any Court or the Commonwealth of Pennsylvania, only such provlslorl declared invalid shall be null and void and all other proviSions not InconsIstent therewith sha!). remain blndln an orce. TENANT . .-.~ IN wrrNESS WHEREOF, the parties hereto have here unto oppoaltFo mn' .'....atures respect\veIY:~C DATE" 9.~ 9..:oZ , ,_ . . ~ TER"'ANT . 9hJm~ DATE BRENNEMAN APARTMENT LEASE .: .) CONVICTED BY ANY MAGISTRATE OR COURT OI? RECORD? __NO _YES PLACED UNDER A PEACE BOND;' NO _YES Please give any additional infonnation which might help management evaluate this application: I hereby apply to co.slgn for the above described premises for the lenn, which my son holds, and upon the conditions above set forth and agree that the rental Is to he payable the _day of,each month In advance. As an Inducement to the owner of the property and to the agent to accept the applicatlon,l warrant that all statements above set forth are true. I RECOGNIZE TIIAT AS A PART OF YOUR PROCEDURE FOR PROCESSING MY APPIJCATION, AN INVESTIGATIVE CONSUMER REPORT MAYBE PREPARED W1IEREBY INFORMATION III OBTAINED TIlROUGH PERSONAL . INTERVIEWS WITH MY NEIGHBORS. FRIENDS, AND OTIlERS WITII WIIOM I MAYBE ACQUAINTED. TInS INQUIRY INCLUDES INFORMATION AS TO MY CHARACTER, GENERAJ~ REPUTATION, PERSONAL CHARACTERlsncs, AND MODE OF LIVING. I UNDERSTAND TIIAT I MIA Y HAVE TIlE RIGHT TO MAKE A WRl'ITEN REQUEST WITHIN A REASONABLE PERIOD OF TIME TO RECEIVE ADDITIONAL, DETAILED INFORMATION ABOUT THE NATURE AND SCOPE OF TIllS INVEsnGATION. know _.Iotru:moonm *h Date Signed ;Z; EXHIBIT B RENTAL APPLICAUON . I I' ' . L.:--~ 17 S. HIGH ST. 'MECHBG. PA. 17055 PHONE/FAX 717.766-3841 E-MAIL: KBVB_H01'MAIL.COM . RENTAL APPLICATION The undersigned hereby makes apPlicafr ~for son to 'JJt.:::tJ; ~~ f) J~-, number located \. . Nit. .0 lib. ' 0"s- beginning on 20~ at a monthly rental of $ , I understand if he not make rent payment on time 1 will be called to make paymentforthwit. PLEASE GIVE YOUR RESIDENCE mSTORY CURRENT ADDRESS Month & Year Moved In Owner Phone07 (..,77-6 7.;l. t'~ Ir;;-C)- .3 ~-.35'oT Phone( ) PLEASE GIVE YOUR EMPLOYMENT INFORMATION EMPLOYER How Long? ADDRESS PERSON TO TALK TO SALARY $ uer lfthere are other sources ofincome you would llke us to consider, please Ust income, source and person (banker, Employer, etc.) Who we could contact for Confirmation. You do NOT have to reveal alimony. chtld support or spouse's annual Income unless you want us to consider it in this application. Phone( ) Amount $ Source PLEASE LIST YOUR BANK AND CREDIT REFERENCES YOUR BANKlSI Cltv-State llrliIJl;/i -I. _2. Phone( ) c// AccI. Num~ l CREDrrREFERENCES 1. 2. 3. CrrY~""ATE --------------------------------------------------------------------- --------------------------------------------------------------------- Acct.. Number HAVE YOU EVER: FILED FOR BANKRUPTCY? NO _YES BEEN EVICTED FROM TENANCY? NO YES WILLFULLY OR INTENTIONALLY REFUSED TO PAY RENT WHEN DUE? _NO _YES RENTAL APPLICATION , . .C- BRENNEMAN APARTMENTS 15 S. HIGH ST., MECHANICSBURG, PA. 17055 717-766-3841 VOICE/FAX KBVB_,@HOTMAIL.COM E-mail RENEWAL OF LEASE DAT~ ~ Re: NOTICE OF RENEWAL OF LEASE ~f} TENAN t,.; ~ PREMISES: Our records indicate that your lease will expire on~~~, C/ if . In accordance with the provisions ~~r lease, Landlord herewith gives notice ~roposes to ren_ your for a hef Jrm of one year to commence I; ~ '3 and end 0 !?t'T We are pleased to infonn you that there will be --.Q increase in your rent for the new lease tenn. Please return the enclosed copy of this letter to me, the landlord, within thirty (30) days from the date of this letter. Should you be willing to renew your lease for a further tenn, sign where Indicated, and this will constitute a legal, binding ag,,"ment. All conditions of the original lease will continue for the new term. Should you be unwilling to ren_ the tenn of the lease, please indicate, and your lease will expire as of the last day of your present tenn. Landlord will then re-Iet your premises to another tenant. EXHIBIT C . . RENEWAl OF LEASE Should the landlord nol near from you within thirty days (30) the terms of the lease will reven to PTermination ofli!!!ase" ctause in ~our presentlea~. Enclosure: Copy of this letter I und<>rstan~ I!lal my lease wm ""Pire on the foregoing feller i Ve~:J'1U 'fours, . " /, ", '~:; /,' .,.. . .0l,' /~-:Jt>;;J;;.ei!?iA~/7." ~_.."c..._' ~":/;-";:;'''''L_'''__ BRI')INE1lAN APARTMENTS ,'/ " I wish to renew my lease for a further term at no increased rental. Upon signing I have inspected and agree that the smoke alarm (51. fire extinguisher, apartment and grounds are foood to be in good condition or eJlceptlOns are fisted belOW '" space pl1Mded. I ~Ilso agree that Ihere are -.......- ~ ~ -~~~ /'"' TEN"AN I - DATE ("". ~, 07 TENANT I do not wish to renew my lease for a 'further term at no increased r(mtat TENANT DATE TENANT EXCEPTIONS . . n 1'-.' 0 C:",:> c- c:-,::) -n "''' --.", ...\ ::::0 ..,- -n f~" ;;0 .- r= -;; -~ ~) '~~) .r . ~;~ , ~.. ' ~\ ) C5 :1 - ..~ (Jl ,-- KEN BRENNEMAN VIRGINIA BRENNEMAN plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. NO: 04-1161 CIVIL MARGARET FITZPATRICK Defendant CIVIL ACTION - LAW TO: PLAINTIFFS 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 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 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. Cumberl.and County Bar Association Lawyer Referral. Service 32 South Bedford Stre,et Carl.isl.e PA l.7013 Tel.ephone: (717) 249-3166 KEN BRENNEMAN VIRGINIA J. BRENNEMAN Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COt::NTY, PENNSYLVANIA VS. : NO. 04.1161 CIVIL MARGARET FITZPATRICK Defendant : CIVIL ACTION - LAW ANSWER TO COMPLAINT AND NEW MATTER AND NOW, comes the Defendant, Margaret Fitzpatrick, by and through her attorney, Gregory J. Katshir, Esquire, with the following Answer to Complaint and New Matter and avers as follows: ANSWER 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Paragraph 5 of the Complaint is denied. After reasonable investigation, Defendant is without information as to the truth of the averments and hence it is denied and proof is demanded at the time of trial and proofthereof is demanded at the time of trial. 6. Paragraph 6 of the Complaint is specifically denied and strict proof thereof is demanded at the time of trial. 7. Paragraph 7 is admitted in part and denied in part. It is admitted that plaintiffs leased the premises to Defendant's son pursuant to a written lease and that Exhibit A represents a copy of said lease agreement. However, it is denied that Plaintiffleased the premises to Defendant's son based upon defendant's guarantee to pay rent and strict proof thereof is demanded at the time of trial. Additionally, it is specifically denied that the exhibit attached and identified as "Exhibit B" represents a guarantee executed by Defenolant. The exhibit is a document entitled "Rental Application" that has no legally binding effect. Pursuant to the document, Plaintiffs were requesting credit information of Defendant. 8. Paragraph 8 is admitted. By way of further answer, Defendant paid rent for her son for one month simply as a favor to her son so that he would not be evicted from his apartment. 9. Paragraph 9 is admitted. By way of further answer, the renewal oflease was executed solely by Defendant's son. 10.Paragraph 10 is denied. After reasonable investigation, Defendant is without information as to the truth of the averments and hence it is denied and proof is demanded at the time of trial. 11.Paragraph 11 is admitted. 12.Paragraph 12 is admitted to the extent that Plaintiff has demanded payment from Defendant however, it is specifically denied that Defendant has any responsibility to pay said rent. 13. Paragraph 13 is admitted in part and denied in part. After reasonable investigation, Defendant is without information as to the truth ofthe averments regarding how much money is owed by Richard G. Castle, III and hence it is denied and proofthereofis demanded at the time of trial. It is admitted however that Richard G. Castle, III, and not Defendant, would owe any monies due. 14.Paragraph 14 and 15 attempt to set forth conclusions oflaw to which no responsive pleading is required. WHEREFORE, Defendant requests this Honorable Court to dismiss Plaintiffs Complaint. NEW MATTER 15.At no time has Defendant executed any written guarantee of payment of her son's debts. The document attached to the Complaint and identified as "Exhibit B" is simply a consent to investigate Defendant's credit history. Further, Defendant denies providing an oral promise to pay the, debts of her son. 16. Pursuant to the Statute of Frauds, 33 P.S. Section 3, any agreement to be responsible for the debt of another must be in writing. 17. Because no written guarantee exists, and any oral promise to pay is unenforceable, the Complaint fails to state a claim for which relief can be granted. 18.Additionally, Defendant's son executed a subsequent renewal oflease on June 30, 2004. The written renewal was for a one year term. Defendant was not a party to that contract nor did she have knowledge that Plaintiffs and her son were entering into such a lease.. 19. Plaintiffs allege rent due to them was owed from Octoher 2003 through March 2004. Said rent was due during the term provided for in the written renewal of lease executed by Defendant's son and Plaintiffs. 20. Therefore, assuming, arguendo, that Defendant had previously executed a written guarantee, the subsequent lease executed by PIaintiff and Defendant's son would extinguish any obligation during the term of the original lease. WHEREFORE, Defendant requests this Honorable Court to dismiss Plaintiffs Complaint. Respectfully submitted, , ' 1M--- Gregory. . Katshir, Esquire Attorney for Defendant PA ID#61967 900 Market Street Lernoyne P A 17043 (717) 763-8183 VERlFICA nON I verify that the statement made in this pleading are hue and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904, relating to unsworn falsification to authorities. t~1 (I/u if Dat ./ ""' , C) r' ~,::'; :'-~.:j .,...... '. "'> c;;;;) C.:"" ~ o ., -I :r 1"i'i1J --.:trn ;:::.Ty 2:~(~ (_:~~~ ,_~';-, fTl ~!:; ."J,J -< :::<;: ::c..::.;, --< "., CJ :-G ~~'j~ N en KEN BRENNEMAN VIRGINIA J. BRENNEMAN : IN THE COURT OF COMMON PLEAS OF : CUMBERLAN][) COUNTY, PENNSYLVANIA PLAINTIFFS CIVIL ACTION, LAW V, MARGARET FITZPATRICK DEFENDANT NO, 04-1161 CIVIL REPLY Plaintiff answers Defendants NEW MATTER as follows: 15. Exhibit A speaks for itself 16. TIlls allegation is a conclusion oflaw whiich requires no response. 17. This allegation is a conclusion oflaw whiich requires no response. 18. It is admitted that defendant's son execute,d a renewal of his lease on June 30, 2004 for a one year term. As to the allegation that defendanlt had no knowledge ofthe renewal of the release, after reasonable investigation plaintiff is without sufficient knowledge to form an opinion as to the truth of the averment and proof is demanded. 19. It is admitted the unpaid rent was due for the period following renewal of the lease. 20. TIlls allegation is a conclusion oflaw whi,ch requires no response. WHEREFORE plaintiff demands judgment of,defendant. \" P ('I:"~ \r"\ Jo . Eakin Att y for Plaintiff ID # 06351 Market Square Building Mechanicsburg, PA 17055 - KEN BRENNEMAN VIRGINIA J, BRENNEMAN : IN THE COURT OF COMMON PLEAS OF : CUMBERLANn COUNTY, PENNSYLVANIA PLAINTIFFS CIVIL ACTION, LAW V, MARGARET FITZPATRICK nEFENnANT : NO. 04-1161 CIVIL VERIFICATION I verify that the statement made in this reply are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904, relating to unsworn falsification to authorities. ~~/~ ~~~ Kenneth Brenneman -- (:'"") '" 0 = (~ ~ c.::;! " .r- '- C:.:: z I ill \i t..~ c r:.J ..{..,- .--1 -'. 0::> KEN BRENNEMAN VIRGINIA BRENNEMAN Plaintiffs ) IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ) : NO. O'l-I/I,.I CIVIL ) : CIVIL ACTION - LAW VS. MARGARET FITZPATRICK Defendant PETITION FOR APPOINTMRNT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: JOHN M. EAKIN, Counsel for the Plaintiff in the above action, respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of the Plaintiff in the action is $3,375.00 + interest and costs The counterclaim of the Defendant is None The following attorneys are interested in the case(s) as counselor are otherwise disqualified to sit as MbitnUo~: John M. Eakin and Gregory J. Katshir WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrato~ to whom the case shall be submitted. < A~D NOW, 9'~L J8 .,200';, in consideration of the foregoing petiti~n, '--ZJ" 11: I~ /Ai!JAIJ( L< : Esqwre, /v/l/<: ,.6~__ , Esqwre, and (_~~ ~9SqUire, are appointed arbitrato~ in the above-captioned action (or actions) as prayed for. J. A:),':'<~' ,,; n:-!'7 III .' i ''-' ;;",1 n, '.- U:,.; ,'""' t-l,n? ~". .1 0\- t:. ~~, ~2 ~ " _::1 ~ r; ~, ~ .. \ ~ l.; ~ ;', ~ \...~ UI '"'-, t ",J,",,_'_ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, (')t{ -II i,' NOTICE OF APPEAL FROM AWARD OF BOARD OF ARBITRATORS TO THE PROTHONOTARY: Notice is given that t"IitW-.uT Flrz.,*~Wt. appeals from the award of the board of arbitrators entered in this case on ~OU{"~'a~ ~, 200Ll A jury trial is demanded'E;ZS. (Check box if a jury trial is demanded. Other wise jury trial is waived. 'I I hereby certify that: 1. The compensation of the arbitrators has been paid, or 2. NOTE: The demand for jury trial on appeal from compulsory arbitration is governed by Rule 1007.1 (b), (b) No affidavit or verification is required. 0 ""'" 0 c:::> c: = .1 ;.~ ,J..- 0 :?, 1"""'"1 (J r'l1 r' I "'0 gl TI.I 0"\ C) J.) -"n ~~ "-t''tI'P -... ':'::' N 0) r I Lt. No .'185 12/02 ' 04 15: 02 ID : MPLS CARll SLE OFF I CE FAX:?172438026 PAGE 2 ~ Vl:rtt..v ~~6HV Vf tJ..L-- Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA v. N\. ~f 1..{)j4/fv: .L '\ Dt:fendants () It ,,[l <tt ( NO. 1 CIVIL TERM PETITION TO PROCEED IN FORMA PAUPERIS The Petitioner in the above~captioned matter respectfully petitions this Court for permission to proceed in fbrma pauperis, As set torth in the attached Affidavit, which is incorporated herein by reference, Petitioner is unable to pay the fees and costs necessary to commence these proceedings. WHEREFORE. Petitioner requests that this Court enter an order permitting her to proceed in forma pauperis. / ?- .Jo ..A:J Y hate VM , Petitioner 11 Lt: No .'185 12/02 '04 15: 02 ID : MPLS CARLI SLE OFF I CE FAX:7172438026 PAGE 3 !/%(.AV~ trr tv!- Plaintiff : IN THE COURT OF COMMON PLEAS OF VS, : CUMBERLAND COUNTY. PENNSYL VANIA : It"! : NO ,0 Y - CIVIL TERM ~ d-t -{-zerfefe~~.S APFIDA VIr IN SUPPORT OF PETITION TO PROCEED IN.FORMA PAUPERIS 1. I am the 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. 1 represent that the information below relating to my ability to pay tile fees and coses is true and correct. (a) Name: Address: (b) Social Security Number: If you are presently employed, state Employer: ~rv Address: Salary or wages per month: Type of work: FILE No.785 12/02 '04 15:03 ID:MPLS CARLISLE OFFIl~ FAX:7172438026 PAGE 4 If you are luesemly unemployed, state Date of last employment: t;(~ Salary or wages per month: Type of work: (c) Other income within the past twelve months Business or profession: Other self-employment: Interest: Dividends: Pension and annuities: Social Security benefits: ? ? 5--' Support payments: Disability payments: Unemployment compensation and !>upplemental benefits: Workman's compensation: Public Assistance: Other: (d) Other contrihutions to household support (Wife)(Husband) Name: If your (husband) (wife) is employed. state Employer: , .-- "V.lW l.C/VC. 'U4 1b:03 ID:MPLS CARLISLE OFFICE Salary or wages per month: Type of work: ContribuliollS from children: (e) Property owned Cash: Checking Account: Savings Account: Certificates of Deposit: Real Estate (including home): Motor vehicle: Make_ Cost Stocks; bonds: Other: (f) Debts and obligations Mortgage: Renc__ Loans: Monthly Expenses: Year Amount owed (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if any' FAX:7172438026 PAGE 5 r-~ ) t i \ i \ I lLC. 11l0. (~~ 12/02 '04 15:03 ID:MPLS CARLISLE OFP^E FAX:7172438026 PAGE 6 Namt:: I fJ~ Age: 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 aTe made subject to the penalties of 18 Pa, C,S, 49041 relating to unsworn falsification to authorities. Date: \ -;)..- (,--0 <{ (&~1~ ___r__ --:-.-:.A "< l',,> \.-:;:> c:.:;) o -1"1 .-1 :T: 'J 111 f-~ -n rn 'l} CJ :~~ ~~~ 2~ ;:';~ :-;.-l :n -< LJ r"'" (~ , en -;:) -"."", _&!" l)? 1"." CO .... :/7 Ie L ,{ I~")-U~ i-/~/~.j- <.-4'1-^ ~ \ V . ,""/.-~ /_t' C<:-<'-1 ~'- '''/;i& nttk--?,:-1 L~... Plaintiff In The Court of Common Pleas of Cumberland /A;/;'U <; cl<.€ l ;; ;:, rb fu, · { ,/ .h' Defendant ,'1,,/ County, Pennsylvania NO.....!::L- lit. I Civil Action - Law. C/ Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution ofthe United States and the Constitution of this Commonwealth and that we will discharge the duties of our office 'th ~~e~~:,/<,r.;'i~~ A/20 Signature < ~ignature , , 1 ,: / I //C/C h. If d dc:' ///) Name (Chairman) i ,- -', ,\ Q",,':'/ u.. (j , Name l;. J; tJ " I It.,.) / L!oA.rc i) ,; It 7 N~me Law Firm '\?7"iA< I.. c, "" O~iv s Law Finn {low'tl1(}ei', &'-/~V ftwLj~ Law Firrd f t s...:;:~ (-k."iOvel Sf, .^..ddress ,,'17 /(t)', .5/ ArJrJrf'~~ ) w, vv1C1',,, SrIr-i..+ ---'"~---"-'-'-"'---~--~ Address /--;/3 Sl.,;rIJ"lPlI4$f",...., ?ill~c)) C..Qt(:r~ Pk !701'"S Zip City, Zip City, Zip 11,/11 vlfvfrli /;1,3'7':; We, the u!ldersigned arbitrators, having been duly appointed alld sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) /~;:'h~ City, (/""- " t 0-,,,,'1 ,,' ...cf..e /) Ic~ C:/Tj~' ~f .J ~3 3 7 E,'" ' /' v _A-~ ..--t"" A-L C&'1'M '~''--f..-<.--, , Arbitrator, dissents. (Insert name if applicable.) Date of Hearing: /6',/s-' o..~ /c)/F [?y (Chairman) -'7"~""" .' ':ra" ;-. ,:" ,..~. ,"., "."<",,,;", ..210'" ";,,~<,,: ",i<;',,,'''\\,..,'...-;, ,c, .,..'",..'..',,' ,-;,....,',...,,'" .,<:t.:~. ',' .... I '()iW /' .., Date of Award: Notice of Entry of Award Now, the '/!!:: day of~", k. , 20 ;) 'I ' at "I: J 0 , P.,M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ 2.'10, I1U ~'A R /?J By: C)y,v,. 0 /Juf'ffl- Prothonotary Deputy "T- ' ~:-:-,\ n -:...: .;;;:- C> .\ Ie'...?" I~ U"'-< "" '.,_ '1 [jA y~""-"" i3-v ,i j.U .0' C~, [,,/j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V AN1A NO. (J '-(- / / {PI , TERM l(~{'15'{u~f /:;;(j/t:< t2<~ ( 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 that we will discharge the duties of our office with fidelity. /,," ./ ,/~J , ~'/'-t 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.) / I ,/ ~ ( 4 // .....,' t"'- -, (_.:...0 c'/f C:1/ ,/ /L,/' ;-_1/ Ci--<-"f..-1. -< ~/-..! / ./' /' / #' / _.- (1, vv< C?,~.7 0,.1 337) ,J .i:-.'\,A ;(& Date of Award: /0 / f? . (.17 (insert name ifapP,licahle.V', , ,', ' ,7-,'/- ./ ,.1,,' / ..." / , ,,/ ~>(;"I" '7 C' v'- r;e-...t'c_.f<...._'-- ~nnan , l~l\", [/\ /I,~ Arbitrator, dissents. Date of Hearing: / ',. (' f', ,:' 'I NOTICE OF ENTRY OF A WARD Now, the clay of , 20_, at _:_' _.M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Artibitrators' compensation to be Paid upon appeal: Prothonotary $ 290.00 By: Deputy _ '~.. ,.' '1 ,"'," .... (v~<(("-'. /1><:I."q f )1/ f\<"Co-I~ . l~/~' /(. /) /' ,U/y I:')C~' l~ ( /f"! ~ 1,; /4 J!~ ~ ~"'( -i> A/u, ~- ..:) / 'f ? / "-i ) ;<'1 Lei III? J 15' (/ /(/3