HomeMy WebLinkAbout08-6515ROBERT D. KODAK, ESQUIRE
KODAK & IMBLUM, P.C.
407 N FRONT STREET, PO BOX 11848
HARRISBURG, PA 17108-1848
(717) 238-7159 Attorney for Plaintiff
TIMOTHY HOGG IN THE COURT OF COMMON PLEAS
Plaintiff Cumberland COUNTY, PENNSYLVANIA
v r NO. a8 - toS15 U'Ji t
7W
RICHARD A. BINNER, JR.
and RACHEL AMON CIVIL ACTION - LAW
Defendant(s)
NOTICE'
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set
forth in the following pages, yo ust take action within twenty (20) days after this
complaint and notice are served , ring a Nd ppearance personally or by an
attorney and filing in writing with t your or objections to the claims set
forth against you. You are warned that'i you faithe 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, 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 LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
717-249-3166
AVISO
LISTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las
demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion
dentro de los proximos veinte (20) dias despues de la notification de esta Demanda y
Aviso radicando personalmente o por medio,de un abogado una comparencencia escrita
y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas
presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion
como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier
suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio
solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso
adicional. Usted puede perder dinero o propiedad u otros derechos importantes para
usted.
LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI USTED NO TIE`NE UN ABOGADO, LLAME O VAYA A LA
SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA
DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE
AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A
PERSONAS QUE CUALIFICAN.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
717-249-3166
FAIR DEBT COLLECTION PRACTICES ACT NOTICE
TO: Rachel Amon
1. Amount of Debt: $3,585.55 Plus interest and attorney fees
2. Name of Creditor: Timothy Hogg
3. Unless you, as the consumer, within thirty (30) days after receipt of this Notice,
dispute the validity of the debt, or any portion thereof, the debt will be assumed
to be valid by me.
4. If you, as the consumer, notify me in writing within the thirty (30) day period that
the debt, or any portion thereof, is disputed, I will obtain verification of the debt
or a copy of a Judgment entered against you and will mail the same to you for
your benefit.
5. The address of Timothy Hoag is:
c/o: Kodak & Imblum. P.C. PO BOX 11848, Harrisburg PA 17108
6. The attached correspondence from me to you is for the purpose of collecting
the above stated debt. Any information I obtain from you will be used for that
purpose.
ROBERT D. KODAK, ESQUIRE
KODAK & IMBLUM, P.C.
PO BOX 11848
HARRISBURG, PA 17108-1848
ATTORNEY FOR: Timothy Hogg
DEBT COLLECTOR
TIMOTHY HOGG
v
RICHARD A. GINNER, JR.
and RACHEL AMON
IN THE COURT OF COMMON PLEAS
Plaintiff Cumberland COUNTY, PENNSYLVANIA
NO. 6?- GSIS a-m-A %
CIVIL ACTION - LAW
Defendant(s)
COMP.,LAINT
The Plaintiff, TIMOTHY HOGG, by his attorneys, KODAK & IMBLUM, P.C., brings
this action ofAssumpsit againstthe Defendants to recoverthe sum of THREE THOUSAND
FIVE HUNDRED EIGHTY-FIVE DOLLARS AND FIFTY-FIVE CENTS ($3,585.55), along
with interest thereon at the statutory rate friom February 2, 2008, upon a cause of action
of which the following is a statement:
1
2
3
The Plaintiff, TIMOTHY HOGG, is, a an adult individual having an address of PO
Box 624, New Cumberland, PA 17070.
The Defendant, RICHARD A. BINNER, JR., is an adult individual residing at 1761
Kings Arms Court, New Cumberland, Cumberland. County, Pennsylvania
17070.
The Defendant, RACHEL AMON, is an adult individual residing at 1761 Kings
Arms Court, New Cumberland, Cumberland County, Pennsylvania 17070.
F:\USER\ROBIN\CCP&DI CMPS\CCP COMPLAINTS\HOGG PROPERTIES 34091.wpd 2
4. On or about March 20, 2002, Defendant Binner entered into a written Rental
Agreement with Plaintiff, a true and correct copy of which is attached hereto,
marked Exhibit "A" and made a part hereof, whereby Defendant would rent the
premises known and numbered as Apt 5, 2109 Princeton Avenue, Camp Hill,
Cumberland County, Pennsylvania, at the rate of Five Hundred Fifty Dollars
($550.00) per month.
5. On or about March 20, 2002, Defendant Amon entered into a written Rental
Agreement with Plaintiff, a true and correct copy of which is attached hereto,
marked Exhibit "B" and made a part hereof, whereby Defendant would rent the
premises known and numbered as Apt 5, 2109 Princeton Avenue, Camp Hill,
Cumberland County, Pennsylvania, at the rate of Five Hundred Fifty Dollars
($550.00) per month.
6. Defendants defaulted the under Lease Agreement with Plaintiff by vacating the
premises before the agreed upon lease term, i.e. on or about August 2002, without
notice, and intentionally causing damage to the leased premises.
7. After crediting Defendants' Security Deposit, Plaintiff incurred additional expenses
for unpaid rent, late charges, and repairs, including labor and materials, to the
leased premises, to the total amount of Two Thousand Four Hundred Six Dollars
and Forty-One Cents ($2,406.41) as set forth on Plaintiffs January 3, 2008
F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\HOGG PROPERTIES 34091.wpd 3
Statement of Account attached hereto, marked Exhibit "C" and made a part
hereof.
8. Due to the default of Defendants, and pursuant to the terms and conditions of the
Residential Lease Agreement executed by Defendants and attached as Exhibit "A"
hereto, attorney's fees and collection costs in the total amount of One Thousand
One Hundred Seventy-Nine Dollars and Fourteen Cents ($1,179.14) have been
added to said account.
9. Plaintiff frequently demanded payment from Defendants of said amount due and
owing as aforesaid, but Defendants refused and neglected and still refuse and
neglect to pay said amount or any part thereof.
WHEREFORE, Plaintiff brings this suit to recover from Defendants the sum of
THREE THOUSAND FIVE HUNDRED EIGHTY-FIVE DOLLARS AND FIFTY-FIVE CENTS
($3,585.55), together with interest as set forth herein.
Respectfully submitted,
KODAK & IMBLUX-P:
Robert D. Kodak, Esquire
407 North Front Street
Post Office Box #11848
Harrisburg, PA 17108-1848
(717) 238-7159
Attorney ID No. 18041
Attorney for Plaintiff
RENTAL AGREEMENT
THIS IS A LEGAL DOCUMENT. By signing, the Tenant agrees that
Tenant has read this lease and has had the opportunity to ask
questions about the lease.
The Text and Landlord agree that
THIS IS A LEASE.
Timothy Hogg is the Landlord.
Richard A Binner, Jr. and Rachel Amon is the Tenant.
This lease is for Apartment # 5 at 2109 Princeton Ave, Camp Hill,
PA 17011
This lease begins on April-1, 2002.
This lease ends on March 31, 2003. Tenant must Notify Landlord in
writing thirty days before the end of this lease that Tenant is
moving out.
If Tenant does not notify Landlord that he/she is moving out, the
lease will automatically become a month-to-month lease. In order
to end the lease during the month-to-month periods, the Tenant must
notify Landlord in writing at least 30 days before Tenant intends
to move out. A full month's rent shall be due for any partial
month in which Tenant occupies the apartment.
The total rent for this lease is $6600(yearly)
payable in monthly installments of $550
Rent is due in advance on or before the FIRST day of each month of
this Lease. Rent is to be mailed to the following address:
Tim Hogg
PO Box 624
New Cumberland, PA 17070
Rent Checks or Money Orders are to be made out to "Tim Hogg" only.
SECURITY DEPOSIT: The Tenant has deposited an amount equal to one
month's rent ($550) as a SECURITY DEPOSIT. This security deposit
is held by the Landlord and applied to any damages to the apartment
caused by Tenant, his/her family, guests or pets. The Security
deposit can also be used for any damages from breaking the lease,
Tenant's unpaid bills, or not paying part of the rent due.
Tenant MAY NOT USE SECURITY DEPOSIT AS RENT
INCREASED RENT IF PAID AFTER THE FIRST DAY OF THE MONTH: Increased
rent begins the FIRST DAY of the month. A ten dollar rent charge
begins on the first day, and five dollars for every day after the
1
EXHIBIT A
first day of the month. These charges cover increased
administrative costs and damages.
ACCEPTANCE OF PROPERTY: The Tenant has examined the apartment and
the apartment is in satisfactory condition. The apartment is
leased in AS-IS condition. Tenant agrees that no agreement is made
to redecorate, repair or improve the apartment unless specifically
written here:
SMALL REPAIRS DURING TENANCY: Tenant is responsible for small
repairs such as stuck windows, loose screws, backed up
toilets/bathtubs/sinks. Tenant is also responsible for lightbulbs
and fuses as they become necessary. Landlord shall decide what
repair is considered "small."
UNDISCLOSED REPAIR
any condition that
Landlord. In the
needed repair or
responsibility sha]
- It is the Tenant's responsibility to report
could be dangerous or wasteful immediately to
event Tenant has not notified Landlord of a
condition, any liability and/or financial
.1 be assumed by Tenant.
CLEANLINESS: Tenant agrees to keep apartment clean, avoid a
garbage build-up and place garbage in outside receptacles. Tenant
agrees that any pest infestation as a result of his/her apartment's
not being kept clean is breaking the lease. Any pest control
services will be charged to the Tenant.
OCCUPANCY AND USE: The apartment is for use as a residence by the
named Tenants who have signed this lease and their children.
Tenant will not use this apartment for any type of business.
Tenant will not use the apartment for disorderly or unlawful
purposes, or in any manner offensive to others. Tenant will obey
all Federal, State, County and Local laws.
APPLIANCES: Any appliances which are in the apartment are there at
the convenience of the Landlord. Landlord agrees to remove
appliances if the Tenant asks for removal. The repair and
maintenance of all appliances is the responsibility of the Tenant.
RULES: "Rider All contains a list of rules that the Tenant shall
follow. If Tenant Breaks any of these rules, he/she is breaking
the lease.
UTILITIES - Landlord is responsible for paying the following:
water, garbage, sewer,
Tenant is responsible for paying the following: Electric, cable,
telephone, gas, plus any other service acquired whether by law or
2
otherwise, not mentioned as a Landlord responsibility. If tenant in
the sole disgression of the landlord overuses or uses wastefully a
utility that is paid by landlord, the excess cost shall be assumed
by tenent.
Tenant EXPENSES: Landlord will not allow any deductions from the
rent or charges to any account of the Landlord for any purpose by
the Tenant.
CHANGES: No changes will be made, and no painting or redecorating
is done to the apartment without written permission from Landlord.
Tenant will not drive nails or screws into the walls or the
woodwork.
KEROSINE HEATERS: No kerosine heaters are allowed in the
apartment.
CHANGE OF Tenants: Only the Tenants named in this lease may use
the leased apartment. Tenant may not give the apartment to anyone
else to use. Tenant must request a new lease if different people
are in the apartment than those named on the lease. If Tenant is
transferred during mid tenancy, Landlord will reasonably look for
a new Tenant for the apartment in order to relieve Tenant of lease
responsibility. Landlord reserves the right to charge tenant for
time spent acquiring new tenant $25.00 per hour and cost of
advertising.
PETS: Pets are not allowed in the apartment without the written
permission of the Landlord.
INSPECTION: Landlord or his employees may enter the apartment at
any time for the following reasons:
1. To inspect the apartment
2. To make necessary repairs
3. To protect the apartment from damage
4. To show the apartment to prospective Tenants or buyers
MOVING OUT: Tenant will leave the apartment and all property of
the Landlord in good clean and operating condition, except for
ordinary wear and tear. Tenant will clean the apartment, including
any appliances, cabinets, baseboards, bathrooms, and remove all
trash from the apartment. Tenant to steam clean carpets before
move-out date and a receipt is to be turned in with the keys.
If cleaning and trash removal is not
will clean the apartment and remove
Tenant. A service fee of $25.00 per
the secuity deposit if tenant does
done by Tenant, the Landlord
trash at the expense of the
contractor shall be aplied to
not steam clean or properly
3
clean the apartment. Tenant will bring all keys to the Landlord
within 24 hours of moving from the apartment.
LIABILITY OF Landlord - Tenant agrees that Landlord shall not be
liable for property damage Or personal injury occurring in or
around the apartment unless the damage or injury results directly
from the Landlord's gross negligence.
BREAKING THE LEASE: If the rent is not paid when due, and/or the
Tenant does not perform in a manner consistent with this lease,
he/she shall have broken the lease. The entire rent due for the
rest of the lease is due and payable immediately. Any court fees,
attorney's fees, collection fees, fees for paying rent after the
first of the month, plus an amount equal to two month's rent for
damages and administrative costs shall also be due.
NOTICE TO QUIT: Tenant understands that he/she is giving up the
right to any ten day, fifteen day, thirty day, or ninety day notice
to quit lease. IF Tenant BREAKS THIS LEASE, EVICTION PAPERS CAN BE
IMMEDIATELY FILED IN COURT.
ITEMS LEFT IN THE APARTMENT BY Tenant: If the Tenant moves out of
the apartment and leaves belongings in the apartment, the ownership
of these belongings shall be given to Landlord. Landlord may do
whatever he wishes with these items.
PAYING LATE RENT: If Landlord allows Tenant to pay rent late or
Creak any rule at any time for any reason, this does not give
Tenant permission to pay late again or break the rules again.
NOTICE: This agreement is the Notice to Tenant of all rents due
and obligations of the Tenant. Tenant AGREES THAT NO ADDITIONAL
NOTICE OF RENT DUE IS NECESSARY,
STORAGE: No storage rights are given under this lease. The Tenant
agrees that neither the Landlord or his employees has any
responsibility for loss of any kind to the Tenant's property.
Tenant agrees that Landlord requires that Tenant buy RENTER'S
INSURANCE to cover damages to his/her personal property.
SEPARATE SECTIONS: The sections of this lease are separate. If a
court finds that any part of this lease is illegal for any reason,
that finding will not affect the remaining parts of the lease.
4
LEAD PAINT: Tenant acknowledges that he/she has been given a copy
of the US EPA booklet "Protect Your Family From Lead in Your Home°
and given time to read the information it contains. Landlord has
no knowledge of lead paint in the apartment although Lead paint was
commonly used before 1979. Any cracking or pealing paint must be
reported to Landlord immediately.
Tenant's Initials:
_/
RIDERS .(SPECIAL PROVISIONS): Special provisions in the attached
Riders are part of this lease.
ENTIRE AGREEMENT: This lease contains the ENTIRE AGREEMENT between
the Landlord and the Tenant. Neither the Landlord nor the Tenant
has agreed to do anything that is not written in this lease.
REPAIRS BY Landlord: If Landlord is to make repairs to the
apartment for damages that are not normal wear and tear, Landlord
is to be paid the actual cost of the repairs by an outside
contractor. If Landlord makes the repairs himself, he will be paid
$25.00 per hour plus the cost of materials to Landlord.
PARKING: Tenant shall abide by all parking signs around apartment
buildings.
Special_Parking_Instructions:_
THIS IS A LEGAL DOCUMENT. By signing, the Tenant agrees that the
Tenant has read this lease, has gone through the lease with the
Landlord and has had the opportunity to ask questions about this
lease.
Landlord
TIMOTHY HOGG DATE 'L D
Tenant (S) 414 - DATE .? 20 O 2-
DATE
DATE
5
Rider A
This rider is attached to and forms a part of the lease beginning
April I 2002 between Timothy Hogg, the Landlord, and Richard A
Binner, Jr, and Rachel Amon, the Tenant(s).
1. Payments of rent and other charges payable by Tenant shall be
payable to Landlord and due on the 1st dy of the month. If
received after the 1st day of the month, include a $10.00 initial
penalty plus $5.00 for each additional day this reflects.
Ia. Rent payments are to be made to Tim Hogg, PO Box 24 New
Cumberland, PA 17070-0624. Please make checks payable6to,"Tim
Hogg" only.
2. Tenant agrees that the premises are leased for use b,y Tenants
famil consisting of 3 persons which consists of
and children. adults
3. Tenants are reminded that they should carry adequate renter ,s
insurance to cover any losses or damage that may be sustained
during occupancy of the above apartment.
4. No motorcycles, motor bikes, truck caps, or snow mobiles
shall be permitted on the premises.
5. No boisterous parties or unnecessary noise permitted.
6. No antennas allowed on the premises. Only the Cable Tv
outlets provided shall be used.
7. No appliques shall be used on the surfaces.
8. Pictures shall be hung by using standard picture hangers.
Under no circumstances shall scotch tape be used to fasten
anything.
9. Tenant shall not park boat, trailer, or disabled vehicles on
property.
6
10. Tenant shall have two keys issued. Locks shall not be
changed or altered and keys shall not be duplicated.
11. Tenant shall not make any alterations, additions, or
improvements without prior written consent of the Landlord.
12. Tenant shall be responsible for small repairs (loose
screws, stuck window, backed up toilets etc.).
13. Upon vacancy of apartment, the appliances and cabinets must
be cleaned thoroughly before Tenant vacates said premises.
14. Upon vacancy of apartment, carpet must be steam cleaned and
a receipt must be turned in with the keys.
15. Tenants are responsible for maintaining smoke detector with
charged battery at all times (where applicable). Tenants are also
responsible for reporting any non working smoke detector
immediately to Landlord.
16. It is understood and agreed that the security payment in the
amount of 550 dollars provided for under the lease for this
premises has been paid. Under no circumstances may the Tenant
apply the security deposit to their last months rent.
16a. The security deposit will accrue interest at a rate of 1.75$
_yearly, accrued yearly, beginning after the first full year of
tenancy has been completed.
17. In the event Tenant has not notified Landlord of a needed
repair or condition, any liability and/or financial responsibility
shall be assumed by Tenant.
18. In the event that Landlord is to!make repairs to apartment
that under the terms and conditions of phis lease are not related
to normal wear and tear, Landlord is to be compensated for time
spent in the amount of $25.00 per hour, and materials at their cost
to Landlord.
19. Tenant will be charged $25.00 for any returned check. Late
fees will be applied to the date of restitution for said returned
check.
20. Extraordinary garbage (tires, furniture, mattresses,
appliances, etc.) is the responsibility of the Tenant to have
removed at Tenant's expense.
21. Additional Tenant responsibilities:
7
22. These rules and regulations shall constitute conditions of
tenancy, and violation thereof shall be a default under this lease.
It is further assumed that these rules do not violate Local, State
or Federal Law. In the aforementioned event, the regulation stated
herein will become null and void, thus rendering precedence to the
law.
y
Date ?--
Timothy Hogg
Tenant
Tenant
Tenant
8
Oct 25 2001 9:47AM HP LRSERJET FAX p.3
RENTAL AGREEMENT
THIS IS A LEGAL DOCUIEZUT. By signing, the Tenant agrees that
Tenant has read this lease and has had the opportunity to ask
questions about the lease.
The Twwat d Lazidl art age that,
THIS IS A LEASE.
Timothy Hogg is the Landlord.
Richard A Hisser, Jr. and Rachel Amon is the Tenant.
This lease is for Apartment # 5 at 2109 Princeton Ave, Camp Hill,
PA 17011
This lease begins on April 1, 2002.
This lease ends on March 31, 2003. Tenant must Notify Landlord in
writing thirty days before the end of this lease that Tenant is
moving out.
If Tenant does not notify Landlord that he/she is moving out, the
lease will automatically become a month-to-month lease. In order
to end the lease during the month-to-month periods, the Tenant must
notify Landlord in writing at least 30 days before Tenant intends
to move out. A full month's rent shall be due for any partial
month in which Tenant occupies the apartment-
The total rent for this lease is $6600(yearly)
payable in monthly installments of $550
Rent is due in advance on or before the FIRST day of each month of
this Lease. Rent is to be mailed to the following address:
Tim Hogg
PO Box 624
New Cumberland, PA 17070
Rent Checks or Money Orders are to be made out to "Tim Hogg" only.
SECURITr DEPOSIT: The Tenant has deposited an amount equal to one
month's rent ($550) as a SECURITY DEPOSIT. This security deposit
is held by the Landlord and applied to any damages to the apartment
caused by Tenant, his/her family, guests or pets. The Security
deposit can also be used for any damages from breaking the lease,
Tenants unpaid bills, or not paying part of the rent due.
Tenant MAY NOT USE SECURITY DEPOSIT AS RENT
INCREASED REST IF PAID AFTER TAR FIRST DAY OF THE HOWM: Increased
rent begins the FIRST DAY of the month. A ten dollar rent charge
begins on the first day, and five dollars for every day after the
EXHIBIT 6
Oct 25 2008 9:47AM HP LRSERJET FAX p.4
first day of the month. These charges cover increased
administrative costs and damages.
ACCRPTANM OF PROPERTY: The Tenant has examined the apartment and
the apartment is in satisfactory condition. The apartment is
leased in AS-IS condition. Tenant agrees that no agreement is made
to redecorate, repair or improve the apartment unless specifically
written here:
SMALL REPAIRS DURING TENANCY: Tenant is responsible for small
repairs such as stuck windows, loose screws, backed up
toilets/bathtubs/sinks. Tenant is also responsible for lightbulbs
and fuses as they become necessary. Landlord shall decide what
repair is considered "small."
UNDISCLOSED REPAIR - It is the Tenants responsibility to report
any condition that could be dangerous or wasteful immediately to
Landlord. In the event Tenant has not notified Landlord of a
needed repair or condition, any liability and/or financial
responsibility shall be assumed by Tenant.
CLEANLIMSS: Tenant agrees to keep apartment clean, avoid a
garbage build-up and place garbage in outside receptacles. Tenant
agrees that any pest infestation as a result of his/her apartment's
not being kept clean is breaking the lease. Any pest control
services will be charged to the Tenant.
OCCUPANCY AND USE: The apartment is for use as a residence by the
named Tenants who have signed this lease and their children.
Tenant will not use this apartment for any type of business.
Tenant will not use the apartment for disorderly or unlawful
purposes, or in any manner offensive to others. Tenant will obey
all Federal, State, County and Local laws.
APPLIA=RS: Any appliances which are in the apartment are there at
the convenience of the Landlord. Landlord agrees to remove
appliances if the Tenant asks for removal. The repair and
maintenance of all appliances is the responsibility of the Tenant.
RULES: "Rider A" contains a list of rules that the Tenant shall
follow. If Tenant Breaks any of these rules, he/she is breaking
the lease.
UTILITIES - Landlord is responsible for paying the following:
water, garbage, sewer,
Tenant is responsible-for paying the following: Electric, cable,
telephone, gas, plus any other service acquired whether by law or
2
Oct 25 2008 9:48AM HP LASERJET FAX p.5
otherwise, not mentioned as a Landlord responsibility. If tenant in
the sole disgression of the landlord overuses or uses wastefully a
utility that is paid by landlord, the excess cost shall be assumed
by tenent.
Tenant EXPENSES: Landlord will not allow any deductions from the
rent or charges to any account of the Landlord for any purpose by
the Tenant.
CgANGES: No changes will be made, and no painting or redecorating
is done to the apartment without written permission from Landlord.
Tenant will not drive nails or screws into the walls or the
woodwork.
XEROSINE HEATERS: No kerosine heaters are allowed in the
apartment.
CHANGE OF Tenants: Only the Tenants named in this lease may use
the leased apartment. Tenant may not give the apartment to anyone
else to use. Tenant must request a new lease if different people
are in the apartment than those named on the lease. If Tenant is
transferred during mid tenancy, Landlord will reasonably look for
a new Tenant for the apartment in order to relieve Tenant of lease
responsibility. Landlord reserves the right to charge tenant for
time spent acquiring new tenant $25.00 per hour and cost of
advertising.
PETS: Pets are not allowed in the apartment without the written
permission of the Landlord.
INSPECTION: Landlord or his employees may enter the apartment at
any time for the following reasons:
1. To inspect the apartment
2. To make necessary repairs
3. To protect the apartment from damage
4. To show the apartment to prospective Tenants or buyers
MOVING OUT: Tenant will leave the apartment and all property of
the Landlord in good clean and operating condition, except for
ordinary wear and tear. Tenant will clean the apartment, including
any appliances, cabinets, baseboards, bathrooms, and remove all
trash from the apartment. Tenant to steam clean carpets before
move-out date and a receipt is to be turned in with the keys.
If cleaning and trash removal is not done by Tenant, the Landlord
will clean the apartment and remove trash at the expense of the
Tenant. A service fee of $25.00 per contractor shall be aplied to
the secuity deposit if tenant does not steam clean or properly
3
Oct 25 2008 9:48AM HP LRSERJET FAX p.G
Clean the apartment. Tenant will bring all keys to the Landlord
within 24 hours of moving from the apartment.
LIABILITY OF Landlord - Tenant agrees that Landlord shall not be
liable for property damage ;or pearsonal injury occurring in or
around the apartment unless the damage or injury results directly
from the Landlord's gross negligence.
BREAKING TSB LEASE: If the rent is not paid when due, and/or the
Tenant does not perform in a manner consistent with this lease,
he/she shall have broken the lease. The entire rent due for the
rest of the lease is due and payable immediately. Any court fees,
attorney's fees, collection fees, fees for paying rent after the
first. of the month, plus an amount equal to two month's rent for
damages and administrative costs shall also be due.
NOTICE TO QUIT: Tenant understands that he/she is giving up the
right to any ten day, fifteen day, thirty day, or ninety day notice
to quit lease. IF Tenant BREAKS THIS LEASE, EVICTION PAPERS CAN BE
IMMEDIATELY FILED IN COURT.
ITFM LEFT IN THE APARTIONT BY Tenant: If the Tenant moves out of
the apartment and leaves belongings in the apartment, the ownership
of these belongings shall be given to Landlord. Landlord may do
whatever he wishes with these items.
PAYING LATE RENT: If Landlord allows Tenant to pay rent late or
break any rule at any time for any reason, this does not give
Tenant permission to pay late again or break the rules again.
NOTICE: This agreement is the Notice to Tenant of all rents due
and obligations of the Tenant. Tenant AGREES THAT ILWN ADDI IONAh,
NOTICE O RENT DU8 IS CES AR
STORAGE: No storage rights are given under this lease. The Tenant
agrees that neither the Landlord or his employees has any
responsibility for loss of any kind to the Tenant's property.
Tenant agrees that Landlord requires that Tenant buy RENTER'S
INSURANCE to cover damages to his/her personal property.
SEPARATE SECTIONS: The sections of this lease are separate. If a
court finds that any part of this lease is illegal for any reason,
that finding will not affect the remaining parts of the lease.
4
Oct 25 2COS 9:48AM HP LASERJET FAX p.7
LEAD PAINT: Tenant acknowledges that he/she has been given a copy
of the US EPA booklet "Protect Your Family From Lead in Your Home",
and given time to read the information it contains. Landlord has
no knowledge of lead paint in the apartment although Lead paint was
commonly used before 1979. Z,ny cracking or pealing paint must be
reported to Landlord immed' tely.
Tenant's Initials :/
RIDERS (SPECIAL PROVISIONS): Special provisions in the attached
Riders are part of this lease.
EM RE AGE: This lease contains the ENTIRE AGREEMENT between
the Landlord and the Tenant. Neither the Landlord nor the Tenant
has agreed to do anything that is not written in this lease.
REPAIRS BY Landlord: If Landlord is to make repairs to the
apartment for damages that are not normal wear and tear, Landlord
is to be paid the actual cost of the repairs by an outside
contractor. If Landlord makes the repairs himself, he will be paid
$25.00 per hour plus the cost of materials to Landlord.
PARKING: Tenant shall abide by all parking signs around apartment
buildings.
Special_Parking Instructions:y, aA ST-?.?3
THIS IS A LEGAL DOCIIMZIT, By signing, the Tenant agrees that the
Tenant has read this lease, has gone through the lease with the
Landlord and has had the opportunity to ask questions about this
lease.
Landlord
TIMOTHY HOGG DATE
Tenant (s) DATE ?j
DATE _
DATE
5
Oct 25 2008 9:48AM HP LASERJET FAX
Rider A
P. e
This rider is attached to and forms a part of the lease beginning
April 1. 2002, between Timothy Hogg, the Landlord, and Richard A
Binner, Jr. and Rachel Amon, the Tenant(s).
1. Payments of rent and other charges payable by Tenant shall be
payable to Landlord and due on the 1st dy of the month. if
received after the 1st day of the month, include a $10.00 initial
penalty plus $5.00 for each additional day this reflects.
Ia. Rent payments are to be made to Tim Hogg, PO Box 624, New
Cumberland, PA 17070-0624. Please make checks payable to "Tim
Hogg" only.
2. Tenant agrees that the premises are leased for use by Tenants
family consisting of 3 persons which consists of "? adults
and _ L children.
3. Tenants are reminded that they should carry adequate renter's
insurance to cover any losses or damage that may be sustained
during occupancy of the above apartment.
4. No motorcycles, motor bikes, truck caps, or snow mobiles
shall be permitted on the premises.
5. No boisterous parties or unnecessary noise permitted.
6. No antennas allowed on the premises. Only the Cable TV
outlets provided shall be used.
7. No appliques shall be used on he surfaces.
8. Pictures shall be hung by using standard picture hangers.
Under no circumstances shall scotch tape be used to fasten
anything.
9. Tenant shall not park boat, trailer, or disabled vehicles on
property.
6
Oct 25 2008 8:48RM HP LRSERJET FAX
' p.9
10. Tenant shall have two keys issued. Locks shall not be
changed or altered and keys shall not be duplicated.
11. Tenant shall not make anv alterations, additions, or
improvements without prior written consent of the Landlord.
12. Tenant shall be responsible for small repairs (loose
screws, stuck window, backed up toilets etc.).
13. Upon vacancy of apartment, the appliances and cabinets must
be cleaned thoroughly before Tenant vacates said premises.
14. Upon vacancy of apartment, carpet must be steam cleaned and
a receipt must be turned in with the keys.
15. Tenants are responsible for maintaining smoke detector with
charged battery at all times (where applicable). Tenants are also
responsible for reporting any non working smoke detector
immediately to Landlord.
16. It is understood and agreed that the security payment in the
amount of 55_Q dollars provided for under the lease for this
premises has been paid. Under no circumstances may the Tenant
apply the security deposit to their last months rent.
16a. The security deposit will accrue interest at a rate of 1.758
yearly, accrued yearly, beginning after the first full year of
tenancy has been completed.
17. In the event Tenant has not notified Landlord of a needed
repair or condition, any liability and/or financial responsibility
shall be assumed by Tenant.
18. In the event that Landlord is to make repairs to apartment
that under the terms and conditions of this lease are not related
to normal wear and tear, Landlord is to be compensated for time
spent in the amount of $25.00 per hour, and materials at their cost
to Landlord.
19. Tenant will be charged $25.00 for any returned check. Late
fees will be applied to the date of restitution for said returned
check.
20. Extraordinary garbage (tires, furniture, mattresses,
appliances, etc.) is the responsibility of the Tenant to have
removed at Tenant's expense.
21. Additional Tenant responsibilities:
7
Security Deposit
Statement
JAN 3 2008
Richard Binner
2109 Princeton Ave 5
Camp Hill, PA 17011
2109 #5: 2109 Princeton Ave 5, Camp Hill PA 17011
Date
03/20/02 Description
Deposit Amount _ __ ___
ount
I Am Memo
- -- $550.00:------- L I - - -
In Account
03/20/02 Payment Toward Deposit $550.00 $0.00
05/05/03
05/05/03 Charge For Damage/Other
Charge For Damage/Other $65.00 Late charge, 7/02
$100.00 Cleaning $550.00
$485.00
05/05/03 Charge For Damage/Other $609.60 Painting Labor, 63.5 hours @ $12/hour,
$38 60)
($224.60)
Prorated 4 of 5 years, 27 nail holes, 5 wall
05/05/03
Charge For Damage/Other _patches from larrge holes
$151.71 Paint Material
$189.64 Prorat
d 4 o
5
05/05/03
Charge For Damage/Other ,
e
f
years
$180.00 Living Room Carpet Installation
$200 ($376.31
5/03
Charge For Damage/Other ,
,
Prorated 9 of 10 years
$41.60 Bedroom Carpet installation
$104
prorated
($556.31)
(
59
9
/03
Charge For Damage/Other ,
,
4 of 10 years
$137.52 Bedroom carpets, $343.82 prorated 4 of 10 $
7.
1)
($735.43)
05/05/03
05/05/03
Char,qe For Damage/Other
__
Charge For Da mage/Other years
$100.00 Late charge, 9/02
$75
00 La
a
($835.43)
05/05/03
Charge For Damage/Other .
te ch
rge 8/02
$100.00 ' Late charge 10/02
4
($910.43)
05/05/03 Charge For Dama a/Other
_._ -g -
$100.00 ; Late char9a 11/02 - ($
11
01
0.43)
2
05105/03 Charge For Dam a g
2
-
$100.00 Late charge
12/02 ' ($1
,
11
0
. 43
)
05/05/03
Charge For Damage/Other ,
$75.00 Late charge
1/03 ($1 21043)
_ .
05105/03 Charge For Damage/Other ,
$70.00 ' Late charge
2/03 ($1,285.43)
05/05/03 Charge For Damage/Other ,
$100.00 Late charge 4103 ($1,355.43)
05/05/03 Charge For Damage/Other $570.00 Unpaid rent 4/03 ; ($1,455.43)
05/05/03 Charge For Damage/Other $380.98 Living room carpet, $423.32, prorated 9 of -($2,025.43)
($2,406.41)
10, years
EXHIBIT ?
Oct 25 2008 9:47AM HP LRSERJET FAX
VERIEl CAT ON
I, Timothy Hoag , verify that the statements made in the aforegoing document
are true and correct. I understand that false statements herein are made subject to the
penalties of IS Pa. C. S. §4901, relating to unsworn falsification to authorities.
Dated: ?a Lq 9c
TIMO H
By:
P•2
34091
91nner
Sv (,?1 c
-y
.
.f. " `n
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-06515 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HOGG TIMOTHY
VS
BINNER RICHARD A JR ET AL
BRIAN BARRICK , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
BINNER RICHARD A JR the
DEFENDANT , at 0019:21 HOURS, on the 5th day of November-, 2008
at 1761 KINGS ARMS COURT
NEW CUMBERLAND, PA 17070 by handing to
RICHARD A BINNER JR DEFENDANT
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 18.00
Affidavit .00
Surcharge 10.00
.00
hlolo r 9, 46.00
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
11/06/2008
KODAK & IMBLUM
By:
c
Deputy Sheriff
A. D.
„? . ,; ?:.
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-06515 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HOGG TIMOTHY
VS
BINNER RICHARD A JR ET AL
R. Thomas Kline Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
AMON RACHEL but was
unable to locate Her in his bailiwick. He therefore returns the
(""MOT -T TRPT' C- TTnrr Tf"V
the within named DEFENDANT
AMON RACHEL
NOT FOUND , as to
1761 KINGS ARMS COURT
NEW CUMBERLAND, PA 17070
PER CO-DEFENDANT RICHARD BINNER, AMON MOVED TO FT. CARSON COLORADO.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
Not Found
i l pl0i 4-
So answers•
_- >
6.00
00
.00 R. Thomas i.ne
10.00 Sheriff of Cumb rland County
r/ 21.00 KODAK & IMBLUM
11/06/2008
Sworn and Subscribed to before
me this day of
A. D.
TIMOTHY HOGG IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2008-06515 CIVIL
RICHARD A. BINNER, JR. CIVIL ACTION -LAW
and RACHEL AMON
Defendants
TO: PROTHONOTARY, COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PRAECIPE FOR DEFAULT MGMENT
Please enter judgment in favor of Plaintiff and against Defendant(s) RICHARD A.
BINNER, JR. (only), named for failure to file within the required time an Answer to the
Complaint in the above-captioned case and assess the Plaintiffs damages as follows:
Amount claimed in Plaintiffs Complaint $3,585.55
Interest at the statutory rate of 6% per annum from February 2, 2008 188.16
Total = $3,773.71
I hereby certify that a written Important Notice of the intent to file this Praecipe was
mailed or delivered to the Defendant(s) and/or his/her Attorney of Record, if any, after
the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe
and a copy of the notice(s) is/ are attached.
KODAK & IM4a,
.
C.
Robert D. Kodak, Attorney for Plaintiff
DATED: Judgment entered and dam es assessed as above.
P othon ry
LAW OFFICES OF
KODAK & IMBLUM, P.C.
CAMERON MANSION
Robert D. Kodak 407 NORTH FRONT STREET
Gary J. Imblum POST OFFICE BOX 11848
HARRISBURG, PA 17108-1848
www.kodak-imblum.com
December 4, 2008
MR RICHARD A BINNER JR
1761 KINGS ARMS COURT
NEW CUMBERLAND PA 17070-2223
RE: Timothy Hogg
VS: Richard A. Binner, Jr.
Our File No. 34091
Telephone
717.238.7152
Facsimile
717.238.7158
FILE E'??Y
No. 2008-06515 Civil, Court of Common Pleas
Cumberland County, Pennsylvania
Dear Mr. Binner:
In accordance with Pennsylvania Rules of Civil Procedure 237.1, we are enclosing herewith a
Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the
Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings to the
Complaint filed against you to the above term and number, nor has any attorney entered an appearance
on your behalf.
Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take
action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office
of the Prothonotary of Cumberland County, Pennsylvania, to enter Judgment against you in the amount
as set forth in said Complaint.
Very truly yours,
RDK/ bjh
enclosure
KODAK &IMBLUM, P.C.
Robert D. Kodak
robert.kodak@kodak-imblum.com
THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
cc ATTENTION DONNA WILSON
A&S COLLECTION ASSOC INC
POST OFFICE BOX 395
WILLIAMSTOWN VT 05679
492611
TIMOTHY HOGG : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 08-6515 CIVIL
RICHARD A. BINNER, JR. and RACHEL AMON CIVIL ACTION - LAW
Defendants
FILE COPY
IMPORTANT NOTICE
TO: RICHARD A. BINNER, IR., Defendant
DATE OF NOTICE: December 4, 2008
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM
THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING
AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS 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 LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU
WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT
A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
717-249-3166
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TIMOTHY HOGG
Plaintiff
V.
RICHARD A. BINNER, JR.
and RACHEL AMON
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2008-06515 CIVIL
: CIVIL ACTION -LAW
TO: RICHARD A. BINNER, TR. (Only), Defendant(s)
You are hereby notified that on OJZ&t?ru-l Q? ddd V28J the following
(judgment) has been entered against you in the above-captioned case.
judgment entered in the amount of $3,773.71.
DATE: Qutuj ?
- "-4.a
thono
I hereby certify that the name and address of the proper person(s) to receive this notice is:
RICHARD A BINNER JR
1761 KINGS ARMS COURT
NEW CUMBERLAND PA 17070-2223
C"?
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CIF t
PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS)
P.R.C.P. 3101 to 3149
TIMOTHY HOGG IN THE COURT OF COMMON PLEAS OF
PO BOX 624, NEW CUMBERLAND PA 17070 Cumberland COUNTY, PENNSYLVANIA
Plaintiff Writ No. Term 20
vs No. 2009-6515 Term 20 08
Amount Due
RICHARD A. BINNER JR 12/19/08 jdmt ............ $ 3,773.71
and RACHEL AMON Interest from jdmt -6/22/09
1761 KINGS ARMS COURT 0.62 per diem ............... $ 114.70
NEW CUMBERLAND PA 17070
DEFENDANT (S) Commission
(S) 5% statutory rate .......... $ 188.69
Costs (to be determined) $
TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER,
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania
(2) against RICHARD A. BINNER, JR. Only
e en ants ;
(3) and against
arms ee s ;
(4) and index this writ
(a) against RICHARD A. BINNER, JR. Only
Defendant(s) and
(b) against
arms ee s ,
as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows:
(Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy):
LEVY UPON ALL PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE ADDRESS IN
CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO FURNITURE, JEWELRY, ELECTRONICS, SUPPLIES, ETC.,
(5) Exemption has (not) been waived
Robert D. Kodak, Esquire -?
PO Box 11848
Harrisburg, PA 17108
(717) 238-7159
Dated 6/22 09 Attorney For Plaintiff(s)
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-6515 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due TIMOTHY HOGG, Plaintiff (s)
From RICHARD A. BINNER, JR and RACHEL AMON, 1761 Kings Arms Court, New
Cumberland, PA 17070
(1) You are directed to levy upon the property of the defendant (s)and to sell all personal property of
the defendants including but not limited to furniture, jewelry, electronics, supplies, etc. .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $3,773.71 L.L. $.50
Interest from 6/22/09 @ $0.62 per diem -- $114.70
Atty's Comm 5 % statutory rate -- $188.69 Due Prothy $2.00
Arty Paid $186.00 Other Costs TO BE DETERMINED
Plaintiff Paid
Date: 6/23/09
(Seal)
REQUESTING PARTY:
Name ROBERT D. KODAK, ESQUIRE
Address: KODAK & IMBLUM
PO BOX 11848
HARRISBURG, PA 17108
Attorney for: PLAINTIFF
Telephone: 717-238-7159
Supreme Court ID No. 18041
S ?.
C tP
rot
honnotary By: 0.
Deputy
1 SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff aF SHE ?RQ ? F/@g
0??.,ttr at rrf11Jody S Smith 10 ??{1 J/? C?OTA?t'?''
Chief Deputy H 21
P1? 2? 28
Richard W Stewart C fie
Solicitor CeE pEN#SYLy CQj/NTY
QO'a
Timothy Hogg
Case Number
vs.
Richard A Binner, Jr (et al.) 2008-6515
SHERIFF'S RETURN OF SERVICE
07/07/2009 Per Tammy at Atty Kodak's office, no service on Amon - pursuing Binner only.
07/15/2009 12:55 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on July 16,
2009 at 1245 hours, he served a true copy of the within writ of execution, upon the defendant, to wit:
Richard
A. Binner, Jr., by making known unto Tonya Deimler, Adult in Charge, at 3411 Walnut Street, Camp Hill,
Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said
true and correct copy of the same. Upon serving the writ of execution, a levy was completed. Postcard
and copy of levy mailed to attorney and letter mailed to defendant on 07-16-09.
01/21/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is
returned STAYED, per request from plaintiff's attorney.
SHERIFF COST: $87.48 SO ANSWERS,
1111-21
January 21, 2011 RON R ANDERSON, SHERIFF
B
Sharon R. Lantz
, 0 L-?-- fd.
? ?sy07?
ioi CountySuite S"enff_ Iele^„ott h,c
WRIT OF EXECUTION and/or ATTACHMENT
r-
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-6515 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due TIMOTHY HOGG, Plaintiff (s)
From RICHARD A. BINNER, JR and RACHEL AMON, 1761 Kings Arms Court, New
Cumberland, PA 17070
(1) You are directed to levy upon the property of the defendant (s)and to sell all personal property of
the defendants including but not limited to furniture, jewelry, electronics, supplies, etc. .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $3,773.71
Interest from 6/22/09 @ $0.62 per diem -- $114.70
Atty's Comm 5 % statutory rate -- $188.69
Atty Paid $186.00
Plaintiff Paid
Date: 6/23/09
hut
(Seal) By:
REQUESTING PARTY:
Name ROBERT D. KODAK, ESQUIRE
Address: KODAK & IMBLUM
PO BOX 11848
HARRISBURG, PA 17108
Attorney for: PLAINTIFF
Telephone: 717-238-7159
Supreme Court ID No. 18041
L.L. $.50
Due Prothy $2.00
Other Costs TO BE DETERMINED
Deputy