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HomeMy WebLinkAbout09-0028r~ Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SUZANNE DIEHL, Plaintiff v. GLEN A. HOFFMAN and JULIANA R. HOFFMAN, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2009 - Dl~~ CIVIL TERM 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 any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. 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 HIIZING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 F:IFILES\Clirnts112827 Dieh1112827.9.com Christopher E. Rice, Esquire MARTSON LAW OFFICES. I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SUZANNE DIEHL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. GLEN A. HOFFMAN and JULIANA R. HOFFMAN, Defendants No. 2009 - ~ CIVII, TERM COMPLAINT 1. Plaintiff, Suzanne Diehl, is an adult individual residing at 110 W. Springville Road, Boiling Springs, Pennsylvania 17007. 2. Defendants, Glen A. Hoffinan and Juliana R. Hoffman, are adult individuals who reside at 307 Glenn Avenue, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. On or about September 1995, Plaintiff and Defendants entered into a written residential lease agreement ("Residential Lease") whereby Defendants agreed to rent the premises at 127 Andrew Court, Carlisle, Pennsylvania 17013 ("Premises"). A true and correct copy of the Residential Lease is attached hereto as Exhibit "A" 4. The Residential Lease ended on or about September 30, 2008. 5. After an inspection of the Premises, Plaintiff determined that Defendants caused damages in the amount of $7,045.42. See copies of invoices attached hereto as Exhibit "B". 6. Defendants have failed and refuse to pay the outstanding charges as stated above. 7. Pursuant to the Lease Agreement, Defendants are indebted to the Plaintiff for damages as stated above, plus costs of suit and attorney fees. WHEREFORE, Plaintiff demands judgment in her favor and against Defendants in the amount of $7,045.42, plus costs of suit, interest, any additional damages discovered hereafter, and attorney fees in the amount of $1,056.81. MARTSON LAW OFFICES By °~ S . Christopher E. Rice, Esquire I. D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Date: /- ~- O ~ Attorneys for Plaintiff This a debt collecting firm. Any information obtained will be used for that purpose. EXHIBTT °'A" LEASE AGREEMENT THIS LEASE AGREEMENT made this// day of~~, of 1995 by and between Suzanne Diehl of 322 S. Hanover St., Carlisle, PA 17013, as Landlord, and l~m Glenn ,~.-H.~.~~~ as Tenant. Landlord hereby leases to tenant a 3 bedroom townhouse located at 127 Andrew Court Carlisle, PA 17013 upon the following terms and conditions, to wit: I. RENTAL TERM: T e term of this lease shall be~e°grirn~rig the sit day of t9C~ObCI' 1995, and ending the3b~y of~, Iggg, 2, MONTHLY RENTAL AND LATE PAYMENT PENALTY: Rental shah be paid in the amount of Eight thousand one hundred and (x8,100.00) Dollars per term, payable in advance of the monthly annive_ no monthly instalments of Six hundred seventy five and 00/100 Dollars. AIII sudtdntr+errtal PeYments shall be due without demand therefor. Each tenant shall be jointly and severally liable for ~ Payments due hereunder. In the event any tenant(s) shah vacaMs the premises, the remaiMrq tenant{s) shall remain fully liable for aN amounts due hereunder and no r,~~on thereof shaA occur. Tenant wiN pay to Landbnd prior to occupancy of the Premises, the monthly rental due in advance Six hundred seventy five and 001100 dollars. Any rentals Paid by check to the Landord and returned by the baMcirq institution for insuf- tident funds or for any reason whatsoever shall be charged an amount of for each and every occurrence against their security deposit. A late d>e ~T oilers (x40.00) dollars (x25.00) shall be due and payable for each rental ~ ~~ five Landlord more than four (4) days after the due date m yment whrdt ~ reserved by the 3. USE OF DEMISED PREMISES: Tenant leases the demised premises for residential purposes for persons and for no: other purpose: Nothing shah be done upon said premises contrary to ~e conditions of the poiides of insurance upon the building where- by the hazard may be increased or the insurance invalidated, no lawful business shah at any time be carried on upon said premises. 4. CONDUCT OF TENANT: Tenant agrees not to do or to permit any ad which shah cause damage to the demised premises or shah intertere w8h or disturb the peaceful enjoyment of the premises by the other tenants and to comply with aN obligatiats imposed upon tenants by state, county or local odes, regulations, ordinances or statutes. Tenants shall keep leased premises in a good state of repair and maintenance as at present and at the expiration of this lease shah surnend~ the premises in like repair and conditbn, Hamel wear and tear alone excepted. The premises are to be kept in a dean and sanitary condi- tion and alt trash or other garbage which may accumulate thereon during the term are to be removed promptly, and in case of failure to remove the same, the landlord may have the same removed and collect as rent due and in arrears double such oust of removal. CARPET AND VINYL CLEANING- Upon expiration or termination of the lease, ail carpeting and vinyl is to be damned commerdally at tenants' expense. 5, SECURITY DEPOSIT: Tenant shall deposit with landkud at the time of execution of this agreement a security deposit in the amount of Six hundred seventy five dollars to be held by landlord to secure the faithful compliance of tenant with all teens and conditions of this agreement in accordance with the provisions of the Pennsylvania Landlord and Tenant Ad of 1951, as amended. 6. UTILITIES: Utility charges are to be paid and services provided as follows: Heating to be paid by tenant Heating of water to be paid by tenant Electricity to be paid by tenant Water and sewer to be paid by tenant Trash removal to be paid by tenant Lawn care provided by Landbrd Snow removal of parking lot provided by landlord 7. PET PROHIBITED: Tenants shall keep no pets of any kind upon the premises without the express written approval of landlord. 8. TERMINATION: n is agreed that either landbrd or tenant may terminate this lease at the end of the initial term by giving the other party written notice of at least two months prior to the end of the initial term. In the event such notice of intent to terminate is not given by either party to the other, this lease shall continue upon the same terms and conditbns in force immediately prior to the expiration of the instal term for another period of one year and so on from year to year unless terminated by other party giving the other two moms written Holies of the tem~inatbn prior to the expir>~ion of the then current term. Provided, however, that if the landbrd shall give one month's written notice expiration of any temp hereby created of his irKention to ch Pte' to the of this lease, and the tenant remains in the ~ ~° terms snd 00~ons premises after the effective date set forth in the notice, the tenant wiN be considered ss a tenant under the terms and conditions as provided in such notice. AN terms and conditions in existence prior to such notices which are not in- cwnsistent with or repealed by such notice, shall remain in full force and effect. 9. LANDLORD WARRANTY: Landlord has rented the premises in their present "as is" condition and without any representations other than those stated in this lease. Landbrd is under no duty to make repairs, alterations, or decorations unless that duty is set forth in this agreement. 10. INSPECTION: Landlord reserves the• right to enter upon the premises at reasonable times and in a reasonable manner to inspect the demised premises and to determine if repairs are needed. upon glvirp reasonable advanced notice of such intended entry. Tenant agrees to permit lartdbrd to show the apartment to other Prespecthre tenants and to permit entry to prospective purchasers if the premises are offered for sale. Ii. DISRUPTIVE ACTIVITIES: Tenant agrees to and shall Hat play musical in- struments, radios, tapes, recoMs or television before 8:00 a.m. or after 10:00 p.m. loud enough to disturb neighbors, nor violate any municipal ordinance or State Laws of what- ever nature, nor drive any large tacks, nails, or large screws into any walls or other wood. worts. 12. PAINTING: Tenant agrees to refrain from painting any part of the rental premises. 13. LAWN MAINTENANCE AND SNOW REMOVAL: The landlord covenants and agrees to keep the lawn mowed. Tenant shah promptly clear the walkways and sidewalks from snow, ice, and debris, as required by an law or ordinance, now if effect or enacted during the terms of this lease. 14. LANDLORD 'S LIABILITY: Tenant agrees that landlord shaft lie liable for property damage or persona! injury occurring in the leased premises or elsewhere on landlord's premises only where such damage or injury results directly from landlord's negligence. 15. LANDLORD'S REMEDIES: In the event tenant shalt fail to comply with any term or condtiion of this lease, landlord shall have the right to: a) txing a law suit to re- cover possession of the lease property; b) bring a law suit to recover the entire balance due of the rent reserved for the full term hereof and any other charges due hereunder to- gather with any and all damages caused by and incurred as a result of tenant's default indudirp reasonable attorney's fees and court cwsts; c) , to exercise any and all rights accruing to him under the Pennsylvania LandloM and Tenant Act, as amended. 16. NOTICE TO QUIT: If an adion is instituted by landlord to recover possession of the leased premises, or for nonpayment of rent, or for any other reason tenant waives his right to three month's notice tp quit and/or the fifteen or thirty days' nntice to qu~lly required by the Landlord's and Tenant Ad of April 6, 1951, as mended, and agrees that five (S) days notice to quit shall be suffident. 17. ASSIGNMENT AND SUBLETTING: Tenant shall not assign or sublease the demised premises or any part thereof without prior written consent of landlord. 18. SEVERABILITY: In the event any provision of this lease shall be dedared in- valkl by any court of the Commonwealth of Pennsylvania only such provision declared in- valid shall be null and void and all other provisions not inconsistent therewith shah remain birrding and in full force. 19. BINDING AGREEMENT: This agreement shall be binding upon the parties hereto, their heirs, executors and assigns and shalt not be modified except by agreement in writing executed by all parties hereto. IN WITNESS WHEREOF, the parties hereto have hereunto set their hands and seals the day and year flr~ above written. WITNESS: LAND RD n T s) ~ ~ ~ ~-- 1 (seal) (seep EXHIBIT "B" CARLISLE GLASS SERVICE 2301 EAST POMI"RET STREET CARLISLE PA 17013 OFFICE 7'17-243-ggp~p FAX 7'17 249-1967 c~uoTATran~ 4UOTE GOOD FpR 3E1 DAYS DATE 11-~9~08 TERMS. DONALD DIEHL f Z7 MEW COURT ~a~ nlo, any--7ia~` s -- nl~w acl~, To ~~ WHITE WITFI rnlarAUED. ~_,~~ 2_~,~ f4Q~.OS PLUS TAX fNBTAI..LED PRICE HOUR3.9-6 MpN-.FRI. .SAT 9--NOON SCREEN BY THE ROLL SCREEN HARDWARE CIIT TO SIZE ~L~SS ~ aCREEN REl~AtR STQI~IY111~IIIIIiDpW RB,pA1R IIIIRliLATED DLASS F1RIPLACE (~L~SStNEOCER~ QR TEMPERED SMOKED ~3L~ASS t3R ~ EY AND BROKZE rri~x, Ul / U1 COMPLETIQN QF J08. TIIIAE LABOR AMD MATERIAL INCLUDED IN QUOTE. liiLA~S SON ~t,ARE ~ TALE Tt~ 6~ASS BEVELED t3LA~ ~RAMEO MIRRORS Johnson Services 770 Condiguinet Ave. Carlisle, PA 17013 Estimate: Address: 127 Andrew Court Carlisle Pa ~ # ---- Description of Repairs 1 2 Rotten Kitchen cabinet Trash removal 3 Holes punched in doors (replace 2 doors) 4 Paint over graffiti on basement walls 5 Bi-fold Doors in kitchen x 2 6 Rear bedroom door replaced 7 Rear bedroom replaced bi-fold door 8 Re seed grass in front of unit 9 2 handrail brackets ` 10 Broken Shutter replaced 11 Holes in walls ~ Total 9ervics Isvolcs ~ : Oa00489s Dais: 12/!/Z008 Pegs: I C~ ~~ ~ Donald Diehl 4 E. High St., Suite A Carlisle, PA I TOl3 Sen~tce at: I~7 Aadrsw Corm Please fiicJNb~t htvivlce ntar~brr off chercJk DsacripUora Amorrt 12/9/08 Price quote for removing old vanity and top in powder room and replacing vanity. 1- 24" x 21"Oak Vanity cabinet 1- 25" x 22" Cultured marble vanity top 1- Mcen Single lever Chateau lav faucet w/metal pop up ~ . Price includes all material and labor to complete job ~76Z.00 Thank You for your bustnessl Tsrss: Balares drs 1S days: l.S7f- /mo. Balaacs Dre: $768.00 X43-s49p RANDY S. SHULL FLOOR COVERINGS 221 Pine Glow Road Gardners, PA 17324 . (717)' 48n~8041 ^ ~ A f TO ~0..~Q1 ~~Ly ~. Terns: A 2911 pe- nwnM- fln~nq charpt ~ bo a pp/bd N thb Ibrok~ b not p,Nid W/fihln 30 deya of deN o/ Mvek.e, Alrn/mtart cAa~r !~ ® ~ ~. _, ,_ lS OUANTrTY D N PRICE AMO UNT 3a•Q _ ~ u n P .az~ ' - h ca~. °~~ V v~- ,+~ e c _..,. ORIGINAL JI}aKk 2~ou., ~~ ~: ~_: 5 t r y<~ :, t~ r.,~~ P-bbey Ct. ~ ~;voi E Dar _~__ '_._.____..~~__._ Carlisle, PA 170 i S ~' ~Z - ~> G~ C'USTOMER'S ORDER NO. ~~_ .r.r.. .~_ __ ISOI_D TO' _.._.~__._..._._._ ..___...__._..__..__ SHIP TO: ___ _ _ _ ~_ - ~-1 J-~ ti_--_ _ _ ~ ~" _ _ _ _ __ o ~ ~ ,~_ ~cc }- ~l_5~< C ___ __ _____ __,_ ___________1_ ~ `~ .___`~ ..~ ~_~3___...____ .... _. 3t.N 3HIPPFp VGA _.._.. . ____. ~ Tw~•:MS , !3_ > r,derns p~'~~ VERIFICATION The foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. t ; ^.' pp ~.) ~ c~ r.J ~ ~ G --# `J ~ 17 ~ ~ t ~ C.,~ s`~ t: .. --.s -C ry ? P.. M1 r I; t' ` I Darrell C. Dethlefs, Esquire ID # 58805 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone - (717) 975-9446 Fax - (717) 975-2309 DDethlefsLa!aol.com SUZANNE DIEHL, Plaintiff V. GLEN A. HOFFMAN and JULIANA R. HOFFMAN, Defendants Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No: 09-0028 - CIVIL TERM PETITION FOR LEAVE TO WITHDRAW APPEARANCE PURSUANT TO PA. R.C.P. 1012 AND NOW, comes the DETHLEFS-PYKOSH LAW GROUP, LLC, by and through Darrell C. Dethlefs, Esquire, present legal counsel for Defendants, Glen A. Hoffman and Juliana R. Hoffman, and files this Petition to Withdraw as Counsel of Record and in support thereof avers the following: 1. Your Petitioner is The Dethlefs-Pykosh Law Group, LLC, by Darrell C. Dethlefs, Esquire, 2132 Market Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Attorneys from Petitioner's law firm, including, but not necessarily limited to, Darrell C. Dethlefs, Michael J. Pykosh, Bryan W. Shook, and Trudy A. Marietta Mintz, may have entered an appearance on behalf of Defendants in this matter. 3. Petitioner makes this Petition on behalf of all attorneys associated with Petitioner's law firm relative to this matter. 4. In February, 2009, Defendants, Glen A. Hoffman and Juliana R. Hoffman, contacted Petitioner seeking legal counsel for this matter concerning Plaintiff. 5. Defendants, Glen A. Hoffman and Juliana R. Hoffman, have not kept up with their obligations to communicate with Petitioner in this matter. 6. Petitioner has made numerous attempts to contact Defendants but have been unable to reach them by phone and by correspondence. 7. Defendants, Glen A. Hoffman and Juliana R. Hoffman, have substantially failed to fulfill their obligations and duties as clients in this matter. 8. Petitioner is without sufficient assistance of clients to adequately represent Plaintiffs. 9. Petitioner's continued representation of Glen A. Hoffman and Juliana R. Hoffman has been rendered unreasonably difficult by virtue of Glen A. Hoffman and Juliana R. Hoffman's failure to fulfill their obligations as clients in this matter, and good cause exists under Rule 1.16(b)(7) of the Pennsylvania Rules of Professional Conduct for Petitioner's withdrawal of appearance in this case. 10. Based upon all of the foregoing, Your Petitioner respectfully requests that the Honorable Court Order that the Petitioner and all attorneys associated with Petitioner is formally withdrawn as counsel for Defendants, Glen A. Hoffman and Juliana R. Hoffman. WHEREFORE, Your Petitioner, The Dethlefs-Pykosh Law Group, LLC, respectfully requests this Honorable Court to grant leave for the entry of an Order allowing its Withdrawal from legal representation of the Defendants pursuant to Pa. R.C.P. 1012. Respectfully submitted, The Dethle -P kosh Law Group, LLC Date: kov-11 By. Dan- A-6. Dethlefs, Esquire I. D. # 58805 2132 Market Street Camp Hill, Pennsylvania 17011 (717) 975-9446 SUZANNE DIEHL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No: 09-0028 - CIVIL TERM GLEN A. HOFFMAN and JULIANA R. HOFFMAN, Defendants CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Petition to Withdraw as Counsel of Record, was hereby served by depositing the same within the custody of the United States Postal Service, First Class, postage prepaid, addressed as follows: Suzanne Diehl c/o Christopher E. Rice, Esquire Martson Law Offices 10 E. High St. Carlisle, Pennsylvania 17013 Glen A. Hoffman and Juliana R. Hoffman 18 W. Springville Road Boiling Springs, Pennsylvania 17007 Date: It By: Respectfully sVbtnitted, Darrell C Dethlefs, Esquire I. D. # 58805 2132 Market Street Camp Hill, Pennsylvania 17011 (717) 975-9446 Y SUZANNE DIEHL, Plaintiff V. GLEN A. HOFFMAN and JULIANA R. HOFFMAN, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No: 09-0028 - CIVIL TERM RULE AND NOW, this the 19 • day of mar-4 , 2011, a RULE is issued upon Plaintiff, Suzanne Diehl, and Defendants, Glen A. Hoffman and Juliana R. Hoffman, to show cause as to why the Petition to Withdraw as Counsel of Record for Defendants, Glen A. Hoffman and Juliana R. Hoffman, should not be granted. RULE returnable on 590114. Z6 0(47f 'Y4 dwv?? . Distribution Legend BY TH OURT: ?e / J. ZM _3 _ El' r ti + -Ti 'Dethlefs-Pykosh Law Group, l 2132 Market Street Camp Hill, Pennsylvania 170 1 Glen A. Hoffman and Juliana R. Hoffman 18 W. Springville Road Boiling Springs, Pennsylvania 17007 Suzanne Diehl c/o Christopher E. Rice, Esquire Martson Law Offices 10 E. High St. Carlisle, Pennsylvania 17013 DK6 , :> r Darrell C. Dethlefs, Esquire ID # 58805 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone - (717) 975-9446 Fax - (717) 975-2309 DDethlefsA ol.com Attorney for Petitioner SUZANNE DIEHL IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff cl> No.: 09-0028 - CIVIL TERM - ca -1 to r"` ? GLEN A. HOFFMAN, and o JULIANA R. HOFFMAN , Defendants bey MOTION TO MAKE RULE ABSOLUTE AND NOW, comes the Petitioner, DETHLEFS-PYKOSH LAW GROUP, LLC, by and through Darrell C. Dethlefs, Esquire, present counsel for Defendants, Glen A. Hoffman and Juliana R. Hoffman, who motions this Honorable Court to make the Order, in the form of a Rule to Show Cause, dated March 9, 2011, absolute and in support thereof states: 1. The Dethlefs-Pykosh Law Group, LLC, by Darrell C. Dethlefs, Esquire, filed a Petition for Leave to Withdraw Appearance Pursuant to PA. R.C.P. 1012 on March 1, 2011. 2. On March 1, 2011, the Order in the form of a Rule to Show Cause and the r r 70 4CD 1 1 y a?© <a , Petition were served upon Defendants, Glen A. Hoffman and Juliana R. Hoffman. I A Certificate of Service was filed on March 1, 2011 by the undersigned. 4. An Order, in the form of a Rule to Show Cause, was entered on March 9, 2011, by the Honorable Judge Hess. 5. The Order provided that Defendants were given 20 days from the date of service of the Petition to show cause as to why the Petition to Withdraw as Counsel of Record for Defendants should not be granted. 6. Defendants have failed to show cause as to why the Petition to Withdraw should not be granted. 7. Based upon all of the foregoing, Your Petitioner respectfully requests that the Honorable Court order that the Petitioner and all attorneys associated with Petitioner is formally withdrawn as counsel for Defendants, Glen A. Hoffman and Juliana R. Hoffman. 8. Pursuant to Cumberland County Local Rule 208.3(a)(1)(b)(i), a hearing or argument is not requested. 9. Pursuant to Cumberland County Local Rule 208.3(a)(1)(b)(ii), discovery is not necessary. WHEREFORE, Your Petitioner, The Dethlefs-Pykosh Law Group, LLC, respectfully requests this Honorable Court to make the March 9, 2011 Rule Absolute and enter an Order authorizing Petitioner to withdraw as counsel for Defendants, Glen A. Hoffman and Juliana R. Hoffman. ukmitted, Date: -? ° < < The Dethlefs aw Group, LLC By: Dar lefs, Esquire I. . 58805 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone: (717) 975-9446 SUZANNE DIEHL IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No.: 09-0028 - CIVIL TERM V. GLEN A. HOFFMAN, and JULIANA R. HOFFMAN, Defendants CERTIFICATE OF SERVICE I hereby certify that on MARCH 30, 2011 a copy of the foregoing Motion and Affidavit of Service, were hereby served by depositing the same within the custody of the United States Postal Service, First Class, postage prepaid, addressed as follows: Suzanne Diehl c/o Christopher E. Rice, Esquire Martson Law Offices 10 East High Street Carlisle, Pennsylvania 17013 Date: Glenn A. Hoffman Juliana R. Hoffman 18 West Springville Road Boiling Springs, Pennsylvania 17007 Respectfully-sou b m itted , The Deth roup, LLC By: Darre . Dethlefs, Esquire I.D. # 58805 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone: (717) 975-9446 SUZANNE DIEHL IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No.: 09-0028 - CIVIL TERM V. GLEN A. HOFFMAN, and JULIANA R. HOFFMAN, Defendants ORDER AND NOW, this the ' day of 2011, upon consideration of the Petition of the Dethlefs-Pykosh Law Group, LLC, it is hereby ORDERED that: 1. The March 9, 2011 Order is hereby made ABSOLUTE. 2. The Petition to Withdraw as Counsel of Record for Defendants is hereby granted. Distribution Legend Dethlefs-Pykosh Law Group, LLC' 2132 Market Street Camp Hill, Pennsylvania 17011 Glen A. Hoffman and Juliana R. Hoffman 18 West Springville Road Boiling Springs, PA 17007 ????t 41, 00 %Suzanne Diehl c/o Christopher E. Rice, Esquire Martson Law Offices 10 East High Street Carlisle, Pennsylvania 17013 C-) r6 rV1 co .Z rn r C D r- Z I s ? Z N rn w :z7 BY THE COURT: F:\FILES\Clients\12827 Dieh1\12827.9 Hoffman\12827.9.pra.judgment Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff 1 ILt, ryrs?rtf`,?- F+ I j" 21 M 11: 23 ?1. '"i t 3ERL I U UUU'3 -DI 'S`t kAlj ,N4! A SUZANNE DIEHL, V. GLEN A. HOFFMAN and JULIANA R. HOFFMAN, Defendants No. 2009 - 0028 CIVIL TERM PRAECIPE TO THE PROTHONOTARY: In accordance with the attached Award of Arbitrators, please enter judgment on the Arbitrator's Award against the Defendants, Glen A. Hoffman and Juliana R. Hoffman, in the amount of $1,500.00 and $249.49 in costs for a total amount of Seventeen Hundred Forty-nine Dollars and 49/100 cents ($1,749.49). MARTSON LAW OFFICES Dated By: (34 A S. Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 6'11--2-1111 Attorneys for Plaintiff ILL 0 0 (A C(?t* 941 a3 (2t4, 0?to6 B3(o "k%LL q\WWA IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA FIFILESTlients\12827 Diehl\12827.9 Hoffman\12827.9.pra.attach wages Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff 1`11 ED-OMCE' X01 ! OCT -6 PM 3: S CUMBERLAND CjUh, REFNNSYL V%, ? NI' SUZANNE DIEHL, V. GLEN A. HOFFMAN and JULIANA R. HOFFMAN, Defendants No. 2009 - 0028 CIVIL TERM PRAECIPE FOR NOTICE OF INTENT TO ATTACH WAGES PURSUANT TO PA.R.C.P. 3302. TO THE PROTHONOTARY: Issue a Notice of Intent to Attach Wages in the above matter against: Defendant Juliana R. Hoffman, 18 West Springville Road, Boiling Springs, PA 17007, and MARTSON LAW OFFICES Dated: le1410 1/ ?.-- C? S By: Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs THIS IS A DEBT COLLECTING FIRM ATTEMPTING TO COLLECT A DEBT FOR SUZANNE DIEHL. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 9zy o u/"t 'jr ., 3?Z S? R-? ? ? SGG2 IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA I 9P CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Juliana R. Hoffman 18 West Springville Road Boiling Springs, PA 17007 MARTSON LAW OFFICES By: Mafy . Price Ten E 9t High Street Carlisle, PA 17013 (717) 243-3341 Dated: / p 6 l// THIS IS A DEBT COLLECTING FIRM ATTEMPTING TO COLLECT A DEBT FOR SUZANNE DIEHL. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Y Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SUZANNE DIEHL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 2009 - 0028 CIVIL TERM GLEN A. HOFFMAN and JULIANA R. HOFFMAN, Defendants CERTIFICATION OF JUDGMENT CREDITOR-LANDLORD I certify that: 1. The Plaintiff ("Judgment-Creditor") is Suzanne Diehl, with an address of 110 West Springville Road, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. Defendant ("Judgment-Debtor") Juliana R. Hoffman, has a last known address of 18 West Springville Road, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. The employer/garnishee of the Defendant Juliana R. Hoffman is Shippensburg Health Care Center, 121 Walnut Bottom Road, Shippensburg, Cumberland County, Pennsylvania 17257. 4. The judgment arises out of a residential lease for the premises at 127 Andrew Court, Carlisle, Cumberland County, Pennsylvania 17015. 5. The amount of the judgment is $1,500.00 plus $249.49 in costs for a total amount of $1,749.49. 6. This praecipe is filed within five years of the date of the original judgment upon which execution is sought. 7. The judgment was entered in a civil action commenced in the Court of Common Pleas. I certify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsifications to authorities. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ??tttt'1p rt tu+nb?rr??? r . ;: OM--E T"E "ERIFF r 1111 OCT 18 Pik ? `4 C'UHIBERLANID PLtaN SYLW; Suzanne Diehl Case Number vs. Juliana R. Hoffman 2009-28 SHERIFF'S RETURN OF SERVICE 10/11/2011 01:01 PM - Timothy Black, Deputy Sheriff, who being duly swom according to law, states that on October 11, 2011 at 1301 hours, he served a true copy of the within Notice of Intent to Attach Wages, upon the within named defendant, to wit: Juliana R. Hoffman, by making known unto herself personally, at 18 W. Springville Road, Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $35.44 October 13, 2011 / 7e- 711?1- TIM BOAC , DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Shen f. Teleosott Inc.