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09-0095
REAGER & ADLER, P.C. By: Linus E. Fenicle, Esquire Attorney I.D. No. 20944 Email: LFenicle(~ReagerAdlerPC.com By: Wayne S. Martin, Esquire Attorney I.D. No. 208078 Email: WMartin(a~Rea~erAdlerPC.com 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 JOHN K. FREEMAN v. IN THE COURT OF COMMON PLEAS Appellant CUMBERLAND COUNTY, PENNSYLVANIA . Docket No. D 9 • vv 9 5 CutiA ~~~' COMMONWEALTH OF PENNSYLVANIA Appellee PETITION TO APPEAL NUNC PRO TUNC PETITION TO APPEAL NUNC PRO TUNC 1. Appellant, John K. Freeman, 1066 30th St. NW, Washington, DC 20007, hereby requests the Court's permission to file appeals after the 30-day appeal period has expired (Appeal "Nunc Pro Tunc") of the following Summons for Non-Traffic Citations (hereinafter collectively referred to as "the October 15 Summons") which were processed by Magisterial District No. 09-1-01, as follows: a. Citation No. P7033670-0, Docket No. NT-0001349-08, Fire Code Violation. A true and correct copy of the Summons and Citation is attached hereto as Exhibit "A." b. Citation No. P7033713-1, Docket No. NT-0001350-08, Property Maintenance Violation. A true and correct copy of the Summons and Citation is attached hereto as Exhibit "B." c. Citation No. P7033671-1, Docket No. NT-0001351-08, Fire Code Violation. A true and correct copy of the Summons and Citation is attached hereto as Exhibit "C." d. Citation No. P7033672-2, Docket No. NT-0001352-08, Fire Code Violation. A true and correct copy of the Summons and Citation is attached hereto as Exhibit "D." 2. Appellant understands that Appeals from Non-Traffic, Summary Offenses must be filed within thirty days of the date of guilty plea, conviction or issuance of a final order, and that Petitions for permission to file an Appeal after the 30-day appeal period has expired (Appeal "Nunc Pro Tunc") can only be granted if Appellant alleges and proves that: (1) the delay in filing the appeal was caused by extraordinary circumstances involving mistake or inadvertent error of a court official; and (2) Appellant acted promptly in filing the Appeal after learning of the mistake or error of the court official. In support of the request for permission to Appeal Nunc Pro Tunc, Appellant alleges the following mistake or inadvertent error committed by a court official as well as when this information was discovered. 3. On or about October 15, 2008, Magisterial District No. 09-1-01 served by mail the October 15 Summons on Appellant. 4. On or about October 16, 2008, Magisterial District No. 09-1-01 served by mail four additional Summons for Non-Traffic Citations on Appellant, Docket Numbers NT- 0001357-08, NT-0001358-08, NT-0001359-08, and NT-0001360-08 (hereinafter collectively referred to as "the October 16 Summons") A true and correct copy of the October 16 Summons are attached hereto as Exhibit "E." 5. Appellant was out of the country from October 18, 2008 until October 30, 2008. 6. Without Appellant's knowledge or permission, Appellant's secretary, Dolores Ford, responded to the October 15 Summons by submitting a payment for $4213.50 to the Magisterial District's Office. 7. By letter dated November 6, 2008, Appellant plead not guilty to the October 15 Summons and the October 16 Summons. A true and correct copy of the letter is attached hereto as Exhibit "F." 8. The District Justice hearing was scheduled for December 16, 2008, but was continued to December 23, 2008. At the hearing the District Justice dismissed the October 16 Summons and indicated that his office had processed the October 15 Summons when Appellant's secretary submitted a payment to the office without indicating a not guilty plea, despite Appellant's plea of not guilty on November 6, 2008. 9. Appellant did not learn that the Magisterial District Office processed the payment as admission of guilt until the December 23, 2008 hearing, after the appeal period had expired. 10. The District Justice indicated at the December 23, 2008 hearing that the processing of the citations as guilty pleas, in view of the November 6, 2008 plea of not guilty by Appellant, was an inadvertent mistake and his office would support a Petition to Appeal Nunc Pro Tunc. 11. A copy of the Notices of Appeal Appellant requests permission to file are attached hereto as Exhibit "G." WHEREFORE, Appellant, John K. Freeman, respectfully requests that this Court grant this petition and enter an order permitting Appellant to file Notices of Appeal Nunc Pro Tunc. Respectfully submitted, REAGER ADLER, P.C. Date: January 8, 2009 Linus E. Fenicle Attorney I.D. No. 20944 Wayne S. Martin Attorney I.D. No. 208078 2331 Mazket Street Camp Hill, PA 17011 (717) 763-1383 Attorneys for Appellant VERIFICATION ~~ I, John Freeman hereby verify that the statements made in this Petition 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. § 4904 relating to unsworn verification to authorities. DATE. ~ S 0 J .Freeman Exti,b;+ ~ • CO.MMONWEALTH.OF PENNSYLVANIA. ~ .'SUMMONS ~ CgUNTY`OF: CU>bsB$RI~AI ~ ~R A SUMMARY CASE , . Ma9. D,S~. No,: ~ NpN TRAFFIC 09-1=01: COMMONWEALTH OF MDJ Name Hon. -_ CHA>ti,L$S}~~1. CLS$BNT, JR _ _ PENNSYLVANIA -. ~ Address . l~.V ~z~~I)b~E :.~a;T . ; '~ . ;~ ~ -. - .. - .. >, _ . ~. ., .. _ OLDS .TOMS CObaKO~iS -SUITS 3 VS 1~SN: CUIl~B$RLAND, PA . , DEFENDANT NAAb1iE and ADDRESS r~evn«,e. ,(7:1,7) 774 5 9 8 9 17 0 7 0 r~R$BMiA>sT, JOSH 8. ~. v _. 10:66 3;OTH ST. . ~ ~PAS8I11if3TON, DC 2 0 0 07 JOHN H . FR$E1rIAN 1066 30TH ST. Nfii( WASHI~iGTON, DC 20007 L J DocketNo.: NT-0001349-08 Date Filed: 10/15/08 $ 7 0 $ $ 311.2.1 FIRS . CODE ~TIOLATIOI~ . FINE AND COSTS: FINE: ~ 1COSTSS, I OTHER: ~TO~LDUE: /~.oo I Ste. S-a /oS7. S'D WITHIN TEN (10) DAYS OF RECEIPT OF THIS SUMMONS YOU MUST: 1. PLEAD NOT GUILTY by notifying the magisterial district judge above in writing and forwarding an amount equal to the total due specified above, or if the fine and costs are not specfied, forward the sum of $50.00 as collateral for your appearance at Vial; OR, 2. PLEAD NOT GUILTY by.appearing before the magisterial district judge above and posting such coAateral for your appearance as the magisterial district judge shall regwre; OR, 3. If you cannot afford to pay the total due specified above or the $50.00 collateral, you must appear before the magisterial district judge above to ehter a plea; OR, 4. PLEAD GUILTY by notif~mg the magisterial district judge above in writing, signing the appropriate plea below, and forwarding an amount equal to the total due specrfied above: OR, 5. PLEAD GUILTY by appearing before the magisterial district judge above if the total due is not specified or if you are required to appear because the offense with which you are charged carves a mandatory sentence of imprisonment, for example, a violation of 75 Pa.C.5. Section 1543(b) (Driving while operating privilege is suspended or revoked). IF YOU ARE FOUND GUILTY BY THE MAGISTERIAL DISTRICT JUDGE AND WISH TO APPEAL, YOU HAVE THIRTY (30) DAYS TO REQUEST A TRIAL DE NOVO IN THE COURT OF COMMON PLEAS. ALL CHECKS OR MONEY ORDERS FOR FINE, COSTS, FEES, OR FOR COLLATERAL, SHALL BE MADE PAYABLE TO 'MAGISTERIAL DISTRICT NO. 09 -1- O 1 'IDENTIFIED ABOVE AND SENT TO THE ADDRESS ABOVE. IF YOU FAIL TO RESPOND TO THIS SUMMONS WITHIN THE TIME SPECIFIED ABOVE, A WARRANT FOR YOUR ARREST SHALL BE ISSUED. If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. IF YOU INTEND TO RESPOND BY MAIL: Detach and complete the lower portion of this summons with your signature on the appropriate plea line, (1) or (2). ' If you PLEAD NOT GUILTY, your check or money order must be in the amount of the total due specified above. If the total due is not specified, your check or money order must be in the amount of $50.00 which will be held for collateral for your appearance at trial: You will be notified by mail of your date and time for trial. If you PLEAD GUILTY, enclose a check or money order in the amount of the total due specified above. Failure to remit the full amount of the fine, costs and fees will result in the issuance of a warrant for your arrest. Your check or money order shall be made payable to the "Magisterial District No." above. (DETACH HERE) ----°--------~~~---------------------------------------------°------------~_~~~_~~---_---------_-___-----°--------------- MA IN PLEA I represent that I make this plea knowi volu arily n ently. (Failure to in ' e a plea when forwarding an amount equal to the total due specified above will r ult it lea i rdedJ 1. I PLEAD NOT GUILTY. r) ~ocket No.: NT-0001349-08 2. I PLEAD GUILTY. Citation No.: P7036670-0 AOPC 677-08 DATE PRINTED : 10 / 15 / 0 8(Signature) 2 ; 2 8 ; 3 2 PM 1i r ~ ~ I ~~~ ~~-~ t V ~. iMyHUtrb81 i of L(quor or lyialt a Brewed ~evefayes. •' ~xl~;b;f Q' CpMMONWEALTH OF PENNSYLVANIA ~pUNTY OF: ~urus~sui.n' ) Mag. Dist. No.• 09-1=01~ MOJ Name: Hon. • .CHA>6tL$S: A. .CLE>I~IT, JR - OLDE TOWNS COIYIItION3 -SIIITE 3 >bTS1iP CIII~IDERI~A)siD, PA Telephone (717) 774-5989 17070 ~. SUMMONS ~R. A SUMMARY CASE - ~ ~ NON-TRAFFIC . COMMONWEALTH OF PENNSYLVANIA VS. DEFENDANT: NAME and npDRESS ~, J083i H . _ ~ 1066 30TH I3T. ~P WASHI1IiGT01~, DC Z 0 0 07 JOH~t H . FREEb1A>li L J 1066 30TH ST. HPP Docket No.: )siT-0001350-08 liPABHINGTON, DC 20007 Date Filed: 10/15/08 ~~ ~ .9: S 16 2 -1 f S 10 8.1.1 PROPERTY ffiAI>ol'rENA>oTCE VIOLATION FINE AND COSTS:I FINE: I COSTS: I OTHER: I TOTAL DUE: ~/ooo . oo $ ~"2 . oo ~ /o S~ . 00 WITHIN TEN (10) DAYS OF RECEIPT OF THIS SUMMONS YOU MUST: 1. PLEAD NOT GUILTY by notifying the magisterial district judge above in writing and forwarding an amount equal to the total due specified above, or if the fine and costs are not specified, forward the sum of $50.00 as collateral for your appearance at trial; OR, 2. PLEAD NOT GUILTY by appearing before the magisterial district judge above and posting such collateral for your appearance as the magisterial district judge shall require; OR, 3. ff you cannot afford to pay the total due specified above or the $50.00 collateral, you must appear before the magisterial district judge above to enter a plea; OR, 4. PLEAD GUILTY by notifying the magisterial district judge above in writing, signing the appropriate plea below, and forwarding an amount equal to the total due specffied above: OR, 5. PLEAD GUILTY by appearing before the magisterial district judge above 'rf the total due is not specified or if you are required to appear because the offense with which you are charged carves a mandatory sentence of imprisonment, for example, a violation of 75 Pa.C.S. Section•1543(b) (Driving while operating privilege is suspended or revoked). IF YOU ARE FOUND GUILTY BY THE MAGISTERIAL DISTRICT JUDGE AND WISH TO APPEAL, YOU HAVE THIRTY (30) DAYS TO REQUEST A TRIAL DE NOVO IN THE COURT OF COMMON PLEAS. ALL CHECKS OR MONEY ORDERS FOR FINE, COSTS, FEES, OR FOR COLLATERAL, SHALL BE MADE PAYABLE TO "MAGISTERIAL DISTRICT NO. 09 -1-01 'IDENTIFIED ABOVE AND SENT TO THE ADDRESS ABOVE. IF YOU FAIL TO RESPOND TO THIS SUMMONS WITHIN'THE TIME SPECIFIED ABOVE, A WARRANT FOR YOUR ARREST SHALL BE ISSUED. If you are disabled and require a reasonable accommodation to gain access to the Magisterial District - Court and its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. IF YOU INTEND TO RESPOND BY MAIL: Detach and complete the lower portion of this summons with your signature on the appropriate plea line, (1) or (2). If you PLEAD NOT GUILTY, your check or money order must be in the amount of the total due specified above. If the total due is not specified, your check or money order must tie in the amount of $50.00 which will be held for collateral for your appearance at trial. You will be notified by mail of your date and time for trial. If you PLEAD GUILTY, enclose a check or money order in the amount of the total due specified above. Failure to remit the full amount of the fine, costs and fees will result in the issuance of a warrant for your arrest. Your check or money order shall be made payable to the "Magisterial District No.' above. (DETACH HERE) -----------------------------------------------_---------_----_----------------------------------- AIL IN PLEA I represent that I p ake this plea kn ly, v tap phi Ili ntly. (Failure to ' irate a plea when forvuarding an amount equal to the total dues ecified above w' ~ t7~.~' t. I PLEAD NOT GUILTY. ~a/kl~ Docket No.: NT-0001350-08 (Signature) 2. I PLEAD GUILTY. Citation No.: P7033713-1 AOPC 617-08 DATE PRINTED : 10 / 15 / 0 8 (Signature) 2 ; 31:5 8 PM µ.T/- _ ... M' ,,x:~ . d ~~~ ~:h r 1.: AApI~IMW OMtrial ~ 2 Comet ,~~e ~r~y & MR~ax _ . ~, ' ~ PA :rte ::. i:t r . ~• •, - ~- _ ~~ - ~: .~~ x s_ .. ~'~u~ ~e (A~ Q /ASiAir 1Q.~J't= ~±~~n ~~ ~ ~'~- ~ . Cl ~irr ~a~resc (B) : ^ Black :'' . f H) ^' Fnic '` fM C7 NoiNRes~ct ~p : L7 NatiosFn.• d .~]:~'~fni0rdivrt -,~~ ^ Female z ~~~,"~.1~ * ((t~ . .; s i 1 .~ = u.-@.ifp~eewre=..s ae.;,~~wrr, . ;.. ~ ~ .%... ..~ ~~ _ ytr.a ~ ems": L ,6 nn. ••.Q Yes. - © ves -~ ,: ^ DI~Q.r~flrly Condu~CI a Il .. CfirJ~paL T , ... E1 .Ta~e1t d $en~tces ^ tMIMn~ (fief . '...; ^ Harassment _ p;PulliicDrlmka0ness ^ .;Si^.O;RabbWr .., ` ~ , Then ~ ~umhase, Gonsim~ption Possession or Transportation of Liquor ot~MaR or Brewed BeVereges l~'~U19f ~ }~!" dse. i c ~. ~ .. .¢1 PL`tbde COLi&-IrTE£ 18 ~,t,~:~i; ~ ~ :. 10100 ~ , ~" ~ ror ~~.e~ ~' /.6~E7D1 ~ ~, 4~.t~.~:. d+~asx.rai:r+~.•~a= ::; ,: nue $/QS"~ ~~ 6~ ~ ~ ~~ . - ;> ~ ; ~ t aS a19 ~~'.h11M'x~{4`~'. 9 l~Q~t ilLtliW b uY zo b' ~ ull~w~ :~Ml~ .~ Cl 1994 ~ r # .: . :rn t ~~ .. ~$gtlart_. _ .. ~' i 5~~ t ~~ .w .. , '-" + ~~ .,. ... ~ .. x.,. ... ~ _. ..,. .... OIFeQ$~ Coda. ..-. -.:.. I6,i 'No .., ,:, 1&19 .;. _':. Y. ~.. ~-' 4E. :i!.~ _:... ~. ~- A9:;Y~tli1MK . . _ [] YildM1npon -- ^ Aswl~oil'LQE tl Nom.: . ~ - r-_ Er.~ ~.. .. _ S . ' _ - ~ ~ ~ "~ ~ ' _'w t -;`k,• r.. tt with ~... .. ... ._. ., .. .. a. .. - -. ~. .- gt~atk~o~~5'd~av.-fPtlUe} ~ ~. .. _ ~~ - ~~ Exl~ih~t ~ r •ti COMMONWEALTH OF~P=E'NNN"'!LVANIA f~l11 IAITV /`1 C. ~ L'.~fl~(gR1t T.A111 :V~yV1Y 1 1 VI - --- - Mag. Dist. No.: 09-1=01=` . MDJ Names Hon. CHARL$$ A'.. CLffi~I$NT, JR OLD$ T4iItNR CObIIrION3 -80ITH 3 NBW..CUMBLBI~IND, PA Te~e~rl«,e °(717) '774-5989' 17070 L J JOHN H . FR>38NAN 1066 30TH ST. N9~ Docket No.: NT-0001351-08 ~PASHINGTON, DC 20007 Date Filed: 10/15/08 $70 SS110.1..2 FIRS CODE VIOLATION _ ~ ~ _ ,.... . v _ ._ ...._..._ __..._.~. . _ ---..~_ ...-- - --_ ___.. ,__ FINE AND COSTS:I FINE: ~ I COST I OTHER: 1000.E SZ . ~ TOTAL DUE: ~ /O S Z. WITHIN TEN (10) DAYS OF RECEIPT OF THIS SUMMONS YOU MUST: 1. PLEAD NOT GUILTY by notifying the magisterial district judge above in wrfting and forwarding an amount equal to the total due specified above, or if the fine and costs are not spec'rf"ied, fonNard the sum of $50.00 as collateral for your appearance at trial; OR, 2. PLEAD NOT GUILTY by appearing before the magisterial district judge above and posting such collateral for your appearance as the magisterial district judge shall require; OR, 3. If you cannot afford to pay the total due specified above or the $50.00 collateral, you must appear before the magisterial district judge above to enter a plea; OR, 4. PLEAD GUILTY by notifying the magisterial district judge above in writing, signing the appropriate plea below, and forwarding an amount equal to the total due spec"rfied above: OR, 5. PLEAD GUILTY by appearing before the magisterial district judge above if the total due is not specffied or if you are required to appear because the offense vwth which you are charged tames a mandatory sentence of imprisonment, for example, a violation of 75 Pa.C.S. Section 1543(b) (Driving while operating privilege is suspended or revoked). IF YOU ARE FOUND GUILTY BY THE MAGISTERIAL DISTRICT JUDGE AND WISH TO APPEAL, YOU HAVE THIRTY (30) DAYS TO REQUEST A TRIAL DE NOVO IN THE COURT OF COMMON PLEAS. ALL CHECKS OR MONEY ORDERS FOR FINE, COSTS, FEES, O)~ FOR COLLATERAL, SHALL BE MADE PAYABLE TO 'MAGISTERIAL DISTRICT NO. '09 -1- O1 'IDENTIFIED ABOVE AND SENT TO THE ADDRESS ABOVE. IF YOU FAIL TO RESPOND TO THIS SUMMONS WITHIN THE TIME SPECIFIED ABOVE, A WARRANT FOR YOUR ARREST SHALL BE ISSUED. If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. IF YOU INTEND TO RESPOND BY MAIL: Detach and complete the lower portion of this summons with your signature on the appropriate plea line, (1) or (2). If you PLEAD NOT GUILTY, your check or money order must be in the amount of the total due specified above. If the total due is not specified, your check or money order must be in the amount of $50.00 which will be held for collateral for your . appearance at trial. You will be notified by mail of your date and time for trial. If you PLEAD GUILTY, enclose a check or money order in the amount of the total due specified above. Failure to remit the full amount of the fine, costs and fees will result in the issuance of a warrant for your arrest. Your check or money order shall be made payable to the "Magisterial District No.' above. (DETACH HERE) ----------------------------------~_~___-_------_----___~_______~_______~_-_-.__~~~-------°------------------------------- MAIL IN PLEA I re resent that I make this lea knowin volunt it ,~rtC'int entl . Failure to indi a plea when forwarding an amount equal to the total due specified abpove will re tin p alE ~.fi ~ded) ~ -' '` ~ "~ 0001351-08 1. I PLEAD NOT GUILTY. ~ Docket No.: ~'~'- ature) 2. I PLEAD GUILTY. Citation No.: P7033671-1 AOPC 617-of; DATE PRINTED : 10 / 15 / 0 8(Signature) 2 ; 3 5 :13 PM SU.MMO.NS ~i ~-:SU:MMARY CASE NO:N-TRAFFIC " COMMONWEALTH OF PENNSYLVANIA ~, ~,~~"1 ~. y i } PA r_:, gL~ortvt{o,~o,MM. ,"'4''jgp{F' ~R' ~- ~..' IIM°^tCE ~~ f .. .. -.. _ _.. ~ ~~ ~ .i ._ _ ..... . - _ -_ - '. _ ~Xhl~i~ J/ COMMONWEALTH OF PENNSYLVANIA ;OUNTY OF: ~~~' 09-1-01 MDJ Name: Hon. CHARLES A. CLEMENT, JR "da~ess: 4 0 0 BRIDGE ST OLDS TOWNE CODI3iON8 - ~IIITE 3 . NSW CIIMBERI.AND, PA Telephone: (717) 774-5989 17070 JOHN H . FRE'1~IAN 1066 30TH ST. NW WASHINGTON, DC 20007 c SUMMONS ~R A SUMMARY CASE NON-TRAFFIC COMMONWEALTH OF PENNSYLVANIA VS. DEFENDANT: NAAAE and AooRESs ~FjLEEI!SArT, JOHN H . 1066 30TH ST. NfiP WASHINGTON, DC 20007 L J Docket No.: NT-0001352-OS Date Filed: 10/15/08 $70 SS110.4 FIRE CODE VIOLATION FINE AND COSTS:I FINE: I COSTS: I OTHER: '~1G~0 . ~~ ~ SZ-. Ov TOTAL DUE: WITHIN TEN (10) DAYS OF RECEIPT OF THIS SUMMONS YOU MUST: 1. PLEAD NOT GUILTY by notifying the magisterial district judge above in wrting and forwarding an amount equal to the total due specified above, or if the fine and costs are not specffied, forward the sum of $50.00 as collateral for your appearance at trial; OR, 2. PLEAD NOT GUILTY by appearing before the magisterial district judge above and posting such collateral for your appearance as the magisterial district judge shall regwre; OR, 3. If you cannot afford to pay the total due specified above or the $50.00 collateral, you must appear before the magisterial district judge above to enter a plea; OR, 4. PLEAD GUILTY by notifying the magisterial district judge above in writing, signing the appropriate plea below, and forwarding an amount equal to the total due specified above: OR, 5. PLEAD GUILTY by appearing before the magisterial district judge above if the total due is not specified or'rf you are required to appear because the offense with which you are charged carries a mandatory sentence of imprisonment, for example, a violation of 75 Pa.C.S. Section 1543(b) (Driving while operating privilege is suspended or revoked). IF YOU ARE FOUND GUILTY BY THE MAGISTERIAL DISTRICT JUDGE AND WISH TO APPEAL, YOU HAVE THIRTY (30) DAYS TO REQUEST A TRIAL DE NOVO IN THE COURT OF COMMON PLEAS. ALL CHECKS OR MONEY ORDERS FOR FINE, COSTS, FEES, OR FOR COLLATERAL, SHALL BE MADE PAYABLE TO "MAGISTERIAL DISTRICT NO. O9 -1-01 'IDENTIFIED ABOVE AND SENT TO THE ADDRESS ABOVE. IF YOU FAIL TO RESPQND TO THIS SUMMONS WITHIN THE TIME SPECIFIED ABOVE, A WARRANT FOR YOUR ARREST SHALL BE ISSUED. If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. IF YOU INTEND TO RESPOND BY MAIL: Detach and complete the lower portion of this summons with your.signature on the appropriate plea line, (7) or (2). If you PLEAD NOT GUILTY, your check or money order must be in the amount of the total due specified above. If the total due is not specified, your check or money order must be in the amount of $50.00 which will be held for collateral for your appearance at trial. You will be notified by mail of your date and time for trial. If you PLEAD GUILTY, enclose a check or money order in the amount of the total due specified above. Failure to remit the full amount of the fine, costs and fees will result in the issuance of a warrant for your arrest. Your check or money order shall be made payable to the 'Magisterial District No." above. (DETACH HERE) --_~__~~_~______~~~~~.__~~__~ ~~M____~~_____~_. ~_____~~___~_~~_~_~~. L IN PLEA I represent that I make this plea knowin oI rilf~ln tly. (Failure to Indic a plea when forwarding an amount equal to the total due specified above will res t' Ity ple. in 1. I PLEAD NOT GUILTY. No.: NT-0001352_-08 2. I PLEAD GUILTY. ' Citation No.: P7033672-2 ~OPC 6~ 7-08 DATE PRINTED : 10 / 15 / 0 8(Signature) 2 : 3 8:54 PM e i ..._.. COMMONWL._.s OF PENNSYLVANIA CITATION NO. NON-TR.AF~FIMnN~ATION /~k } ~., ~ ~ ~ ~ ~ _ -y;~ t. District Numbsr r ~ 3. SodY Sewdy' N1unGr-. ~' ~ Atldrese d OYNtI q~ ~,•, S ' F `~~ " ~P ~ ~ T S. DrMla Number ~4~5'~$~ 7~ 8. State ^ PA (i (7 1it 3 i CF[~3I~I,Ai :"~~Vi ~ 7 7. DMSndam'a +a~ s. ~ ,/ is a~ ( ~Y T.~~~Y'°~ ~ .3' ~ ; J (,rte ; T E/, t:~ ~~i f r'~ # _~ } r L ,.'r <- , v 13. Casa Insobted by g. RecarE 10. Sax N. Dab d eirO1 12. (VV)~hfle (A) ^ Asian (M) ~ Male (MM~oDirq (R) Resident (0) ^ On•View Arrest (B) ^ Black (H) ^ Hispank (N) ^ Non-Resident C CdationlSummons (1) ^ Native American (U) ^ Unknown (Fl ^ Female U ^ Unknown O~ it. JWEMLE 15. Par4s Ndeled 16. Prsnre Noma f7. Dab rlotleetl 16. Time Q Yes ~ Yes 19. CMrpo ^ Disorderly Conduct ^ Criminal Trespass ^ Theft of Services ^ Criminal Mischief ^ Harassment ^ Public Drunkenness ^ Scattering Rubbish se, tjsurt~t(orL Qo.SSession or Transportation of Liquor or Malt or Brewed Beverages Retail Th J~ ~ ~ ~ ~ ` t # , J +~ '~ it !. Oth r e 20. are d OBemw ({{p f ,,,{ / t ry ~ is 21. Pa. Code 22 IME C DE TIT.LE}.@ ,~r^^ !! 23. SECTION 24. SUB SEC. rt }[ !.. : ~,J i~ ~ ~(~ r1 .~li~.. t.- l'4~~ ~Ll; i } iii +/i. i/~v~ t `"' !~t%'T %~bi S 25. FINE ~ f J uY.~~j~~'°Y~~. G.`r..~ _ n y .1r L (~ d{{{ ~ t~ a //{y } I (y!'. '1 4.~~~$(1., ~I ~~i 4N 7- l t ~ ~ ~'• 28. COSTS _ ~ f ~~-f.'.~^M pp ~1 } .-J y; Y f : t t.~ ... b s -'~~ it Y 6/~"i' fL ~' j } • ~. Y S 27. J.C.PIAT.J. 10.00 ~ . 4 y {~ f r~ ~'e ~+ " = I `x$ ~ ~ ~ ' ~ 29 28. L T ~! P~ .'';`~ . t~t'7r-~ ~P. t , . . ~r !~~s r {J is1 p In s.rx.e pea,ulw DUE 30. Detg j 31. Time 32 Dry 33. GBy7wp.Ba~rro .^ ., Y ) 34. Codq 35. Zone ty~aggg 1 i ( "~ /y > 38. ~~a k} ~ {i t ~ •'"' i ; ^ ~ ' ~ ' '. " f. 3T. '~; ~~:. £ ~.i._ ~5 ~) r } 38. code count ; f ; T u r e (; L )` l,.4 e fl ~.. v lowbdga Receipt d Cdadon 40. Date ^ leetlw 41. ~. DslaMam'S SlgnWwe • Ard X ^ FINd ' ^ Fged an kao. rc«vea 42. i verity Out Ore faM set toM ti tllis tibtion aro tr11e to Oa best d my bwwbdgs, Nlamntion and befar. Tbis vedeuean a matle sugad b On peneObs of Sac9on 4904 S tln Crimes Code (te PaC.S. $4904) rskling b unworn rebi8ra6on b autlwdtlas. lijlRE BADGE NUt.IBER ORI NUMBER ICER~ Sl F Ty i r ~ i le 43. SbOOn Adtlress aW~', L' vII ~ C€y__SI;r''{~:»2~~Itt~'~~ 44. OOensa Code d5. Property Record No. 48. Systems Code 47. 48. 49. IneMem No. ^ IrNiN nePed ^ AMnHOn I.CE 50. VINm's Name S1. Date o/ BhO1 (MM I DD/ YY) 52. Sax 53. RacdEOrcdGly 58~.,7Rsrnsdo 131Apoana lht .. fTit'~Y '{, :.LtS 1. elt)i~,.i.. ~~,i-1.V1~ L'~ ,~J{}v~ , WG`~` t+,wj)1,E~ ;3~''H VEIi ~~~=t a'; ~ ~:ti ciao:{E ~C)1: :r ~A~~~rr r ~~~ ~ ~T~~s TT; ilt,~~~'iAi U'; )~4 r tr f~F'.~ .. u f ~~a3i~~.%~' ~~„ A.~li s7. sew. IML ttedg. ra. ~~.3)~t i~'}'v4f AOPC 407-95 (Rev. 1/1/08) aEFE9d~nI~T1~ ~~~sy ~~~,lr+ E l COMMONWEA~.TH OF PENS ~.~/ANIA n~~ tntTV nF• f'D1~B$RLApD Mag. Oist. No.: 09-1-01 MDJ Name: Hon. CHABLSS A. CLSIlTSNT, JR Address: 400 B>6LIDG8 ST OLDS TOWNS COISbION3 -SIIITS 3 NSW CDMBS>6LLAND, PA Telephone: (717) 774-5989 17070 ,~: SUMMONS FOR A SUMMARY CASE NON-TRAFFIC COMMONWEALTH OF PENNSYLVANIA VS. DEFENDANT: NAME and a,oDRess rFRSSI[A>si, JOHN $ . ~ 1066 30TH ST. NW ~PASHINGTON, DC 20007 L J ,TOBN 8. F>6tEBS[AN 1066 30TH ST. HtiP Docket No.: NT-0001357-08 ~PASHINGTON, DC 20007 Date Filed: 10/16/08 Charge(s): $7 0 $ $110.4 FIBS CODS VIOLATION FINE: COSTS: OTHER: ` TOTAL DUE: FINE AND COSTS: ~/~, ~ ~ S7. Sa ~ ~ /OS7 S~ WITHIN TEN (10) DAYS OF RECEIPT OF THIS SUMMONS YOU MUST: ' 1. PLEAD NOT GUILTY by notifying the magisterial district judge above in writing and forwarding an amount equal to the total due specified above, or if the fine and costs are not specified, forward the sum of $50.00 as collateral for your appearance at trial; OR, p. PLEAD NOT GUILTY by appearing before the magisterial district judge above and posting such collateral for your appearance as the magisterial district judge shall regwre; Ofl, 3. If you cannot afford to pay the total due specified above or the $50.00 collateral, you must appear before the magisterial district judge above to enter a plea; OR, 4. PLEAD GUILTY by notifying the magisterial district judge above in writing, signing the appropriate plea below, and forwarding an amount equal to the total due specified above: OR, 5. PLEAD GUILTY by appearing before the magisterial district judge above ff the total due is not specified or "rf you are required to appear because the offense with which you are charged carves a mandatory sentence of imprisonment, for example, a violation of 75 Pa.C.S. Section 1543(b) (Driving while operating privilege is suspended or revoked). IF YOU ARE FOUND GUILTY BY THE MAGISTERIAL DISTRICT JUDGE AND WISH TO APPEAL, YOU HAVE THIRTY (30) DAYS TO REQUEST A TRIAL DE NOVO IN THE COURT OF COMMON PLEAS. ALL CHECKS OR MONEY ORDERS FOR FINE, COSTS, FEES, OR FOR COLLATERAL, SHALL BE MADE PAYABLE TO "MAGISTERIAL DISTRICT NO. 09 -1- O1 "IDENTIFIED ABOVE AND SENT TO THE ADDRESS ABOVE. IF YOU FAIL TO RESPOND TO THIS SUMMONS' WITHIN THE TIME SPECIFIED ABOVE, A WARRANT FOR YOUR ARREST SHALL BE ISSUED. If you are disabled and require a reasonable accommodation to gain access to the Magisterial District - Court and its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. IF YQU INTEND TO RESPOND BY MAIL: Detach and complete the lower portion of this summons with your signature on the appropriate plea line, (1) or (2). If you PLEAD NOT GUILTY, your check or money order must be in the amount of the total due specified above. If the total due is not specified, your check or money order must be in the amount of $50.00 which will be held for collateral for your appearance at trial. You will be notified by mail of your date and time for trial. If you PLEAD GUILTY, enclose a check or money order in the amount of the total due specified above. Failure to remit the full amount of the fine, costs and fees will result in the issuance of a warrant for your arrest. Your check or money order shall be made payable to the "Magisterial District No." above. (DETACH HERE) ---------------------------------------------------------------------------------------------------------------------------------------- t IN PLEA I represent that I make this plea know' vo to Iligently. (Failure to ' icate a plea when forwarding an amount equal to the total due specified above will r pl n 1. I PLEAD NOT GUILTY. ~ P wlt Docket No.: NT-0001357-08 (Signature) 2. I PLEAD GUILTY. Citation No.: P7033715-3 enprat~_nst DATE PRINTED: 10/17/08(Signature) 10:57:38 AM r .. s 6 ~~ h,: D PA .. Yes ~~ Yas 's,. _ a , r ~a: ary. ~Itschief ~. ~. In p,i --~'p'~iOa ,4yry ~' .7s, } z'};~''~~ Eti h AmrMOn LCE .. $:~'Red nr~y ~~~'' - .. COMMONWEALTH OF PENN )VANIA COUNTY OF: CU1~~ERLAND ~ Mag. Dist. No.: 09-1-01 JOS>Di H . FRES~iN 1066 30TH ST. NAP ~PAS8INt3T0N, DC 2 0 0 07 870 8jg110.1.2 FIRE CODE VIOLATION PENNSYLVANIA VS. DEFENDANT:. NAME and ADDRESS ~1+'8ggl~AN, JOffi~i' 8 1Q6f~30TH ST. ' 1PA$HI1DT(3TO1Q, DC 20007 -1 L J Docket No.: NT-0001358-08 Date Filed: 10/16/08 FINE: COSTS: OTHER: TOT,ASL DUE: FINE AND COSTS: ~ /DDO_Q'~ ~ SZ.Oo lOS2_~ WITHIN TEN.(10) DAYS OF RECEIPT OF THIS SUMMONS YOU MUST: 1. PLEAD NOT GUILTY by notifying the magisterial district judge above in writing and forwarding an amount equal to the total due specified above, or if the fine and costs are not specified, forward the sum of $50.00 as collateral for your appearance at trial; OR, 2. PLEAD NOT GUILTY by appearing before the magisterial district judge above and posting such collateral for your appearance as the magisterial district judge shall require; OR, 3. If you cannot afford to pay the total due specirfied above or the $50.00 collateral, you must appear before the magisterial district judge above to enter a plea; OR, 4. PLEAD GUILTY by notifying the magisterial district judge above in writing, signing the appropriate plea below, and forwarding an amount equal to the total due specified above: OR, 5. PLEAD GUILTY by appearing before the magisterial district judge above 'rf the total due is not specified or if you are required to appear because the offense with which you are charged carves a mandatory sentence of impnsonment, for example, a violation of 75 Pa.C.S. Section 1543(b) (Driving while operating privilege is suspended or revoked). IF YOU ARE FOUND GUILTY BY THE MAGISTERIAL DISTRICT JUDGE AND WISH TO APPEAL, YOU HAVE THIRTY (30) DAYS TO REQUEST A TRIAL DE NOVO IN THE COURT OF COMMON PLEAS. ALL CHECKS OR MONEY ORDERS FOR FINE, COSTS, FEES, OR FOR COLLATERAL, SHALL BE MADE PAYABLE TO "MAGISTERIAL DISTRICT NO. 09 -1-01 "IDENTIFIED ABOVE AND SENT TO THE ADDRESS ABOVE. IF YOU FAIL TO RESPOND TO THIS SUMMONS WITHIN THE TIME SPECIFIED ABOVE, A WARRANT FOR YOUR ARREST SHALL BE ISSUED. If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. IF YOU INTEND TO RESPOND BY MAIL: Detach and complete the lower portion of this summons with your signature on the appropriate plea line, (1) or (2). If you PLEAD NOT GUILTY, your check or money order must be in the amount of the total due specified above. If the total due is not specified, your check or money order must be in the amount of $50.00 which will be held for collateral for your appearance at trial. You will be notified by mail of your date and time for trial. If you PLEAD GUILTY, enclose a check or money order in the amount of the total due specified above. Failure to remit the full amount of the fine, costs and fees will result in the issuance of a warrant for your arrest. Your check or money order shall be made payable to the,"Magisterial District No." above. ------------°----- 9°------------q (DETACH HERE) --- ---------------------------------------------- p -------~-----~------~- AIL IN PLEA I represent that I make this plea knowin of to telligently. (Failure to ' cafe a lea when forwardiri an amount a ual to the total due specified above will r t a b to ~~cc~d~d~- 1. I PLEAD NOT GUILTY. Docket No.: pT-0001358 08 n r 2. I PLEAD GUILTY. Citation No.: P7033714-2 A()PCS17-08 DATB PRINTED: 10/17/08( ignature 11:09:02 A>IS ll SUMMONS F.~R A SUMMARY CASE NON=TRAFFIC COMMONWEALTH OF t .. .... _ . 6 liquor or':t~altror Br~lved Beverages ,' I .yro_ . ~~ JOHN H . FBB _. 1066 30TH ST. 1ll~i Docket No.: DT-0001359-08 ~ASHINaTON, DC 20007. Date Filed: 10/16/08 - - - Char e s Ii TO ~$ 31 .2.1 F188 COD 1TIOLATL~ ~,, ~ _,~ ~ _ - ,~ ~..fi... r+'~.. p~ d~3an,::....~t ~..a~.+d.,%5t~; _ ?~~.'.l~i.''4 5. ~+asic._ f ~.°_ •r.'..s ~ , x _:s-~ T,;°^' :.~`. _-a,:~~ .~.~t•.~u..:...e.`. :1 FINE: COSTS. OTHER: TOTAL DUE: FINE AND COSTS: ~/~.pp ~ $"Z,~ `~ /OSZ.Ov W(THIN TEN10) DAYS OF RECEIPT OF-THIS SUMMONS YOU MUST: 1. PLEAD NOT GUILTY by notifying the magisterial district judge above in writing and forwarding an amount equal to the total due . specified above, or if the fine and costs are not specified, forward the sum of $50.00 as collateral for your appearance at trial; OR, 2. PLEAD NOT GUILTY by appearing before the magisterial district judge .above and posting such collateral for your appearance as the magisterial district judge shall require; OR, 3. If you dannot afford to pay the total due specified above or the $50.00 collateral, you must appear before the magisterial district judge abbvr~ to enter a plea; OR, 4. PLEAD GUILTY by notifying the magisterial district judge above in writing, signing the appropriate plea below, and forwarding an amount equal to the total due specfied above: OR, 5. PLEAD GUILTY by appearing before the magisterial district judge above if the total due is not specified or'rf you are required to appear because the offense with which you are charged carries a mandatory sentence of imprisonment, for example, a violation of 75 Pa.C.S. Section 1543(b) (Driving while operating privilege is suspended or revoked). IF YOU ARE FOUND GUILTY BY THE MAGISTERIAL DISTRICT JUDGE AND WISH TO APPEAL, YOU HAVE THIRTY (30) DAYS TO REQUEST A TRIAL DE NOVO IN THE COURT OF COMMON PLEAS. ALL CHECKS OR MONEY ORDERS FOR FINE, COSTS, FEES, OR FOR COLLATERAL, SHALL BE MADE PAYABLE TO 'MAGISTERIAL DISTRICT NO. 09 -1- O1 "IDENTIFIED ABOVE AND SENT TO THE ADDRESS ABOVE. _ _ _ _ ...: _..IF YQU FAII. TO RESPOND TO THIS SUMMONS WITHIN THE TIME SPECIFIED A67JVE, A WARRANT-FOR YOUR - - -- ARREST SHALL BE ISSUED. If you are disabled and require a reasonable accommodation to gain acce,~s to the Magisterial District - Court and its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. IF YOU INTEND TO RESPOND BY MAIL: Detach and complete the lower portiori of this summons with your signature on the appropriate plea line, (1) or (2). If you PLEAD NOT GUILTY, your check or money order must be in the amount of the total due specified above. If the total due is not specified, your check or money order must lie in the amount of $50.00 which will be held for collateral for your appearance at trial. You will be notified by mail of your date and time for trial. If you PLEAD GUILTY, enclose a check or money order in the amount of the total due specified above. Failure to remit the full amount of the fine, costs and fees wilt result in the issuance of a warrant for your arrest. Your check or money order shall tie made payable to the "Magisterial District No." above. (DETACH HERE) -----------~~_~~~_~_~_________r______~_~_~~------------------~-=-- I represent that I make this plea knc to the total due specified above will 1. I PLEAD NOT GUILTY. 2. I PLEAD GUILTY. / ~` AOPC 617-08 DATE PRI1~T$D : 10 / 2 0 / 0 to Indic a plea when forwarding an amount equal .r-....- ~~:.'~.. ~.... No.: p'T-0001359-08 Citation No.: P7033738-5 12:25:29 PM ,~" / + ~~' ~~^_ ~; _ 6. $4Y ' 0 PA ~ .~. w ... '~+^'Y~dS'~f!i Z~i-Viaw Amict'.~ n l~°nFwr>- -- irali a Brewed 9eveiages' ' G ~ ~~' ~ ~ lA l f" t R.. v~°~ { ~~~'`~ ~' ~~ ~ ~1~ BeCC9n t9~1C ~tl ~ 11 _ 5 .:. a .t 3'" x .z F}+Sa~ AF ti +~ z-; '~''f.. ~ c"{ F~pp~7(g{ER -. x ' t~ #t ~ ~ ~ fi - ~ ©~ Z - p, , c ~t~ ~;. 8 ' • .. M.OMMreeCOda Reribfq llo- ~ ~~ A'?Oe IB.CoO~__ a7: - ~e z ;. i9~'k~dtlen(',No. ~ '. - ~ -- --- A .1` 907-95.(Rav 1UIDB).. '~ ~x~}. z`'t r -"-'-',.~~~,qp .. - COMMONWEALTH :OF PENS' }VANIA - ~ COUNTY OF: ~' Mag. Dist: No.: 09-1=01 MDJ Name: Hon. ' C8A8LS3 A. CL~r JR Address.4t1.Q_„$R~DGS ST OLDS TO1~8 COlM~dON3 - $IIITL 3.. - ~ NSN CIIbI~SRLAND, PA . Telephone (717) 774-.59.89 17070 JO]~ H . FRSSb1AN 1066 30TH ST. p9i ~PASBINGTON, DC 20007 ,;k ~~ ~ SUMMONS ~ .,/~ A SUMMARY CASE NON=TRAFFIC COMMONWEALTH OF PENNSYLVANIA VS. DEFENDANT: NAME and ADoR~ss ~F]6LSB>f<A~Tr JOS>!~ ~ H 10.6.b, °.3QT8 ST . S~ ~8I1~©TON, DC "2 0 0 07 L J Docket No.: 1QT-0001360-08 Date Filed: 10/16/08 $16 2 -1 $ $10 8 1 1 P>6LOPSRTY MAI]~TSls<ANCS CODS FINE AND COSTS: FINE: COSTS: I OTHER: I TOTAL DUE: WITHIN TEN (10) DAYS OF RECEIPT OF THIS SUMMONS YOU MUST: 1. PLEAD NOT GUILTY by notifying the magisterial district judge above in writing and forwarding an amount equal to the total due specified above, or if the fine and costs are not specified, forward the sum of $50.00 as collateral for your appearance at trial; OR, 2. PLEAD NOT GUILTY by.appearing before the magisterial district judge above and posting such collateral for your appearance as the magisterial district judge shall require; OR, 3. If you cannot afford to pay the total due specified above or the $50.00 collateral, you must appear before the magisterial district judge above to enter a plea; OR, 4. PLEi~D GUILTY by notifying the magisterial district judge above in writing, signing the appropriate plea below, and forwarding an amount equal to the total due specified above: OR, 5. PLEAD GUILTY by appearing before the magisterial district judge above if the total due is not specified or if you are required to appear because the offense with which you are charged carries a mandatory sentence of imprisonment, for example, a violation of 75 Pa.C.S. Section 1543(b) (Driving while operating privilege is suspended or revoked). IF YOU ARE FOUND GUILTY BY THE MAGISTERIAL DISTRICT JUDGE AND WISH TO APPEAL, YOU HAVE THIRTY (30) DAYS TO REQUEST A TRIAL DE NOVO IN THE COURT OF COMMON PLEAS. ALL CHECKS OR MONEY ORDERS FOR FINE, COSTS, FEES, OR FOR COLLATERAL, SHALL BE MADE PAYABLE TO "MAGISTERIAL DISTRICT NO. 09 -1-01 "IDENTIFIED ABOVE AND SENT TO THE ADDRESS ABOVE. IF YOU FAIL TO RESPOND TO THIS. SUMMONS;WITNIN THE TIME SPECIFIED ABOVE, A WARRANT FOR YOUR ARREST SHALL BE ISSUED. If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. _. IF YOU INTEND TO RESPOND BY MAIL: Detach and complete the lower portion of this summons with your signature on the appropriate plea line, (1) or (2). If you PLEAD NOT GUILTY, your check or money order must be in the amount of the total due specified above. If the total due is not specified, your check or money order must be in the amount of $50.00 which will be held for collateral for your appearance at trial. You will be notified by mail of your date and time for trial. If you PLEAD GUILTY, enclose a check or money order in the amount of the total due specified above. Failure to remit the full amount of the fine, costs and fees will result in the issuance of a warrant for your arrest. Your check or money order shall be made payable to the "Magisterial District No." above. (DETACH HERE) -------------------- -----------°------------------------------------°---~~~~~--~°------------ --------------- -- MA N PLEA I represent that I make this plea knowin v~al~u~ nl n .` " ntly. (Failure to Indic a plea when forwarding an amount equal to the total due specified above will re It•i °LW':ry_p Ong ~~~~~~ r v r ~ ~~ ~ Docket No.: -0001360-08 _ 1. I PLEAD NOT GUILTY. re) 2. I PLEAD GUILTY. Citation No.: P7033737-4 AOPC 617-Ot3 DATE PRINTED : 10 / 2 0 / 0 8 ignature) 12:4 5 : 3 2 PM .,..mow.,: ~ :.: '' ~ Yes: -;Q Yes - - ~e..cn.wduct ~:yCnrri(taFFr4Spass ~}..Zkietl0~$e_,~ Q C~nsnp~,~Ais~ret - ~ I'l':_~..N~r tlnuJcanrwss..'.~ ~},...$Cduedr~:A4libb~h -: r!?s ..~uf?'?~.i#'.+/ ~.t l' ._ ~~s~ to ~ >l r14d41 n~sHnO+o 4fnrann7a'lal~q~M~. $Af~C1 ~ ~ _ EFL ~"~1 ~~ 3• .: . w ...i'E 13~S9eAlan AddiMS .. ... ~ .. ~. ~.- - ._ ~ ., N.~ __ - , `~4~R~ ;- .~.o ~kl,ih~t G CHESAPEAKE MANAGEMENT CTROUP, INC. November 6, 2008 Mr. Charles A. Clement, Jr. 400 Bridge Street Olde Towne Commons -Suite 3 New Cumberland PA 17070 Re: Docket Numbers: NT-0001349-08 NT-00013 51-08 NT-0001350-08 NT-0001352-08 Dear Mr. Clement: Attached are pleadings relating to the 4 referenced dockets. I was out of the country from October 18, 2008, until October 30, 2008, and thus received the summons Thursday ,October 30, 2008, as they were delivered to my office. My mother, Frances Freeman, the owner of the property is confined to a nursing home and is suffering from dementia. My brother and I were unawarethat abreak-in had occurred and we visited the premises on October 31S` and November 1, 2008, to re-secure the premises. We are taking steps to address other issues as follows: (1) two masonry contractors have been, requested to submit proposals to address the masonry condition on the chimney; the chimney top does need some work but I do not believe that it poses an imminent safety problem (2) the debris on the rear porch and in the basement will be removed this Friday, November 7, 2008 (3) the.front porch does have some rotted wood but is not structurally unsound. 1066 - 30TH STREET, N.W., WASHINGTON, D.C. 20007 (202) 333-8312/ TELEFAX (202) 333-0295 t' 4 t i My brother, Jan Freeman, has spoken with Lor~ver Allen Township Building officials and informed them that we are intent upon removing all contents from the house in conjunction with offering it for sale as soon as possible. We hope to have the property empty by the end of the month and sold quickly. Duplicate summons (NT-0001358-08, NT-0001357-08, NT-0001360-08 and NT- 0001359-08 are also pled not guilty and are enclosed. This pleading is within the 10 day period as determined by the October 30, 2008, date of receipt which occurred upon my return to my office. Thank you for your cooperation. Sincerely, C~---~ J hn K. Freeman for rances Freeman cc: Jan Freeman Linus Fenicle E,~ bi 6; f G rniu~unNwFO1 TH OF PENNSYLVANIA COURT OF COMMON PLEAS Judicial District, County Of Cumberland FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT COMMON PLEAS No. NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District Judge on the date and in the case referenced below. NAME OF APPELLANT nnA~. uis ~ . rvv. Freeman, John K. 09-1-01 Clement, Charles A. Jr. ADDRESS OF APPELLANT CITY STATE ZIP CODE 1066 30th St. NW Washington DC 20007 DATE OF JUDGMENT IN THE CASE OF (Plaintiff) (De/endant)' Commonwealth of Pennsylvania ~ ~reeman, John K. NT-0001349-08 This block will be signed ONLY when this notation is required under Pa. R.C.P.D.J. No. 10086. This Notice of Appeal, when received by the Magisterial District Judge, will operate as a SUPERSEDERS to the judgment for possession in this case. was Claimant (see Pa. R. C. P. D. J. No. 1001(6) before a Magisterial District Judge, A COMPLAINT MUST BE FILED within twenty (20) days after tiling 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 ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before Magisterial District Judge. 1F NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon Name of appellees) appellee(s), to file a complaint in this appeal (Common Pleas No. )within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or attorney or agent RULE: To Name of appellees) appellees) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. Date: . 20 NOTICE OF APPEAL Signature of Prothonotary or Deputy YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-05 r_niuiunNwFOI TH OF PENNSYLVANIA OOURT~OF COMMON PLEAS Judicial District, County Of Cumberland FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT COMMON PLEAS No. NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District Judge on the date and in the case referenced below. NAME OF APPELLANT MAG. DISI. NV. rvr~mc yr mva Freeman, John K. 09-1-01 Clement, Charles A. Jr. ADDRESS OF APPELLANT CITY STATE ZIP CODE 1066 30th St. NW Washington DC 20007 DATE OF JUDGMENT IN THE CASE OF (Plaintiff) (Defendant)' Commonwealth of Pennsylvania ~ reeman, John K. DOCKET No. SIGNATU PELLANT OR EY OR AG T NT-0001350-08 /~ .~~' , This block will be signed ONLY when this notation is required under I'a. R.C.P.D.J. No. 10088. This Notice of Appeal, when received by the Magisterial District Judge, will operate as a SUPERSEDERS to the judgment for possession in this case. appellant was Claimant (see Pa. R. C. P. D. J. No. 1001(6) in actlon before a Magisterial District Judge, A COMPLAINT MUST BE FILED within twenty (20) days after frling the NOTICE of APPEAL. Signature of Prothonotary or Depufy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.D.J. No. 1001(7) in action before Magisterial District Judge. IF NOT USED, detach from copy of notice of appeal to be se-ved upon appellee. PRAECIPE: To Prothonotary Enter rule upon appellee(s), to file a complaint in this appeal Name of appellees) (Common Pleas No. )within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or attorney or agent RULE: To appellees) Name of appellees) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. Date: . 20 NOTICE OF APPEAL Signature o(Prothonotary or Deputy YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTITRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-05 ~n~^~unr~wGe~ TW nF PENNSYLVANIA GOURI~OF COMMON PLEAS Judicial District, County Of Cumberland COMMON PLEAS No. NOTICE OF APPEAL NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District Judge on the date and in the case referenced below. Freeman, John K. 1066 30`" St. NW Washington NAME OF MDJ Clement, Charles A. Jr. DC 20007 IN THE CASE OF (Plainfi(f) Commonwealth of Pennsylvania NT-0001351-08 This block will be signed ONLY when this notation is required under Pa. R.C.P.D.J. No. 10088. This Notice of Appeal, when received by the Magisterial District Judge, will operate as a SUPERSEDERS to the judgment for possession in this case. Signature of Prothonotary or Deputy FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT John K. appellant was Claimant (see Pa. R.C. P.D.J. No. 1001(6) in before a Magisterial District Judge, A COMPLAINT MUST BE FILED within twenty (20) days after filing the NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before Magisterial District Judge. lF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon Name of appellees) appellee(s), to file a complaint in this appeal (Common Pleas No. )within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or attorney or agent RULE: To , appellees) Name of appellees) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. Date: . 20 Signature of Prothonotary or Deputy YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTlTRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-05 ..~..nurw~ Tu nc DCAIIJCVI VoNh4 ~ OOURT~OF COMMON PLEAS Judicial District, County Of Cumberland NOTICE OF APPEAL FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT COMMON PLEAS No. NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District Judge on the date and in the case referenced below. Freeman, John K. 1066 30~" St. NW Washington IN THE CASE OF (Plaintiff) Commonwealth of Pennsylvania NT-0001352-08 This block will be signed ONLY when this notation is regwrea unaer ra. R.C.P.D.J. No. 10086. This Notice of Appeal, when received by the Magisterial District Judge, will operate as a SUPERSEDERS to the judgment for possession in this case. Clement, Charles A. Jr. STATE DC (Defendant)' Fr man, John K. VS O A NT OR R OR AGE sllant was Claimant (see Pa. R. C.P.D.J 1(6) in action before a Magisteria! Disfrict Judge, A COMPLAINT MUST BE FILED within twenty (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 ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before Magistefial District Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon Name of appellees) (Common Pleas No. appellee(s), to file a complaint in this appeal within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or aftomey or agent RULE: To appellees) Name of appellees) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. Date: . 20 Signature of Prothonotary or Deputy YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTPI'RANSCRIPT FORM WITH THIS NOTICE OF APPEAL. 20007 AOPC 312-05 • • PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER irling of the notice of appeal. Check applicable boxes.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ; ss AFFIDAVIT: I hereby (swear) (affirm) that I served ^ a copy of the Notice of Appeal, Common Pleas No. (date of service) , 20 , upon the Magisterial District Judge designated therein on ^ by personal service ^ by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) , on 20 ^by personal service^ by (certified) (registered) mail, sender's receipt attached hereto. (SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF , 20 Signature of official before whom affidavit was made Signature of affiant Title of official My commission expires on , 20 AOPC 312A - 05 C'~ *°~ -a t ~~~ n w ,~ ~ ~ ~ a~ ~ - ~,.~ J << ~ :>. j~, ^~