HomeMy WebLinkAbout09-0775?j
Bryan W. Shook, Esquire
ID # 203250
The Law Office of Darrell C. Dethlefs
2132 Market Street
Camp Hill, Pennsylvania 17011
Telephone - (717) 975-9446
Fax - (717) 975-2309
BShookCdcdlaw.net Attorney for Plaintiff
THOMAS J. GAUL and IN THE COURT OF COMMON PLEAS
GEORGINE GAUL, his wife CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V. No: 09- '715 CfVlllirm
LEHMAN GROUP, INC. t/d/b/a CIVIL ACTION - LAW
LEHMAN PROPERTY
MANAGEMENT, :
Defendant
NOTICE TO DEFEND AND CLAIM RIGHTS
NOTICE TO DEFEND
You have been sued in Court. If you wish to defend against the claims set forth in
the following pages, you must take action within twenty (20) days after this Complaint
and Notice are served, by entering a written appearance personally or by attorney, and
filing in writing with the Court your defenses or objections to the claims set forth against
you. You are warned that if you fail to do so, the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money
claimed in the Complaint or for any 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 OR KNOW A LAWYER, THEN YOU SHOULD GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
NOTICIA
Le han demandado a usted en la corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas signuientes, usted tiene vienta (20) dias
de plazo al partir de al fecha de la demanda y la notificacion. Usted debe presentar una
apariencia escrita o en persona a por abogado y archivar en la corte en forma escrita
sus defensas o sus objectiones a las demandas en contra de su persona. Sea avisado
que si usted no se fefiende, la corte tomara medidas y puede una orden contra usted
sin previo aviso o notificacion y por cualquier queja o akuvui que es pedido en la
peticion de demanda. Listed puedo parder dinero o sus propiedades o otros derechos
importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE
ABOGADO 0 SI NO TIENE EL DIMERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA 0 LLAME POR TELEPONO A LA OFICINA CUYA DIRECCION
SE EMCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSSGUTA ASISTENCIA LEGAL:
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Respectfully Submitted
a
Date: ` 9 - ° 9 By: 62 JVVIL
Brya . Shook, Esquire
Attorney Id. No.: 203250
2132 Market Street
Camp Hill, PA 17011
(717) 975-9446
Attorney for Plaintiff
4. Prior to November 8, 2007, Plaintiffs, Thomas J. Gaul and Georgine Gaul, his
wife, purchased several investment properties, including, but not limited to:
a. 1940 Bellevue Road, Harrisburg, Dauphin County, Pennsylvania
b. 216-218 4th Street, Enola, Cumberland County, Pennsylvania
c. 1929 Market Street, Harrisburg, Dauphin County, Pennsylvania
d. 2233 North 6th Street, Harrisburg, Dauphin County, Pennsylvania
e. 2200 Walnut Street, Harrisburg, Dauphin County, Pennsyvlania.
5. On or about November 8, 2007, Plaintiffs and Defendant entered into a
Management and Leasing Agreement (hereinafter referred to as "Agreement")
covering the five properties identified in paragraph 4 above. (A copy of the
aforementioned Management and Leasing Agreement is attached hereto, made
part hereof and marked as Exhibit "A").
6. On or about September 4, 2008, Plaintiffs timely tendered their written notice to
quit services and terminate the aforementioned November 8, 2007 Agreement to
Defendant. (A copy of the aforementioned September 4, 2008 letter to Defendant
is attached hereto, made part hereof and marked as Exhibit "B").
7. Plaintiffs believe and, therefore, aver, that Defendant breach its duties under the
Agreement by, but not necessarily limited to:
a. Failing to collect rents and payments due in violation of Paragraph 2(b) of
the Agreement;
b. Failing to deposit all rents and payments due to Plaintiffs, including the
collection of delinquent rents and payments in violation of Paragraph 2(b)
of the Agreement;
c. Failing to submit timely, complete, accurate monthly operating financial
statements to Plaintiffs in violation of Paragraph 2(f) of the Agreement;
d. Failing to arrange for and supervise Defendant's employees or outside
contractors to perform regular maintenance on Plaintiff's properties in
violation of Paragraph 2(g) of the Agreement;
e. Failing to arrange for and supervise determination of major repairs in
violation of Paragraph 2(h) of the Agreement;
f. Failure to pay utilities, including, but not necessarily limited to, gas and
electric utility bills, on behalf of Plaintiffs in a timely fashion whereby
causing Plaintiffs to incur late fees and charges, irreparable harm to
Plaintiff's credit reports and require Plaintiffs to place security deposits to
secure utility services;
g. Failing to provide Plaintiffs with tenants' security deposits upon termination
of the Agreement; and
h. Failing to provide Plaintiffs monies received to date from rents collected.
8. Plaintiffs believe and therefore aver that Defendant breach its duty of good faith
and fair dealing inherent in every contract.
9. The total rents that should have been received by Defendant from tenants, if all
rents were paid during the time Defendant was managing Plaintiffs' properties,
should have been $63,635.00.
10. Defendant's management fee, as outlined on Schedule A to the Agreement is 7%
or $4,454.45 of the aforementioned $63,635.00.
11. Therefore, Plaintiffs share of the $63,635.00 would be $59,180.55 which is
computed by subtracting the $4,454.45 (management fee) from the $63,635.00
(total rents).
12. Defendant should have received $5,450.00 to hold, in the form of security
deposits, from tenants.
13. To date, Plaintiffs have received $32,489.28 from Defendant in the form of rents
collected.
14. To date, Defendant has not surrendered possession of the tenants' security
deposits despite the termination of the Agreement by Plaintiffs.
WHEREFORE, Plaintiffs demand judgment against the Defendant in the amount of
$26,691.27 for rental payments not received as well as $5,540.00 for the tenants'
security deposits and whatever other relief this Honorable Court deems necessary and
just.
Respectfully Subnmitt)ed,
Dated: Ol - I - O q 6
Bryan W Shook, Esquire
Attorney Id. No.: 203250
2132 Market Street
Camp Hill, PA 17011
(717) 975-9446
MANAGEMENT AND LEASING AGREEMENT OWNER
Uhtmn Proprty Managemat (I&"
THIS AGREEMENT, made this 8'h day of November, 2007, by and between Thomas J.
Gaul of Lewisberry, PA (hereinafter called "Owner') and Lehman Property Management,
(hereinafter called LPM).
WHEREAS, Owner is the owner of the property, (hereinafter called the property) listed on the
attached property list, schedule A.
WHEREAS, LPM, a licensed real estate broker, is engaged in the business of leasing and
property management in the Central Pennsylvania area; and
WHEREAS, Owner requires leasing and property management services and LPM is ready,
willing and able to provide such services;
NOW THEREFORE, in consideration of the services to be rendered, the compensation to be
paid, and mutual covenants herein contained, the parties hereto, intending to legally bind
themselves and respective successors and assigns, do hereby agree as follows:
L F.. plovment. Owner hereby employs LPM, as an independent contractor, to perform the
services described herein, and does agree to pay LPM therefore the compensation agreed
upon herein. LPM accepts such employment and agrees to perform the services
described.
2. Duties of LPM
a. Negotiate, prepare and execute all leases for the Properties.
b. Collect and deposit all rents and payments due to Owners, including the
collection of delinquent rents and payments. Establish an account at integrity
Bank, in the name of LPM, to serve as a trust account for owner funds.
c. Establish a separate escrow account for deposits of tenant deposits required by
law to be maintained in an escrow account.
d. Approve and pay all operating bills for the properties from funds available in
the owners trust account.
e. Pay any other bills of the properties as directed by Owner from funds
available in the owners trust account.
MANAGEMENT AND LEASING AGREEMENT
Lebman Property Management (19/07)
f. Submit complete monthly operating financial statements to the Owner for the
properties.
g. Arrange for and supervise LPM employees or outside contractors to perform
regular maintenance work on the properties.
h. Arrange for and supervise determination of major repairs and, with Owner
approval, proceed with the work.
3. Operating Expenses. Include as operating expenses of the Properties:
a. LPM compensation. As compensation for the services described, Owner shall
pay leasing commissions and a management fee as described below:
i. Leasing Commission. The following shall be deemed earned by LPM
upon delivery of an executed lease by a prospective tenant. These
commissions shall be payable upon receipt from a tenant of the first
months rental and security deposit. The commission is a percentage of
the gross rent for the term of the lease. The percentage is specified on
schedule A.
ii- Renewal Commission. The following shall be deemed earned by LPM
upon delivery of an executed lease renewal by the current tenant.
These commissions shall be payable upon receipt from a tenant of the
first months rental after the start of the new lease. The commission is a
flat fee which is specified on schedule A.
iii. Management Fee. As compensation for its continuing management
services, Owner shall pay LPM a management fee as a percentage of
the monthly gross income of the Properties, payable each month as
billed. The term "Gross Income" shall include all collected rents and
other income and charges from normal operation of the premises,
including but not limited to rents, late rent, parking fees, laundry
income, forfeited security deposits, pet deposits, other fees and
deposits and other miscellaneous income. Gross income shall include
Owner-occupied space at market rental rate whether collected or not
(last sentence is not applicable).
Owner Page 2 of 6 LPM
MANAGEMENT AND LEASING AGREEMENT
Lehman Property Management (101107)
iv. Adminiltrative Fee. As compensation for arrangement and tracking of
various work performed by subcontractor, specialized advertising
campaigns, handling of insurance claims, etc. This fee has a maximum
of 10% of the actual cost and a minimum fee of $5.00.
b. All actual maintenance work performed on the Properties by IPM employees,
billed as specified on schedule B
c. All costs of sub-contractor work performed on the properties.
d. All purchase of supplies, materials, advertising, and promotion for the
properties.
e. All purchases of equipment and parts for sole use of the properties.
f. Costs of utilities and services necessary to the properties.
g. Costs of any and all legal fees for any reason, including but not limited to the
collection of delinquent rents and evictions.
h. All real estate taxes, insurance premiums, assessments for municipal
improvements and governmental levies on the properties.
4. Owner Consent. LPM will first secure the consent of Owner before making expenditures
in excess of the sum of $300 dollars per property in connection with the costs of outside
contractor work (including legal expenses), purchase of supplies and materials and
purchase of equipment and parts, unless such expense is incurred under such
circumstances, as LPM shall reasonably deem to be an emergency.
5. Compensation to LPM. As compensation for the leasing and management services
described above, Owner shall pay LPM any leasing commission or management fee
earned. LPM shall deduct this compensation as a priority operating expense from rents
collected prior to payment of any other expenses or to payment to owner.
Owned - Page 3 of 6 LPM
I U -,C*/
MANAGEMENT AND LEASING AGREEMENT
Lehmmn Property Mon Bement (10W)
6. Term of Emploxmgnt. This agreement shall be for a term of one year from the date
hereof: provided that either party may terminate this Agreement upon (90) days' written
notice to the other. If not so terminated, this agreement shall be deemed to be renewed for
a like term on each successive anniversary date hereof. U Owner terminates agreement
within the initial twelve (12) months, it will pay a termination fee of $300.00 per property
in addition to any other funds due to LPM for incurred expenses, except that if LPM is
terminated with cause, there shall be no termination fee payable by Owner other than that
portion earned to date.
7. Rental Collection and payments. LPM shall collect all rents and payment due Owner
under the lease, and shall pay all operating expenses of the Properties, provided,
however, that in the event rental collections are not sufficient to pay all such expenses,
LPM shall promptly notify Owner and detail for Owner the amount of such shortage and
the vendors or other persons who cannot be paid by reason thereof. LPM shall have no
responsibility to fund such operating deficit in any way. All vendors and other creditors
of the Properties shall bill Owner, in care of LPM as such address as LPM shall
designate.
8. Not Partners. It is expressively agreed that LPM shall act hereunder as an independent
contractor subject only to the general supervision of Owner, and that LPM is not a
partner, joint venture with or agent of Owner, has no interest in the profits and losses of
Owner, and is connected with Owner only as set out in this agreement.
9. Discharge gf Liability. Owner shall indemnify, defend and save LPM harmless from all
loss, damage, cost, expense (including attorney's fees), liability or claims from personal
injury or property damage incurred or occurring in, on, or about the properties. Owner
shall obtain and keep in force adequate insurance against Physical damage (e.g. fire with
extended coverage endorsement, boiler and machinery, etc.) and against liability for loss,
damage, or injury to property or persons, which might arise out of the occupancy,
management, operation or maintenance of the Properties. LPM shall indemnify Owner as
to any awarded judgments related to the negligence of LPM as it relates to the Civil
Rights Act of 1866, the Fair Housing Act of 1968, The Fair Housing Amendments Act of
1988 and/or the American Disabilities Act.
10. Owner is responsible. To pay the mortgage, utilities, taxes, and all other bills pertaining
to the aforementioned property.
Owner Page 4 or 6 LPM
MANAGEMENT AND LEASING AGREEMENT
Lehman Property Management (MM
11. Unit Availability. Owner will notify IPM in writing when a unit is available for showing
and occupation. Unit must meet all code requirements for rental, including a rental
inspection. LPM will place a tenant in property, within 10 weeks, utilizing a standard
screening procedure and lease contract. LPM is authorized to utilize rent credit incentives
of up to V4 a month rent to obtain a tenant rapidly. Failure to deliver tenant on the part of
LPM would allow Owner to terminate the unit for cause as specified in paragraph 5. This
clause does not apply if Owner fails to continue to provide access to the unit, maintain
insurance, and/or resolve any maintenance or function problems LPM preventing the
leasing of the unit.
12. Notices. All notices or communications required or made between the parties shall be
deemed given or made upon deposit in the united states mail, addressed as set out below,
or to such other address as the parties may furnish:
If to Owner:
Thomas J. Gaul
PO Box 540
New Cumberland, Pa 17070
717-648-5843
If to LPM:
Lehman Property Management
2740 Penbrook Ave
Harrisburg, Pa 17103
13. Authorized Simatures. The persons executing this Agreement on behalf of the respective
parties each represent that they are authorized so to do, and that this agreement is and
shall be binding upon such parties.
14. Employee Insurance. Owner and LPM understand that it is the LPM's sole and complete
responsibility to pay all employment taxes, including Federal and State withholding taxes,
Social Security, and obtain insurance, including worker's compensation coverage and
public liability insurance arising out of or relating to this Agreement.
Owner Page 5 of 6 LPMyIWZ7-
MANAGEMENT AND LEASING AGREEMENT
Addendum
Item Rates
Hourly Overtime Holiday
Min Max
General Labor $15 $18 X1.5 X2
General Maintenance $24 $30 X1.5 X2
Master Plumber $40 $60 X1.5 X2
Master Electrician $40 $60 X1.5 X2
Legal Filing * $30 $40 NA NA
Present At Hearing * $45 $60 NA NA
* Plus filing fee
?{? in. ? 962c, ® CO A,) CCt-Sv , ?,i* .
Owner Lp-
MANAGEMENT AND LEASING AGREEMENT
Property List
Schedule A
Owner O-1 LP
MANAGEMENT AND LEASING AGREEMENT
Lehman Property Management (10J09)
15. Construction. Wherever the context so requires, the feminine gender shall be substituted
for the masculine, the masculine for the feminine or the neuter for either; the singular
shall be sustained for the plural and vice versa. Paragraph headings are only for the
convenience of the parties and do not constitute a part of this agreement. This agreement
is made and executed in the commonwealth of Pennsylvania and shall be construed and
enforced in accordance with the laws thereof.
16. Entire Agreement. This Agreement represents the entire agreement between the parties
with respect to the within subject matter. No alterations, modifications or amplifications
hereof shall be effective unless reduced to writing and signed or initialed by all parties
hereto, or their authorized representatives. Rental schedules and parameters for lease
negotiations shall be established from time to time between the parties, and shall be
reflected in memoranda.
In Witness Whereof, the parties hereto, intending to legally bind themselves, their heirs, personal
representatives, successors and assigns, have hereunto set their respective hands an seals on the
day and year first above written.
Le k2an Management O
Ilh/p? A/ / / lgq
G D Thomas ul Date
President
Dian Lehman Date Geogine Gaul Date
Secretary
Owner V Page 6 of 6 LPw/,
Jo Jo Properties LLC
PO Box 540
New Cumberland, PA 17070
717.648.5843
September 4, 2008
Lehman Property Management
2740 Penbrook Avenue
Harrisburg, PA 17103
Glenn:
This letter will serve as our notice to quit services effective November 1, 2008.
We would like to set a time to tie up all loose ends, security deposits, all original bills
from all vendors used on our properties, all pertinent information relating to existing
tenants and vendors, all keys, etc. We would like to start collecting the information,
especially original bills as soon as possible. I need to have this information by the end of
September in order for me clarify anything with my accountant.
Please contact me as soon as possible to set this up at 648-5843.
Sincerely,
Thomas J. Gaul
VERIFICATION
I hereby verify that the statements of fact made in the foregoing documents are
true and correct to the best of my knowledge, information and belief. I understand that
any false statements therein are subject to the criminal penalties contained in 18 Pa C.
S. Section 4904, relating to unsworn falsification to authorities.
Date: a??)axJ
'? / (v 09 Thomas JJdiul
VERIFICATION
I hereby verify that the statements of fact made in the foregoing documents are
true and correct to the best of my knowledge, information and belief. I understand that
any false statements therein are subject to the criminal penalties contained in 18 Pa C.
S. Section 4904, relating to unsworn falsification to authorities.
Date: T(.?. fc 009 '4". 'Zzz?z
Georgin Gaul
410-
ohs
gi
., i
0
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2009-00775 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GAUL THOMAS J ET AL
VS
LEHMAN GROUP INC ET AL
R. Thomas Kline Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
LEHMAN GROUP INC T/D/B/A LEHMAN PROPERTY MANAGEMENT
but was unable to locate Them in his bailiwick. He therefore
deputized the sheriff of DAUPHIN County, Pennsylvania, to
serve the within COMPLAINT & NOTICE
On February 25th , 2009 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs:
Docketing 18.00
Out of County 9.00
Surcharge 10.00
Dauphin County 49.25
Postage .42
86.67
02/25/2009
DARRELL DETHLEFS
So answers-
Thomas Kli e
Sheriff of Cumberland County
Sworn and subscribe to before me
this day of
A. D.
i --
jf
t
C?j
In The Court of Common Pleas of Cumberland County, Pennsylvania
Thomas J. Gaul and Georgine Gaul
vs.
Lehman Group, Inc. t/d/b/a Lehman Property Management
96 Fairfax Village
Harrisburg, PA 17112 OR
2740 Penbrook Ave.
Harrisburg, PA 17103
Civil No. 2009-775
Now, February 17, 2009, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff
of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Affidavit of Service
Now, , 20 , at o'clock M, served the
within
upon
at
by handing to
a
and made known to
copy of the original
the contents thereof.
So answers,
County, PA
Sworn and subscribed before
me this day of 120
COSTS
SERVICE $
MILEAGE
AFFIDAVIT
(Rf#iz.t of the 'She ff
MarMaEstate ne Snyder
William T. Tully
Solicitor
Commonwealth of Pennsylvania
County of Dauphin
Jack Lotwick
Sheriff
Charles E. Sheaffer
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
THOMAS & GEORGINE GAUL
VS
LEHAMN GROUP INC. T/DB/A
LEHMAN PROPERTY MANAGEMENT
Sheriffs Return
No. 2009-T-0414
OTHER COUNTY NO. 2009775
And now: FEBRUARY 23, 2009 at 11:05:00 AM served the within COMPLAINT upon
LEHAMN GROUP INC. T/DB/A LEHMAN PROPERTY MANAGEMENT by personally
handing to GLENN LEHMAN 1 true attested copy of the original COMPLAINT and making
known to him/her the contents thereof at 2740 PENBROOK AVE. HBG PA 17103
PRESIDENT; 96 FAIRFAX VILLAGE IS A PROPERTY THEY MANAGE
Sworn and subscribed to
before me this 24TH day of February, 2009
A7??/
NOTARIAL SEAL
FRY JANE SNYDER, Notary Publi
Highspire, Dauphin County
M Oommission Ex ilea 1 2010
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 780-6590 fax: (717) 255-2889
So Answers,
Sheriff of Da hin
By
Deputy Sheriff
Deputy: G MILLER
Sheriffs Costs: $49.25 2/19/2009
Timothy M. Barrouk, Esquire
ID# 203250
The McShane Firm, LLC
4807 Jonestown Road Suite 14
Harrisburg, PA 17109
Telephone- (717)657-3900
Fax- (717)657-2060
tmb(&them c shanefirm.com
Attorney for Defendant
THOMAS J. GAUL and IN COURT OF COMMON PLEAS
GEORGINE GAUL, his wife CUMBERLAND COUNTY PENNSYLVANIA
Plaintiffs
V. No: 09-775 Civil Term
i
LEHMAN GROUP, INC. t/? /b/a CIVIL ACTION- LAW
LEHMAN PROPERTY
MANAGEMENT,
Defendant
MA
AND NOW this
Inc. t/d/b/a Lehman
McShane Firm, LLC and
Answer With New Matte
1. Admitted
2. Admitted
3. Admitted
th day of May, 2009, comes the Defendant, Lehman Group,
rty Management, by and through his undersigned Attorney, The
Timothy M. Barrouk , Esquire and avers in support of their
and Counterclaim as Follows:
4. Denied in Part and Admitted in Part. Defendant is without sufficient
knowledge to admit or deny whether 1940 Bellevue Road, Harrisburg,
Dauphin County, Pennsylvania and 1929 Market Street, Harrisburg,
Dauphin County, Pennsylvania were purchased by Plaintiff's, Thomas J.
Gaul and eorgine Gaul, prior to November 8, 2007. As such, specific
proof is demanded at trial.
i
• f
5.
6
Denied in P art. It is admitted that the Defendant entered into a
Manageme nt and Leasing Agreement (hereinafter referred to as
"Agreeme t") with Plaintiff s on or about November 8, 2008. To the
extent that Plaintiff s allege that the properties in paragraph 4 are included
in the Agre ment, Plaintiff is averring a conclusion of law to which no
responsive leading is required. To the extent that this statement is factual
in nature th Defendant avers that the Contract speaks for itself. Further,
Defendant, specifically denies that the properties listed in paragraph 4(a)
and paragr h 4(c) are covered by the Agreement because they are not
listed anyw here in the agreement.
Denied in P an. Defendant admits that a notice of termination was sent
from Plainti ffs to Defendant on September 4, 2008. However,
Defendant' averment that Plaintiff s "timely" tendered their written
notice to qu t services and terminate the Agreement is a conclusion of law
to which no responsive pleading is required. To the extent that it is
deemed fact 1 in nature, it is denied. Paragraph 6 of the Agreement
states that "T his agreement shall be for a term of one year from the date
hereof. prov ided that either party may terminate this Agreement upon 90
days' written notice to the other." (See attached Exhibit A). Clearly,
September 4 2008 is less than 90 days from November 8, 2008.
Additionally the Agreement was for one year and was entered into on
November 8 2007. The September 4, 2008 letter indicated that Plaintiff s
were going t Quit Services effective November 1, 2008.
V
7. Defendant denies the allegations contained in Paragraph 7 of Plaintiffs'
Complaint. Defendant is advised and therefore avers that said allegations
are conclus ons of law to which no responsive pleading is required. To the
extent that her answer is required please refer to paragraphs 7(a)
through 7
a. Def ndant denies the allegations contained in Paragraph 7(a) of
Plai tiffs Complaint. Defendant is advised and therefore avers that
said allegations are conclusions of law to which no responsive
is required. Further, Plaintiff's fail to indicate specific
and properties for which rents were not collected. As such,
is without sufficient knowledge to confirm or deny this
and specific proof is demanded at Trial. To the extent
that farther answer is required, Defendant denies Plaintiffs' general
that it failed to collect rents and avers that all rents were
in accordance with the agreement.
b. =Complaint. t denies the allegations contained in Paragraph 7(b) of
Defendant is advised and therefore avers that
said allegations are conclusions of law to which no responsive
is required. Further, Plaintiffs' failed to plead with
specifi
not de
to con
at trial.
ity any specific rents or payments due to them that were
)sited. As such, Defendant is without sufficient knowledge
rm or deny this allegation and specific proof is demanded
To the extent that further answer is required, Defendant
• }
denies Plaintiffs' general averment and avers that all rents and
pay ents due to Plaintiffs, including collection of delinquent rents
and ayments where deposited to Plaintiffs within 6 hours of the
time they were received by Defendant.
C. Def ndant denies the allegations contained in Paragraph 7(c) of
Plai tiffs Complaint. Defendant is advised and therefore avers that
said llegations are conclusions of law to which no responsive
pleading is required. Further, Plaintiffs failed to plead with
specificity any specific instance of statements not being timely,
completely, or accurately submitted. To the extent that further
answ is required, Defendant denies Plaintiff's averment because
Defendant did submit timely, complete, and accurate monthly
operating statements to Plaintiffs as required by paragraph 2(f) of
the a reement_
d. Defe dant denies the allegations contained in Paragraph 7(d) of
Plaint iffs Complaint. Defendant is advised and therefore avers that
said legations are conclusions of law to which no responsive
pleadi ng is required. To the extent that further answer is required
Defen dant denies Plaintiff's averment because Defendant did
arrang e for and supervise its employees or outside contractors to
perfori n regular maintenance on Plaintiff's properties in
accord ce with Paragraph 2(g) of the Agreement.
V I.
e. De ndant denies the allegations contained in Paragraph 7(e) of
Plaintiffs' Complaint. Defendant is advised and therefore avers
that said allegations are conclusions of law to which no responsive
pleading is required. Plaintiff's failed to plead with specificity any
specific instance of Defendant's failure to arrange for and
vise determination of major repairs and specific proof is
nded at trial. To the extent that further answer is required,
iff s averment is denied because Defendant arranged for and
sed determinations of all major repairs as outlined in the
f. Defe dant denies the allegations contained in Paragraph 7(f) of
Plaintiffs' Complaint. Defendant is advised and therefore avers
that id allegations are conclusions of law to which no responsive
pleading is required. All bills went to the Plaintiff first and were
then orwarded to the Defendant. Defendant paid all bills received
and also made reasonable efforts to contact utility providers to
confi that there were no outstanding bills.
g. Denied. Plaintiff was reimbursed all security deposits in
accordance with the agreement. Please see exhibit B as proof of
h. Denied. Defendant provided Plaintiff with all monies received by
the Defendant for rents collected.
V ?
8. Defendant denies the allegations contained in Paragraph 8 of Plaintiffs'
Complaint. Defendant is advised and therefore avers that said allegations
are conclus ons of law to which no responsive pleading is required. To the
extent that er answer is required, Defendant denies that it breached its
duty of goo faith and fair dealing.
9. Defendant d enies the allegations contained in Paragraph 9 of Plaintiffs'
Complaint. Defendant is advised and therefore avers that said allegations
are conclusi ns of law to which no responsive pleading is required. It is
impossible place an accurate figure on total rents if all rent for the
properties i all rents were received because it is impossible to state
whether a p operty will always be occupied. Accordingly, specific proof
is demande at trial.
10. Defendant d vies the allegations contained in Paragraph 10 of Plaintiffs'
Complaint. Defendant is advised and therefore avers that said allegations
are conclusi ns. of law to which no responsive pleading is required. As
stated in paragraph 9 the payments of $63,635.00 are in dispute and as
11.
such a specific calculation of the management fee is impossible to
calculate. Specific proof is demanded at trial. Defendant does admit that
he is entitled to a 7% management fee.
Defendant d nies the allegations contained in Paragraph 1 I of Plaintiffs'
Complaint. efendant is advised and therefore avers that said allegations
are conclusio s of law to which no responsive pleading is required. To the
k
12
extent that further answer is required Plaintiff s calculations are denied as
more fully outlined in paragraphs 9 and 10.
Defendant denies the allegations contained in Paragraph 12 of Plaintiffs'
Complaint. Defendant is advised and therefore avers that said allegations
are conclusions of law to which no responsive pleading is required.
Plaintiffs' fail to aver how the figure of $5,450.00 was reached and
specific pro f is demanded at trial. To the extent that further answer is
required it i averred by Defendant that all security deposits from tenants
were receiv d and subsequently reimbursed to Plaintiffs.
13. Denied.
14. Denied.
WHEREFORE,
judgment in his favor and
15. The
herein.
16. Defendant
17.
18.
dant respectfully requests that this Honorable Court enter a
;ainst the Plaintiff on its Complaint.
NEW MATTER
is of paragraphs one (1) through fourteen (14) hereof are
by reference as if the same were more fully set forth at length
ted all rent into Plaintiff s account within six hours of
receipt for al properties.
Defendantsubmitted timely, complete, and accurate monthly operating
financial statements to the Plaintiffs as outlined in attached Exhibit A.
Paragraph 6 of the Management and Leasing Agreement indicates that
"this agreem nt shall be for a term of one year from the date hereof.
19.
20.
21
22
23.
24.
25
26.
27
28
Plaintiffs t ok all of the keys to his properties from Defendant on
September 0, 2008.
The letter t terminate the aforementioned agreement dated September 4,
2004, state that "This letter serves as our notice to quit services effective
November , 2008".
The Plaintif fs did not provide the appropriate 90 day notice as required by
paragraph 6 of the Agreement.
Paragraph 6 of the Agreement provides, "If the owner terminates
agreement thin the initial twelve (12) months, it will pay a termination
fee of $300. 00 per property in addition to any other funds due to LPM for
incurred exp enses...."
The Plaintif collected all rent for the month of November 2007.
Defendant's aid a total of thirty-eight thousand and one dollars and
eighty three ents ($38,001.83) to Plaintiff's.
216-2184 th Street, Enola, Cumberland County, Pennsylvania was brought
to the Defen ant with all of the units occupied. Leases were provided for
this property. No tenant ledgers were provided for this property.
The rent for 18 4th Street, Enola, Cumberland County, Pennsylvania was
paid directly to Plaintiffs.
The Plaintiff held the security deposits for 218 4th Street, Enola,
Cumberland County, Pennsylvania.
The Plaintiffs held the security deposits for Apartments 1 and 2 at 216 4th
Street, Enola, Pennsylvania.
29.
30
31
32
33
34
35.
36.
The security deposit for the tenant of Apartment 2 at 216 41h Street, Enola,
Pennsylvania was returned from the Plaintiffs' trust account upon the
tenant vaca ing the premises.
Defendant' rented Apartment 2 at 216 4`h Street, Enola, Pennsylvania
within six ( ) weeks of it becoming vacant.
The following amounts are still owed with regard to 216-218 4`h Street,
Enola, Cum erland County, Pennsylvania:
a. Man gement Fee $608.30
b. Inspection Attendance Fee $45.00
C. Adm'nistrative Fees $7.89
d. Terrr ination Fee $300.00
2223 North `h Street, Harrisburg, Dauphin County, Pennsylvania was first
brought to D fendant in January 2008.
2223 North th Street, Harrisburg, Dauphin County, Pennsylvania was
being rehabilitated by Plaintiffs during the period beginning January 2008
and ending arch 2008.
In April 2008, the Plaintiffs terminated Defendants management of 223
North 6`h Street, Harrisburg, Dauphin County, Pennsylvania.
In August 2008, the Plaintiffs rehired Defendants to manage 2223 North
6`h Street, H 'sburg, Dauphin County, Pennsylvania.
All maintenar. ce requests for 2223 North 6`h Street, Harrisburg, Dauphin
County, Penn ylvania were sent to the Owner who sent the contractor he
had directly engaged to make repairs.
37
38
39.
40.
41
42.
43.
The follow ng amounts are still owed with regard to 223 North 6`h Street,
Harrisburg, Dauphin County, Pennsylvania:
a. M agement Fee $30.00
b. Insp ection Attendance Fee $45.00
C. Adm inistrative Fees $7.89
d. Te ination Fee for April 2008 $300.00
e. Final Termination Fee $300.00
During the m eeting to discuss termination of management for 223 North
6`h Street, H sburg, Dauphin County, Pennsylvania, Plaintiffs
authorized n more work to be performed by Defendant without specific
approval.
1940 Bellew e Road, Harrisburg, Dauphin County, Pennsylvania was
brought to D fendant under rehabilitation.
1940 Bellew Road, Harrisburg, Dauphin County, Pennsylvania was
made availab le in January 2008.
On February , 2008, 1940 Bellevue Road, Harrisburg, Dauphin County,
Pennsylvania was rented for eight hundred ($800.00) dollars with an eight
hundred ($80 0-00) dollar security deposit.
The security d eposit for 1940 Bellevue Road, Harrisburg, Dauphin
County, Penn ylvania was deposited into the owners account on February
5, 2008.
The tenant at 1 940 Bellevue Road, Harrisburg, Dauphin County,
Pennsylvania ame recommended by Plaintiff, Thomas Gaul.
r •
44
45
46
47.
48.
49
50.
A Landlord/Tenant Complaint was filed against the tenant in September
2008.
At the conclusion of the meeting to terminate management 1940 Bellevue
Road, Harrisburg, Dauphin County Pennsylvania, Plaintiffs took
possession f all keys to the property.
The following amounts are still owed with regard to 1940 Bellevue Road,
Harrisburg, Dauphin County Pennsylvania:
a. Management Fee $47.22
b. Hearing Attendance Fee $60.00
C. Utili y (water) $77.73
d. Termination Fee $300.00
Plaintiffs ov rpaid Defendant fourteen dollars and twelve cents ($14.12) in
administrative fees for 1940 Bellevue Road, Harrisburg, Dauphin County,
Pennsylvania.
The total am unt of uncollected fees for 1940 Bellevue Road, Harrisburg,
Dauphin Co ty Pennsylvania from Plaintiff is four hundred and seventy
dollars and eighty-three cents.
2200 Walnut Street, Harrisburg, Dauphin County, Pennsylvania, was
brought to Defendant with 2 units under rehab.
Apartment 2 was the only unit rented at 2200 Walnut Street, Harrisburg,
Dauphin Co ty, Pennsylvania when it was brought to Defendant.
51. Defendant resolved numerous heating and plumbing issues with regard to
2200 Walnut Street, Harrisburg, Dauphin County, Pennsylvania that were
caused by ulty craftsmanship of the contractor engaged by the owner.
52. At no point was a marketable unit empty for more than a six week period
at 2200 Walnut Street, Harrisburg, Dauphin County, Pennsylvania.
53. The followi g amounts are still owed with regard to 2200 Walnut Street,
Harrisburg, Dauphin County, Pennsylvania:
a. Management Fee $38.71 (owed to Plaintiff)
b. Fee or Storage of Propertey $40.00
Unit 2F
C. A
d. T
54.
55.
56.
e. Ylaa
f. Refr.
A security d
Dauphin Co
February l,:
A security di
Dauphin Coi
February 19,
A security de
Dauphin Cot
inistrative Fees $157.88
iination Fee $300.00
ment Fee $900.00
gerator for Unit 2 $391.14
,posit for Apartment 2 at 2200 Walnut Street, Harrisburg,
mty, Pennsylvania was deposited to Owner's account on
,009 in the amount of seven hundred ($700.00) dollars.
posit for Apartment 1 at 2200 Walnut Street, Harrisburg,
nty, Pennsylvania was deposited to Owner's account on
2009 in the amount of one thousand ($1000.00) dollars.
posit for Apartment B at 2200 Walnut Street, Harrisburg,
city, Pennsylvania was deposited to Owner's account on
February 11), 2009 in the amount of six hundred and fifty ($650.00)
dollars.
57. No security Deposit was provided to the Defendant for Michael Alexander
in Apartment 1 at 1929 Market Street, Harrisburg, Dauphin County,
Pennsylvan a.
58. Plaintiff held the security deposit for Shawnta Kent in Apartment 2 at
1929 Market Street, Harrisburg, Dauphin County Pennsylvania in the
amount of six hundred and twenty ($620.00) dollars.
59. Plaintiff hel the security deposit for Ken Smith in Apartment 3 at 1929
Market Street, Harrisburg, Dauphin County Pennsylvania in the amount of
four hundred ($400.00) dollars.
60. The followi g amounts are still owed with regard to 1929 Market Street,
Harrisburg, Dauphin County Pennsylvania:
a. Administrative Fees $60.00
b. Termination Fee $300.00
C. He ng fee for second hearing on Apartment 2 $60.00
d. Man, gement fees $103.22
e. Renewal fees $85.00
61
COUNTERCLAIM
The averments of paragraphs one (1) through sixty (60) hereof are
incorporated by reference as if the same were more fully set forth at length
herein.
62.
63.
64
65.
i
Plaintiff o es Defendant a total of five hundred and eighty-four dollars
and sevent -eight cents ($584.78) for uncollected money with regard to
1929 Marke Street, Harrisburg, Dauphin County, Pennsylvania.
Plaintiff ow?s Defendant a total of one thousand six hundred and fifty-five
dollars and ' rty one cents ($1655.41) for uncollected money with regard
to 2200 WaII ut Street, Harrisburg, Dauphin County, Pennsylvania.
Plaintiff owe Defendant a total of eight hundred and fifty-five dollars and
i
fifty seven cis ($852.62) for uncollected money with regard to 216-218
4ch Street, En?la, Cumberland County, Pennsylvania.
Plaintiff owes Defendant a total of six hundred and thirty dollars ($630.00)
for uncollected money with regard to 2223 North 6'h Street, Harrisburg,
;
Dauphin Cour
66. Plaintiff owes
for uncollecte
Dauphin Coui
67. Plaintiff owes ]
three and ninet
from Plaintiff.
WHEREFORE, Defen
of four thousand one hundred
monies not collected from the
Honorable Court deems neces
, Pennsylvania.
a total of six hundred and thirty dollars ($470.83)
money with regard to 1940 Bellevue Road, Harrisburg,
, Pennsylvania.
a total of four thousand one hundred and ninety-
cents ($4,193.19) for money not collected by Defendant
demand judgment against the Plaintiffs in the amount
ninety-three dollars and nineteen cents ($4,193.19) for
ills by the Defendant and whatever other relief this
Respectfully Submitted,
Date: C, 0.1
G--_
T Attorney imothy I. M. DB.#arrouk20453,7Esquire
4807 Jonestown Road
Suite 242
Harrisburg, Pennsylvania 17109
#717-657-3900
Attorney for Plaintiff
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Beginning Bank Balance
Net Income/Loss
Other Transactions
Received from owner
Paid to owner
Net Change in Security
Ending Bank Balance
tailed Owners Statement
Ownership: Sixth N 2233
For the period 101112007 - 1013112007
Cash Requirements
Reserve Amount: 0.00
Security Deposits Held: 750.00
Total Requirements 750.00
Lehman Prepmly Y...{wint
0.00
0.00
0.00
0.00
0.00
0.00
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Beginning Bank Balance
Net Income/Loss
Other Transactions
Received from owner
Paid to owner
Net Change in Security
Ending Bank Balance
tailed Owners Statement
Ownership: Sixth N 2233
For the period 111112007 - 11/30/2007
Cash Requirements
Reserve Amount: 0.00
Security Deposits Held: 750.00
Total Requirements 750.00
Lehman Pr "ay w?.o.ae
0.00
0.00
0.00
0.00
0.00
0.00
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Beginning Bank Balance
Net Income/Loss
Other Transactions
Received from owner
Paid to owner
Net Change in Security
Ending Bank Balance
tailed Owners Statement
Ownership: Sixth N 2233
For the period 121112007 - 1213112007
Cash Requirements
Reserve Amount: 0.00
Security Deposits Held: 750.00
Total Requirements 750.00
LehMM P»pnety r ea?.e,.nc
WWI
0.00
0.00
0.00
0.00
0.00
0.00
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Owners Statement
Beginning Bank Balance
Net Income/Lose
Other Transactions
Received from owner
Paid to owner
Net Change in Security
Ending Bank Balance
Ownership: Sixth N 2233
For the period 11112008 - 113112008
Cash Requirements
Reserve Amount: 0.00
Security Deposits Held: 750.00
Total Requirements 750.00
Lebman Pro" ty,f a.?emaa,
0.00
0.00
0.00
0.00
0.00
0.00
Lehman Property Man> Bement Ghmaa Pmpoty,..u4amast
2740 Penbrook Ave
FM -I FM
Harrisburg, Pa 17103 ;
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
ailed Owners Statement
Ownership: Sixth N 2233
For the period 21112008 - 212912008
Beginning Bank Balance 0.00
Expense
Date Reference Type Comment Amount
2/15/2008 1244 50026 Water And Sewer Utility 10018063-0000 7 24.56
24.56
Net Income/Loss 1 -24.56
Other Transactions
Received from owner 0.00
Paid to owner 0.00
Net Change in Security De sits 0.00
Ending Bank Balance 1 -24.56
Cash Requirements
Reserve Amount: 0.00
Security Deposits Held: 750.00
Total Requirements 750.00
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Lehmu Aopwty we.?.mne
nn
PPetalled Owners Statement
Ownership: Sixth N 2233
For the period 31112008 - 313112008
Beginning Bank Balance -24.56
Expense
Date Reference Type Comment Amount
3/17/2008 50026 ?Iater And Sewer Utility 10018063-0000 7 24.56
24.56
Net Income/Loss 1 -24.56
Other Transactions
Received from owner
Paid to owner
Net Change in Security
Ending Bank Balance
Cash Requirements
Reserve Amount: 0.00
Security Deposits Held: 750.00
Total Requirements 750.00
0.00
0.00
0.00
-49.12
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Owners Statement
Beginning Bank Balance
Net Income/Loss
Other Transactions
Received from owner
Paid to owner
Net Change in Security
Ending Bank Balance
Cash Requirements
Reserve Amount:
Security Deposits Held:
Total Requirements
Ownership: Sixth N 2233
For the period 41112008. 413012008
0.00
750.00
750.00
Lehman ftol," 1amutemene
-49.12
0.00
0.00
0.00
0.00
-49.12
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Beginning Bank Balance
Net InconWLoss
Other Transactions
Received from owner
Paid to owner
Net Change in Security
Ending Bank Balance
ailed Owners Statement
Ownership: Sixth N 2233
For the period 51112008 - 513112008
Cash Requirements
Reserve Amount: 0.00
Security Deposits Held: 750.00
Total Requirements 750.00
Lehm Pmpwtj ele..?.easet
Matma
-49.12
0.00
0.00
0.00
0.00
-49.12
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Beginning Bank Balance
Net Income/Lose
Other Transactions
Received from owner
Paid to owner
Net Change in Security
Ending Bank Balance
ailed Owners Statement
Ownership: Sixth N 2233
For the period 61112008 - 613012008
Cash Requirements
Reserve Amount: 0.00
Security Deposits Held: 750.00
Total Requirements 750.00
Lehman Pmpetq,4w?em et
.,
-49.12
0.00
0.00
0.00
0.00
-49.12
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Beginning Bank Balance
Net Income/Loss
Other Transactions
Received from owner
Paid to owner
Net Change in Security
Ending Bank Balance
ailed Owners Statement
Ownership: Sixth N 2233
For the period 71112008 - 713112008
Cash Requirements
Reserve Amount: 0.00
Security Deposits Held: 750.00
Total Requirements 750.00
Lehman Pio"dy meat
WM-IffWI
-
-49.12
0.00
0.00
175.44
0.00
-224.56
Lehman Property Man Bement mm"M"t
2740 Penbrook Ave abt"
Harrisburg, Pa 17103 ...
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
etailed Owners Statement
Ownership: Sixth N 2233
For the period 81112008 - 813112008
Beginning Bank Balance
Income
Date Reference Type
Comment -224.56
Amount
8/18/2008 TJG005 - TJi Rent C arge Natasha Turner 425.00
8/29/2008 TJG005 - TJ4 Rent C arge Joseph McClendon 650.00
1,075.00
Expense
Date Reference Type Comment Amount
8/31/2008 5041 M nagement Fee Management fees: Thomas J. Ge 45.50
45.50
Net Income/Loss 1,029.50
Other Transactions
Received from owner 0.00
Paid to owner 0.00
Net Change in Security Dep sits 0.00
Ending Bank Balance 804.94
Cash Requirements
Reserve Amount: 0.00
Security Deposits Held: 750.00
Total Requirements 750.00
Lehman Property Management Pmpefty
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
ailed Owners Statement
Ownership: Sixth N 2233
For the period 91112008 - 913012008
Beginning Bank Balance 804.94
Income
Date Reference Type Comment Amount
9/5/2008 TJ0005 - TJ( Rent arge Natasha Turner 750.00
750.00
Expense
Date Reference Type Comment Amount
9/30/2008 5041 7nagement Fee Management fees: Thomas J. GE 52.50
52.50
Net Income/Loss 697.50
Other Transactions
Received from owner 0.00
Paid to owner 2,059.00
Net Change in Security Dep sits 0.00
Ending Bank Balance 1 -556.56
Cash Requirements
Reserve Amount: 0.00
Security Deposits Held: 750.00
Total Requirements 750.00
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Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Detailed Owners Statement
Ownership: Bellevue 1940
For the period 101112007 - 1013112007
uhmen Property MM"gement
0.00
Beginning Bank Balance 0.00
Net income/Loss
Other Transactions 0.00
0.00
Received from owner 0.00
Paid to owner
Net Change in Secur ty Deposits
0.00
Ending Bank Balance
Cash Requirements 200.00
Reserve Amount: 00
0
Security Deposits H ld: .
Total Requirements 200.00
COMMENTS
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Beginning Bank Balance
Net Income/Loss
other Transactions
Received from owner
Paid to owner
Net Change in Secur'
Ending Bank Balance
Cash Requirements
Reserve Amount:
Security Deposits
Total Requirements
Detailed Owners Statement
Ownership: Bellevue 1940
For the period 111112007 - 1113012007
Deposits
200.00
0.00
020020 00
CO
y?ngamant
Lahmm PM WW
0.00
0.00
0.00
0.00
0.00
0.00
Lehman Property M
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Detailed Owners Statement
Ownership: Bellevue 1940
For the period 121112007 - 1213112007
Beginning Bank Balance
Net income/LOss
Other Transactions
Received from owner
Paid to owner
Net Change in Securi Deposits
Ending Bank Balance
Cash Requirements 200.00
Reserve Amount: 0.00
Security Deposits Hel : 200.00
Total Requirements
yi np,.,.rq MaWLPM-t
y
0.00
0.00
0.00
0.00
0.00
0.00
COi
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Detailed Owners Statement
Ownership. Bellevue For the period 11112008 - 113112008
Beginning Bank Balance
Net Income/l-oss
other Transactions
Received from owner
paid to owner Deposits
Net Change in Secud Ending Bank Balance
Cash Requirements 200.00
Reserve Amount: 0.00
Security Deposits H Id: 200.00
Total Requirements
COMMENTS
Lehman M_ '.'q Naar---
j,- M
0
0.00
0.00
0.00
0.00
0.00
Lehman Properly
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Lehman Pcopert7 K..Wmsnt
FOR.. G
116
Detailed Owners Statement
Ownership: Bellevue 1940
For the period 21112008 - 212912008
0.00
Beginning Bank Balance
Income
Date Reference
215/2008 TJG004 - TJ(
Expense
Date Reference
2/10/2008
2/10/2008
2/15/2008 1244
2/17/2008
2/18/2008 1257
2/25/2008
Charge
comment Amount
Dywana Blanding 800.00
800.00
Comment Amount
Tvpe
Repairs & Maintenance
General Maintenance 82.50
40.00
Repairs & Maintenance General Maintenance 47.76
3 Water And Sewer Utility 09082051-0000 7 278.68
Repairs & Maintenance General Maintenance
95900-66040 Final 35.40
1 Electric
Change to locks/keying 126.55
Locks 610.89
189.11
Net Income/L.oss
Other Transactions
Received from
Paid to owner
Net Change in
Ending Bank Balance
0.00
0.00
800.00
Deposits
Cash Requirements 200.00
Reserve Amount: 800.00
Security Deposits Held:
1,000.00
Total Requirements
989.11
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J- Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Lehman P-Pet7
n;
Detailed Owners Statement
Ownership: Bellevue 1940
For the period 31112008 - 313112008
989:11
Beginning Bank Balance
Income
Date Reference
3/3/2008 TJG004 - TJI
Expense
Date Reference
3/ p8 1311
3/9/2008 1312
3/17/2008
3/25/2008
Net Income/Loss
other Transactions
Received from
Paid to owner
Net Change in
Ending Bank Balance
it Charge
?1 Electric
23 Gas And Propane
26 Water And Sewer Utility
1 Management Fee
Comment Amount
800.00
Dywana Blanding 800.00
Comment Amount
95900-66040 feb 35.40
96.44
207 372 6220 09 final 64.38
09082051-0000 7 56.00
Management fees: Thomas J. Ge 252.22
547.78
0.00
0.00
0.00
Deposits
1,536.89
Cash Requirements 200.00
Reserve Amount: 800.00
Security Deposits Held:
1,000.00
Total Requirements
Lehman Property M
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Beginning Bank Balance
income
Date Reference _
4/4/2008 TJG004 - TJ( WE
4/4/2008 TJG004 - TJI Re
4/4/2008 TJG004 - TJt W
Expense
Date Reference
4/25/2008
Net Income/t-oss
Other Transactions
Received from owner
Paid to owner
Net Change in Securi
Ending Bank Balance
Cash Requirements
Reserve Amount:
Security Deposits i
Total Requirements
LCUM. PmP.A7 y.Jwment
- n n
Detailed Owners Statement
Ownership: Bellevue 1940
For the period 41112008 - 413012008
1,536.89
Comment Amount
Type 400.00
Charge Dywana Blanding 400.00
Charge Dywana Blanding 30.00
Dywana Blanding 830.00
:r reimbursement
Comment Amount
Tvge 56.00
41 Management Fee Management fees: Thomas J. Ga 56.00
774.00
y Deposits
200.00
800.00
1,000.00
0.00
0.00
0.00
2,310.89
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Lehman piopeRy KwIm ement
f? ?R $_
a
Detailed Owners Statement
Ownership: Bellevue 1940
For the period 51112008 - 513112008
2,310.89
Beginning Bank Balance
Income
Date Reference
5/5/2008 T%604 - TJ(
5/5/2008 TJG004 - TJt
5/5/2008 TJG004 - TJI
5/5/2008 TJG004 - TJt
Expense
Date Reference
5/16/2008
5/19/2008 1514
5/26/2008
5/30/2008 5047150470
Net Income/Loss
other Transactions
Received from
Paid to owner
Net Change in
Ending Bank Balance
ter reimbursement
ter reimbursement
it Charge
nt Charge
3 Admin Fee
3 Repairs & Maintenance
1 Management Fee
26 Water And Sewer Utility
Comment Amount
34.38
pywana Blanding 76.57
Dywana Blanding 389,05
Dywana Blanding 380.00
Dywana Blanding 880.00
Comment Amount
Adminsistrative charge 7.50
7550
rehang door/repair 2 doors 53.83
Management fees: Thomas J. Ge 233.03
369.36
510.64
0.00
0.00
0.00
Deposits
Cash Requirements 200.00
Reserve Amount: 800.00
Security Deposits eld: 1,000.00
Total Requirements
2,821.53
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
I.eh. P-oPOA7 Na P--t
Detailed Owners Statement
Ownership: Bellevue 1940
For the period 61112008 - 613012008
2,821.53
Beginning Bank Balance
Income
Date Reference
6/5/2008 TJ6004 - TJI
6/5/2008 TJ0004 - TJ(
6/5/2008 TJG004 - TJl
615/2008 TJG004 - TJ(
6/5/2008 TJG004 - TJ(
Expense
Date Reference
6/21/2008
6/25/2008
Net Income/Loss
Other Transactions
Received from
Paid to owner
Net Change in
Ending Bank Balance
Charge
)r reimbursement
Charge
Charge
Charge
3 Admin Fee
1 Management Fee
Comment Amount
Dywana Blanding 30.95
Dywana Blanding 66.82
Dywana Blanding 6,10
Dywana Blanding 399.13
Dywana Blanding 300:00
800.00
Comment Amount
Adminsistrative charge 20.00
Management fees: Thomas J. Ge 51.32
71.32
728.68
0.00
2,749.76
0.00
Deposits
800.45
Cash Requirements 200.00
Reserve Amount: 800.00
Security Deposits eld: 1,000.00
Total Requirements
Lehman Property M
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Lehman Prop"" Mangement
Detailed Owners Statement
Ownership: Bellevue 1940
For the period 71112008 - 713112008
800.45
Beginning Bank Balance
Income
Date Reference _
7 //72008 TJG RE
7/7/2008 TJG004 - TJI W
7/7/2008 TJG004 - TJ( Ri
7/7/2008 TJG004 - TJ( R,
7/7/2008 TJG004 - TJ( R,
Expense
Date Reference
7l2 008
7/31/2008
7/31/2008 1922
Net income/Loss
Other Transactions
Received from
Paid to owner
Net Change in
Ending Bank Balance
Cash Requirements
Reserve Amount:
Security Deposits
Total Requirements
it Charge
.ter reimbursement
nt Charge
nt Charge
nt Charge
Comment Amount
Dywana Blanding 100.87
11.91
Dywana Blanding 87 22
Dywana Blanding 500A0
Dywana Blanding 100.00
Dywana Blanding 800.00
Comment Amount
Tvpe 55.17
1 Management Fee Management fees: Thomas J- G? g 30
3 Admin Fee Adminsistrative charge 93,00
Replace wax ring/supply line and
)31 Plumbing 157.47
642.53
0.00
600.45
0.00
Deposits
842.53
200.00
800.00
1,000.00
Lehman ProperW
2740 Penbrooak17103
Pa
Harrisburg,
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Beginning Bank Balance
Income
Date Reference
8/29/2008 TJG004 - TJ(
812912008 TJG004 - TJ(
8/29/2008 TJG004 - TJ(
8/29/2008 TJG004 - TJt
Expense
Date_ Reference
8/31/2008
Net Income/Loss
other Transactions
Received from
paid to owner
Net Change in
Ending Bank Balance
Cash Requirements
Reserve Amount:
security Deposits
Total Requirements
LIIM= ftowl" y,,,Lem?c
!tom
Detailed Owners Statement
Ownership: Bellevue 1940
For the period 81112008 - 813112008
842.53
Comment Amount
77.73
T Dywana Blanding 112.78
r reimbursement Dywana Blanding 596.73
Charge Dywana Blanding 47.76
Charge Dywana Blanding 835.00
ar reimbursement
ComrrnO - Amount
58,45
T e Management fees. Thomas J Ge 58.45
1 Management Fee
776.55
Deposits
200.00
leld: 800.00
1,000.00
Gv
0.00
262.53
0.00
1,356.55
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Lou.. Prop ? 1D.Wment
nn
nom==
Detailed Owners Statement
Ownership: Bellevue 1940
For the period 91112008 - 913012008
1,356.55
Beginning Bank Balance
income
Date Reference
9/26/2008 TJG004 - TJ(
9/26/2008 TJG004 - TJ(
9/26/2008 TJ0004 - TJ(
9/26/2008 TJG004 - TJ(
9/30/2008
Expense
Date Reference
9/5/2008 2109
9/29/2008 2256
9/30/2008
Charge
Charge
Sufficient Funds Fee
Charge
! NSF Fee
Type
61 Filing Fee
41 Land Scaping
.1 Management Fee
Comment Amount
203.27
pywana Blanding 80,00
Dywana Blanding 35.00
Dywana Blanding 281 73
pywana Blanding
ement fees: Thomas J. Gc -35.00
Manag 565.00
Comment Amount
D ana Blanding 194( 96.50
llT Comp- yw 35.00
Landscaping and exterior cleanul 39.55
Management fees: Thomas J. Ga 171.05
393.95
Net Income/Loss
other Transactions
Received from
Paid to owner
Net Change in
Ending Bank Balance
0.00
1,770.52
0.00
Deposits
Cash Requirements 200.00
Reserve Amount: 800.00
Security Deposits Held: 1,000.00
Total Requirements
-20.02
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Lehman Property Man y?ant
Bement cahmaa howK7
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 1707
717-648-5843
Detailed Owners Statement
Ownership: Fourth 216 - 218
i For the period 101112007 - 1013112007
i
0.00
Beginning Bank Balance
0.00
Net income/Loss
Other Transactions 0.00
Received from owner 0.00
Paid to owner 0.00
Net Change in Securi Deposits
0.00
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Beginning Bank Balance
Net IncomelLoss
Other Transactions
Received from owner
Paid to owner
Net Change in Secur
Ending Bank Balance
Cash Requirements
Reserve Amount:
Security Deposits
Total Requirements
Detailed Owners Statement
Ownership: Fourth 216 - 218
For the period 111112007 - 1113012007
Deposits
150.00
650.00
800.00
Leemm pcoPeR7 m•p1nme"t
Tam=
0.00
0.00
0.00
0.00
0.00
0.00
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Beginning Bank Balance
Income
Date Reference
12/1/2007 TJG002 - TJI
12/1/2007 TJG002 - TJ(
12/3/2007 TJ0002 - TJI
12/5/2007 TJ0002 - TJl
Lehman Property r+..10121ced
Detailed Owners Statement
Ownership: Fourth 216 - 218
For the period 121112007 - 1213112007
0.00
By Paid Direct to owner
Charge
Charge
Charge
1,300.00
Expense
Date Reference
12/21/2007
Net Income/Loss
Other Transactions
Received from owner
Paid to owner
Net Change in Secudi
Ending Bank Balance
Cash Requirements
Reserve Amount:
Security Deposits
Total Requirements
li Management Fee
Comment Amount
Aaron Gaul -790.00
Aaron Gaul 790.00
Stephanie McMillen 650.00
Tom Strausbaugh 650.00
Comment Amount
Management fees: Thomas J. Ge 146.30
146.30
1,153.70
Deposits
0.00
0.00
0.00
1,153.70
150.00
650.00
800.00
yeLm?n Pcope*4 H?oaL°?t
Lehman Property Manag ement
?-
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Detailed Owners Statement
Ownership: Fourth 216 - 218
For the period 11112008 - 113112008
1,153.70
Beginning Bank Balance
Income Comment
T Amount
650.00
e Reference
Date t Tom Strausbaugh 650.00
_
1/5/2058- TJG002 -TJ( We nt Charge Stephanie McMillen
1
300.00
1/8/2008 TJG002 - TJt R nt Charge
,
Expense
nce Comment
T
Management fees: Thomas J. G? Amount
91.00
Da_ Refere
5
41 Management Fee 91,00
1/25/2008
1,209.00
Net income/Loss
other Transactions
Received from
Paid to owner
Net Change in
Ending Bank Balance
Deposits
Cash Requirements 150.00
Reserve Amount: 650.00
Security Deposits Meld: 800.00
Total Requirements
0.00
1,003.70
0.00
1,359.00
Lehman Property Mana ement Uhm'°ft°'°"''°'°"`men`
A
?
"
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Detailed Owners Statement
Ownership: Fourth 21 6 - 218
For the period 21112008 - 212912008
1,359.00
Beginning Bank Balance
Income
T
O
Comment
Amount
Date Reference YP 00
370
2/1/2008 TJG002 - TJ( M ey Paid Direct to owner Aaron Gaul .
-
2/1/2008 TJG002 - TJt R t Charge Aaron Gaul 370.00
00
-370
2/1/2008 TJG002 - TJ( M ney Paid Direct to owner Aaron Gaul .
00
370
2/1/2008 TJ0002 - TJ( R M Charge Aaron Gaul
Tom Strausbaugh .
650.00
2/5/2008 TJG002 - TJ( R nt Charge Stephanie McMillen 650.00
2/12/2008 TJG002 - TJ1 R nt Charge Stephanie McMillen 32.50
2/1212008 TJG002 - TJl
2/12/2008 TJG002 - TJ4 L
U e Charge
allocated Prepay Stephanie McMillen 32.50
1,365.00
Expense
T
e
Comment
Amount
Date Reference
2/17/2008 1251 5 yp
026 Water And Sewer Utility Acct# 24-1562032-3 136.82
2/17/2008 1251 5 026 Water And Sewer Utility Acct# 24-1649782-0 113.46
2/17/2008 1252 5 026 Water And Sewer Utility GAUL TJO02 230.00
2/17/2008 1252 5 026 Water And Sewer Utility GAUL TJ001 115.00
2/25/2008 5P 41 Management Fee Management fees: Thomas J. GE 147.35
742.63
Net Income/Loss
622.37
Other Transactions 0.00
Received from owne
50.00
Paid to owner 0.00
Net Change in Secu it y Deposits
1,931.37
Ending Bank Balance
Cash Requirements
Reserve Amount: 150.00
Security Deposits H I d: 650.00
Total Requirements 800.00
COMMENTS
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Beginning Bank Balance
income
Date Reference
3/1/2008 TJG002 - TJ(
3/1/2008 TJG002-TJ(
3/5/2008 TJ0002 - TJi
317/2008 TJG002 - TJI
3/7/2008 TJG002 - TJc
Expense
Date Reference
3/9/2008 1312
3/9/2008 1313
3/9/2008 1313
3/25/2008
3/31/2008 1366
Net Income/Loss
Other Transactions
Received from owner
Paid to owner
Net Change in Secud
Ending Bank Balance
Cash Requirements
Reserve Amount:
Security Deposits
Total Requirements
L.h.- PWPmb waacem nc
-
Detailed Owners Statement
Ownership: Fourth 216 - 218
For the period 31112008 - 313112008
1,931.37
Comment Amount
Type
y Paid Direct to owner Aaron Gaul -370.00
00
370
Charge Aaron Gaul
Tom Strausbaugh .
650.00
Charge Stephanie McMillen 500.00
Charge Stephanie McMillen 150.00
Charge 1,300.00
23 Gas And Propane
26 Water And Sewer Utility
26 Water And Sewer Utility
1 Management Fee
23 Gas And Propane
Comment _Amount
221 612 6150 10 279.45
24-1562032-3 136.82
24-1649782-0 113.46
Management fees: Thomas J. Gs 116.90
221 612 6150 10 562.35
1,208.98
91.02
Deposits
0.00
1,781.37
0.00
241.02
150.00
650.00
800.00
Lehman PMP@r q -9--!
Lehman Property Mana gement
2740 Penbrook Ave n
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Detailed Owners Statement
Ownership: Fourth 216 - 218
For the period 41112008 - 413012008
241.02
Beginning Bank Balance
Income
T e
Comment
Amount
Date Reference Tom Strausbaugh 650.00
417/2008 TJG002 - TJt R nt Charge Aaron Gaul -370.00
4/7/2008 TJG002 - U M ney Paid Direct to owner Aaron Gaul 370.00
4/7/2008 TJG002 - TJt R nt Charge Stephanie McMillen 85.00
4/9/2008 TJG002 - TJ1 R nt Charge Stephanie McMillen 500.00
4/9/2008 TJG002 - TJ( R nt Charge Stephanie McMillen 65.00
4/9/2008 TJG002 - TJ( U nallocated Prepay 1,300.00
Expense Comment Amount
Date Reference T
Management fees: Thomas J. Ga
116.90
4/25/2008 5 041 Management Fee Adminsistrative charge 8.00
4/30/2008 5 043 Admin Fee Landscaping and exterior cleanul 80.00
4/30/2008 1435 5 0041 Land Scaping 204.90
1,095.10
Net income/Loss
Other Transactions 0.00
Received from owne r 1,391.02
Paid to owner 0.00
Net Change in Secu 'ty Deposits
-54.90
Ending Bank Balance
Cash Requirements 150.00
Reserve Amount:
Security Deposits H Id: 650.00
Total Requirements 800.00
Lehman Property Mana ement Ub=nftoputy K"apment
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Detailed Owners Statement
Ownership: Fourth 21 6 - 218
For the period 51112008 - 513112008
-54.90
Beginning Bank Balance
Income
Tune
Comment
Amount
Date Reference
51612008 TJ0002 - TJt Re t Charge Tom Strausbaugh 650.00
5/16/2008 TJ0002 - TJ4 Re t Charge Stephanie McMillen 65.00
00
370
5/16/2008 TJG002 - TJl R t Charge Stephanie McMillen .
50
32
5/16/2008 TJG002 - TJ( La a Charge Stephanie McMillen
Stephanie McMillen .
150.00
5/16/2008 TJG002 - TJ( R nt Charge Stephanie McMillen 32.50
5/16/2008 TJ0002 - TJi U allocated Prepay 1,300.00
Expense
e
T
Comment
Amount
Date Reference
5/10/2008 1456 5 yp
023 Gas And Propane 221 612 6150 10 269.10
5/10/2008 1460 5 026 Water And Sewer Utility GAUL TJ001 138.00
5/10/2008 1460 5 026 Water And Sewer Utility GAUL TJO02 276.00
00
173
5/11/2008 1469 5 31 Plumbing Repair to plumbing system .
30
17
5/11/2008 5 43 Admin Fee Adminsistrative charge .
0
00
5/11/2008 1470 5 041 Land Scaping VOID: fee for fuel .
00
15
5/11/2008 1471 5 041 Land Scaping fee for fuel
Adminsistrative charge .
5.00
5/1112008 5
0 )43 Admin Fee.
41 Management Fee Management fees: Thomas J. GE 91.00
5/26/2008
5/27/2008 1563 1
0 026 Water And Sewer Utility 24-1649782-0 34.44
5/2712008 1563 0026 Water And Sewer Utility 24-1562032-3 28.87
5/30/2008 1570 0023 Gas And Propane 221 612 6150 10 272.46
1,320.17
-20.17
Net Income/Loss
Other Transactions 0.00
Received from ow n r 0.00
Paid to owner 0.00
Net Change in Sec ri ty Deposits
-75.07
Ending Bank Balance
Cash Requirements
Reserve Amount: 150.00
Security Deposits Held: 650.00
Total Requirements 800.00
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Beginning Bank Balance
Income
Date Reference
6/6/2008 TJG002 - TJ(
6/6/2008 TJG002 - TJI
6/6/2008 TJG002 - TJ(
6/6/2008 TJG002 - TJt
6/6/2008 TJG002 - TJI
Expense
Bate Reference
6/24/2008 1722
6/24/2008 1722
6/25/2008
Net Income/Loss
Other Transactions
Received from
Paid to owner
Net Change in
Ending Bank Balance
Cash Requirements
Reserve Amount:
Security Deposits
Total Requirements
Lehman Pr*uq Na-pment
JR-w-tr ir...m
Detailed Owners Statement
Ownership: Fourth 216 - 218
For the period 61112008 - 613012008
-75.07
Charge
Charge
Charge
Charge
Charge
Comment Amount
Stephanie McMillen 130.00
Stephanie McMillen 305.00
Stephanie McMillen 32.50
Stephanie McMillen 32.50
Stephanie McMillen 150.00
26 Water And Sewer Utility
26 Water And Sewer Utility
1 Management Fee
650.00
Comment Amount
24-1649782-0 42.52
24-1562032-3 50.04
Management fees: Thomas J. Ge 45.50
138.06
511.94
Deposits
0.00
0.00
650.00
1,086.87
150.00
1,300.00
1,450.00
Lehman Property Ma
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 1
717-648-5843
Beginning Bank Balance
Income
Date Reference
7/5/2008 TJG002 - TJ(
7/5/2008 TJG002 - TJl
7/13/2008 TJG002 - TJ(
7/13/2008 TJG002 - TJt
7/1312008 TJG002 - TJ(
7/13/2008 TJG002 - TJI
7/1312008 TJG002 - TJt
Expense
Date Reference
7/14/2008
7/25/2008
7/26/2008 1872
7/26/2008 1872
7/26/2008 1874
7/26/2008 1874
Net Income/Loss
Other Transactions
Received from
Paid to owner
Net Change in
Ending Bank Balance
Cash Requirements
Reserve Amount:
Security Deposits
Total Requirements
nt
Detailed Owners Statement
Ownership: Fourth 216 - 218
For the period 71112008 - 713112008
Lehman P,opa,q Kangamant
r;•
?t
1,086.87
Charge
Charge
Charge
Charge
Charge
Charge
Charge
3 Repairs & Maintenance
1 Management Fee
26 Water And Sewer Utility
26 Water And Sewer Utility
26 Water And Sewer Utility
126 Water And Sewer Utility
Comment Amount
George Ayala 330.00
George Ayala 320.00
Stephanie McMillen 32.50
Stephanie McMillen 167.50
Stephanie McMillen 300.00
Stephanie McMillen 182.50
Stephanie McMillen 17.50
1,350.00
Comment Amount
Install window / get locks/ deliver 40.00
Management fees: Thomas J. Ge 94.50
24-1562032-3 46.15
24-1649782-0 46.84
GAUL TJO02 230.00
Gaul TJO01 115.00
572.49
777.51
Deposits
0.00
936.87
0.00
927.51
150.00
1,300.00
1,450.00
i
COMMENTS : .
Lehman Property Man a ement 14b=nP°"`q'"'°"°m`°`
2740 Penbrook Ave "
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Detailed Owners Statement
Ownership: Fourth 216 - 218
For the period 81112008 - 813112008
Beginning Bank Balance 927.51
Income
Date Reference Type Comment Amount
8/412008 TJG002 - TJ( Re t Charge George Ayala 400.00
8/4/2008 TJG002 - TJ( Re t Charge George Ayala 250.00
8/20/2008 TJG002 - TJ( La a Charge Stephanie McMillen 15.00
8/20/2008 TJ0002 - TJ( R t Charge Stephanie McMillen 35.00
8/20/2008 TJG002 - TJ( R nt Charge Stephanie McMillen 615.00
8/20/2008 TJG002 - TJ( La a Charge Stephanie McMillen 65.00
8/20/2008 TJG002 - TJ( U allocated Prepay Stephanie McMillen 20.00
1,400.00
Expense
Date Reference Type Comment Amount
8/28/2008 5( 42 Placement Fee P-212-2008 546.00
8/29/2008 2086 5( 026 Water And Sewer Utility 216 4th St 44.78
8/29/2008 2086 5 026 Water And Sewer Utility 28 4th St 66.11
8/29/2008 5( 43 Admin Fee Adminsistrative charge 7.00
8/29/2008 2098 5 20 Locks Change to locks/keying 98.98
8/31/2008 5 41 Management Fee Management fees: Thomas J. GE 98.00
860.87
Net Income/Loss 539.13
Less Undeposited Funds -650.00
Other Transactions
Received from owne 0.00
Paid to owner 777.51
Net Change in Secu ty Deposits -650.00
Ending Bank Balance 39.13
Cash Requirements
Reserve Amount: 150.00
Security Deposits H id: 650.00
Total Requirements 800.00
COMMENTS
i
Lehman Property Management
2740 Penbrook Ave .-
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 1
717-648-5843
Beginning Bank Balance
Income.
Date Reference
9/17/2008 TJG002 - TJ1
9/17/2008 TJG002 - TJ1
Expense
Date Reference
9/30/2008
Net Income/Loss
Other Transactions
Received from owner
Paid to owner
Net Change in Securi
Ending Bank Balance
Cash Requirements
Reserve Amount:
Security Deposits
Total Requirements
Detailed Owners Statement
Ownership: Fourth 216 - 218
For the period 91112008 - 913012008
39.13
Charge
Charge
Comment Amount
Stephanie McMillen 630.00
Stephanie McMillen 20.00
650.00
11 Management Fee
Comment Amount
Management fees: Thomas J. Ge 45.50
45.50
604.50
Deposits
0.00
932.83
0.00
-289.20
150.00
650.00
800.00
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Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
i
Thomas J. Gaul
PO Box 540
New Cumberland, PA 1707
717-648-5843
Beginning Bank Balance
Net Income/Loss
Other Transactions
Received from owner
Paid to owner
Net Change in Securi
Ending Bank Balance
Cash Requirements
Reserve Amount:
Security Deposits Held:
Total Requirements
Detailed Owners Statement
Ownership: Walnut 2200
For the period 101112007 - 1013112007
ub-.. F-Peeq K-M--
MA
0.00
0.00
Deposits
200.00
0.00
200.00
0.00
0.00
0.00
0.00
COM' .
MENTS'"
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 1
717-648-5843
Beginning Bank Balance
Net Income/Loss
Other Transactions
Received from owner
Paid. to owner
Net Change in Security
Ending Bank Balance
Cash Requirements
Reserve Amount:
Security Deposits Held:
Total Requirements
Lehman P-"Ky aanq mmc
Detailed Owners Statement
Ownership: Walnut 2200
For the period 111112007 - 1113012007
0.00
0.00
0.00
0.00
0.00
0.00
200.00
0.00
200.00
COMMENTS
Lehman Property Ma
2740 Penbrook Ave
Harrisburg, Pa 17103 nagement Le16-11 Property Y,ugemmt
, , n n
, °-
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 1
717-648-5843
Detailed Owners Statement
Ownership: Walnut 2200
For the period 121112007 - 1213112007
Beginning Bank Balance 0.00
Net Income(Loss 000
Other Transactions
Received from owner 0.00
Paid to owner 0.00
Net Change in Secud Deposits 0.00
Ending Bank Balance 0.00
Cash Requirements
Reserve Amount: 200.00
Security Deposits Held. 0.00
Total Requirements 200.00
COMMENTS
Lehman Property Man gement Lehman Pwpxtyl -M-nt
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Detailed Owners Statement
Ownership: Walnut 2200
For the period 11112008 - 113112008
Beginning Bank Balance 0.00
Expense
Date Reference Type Comment Amount
1/24/2008 500.52 Inspection Attedance Attend municiple of city inspectioi 32.00
32.00
Net Income/l-oss 1 -32.00
Other Transactions
Received from owner 0.00
Paid to owner 0.00
Net Change in Security eposits 0.00
Ending Bank Balance 1 -32.00
Cash Requirements
Reserve Amount: 200.00
Security Deposits Held: 0.00
Total Requirements 200.00
COMMENTS
Lehman Property Ma nagement L
i
2740 Penbrook Ave mm hop rtyKaftWment
a
AL-
Harrisburg, Pa 17103
° ? 1
M
717-652-4434
awc..a.v....
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 1707
717-648-5843
Detailed Owners Statement
Ownership: W alnut 2200
For the period 21112008 - 212912008
Beginning Bank Balance -32.00
Income
Date Reference Type Comment Amount
2/1/2008 TJG001 - TJI Re nt Charge Amanda Sload 370.00
2/1312008 TJG001 - TJI Re it Charge Amanda Sload 320
00
2119/2008 TJG001 - TJI Re it Charge Kristian Gonzalez .
200
00
2/19/2008 TJG001 - TJI Re it Charge Kristian Gonzalez .
450
00
2/19/2008 TJG001 - TJI Re it Charge Kristian Gonzalez .
50
00
2/19/2008 TJG001 - TJc Re it Charge Kristian Gonzalez .
500
00
2/19/2008 TJ0001 - TJc Re it Charge Kristian Gonzalez .
100
00
2/19/2008 TJG001 - TJI Re it Charge Ashley Boyne .
500
00
2/19/2008 TJG001 - TJI Un Ilocated Prepay Ashley Boyne .
500
00
2/22/2008 TJG001 - TJI Un Ilocated Prepay Ashley Boyne .
500.00
Expense 3,490.00
Date Reference Type Comment Amount
2/5/2008 3 50 0 Appliance Refrigerator 497
14
2/10/2008 50 2 Placement Fee P-109-2008 .
363
00
2/15/2008 1244 50( 26 Water And Sewer Utility 62041139-0000 8 .
11
32
2/17/2008 1249 50( 21 Electric 34401-12017 .
23
12
2/17/2008 1253 50 6 Water And Sewer Utility Acct# R00025-00 .
82
00
2/23/2008 500 3 Repairs & Maintenance General Maintenance .
82
50
2/25/2008 504 1 Management Fee Management fees: Thomas J. GE .
314
30
2/29/2008 500 Repairs & Maintenance General Maintenance .
145
20
2/29/2008 503 Cleaning Make ready Cleaning .
260
00
2/29/2008 500 Repairs & Maintenance General Maintenance .
450.36
2,228.94
Net Income/Loss
1,261.06
Other Transactions
Received from owner
Paid to owner 0.00
Net Change in Sec
urity
eposits 0.00
2,300.00
Ending Bank Balance
4,229.06
Cash Requirements
Reserve Amount:
Security Deposits
Total Requirements
200.00
3,000.00
3,200.00
COMMENTS
Lehman Property Ma nagement Lehm Pmpatt7 Manap e t
2740 Penbrook Ave ,
?
ft
Harrisburg, Pa 17103 t
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 1707
717-648-5843
Detailed Owners Statement
Ownership: Walnut 2200
For the period 31112008 - 313112008
Beginning Bank Balance 4,229.06
Income
Date Reference Type Comment Amount
312/2008 TJ0001 - TJI Re it Charge Amanda Sload 35.00
312/2008 TJG001 - TJ4 Re it Charge Amanda Sload 335.00
3/4/2008 TJG001 - TJ( Re it Charge Amanda Sload 200.00
3/19/2008 TJG001 - TJ( Re it Charge Amanda Sload 165.00
3/19/2008 TJG001 - TJt La Charge Amanda Sload 5.00
740.00
Expense
Date Reference Type Comment Amount
3/9/2008 1311 500 21 Electric 34401-12017 34.89
3/10/2008 50( 3 Repairs & Maintenance Pick up items in unit 40.00
3/10/2008 50 2 Placement Fee P-142-2008 325.00
3/14/2008 50 0 Repairs & Maintenance Make ready 275.00
3/14/2008 500 31 Plumbing Replace Thermoe couple 69.11
3/14/2008 50( 31 Plumbing Kitchen sink leak 55.00
3/14/2008 50( 3 Repairs & Maintenance Hotwater heater/stove/mailboxes 378.00
3/14/2008 50( 3 Repairs & Maintenance Install Auto feed 480.00
3/14/2008 50 3 Repairs & Maintenance No Heat 75.00
3/14/2008 500 3 Repairs & Maintenance Install heat in utility area 400.00
3/16/2008 1327 50( 43 Trash Removal 0000948091 255.66
3/17/2008 50( 26 Water And Sewer Utility 62041139-0000 8 45.82
3/24/2008 50( 31 Plumbing Water leak 33.00
3/25/2008 50 1 Management Fee Management fees: Thomas J. Ge 51.80
3127/2008 1388 50 0 Locks W64766 30.74
3/31/2008 50 3 Repairs & Maintenance Deliver refrigerator 28.00
3/31/2008 501 0 Locks Provide locks for basement 125.00
3/31/2008 50 0 Locks Double sided deadbolots interior 71.06
3/31/2008 50 0 Locks Utility locks 145.00
3/31/2008 1366 50( 23 Gas And Propane 214 458 6180 28 9.24
3/31/2008 50( 3 Repairs & Maintenance Repaired leak under sink 66.00
3/31/2008 50 Repairs & Maintenance REPLACE DOOR LOCKS 40.00
3,033.32
Net Income/Loss -2,293.32
Other Transactions
Received from owner
Paid to owner
Net Change in Security
Ending Bank Balance
0.00
3,429.14
0.00
.1,493.40
Cash Requirements
Reserve Amount: 200.00
Security Deposits Held: 3,000.00
Total Requirements 3,200.00
- COMMENTS
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 1
717-648-5843
Beginning Bank Balance
Income
Date Reference
4/1/20.08 TJG001 - TJI
4/1/2008 TJ0001 - TJI
4/1/2008 TJG001 - TJI
4/2/2008 TJG001 - TJI
4/4/2008 TJG001 - TJI
4/4/2008 TJG001 - TJI
4/4/2008 TJG001 - TJI
4/15/2008 TJG001 - TJI
4/15/2008 TJG001 - TJI
4/15/2008 TJG001 - TJI
4/30/2008 TJG001 - TJI
Expense
Date
4/21/2008
4/25/2008
4/30/2008
4/30/2008
4/30/2008
Reference
1435
1431
Net Income/Loss
Other Transactions
Received from owner
Paid to owner
Net Change in Securit
Ending Bank Balance
Cash Requirements
Reserve Amount:
Security Deposits
Lehman Property Yangement
P 119*
Detailed Owners Statement
Ownership: Walnut 2200
For the period 41112008 - 413012008
-1,493.40
Type Comment Amount
Credit Ashley Boyne -50.00
Charge Ashley Boyne 50.00
Charge Amanda Sload 370.00
Charge Amanda Sload 170.00
Charge Ashley Boyne 950.00
Charge Ashley Boyne 25.00
located Prepay Ashley Boyne 100.00
Charge Amanda Sload 160.00
Charge Amanda Sload 16.00
located Prepay Amanda Sload 24.00
located Prepay Amanda Sload 100.00
1,915.00
12 Placement Fee
it Management Fee
13 Admin Fee
141 Land Scaping
13 Repairs & Maintenance
Comment Amount
P-133-2008 500.00
Management fees: Thomas J. Ge 130.55
Adminsistrative charge 5.00
Landscaping and exterior cleanul 45.00
Checked heater 30.00
710.55
1,204.45
Deposits
0.00
0.00
0.00
-288.95
200.00
3,000.00
Total Requirements 3,200.00
COMMENTS
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 1
717-648-5843
Beginning Bank Balance
Income
Date
Reference
5/1/2008 TJG001 - TJ(
5/1/2008 TJG001 - TJ(
5/2/2008 TJG001 - TJ(
5/2/2008 TJG001 - TJ(
5/4/2008 TJG001 - TJ(
5/4/2008 TJ0001 - TJ(
5/4/2008 TJG001 - TJ(
5/12/2008 TJG001 - TJ(
5/12/2008 TJG001 - TJ(
5/12/2008 TJG001 - TJ(
5/27/2008 TJG001 - TJ(
5/29/2008 TJG001 - TJ(
Expense
Date
Reference
5/10/2008 1456
5/10/2008 1457
5/11/2008 1480
5/11/2008 1481
5/16/2008
5/19/2008 1510
5/19/2008
5/19/2008 1519
5/26/2008
5/30/2008 1569
5/30/2008 1570
5/30/2008
5/30/2008 1579
Net Income/Loss
Other Transactions
Lehmm P "afty K=Wmmt
t 01 ift
Detailed Owners Statement
Ownership: Walnut 2200
For the period 51112008 - 513112008
-288.95
Type Comment Amount
Credit Ashley Boyne -50.00
Charge Ashley Boyne 50.00
Charge Amanda Sload 370.00
Charge Kristian Gonzalez 650.00
Charge Ashley Boyne 850.00
Charge Ashley Boyne 25.00
located Prepay Ashley Boyne 200.00
Charge Amanda Sload 206.00
Charge Amanda Sload 20.60
orated Prepay Amanda Sload 43.40
orated Prepay Amanda Sload 100.00
Charge Kristian Gonzalez 650.00
3,115.00
)23 Gas And Propane
)21 Electric
)26 Water And Sewer Utility
)26 Water And Sewer Utility
13 Admin Fee
)31 Plumbing
13 Admin Fee
)41 Land Scaping
11 Management Fee
)21 Electric
)23 Gas And Propane
13 Admin Fee
)41 Land Scaping
Comment Amount
214 458 6180 28 152.33
34401-12017 100.91
VOID: Acct# R00025-00 0.00
Acct# R00025-00 93.10
Adminsistrative charge 6.90
replaced supply tubes/b-sink 69.00
Adminsistrative charge 5.00
Landscaping and exterior cleanul 45.00
Management fees: Thomas J. GE 176.05
34401-12017 199.63
214 458 6180 28 154.22
Adminsistrative charge 5.00
Landscaping and exterior cleanul 45.00
1,052.14
2,062.86
Received from owner
Paid to owner
Net Change in Security
Ending Bank Balance
0.00
0.00
0.00
1,773.91
Cash Requirements
Reserve Amount: 200.00
Security Deposits Held: 3,000.00
Total Requirements 3,200.00
COMMENTS..
Lehman Property Man agement
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 1707
717-648-5843
Detailed Owners Statement
Ownership: Walnut 2200
For the period 61112008 - 613012008
Beginning Bank Balance
Income
Date Reference Type Comment
6/1/2008 TJG001 - TJ( Re it Credit Ashley Boyne
6/1/2008 TJG001 - TJ( Ren t Charge Ashley Boyne
6/2/2008 TJG001 - TJ( Re it Charge Amanda Sload
6/5/2008 TJG001 - TJ( Re t Charge Ashley Boyne
6/5/2008 TJG001 - TJ( Re t Charge Ashley Boyne
6/5/2008 TJG001 - TJ( Un [located Prepay Ashley Boyne
6/16/2008 1689 40 26 Water and Sewer 62041139-0000
6/16/2008 J240 40 26 Water and Sewer
Expense
Date Reference
6/9/2008
6/13/2008 1665
6/13/2008
6/13/2008 1685
6/1312008 1674
6/16/2008 1689
6/16/2008 J240
6/25/2008
6/30/2008
6/30/2008 1736
52 Inspection Attedance
?1 Electric
3 Admin Fee
I.1 Land Scaping
I.3 Trash Removal
?6 Water And Sewer Utility
?6 Water And Sewer Utility
I Management Fee
3 Admin Fee
li Land Scaping
Comment
Property inspection
34401-12017
Adminsistrative charge
Landscaping and exterior cleanul
0001004599
09079015-0000
Management fees: Thomas J. Ge
Adminsistrative charge
Landscaping and exterior c[eanul
Lehman Property Management
a?a..a.Q...m
1,773.91
Amount
-50.00
50.00
370.00
750.00
25.00
300.00
-145.03
-145.03
1,154.94
Amount
32.00
199.63
5.00
45.00
183.18
197.74
-145.03
157.15
5.00
45.00
724.67
Net Income/Loss
Less Undeposited Funds
Other Transactions
Received from owner
Paid to owner
Net Change in Security
Ending Bank Balance
430.27
-650.00
0.00
1,749.76
0.00
1,104.42
Cash Requirements
Reserve Amount: 200.00
Security Deposits Hel : 3,000.00
Total Requirements 3,200.00
COMMENTS
Lehman Property Man agement Ulman Property Nanapmwt
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 17070
717-648-5843
Detailed Owners Statement
Ownership: Walnut 2200
For the period 71112008 - 713112008
Beginning Bank Balance 1,104.42
Income
Date Reference Type Comment Amount
7/1/2008 TJG001 - TJt Re Charge Kristian Gonzalez 650.00
7/1/2008 TJG001 - TJ( Re Credit Ashley Boyne -50.00
7/1/2008 TJG001 - TJ( Re Charge Ashley Boyne 50.00
7/1/2008 TJG001 - TJ( Re Charge Amanda Sload 150.00
7/1/2008 TJG001 - TJ( Re Charge Amanda Sioad 36.60
7/1/2008 TJG001 - TJ( Late Charge Amanda Sioad 18.66
7/1/2008 TJG001 - TJ( Re Charge Amanda Sload 314.74
7/3/2008 TJG001 - TJ( Re Charge Ashley Boyne 650.00
7/3/2008 TJG001 - TJ( Re Charge Ashley Boyne 25.00
7/3/2008 TJG001 - TJ( Un (located Prepay Ashley Boyne 400.00
7/17/2008 TJG001 - TJ( Re Charge Amanda Sload 100.00
2,345.00
Expense
Date Reference Type Comment Amount
717/2008 1784 500 41 Land Scaping Landscaping and exterior cleanul 45.00
7/21/2008 1856 500 41 Land Scaping Landscaping and exterior cleanul 45.00
7/21/2008 506 Appliance Purchase or repair of appliance 263.94
7/21/2008 500 Repairs & Maintenance pick up and deliver refrig 40.00
7/25/2008 504 Management Fee Management fees: Thomas J. GE 167.65
7/31/2008 1927 500 1 Land Scaping Landscaping and exterior cleanul 45.00
606.59
Net Incomell-oss 1,738.41
Less Undeposited Funds 650.00
Other Transactions
Received from owner 0.00
Paid to owner 904.22
Net Change in Security eposits 0.00
Ending Bank Balance 1,288.61
Cash Requirements
Reserve Amount:
Security Deposits
Total Requirements
200.00
3,000.00
3,200.00
1' COMMENTS
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 1
717-648-5843
Beginning Bank Balance
Income
Date Reference
8/1/2008 TJG001 - T, R
8/1/2008 TJG001 - TJ4 L
8/1/2008 TJG001 -TJ( R
8/1/2008 TJG001 - TJ( R
8/1/2008 TJG001 - TJ( R
8/4/2008 TJ0001 - TJI R
8/4/2008 TJG001 - TJ( R
8/4/2008 TJG001 - TJ( R
8/4/2008 TJG001 - TJ( U
8/22/2008 TJ0001 - TJ( U
Expense
Date Reference _
8/18/2008 2032 500
8/29/2008 2088 500
8/31/2008 504
Net Income/Loss
Other Transactions
Received from owner
Paid to owner
Net Change in Security
Ending Bank Balance
Cash Requirements
Reserve Amount:
Security Deposits Held
Total Requirements
Lehmm Property YanWment
Detailed Owners Statement
Ownership: Walnut 2200
For the period 81112008 - 813112008
1,288.61
Charge
Charge
Charge
Credit
Charge
Charge
Charge
Charge
ocated Prepay
ocated Prepay
Comment Amount
Amanda Sioad 285.26
Amanda Sioad 38.53
Amanda Sload 388.21
Ashley Boyne -50.00
Ashley Boyne 50.00
Kristian Gonzalez 650.00
Ashley Boyne 550.00
Ashley Boyne 25.00
Ashley Boyne 500.00
Kristian Gonzalez 650.00
3,087.00
4 Land Scaping
B Water And Sewer Utility
Management Fee
Comment Amount
Landscaping and exterior cleanul 150.00
Acct# R00025-00 89.00
Management fees: Thomas J. GE 219.59
458.59
2,628.41
0.00
1,573.41
0.00
2,343.61
200.00
3,000.00
3,200.00
?;_ COMMENTS
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 717-652-4441
Thomas J. Gaul
PO Box 540
New Cumberland, PA 1
717-648-5843
Beginning Bank Balance
Income
Date
9/1/2008
9/1/2008
9/1/2008
9/1/2008
9/5/2008
9/5/2008
9/5/2008
Reference
TJG001 - Tit
TJG001 - Tit
TJG001 - Tit
TJG001 - TJ4
TJG001 -Tit
TJG001 - Tit
TJG001 - TJ(
Expense
Date Reference-
9/30/2008
Net Income/Loss
Other Transactions
Received from owner
Paid to owner
Net Change in Security
Ending Bank Balance
Cash Requirements
Reserve Amount:
Security Deposits Held:
Total Requirements
Lob- P-Put, La- p-ont
Detailed Owners Statement
Ownership: Walnut 2200
For the period 91112008 - 913012008
2,343.61
Credit
Charge
Charge
Charge
Charge
Charge
xated Prepay
1 Management Fee
Comment Amount
Ashley Boyne -50.00
Ashley Boyne 50.00
Amanda Sload 311.79
Amanda Sload 400.21
Ashley Boyne 450.00
Ashley Boyne 25.00
Ashley Boyne 500.00
1,687.00
Comment Amount
Management fees: Thomas J. GE 121.59
121.59
1,565.41
0.00
4,286.82
0.00
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Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 7170652-4441
TO:
Michael Alexander
1929 Market St
Apt 1
Harrisburg, PA 17103
III
IN
Statement
10/1/07 - 2/27/09 2/27/09
TJG003 TJG003A 213R 127
0.00 5,167.75 -5,275.00 -107.25
9/2/08 2921 ck $1050.00
PLEASE RETURN TOP PORTION WITH YOUR REMITTANCE
Previous Balance
12/01/07 Rent Charge 0.00
12/05/07
Payment Received -
hank You
2868
Decembers Rent 500.00
-525.00
01/01/08 Rent Charge
01/02/08
Payment Received -
hank You
2872 500.00
02/01/08
Rent Charge -500.00
02/05/08
Payment Received -
Thank You
2875 500.00
02/06/08
Late Charge -500.00
03/01/08 Rent Charge 47.50
03/06/08 Late Charge 500.00
03/17/08
Payment Received -
hank You
ck 2883
ck 2883 50.00
04/01/08
Rent Charge -525.00
04/01/08
Payment Received -
hank You
ck 2884
ck 2884 500.00
05/01/08
Rent Charge -500.00
05/05/08
Payment Received -
hank You
ck 2888
ck 2888 500.00
06/01/08
Rent Charge -600.00
06/03108
Payment Received -
hank You
2891
PSECU 500.00
06/18/08
Repair Maintenance
lumbing
IV# 266
Replace toilet seat -525.00
25
00
06/18/08 Admin Fee IV# 266 Adminsistrative charge .
5
00
07/01/08 Rent Charge .
07/03/08
Payment Received - T
hank You
2903
ck 500.00
08/01/08
Rent Charge -550.00
08/06/08 Late Charge 500.00
09/01/08 Rent Charge 40.25
09/02/08
Payment Received - T
ank You
2921 ck
Check 500.00
-1,050.00
-107.25
Lehman Property Management
2740 Penbrook Ave
Harrisburg, Pennsylvania - 17103
Statement
Statement Period Statement Date
10/1 /2008 -12/31/2008 2/27/2009
Page 1
Michael Alexander
1929 Market St Apt 1
Harrisburg, PA 17104
Previous Balance Balance Due
($107.25) $392.75
Account No. 00072510
Market 1929 - 1
Date Memo Increase Decrease Balance
10/1/2008 Rent $500.00 $392.75
10/7/2008 Late fee $25.00 $417.75
10/21/2008 Payment received $525.00 ($107.25)
12/1/2008 Rent $500.00 $392.75
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 7170652-4441
TO:
Shawnta Kent
1929 Market St
Apt 2
Harrisburg, PA 17104
Statement
10/1 /07 - 2/27/09 2/27/09
TJG003 TJG0038 213R 125
0.00 4,643.00 P=-3,279.00 P11,,36400
712108 023016 $566.00
PLEASE RETURN TOP PORTION WITH YOUR REMITTANCE
Previous Balance 0.00
12/01/07 Rent Charge 620.00
12/03107 Payment Received - hank You MCI 08-763413533 -35.00
12/03/07 Money Paid Direct to owner -585.00
01/01/08 Rent Charge 620.00
01/03/08 Payment Received - hank You Mo 08-641711022 -35.00
01/06/08 Money Paid Direct to caner -585.00
02/01/08 Rent Charge 620.00
02/01/08 Payment Received -T hank You 020673 011604 -590.00
02/04/08 Payment Received - hank You MO 08-642229570 -30.00
03101/08 Rent Charge 109.00
03104/08 Payment Received - hank You MO 08-642871747 -30.00
04/01/08 Rent Charge 620.00
04/04/08 Payment Received - hank You Mo 08-878102892 -54.00
04/15/08 Payment Received - hank You gov ck 021872 gov ck 021872 -566.00
04/15/08 Payment Received - ank You 021872 Remainder of payment -79.00
05/01/08 Rent Charge
620.00
05/02/08 Payment Received - ank You MID 08841190699 -54.00
05/02/08 Payment Received - ank You g ck 022055 gov ck 022055 -566.00
06/01/08 Rent Charge
620.00
06/03/08 Payment Received - T ank You mo 08-842455585 -54.00
06/04/08 Payment Received - T ank You 022538 Section 8 -566.00
07/01/08 Rent Charge
620.00
07/02/08 Payment Received - T ank You Mo 08842994393 -54.00
07/02/08 Payment Received - T ank You 023016 gov ck 023016 -566.00
08/01/08 Rent Charge
620.00
08/06/08 Late Charge 62.00
09/01/08 Rent Charge 620.00
09/06/08 Late Charge 62.00
1,364.00
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 7170652-4441
TO:
Ken Smith
1929 Market St
3rd floor
Harrisburg, PA 17103
11111011111111111111
Statement
10/1/07 - 2/27/09 2/27/09
TJG003 TJG003C 213R 126
0.00 4,930.85 -3,618.00 1,312.85
8/13/08 MO $200.00
PLEASE RETURN TOP PORTION WITH YOUR REMITTANCE
Previous Balance
12/01/07 Rent Charge
12105/07 Late Charge
12/10/07 Payment Received -'
12/19/07 Non-Sufficient Funds
12/19/07 Non-Sufficient Funds
12/28/07 Payment Received - '
01/01/08 Rent Charge
01/06/08 Late Charge
02/01/08 Rent Charge
02/06/08 Late Charge
02/15/08 Payment Received -
03/01/08 Rent Charge
03104/08 Payment Received -
03106/08 Late Charge
04/01/08 Rent Charge
04/04/08 Payment Received -
04/04/08 Payment Received -
04/04/08 Filing Fee - Tenant la
04/05/08 Late Charge
05/01/08 Rent Charge
05/06/08 Late Charge
05/09/08 Payment Received -1
05/09/08 Payment Received -1
05/30/08 Payment Received -1
05/30/08 Payment Received -1
05/30/08 Payment Received -1
06/01/08 Rent Charge
06/09/08 Late Charge
07/01/08 Rent Charge
k You
istment
k You
k You
k You
k You
k You
d action
MO check 1051
MO NSF (12/10/07) $420.00
(12/10/07) $420.00
mo decembers rent 08-641710859
0.00
400.00
20.00
-420.00
420.00
35.00
-360.00
400.00
40.00
400.00
40.00
-420.00
400.00
-90.00
40.00
400.00
-400.00
-400.00
96.50
40.00
400.00
40.00
-200.00
-200.00
-300.00
-300.00
-128.00
400.00
40.00
400.00
MO 08-801463005
MO 08-863276544
MO 08-841173085
MO 08-841173084
You MO 08-943558067
You MO 08-943-558068
You MO 08842455378
You MO 08842455377
You MO 08-842455386
Page 1
J ?
Lehman Property
2740 Penbrook Ave
Harrisburg, Pa 17103
717-652-4434
FAX 7170652-4441
Statement
10/1/07 - 2/27/09 2/27/09
TJG003 TJG003C 2BR 126
0.00 4,930.85 -3,618.00 1,312.85
07/13108 Late Charge
39.35
08/01/08 Rent Charge 400.00
08/06108 Late Charge 40.00
08/13/08 Payment Received - hank You MO 08-866359322 -200.00
08/13108 Payment Received - hank You MO 08-866359321 -200.00
09/01/08 Rent Charge 400.00
09/06/08 Late Charge 40.00
1,312.85
Page 2
a
Lehman Property Management
2740 Penbrook Ave
Harrisburg, Pennsylvania - 17103
Statement
Statement Period Statement Date
10/1/2008 - 12/31/2008 2/27/2009
Page 1
Ken Smith
1929 Market St 3rd Fl
Harrisburg, PA 17104
Previous Balance Balance Due
$1,312.85 $329.35
Account No. 00074824
Market 1929 - 3
Date Memo Increase
10/1/2008 Rent $400.00
10/7/2008 Late fee $20.00
10/9/2008 Payment received
10/11/2008 LT
$96.50
10/31/2008 Payment received
10/31/2008 Payment received
10/31/2008 Payment received
11/12/2008 Payment received
Decreased Balance
$1,712.85
$1,732.85
$400.00 $1,332.85
$1,429.35
$200.00 $1,229.35
$500.00 $729.35
$300.00 $429.35
$100.00 $329.35
AV
THOMAS J. GAUL and
GEORGINE GAUL, his
Plaintiffs
V.
LEHMAN GROUP, INC. I
LEHMAN PROPERTY
MANAGEMENT,
Defendant
I, Glenn Lehman, l
made in the Complaint are
made subject to the penalt:
falsification to authorities.
: IN COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
No: 09-775 Civil Term
CIVIL ACTION- LAW
VERIFICATION
)efendant, in the above-captioned, verify that the statements
true and correct. I understand that false statements herein are
es of 18 Pa. C. S. A. Section 4904 relating to unsworn
1.
GEORGINE GAUL, his
Plaintiffs
V.
LEHMAN GROUP, INC.
LEHMAN PROPERTY
MANAGEMENT,
Defendant
Attorney for Defendant
IN COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
No: 09-775 Civil Term
CIVIL ACTION- LAW
TO THE HONORABLE
I, Timothy M. Barn
completed in compliance w.
OF SAID COURT:
CERTIFICATE OF SERVICE
uk, Esquire, hereby certify that the following service has been
:h the Rules of Civil Procedure:
First Class Mail
Bryan Shook, Esquire
2132 Market Street
Camp Hill, PA 17011
Respectfully submitted,
The McShane Firm, LLC
Z_
Timothy M. Barrouk, Esquire
Attorney ID # 204537
Attorney for the Petitioner
4807 Jonestown Road
Suite 242
Harrisburg, PA 17109-1739
Telephone: 717-657-3900
Facsimile: 717-657-2060
t "i{.Lt,/"t3 i r' fvfnr_
c
OF THE F TWiNOTARY
1009 APR 13 AM 10: 04
PEN
Bryan W. Shook, Esquire
ID # 203250
The Law Office of Darrell C. Dethlefs
2132 Market Street
Camp Hill, Pennsylvania 17011
Telephone - (717) 975-9446
Fax - (717) 975-2309
BShookg,dcdlaw.net Attorney for Plaintiff
THOMAS J. GAUL and IN THE COURT OF COMMON PLEAS
GEORGINE GAUL, his wife CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V. No: 09-775 Civil Term
LEHMAN GROUP, INC. t/d/b/a CIVIL ACTION - LAW
LEHMAN PROPERTY
MANAGEMENT,
Defendant
To: Tim M. Barrouk, Esquire
4807 Jonestown Road, Suite 148
Harrisburg, Pennsylvania 17109
You are hereby notified to file a written response to the enclosed New Matter &
Counterclaim within twenty (20) days from service hereof or a judgment may be entered
against you.
6-II-aooq
Bryan W. hook, Esquire
Bryan W. Shook, Esquire
ID # 203250
The Law Office of Darrell C. Dethlefs
2132 Market Street
Camp Hill, Pennsylvania 17011
Telephone - (717) 975-9446
Fax - (717) 975-2309
BShook &,dcdlaw.net Attorney for Plaintiff
THOMAS J. GAUL and IN THE COURT OF COMMON PLEAS
GEORGINE GAUL, his wife CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V. No: 09-775 Civil Term
LEHMAN GROUP, INC. t/d/b/a CIVIL ACTION - LAW
LEHMAN PROPERTY
MANAGEMENT,
Defendant
PLAINTIFFS' REPLY TO DEFENDANT'S NEW MATTER AND COUNTERCLAIM
AND PLAINTIFFS' NEW MATTER TO DEFENDANT'S COUNTERCLAIM
AND NOW, comes the Plaintiffs, Thomas J. Gaul and Georgine Gaul, his wife, by
and through his attorneys, THE LAW OFFICE OF DARRELL C. DETHLEFS, by Bryan
W. Shook, Esquire, who responds to Defendant's New Matter and Counterclaim, and
brings forth New Matter to Defendant's Counterclaim as follows:
15. Paragraph 15 being a paragraph of incorporation does not require a response.
16. Denied. It is specifically denied that Defendant deposited all rent into
Plaintiff's account within six hours of receipt for all properties. Plaintiffs demand
strict proof of this averment at time of trial in this matter.
17. Denied. It is specifically denied that Defendant submitted timely, complete,
and accurate monthly operating financial statements to Plaintiffs. Plaintiffs
demand strict proof of this averment at time of trial in this matter.
18. Admitted.
19.After reasonable investigation the Plaintiffs are without knowledge or information
sufficient to form a belief as to the truth of Defendant's averment # 19.
20. Admitted.
21. Denied. The allegations contained in paragraph 21 contain conclusions of
law to which no response is required. To the extant that a response is required,
Plaintiffs specifically deny the allegations contained in paragraph 21 and demand
strict proof thereof at time of trial. By way of further response, Defendant
specifically requested the letter which was hand delivered to Defendant to which
Defendant raised no objection.
22. Denied. The allegations in paragraph 22 contain conclusions of law to which
no response is required. To the extant that a response is deemed required,
Plaintiffs specifically deny the allegations contained in paragraph 22 and demand
strict proof thereof at time of trial.
23. Admitted.
24. After reasonable investigation the Plaintiffs are without knowledge or information
sufficient to form a belief as to the truth of Defendant's averment # 24. By way of
further response, Plaintiffs aver that Defendant has paid them $32,489.28.
25. Admitted in Part, Denied in Part. It is admitted that leases were provided for this
property. Defendant was informed that he did not have to manage 216 4th Street
because Defendants' nephew and good friend lived there. With respect to 218
4th Street, the first floor was rented by Stephanie McMillen on March 23, 2007
and the second floor at 218 4th Street was rented by Thomas Strausbaugh who
moved out in May 2008 at which point Defendant rented to George Ayala
beginning July 3, 2008.
26. Denied. It is specifically denied that rent for 218 4th Street, Enola,
Cumberland County, Pennsylvania was paid directly to Plaintiffs. By way of
further answer, as per agreement between the parties hereto, rent for 216 4th
Street, Enola, Cumberland County, Pennsylvania was paid directly to Plaintiffs.
27.Admitted in Part, Denied in Part. It is admitted that Plaintiffs held the security
deposit for 218 4th Street, Enola, 1St Floor as the tenant moved in prior to
Defendant commencing management services. It is specifically denied that
Plaintiffs held the security deposit for 218 4th Street, Enola, 2nd Floor; Plaintiffs
demand strict proof thereof at time of trial. By way of further answer, Plaintiffs
aver that Defendant held the security deposit for 218 4th Street, Enola, 2"d Floor.
28.Admitted in Part, Denied in part. It is admitted that Plaintiff held the security
deposit for 216 4th Street, Enola, Pennsylvania. It is specifically denied that there
are two apartments at 216 4th Street, Enola, Pennsylvania.
29. Denied. It is specifically denied that the security deposit for the tenant of
Apartment 2 at 216 4th Street, Enola, Pennsylvania was returned from the
Plaintiffs trust account upon the tenant vacating the premises. Plaintiffs demand
strict proof of this averment at time of trial in this matter. By way of clarification,
Plaintiffs believe that Defendant may have mistakenly referred to 216 4th Street
when he intended to refer to 218 4th Street.
30. Denied. It is specifically denied that Defendant rented Apartment 2 at 216
4th Street, Enola, Pennsylvania within six (6) weeks of it becoming vacant.
Plaintiffs demand strict proof of this averment at time of trial in this matter. By
way of clarification, Plaintiffs believe that Defendant may have mistakenly
referred to 216 4th Street when he intended to refer to 218 4th Street.
31. Denied. The allegations in paragraph 31 contain conclusions of law to which
no response is required. To the extant that a response is deemed required,
Plaintiffs specifically deny the allegations contained in paragraph 31 and demand
strict proof thereof at time of trial.
32. Denied as stated. It is specifically denied that 2223 North 6th Street, Harrisburg,
Dauphin County, Pennsylvania was first brought to Defendant in January 2008.
By way of clarification, if Defendant mistakenly listed 2223 yet meant 2233, then
this averment is true and would be admitted.
33. Denied as stated. It is specifically denied that 2223 North 6th Street, Harrisburg,
Dauphin County, Pennsylvania was being rehabilitated by Plaintiffs during the
period beginning January 2008 and ending March 2008. By way of clarification,
if Defendant mistakenly listed 2223 yet meant 2233, then this averment is true
and would be admitted.
34. Denied as stated. It is specifically denied that in April 2008, the Plaintiffs
terminated Defendant's management of 223 North 6th Street, Harrisburg,
Dauphin County, Pennsylvania. By way of clarification, if Defendant mistakenly
listed 223 yet meant 2233, then this averment is true and would be admitted.
35. Denied as stated. It is specifically denied that in August 2008, the Plaintiffs
rehired Defendants to manage 2223 North 6th Street, Harrisburg, Dauphin
County, Pennsylvania. By way of clarification, if Defendant mistakenly listed
2223 yet meant 2233, then this averment is true and would be admitted.
36. Denied as stated. It is specifically denied that all maintenance requests for
2223 North 6th Street, Harrisburg, Dauphin County, Pennsylvania were sent to
the Owner who sent the contractor he had directly engaged to make repairs.
Plaintiffs demand strict proof of this averment at time of trial in this matter. By
way of clarification, Plaintiffs believe that Defendant may have mistakenly
referred to 2223 North 6th Street when he intended to refer to 2233 North 6th
Street.
37. Denied. The allegations in paragraph 37 contain conclusions of law to which
no response is required. To the extant that a response is deemed required,
Plaintiffs specifically deny the allegations contained in paragraph 37 and demand
strict proof thereof at time of trial.
38. Denied as stated. It is specifically denied that during the meeting to discuss the
termination of management for 223 North 6th Street, Harrisburg, Dauphin County,
Pennsylvania, Plaintiffs authorized no more work to be performed by Defendant
without specific approval. By way of clarification, Plaintiffs believe that Defendant
may have mistakenly referred to 223 North 6th Street when he intended to refer to
2233 North 6th Street. If the address was incorrectly listed then Plaintiffs respond
that after reasonable investigation they are without knowledge or information
sufficient to form a belief as to the truth of averment # 38.
39. Admitted.
40. Admitted.
41. Admitted.
42. Denied. It is specifically denied that the security deposit for 1940 Bellevue
Road, Harrisburg, Dauphin County, Pennsylvania was deposited into the owners
account on February 5, 2008. Plaintiffs demand strict proof of this averment at
time of trial in this matter.
43. Admitted.
44. Admitted.
45. Denied. It is specifically denied that at the conclusion of the meeting to
terminate management 1940 Bellevue Road, Harrisburg, Dauphin County,
Pennsylvania, Plaintiffs took possession of all keys to the property. Plaintiffs
demand strict proof of this averment at time of trial in this matter.
46. Denied. The allegations in paragraph 46 contain conclusions of law to which
no response is required. To the extant that a response is deemed required,
Plaintiffs specifically deny the allegations contained in paragraph 46 and demand
strict proof thereof at time of trial.
47. Plaintiffs, after reasonable investigation are without knowledge or information
sufficient to from a belief as to the truth of Defendants averment # 47.
48. Denied. The allegations in paragraph 48 contain conclusions of law to which
no response is required. To the extant that a response is deemed required,
Plaintiffs specifically deny the allegations contained in paragraph 48 and demand
strict proof thereof at time of trial.
49.Admitted in Part, Denied in Part. It is admitted that the basement unit of 2200
Walnut Street, Harrisburg, Dauphin County, Pennsylvania was brought to
Defendant with the basement unit under rehab. It is specifically denied that 2200
Walnut Street, Harrisburg, Dauphin County, Pennsylvania was brought to
Defendant with two units under rehab.
50.Admitted in Part, Denied in Part. It is specifically denied that Apartment 2f was
the only unit rented at 2200 Walnut Street, Harrisburg, Dauphin County,
Pennsylvania when it was brought to Defendant. There is no Apartment 2f at this
address. It is admitted however that there was a tenant in the 2nd floor apartment
when the property was brought to Defendant.
51.Admitted. By way of clarification, the issues were localized to the basement
unit at 2200 Walnut Street, Harrisburg, Dauphin County, Pennsylvania.
52. Ad m itted.
53. Denied. The allegations in paragraph 53 contain conclusions of law to which
no response is required. To the extant that a response is deemed required,
Plaintiffs specifically deny the allegations contained in paragraph 53 and demand
strict proof thereof at time of trial.
54. Denied. It is specifically denied that a security deposit for Apartment 2 at
2200 Walnut Street, Harrisburg, Dauphin County, Pennsylvania was deposited to
Owner's account on February 1, 2009 in the amount of seven hundred ($700.00)
dollars. Plaintiffs demand strict proof of this averment at time of trial in this
matter.
55. Denied. It is specifically denied that a security deposit for Apartment 1 at
2200 Walnut Street, Harrisburg, Dauphin County, Pennsylvania was deposited to
Owner's account on February 19, 2009 in the amount of one thousand
($1,000.00) dollars. Plaintiffs demand strict proof of this averment at time of trial
in this matter. By way of clarification, as per the lease agreement, the security
deposit was two thousand ($2,000.00).
56. Denied. It is specifically denied that a security deposit for Apartment B at
2200 Walnut Street, Harrisburg, Dauphin County, Pennsylvania was deposited to
Owner's account on February 19, 2009 in the amount of six hundred and fifty
($650.00) dollars. Plaintiffs demand strict proof of this averment at time of trial in
this matter.
57. Admitted.
58. Denied. It is specifically denied that the security deposit for Shawnta Kent in
Apartment 2 at 1929 Market Street, Harrisburg, Dauphin County, Pennsylvania in
the amount of six hundred and twenty dollars ($620.00). Plaintiffs demand strict
proof of this averment at time of trial in this matter. By way of clarification, the
tenant in Apartment 2 at 1929 Market Street was a Section 8 tenant, there was
no security deposit received and tenant was there when Plaintiff's purchased the
property.
59. Admitted.
60. Denied. The allegations in paragraph 60 contain conclusions of law to which
no response is required. To the extant that a response is deemed required,
Plaintiffs specifically deny the allegations contained in paragraph 60 and demand
strict proof thereof at time of trial.
WHEREFORE, Plaintiffs, Thomas J. & Georgine Gaul, his wife, demand
judgment against Defendant, Lehman Group, Inc. t/d/b/a Lehman Property
Management, in the full amount demanded in the several counts of their Complaint
and any other such relief as this Honorable Court deems necessary and just.
PLAINTIFFS' RESPONSE TO DEFENDANT'S COUNTERCLAIM
61. Paragraph 61 being a paragraph of incorporation does not require a response.
62. Denied. The allegations in paragraph 62 contain conclusions of law to which
no response is required. To the extant that a response is deemed required,
Plaintiffs specifically deny the allegations contained in paragraph 62 and demand
strict proof thereof at time of trial.
63. Denied. The allegations in paragraph 63 contain conclusions of law to which
no response is required. To the extant that a response is deemed required,
Plaintiffs specifically deny the allegations contained in paragraph 63 and demand
strict proof thereof at time of trial.
64. Denied. The allegations in paragraph 64 contain conclusions of law to which
no response is required. To the extant that a response is deemed required,
Plaintiffs specifically deny the allegations contained in paragraph 64 and demand
strict proof thereof at time of trial.
65. Denied. The allegations in paragraph 65 contain conclusions of law to which
no response is required. To the extant that a response is deemed required,
Plaintiffs specifically deny the allegations contained in paragraph 65 and demand
strict proof thereof at time of trial.
66. Denied. The allegations in paragraph 66 contain conclusions of law to which
no response is required. To the extant that a response is deemed required,
Plaintiffs specifically deny the allegations contained in paragraph 66 and demand
strict proof thereof at time of trial.
67. Denied. The allegations in paragraph 67 contain conclusions of law to which
no response is required. To the extant that a response is deemed required,
Plaintiffs specifically deny the allegations contained in paragraph 67 and demand
strict proof thereof at time of trial.
WHEREFORE, Plaintiffs respectfully request that his Honorable Court dismiss
Defendant's Counterclaim and order Defendant to pay Plaintiffs' costs of defending
Defendant's Counterclaim.
PLAINTIFFS' NEW MATTER TO DEFENDANT'S COUNTERCLAIM
68. Plaintiffs hereby incorporate and make part hereof the preceding paragraphs as if
fully set forth herein.
69. Defendant's Counterclaims may be barred by doctrine of laches.
70. Defendant's Counterclaims may be barred by the doctrine of res judicata.
71. Defendant's Counterclaims may be barred by the doctrine of estoppel.
72. Defendant's Counterclaims may be barred by the doctrine of waiver.
73. Defendant's Counterclaims may be barred in whole or in party by the ethical
statute of limitations.
74. Defendant's Counterclaims may be barred by the doctrine of unclean hands.
75. Defendant's Counterclaims may be barred for lack of consideration.
76. Defendant's Counterclaims may be bared by their failure to mitigate any
damages sustained (all of which are specifically denied).
77. Plaintiffs believe, and, therefore, aver, that any damages suffered by Defendant
were the direct result of Defendant's actions and not those of Plaintiffs.
WHEREFORE, Plaintiff respectfully requests that his Honorable Court dismiss
Defendant's Counterclaim and order Defendant to pay Plaintiffs' costs of defending
Defendant's Counterclaim.
Date: 6- 11 " a ODD(
Respectfully Submitted,
?'W
Bryan W. Shook, Esquire
I.D. # 203250
2132 Market Street
Camp Hill, Pennsylvania 17011
Attorney for Plaintiff
THOMAS J. GAUL and IN THE COURT OF COMMON PLEAS
GEORGINE GAUL, his wife CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V. No: 09-775 Civil Term
LEHMAN GROUP, INC. t/d/b/a CIVIL ACTION - LAW
LEHMAN PROPERTY
MANAGEMENT,
Defendant
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing Plaintiff's Response To
Defendants' New Matter and Counterclaim and Plaintiffs New Matter to
Defendant's Counterclaim, was hereby served by depositing the same within the
custody of the United States Postal Service, First Class, postage prepaid, addressed as
follows:
Lehman Group, Inc. t/d/b/a
Lehman Property Management
c/o Timothy M. Barrouk, Esquire
The McShane Firm, LLC
4807 Jonestown Road, Suite 148
Harrisburg, Pennsylvania 17109
Date: C-11-01
Respectfully Submitted,
?'_ "uJ
Bryan W. Shook, Esquire
I.D. # 203250
2132 Market Street
Camp Hill, Pennsylvania 17011
Attorney for Plaintiff
VERIFICATION
I hereby verify that the statements of fact made in the foregoing documents are
true and correct to the best of my knowledge, information and belief. I understand that
any false statements therein are subject to the criminal penalties contained in 18 Pa C.
S. Section 4904, relating to unswom falsification to authorities.
Date:
10 a'c-- 09
VERIFICATION
I hereby verify that the statements of fact made in the foregoing documents are
true and correct to the best of my knowledge, information and belief. 1 understand that
any false statements therein are subject to the criminal penalties contained in 18 Pa C.
S. Section 4904, relating to unswom falsification to authorities.
Date: A P 4 U.-, & J
o? Georgine ul
t
O THE Y'
0rt
tf?.. 12 ':8 rt. 3' 7
Timothy M. Barrouk, Esquire
ID# 203250
The McShane Firm, LLC
4807 Jonestown Road Suite 148
Harrisburg, PA 17109
Telephone- (717)657-3900
Fax- (717)657-2060
trnb(a,themcshane firm. corn
Attorney for Defendant
THOMAS J. GAUL and
GEORGINE GAUL, his wife
Plaintiffs
V.
LEHMAN GROUP, INC. t/d/b/a
LEHMAN PROPERTY
MANAGEMENT,
Defendant
IN COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
No: 09-775 Civil Term
CIVIL ACTION- LAW
DEFENDANT'S ANSWER TO PLAINTIFF'S NEW MATTER
TO DEFENDANT'S COUNTER CLAIM
AND NOW this 29th day of June, 2009, comes the Defendant, Lehman Group,
Inc. t/d/b/a Lehman Property Management, by and through his undersigned Attorney, The
McShane Firm, LLC and Timothy M. Barrouk, Esquire and avers in support of their
Answer With New Matter and Counterclaim as Follows:
68. Paragraphs one through sixty-seven of Defendants' Answer With New Matter
and Counter Claim are incorporated by reference as if the same were more
fully set forth at length herein.
69. Defendant is advised and therefore avers that said allegations contained in
Plaintiff's averment sixty-nine (69) are conclusions of law to which no
responsive pleading is required. To the extent that they are deemed factual in
nature they are denied. Undersigned Counsel obtained the consent of
Attorney Bryan Shook to file his Answer and Counterclaims outside of 20 days
from the date of service of Plaintiff's complaint. During this time
undersigned counsel and Attorney Shook engaged in conversation regarding
settlement of the case. Defendant raised his claim as a Counterclaim in his
Answer to Plaintiff's Complaint. No prejudice was suffered by the Plaintiff.
70. Defendant is advised and therefore avers that said allegations contained in
Plaintiff's averment seventy (70) are conclusions of law to which no
responsive pleading is required. To the extent that they are deemed factual in
nature they are denied. Defendant's Counterclaim had not been previously
litigated and as such the Doctrine of Res Judicata is not applicable.
71. Defendant is advised and therefore avers that said allegations contained in
Plaintiff's averment seventy-one (71) are conclusions of law to which no
responsive pleading is required. To the extent that they are deemed factual in
nature they are denied. Plaintiff fails to state any reason why Defendant's
claim might be barred by the Doctrine of Estoppel. However, it is expressly
denied that this claim is barred by the Doctrine of Estoppel.
72. Defendant is advised and therefore avers that said allegations contained in
Plaintiff's averment seventy-two (72) are conclusions of law to which no
responsive pleading is required. To the extent that they are deemed factual in
nature they are denied. Undersigned Counsel obtained the consent of Attorney
Bryan Shook to file his Answer and Counterclaim outside of 20 days from the
date of service of Plaintiff s complaint. During this time undersigned counsel
and Attorney Shook engaged in conversation regarding settlement of the case.
Defendant raised his claim as a Counterclaim in his Answer to Plaintiff's
Complaint. No prejudice was suffered by the Plaintiff.
73. Defendant is advised and therefore avers that said allegations contained in
Plaintiff s averment seventy-three (73) are conclusions of law to which no
responsive pleading is required. To the extent that they are deemed factual in
nature they are denied. Undersigned Counsel obtained the consent of
Attorney Bryan Shook to file his Answer and Counterclaim outside of 20 days
from the date of service of Plaintiff s complaint. During this time
undersigned counsel and Attorney Shook engaged in conversation regarding
settlement of the case. Defendant raised his claim as a Counterclaim in his
Answer to Plaintiff s Complaint. No prejudice was suffered by the Plaintiff.
74. Defendant is advised and therefore avers that said allegations contained in
Plaintiff s averment seventy-four (74) are conclusions of law to which no
responsive pleading is required. To the extent that they are deemed factual in
nature they are denied. Plaintiff fails to state why the Defendant's claim
should be barred by the Doctrine of Unclean Hands. However, Defendants
expressly deny that its claim was made with unclean hands.
75. Defendant is advised and therefore avers that said allegations contained in
Plaintiff s averment seventy-five (75) are conclusions of law to which no
responsive pleading is required. To the extent that they are deemed factual in
nature they are denied. Plaintiff entered into a contract whereby Defendants
were to perform services in exchange for fees. Defendant performed the work
required by the contract. Said work and services constitutes consideration.
76. Defendant is advised and therefore avers that said allegations contained in
Plaintiff s averment seventy-six (76) are conclusions of law to which no
responsive pleading is required. To the extent that they are deemed factual in
nature they are denied. Plaintiff failed to state with any specificity how
damages were being calculated. Additionally, the Defendant provided
detailed information regarding the financial status and rents collected to
mitigate damages.
77. Defendant is advised and therefore avers that said allegations contained in
Plaintiff's averment seventy-seven (77) are conclusions of law to which no
responsive pleading is required. To the extent that they are deemed factual in
nature they are denied. The damages suffered by the Defendants were the
direct result of the conduct of Plaintiff. Specifically, Plaintiiff's failure to
comply with his contractual obligations.
WHEREFORE, Defendant demand judgment against the Plaintiffs in the amount
of four thousand one hundred and ninety-three dollars and nineteen cents ($4,193.19)
for monies not collected from the Plaintiffs by the Defendant and whatever other
relief this Honorable Court deems necessary.
Respectfully Submitted,
Date:
Timothy M. Barrouk, Esquire
Attorney I.D.# 204537
4807 Jonestown Road
Suite 242
Harrisburg, Pennsylvania 17109
#717-657-3900
Attorney for Plaintiff
Attorney for Defendant
THOMAS J. GAUL and IN COURT OF COMMON PLEAS
GEORGINE GAUL, his wife CUMBERLAND COUNTY PENNSYLVANIA
Plaintiffs
V.
No: 09-775 Civil Term
LEHMAN GROUP, INC. t/d/b/a CIVIL ACTION- LAW
LEHMAN PROPERTY
MANAGEMENT,
Defendant
TO THE HONORABLE JUDGES OF SAID COURT:
CERTIFICATE OF SERVICE
I, Timothy M. Barrouk, Esquire, hereby certify that the following service has been
completed in compliance with the Rules of Civil Procedure:
First Class Mail
Bryan Shook, Esquire
2132 Market Street
Camp Hill, PA 17011
Respectfully submitted,
The McShane Firm, LLC
Timothy M. Barrouk, Esquire
Attorney ID # 204537
Attorney for the Petitioner
4807 Jonestown Road
Suite 242
Harrisburg, PA 17109-1739
Telephone: 717-657-3900
Facsimile: 717-657-2060
f
2039 JUL -1 Ali ` 11` 24
Ft."d;
Trudy A. Marietta. Mintz, Esquire
ID# 208523
Dethlefs-Pykosh Law Group. LLC 4 y?;Z,t}.34
2132 Market Street
Camp Hill, PA 17011 _ ',-)UNN
Telephone - (717) 975-9446 GUtJ? ?•i' ;''
Fax - (717) 975-2309 pENiv?`t LVPu"?ilA
i maricadminti u d jIgInN .com
THOMAS J. GAUL and IN THE COURT OF COMMON PLEAS
GEORGINE GAUL, his wife CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V.
No. 09-775 Civil Term
LEHMAN GROUP, INC. t/d/b/a CIVIL ACTION - LAW
LEHMAN PROPERTY
MANAGEMENT,
Defendant
PETITION FOR THE APPOINTMENT OF ARBITRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
Trudy A. Marietta Mintz, counsel for the Plaintiffs in the above action, respectfully
represents that:
1. The above-captioned action is at issue.
2. The claim of the Plaintiffs in the action is Thirty-two Thousand Two Hundred Thirty-one
Dollars and Twenty-seven Cents ($32,231.27) plus interest and costs.
3. The counter claim by the Defendant in the action is Four Thousand One Hundred Ninety-
three Dollars and Nineteen Cents ($4,193.19).
4. The following attorneys are interested in the case as counsel or are otherwise disqualified
to sit as arbitrators:
Trudy A. Marietta Mintz, Esquire
Dethlefs-Pykosh Law Group, LLC
2132 Market Street
Camp Hill, PA 17011
Timothy M. Barrouk, Esquire
The McShane Firm, LLC
4807 Jonestown Road
Suite 148
Harrisburg, PA 17109
WHEREFORE, your Petitioner prays your Honorable Court to appoint three (3)
arbitrators to whom the case shall be submitted.
Respectfully submitted,
DETHLEFS-PYKOSH LAW GROUP. LLC
Trudy arietta Mintz, Esquire
2132 Market Street
Camp Hill, PA 17011
(717) 975-9446
Attornev for Plaintiffs
CERTIFICATE OF SERVICE
THIS IS TO CERTIFY that on the 8L' day of September, 2010 a true and correct
copy of the foregoing Petition for the Appointment of Arbitrators was mailed, first class postage
prepaid to :
Timothy M. Barrouk, Esquire
The McShane Firm
4807 Jonestown Road
Ste. 148
Harrisburg, PA 17109
TRUDY A. M ETTA MINTZ, Esquire
T p, r r,
?tf?Fi 17rtl1
)ENNSYiroVa
Timothy M. Barrouk, Esquire
ID# 203250
The McShane Firm, LLC
4807 Jonestown Road Suite 148
Harrisburg, PA 17109
Telephone- (717)657-3900
Fax- (717)657-2060
tmbCc-)themcshanefirm.com
Attorney for Defendant
THOMAS J. GAUL and
GEORGINE GAUL, his wife
Plaintiffs
V.
LEHMAN GROUP, INC. t/d/b/a
LEHMAN PROPERTY
MANAGEMENT,
Defendant
IN COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
No: 09-775 Civil Term
CIVIL ACTION- LAW
MOTION TO CONTINUE
AND NOW, this 15h day of February, 2011, comes the Defendants, Lehman
Property Management, Inc., t.d.b.a Lehman Property Management by and through their
undersigned attorney, The McShane Firm, LLC, and Tim M. Barrouk, Esquire, and
respectfully aver as follows:
1. This matter is currently scheduled for arbitration on February 28th, 2011.
2. The undersigned has a scheduling conflict and is scheduled to appear for trial
in the Court of Common Pleas in the matter of Commonwealth v. Jason
Thompson, Docket No. CP-24-CR-0000334-2009 on the same date and time.
See attached order dated November 14, 2010.
3. On December 21, 2010 undersigned counsel received an Order rescheduling
the arbitration for February 28, 2011 at 9:30 a.m.
4. Despite counsel providing calendars for November and December, 2010 with
their availability, this matter was ultimately scheduled without conferring with
counsel's schedules for February, 2011.
5. Counsel for the Plaintiff, Trudy A Marietta Mintz, Esquire, was contacted and
consents this continuance.
WHEREFORE, Defendants, Lehman Property Management, Inc., t/d/b/a
Lehman Property Management, respectfully request this Honorable Court grant
their Motion and this continue this matter to a date convenient to all parties.
Respectfully submitted,
The McShane Firm, LLC
L
Tim M. Barrouk, Esquire
4807 Jonestown Road, Suite 148
Harrisburg, PA 17109
Tel: 717-657-3900
Fax: 717-657-2060
Attorney ID: 204537
Attorney for Defendant
IN THE COURT OF COMMON PLEAS OF THE FIFTY-NINTH
JUDICIAL DISTRICT OF PENNSYLVANIA
COMMONWEALTH OF PENNSYLVANIA COUNTY BRANCH ELK
VS. CRIMINAL
JASON THOMPSON CP-24-CR-334-2009
ORDER OF COURT
NOW, November 29, 2010, following status conference this date, IT IS
ORDERED AND DECREED that jury seiection shall be conducted on February
14, 2011, commencing at 9:00 a.m. in the Main Courtroom, Second Floor, Elk
County Courthouse, Ridgway, PA.
Final Call of the Jury List is scheduled for February 7, 2011, at 11:00 a.m.
in the Main Courtroom, Second Floor, Elk County Courthouse, Ridgway, PA.
Jury trial shall commence at 9:00 a.m. on February 28, 2011, in the Main
Courtroom, Second Floor, Elk County Courthouse, Ridgway, Pa. One day is
allotted for trial.
Counsel for both the Commonwealth and the defendant have confirmed
their availability for the dates and times scheduled above.
BY THE COURT:
A. Masson Pr6sicTent Judge
j IL It
DEC - 6 2010 I
-- --
k
CERTIFICATE OF SERVICE
I, Cathi Leigh McAdams, an employee of The McShane Law Firm, LLC, hereby
certify a true and correct copy of the foregoing Motion for Continuance was served by
facsimile and postage prepaid, U.S. First Class mail on February 15, 2011 to the
following:
Trudy A. Marietta Mintz, Esquire
1 N. Walnut St., Suite 1
Mechanicsburg, PA 17055
Jennifer Spears, Esquire
10 E. High St.
Carlisle, PA 17013
Marlin L. Markley, Jr.
3920 Market St.
Camp Hill, PA 17011
Date Cathi Leigh McAd ms, Paralegal
f
DETHLEFS-PYKOSH' AW GROUP, LLC
BY: DARRELL C. DE-HLEFS, ESQUIRE
Attorney I.D. No. 58.305
ddethlefs@aol.com.
2132 Market Street;.
Camp Hill, PA 1701:1
Telephone: (717) 975-9446
Facsimile: (717) 97''--2309
THOMAS J. GAUL end
GEORGINE GAUL,
Plaintiffs
i
V.
LEHMAN GROUP," NC., dba
LEHMAN PROPER-;"Y MANAGEMENT,
Defendants
TO THE PROTHONOTARY:
2'51I t R --4 Ail P:
PENNSV"
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
PRAECIPE
Please withdraw ,she appearance of Trudy A. Marietta Mintz, Esquire, as counsel for Thomas J.
Gaul and Georgin° Gaul.
Tru A. Mariettz Mintz, Esquire
14 North Walnut Street
Mechanicsburg, PA 17055
TO THE PROTHOr?OTARY:
Please enter the "-ppearance of Darrell C. Dethlefs, Esquire, of Dethlefs-Pykosh Law Group, LLC,
as attorney for Th':)mas J. Gaul and Georgine Gaul
Darrell C. Dethlefs, Esquire
Dethlefs-Pykosh Law Group, LLC
2132 Market Street
Camp Hill, PA 17011
DETHLEFS-PYKOSH 'AW GROUP, LLC
BY: DARRELL C. DEHLEFS, ESQUIRE
Attorney I.D. No. 5E?805
ddethlefs@ ol.com
2132 Market Street
Camp Hill, PA 17011
Telephone: (717) 9:15-9446
Facsimile: (717) 97'-1-2309
THOMAS J. GAUL 'ind
GEORGINE GAUL,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V.
No..
LEHMAN GROUP, !'NC., dba
LEHMAN PROPER"'Y MANAGEMENT,
Defendants CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I, Darrell C. Dethlefs, Esquire, hereby certify that I have caused a true and correct copy
of the Praecipe n be served upon the following counsel of record via United States Postal
Service, First Clas.,; Mail, postage prepaid, addressed as follows:
Thomas M. Barroi..ck, Esquire
4807 Jonestown F`oad, Suite 148
Harrisburg, PA 17109
n
Resr)ectfu#v S4bmitted:
Dated
e
BY:
Darrell'C'I)'ethlefs, Esquire
J° a,? 60R In The Court of Common Pleas of Cumberland
Plaintiff w'4c
LZAt,,A Aopk'J Mv,,tT w? Defendant
County, Pennsylvania No& - 7 7, f
Civil Action - Law.
Oath
We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United
States and the Constitution of this Commonwealth and that we will discharge the duties of our office
with fidelity.
L" 7
Signature
Name (Chairman)
4tur
i?a e
4C e/1- f kam Wo 6?k 011
Law Firm Law Firm
Address Address
dA rGc/1 ?? j (culliZo 1?7p 1903
Ci zip City, Zip
Signatur
fl ',
Name
k(t
&CoA-4,4•d' 4c.,
Law Firm
Address
e E-,. u•,it, PA- /7,711
City, Zip
Award
We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the
following award: (Note: If damages for delay are awarded, they shall be separately stated.)
ON u/11 fAS' C/a We 7,- ?n 1/tv0/l. OOC N'e ,41/ r-ti-cQ x
Date of Hearing:
Date of Award: (Chairman)
Notice of Entry of Award
Now, the 74 day of , 20 // , at 1-2%.2ff f ,M., the above award was
entered upon the docket and notice th reof given by mail to the parties or their attorneys.
Arbitrators' compensation to be paid upon appeal: $ 354 Cpl)
By:
Deputy
. Arbitrator, dissents. (Insert name if annlicahle_
FILED-OFFICE
OF THE P90THONOTARY,
2011 APR -7 PM 12: 24
CUMBERLAND COUNTY
PENKSYLVANI A
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