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HomeMy WebLinkAbout09-1589Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SUZANNE DIEHL and DONALD E. DIEHL, Plaintiffs V. STEPHANIE TURNER and ERIC KELLER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2009 - `rO CIVIL TERM NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 FAFILEST Tents\12827 Diehl\12827.14.com Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SUZANNE DIEHL and DONALD E. DIEHL, Plaintiffs V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :No. 2009 - I,-0 CIVIL TERM STEPHANIE TURNER and ERIC KELLER, Defendants COMPLAINT 1. Plaintiffs, Suzanne Diehl and Donald E. Diehl, are adult individuals residing at 110 W. Springville Road, Boiling Springs, Pennsylvania 17007. 2. Defendants, Stephanie Turner and Eric Keller, are adult individuals who reside at 687 South Middlesex Road, Carlisle, Pennsylvania 17015. 3. On or about June 6, 2007, Plaintiffs and Defendants entered into a written residential lease agreement ("Lease") whereby Defendants agreed to rent the premises at 133 Andrew Court, Carlisle, Pennsylvania 17013 ("Premises"). A true and correct copy of the Lease is attached hereto as Exhibit "A" 4. The Residential Lease ended on or about July 31, 2008. 5. Pursuant to the Lease, Defendants agreed to make monthly rental payments of $875.00 due on or before the first day of each month. 5. In the event that a payment became delinquent, a late charge of $3.00 per day was assessed. 6. Defendants failed to make a timely payments of rent for the months of July 2008 through February 2009, before vacating the Premises in February 2009. 7. Defendants have failed to pay rent for the remainder of the term of the Lease being March 2009 through July 2009. 8. Defendants have failed to pay for the damages as set forth on Exhibit "B" that are due under the Lease totaling $3,585.60. 9. The outstanding rent owed for the remaining term of the Lease is $4,375.00. 10. Defendants have failed and refuse to pay the outstanding charges as stated above. A copy of the February 25, 2009, letter to the Defendants outlining the amounts owed is attached as Exhibit "B." 11. Pursuant to the Lease Agreement, Defendants are indebted to the Plaintiffs for damages as stated above, plus costs of suit and attorney fees. WHEREFORE, Plaintiffs demand judgment in their favor and against Defendants in the amount of $7,960.60, plus costs of suit, interest, any additional damages discovered hereafter, and attorney fees in the amount of $1,000.00. MARTSON LAW OFFICES By Christopher E. Rice, Esquire I. D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Date: /z - 0 Attorneys for Plaintiffs This a debt collecting firm. Any information obtained will be used for that purpose. EXHIBIT "A" RESIDE L SE AGREEMEN'T' This is a Lease. Today's date is -J-U Me (o The Landlord is Suzanne Diehl 4 200 7. Diehl, a licensed Pennsylvania Real Estate East BStreet Suite A, Carlisle, PA 17013) and/or Donald 17013). (bast High Street, Suite A, Carlisle, PA E. The Tenant(s), collectively referred to as "Tenant," are. The rented property is: The Landlord and Tenant will legally be and Tenant both undo responsible to follow the terms of this Lease Landlord this is a legal, binding contract and either attorney's opinion before signing that going it. Party may seek an 1. TERM OF SE This lease will begin on ???? 200$ on Au (g UST / 200 and end at midnight 2 ?CATION It is agreed that either Landlord or Tenant ma of the initial term by giving the other may terminate this Lease at the end the initial term. In the event ? Pte' wntten notice at least two (2) months prior to the end of other, this Lease shall continue with ?eotice of intent to termi nate is expiration of the initial term for another same terms and conditiin f given by either party to the ons terminated by the other s of ori year and so on from rce immediately Prior to the perie to the expiration of the then urten Bother two (2) months year to year, unless written notice of the term' month written noti ce prior to the expiration however, that is the Landlord won prior terms and conditions prior Lease, of any term hereb shall give one forth in the notice, the Tenant will be and consde hereby created of his intention to change the errant remains in the prises after the effective date set provided in such notice. A11 t red as a Tenant under the ter erms and conditions in existence ms and conditions as inconsistent with or repealed by such notice, shall remain in e fWl p fo r to such notice mu rce and effect. ch are not 3• nNDIN?GAS Ur v for ay reason, before the Lease ends, oilY bt doui nd this Lease at the end of an y g the following; Y calendar month, (a) giving Landlord at least dlft Paying any money due to the (30) days written notice; late charges, damages or any other up to the ending date, including rent, and'ges the law allows the ;Landlord to collect (c) paying to Landlord two 2 ' () months rent as additional damages. If either the Landlord or the Tenant fails or refuses to do anythin rePAY has broken the Lease and the other 8 gwred b law. Ply may enforce this Lease accordm t pew then that This could include ending the Lease, and/or suing the party that fai g and damages. l ed to perform for Ioses sea 4. BREAI{IlV THE LEASE, (a) (b) (c) (d) (e) M (g) 5. LANDi?r 1D's FMFDIES remedies afforded bylaw: if Tenant breaks the Lease, Landlord may, in addition to all other (a) end this Lease. Landlord must give Tenant before starting any legal action havanfive (5) t evicted o written notice any reason. breaking this Lease for Tenant understand that it is gh4ng nMM1' (90) day noti=ces aQowed under thits tight e Pennta lvQ en (I S), thirty sY aLandlord-Tenant laws (b) demand immediate payment in full for all charges, including but not limited due, additional rental and charges reserved for the remainder of the unexpired to: rent term, late fees, damages and filing fees; Lease (c) have Tenant's Property seized pay Tenant to Landlord; by the Courts and sold to any debts owed by (d) sue Tenant for additional damages, costs, expenses, and reasonable attorney's 6• RENT. Tenant agrees fees, T t/ F-7 V ?? to Landlord monthly rent of J ?.y ? ?V4 '1111 monthly rent in advance by the fi day of each month. oDO b Tenant agrees to a rjs Tenant paid Y first day of each month agrees to pay to Landlord a late fee of $3.00 per day for administrative costs, expenses damages beginning the second day of each mon understands that the monthly rent is due on or ?' until all charges are paid in full. Tenant and receive a bill or invoice for monthly rent, Payment of the final monthly rental shall be due on the 7• SECL& TY DEPn?t'r Tenant will pay to Landlord a security del set forth in Paragraph 6 above. Landlord will hold the deposit as security for: to one month rent (a) payment of rent; (b) payment of any other sum due from Tenant to Landlord; (c) charges for damages caused by Tenant, Tenant's family or Tenant's (d) performance of this Lease. guests; Tenant has broken the Lease if Tenant: fails to pay rent when it is due; fails to pay Landlord any other sum when it is due; breaks any provision of this Lease, including the Rules and Regulations attached hereto; moves itself or its possessions from the premises prior to paying Landlord any and all charges due to the end of the Lease; fails to move itself and its possessions from the p Lease; remises at the end of the does any act which is not allowed under the terms of this Lease; and does not do any act which is required under the terms of this Lease. Tenant & ther understands that the Tenant may not apply this security deposit against rent o other money due to the Landlord. or any Landlord will refund the security deposit to Tenant, less any sum due on Tenant's accoun thirty (30) days following the end of the Lease. Any refund will be made by check a blew persons signing this Lease as Tenants. Tenant must supply to Landlord in writing a orwardin all street address (no post office boxes) in order to receive any refund due Tenant, g 8. POSSESSION Tenant agrees that if Landlord cannot give Tenant immediate possession due to the fact that a previous tenant has not vacated the premises at the end of their lease or for any other reason beyond the control of the Landlord, the Tenant will not hold Landlord responsible for an any damages. However, Landlord will not begin to charge monthly rent until such time as Landlord give Tenant substantial possession. All other terms of this Lease will remain in full force can and d a effect. 9. USE OF PROEPRTY Tenant Tenant and those others listed on La agrees 's Rental Apse on.yTe th principal residence of the any act or practice which: agrees not to do or permit (a) injures the premises or anyone on the premises; (b) disturbs other residents or neighbors of the property; (c) adversely affects the insurance on the property; (d) is against the law. Z 10. ?-_QF_PROPF Tenant will not misuse or mistreat dn portion property, including appliances and common areas. Tenant further agrees to: (a) give notice to Landlord of any repairs; (b) pay for any repairs to Landlord's property necessitated by any act or lack of care on the part of Tenant, Tenant's family or Tenant' s (c) leave the property, includin guests; vacating the premises. Wheappliances vacating ?? floor coverings, clean when vinyl is to be cleaned by a professional commercial cleanerreat Tenant's expense. Landlord will make any necessary repairs to the having received notice of the need for premises within a reasonable period of time after repair from Tenant. 11. DAMAGE BY FIltE. If the premises is damaged by fire or other mishap, the Landlord will repair it within a reasonable period of time. Tenant may continue to reside at the premises if the same is not rendered uninhabitable, and rental fees shall continue to apply. If the premises determined to be uninhabitable, Tenant may move out and end the Lease. Tenant shall shall be be responsible for immediate payment of any rent or other charges due to the date which the property is surrendered. 12. INSURANCE. Landlord will be responsible to provide ins and other casualty, including liability coverage for injury °T ?Ce on the premises against fire damage occurring within common areas of the premises. Landlord is NOT responsible located in or on the premises. Tenan?0 obs or damage to Tenants personal belongings. fain Renter's h Perso nal Property surance for protection of its 13. UTILI TIES Landlord and Tenant are responsible to pay for utilities as follows: Landlord: Water Sewer Trash Electric Gas Fuel Oil Tenant: - Tenant is responsible for telephone and cable television services. maintenance of all other systems belonging to Landlord, Landlord Landlord is responsible provide heat, hot water, or other utilities or services if the fail is not re able ible for Any repairs needed to maintain the spansble for failure to Performed in a reasonable Period Utility systems Owed by Landlord in wo kthe d 9s in?dlors control. of time. g order shall be 14. APPLIANCES Landlord and Tenant will Supply the appliances as follows: Stove Refrigerator Dish Landlord: _ her Washes Dryer Tenant: 15. ENTRY BY LANDLORD. Landlord Property at reasonable time for the °r anyone flowed by Landlord has the right to enter the Purpose of (a) inspecting the property; (b) 8 PertY; nuking repairs or alterations as needed; (c) enforcing this Lease; (d) showing the property to prospective purchasers or tenants. 16. ?S_SIGNrMENT OR cr1gL?Q Part thereof without prior written Tenant shall not assign or sublease the r consent of the Landlord. P Wises or any 17. BAD CHECKS. Tenant will be char due to "IlVSUFFICIENT RINDS ged a fee of $20.00 for each check turned to Landlord the check. In addition, Tenant will beased by closing of an account or an re as a result of said bad check. responsible for any and all char y Other technical defect of 8es that Landlord may incur 1 g RULES AND REGULATIONS. Tenant agrees that it, it's Rules and Regulations attached hereto and made a family and Part of this Lease. Y guests will obey the 19. NON-WAIVER OR REMEDIES Tenant a ees charges after they are due, or if Landlord does not insist othat if n strict andlord enforcement accepts rent or an other the Lease, this will not be considered a waiver of the right to insist the strict any term or condition of this Lease in the future. Land of any other teens of performance of any reason, enforce orwaive lord may selectively and inconsistently, for any remedies available to Landlord without establishing future oIic. P y 20. LAWN MAn?rrmi .ANCE ANn SNOW R Fl??rn17 lawn maintained. Tenant shall be responsible to r r? Landlord'?re s to keep the any snow, ice and debris as required by any law or promptly now in effect oI d sidewalks from term of this Lease. enacted during the 21. S RIDER OF PREMISE Upon the expiration or to be responsible to return the remises to nation of this Lease, Tenant Shall Tenant shall e to p Landlord in the same condition in which Tenant received it. responsible to return the premises in broom-cleaned condition. Tenant shall be responsible for the removal of all personal belongings Lease. If Tenant shall fail to remove its personal upon the expiration or termination of this belongings removed and charge the Tenant with anybelongings, costs incurred °T shall have Tenant's personal responsible to contract with and pay for the professional co Want shall also be vinyl in the premises. commercial cleaning of all carpeting and Signed and agreed to this ? day of (,t u?- bound hereby. 200--/7., and tending to be legally Witness: U tint ames?. ? t L • % CrI'n Cr' Tenant ?? M"A11Tif 1217'r* Tena? incl ?La®NS conduct resident temselves in any way tjW y? guests, will not do anyd?g or an or ?ghbor. w.nth the rights, comforts or conyemenees of noise or any other 2 No pets of any kind shall be kept at tten as addidonW on. If any pet is kept by Tenant Landlord's P, shalt mdthotlt o without the Landlords' prior paYnN not tit the sum of 550.00 per moadl for each full P?nission, Test does mean that Landlord must allow per, °! Partial month. This 3. ANN r A =_ In the evmt additional o sh ll shall live in the PmPerty, a fee of 0.00 per p Person, pons e not listed on Landlord's Rental 19h be Paid by Tenant This PaYmeaa?t does not q fOr full or Partial additional tenants. that nd moat allow 4. STAN O__F,D T r n•T? Tenant shall keeP dmftwng in LQg A Tenant shall not change or install additional j good and ,condition. S;-* andloa fee of Lease. 0.00 per lock will be o? without the writ aged for any keys not mtumed at the end of sth°e of 6. ??&IF"= Tee is not Permitted to"" any kern 7. sere or space heaters in the propenY to be bored on the 8. PmP?y any toxic, hazardous or flammable substances. t veil not More or pemlt Protection and wanVng Landlord will equ eat. Tenant 28 _ devices in the prop?y. Tit will n n the fire prevention, Tenant win replace brie amble for vcdfying the all such equ m 'ft is with or disable any such is not fi?tioizin& >?s i'eP?when d or has ?d ??Y Landlo ??yP?ational at all tunes. nnipl ed with soh olii intent EXHIBIT "B" Donald E. Diehl Rentals 4 East High Street, Suite A Carlisle, PA 17013 249-7127 February 25, 2009 249-7125(FAX) Stephanie Turner & Eric Keller 133 Andrew Court Carlisle, PA 17015 Dear Eric & Stephanie: According to our records you owe the following: July 2008 rent ................. .................................... -,$875.00 August 2008 rent........... Paid 8-2-08........... ....................................... -$895.00 .............................................. +$100.00 Paid 8-2-08........... Paid 8-12-08...... .............................................. +$500.00 September 2008 rent........."..."'.,..""••.••"..•"•""""•••+$500.00 Paid 9-4-08.......... ..................................... -$895.00 October 2008 rent ..................."...........................+$900.00 Paid 10-3-08.. ............................................ -$895.00 watersewer:bill.7-01-08 to '".....'""""'•'.•••+$900.00 9-30-08.......... -$105.00 Paid 10-16-08 water sewer.. "' " Paid10-16-08........... ................................ +$105.00 November 200 r ............................. +$20.00 ent............... " -$895.00 Paid 11-12-08.. '.•.•""""'""'"""' December 2008 rent .... ,'•.""•".•"'""•""?•'"?•'.."""""•••+$900.00 January 2009 rent .............................................. -$895.00 Paid 1-10-09.. ... ................................. -$895.00 February 2009 rent............ •...•••'"•"?.???••'""""""'••+$900.00 Watersewer10-1-08to 12-31-08 ................................. $895.00 ........... -$119.60 Water sewer 4-01-08 to 6-30-08.......................... $103.00 Water sewer1-01-08 to 03-31-08..... Water sewer 10-01-07 to 12-31-07 '•'.'."'•"•"""'-$109.00 .. _S105.00 Balance owed as of February25, 2009.. - $2, 356, 60 late fees of $3.00 per day for 243 days - ., . . 59.00 Balance with late fees du 33,585-60 Please make a check out to Donald E. Diehl and mail it to 4 East High Street, Carli l 17013. Thank you, s e, PA Sincerely Donald E. Diehl VERIFICATION The foregoing Complaint is based upon information which has been gathered by our counsel in the preparation of the lawsuit. The language of the document is that of counsel and not our own. We have read the document and to the extent that it is based upon information which we have given to counsel, it is true and correct to the best of our knowledge, information and belief. To the extent that the content of the document is that of counsel, we have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if we make knowingly false averments, we may be subject to criminal penalties. R CKI IJI w ? Cs >v ? r7 f? -r i d Sheriff s Office of Cumberland County R Thomas Kline ?*,SIT of +Laabcr??? Edward L Schorpp Sheriff" Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFaU Of THE SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/16/2009 02:45 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 16, 2009 at 1445 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Stephanie Turner by making known unto Eric Keller, boyfriend of defendant, at 687 S. Middlesex Road, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 03/16/2009 02:45 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 16, 2009 at 1445 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Eric Keller by making known unto Carol Keller, grandmother of defendant, at 687 S. Middlesex Road, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $48.92 (PAID) SO ANSWE , i March 17, 2009 R THOMAS KLINE, SHERIFF Deputy Sheriff Docket No. 2009-1589 Suzanne Diehl v Stephanie Turner [7 _ f ,i . FARLESUients\12827 Diehh12827.14.pra.defauh Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SUZANNE DIEHL and DONALD E. DIEHL, Plaintiffs V. STEPHANIE TURNER and ERIC KELLER, Defendants TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2009 - 1589 CIVIL TERM PRAECIPE Enter default judgment in the above-captioned action in favor of Plaintiffs and against Defendants in the amount of $7,960.60, plus costs of suit, interest, any additional damages discovered hereafter, and attorney fees in the amount of $1,000.00 as prayed for in the Complaint, for failure to file an Answer to Plaintiffs' Complaint. I do hereby certify that a written notice of intention to file this Praecipe was mailed to the Defendants at the address indicated thereon, on April 20, 2009, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. MARTSON LAW OFFICES Dated: - y Q 9 By: C'etl. S 2 Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff F:T1LES\C1ients\12827 DiehA12827.14.10 daynotice Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SUZANNE DIEHL and : IN THE COURT OF COMMON PLEAS OF DONALD E. DIEHL, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : No. 2009 - 1589 CIVIL TERM STEPHANIE TURNER and ERIC KELLER, Defendants IMPORTANT NOTICE TO: STEPHANIE TURNER DATE OF NOTICE: April 20, 2009 687 South Middlesex Road, Carlisle, PA 17015 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 MARTSON LAW OFFICES By_ Christopher E. Rice, Esquire This a debt collecting firm. Any information obtained will be used for that purpose. Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SUZANNE DIEHL and : IN THE COURT OF COMMON PLEAS OF DONALD E. DIEHL, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : No. 2009 - 1589 CIVIL TERM STEPHANIE TURNER and ERIC KELLER, Defendants IMPORTANT NOTICE TO: ERIC KELLER DATE OF NOTICE: April 20, 2009 687 South Middlesex Road, Carlisle, PA 17015 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 MARTSON LAW OFFICES By "? 'o' /E-- Christopher E. Rice, Esquire This a debt collecting firm. Any information obtained will be used for that purpose. Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SUZANNE DIEHL and DONALD E. DIEHL, Plaintiffs V. STEPHANIE TURNER and ERIC KELLER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 2009 - 1589 CIVIL TERM AFFIDAVIT AS TO MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he has authority to make this affidavit on behalf of his client, and to the best of his knowledge, information and belief, the Defendants above named are not in the military service of the United States of America, that he has knowledge that the said Defendants are now living at: 687 South Middlesex Road, Carlisle, PA 17013. Said Defendants' place of employment is unknown. S 2-- Christopher E. Rice, Esquire Sworn to and subscri d be ore me this day of 72009. r N ublic CpMMpNYVEA 1H OF PENNSYLVANIA Notarial Seel Mary M. PhDs, Notary Punta Cartels 8M, Cumbuiand 1 * My cwmy s W Lvft &4 Member, Psnnsyly 0 AssoolaNon; Now m Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SUZANNE DIEHL and DONALD E. DIEHL, Plaintiffs V. STEPHANIE TURNER and ERIC KELLER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 2009 - 1589 CIVIL TERM COMMONWEALTH OF PENNSYLVANIA ) SS COUNTY OF CUMBERLAND ) Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he is an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, attorneys for the Plaintiff in the above captioned matter and that pursuant to the provisions of the Pennsylvania Rules of Civil Procedure, a notice of intention to enter default judgment against the Defendants was given to them by mail on April 20, 2009. 0?? S K- Christopher E. ice, Esquire Sworn to and subscribed before me this day of '2009. N ublic COMMONWEALTH OF PENMnvnNa Notmd sees Mary M. Prkw Notary PLM ?1 2M1 M CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Stephanie Turner 687 South Middlesex Road Carlisle, PA 17013 Eric Keller 687 South Middlesex Road Carlisle, PA 17013 MARTSON LAW OFFICES By:, M Price Ten st High Street Carlisle, PA 17013 (717) 243-3341 Dated: j ? 0 9 In malting this communication, we are advising you this firm is attempting to collect a debt for Suzanne Diehl and Donald E. Diehl. Any information gained from this communication will be used for that purpose i W r OF THE FR r, ?F?Y 2N9 MAY -4 PH 2: 32 r O Ay S Oi l?f ?7?/(0?11f lu ?Uf?? 4Ylac.? Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SUZANNE DIEHL and DONALD E. DIEHL, Plaintiffs V. STEPHANIE TURNER and ERIC KELLER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 2009 - 1589 CIVIL TERM TO: STEPHANIE TURNER, DEFENDANT NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the day of May, 2009, the following Judgment was entered against you in the above-captioned action: judgment in the amount of $7,960.60, plus costs of suit, interest, any additional damages discovered hereafter, and attorney fees in the amount of $1,000.00 as prayed for in the Complaint for failure to file an Answer to Plaintiff's Complaint. Date: r honotary I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Stephanie Turner 687 South Middlesex Road Carlisle, PA 17013 Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SUZANNE DIEHL and DONALD E. DIEHL, Plaintiffs V. STEPHANIE TURNER and ERIC KELLER, Defendants TO: ERIC KELLER, DEFENDANT : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 2009 - 1589 CIVIL TERM NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the day of May, 2009, the following Judgment was entered against you in the above-captioned action: judgment in the amount of $7,960.60, plus costs of suit, interest, any additional damages discovered hereafter, and attorney fees in the amount of $1,000.00 as prayed for in the Complaint for failure to file an Answer to Plaintiff's Complaint. Date: I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Eric Keller 687 South Middlesex Road Carlisle, PA 17013