HomeMy WebLinkAbout09-3290COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS
Judicial District, County Of
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. 09- 3A /Q0 ctv"/
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on
the date and in the case referenced below.
NAME OF APPELLAJ4T MAG. DIST. NO. NANIt yr U.J.
C •se a_ G .?-?-, 16q - 3 -6 ? 7- 6J4 49' f t 70 5 c
ADDRESS "T ANT ITY STATE ZIP CODE
al.h YVIec?Ath-cS6P 17090
IN THE CASE OF
-1S'` - I I CL & rQ rn m C -. <xi ke rek) IcA C6 t, n r
DOCKET No. ?? O O q s C q SIGNATURE OF APPELLANT OR ATTORNEY OR AGENF'
This block will be signed ONLY when this notation is required under Pa. If appellant was Claimant (see Pa. R.C.P.D.J. No. 1001(6) in action
R.C.P.D.J. No. 1008B.
This Notice of Appeal, when received by the District Justice, will operate as a before a District Justice, A COMPLAINT MUST BE FILED within twenty
SUPERSEDEAS to the judgment for possession in this case.
(20) days after riling the NOTICE of APPEAL.
Signature of Prothonotary orDepAy
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before District Justice. IF
NOT USED, detach from copy of notice of appeal to be served upon appellee.
PRAECIPE: To Prothonotary
Enter rule upon k r&Rre h e 4 16,1V Co hn e K appellee(s), to file a complaint in this appeal
Name of appellee(s)
(Common Pleas No. / - 3 ?_ $ Q C WI. I ) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
Signature of appellant or alltlYmiy or agent
RULE: To r(xi R of e nP_ & ki'+ h n et' , appellee(s) I
Name o appellee(s) &I 5 e-' Q Gramme-
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service
of this rule upon you by personal service or by certified or registered mail.
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of the mailing. (EGG o O?
Date: 6L?? , 20 Q 9 signature of Proth ry or Deputy
CIO (
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
AOPC 312-02
WHITE -COURT FILE TO BE FILED WITH PROTHONOTARY GREEN - COURT FILE YELLOW - APPELLANT'S COPY
PINK -COPY TO BE SERVED ON APPELLEE GOLD -COPY TO BE SERVED ON DISTRICT JUSTICE
1*a,
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILI COM'P'LAINT
(This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER ding of the notice of appeal. Check applicable boxes.)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ; ss
AFFIDAVIT: I hereby (swear) (affirm) that I served
? a copy of the Notice of Appeal, Common Pleas , upon the District Justice designated therein on
(date of service) 20 , ? by personal service ? by (certified) (registered) mail,
sender's receipt attached hereto, and upon the appellee, (name) , on
,20 ? by personal service ? by (certified) (registered) mail,
sender's receipt attached hereto.
(SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS DAY OF , 20
Signature of affiant
Signature of official before whom affidavit was made
Title ofofficial
My commission expires on 20
uU c?i j r1
ti CC.
` v
C\j
LLJ ^q"? `ma`y
ix Lu
_ `?=iL
10
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CMWERLAND
Mag. Dist. No.:
MDJ Name: Hon.
09-3-04
THOMAS A. PLACEY
Address: 104 S SPORTING HILL RD
MECHANICSBURG, PA
't'elephone: (717 ) 761-8230 17050
NOTICE OF JUDGMENT/TRANSCRIPT
RESIDENTIAL LEASE
PLAINTIFF: NAME and ADDRESS
r_XATHERINE E. & CHRISTOPHER CODER 7
1772 KMWALL DRIVE
MECHANICSBURG, PA 17055
L J
VS.
DEFENDANT: NAME and ADDRESS
rGRA111MEL, GISELA
28 DAPP LANE
MECHANCISBRUG, PA 17050
GISELA GRAMMEL L J
28 DAPP LANE Docket No.: LT-0000264-09
MECHANCISBRUG, PA 17050 Date Filed: 5/04/09
s?
I
THIS IS TO NOTIFY YOU THAT:
Judgment: 1FOR PLAINTIFF
a Judgment was entered for: (Name) KATHERINE E. A CHRISTOPHER CON
Judgment was entered against GRAMIM, GISELA in a
Landlord/Tenant action in the amount of $ 3,919.35 on 5/15/09 (Date of Judgment)
The amount of rent per month, as established by the Magisterial District Judge, is $ 1, 750.00.
The total amount of the Security Deposit is $ 1,750.00
Total Amount Established b1[ 2M5 J3Less -Security Deposit Applied
Rent in Arrears •
Physical Damages Leasehold Property $ .00-$ .00=
Darnages/Unjust Detention $ 1475n nO- $ _ 00=
Less Amt Due Defendant from Cross Complaint -
Interest (if provided by lease)
L/T Judgment Amount
? Attachment Prohibited/ Judgment Costs
42 Pa.C.S. § 8127 Attorney Fees
? This case dismissed without prejudice.
® Possession granted.
? Possession granted if money judgment
? Possession not granted.
Total Judgment
$ Adjudicated amount
825.35
$ .00
$ 1,790-00
$ .00
$ 1,27-_00
$ 3,790_35
$ 129.00
$ _AO
$ 3,919.35
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
? Defendants are jointly and severally liable.
IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN
TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS
OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT, IF ANY. IN
ORDER TO OBTAIN A SUPERSEDEAS, THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF
THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED. HOWEVER, LOW-INCOME AND/OR
SECTION 8 TENANTS SHOULD REFER TO Pa.R.C.P.M.D.J. No. 1008 OR 1013 FOR DIFFERENT PROCEDURES REGARDING THIS DEPOSIT.
IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE PARTY HAS
30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF
COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION.
THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THE NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT
HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT
OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR, PAYS IN FULL,
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
r3 +
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND
Mag. Dist. No.:
MDJ Name: Hon.
09-3-04
THOMAS A. PLACEY
Address: 104 S SPORTING HILL RD
MECHANICSBURG, PA
Telephone: (717 ) 761-8230 17050
NOTICE OF JUDGMENT/TRANSCRIPT
RESIDENTIAL LEASE
PLAINTIFF: NAME and ADDRESS
rGRAMMEL, GISELA -l
28 DAPP LANE
MECHANCISBRUG, PA 17050
L J
VS.
DEFENDANT: NAME and ADDRESS
rEATHERINE & CHRISTOPHER COMM ?
1772 KENDALL DRIVE
MECHANICSBURG, PA 17055
GISELA GRAMMEL L J
28 DAPP LANE Docket No.: LT-0000264-09
MECHANCISBRVG, PA 17050 Date Filed: 5111109
CROSS COMPLAINT 001
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR DSIr RANT
® Judgment was entered for: (Name) KATEMINE & CHRISTOPHER COMM
Judgment was entered against GxANKEL, GISELA, in a
Fx-] Landlord/Tenant action in the amount of $ .00 on 5115109 (Date of Judgment)
. The amount of rent per month, as established by the Magisterial District Judge, is $ .00.
The total amount of the Security Deposit is $ .00
Total Amount Established by MDJ Less • Security Deposit Applie_
Rent in Arrears $ .00-$ .09 =
Physical Damages Leasehold Property $ .00- .00=
Damages/Unjust Detention $ .00-1 _ 00=
Less Amt Due Defendant from Cross Complaint -
Interest (if provided by lease)
L/T Judgment Amount
? Attachment Prohibited/ Judgment Costs
42 Pa.C.S. § 8127 Attorney Fees
? This case dismissed without prejudice.
? Possession granted.
? Possession granted if money judgment
? Possession not granted.
Total Judgment
$ Adjudicated Amount
.00
$ .00
$ _oo
$ .00
$ _00
$ _00
$ _00
$ _00
$ .00
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
? Defendants are jointly and severally liable.
IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN
TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS
OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT, IF ANY. IN
ORDER TO OBTAIN A SUPERSEDERS, THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF
THREE MONTHS RENT OR THE REi T ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED. HOWEVER, LOW-INCOME AND/OR
SECTION 8 TENANTS SHOULD REFER TO Pa.R.C.P.M.D.J. No. 1008 OR 1013 FOR DIFFERENT PROCEDURES REGARDING THIS DEPOSIT.
IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE PARTY HAS
30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF
COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. ,
THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THE NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT
HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST CODE fiROM' THE COURT
OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE.
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL" )ISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
47 D Date 1..? , Magisterial District Judge,
certify at this is a true an ere r o e lag containing the judgment.
` S Date , Magisterial District Judge
KATHERINE E. CONNER AND
CHRISTOPHER C. CONNER
Landlord
V.
GISELA GRAMMEL,
Tenant
GISELA GRAMMEL,
Tenant
V.
KATHERINE E. CONNER AND
CHRISTOPHER C. CONNER
Landlord
WOO"
District Court 09-3-04
LT-0264-09
District Court 09-3-04
LT-0264-09-CC-001
SUMMARY OF FACTS
The parties entered into a written lease agreement in March 2007 for the rental
of a residential property, which had been Landlord's family homestead. The agreement
called for monthly rent of $1,750.00 with a security of $1,750.00 and a 10% late fee if
rent not paid by the 5T" day of the month. In March 2008 the lease was extended until
1 April 2009. In that April Landlord agreed to temporarily take $1,650.00 in rent
payable in weekly installments without extending the lease again. A "pay and stay"
type notice to vacate was sent by Landlord on 18 April 2009. A review of the rental
accounting shows outstanding rent in April of $650.00, together with $1,750.00 as a
holdover tenancy (unjust detention) for May, Landlord also paid trash and sewer of
$175.35. Late fees on the lease from November 2008 totaled $1,215.00 at $175.00 per
month except April at $165.00.
Tenant does not dispute not paying the rent but seeks a counter claim set off for
"false advertising of the property," breach in the required Landlord maintenance of the
property and improper entry upon the property when performing Landlord
maintenance. The false advertising claim is based on the newspaper listing of the
property with a barn; however, the barn was subsequently leased in November 2008 to
a neighbor (Zimmerman) for horses.' Tenant seeks a $300.00 per month reduction in
rent from November for this "false advertising." The combined last issue of Tenant
involves maintenance, most of which is left for an appropriate case on damage to the
1 The genesis of how the horses came to the barn is also disputed but it is not germane here unless they
were Tenant's, which would give rise to notice and security deposit issues under the lease.
real property.2 The narrow issue for possessory purposes focuses on the implied
warranty of habitability.
DISCUSSION
The burden in every civil case is on a plaintiff to show that a defendant has
breached an owed duty that has resulted in measurable damages. In this case there
are two plaintiffs' claims to consider. The duty for each claim is found in the terms of
the lease and the Landlord Tenant Law. In reviewing Landlord's case, the lease and the
oral modification of the parties show that Tenant was to pay rent and utilities that are
now outstanding. All combine to a rent in arrears of $2,575.35 (rent/utilities/unjust
detention) together with late fees of $1,215.00.
Tenant's first set off claim is for a deceptive business practice of falsely
advertising the property, which is not supported by the facts. The property does indeed
have a barn and the lease requires certain specific action by Tenant if she should seek
to use it as part of the lease, which Tenant did not. Thus, there is nothing false about
the ad or the lease.
The second set off claim is for violation of the implied warranty of habitability. A
tenant finding oneself in an uninhabitable place can leave, this Tenant did not.
Alternatively, the repairs can be made and deducted from the rental payment; this
Tenant again did not repair so there is no reduction. At the Court of Common Pleas,
Tenant could have brought the costlier action for specific performance or declaratory
judgment. In all of these options notice to Landlord is required.
The logical mind would find that since the property was uninhabitable the Tenant
would have moved and Landlord would be responsible for out of pocket cost of the
breach. Tenant did not move when these habitability issues arose; however, the law
also provides for partial habitability. The facts do not show that Tenant had to vacate
unusable rooms, spend monies on treating the purported issues or had adverse health
issues caused by the uninhabitability. The facts shown do not rise to the level of a
breach but rather are typical of existing and addressable conditions with a home of this
age and character. There is no shown breach by Tenant upon which to support a set off
judgment.
In such a case it is suggested to both parties to take pictures and have witnesses capable of identifying
cause of damage. The photos shown to the Court noted that the ceiling issue was caused by a "leak in
roof flashing". While a representative photo, the photo and caption are not sufficient to show the source
of damage and then be able to trace back responsibility for repair in the lease. In this instance someone
with knowledge, perhaps an experienced contractor, would need to identify and explain the damage
source that would then be attributed to party responsibility via the lease.
?X
The net judgment is for Landlord in the above amounts plus the cost of this
action without any set off for Tenant. All parties have previously been advised of their
appeal rights and any original exhibits have been returned to the presenting party.
By the Court,
15 May 2009
Date Thomas A. Pla ey M.D.J.
ED
2M ?'A 22 t r?
(This proof of
r'9 , I(Domestic Mail Only; No Insurance Coverage Provided)
C3
• delivery information • ••
M
F
S E
Ln "WrM
OM Postage $ 40.44 00
Q'
Certified Fee $2.80 03
rl Postmark
O Return Reoeipt Fee $2.30 Here
C3 (Endorsement Required)
O Restrioled Delivery Fee
O (Endorsement Required) $0.00
q Toted Postage & Fees $ =S5,54 05!29!2009
O
t To?
COMMONWEALTH OF 6%NNSYLVANIA
COUNTY OF Gt t:ke-I"/':L A,oC ; ss
AFFIDAVIT- I hereby (vow) (afiinn) then l served
17
C N
p
C=
.
.sa ry
C-
C=
-a,
M"r7
- t -?-3 C?'3
-{_, C3
?r
--
.?
1 FILE COMPLAINT
tice of appeal. Check applicable boxes.)
a copy of the Nofte of Appeal, Calmmon Pleas 01-JU'fd, upw the District Justice designated therein on
(data of service) 20 . 7Vb5?d?e ce L3 by (certified) (registered) mail,
serwW* reoW ? hereto, and upon the WWI", #AM) hn ?' on
20r4_ ? by persondl seirviot by (certified) (registered) mail,
senoeei%c-g aftched hereto.
(SWORN ,FIRME ) RIBED BE E
THIS DAY t* OW& d-•
Signature ofafBant
Signature of official befo 0 ! merle
v Anri oA07?r
rVe of official
My commission expies an ?- .20_10
_• 9AI
PROTMO :' IIC
CARUSLE CUM COURT OUSL
MY COMMISSI rJGIRY 4, 20.10
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Katherene E.H. Conner and Christopher C. Conner,
Plaintiffs
v.
Gisela Grammel
Defendant
NOTICE TO PLEAD:
09-3290 Civil
You are hereby notified that you are required to respond to the within
captioned complaint within twenty (20) days of service or judgment may be
entered against you.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Katherene E. H. Conner and Christopher C. Conner,
Plaintiffs
09-3290 Civil
v.
Gisela Grammel,
Defendant
Complaint
AND NOW come the Plaintiffs Katherene E. H. Conner and Christopher C.
Conner, who file this complaint and in support thereof avers the following:
1. Plaintiffs are the owner of a residential property located at 28 Dapp Lane
Mechanicsburg, Pa 17055, Cumberland County, Pa.
2. Defendant is Gisela Grammel, last known address provided as 122 East
Old Mill Road, Camp Hill, Pa ,Cumberland County, Pa.
3. Plaintiff and Defendant entered into a written residential lease agreement
on March 1, 2007; the lease agreement is attached to this complaint and
incorporated herein.
4. Defendant lived in the property at 28 Dapp Lane until evicted by order of
District Justice Placey on May 15, 2009.
5. Defendant violated the lease agreement by, inter alia, failing to timely
pay rent beginning in November of 2008.
6. Plaintiffs provided Defendant with numerous opportunities to satisfy
her rent obligations; on Apri122, 2009 Plaintiff's gave Defendant
notice pursuant to the lease agreement to pay rent or vacate the property.
7. The amount of rent owed by Defendant to Plaintiff for April and May
2009 is $2400.00.
8. The amount of late fees owed by Defendant to Plaintiff is $1225.00.
9. Plaintiffs paid utility bills that are the responsibility of the Defendant.
10. Defendant vacated the property on or about June 5, 2009; however, the
property is in a substantial state of disrepair and could not be re leased;
the amount of rent owed for June 2009 is $1750.00.
11. Inspection of the property was scheduled for June 6th 2009; Defendant
did not appear.
12. The damage to the property includes without limitation the following:
a. numerous stains to the carpet which can not be removed
necessitating replacement of the carpet in the living room,
dining room, kitchen, bedrooms.
b. numerous stains in the sinks and toilets which require extensive
cleaning or replacement.
c. replacement of screens in the porch.
d. cleaning of stove and range top.
e. cleaning of bathrooms and walls.
f. repair of wall stained by Clorox and mildew.
g. extensive removal of weeds and overgrown shrubbery that was the
responsibility of Defendant as tenant.
h. re painting of entry foyer.
i. extensive cleaning of interior of property.
j. removal of trash left by Defendant upon vacating the property.
k. replacement and re keying of locks because Defendant did not
return keys.
1. replacement of broken window.
m. replacement of light fixture in bedroom.
n. re filling oil tank which was required to be filled upon vacating
property.
o. maintenance of furnace and air conditioning system.
13. Defendant did not leave the property in a condition required by the
terms of the lease and the property can not be re leased until the repairs
are completed.
14. The amount in dispute is within arbitration limits.
Wherefore, Plaintiffs demand judgment in their favor in the amount of
$10,000.00 together with interest and costs.
Respectfully Submitted,
~~~~~
at erene E. " .Canner
Christopher C. Conner
RESIDENTIAL LEASE AGREEMENT
This LEASE AGREEMENT, dated this day of Mazch 2007, is
between GISELA GR:AMMEL, hereninafter Tenant, and CHRISTOPHER C. AND
KATHERENE CONNER, hereinafter Landlord. Landlord agrees to rent to Tenant the
following property: 28 Dapp Lane ,Mechanicsburg, Pennsylvania 17050.
This lease begins on March , 2007 and ends on March 1, 2008.
The property will be used as a residence only.
This lease will automatically renew for a term of sixty days at the Ending Date,
unless Tenant gives sixty days written notice before Ending Date or before the end of
any renewal term, OR, the Landlord gives sixty days notice before Ending Date or
before the end of the renewal term.
RENT, SECURITY DEPOSIT ,ADVANCE PAYMENT:
The tenant agrees to pay rent in the amount of $1750.00 per month. Monthly
rent is due by the fast day of every month. A late charge of 10% or $175.00 will be
chazged if the rent is more than five (5) days late. Rental payments may be made pay-
able by check or money order to Katherene Conner , 1772 Kendall Drive, Mechanicsburg
Pennsylvania 17055.
Deposit prior to Tenant taking possession: First months rent of $1750.00 and
security deposit of $1750.00., receipt of which is acknowledged. In addition, Tenant
agrees to pay sixth months rent (10,500.00) on or before Mazch 16, 2007 for the last
six months of the Lease. Monthly payments of $1750.00 to commence on April 1, 2007.
Landlord may withhold from the security-:deposit an amount reasonably necessary to
cover the tenant defaults including without limitation damages to the dwelling,
extraordinary cleaning costs following tenants departure,unpaidrent and other accrued
and unpaid costs. Tenant will be responsible for having the carpets professionally cleaned
before moving out and providing a receipt from the carpet cleaning service.
UTILITIES AND SERVICES:
Landlord will pay for the following:
Heater maintenance contract if applicable.
Sewer maintenance.
Lawn and shrubbery caze of paddock, as necessary, and front field.
Tenant will pay for the following in addition to monthly rental:
Electricity
Cold water (well)
Hot Water
Heat (Oil- Upon leaving, furnace to be filled to capacity at time of move in)
Snow Removal- Landlord will bill shared cost
Trash Removal
Sewage costs- Landlord will bill (quarterly)
Telephone, cable or satellite and pest control.
Annual cleaning of heating and cooling systems after first full
year of lease.
APPLIANCES AND PERSONAL PROPERTY INCLUDED WITH PROPERTY:
The appliance listed below are provided for the Tenant's use. Landlord is responsible for
repair of these items in excess of $100.00 and replacement of items beyond repair.
Tenant must tell landlord if any of these items are not working properly.
Refrigerator, Washer, Dryer, Range/Stove, Dishwasher, Garbage Disposal, Water
Softener.
Tenant is responsible for: replenishment of oil as needed and to fill oil tank at level
upon moving in, salt for water softener.
LEAD BASED PAINT DISCLOSURE: Landlord does not know of any lead based paint
or lead based paint hazards on the Property. Landlord has no reports or records of lead
based paint or lead based paint hazards on the Property.
TENANT'S CARE OF PROPERTY:
Tenant has inspected the property and its contents and agrees that they are in
satisfactory working order, as are the electrical, plumbing, and heating systems.
Tenant, Tenant's family and guests agree to keep the property clean and safe, maintain
lawn and shrubs except as set forth above, get rid of all trash, garbage and any other
waste materials as required by Landlord and the law; use care when using any of the
electrical, plumbing, ventilation or other facilities or appliances on the Property; tell
Landlord immediately of any repairs needed. Landlord does not have to repair any
damage caused by Tenant's willful, careless or unreasonable behavior. Tenant will
not keep any flammable materials on the Property, willfully destroy or deface any part of
the property, disturb the peace and quiet of other tenants, make changes to the property,
such as painting or remodeling without the written permission of Landlord. Tenant
understands that any changes or improvements to the property belong to Landlord.
Tenant will pay to repair any item in or on the Property that cost less than $100.00.
Tenant agrees to be responsible for any windows which become cracked or broken
while they live there.
Tenant agrees that drain stoppages which aze caused by improper use will be the
responsibility of the tenant and will agree to pay for clearing drain pipes except those
which a plumber certifies were caused by defective plumbing, tree roots or acts of God.
Tenant agrees to keep all gutters and downspouts free and clear of debris, leaves.
Tenant agrees to maintain all smoke and fire detection devices.
Tenant agrees that no smoking will be allowed in the property, including the
house and barn .
Tenant agrees not to install additional locks or security devices without prior written
approval from Landlord; locks may not be changed without prior written approval
from Landlord.
Under no circumstances, are any supplemental heating devices to be used including
without limitation kerosene heaters, wood stoves, space heaters, gas heaters.
Tenant's use of fireplace is permitted but must be maintained and cleaned by Tenant.
LANDLORD' S MAINTENANCE OF PROPERTY:
Landlord will keep the Properly and common azeas in reasonable condition. Landlord
will keep the structural parts of the Property in good working order, including the ceilings
steps, roof, porches, floors, windows, walls, doors. Landlord will keep all heating and
cooling systems in good working order and maintain appliances as set forth herein.
PETS:
Pets are allowed only upon notice to the Landlord and as agreed to by the Landlord. In
the event, the Tenant elects to have pets, Landlord may request a pet deposit of $1,000.00
to be paid within 30 days of notice of pets and may set forth different requirements for
keeping and maintaining pets.
LANDLORD'S RIGHT TO ENTER THE PROPERTY:
Tenant agrees to let Landlord or Landlord representatives enter the property upon
reasonable notice to Tenant and at reasonable times to inspect, repair or show the
Properly. Landlord will give tenant at least 24 hours notice unless otherwise agreed,
of the date time and reason for the visit. In case of emergency, Landlord may enter the
properly without notice. If Tenant is not there, Landlord will tell Tenant who was there
and why within 24 hours of the visit.
SALE OF PROPERTY, SUB-DIVISION OF PROPERTY:
Tenant understands that Landlord may elect to sub- divide the properly. Sub-division of
the property will not affect the dwelling. If Landlord and Tenan# agree at the end of the
first year of the term of the lease that Tenant will purchase the property and if the
Landlord and Tenant agree to use a real estate broker, the parties agree to use Walker
Realty subject to agreement of purchase price, terms of commission and other incidents
of the sale of the property.
If property is sold to a third party, Landlord agrees to give notice in writing
to the tenant and to forward security deposit to new owner and provide name
name and address of new owner., In the event of sale of properly to third person,
Landlord will have no further obligation under Lease.
SUBLEASING AND TRANSFER:
Tenant may not sublease or rent property to another person without prior written
notice from Landlord, which Landlord will not unreasonably withhold.
VIOLATION OF LEASE AGREEMENT:
Violation of any term of this Agreement will be cause for eviction. Tenant violates this
lease agreement if Tenant does not pay rent or other charges that are the responsibility of
Tenant; leaves property permanently before the end of the Lease; fails to abide by any
other terms of the Lease. If Tenant violates this Lease by not paying rent, Landlord
cannot evict Tenant without giving written notice; Tenant agrees that five days written
notice is sufficient and if Tenant has not vacated the property by the end of the sixth day
after written notice, Landlord can file a lawsuit and pursue all other legal remedies to
evict Tenant.
INSURANCE, DAMAGES:
Landlord maintains property insurance on the property and dwelling. LANDLORD' S
INSURANCE DOES NOT COVER TENANT, TENANT'S PROPERTY OR GUEST'S.
TENANT IS RESPONSIBLE FOR FIRE AND LIABILITY INSURANCE FOR
TENANT, TENANT' S PROPERTY AND GUESTS..
Landlord is not responsible for any injury or damage that occurs on the Property and
Tenant agrees to pay any loss or claim, including attorney's fees that results from
damage to the property or injury.
Landlord is responsible for damages caused by Landlord's failure to abide by the terms
of the Lease.
Tenant is responsible for any loss to Landlord that Tenant, Tenant's family or guests
cause. Tenant agrees to indemnify Landlord for any loss ,injury or damage to any
person or property caused by Tenant, Tenant's family or guests.
CAPTIONS:
The captions in this Lease are meant only for the convenience of reading the Lease.
ENTIRE AGREEMENT:
This lease agreement is the entire agreement between Tenant and Landlord.
%,
;,~ ,.~~.
t --~. TENANT
seta amme#
:~'"
LORD
C topher C. and Kathe ne E. Conner
ADDENDUM TO RESIDENTIAL LEASE
Whereas, the parties entered into a Residential Lease effective March 1, 2007 for one
year.
Whereas, the parties are extending the lease for one year from April 1, 2008 until April 1,
2009.
The rent for the new term of the lease will remain at $1750.00 per month due on the
first day of every month. The tenant will pay a late charge of 10% or 175.00 if the rent
is more than five days late.
All other terms of the residential lease will remain in full force and effect.
VERIFICATION
I verify that the statements made in this Complaint are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A.
Section 4904 relating to unsworn falsification to authorities.
Date:w 0`3
therene E. H. Conner, Plaintiff
Date: $ ~ 1 ~/-L~/1
Christ pher C. Conner, Plaintiff
CERTIFICATE OF SERVICE
I certify that I have this date served a copy of the within captioned
complaint on Defendant by first class mail to the following address:
Gisela Grammel
122 East Old Mill Road
Camp Hill Pa 17011
Date: ~ ~
K therene E. H. Conner
f
..
S~ ~ ~
kf 0 4 k; A14 ?? Ul^ 4AlV r
G pi l C hrh Liver
Plaintiff
AtC0"o
r!-rM i
Defendant
In The Court of Common Pleas of Cumberland
County, Pennsylvania No.-0j--
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.
Signature
Name (Chairman)
Law Firm
Address
City, Zip
C A' PF - ?P?.
AAAIW _ , J,?V ?.
(/ -
Signature Signa ire A A
Name
l
Law Firm vi l,
q c 4?
Address
C
City, Zip
Alu Sa Pddfff
Name' /10.& d
QW0101 kiy[slalLtC
Law Firm
?aoo Mau BO M 0
Address •r, Md Boof, &tv 5?1
W I NN Fbf 17615
City, Zip
/019??lr !8q s5 ??.
Award r?
We, the undersigned arbitrators, having been duly appointed and sworn (or armed), make the 111tak,{
following : (Note: If damages for delay are awarded, t ey shall be separately stated.) ??1
aw 4p$?Iaa,D s as?
(tue fen t.10.Ve eeg . ve.im1a& PY* 0 PeS, UN U MS-1 F?M is
. Arbitrator, dissents. (Insert name if applicable.)
Date of Hearing: 712V 0
Date of Award:
1 k (Chairman)
-AAR,
Notice oftotry of Award
Now, the 1 4',day of _ 20 , at 1;,2 ?j_, ?--.M., the above award was
entered upon the docket and notize thereoftwen. by avail to the parties or their attorneys.
Arbitrators' compensation to be paid 4j)on appeal: $ S ?LS•
B
lau
Pro onotary Deputy
OF THF? PROTHONOTARY
2010 NOV 17 PM I : 24
CUMBERLAND COUNTY
PENNSYLVANIA
aY.oE,r 1??,.?
r
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Katherene E.H. Conner and Christopher C. Conner
Plaintiffs
V.
Gisela Grammel
Defendant
PRAECIPE TO ENTER JUDGMENT
To The Prothonotary:
Please enter judgment in the above captioned case in the amount of
$8102.66.
Respectfully Submitted,
c:
p w -4o
co
erene E. H. Conner
Plaintiff
1772 Kendall Drive
Mechanicsburg, Pa 17055
717 697-9224
l??sh
jl ?s3 67 y
09-3290 Civil
c
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Katherene E. H. Conner and Christopher C. Conner
Plaintiffs
v.
: 09-3290 Civil
Gisela Grammel
Defendant
NOTICE OF ENTRY OF JUDGMENT OF AWARD OF ARBITRATORS
Judgment is entered in the above captioned matter in the amount of
$8,102.66.
-- /) ?AA
Prothonotary
Date:
r
CERTIFICATE OF SERVICE
I certify that I have this day mailed a copy of the Praecipe to Enter Judgment and
Notice of Entry of Judgment by first class mail to the following:
Gisela Grammel
122 East Old Mill Road
Camp Hill, Pa 17011
74
tE. H. Conner
Plaintiff
1772 Kendall Drive
Mehcanicsburg, Pa 17055
717 697-9224
Date:
In the Court of Common Pleas
Cumberland County
Katherene E. H. Conner and Christopher C. Conner,
Plaintiffs
v. 09-3290-03-'r
Gisela Grammel
Defendant
PRAECIPE FOR NOTICE OF INTENT TO ATTACH WAGES
Pursuant to Pa. R.C.P. Rule 3311
To The Prothonotary:
Issue a Notice of Intent to Attach wages in the above captioned matter
(1) X against Gisela Grammel, defendant,
(2) _ against Empire Kosher Poultry, employer of the Defendant.
Date: Pel /y
geriAitm,
Katherene E. H. Conner
Judgment Creditor
1772 Kendall Drive
Mechanicsburg, Pa 17055
717 697 9224
4a_8. so pciplW
call
P/31004041
In the Court of Common Pleas
Cumberland County
Katherene E. H. Conner and Christopher C. Conner,
Plaintiffs
v.
Gisela Grammel
Defendant
: 09-3290
DATE OF SERVICE OF THIS NOTICE:
(date to be inserted by Sheriff)
A judgment has been entered against you in court for nonpayment of rent
for, or damage to, residential property that you rented. The judgment creditor -
landlord has begun proceedings to attach 10% of your net wages, salary, and
commissions for each pay period until the judgment is satisfied.
The following exception will prevent your wages from being attached:
Poverty Guidelines- Your wages may not be attached if your net income is
below the poverty income guidelines as provided annually by the Federal
Department of Health and Human Services or if the amount of the attachment would
cause your net income to fall below the poverty income guidelines. A copy of the
guidelines is attached to this notice.
If the exemption is applicable to you, you must return the claim for
exemption of wages, which is attached, to the Prothonotary within 30 days of the
date of service of this notice upon you. The date of service of this notice is set forth
above. If you return the form claiming this exemption within 30 days, your wages
will not be attached without subsequent court approval.
There may be other legal grounds for opposing the wage attachment that you may
be able to raise by filing a motion with the court. For example, your wages may not
be attached if you are an abused person or victim as set forth in Section 8127(f) of
the Judicial Code when the attachment is to satisfy a judgment for physical damages
to the leased premises.
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.
Mid Penn Legal Services
401 East Louther Street
Carlisle, Pa 17013
717 -243 9400
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pa 17013
717 249 3166
2
In the Court of Common Pleas
Cumberland County
Katherene E. H. Conner and Christopher C. Conner,
Plaintiffs
v.
Gisela Grammel,
Defendant
: 09-3290
CERTIFICATION BY JUDGMENT CREDITOR -LANDLORD
PURSUANT TO RULE Pa. R.C.P. Rule 3311
I certify that
1. The plaintiff judgment creditor is
2. The defendant judgment debtor is
3. The employer garnishee is
Katherene E.H. Conner and
Christopher C. Conner
1772 Kendall Drive
Mechanicsburg, Pa 17055
Gisela Grammel
122 East Old Mill Road
Camp Hill, Pa 17011
Empire Kosher Poultry, Inc.
247 Empire Drive
Mifflintown, Pa 17059-0985
4. This judgment arises out of a residential lease for the premises at
28 Dapp Lane, Mechanicsburg Pa 17055.
5. a. The amount of the judgment is $8,102.66 plus costs. (Certified copy attached
and incorporated by reference)
b. The security deposit in the amount of $1950.00 was held by the judgment
creditor, landlord. The security deposit has been already applied to the
outstanding non paid rent.
c. The amount of $ 0.00 has been paid toward the satisfaction of the judgment.
6. This praecipe is filed within five years of the date of the original judgment.
Cro
G)
CD
7. The judgment was entered in a civil action brought in the court of common pleas
following appeal by the Plaintiff from a magisterial district. A certified copy of the
judgment is attached hereto and incorporated herein by reference.
1
I certify that the statements made in this Certification are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.
C.S.A. 4904 relating to unsworn falsification to authorities.
Ka herene E. H. Conner
Judgment Creditor -Landlord
2
ktgAt44 CH- 4,vllir
24ri kpi4ef e, C P hff
a,-54/4
Defendant
In The Court of Common Pleas of Cumberland
County, Pennsylvania No. 0 I - _Ivry
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.
Signature
Name (Chairman)
Law Firm
Address
City, Zip
CPO i4 A -1;A41
Name
aitati
Law Firm
Wejuil
A, V(041
Address
City,
Ssa .A(Q1
Ivatel l okIv) , LIL
Law Firm
1. Du) Wainu - k1ThY i
Address 1410 Tiob (VP P 31
bilitPA17D15
Zip City, Zip
I0`LI
Award 1 B9 SS
We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the j,/gal t°
followingaw d: (Note: If damages for de y are awarded, ey shall be separately stated.)
we LwJ TQ ?►al tJfF WW1 411 to a .(a nrau6oS pcls-
We Yen t,1 ees. YPim nt- 4f lees, OA �. t C 1Y10/1 IS
1bTfaden ifIC S-e'iifl aS11-,
Ilt 6 r 4 (irt U.)01 Ai1/..1 lin�4e%4114.
Date of Hearing: 10111/1712010 0
Date of Award:
TRUE COPY FROM RECORD
In Testimony..wnereof, I here unto set my hand
and trie� sea,loof si?.id Court at Carlisle, Pa.
This X1166 ` d�rY of V { 20
. Arbitrator, dissents. (Insert name if applicable.)
Notici
of Award
Now, the / y o • - . l ; Zo i4f3- , at , ? .M., the above award was
entered upon the docket and notiz e thereorgic-en by mail to the parties or their attorneys.
Arbitrators' compensation to be paid upon appeal:
ri}r� t ►p.a171
Reports
Data & Tools
Policy Offices. Key Initiatives
2014 Poverty Guidelines
One Version of the [t1.5.1 Federal Poverty Measure
About
[ Federal Register Notice. lanuary 24. 2013 — Full text]
[ Prior Poverty Guidelines and Federal Rea/stet References Since 1982 ]
[ Frequently Asked Questions (FAQs) ]
[ Further Resources on Poverty Measurement. Poverty Lines. and Their History ]
[ Computations for the 2014 Poverty Guidelines ]
The following figures are the 2014 HHS poverty guidelines which are scheduled to be published in the Federal Register on January 22,
2014, (Additional information will be posted after the guidelines are published.)
2014 POVERTY GUIDELINES FOR THE 48 CONTIGUOUS
STATES
AND THE DISTRICT OF COLUMBIA
Persons in family/household Poverty guideline
1
$11,670
2
15,730
3
19,790
4
23,850
—
5
27,910
6
31,970
7
36,030
8
40,090
For families/households with more than 8 persons, add $4,060
for each additional person.
2014 POVERTY GUIDELINES FOR ALASKA
Persons in family/household Poverty guideline
1
514,580
2
19.660
3
24,740
4
29,820
5
34,900
' 6
39,980
7
45,060
8
50,140
For families/households with more than 8 persons, add $5,080
for each additional person.
2014 POVERTY GUIDELINES FOR HAWAII
Persons in family/household Poverty guideline
1
513,420
1ROHn
3
22,760
4
27,430
5
32,100
6
36,770
7
41,440
8
46,110
For families/households with more than 8 persons, add 54,670
for each additional person.
The separate poverty guidelines for Alaska and Hawaii reflect Office of Economic Opportunity administrative practice beginning in the
1966-1970 period. Note that the poverty thresholds — the original version of the poverty measure — have never had separate
figures for Alaska and Hawaii The poverty guidelines are not defined for Puerto Rico, the U.S. Virgin Islands, American Samoa, Guam,
the Republic of the Marshall Islands, the Federated States of Micronesia, the Commonwealth of the Northern Mariana Islands, and
Palau. In cases in which a Federal program using the poverty guidelines serves any of those jurisdictions, the Federal office which
administers the program is responsible for deciding whether to use the contiguous -states -and -D.C. guidelines for those jurisdictions
or to follow some other procedure.
The poverty guidelines apply to both aged and non -aged units. The guidelines have never had an aged/non-aged distinction; only
the Census Bureau (statistical) poverty thresholds have separate figures for aged and non -aged one-person and two -person units.
Programs using the guidelines (or percentage multiples of the guidelines — for instance, 125 percent or 185 percent of the
guidelines) in determining eligibility include Head Start, the Supplemental Nutition Assistance Program (SNAP), the National School
Lunch Program, the Low -Income Home Energy Assistance Program, and the Children's Health Insurance Program. Note that in
general, cash public assistance programs (Temporary Assistance for Needy Families and Supplemental Security income) do NOT use
the poverty guidelines in determining eligibility. The Earned Income Tax Credit program also does NOT use the poverty guidelines to
determine eligibility. For a more detailed list:of programs that do and don't use the guidelines, see the Frequently Asked Questions
(FAQs).
The poverty guidelines (unlike the poverty thresholds) are designated by the year in which they are issued. For instance, the
guidelines issued in January 2014 are designated the 2014 poverty guidelines. However, the 2014 HHS poverty guidelines only reflect
price changes through calendar year 2013; accordingly, they are approximately equal to the Census Bureau poverty thresholds for
calendar year 2013. (The 2013 thresholds are expected to be issued in final form in September 2014; a preliminary version of the
2013 thresholds is now available from the Census Bureau.)
The poverty guidelines may be formally referenced as "the poverty guidelines updated periodically in the Federal Register by the U.S.
Department of Health and Human Services under the authority of 42 U.S.C. 9902(2)."
Go to Further Resources on Poverty Measurement. Poverty Lines. and Their History
Go to Frequently Asked Questions (FAQs)
Return to the main Poverty Guidelines. Research. and Measurement page.
ASPE Home I HHS Home I Ouestions? I Contacting HHS I Accessibility I Privacy Policy I FOIA I Plain Writing Act I No Fear Act I Disdaimersl
The White House I USA,gov I Flu.gov I Viewers & PlayerslHHS Digital Strategy
U.S. Department of Health & Human Services — 200 Independence Avenue, S.W. — Washington, D.C. 20201
In the Court of Common Pleas
Cumberland County
Katherene E. H. Conner and Christopher C. Conner,
Plaintiffs
v. : 09-3290
Gisela Grammel
Defendant
NOTICE OF CLAIM OF EXEMPTION OF WAGES FROM ATTACHMENT
To The above - named Plaintiffs:
The Defendant in the above -captioned matter has filed a claim for
exemption from attachment of his or her wages, salary or commissions. A copy of
the claim is attached. If you wish to challenge the claim for exemption, you should
file with the court a motion setting forth facts which show that the defendant's net
incomes is not below the Federal Department of Health and Human Services poverty
guidelines or that the attachment will not cause the defendant's net income to fall
below those poverty income guidelines.
Date:
Prothonotary
1
In the Court of Common Pleas
Cumberland County
Katherene E. H. Conner and Christopher C. Conner,
Plaintiffs
v. : 09-3290
Gisela Grammel
Defendant
CLAIM FOR EXEMPTION FROM WAGE ATTACHMENT
NOTICE
This Claim for Exemption must be filed with the Prothonotary of the Court
within 30 days of service upon you of the Notice of Intent to Attach Wages.
I, the above named Defendant, claim exemption of my wages, salary, or commissions
from attachment on the following grounds:
_My net monthly income is below the poverty income guidelines as
provided by the Federal Department of Health and Human Services
OR
_The amount of wages to be attached would place my net income below the
poverty income guidelines as provided annually by the Federal Department of
Health and Human Services.
I have dependents
(Number)
My net monthly income is $
(Net monthly income is your total monthly wages less (1) any support payments
made to the court, (2) federal, state and local income taxes, 3) F.I.C.A. payments and
non -voluntary retirement payments, (4) union dues and (5) health insurance
premiums.)
I certify that the statements made in this Claim for Exemption are true and correct. I
understand that false statements herein are made subject to the penalties of 18
Pa.C.S.A. 4904, relating to unsworn falsification to authorities.
1
Date:
Defendant
This claim shall be delivered or mailed to:
Office of the Prothonotary
Court of Common Pleas
Cumberland Count Court of Common Pleas
Cumberland County Courthouse
1 Courthouse Avenue
Carlisle, Pa 17013
2
In the Court of Common Pleas
Cumberland County
Katherene E. H. Conner and Christopher C. Conner,
Plaintiffs,
v. : 09-3290
Gisela Grammel,
Defendant
WRIT OF ATTACHMENT OF WAGES, SALARY COMMISSION
Commonwealth of Pennsylvania
County of Cumberland
To: Empire Kosher Poultry, Inc.,
247 Empire Drive
Mifflintown, Pa. 17059-0985
You have been identified as the employer of the above-named defendant.
You are directed to withhold the wages, salary and commissions of the defendant in
your possession to satisfy the judgment against the defendant.
You are notified of the following:
1. An attachment of wages, salary and commissions has been issued;
2. You are ordered to withhold from the wages, salary and commissions of
the defendant an amount per pay period, which does not exceed ten (10)
percent of the defendant.
Net wages are all wages paid less only the following items: any support
payments made to the court, federal state and local income taxes, FICA
payments and non voluntary retirement payments, union dues and health
insurance premiums.
3. The total amount attached is $ 8102.66 plus costs and the withholding
must continue until the amount of the attachment is satisfied.
4. The attached wages shall be sent to the Prothonotary of the court of
common pleas within 15 days from the close of the last pay period of each
month. The check must :
a. contain the name of the employee whose wages are being
attached.
b. be made payable to the Prothonotary, and
c. be sent to :
Prothonotary
1
Cumberland County Court of Common Pleas
Office of the Prothonotary
One Courthouse Square
Carlisle, Pa 17014
717-240- 6195
Attention:
Wage Attachment Remittance
5. You are entitled to deduct each pay period from the money collected from
the defendant employee the costs incurred from the extra bookkeeping
necessary to record the transaction, not exceeding $5.00 of the amount of
money so collected.
6. By law, you may not take any adverse action against the defendant
because his or her wages, salary or commissions have been attached.
7. You shall send the following notice to the Prothonotary if the defendant
has never been or is no longer an employee:
I have received a Writ of Attachment in the following case:
Katherene E. H. Conner and Christopher C. Conner v. Gisela Grammel
Plaintiffs Defendant
Case No. 09-3290
The following person, has never been (_) or
is no longer (_)
Date:
Employer:
Seal of the Court
Prothonotary
By:
Deputy
2
I certify that the statements made in this Notice of Intent to Attach Wages and
Certification by Judgment Creditor are true and correct. I understand that false
statements herein are made subject to the penalties of 18 P.A.C.S. Section 4904 relating
to unsworn falsification to authorities.
Date:
atherene E. H. Conner
Judgment Creditor
1772 Kendall Drive
Mechanicsburg, Pa 17055
717 697 9224
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ,1_!..i.I.,'-ijf:HUL
Sheriff ::..:F THE P 0 T ii OH 0 TAW,'
, 00 et cumber
Jody S Smith .„.. It
Chief Deputy r A., 3'„,,,.,.,,,, 23114 SEP 1 :
2 PH 3 148
Richard W Stewart CUMBERLAND COUNTY
Solicitor OFFICE OF ME 4,AtERIFF PENNSYLVANIA
Katherene E.H. Conner (et al.)
vs.
Gisela Grammel
Case Number
2009-3290
SHERIFF'S RETURN OF SERVICE
09/08/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Gisela Grammel, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Notice of Intent to Attach Wages as "Not
Found" at 122 Old Mill Road, Lower Allen, Camp Hill, PA 17011. Deputies were advised by current
resident that he has lived at this address for four years and that the defendant was a previous tenant.
SHERIFF COST: $67.39 SO ANSWERS,
September 08, 2014 RONNY R ANDERSON, SHERIFF
to) CounlySuAo Shoot., TelE.,osoft. Inc,