HomeMy WebLinkAbout09-7464LIBERTY HOLDING COMPANY
A Partnership
Plaintiffs
vs.
KIRSTIN M. SWEIGARD d/b/a
INSTANT TAX SERVICE
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. Oq - g4U4 CIVIL
COMPLAINT
1. LIBERTY HOLDING COMPANY is a Pennsylvania Partnership with its principal office
located at 1255 Claremont Road, Carlisle, Cumberland County, Pennsylvania and a mailing
address of P.O. Box 158, Carlisle, PA 17013.
2. Defendant KIRSTIN M. SWEIGARD d/b/a INSTANT TAX SERVICE, an S. Corporation, is
a sui juris individual with an address of 1031 W. Trindle Road, Mechanicsburg, Cumberland
County, Pennsylvania 17055.
3. Plaintiffs and Defendants entered into a rental agreement for 2 South Hanover Street, Carlisle,
Pennsylvania dated November 21, 2008, a copy of which is attached hereto, incorporated by
reference and marked Exhibit "A".
4. The three (3) year rental agreement provided for initial monthly payments of $1,300 per
month beginning December 15, 2008, with escalations in rent yearly.
5. The rental agreement provided for late charges for payments thirty (30) days in arrears.
6. The rental agreement provided for attorney's collection fees in the amount of fifteen (15%)
percent.
7. Defendant has failed to make any rental payments since March, 2009.
8. As a consequence of Defendant's failure to pay rent, the balance due an owing under the
rental agreement up to the date of filing is $9,750.00, with additional amounts due for late fees.
A copy of the statement of rent is attached hereto, incorporated by reference and marked Exhibit
«B»
9. The amounts due under the Rental Agreement remain unpaid despite repeated requests for
payment.
10. The subject premises remains vacant despite efforts to find a new tenant.
11. The rend due and owing continues to accrue at the amount of $1,300.00 per month for 2009
and will increase to $1,350.00 per month for 2010.
NOW THEREFORE,, Plaintiffs pray the Court award Plaintiff damages in excess of
$11,000.00 plus additional accrued rent, interest, attorney's fees and costs in the above-
mentioned matter.
Respectfully submitted,
William A. Duncan, Esquire
Supreme Court ID 22080
1 Irvine Row, Carlisle, PA 17013
717-249-7780
717-249-7800 fax
Dated:
VERIFICATION
The undersigned, having read the attached Complaint, hereby verifies that the facts set
forth therein are true and correct to the best of his knowledge, information and belief.
This verification is made subject to the penalties of 18 Pa.C.S.section 4904 pertaining to
unsworn falsification to authorities.
Dated:
J. Michael Adler, Partner
Liberty Holding Company
AGREEMENT
THIS LEASE AGREEMENT dated this 21St day of November , 2008.
between Liberty Holding Co., with offices located at P.O. Box 158 Carlisle PA 17013
Hereinafter referred to as "Landlord,"
and
Kirstin M. Sweigard , with Residence located at 1031 W Trindle Rd,
Mechanicsburg, PA 17055 Hereinafter referred to as "Tenant " and operating as
S ?-
WITNESSETH:
The landlord does hereby lease and demise to the Tenant, the premises situated at 2 South
HANOVER STREET BOROUGH OF CARLISLE CUMBERLAND COUNTY
PENNSYLVANIA 17013. All for use in the conduct ofd a?,-). For the term of 3
Years, beginning on the 15th Day of, December, 2008, and expiring on the 31st Day of
December, 2011, as rent for said premises, Tenant agrees to pay to Landlord the sum of L650.00
dollars and 36 Monthly installments payable in advance without demand at $ 1,300.00 each month
of the First Year; $ 1,350.00 each month of the Second Year, and $ 1,400.00 each month of the
Third Year Prior to the first day of each month. The parties hereto, intending to be legally bound
hereby, further covenant and agree with each other as follow:
Make payment payable to: Liberty Holding Co.
P.O. Box 158
Carlisle, PA 17013
Late Charge: If payment is not received by the Last Business Day of the month, there is a late charge
imposed of. 5% on the 1St Late Fee: $ 65.00
10% on the 5th Late Fee: $130.00
PAYMENT OF RENT
(1) All rents are payable in advance, without set-off or deduction of any kind, prior to the first
day of each calendar month of the tenancy at the office of the Landlord, or such other place as the
Landlord may from time to time designate, all without relief from valuation and appraisement laws, and
at the expiration of the term Tenant will peacefully yield up to the Landlord said premises in good
order, repair, and broom clean, less reasonable wear and tear
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REPAIRS ORDINANCES AND VIOLATIONS
(2) The Tenant covenants: that no waste or damage shall be committed upon or to the said
demised premises; that the premises shall be used for only the purpose hereinabove stated; that said
premises shall not be used for any unlawful purpose and no violation of law or ordinance or duly
constituted authority shall be committed thereon. Throughout said term, Tenant shall; take good care of
the demised premises, fixtures and appurtenances and all alterations, additions and improvements to
same; damage and loss from acts of God excepted; make all repairs in and about the same necessary to
preserve them in good order and condition, which repairs shall be equal in quality to the original work;
promptly pay the expense of such repairs; suffer no waste or injury to demised premises; give prompt
notice to the Landlord of any damage that may occur; execute and comply with all laws, rules, orders,
ordinances and regulations at any time
issued or in force, applicable to the demised premises or to the Tenant's use and occupancy thereof,
of the City, County, State and Federal Governments and Landlord, and of each and every department,
bureau and official thereof, and of the Board of Fire Underwriters having jurisdiction thereof. Landlord
shall keep and maintain in good order and condition the roof, exterior walls and structural portions of
the building of which the demised premises are a part.
INCREASED FIRE INSURANCE RATE
(3) Tenant shall not do, suffer to be done, or keep, or suffer to be kept anything in, upon or
about the demised premises which will contravene Landlord's policies insuring against loss or damage
by fire or other hazards, including but not limited to public liability, or which will prevent Landlord
from procuring such policies in companies acceptable to Landlord; and if anything to be done, omitted
to be done or suffered to be done, by Tenant or kept in, upon or about the premises shall cause the rate
of fire or other insurance on the premises or other property of Landlord in companies acceptable to
Landlord to be increased beyond the minimum rate from time to time applicable to the demised
premises for use for the purposes permitted under this lease or which such other property for the use of
uses made thereof. Tenant will pay the amount of such increase promptly upon Landlord's demand.
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ASSIGNMENT OR SUBLETTING
(4) Tenant expressly covenants that it will not assign, mortgage or encumber this agreement nor
under-let or suffer or permit the demised premises or any part thereof to be used by others without the
prior written consent of Landlord in each instance. Any transfer of stock amongst the shareholders or
the corporation or between the shareholders and the corporation shall not be deemed an assignment or
subletting of this agreement. Any sale, pledge or other disposition of the stock of the Tenant to a third
party of a controlling interest in the Tenant shall be deemed an assignment of this lease and therefore be
prohibited without the express written consent of Landlord, which consent shall not be unreasonably
withheld.
In the event the Landlord's written consent is given to an assignment or subletting, the
Tenant shall, nevertheless, remain liable to perform all covenants and conditions thereto and to
guarantee such performance by his assignee or sub-tenant.
BANKRUPTCY OR INSOLVENCY
(5) To more effectively secure the Landlord against loss of the rent and other payments herein
provided to be made by the Tenant, it is agreed as a further condition of this lease that the filing of any
petition in bankruptcy, insolvency or other debtor's proceedings by or against the Tenant, or the
adjudication in Bankruptcy of the Tenant or the appointment of a Receiver for Tenant by any Court
shall be deemed to constitute a breach of this lease, and thereupon without entry or other action by the
Landlord, this lease shall, at the option of Landlord, become and be terminated and notwithstanding any
other provisions of this lease, the Landlord shall forthwith upon any such termination be entitled to
recover the rent reserved in this lease for the residue of the term hereof less the fair rental value of the
premises for the residue of said term.
LITIGATION
(6) In the event the Landlord or its Agents, without fault on their part, become involved,
through or on account of the terms of this lease, or through or on account of the occupancy of the
demised premises by the Tenant, or the conduct of Tenant's business upon said demised premises, in
any controversy or litigation, the Tenant shall upon notice from Landlord to its Agents immediately
take all necessary steps to remove said Landlord's connection with or liability under such controversy
or litigation, particularly if such controversy or litigation throws a cloud or encumbrance upon the title
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of said Landlord to its property. If the Tenant believes it has a good and valid defense
aim, in such
controversy or litigation which Tenant desires to set up and maintain by and throughout cou
o
and litigation, the Tenant shall have the right to do so, provided it first executes and deliv rt procedure
ers
ttont the
Landlord an indemnity bond with surety satisfactory to Landlord, and in an amount suffie
to
discharge any and all final judgments, liens, costs, damages, expenses and obligations Landlord
whatsoever, in or arising out of the controversy or litigation involving the Landlord or its Agents,
including all costs, expenses and attorney's fees incurred by Landlord or its Agents in Agents,
interest or defending themselves in such controversy or litigation. Provided, however, protecting their
shall be required unless the claim amount exceeds $10,000.00. Tenant hereby waives, a d at no bond
agrees
lease
that it will waive, all rights to trial by jury in any and all legal proceedings arising under this
of the termination of this lease, or with respect to the demised or the use thereof. lease, out
UTILITIES
(7) The Tenant covenants to pay when due See Su lement Sheet (A) and
charges, extraordinary as well as ordinary which shall, during the term of this lease, be charged other
assessed, imposed, or grow due or payable on or on account of said premises or an a
thereof, by virtue of or under any present or future law or requirement of an
Y y governmental author PPurteauthor
or other services furnished to said premises or the occupant hereof during authority;
agrees to demand to produce and exhibit to the Landlord receipts b g said term. The Tenant
payments. The Tenant, however, may defer the payment of a tax, assessm pficials showing said
as the validity thereof shall be contested by the Tenant in good faith and by appropriate legal so long
proceedings, provided that neither the premises nor the lien of such tax, assessment or of gal
meanwhile advertised for sale because of such nonpayment. If the Tenant shall, in violation charge be
provision of this lease, fail to pay or discharge any such tax, assessment or other char e the La any
may (but shall not be obli ated to g ? ndlord
g ) pay or discharge it, and if the Landlord does pay or discharge the
aforementioned items, the Tenant is hereby obligated to reimburse the Landlord, with all ex en
interest, and penalties connected therewith, on demand of the Landlord; and for all purposes se under r
lease and in any suit of any kind between the parties hereto any receipt showing the a me this
tax, assessment, or other charge signed by an p Y nt of such
y y public official authorized to give similar receipts shall be
conclusive evidence against the Tenant that the amount of such payment was due and payable and
such tax assessment or other charge was a valid and existing lien on the premises at the time of that
payment. such
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OUTSIDE APPEARANCE
(8) Tenant shall not burn any trash of any kind in or about the building, nor shall Tenant permit
rubbish, refuse or garbage to accumulate or fire hazard to exist in or about the premises. Tenant shall
store all trash and garbage within the designated receptacle, and the cost for same shall be as per
Supplement Sheet (A)
INTERIOR ALTERATIONS
(9) Tenant may at its expense, make such alterations and improvements to the demised
premises and install interior partitions as it may require, provided that the written approval of the
Landlord be first obtained and that such improvements and alterations are done in a workmanlike
manner in keeping with all building codes and regulations and in no way harm the structure of the
demised premises, provided that at the expiration of this lease or any extension thereof, such
improvements and alterations made shall become the sole property of the Landlord. Landlord and
Tenant recognize that certain equipment and fixtures are presently in place in the demised premises.
Landlord represents and warrants that as of the date Tenant commences business in the demised
premises, the equipment and fixtures of Landlord shall be in good working condition and are
appropriate for their intended purposes. During the term of this lease, Tenant shall be responsible for
maintenance expenses associated with the equipment and fixtures of Landlord. Leasehold
improvements which are not equipment made by Tenant to the demised premises during the leasehold
shall remain in the property at the termination of this agreement.
The Landlord is understood to be held harmless from the payment of any claims either by way
of damages or lien for any changes, additions, or alterations to the leased premises. All of such
changes, additions, or alterations shall be made solely at the expense of the Tenant; and the Tenant
agrees to protect, indemnify and save harmless the Landlord on account of any injury to third persons or
property, by reason of any such changes, additions, or alterations, and to protect, indemnify and save
1armless Landlord from the payment of any claim of any kind or character on account of bills for labor
or material in connection therewith.
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FIRE
(10) If the demised premises are damaged by fire or other casualty through no fault of Tenant
and the damage can reasonably be repaired within (120) days of the occurrence then, if Landlord gives
Tenant written notice within (30) days of the occurrence of Landlord's intention to make repairs, this
lease shall continue in effect with rent abated from the date of the occurrence to the completion of the
repairs. If the demised premised are damaged by fire or other casualty through no fault of Tenant and
the damage cannot reasonably be repaired within (120) days of the occurrence, then either Landlord or
Tenant shall have the right to terminate this lease agreement, termination to be effective from the date
of the occurrence. In case of such termination, Tenant shall pay rent apportioned to the time of the
damage and shall immediately surrender the demised premises to Landlord, and all further liability
between Landlord and Tenant reserved in this agreement shall cease.
In the event damage to the demised premises shall be so slight as not to render the same
unfit for the operation of the business of Tenant, the Landlord agrees to repair such damage with
reasonable promptness, in which case the rent shall continue to be payable as provided for in this lease
agreement. There shall be no obligation upon Landlord to repair or rebuild during the last (30) days of
the term of this lease agreement, limited to a basic building and the replacement of any interior work
which may have originally been installed at Landlord's cost. Except as herein provided, there shall be
no obligation to repair or rebuild in the case of fire or other casualty.
OPTION TO EXTEND TERM
(11) Tenant may, on written notice given to Landlord three (3) months or more before the last
day of the original term thereof, extend the said term for 3 years from the end of such original
term, and if such option is exercised it shall be the then current negotiation. Tenant shall not have
the right to exercise said option if at the time of exercising thereof, Tenant shall be in default of any
terms of this lease.
HOLDOVER
(12) If after the expiration of this lease including the exercising of the option set forth in
Paragraph 11 hereinabove, the Tenant shall occupy said premises with the consent of the Landlord and
rent is accepted frorn said Tenant, such occupancy and payment shall be construed as an extension of
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this lease for the term of one month only from the date of such expiration, and occupation thereafter
shall operate to extend the term of this lease for but one month at a time unless other terms of such
extension are endorsed hereon in writing and signed by the parties hereto. In such event if either
Landlord or Tenant desires to terminate such occupancy at the end of any month after the termination of
this lease, the party so desiring to terminate the same shall give the other party at least Ninety (90) days'
written notice to that effect. Failure on the part of the Tenant to give such notice shall obligate it to pay
rent for an additional three (3) calendar months, following the month in which the Tenant has vacated
the demised premises. If such occupancy continues without the consent of the Landlord, Tenant shall
pay to the Landlord, as liquidated damages, double the amount of rent at the highest rate specified in
this lease for the time Tenant' retains possession of the premises or any part thereof after termination of
the term by lapse of time or otherwise.
INSPECTION
(13) Landlord expressly reserves the following rights: (a) to enter said premises at any time to
examine or make such repairs, additions or alterations as it may deem necessary for the safety,
improvement or preservation thereof, or of said building but Landlord assumes no obligation to make
repairs to said premises or said building other than as expressly stated in this lease agreement; and (b)
to enter the demised premises and display a notice or sign "For Rent" and/or "For Sale" at any time
within six (6) months before the expiration or sooner termination of this lease, and to maintain the same
as placed; and (c) during or after the time Tenant abandons or vacates the premises or otherwise
defaults hereunder, to enter and decorate, remodel, repair, alter or otherwise prepare the premises for
occupancy. The exercise of any reserved right by Landlord shall never by deemed an eviction or
disturbance of Tenant's use and possession of the premises and shall never render Landlord liable in
any manner to Tenant or to any other person.
LIABILITY
(14) It is agreed that the Landlord shall not be liable to the Tenant or any other person on the
demised premises or in the building for any damage either to person or property. Landlord shall not be
under any responsibility or liability in any way whatsoever for the quality, quantity, impairment,
interruption, stoppage, or other interference with service involving water, heat, gas, electric current for
light and power, telephone or any other service.
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LIABILITY FOR DAMAGES AND PLATE GLASS TENANT
(15) The Tenant agrees to be responsible for any damage to the property of the Landlord which
may result from any use of the demised premises, or any act done thereon by the Tenant or any person
coming or being thereon by the license of the Tenant, express or implied, and also to save the Landlord
harmless from any liability to any person, for damage to person or property, resulting from any such
causes, and to protect such liability with Public Liability Insurance and to furnish Landlord a certificate
issued by the insurance carrier showln such in ranee in force and with Landlord covered thereby with
limitations of at least $1Million/4 rn U40^3 _ ? n in case of personal injury and/or death and/or property
damage. Tenant agrees to replace ll glass broken, damaged or destroyed in any manner whatsoever,
the Tenant assuming all responsibility for the glass in the premises herein demised, and to cause such
liability to be protected by plate glass insurance at Tenant's expense and further to deposit such plate
glass insurance policy or certificate showing such insurance in force with Landlord during the term of
this lease. Tenant agrees, at Tenant's expense, to keep all plumbing and heating lines from the point of
entrance to demised premises to the point of actual use tight and free from leakage and stoppage at all
times and to use reasonable diligence in the conservation of these supplies. If Tenant shall enter the
demised premises prior to the term hereof, Tenant shall be liable as herein set out, and such occupancy
shall be upon all the terms and conditions hereof except that rent shall be due at the time set forth in
Paragraph 1 hereof. Such prior occupancy by Tenant shall be at its own risk.
WAIVERS
(16) The failure of the Landlord to insist, in anyone or more instances, upon a strict
performance of any of the covenants of this lease, or to exercise any option herein contained, shall not
be construed as a waiver or a relinquishment for the future of such covenant or option, but the same
shall continue and remain in full force and effect. The receipt by the Landlord of rent, with knowledge
of the breach and no waiver by the Landlord of any provision hereof shall be deemed to have been
made unless expressed in writing and signed by the Landlord. Even though the Landlord shall consent
to an assignment hereof no further assignment shall be made without express consent in writing by the
Landlord.
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EARLY REMOVAL
(17) If the Tenant should remove or prepare to remove or attempt to remove from the premises
hereby leased before the expiration of the term or at any time during the continuance of this Lease, or if
the Tenant shall be in default in payment of any installment of rent for the period of ten (10) days, or
should there be a default in any of the covenants or conditions as herein contained, then in any such
event, rent for the maximum term of six (6) months at the rate which it is then due and collectible under
the terms of this Lease shall immediately become due and payable and shall be collectible by distraint
or otherwise provided, however, that in the event Tenant or Landlord provides or finds a new tenant for
the demised premises on terms equivalent to those provided for in this Lease before the expiration of
six (6) months from the date of removal or default by Tenant, then the amount collectible by Landlord
hereunder shall be the actual loss rent during the period the demised premises are vacant. If Landlord
breaches any of the terms or conditions of this Lease agreement Tenant may, after providing reasonable
notice of the breach to Landlord and further after giving Landlord reasonable opportunity to cure said
breach, declare this Lease terminated and the rent obligation shall cease.
ATTORNEY'S FEES
(18) If Tenant shall default in the payment of the rent herein reserved by failing to pay the rent
within( 10 ) days of the date when the rent was due or in the payment of any other sums due
hereunder by Tenant, Tenant hereby authorizes and empowers any Prothonotary or any attorney of any
Court of record to appear for Tenant in any and all actions which may be brought for said rent and/or
said other sums and/or to sign for Tenant Agreement for entering in any competent Court an amicable
action or actions for the recovery of said rental and/or other sums; and, in said Suits or in said amicable
action or actions, to confess Judgment against Tenant for all or any part of said rental and or said rental
and/or said other sums, including, but not limited to, the amounts due from Tenant to Landlord, and for
interest and costs, together with any attorney's commission for collection of fifteen (15%) percent.
Such authority shall not be exhausted by unexercised thereof, but Judgment may be confessed as
aforesaid from time-to-time as often as any of said rental and/or other sums shall fall due or be in
arrears, and such powers may be exercised as well after the expiration of renewal Term of this Lease
Agreement and/or during any extended or renewal Term of this Lease agreement and/or after the
expiration of any extended or renewal Term of this Lease Agreement.
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INTERPRETATION
(19) It is agreed that if any provision of this Lease shall be determined to be void by any court
of competent jurisdiction then such determination shall not affect any other provision of this Lease, all
of which other provisions shall remain in full force and effect; and it is the intention of the parties
hereto that if any provision of this lease is capable of two constructions, one of which would render the
provisions void and the other of which would render the provision valid, then the provision shall have
the meaning which renders it valid.
QUIET ENJOYMENT
(20) The Landlord covenants that the Tenant, subject to the conditions and covenants herein
contained, on paying the rent and performing the covenants aforesaid, shall and may peacefully and quietly
have, hold and enjoy the demised premises for the term aforesaid.
ENTIRE AGREEMENT
(21) It is agreed that Landlord has not made any statement, promise or agreement, or taken
upon itself any engagement whatsoever, verbally or in writing, in conflict with the terms of this lease,
or that in any way modifies, varies, alters, enlarges or invalidates any of its provisions, and that no
obligations of the Landlord shall be implied in addition to the obligations herein expressed. All notices
to be given hereunder by either party shall be in writing and given to the Landlord or the Tenant, and
shall be sent by registered or certified mail, postage prepaid, addressed to the party intended to be
notified at the post office address of such party last known to the party giving
notice, and notice given as aforesaid shall be a sufficient service thereof and shall be deemed given as
of the date when deposited in any post office, or in any post office box regularly maintained by the
Federal Government. The covenants and agreements contained in the foregoing lease are binding upon
the parties hereto and their respective heirs, executors, administrators, successors, legal representatives
and assigns.
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IN WITNESS WHEREOF, the parties hereto have caused this Lease to be executed by their respective
presidents and/or owners.
LA
By
Date
TENANT
By`?/r?iiLC?? r?r?Ciin?
By
Date
IN WITNESS WHEREOF, the parties hereto have caused this Lease to be executed by their respective
presidents and/or owners.
LANDLORD
By
Date
TENANT
By
By
Date
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PERSONAL GUARANTY: To induce Lessor to enter into this Lease, the undersigned unconditionally
guarantees to Lessor the prompt payment when due of all of Lessee's obligations to Lessor under the
Lease. Lessor shall not be required to proceed against Lessee or the Equipment or to enforce any other
remedy before proceeding against the undersigned. The undersigned agrees to pay all attorney fees and
other expenses incurred by Lessor by reason of Lessee's default. The undersigned waives notice of the
acceptance hereof and of all other notices or demands of any kind to which the undersigned may
otherwise be entitled. The Undersigned consents to any extensions of time or modifications in the
amount of payment granted to Lessee and to the release and/or compromise of any obligations of
Lessee or any other obligators and guarantors without in any way releasing the undersigned from its
obligations hereunder. This is a continuing Guaranty.
Guarantor Signature
No title allowed
Date,Z
Guarantor Signature
(If applicable) No title allowed
Date
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SUPPLEMENT SHEET "A"
LEASE AGREEMENT FOR 105 N. HANOVER STREET
CARLISLE, PA 17013
ITEM LESSOR RESPONSIBILITY
Snow/Ice Removal
Exterior Building Maintenance Provided by Lessor
Air-conditioning System
City Water
City Sewer
Electric System
Electric
Heating System
Heating oil/steam
Plumbing System
Floor Covering
Lighting System
Interior Wall / Ceilings
Business Sign
Parking
Exterior Renovations
Restrooms
Storage Area
Janitorial Services
Trash Removal
Telephone
Security
Insurance
Provided by Lessor
Provided by Lessor
LESSEE RESPONSIBILITY
All Removal
All Maintenance
All Maintenance
All Usage
All Maintenance
Provided by Lessor
Review of Sign
None Provided
Full Responsibility
Maintenance Costs
All Maintenance
All Maintenance
All Maintenance (lamps etc.)
All Maintenance
Review with Owner; Full
Responsibility of & Cost of Sign;
Review with Borough
All Maintenance
All Maintenance
Total Cost
Total Cost (borough bags)
Total Cost
Total Cost
Building Only Total Cost of Insurance, including
Liability, Fire, and contents
required, naming Lessor as the
additional insured; non-
cancelable, without 30 days
written notice
-13-
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2009 4?9?10"
Liberty Holding Cortlpwy Statement
P.0, Box 35$
.._.
Carlisle, PA 17013 Date
8/6./2009
To,
]nstant'Iax service
Car!iste, ?A 17013
Arn4unf DUD flrrtOUn1 Etta;
...._.._ ._._ ? w_ $12.380:1717
Out" Transaction
,---
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FILED-OfRrl
OF THE PROTHo OTARY
2009 OCT 29 kM IQ: 2 7
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Put a 3a?la
Sheriff s Office of Cumberland County
R Thomas Kline ~~~~-`~ ~ `~.` i-i~~~f,:
Sheriff - +
~~ ~;,. nl uaitGrrl,~~~~
Ronny R Anderson L~~~ {i.+`:t -~ i„ i i ~~ ~ r
Chief Deputy
Jody S Smith ~ w -
Civil Process Sergeant ~ ~' ~ ~~~ =.,~~:irr ~ '~ , ~'"'
Edward L Schorpp
Solicitor
Liberty Holding Company
vs. Case Number
Kirstin M. Sweigard 2009-7464
SHERIFF'S RETURN OF SERVICE
10/29/2009 04:00 PM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October
29, 2009 at 1600 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Kirstin M. Sweigard d/b/a Instant Tax Service, by making known unto herself personally,
at 1031 W. Trindle Road Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the
same time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $37.44 SO ANSWERS,
/0~~ ~~1
October 30, 2009 R THOMAS KLINE, SHERIFF
BY ~ ~~.
De uty Sheriff