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HomeMy WebLinkAbout09-8410IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT L. FREY, JR., No. ©LJ` _ Plaintiff S?IzllQ 6.L? , V. CIVIL ACTION - LAW WORDS OF LIFE MANAGEMENT FOR THE ESTATE OF MARY C. BURSON, and JEAN BURSON, Defendants 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 plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notification y por cualguier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiendades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SOFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONAL O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 Respectfully submitted, GG/ Walter C. Theal, as Attorney-in-fact for Robert L. Frey, Jr. 225 Brian Drive Enola, Pennsylvania 17025 (717) 739-1173 Pro Se IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT L. FREY, JR., No. Plaintiff V. CIVIL ACTION - LAW WORDS OF LIFE MANAGEMENT FOR THE ESTATE OF MARY C. BURSON, and JEAN BURSON, Defendants COMPLAINT AND NOW, comes Walter C. Theal, as attorney-in-fact for Plaintiff, Robert L. Frey, Jr., by and through his attorney, Sean M. Shultz, Esquire, to file a Complaint, in support of which the following statements are made: 1. Plaintiff is Robert L. Frey, Jr., an adult individual who resides at 1205 S. 28th Street, Harrisburg, Pennsylvania 17011. 2. Defendants are Words of Life Management for the Estate of Mary Burson, an unknown entity; and Jean Burson, an adult individual who resides at Box 338, 202 Third Street, Summerdale, Pennsylvania 17093. 3. On September 4, 2006, Plaintiff and Defendants entered into a Residential Lease Agreement in which Defendants agreed to rent to Plaintiff the premises located at 225 Brian Drive, Enola, Pennsylvania. The monthly rent was $695.00, and the security deposit was two months rent, $1,390.00. A copy of said Residential Lease Agreement is attached as Exhibit "A" and made a part hereof. 4. On or about September 14, 2008, Plaintiff suffered a hemorrhagic stroke and was admitted to Harrisburg Hospital where he remained in a coma for several days. 5. Plaintiff paid his rent for the month of September on September 3, 2008. 6. During Plaintiff's incapacitation, Defendant Burson visited the Harrisburg Hospital and observed Plaintiff in an unconscious and comatose state. 7. On September 26, 2008, Defendant Burson changed the locks on the residence and posted a notice on the front door of the residence indicating that the premises had been abandoned by Plaintiff and that an appointment had to be made with Defendant Burson to retrieve Plaintiff's personal papers from storage. 8. The notice further indicated, "Abandonment procedures are being undertaken in accord with the abandonment clause of his rental agreement. No tenant or representative thereof any longer has the right to occupy. The locks have been changed to protect the private information of former tenant and property from theft and damage." A copy of the notice dated September 26, 2008 is attached as Exhibit "B" and made a part hereof. 9. One of Plaintiff's neighbors observed Defendant Burson removing Plaintiff's personal property, including several metal lock boxes containing his valuable coin collection, from the residence in the middle of the night. The neighbor informed Defendant Burson that Plaintiff had been hospitalized and did not abandon the premises. 10. Plaintiff's daughter, Amy Christaldi, attempted to gain entrance to the residence and was told by Defendant Burson that she could gain entrance if she would give Defendant Burson a DVD recorder in the residence and also get written permission from all family members to gain entrance to the residence. 11. On October 8, 2008, due to his incapacitation, Plaintiff was admitted to Spring Creek Rehabilitation & Health Care, a full-time care facility, where he currently resides. 12. In early October, 2008, Defendant Burson informed Plaintiff's family that she had a new tenant for the residence and requested that they remove all Plaintiff's personal property from the residence. 13. Defendants agreed to purchase the refrigerator in the residence from Plaintiff's family for $100.00. 14. Defendants have refused to return the $1,390.00 security deposit to Plaintiff. 15. Defendants have refused to pay $100.00 to Plaintiff s family for the refrigerator left in the residence. 16. Several chords of wood valued at $500.00 were removed from the residence and Defendants have refused to pay for them. 17. Plaintiff incurred attorney's fees in the amount of $300.00 for the preparation of this Complaint to be filed pro se. The invoice from the Law Office of Sean M. Shultz, P.C. is attached hereto and made a part hereof as Exhibit "C". WHEREFORE, the Plaintiff demands judgment in his favor and against Defendants for $2,290.00, plus filing costs, court costs, attorney's fees, and such other costs, damages, and remedies as the Court deems appropriate. Respectfully submitted, Wal er . Theal, as Attorney-in-fact for Robert L. Frey, Jr. 225 Brian Drive Enola, Pennsylvania 17025 (717) 739-1173 Pro Se IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT L. FREY, JR., No. Plaintiff V. CIVIL ACTION - LAW WORDS OF LIFE MANAGEMENT FOR THE ESTATE OF MARY C. BURSON, and JEAN BURSON, Defendants VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. Date: Walter C. Theal, as attorney-in-fact for Robert L. Frey, Jr. Exhibit "A" RESIDRMAL LOANS MDESSIENT This lease agreement shall t be zecorded for any reason and (hereinafter referred to as the `Agreement-) made and sitar" into this day of September, 2006, by and between Words of Life Management for estate of NUT C. Bureaus Jaan Burn irector whom- ade?.• is P.O. POi 336 Snmmardals, PA. 17093 (hereinafter referred to am -Le•ws-) and rte L. CQa,?.u .1 (hereinafter referred to as "A" W). IMNESSETE, mom, Lessor Words of Life management for estate of Vary C. Sursons Jean Burson Director, of certain real property being, lying and situate in Cumberland County, Pennsylvania, such real property having a street address of 225 Brian Dr. Souls, PA 17025. ' W®taas, tosses is desirous of loving the Premises from Lessor on the terms and conditions as contained herainy HOW, TmtWOBS, for and in consideration of the mum of TWEM ONE SMMM 2KD= rM Dollars ($2135.00), F27TY DOLLARS($50.00)Wlkich shall be used to pay for a credit report. And TWO THOUSAND ZION. PIPE Dollars ($ 2085.00.00) which shall be the first installment an move in costs, the covenants and obligations contained herein and other good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, the parties hereto hereby agree As follows, 1. TERN. Lessor losses to Lessee and Losses leases from Lessor the above described Premises together with any and all appurtenances thereto,.for a tern of one year, such term beginning on September 11, 2006 and ending at 12 o'clock midnight an September 1" in the year 2007. October rent 463.33 shall be due an October 1" 2006 prorated to refund everpmyseat of $231.57 in September, 2006. 2. Sent. The total rent for the term hereof is the ems of lImr THOUSAND 01R zu D EIOET DOLLARS ADD Tuxan TB)Za CENTS. 00108.33), parable as the first day of each month of the term, is equal installments of SIX BOMWW 11lKSTT TrVl DOLLARS ($993.001. first installment to be paid prior to *coupanay, the sicced smmth'a to be paid on October 1, 2006. All each permeate shall be made to Lessor at Lossar'a address as set 'forth in tits pfesmble to this 2nseamaat on or befOrs StA_ 6114' thent 3. DSPASV,.. Pl49t be e4400m.r.: 1"aft:/Mail . ; yitl! AMSlllflt. asr _ . 3osase v3M111QitBNB (MS a (?Als Msa111 ? son W1 1 P"w mw ssemesem ¦ hh1411 LE saslgst is AAIXMe, 1tY0eiC daxfag Omtsmw >w fist et •+n?1WnN eeMm roe titrNkdsatsat of sme6m+ 0 w aa' met art flee. as moy" to the 9;"" th" . Should Cost of repairs exceed this count, tenant agrees to pay the ovirBgo. 6. USX OF PI UM- The Promises shall be used and occupied by Lassse and Lessors long toss guest or immediate family, consisting of :iMLMAU C)!sy _ to be used exclusively, as a private single family dwelling, end no part of the dal-d shall be Used at any time during the taro of this Agreement by Lessee for the purpose of carrying om any business, profession, or trade of any kind, or for any purpose other than as a private single family dwelling. Lessee shall act allow any other person, other than Lessee's long tea guest or immediate family Am named above to use or occupy the Premises without first obtaining Lessor's written consent to soah use. Losses shell comply with any and all la's, ordinances, rules and orders of any and all governmental or quasi-gevermmmntal acthorities affecting the cleanliness, use, occupancy and prseezvation of the Premises. Other occupants wt vacate upon request or assome full responsibilities of this lee". 5. CONDITION OF PRIKIBXS. Lasses stipulates, represents and warrants that Lessee has examined the Premises, and that they are at the time of this Lee" in good order, repair, and in a safe, clean and tamantable condition. Xxapt for damaged storage shed door, which most be kept closed during rain storms. 6. ASSI9OamR AM BOX-Z TIED. Lasses shall not assign this Agreement, or sub-1st or grant may liaeave to use the Premises or any part thereof without the prior written consent of Lessor. Consent by Lessor to ome such assignment, sub-letting or license shall not be deemed to be a consent to say subsequent assignment, sub-letting or license. An Ysignm Let, sub-letting or license without the prior written consent of Lessor or an assignment or sub-letting by operation of law shall be absolutely null and void and shall, at Lessors option, terminate this Agreement. 7. AufSkaTIONt AND-XNPROVXlmPfs. Losses shall make no alterations to the buildings or improvements an the Promises or construct any building or make any other improvements on the Promises without the prior written consent of Lesser. Aar and all alterations, abonges, and/or improvements built, constructed or placed an the _._ ._.--=rsSdaSB,.ED! 7Als(Iy.,?h.B?l,, p}(}g?? a.Sby$2wis.;,,?rovided by written, 09-t between Lessor and Losses, be and became the property of Lessor and remain on the Trsi/N at ttia" g3e`ati?Ct'e Iriit ta*minatian ar-CXis Agreement. 6. Nate-VILIVIMY OF POSan"xoar. Ea the event Leaser cannot deliver pessesoion of the Premises to Lessee upon the cammeacement of the Lease ass, through no fault of Lessor or its agents, than Lessor or its agents shall have no liability, but the rental herein provided shall abate until possession is given. Lessor or its agents shall have thirty (30) days in which to give possession, and if possession is tendered within swig time, Lose" agrees to accept the demised Premises and pay the renal herein provided from that date. In the event possession cannot be delivered within such time, through no fault of Lessor or its agents, then this Agreement and all rights hereunder shall terminate. 9. XaaaRDOUS 39MMXALS. Ashes shall not keep an the Promises may item of a dangerous, flammable or explosive character that night unreasonably Increase the danger of firm or explosion en the Promises or that might be considered hazardous or extra hazardous by mW responsible insurance company. 10. VfILITIXS. Lenses shell be responsible for arranging for and paying for all utility services required on the Promises Electric, water, cable TV, and phone. Lessor to pays last Pennaboro fee for water, sever and trash, base owner's foe and recreation fee. It. WAINImWCS AND SEPAAI, ROLSS. Lessee will, at is sale expense, keep and maintain the Premises and appurtenances in good end sanitary condition and repair during the are of this Agreement and may renewal thereof. Without limiting the generality of.the foregoing, Lessee shall* (a) Not obstruct the driveways, sidewalks' courts, entryways, stairs and or halls, which shall be used for the purposes of Ingress and ogress only, (b) Keep all windows, glass, window coverings, doors, looks and hardware in goad, clean order and repairs (C) not obstruct or cows the windows or doormy (d) Not leave windows or doors in an open position during any inaement weathers (e). Ent bang say laundry, clothing, sheets, eta. from Rt0' window, rail, parch or balcony nos air or dry any of sees withia any yard area or spaaey (f) Not OVA" Or permit any looks or books to be placed Upon may door or window without the prior written consent of Lessor, (g) Keep all sir conditioning filters ale= and -Area from dirty . (h) ieP..'eil..lii`LEOr}.se+ .St.0"i ...tellea,- mad all -o0bee. rata= and . . plmmbing apparatus te ga6?d order and 'repair and shall use am* only for ehe'porpaaes for which they .%*" constructed. Lessee shall mt allo*'amr'ssiriptngar rubbish, sand, rags, ashes or other sobstanaes to be thrown or deposited therein. Any damage to any each apparatus and the cast of clearing stopped plumbing resulting from zisn" mball be burns by Lessees (I) And Losaee's. family and guests shall at all times maintain order is the. Promises' onsl at all places on the Premises, and shall not male or permit our load or improper noises, or otherwise disturb other residents, U) Keep all radies, alwvisioa sets, stereos, phonographs, etc., turned down to a level of sound that does not annoy or interfere with other residents, (k) Depasit all trash, gasbego, eobbish or refuse in the loeatiane provided therefore and shell not alive any trash, garbage, rubbish or refuse to be deposited or permitted to stand on the exterior of any building or within the common elementsy (I) Abide by and be bound br any and all rules and regulations afleating the Premises or the stamen area appurtenant ther?to which mar be adopted or promulgated by the Condominium or Xomeowners• Association having control aver them. 12. DAAaON TO PSaklsES. La the event the Promises are destroyed or rendered wholly untenantable by firestorm, earthquake, or other casualty not caused by the negligence of Leases, this Agreement shall terminate from each time except for the purpose of enforcing rights that any have then accrued hereunder. The rental provided for herein shall tben be accounted for by and between Lessor and Lease* up to the time of much injury or destruction of the Premises. Lessee paying rentals up to each date and Lessor refunding rentals collected beyond such date. Should a portion of the Promises thereby be rendered untenantable, the Lessor shall have the option of either repairing such injured ar damaged portion or terminating this Lee". Xn the event that Lessor exercises its right to repair such untanentable portion, the rental shall abate in the proportion that the injured parts bears PAM 1 OP 2 to the w1101e Prumiess, and Ouch part so injured shall be restored by Lessor as speedily as practicable, after which the 1071 rent shall reccomome and the Agreement continue according to its terns. 13. 1MRPROTIOM OF PRMa2RRS. Lessor and Lessor's agents shall have the right at all reasonable times daring the term of this Agreement and any renewal thereof to enter the Promises for the purpose of inspecting the Premises and all buildings and improvements thereon. And for the purposes of eating any repairs, additions or alterations as emir be deemed appropriate by Lessor for the preservation 01 the Promises or the building. Lessor and its agents shall further have the right to exhibit the Preaiw and to display the usual -for sale-, `for rent- or `vacancy- signs an the Premises at any time within forty- five (45) days before the expiration of this Lesso. The right of entry shall likewise exist for the purpeee.of removing placards, signs, fixtures, alterations or additions, but do not conform to this Agreement or to any restrictions, rules or regulations affecting the Prodsos. 14. ROROMMMTIOW of LghU. This Ao"eaent and Lesson's interest hereunder are and shall be subordinate, junior and inferior to any and all mortgages, liens or enmsbruoss new or hereafter placed on the Premises by Lessor, all advances made under any such mortgages, lines or one mbremaes (Including, but not lialted to, future advances), the interest payable an such mortgages, linos or enambraneu and any and all renewals, extensions or modifications of ooh s0rlgagea, liens or am,sbranees. 15. JMMM,S IWO ovnt. If Lemses remains in possession of the Premises with the coconut of Lesser after the natural expiration, of this Agreement, a now tenancy from manth-to-month shall be created between Lessor and Leases which shall be subject to all of the terms and conditions hereof except that rut shall than be due and owing at S7S a' WIM•ry FX" DOLLARS (4695.00) per 000th and except that such tenancy shall be terminable upon thirty (30) days written notion served by either party. if. sumannOWN OP IRMO=. Upon the expiration of the term hereof, losses shall surrender the Promises in as good a state and condition as they were at the cammencoment of this Agreement, reasonable use and wear and Gar thereof end damages by the Clemente ucacted. 17. ANDM . Losses 3iaii eTi?utitied to keep no pits except one cam t t t =82=1 lemant may have a dog by dime Owner's Regulation. IS. QVdRS 1:05O!fl®IT. Lesson, upon payment of all of the some referred to herein as being payable by too*" and. Lessee's performance of all Luau's agreements contained herein and Laxness Observes" of all rules and rnpo"tio", sball and may Peacefully and quietly be", bold and enjoy said Promises for the term hereof. 19. IMMUFICATIOM. Lessor shall not be liable for any damage or injury of or to the Lessee, Lesson's family, gusts, invitess, agents or employees or to any person entering the Predses or the building of which the Premises are a part or to 900" or equipment, or in the structure or equipment of the structure of Which the Premtsu are a part, end Lessee hereby agrees to Indemnify, defend and held Lessor barmlus from my and all claims or assertions of every kind and nature. 20. DIFAMT. If Lessee fails to Damply with any of the material provisions of this Agreement, other than the covenant to pay rut, or of any present role and regulations or any that any be hereafter pres=lbod by Lessor, or materially fails to comply with any duties imposed on Less" by statute, within seven (7) days after delivery of written notice by Lessor specifying the non-aampliaaae and indicating the intention of Lessor to terminate the Lease by reason thnr"f, Lsuor say terminate this Agreement. If Lessee fails to pay rut when due and the default continues for seven (7)dayn thereafter, Lessor say, at Lessors option, declare the entire balance of rent payable hereunder to be immediately due and payable and may smarsise aaF and all rights and remedies available to Lessor at law or in equity or nay ivsdiately terminate this Agreement. 21. LATE OWM. In the event that any payment required to be paid by Lesson hereunder is not made within FOWL (4) days of when due, Lessee shall pay to Lessor, in addition to such payment or other charges due hereunder, a `late fee' In the smormt of Tel (610.00) per day. 22. ARANDOMMZMT. If at any time daring the tern of this Agreement Less" abandons the Premises or any part thereof, Lessor may, at Lessor's option, obtain possession of the Premises in the manner provided by law, and without becoming liable to Lesson for damages or for any payment of may kind whatever. Lessor may, at Lessor's discretion, as agent for Losses, relet the Premises, or any part thereof, for the whole or any part thereof, for the whole or any part of the than unexpired tors, and may receive and collect all rent payable by virtue of such reletting, and, at Lessor's option, bold Leeses liable for any difference between the rant that would be" been ...__.....pm;gmble imdar.this.._agree- dur1 __thc balance of the nn"gired torn, if this Agreement had continued in force, and the net rent for such period rseiized by Lessee by -mad of mQ riri'EEiag"':-i1 lilddsTd`ii?OtiC'Of'Y0i6iEly'YY "--... exercised following abandonment of the Promises by Lessner then Lessor shall consider any personal property belonging to Less" and left an the Premises to also have been abandoned, in Which case Lessor my dispose of all such personal property in any meaner Lesser shall due proper and Lessor is hereby relieved of all liability for doing so. 23. ATZORMS01 PENN. Should it became necessary for Lessor to employ an attorney to enforce any of the conditions or cevemants hereof, including the collection of rentals or gaining possession of the Promises, Leases agrees to pay all expenses so incurred, including a reasonable attormeys• fee. 24. RRCOFDSWO OF A?. Levee shall not record this Agreement an the Public Rewords of any public office. In the event that Less" shall record this Agreaant, this Agreement shall, at Lessor's option, terminate immediately and Lesser shell be entitled to all rights and remedies that it has at low or in equity. 25. GOVlAd1111g Lill. This Agreement shall be governed, construed and interpreted by, through and under the Laws of the State of Pennsylvania. 26. EZVMMZWrr. If any provision of this Agreement or the application thereof shall, for any reason and to any extent, be Invalid or unenforceable, neither the remainder of this Agreement nor the application of the proviStan to other persons, entities or circumstances shalt be affected thereby, but instead shall be enforced to the nmeima extent Permitted by low. 27. RmmXHO RFFSCr. The aawanents, obligations and conditions herein contained shall be binding on and inure to the benefit of the heirs, legal representatives, and assigns of the parties hereto. 28. DMMPTM RRADM=. The descriptive headings used heroin are for convenience of reference only and they are not intended to have any effect whatsoever In detemd"ag the rights or obligations of the Lessor or Lessee. 29. OWgTMMON. The pronouns used herein shall include, where appropriate, either gender or both, singular and plural. 30. MOW-WAivRR. So indulgence, waiver, election or non-election by Lessor under this Agreement shall affect Lesson's duties and liabilities hereunder. 31. MDDITICATIOK. The parti" hereby agree that this document contains the entire agreement between the parties and this Agremmact sball.mot be modified, changed, altered or amended in any way except through a written amendment signed by all of the parties hereto. . -3A,._ 115.,pR3tlNgf....PSea..tlem:-to.2lae .ea?fsn,...or. hansnaneVa 9p0 increases make rental ibofeixse ceassxary. Lessor reaervii the -Ikdht'to'smker•seeb, increases as 4040 swasanabla. 33. Lessee will furnish his own refrigerator, a stack unit washer and dryer or.pay $100.00 to remodel the laundry room if he desires to install standard size units. Lessor, Words of Life Management of Notate of Mary c. As TO LRSiOR This day of September, 2006 , Surson, Jean Burson niraator As to Leos" this _ day of.Paptimber, 2006 PAM2OF2 Exhibit "B" POSTED ON THE PREN[ESIS SEPTEMBER 26, 2008 ";'O WHOM IT MAY CONCERN. PLEASE CALL FOR AN APPOINTMENT TO RETRIEVE PERSONAL PAPERS OF ROBERT FREY FROM STORAGE. IF YOU HAVE DOCUMENTATION TO SHOW YOU HAVE AUTHORITY TO HANDLE HIS AFFAIRS AND READ HIS MAIL. 717 5034521 ROBERT FREN' THROUGH INCAPACITY HAS ABANDONLD HIS TENANCY AT 225 BRIAN DRIVE AND IS HEREBY NOTIFIED THAT HE IS ALSO NOTIFIED TO VACATE IN 30 DAYS AND HIS TENANCY WILL BE TERMINATED BY THIS 30 DAY NOTICE AS OF OCTOBER 26, 2008 ACC('RDING TO THE 30 DAY NOTICE PROVISION OF HIS RENTAL AGREEMENT WHICH IS A MONTH TO MONTH TENANCY. ABANDONMENT PROCEE.DURES ARE BEING UNDERTAKEN IN ACCORD WITH THE ABANDONMENT CLAUSE OF HIS RENTAL AG-Q,'LEMFN'T. NO TlINANT OR RFPRESENTATIVE TI4FRFOF ANY LONGER HAS THE k.IGHT TO OCCUPY. THE LOCKS HAVE BEEN CHANGED TO PROTECT THE PRIVATE INFORMATION OF FORMER TENANT AND PROPERTY FROM THEFT AND DA-MAGE. NO TRESPASSING! TRESPASSING WILL BE PROSECUTED IN ACCORD WITH THE LAW. TEN DAY PAY OR QUIT NOTICE POSTED 9/30/2008 KENT DUE ON OCTOBER 1ST 2008 MUST BE PAID BY THE TENTH TO AVOID EVICTION. YOU WILL BE REQUIRED TO PAY ALL CHARGES INCURRED BY THIS ACTION RENT OF $7120.00 IS DUE ON OCTOBER IST. IF IT IS NOT PAID BY OCTO B F R I OT" 2008 71 0 (J - r?< < 13e5 ; k. Exhibit "C" Law Office of Sean M. Shultz, P.C. 4 Irvine Row Carlisle, PA 17013 Invoice submitted to: Walter C. Theal As Attorney-in-fact for Robert L. Frey, Jr. 225 Brian Drive Enola, PA 17025 December 07, 2009 In Reference To: Jean Burson Invoice #10175 Professional Services Hrs/Rate Amount 12/1/2009 Telephone conference with client 0.50 NO CHARGE 12/2/2009 Draft Complaint 1.50 NO CHARGE 12/7/2009 Office conference with client 0.50 NO CHARGE Office conference with client 0.30 NO CHARGE Revisions to Complaint 0.20 NO CHARGE Preparation and filing of Complaint 221.50 For professional services rendered 3.00 $221.50 Additional Charges : 12/7/2009 Filing fee for Complaint 78.50 Total additional charges $78.50 Total amount of this bill $300.00 Accounts receivable transactions 12/7/2009 Payment - Thank You No. 1221 ($300.00) Total payments and adjustments ($300.00) Walter C. Theal Balance due Page Amount $0.00 RB. Ic OFVE W 0 lall occ F? co s 7? ,?` a3vS?? .c°~~ ~ F lam ff In The Court of Common Pleas of Cumberland County, Pennsylvania No:~- i~ U ~/ Defendan Civil Action -Law. ~ ~ e . ~f~, .P,~t~r ~~ v Oath We d°o 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 fid 'ty. Signature ~~~ Name (Chairman) ~ D. BUELL County arthouse Square PA 17013 Signature o ~~r~ Name i" ' ignature ~~.~ w~ Name --~ r , , Q9~ 87 ~0 ~„~P'(ES F03Tq~F` ti ~ ~ ~ ~ wr ~'-~~'~~ 111 NtY lS(IUJ!' ,rt fi~n,~ o~ ~~ 0 rx ~`'~~ - ~ 00.44 . ~,~'~y ~ • c~ooass~ sus APR' ~. ~~_,, ?OI~ A Dp MAILED FROM ZIP CODE ? ' :` ~(Jd~JJL_. FOR ROBERT L FREY, JR. 225 BRIAN DRIVE ENOLA, PA FC?RIJ~R~ "CxME~E~P~ F?TN~T~rC? ~E:RdD~'~:L'TJiC~ FREY .]R' ROE#EYi?T to 1112 F{7R1C9 A~/E HFiRRZ^a1~UF2G RA 17109-'SE+15 RE"1'URN 'T C5 SEN[~EF2 ~7ai~c~~~~~ I.,.III~~~)Ila,~~„II~~Ii...ilr~~ll~,~i~l~~ll~„LI~I~I~II~„1