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Home My WebLink About09-8681HUNTER'S RIDGE HOMEOWNERS ASSOCIATION, PLAINTIFF VS. MARIA WILLIAMS, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. bq - 8(o8( 01vt lL°r'1M 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 IMPORTANT RIGHTS. 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 By: Date: December 9, 2009 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 HUNTER'S RIDGE HOMEOWNERS ASSOCIATION, PLAINTIFF VS. MARIA WILLIAMS, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 6 9- y6 Pl e r a 7 COMPLAINT Plaintiff Hunter's Ridge Homeowner's Association (hereinafter "Plaintiff") is a non- profit Pennsylvania Corporation with a mailing address of P.O. Box 454, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant Maria Williams (hereinafter "Defendant") is an adult individual residing at 1774 Weatherburn Drive, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Defendant resides within a development subject to the Declaration of Covenants, Conditions, Restrictions and Easements for Hunter's Ridge which was recorded on May 14, 1989 in the Office of Recorder of Deeds for Cumberland County, Pennsylvania in Miscellaneous Book 380, Page 519. 4. Defendant resides within a development subject to the Bylaws of the Association of Hunter's Ridge Homeowners' Association. The governing documents of the Association require the Defendant to pay a monthly homeowners' association fee which has been established by the Association to be One Hundred Twenty Eight and 00/100 ($128.00) Dollars to cover such items as exterior maintenance, snow removal, fees, and landscaping. 6. Since December 31, 2008 the Defendant has failed to timely pay her monthly homeowners' association dues. Defendant failed to appear at a hearing before the Plaintiff's Board on December 4, 2009 despite receiving written notice via certified and regular United States Mail. 8. Attached as Exhibit "A" is a true and correct copy of a Statement dated December 2, 2009 shows the outstanding amount due as of that date to be Five Hundred Fifty and 00/100 ($550.00) Dollars. 9. Defendant is aware of the governing documents which are available for review at www.hrhoal707O.com 10. The Declaration of the Association expressly permits the Association to recover all costs and attorney's fees incurred in enforcing the governing documents for the Association. See Article VI, Section 6.8.6. 11. The Bylaws of the Association expressly permit the Association to recover interest at the rate of eighteen (18%) percent per annum on any assessments not paid within five (5) days after its due date. See Paragraph 6.3. 12. The Declaration of Covenants expressly provides for the acceleration of all unpaid assessments due for the fiscal year to be immediately due and payable. See Article VI, Section 6.12 of the Declaration of Covenants. 13. Plaintiff seeks to recover accelerate the twelve (12) months of assessments due for 2010 or One Thousand Five Hundred Thirty Six and 00/100 ($1,536.00) Dollars pursuant to Article VI, Section 6.12 of the Declaration of Covenants. 14. Plaintiff has incurred legal fees of Three Hundred and 00/100 ($300.00) Dollars in filing this complaint. WHEREFORE, Plaintiff seeks an award of Two Thousand Three Hundred Eighty Six and 00/100 ($2,386.00) Dollars against the Defendant as well as an award of costs and future legal fees in excess of $300.00 and interest at One and 17/100 ($1.17) Dollar per diem in interest from December 9, 2009. Respectfully submitted, BY: 11 Law Firm '619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Attorney for Plaintiff Date: December 9, 2009 VERIFICATION I/yv6 verify that the statements made in the foregoing document 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. BY: 44-zM-4 'r L4"4 .-_ resident of the ` Hunters Ridge Homeowners' Association Date: 12 -/?,? 9 . Hunter's Ridge Homeowners Assn. PO Box 454 New Cumberland, PA 17070 TO Ms. Maria Williams 1774 Weatherburn Dr. New Cumberland, PA 17070 Statement DATE :?] 12/2/2009 AMOUNT DUE AMOUNT ENC. $550.00 DATE DESCRIPTION AMOUNT BALANCE 12/3112008 Balance forward 130.00 01/01/2009 Monthly Fee 128.00 258.00 01/08/2009 Late Fee 10.00 268.00 02/01/2009 Monthly Fee 128.00 396.00 02/09/2009 Late Fee 10.00 406.00 03/01/2009 Monthly Fee 128.00 534.00 03/03/2009 PMT 42501. -276.00 258.00 03/08/2009 Late Fee 10.00 268.00 04/01/2009 Monthly Fee 128.00 396.00 04/05/2009 PMT #2400. -200.00 196.00 04/08/2009 Late Fee 10.00 206.00 05/01/2009 Monthly Fee 128.00 334.00 05/09/2009 Late Fee 10.00 344.00 06/01/2009 Monthly Fee 128.00 472.00 06/06/2009 PMT #2433. -250.00 222.00 07/01/2009 Monthly Fee 128.00 350.00 07/11/2009 Late Fee 10.00 360.00 07/20/2009 PMT #2445. -250.00 110.00 08/01/2009 Monthly Fee 128.00 238.00 08/10/2009 Late Fee 10.00 248.00 09/01/2009 Monthly Fee 128.00 376.00 09/08/2009 PMT #2452. -250.00 126.00 09/09/2009 Late Fee 10.00 136.00 10/01/2009 Monthly Fee 128.00 264.00 10/07/2009 Late Fee 10.00 274.00 11/01/2009 Monthly Fee 128.00 402.00 11/09/2009 Late Fee 10.00 412.00 12/01/2009 Monthly Fee 128.00 540.00 12/02/2009 Late Fee 10.00 550.00 AMOUNT DUE $550.00 'AIR Y [C09 07C 17 r ' 12: 3 5 *ga.oo PO prN cir * 8gg4d a55! U4 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff OF PWTHL),NOTAW trtr of ?tiurGirr Jody S Smith ` s 2018 JAN -6 AN S.- 43 Chief Deputy -r Edward L Schorpp CumworsLAID GOL11+PfY Solicitor :E :F ° F? Fi?rt5Y1.VANW Hunter's Ridge Homeowners Association vs. Maria B. Williams Case Number 2009-8681 SHERIFF'S RETURN OF SERVICE 12/28/2009 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Maria B. Williams, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Maria B. Williams. The New Cumberland Postmaster has advised the defendant's mail is received at P.O. BOX 17 New Cumberland, PA 17070 which has a physical address of 1774 Weatherburn Drive, New Cumberland, PA 17070. Terri Marquis current neighbor advised Deputies the defendant has moved. SHERIFF COST: $48.74 December 28, 2009 SO R ANDERSON, SHERIFF c, CountpSuitc Shenff, Teleosoft. Inc. o c v,f cDavid cD. Buell _ Renee X Simpson Prothonotary o �!4 1s` Deputy Prothonotary v `D,. 3 M1 i o �irkS. Sohonage, ESQ �, �3<=l Irene E. Morrow Solicitor 1750 2nd Deputy(Prothonotary Office of the Prothonotary Cumler&aniCounty, Pennsylvania 1 .64 - 81„,81 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE—THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 • Carlisle, TA 17013 • (717)240-6195 • Ea., (717)240-6573