HomeMy WebLinkAbout10-0958RLED-t? Ta
OF THE PR T' ?TARP
2010 FEB -4 PM 2= 18
CUt,?r?w.rdC+ 'COUNTY
PEtwN;aYLVANA
GOTHIE VAN ALLEN LLC
Joseph N. Gothie, Esq. PA I.D. No. 80390
Moshe Bell-Jacobs, Esq. PA I.D. No. 210233
111 East Market Street, Suite 101
York, PA 17401
V: 717-848-8455
E: jng@gvafirm.com
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
COUNTRY MANOR WEST
Plaintiff
V.
RICKY SEACHRIST
Defendant
No.
CIVIL ACTION - LAW
NOTICE TO PLEAD
TO RICKY SEACHRIST
YOU ARE HEREBY NOTIFIED to file a written response to the enclosed First
Amended Complaint on or before twenty (20) days from the date of this Complaint or a
Judgment may be entered against you.
BY: 4)• 14 Dated: GO HIE AN ALLEN LLC
Joseph N. Gothie, Esq. PA I.D. No. 80390
Moshe Bell-Jacobs, Esq. PA I.D. No. 210233
111 East Market Street, Suite 101
York, PA 17401
V: 717-848-8455
E: jng@gvafirm.com
1
C7D-M,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
COUNTRY MANOR WEST
Plaintiff
v
RICKY SEACHRIST
Defendant
No. D'- 95'r C \/-y /
CIVIL ACTION - LAW
NOTICE TO DEFEND
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 NOTICE 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.
2
Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
1-800-990-9108
717-249-3166
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE.
Respectfully submitted,
BY: d"? ?' Dated: 6ZP(W(3
G HIE AN ALLEN LLC
Joseph N. Gothie, Esq. PA I.D. No. 80390
Moshe Bell-Jacobs, Esq. PA I.D. No. 210233
111 East Market Street, Suite 101
York, PA 17401
V: 717-848-8455
E: jng@gvafirm.com
3
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
COUNTRY MANOR WEST
Plaintiff
V.
RICKY SEACHRIST
Defendant
No. 10 " 7 J-?r G `v i Iel1",
CIVIL ACTION - LAW
COMPLAINT
AND NOW, TO WIT, this 4 h day of February, 2010, comes the Plaintiff by its attorney, Joseph
N. Gothie, who files this Complaint, of which the following is a statement:
1. The Plaintiff ("CMW") is a property management company operating Country Manor
West Mobile Home Park in Carlisle, Cumberland County, PA.
2. Country Manor West is a registered fictitious name in the Commonwealth of
Pennsylvania.
3. Plaintiffs business address is 2 Apple Alley, Carlisle, PA 17013.
4. The Defendant is an adult residing at 126 Peach Lane, Carlisle, PA 17015.
5. The Plaintiff owns the lot upon which the Defendant's mobile home rests.
4
6. Defendant has possession of the property under a written agreement ("Lease") signed
with Plaintiff on October 20, 2006. See Exhibit A.
7. The Lease requires Defendant to follow all the rules and regulations associated with the
Lease and to pay rent of $371.00 per month. See Exhibit A.
8. The monthly lot rent is $371.00 per month due on the 5t' day of each month.
9. On or about October 15, 2009, Plaintiff sent a certified mail notice to Defendant
indicating that as of October 15, 2009, Defendant owed $693.54 in late rent and utilities.
See Exhibit B.
COUNT I - EVICTION
10. Paragraphs 1 through 9 are incorporated herein by reference as if fully restated and
realleged herein.
11. Defendant failed to pay rent and utilities when due in October 2009.
12. After Plaintiff's notice of failure to pay rent to Defendant in October 2009, Defendant
continued to fail to pay rent for November and December 2009.
13. The Lease requires that rent is due on the 5t' of each month, paid monthly in advance,
under the "Registration and Rent" heading. See Exhibit A.
14. Defendant timely paid rent prior to October 2009.
15. It is believed and therefore averred that Defendant knows that the rental of Plaintiff's lot
is subject to monthly rental payments.
16. This is an action to evict Defendant from real property owned by Plaintiff.
17. The Defendant has possession of the lot as evidenced by the continued presence of the
Mobile Home on Plaintiffs lot.
5
18. The Defendant has failed to pay rent timely from October 2009 and after Plaintiff s
notice of failure to pay rent.
19. Plaintiff is entitled to recover possession of the mobile home lot from Defendant.
20. Plaintiff suffers damage by not being able to collect monthly rent on its lot.
21. While Defendant occupies the lot, Plaintiff is prevented from renting the lot to a tenant
who will pay the required monthly rent.
22. Plaintiff is entitled to the remedies available under the Mobile Home Park Rights Act and
the Landlord Tenant Act, including money damages and recovery of possession of the
real property from Defendant.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant judgment in its
favor in the amount of $1,551.21, plus additional rent, late fees, and utilities that may come due,
plus costs and interest as well as granting exclusive possession of the property to Plaintiff and
ejecting Defendant therefrom.
COUNT II - BREACH OF CONTRACT
23. Paragraphs 1 through 22 are incorporated herein by reference as if fully restated and
realleged herein.
24. A contract exists between the Plaintiff and Defendant in the form of a written Lease
signed on October 20, 2009. See Exhibit A.
25. The consideration for the Lease was monthly rent paid to Plaintiff for Defendant's use of
Plaintiff's lot.
26. The Lease requires that rent is due on the 5th of each month, paid monthly in advance,
under the "Registration and Rent' 'heading. See Exhibit A.
6
27. The Lease imposes late fees for the payment of late rent.
28. Defendant has failed to pay the required amount of rent for October, November and
December of 2009 as required by the Lease.
29. Plaintiff's damages are illustrated through an accounting of Defendant's payments
resulting in a total amount of $1,551.21 in rent, utilities and late fees. See Exhibit C.
30. Defendant continues to incur rental costs and late fees with each subsequent nonpayment
of rent as required by the Lease and as of the date of this Complaint.
31. Plaintiff suffers damage by not being able to collect monthly rent on its lot.
32. Plaintiff is prevented from renting the lot to a tenant who will pay the required monthly
rent while Defendant occupies the lot.
33. Plaintiff demands payment under a theory of breach of contract in amount equal to the
appropriate rent and late fees due to Plaintiff, in an amount equal to the accounting shown
on Exhibit C subject to later rent and late fees that come due.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant judgment in its
favor in the amount of $1,551.21, plus additional rent, late fees, and utilities that may come due,
7
plus costs and interest as well as granting exclusive possession of the property to Plaintiff and
ejecting Defendant therefrom.
Respectfully submitted,
BY: J"z '?). Dated: a Y -;?OlCl
GCFTHIEfVAN ALLEN LLC
Joseph N. Gothie, Esq. PA I.D. No. 80390
Moshe Bell-Jacobs, Esq. PA I.D. No. 210233
111 East Market Street, Suite 101
York, PA 17401
V: 717-848-8455
E: jng@gvafirm.com
8
VERIFICATION
I, Leanne Heller, Operations Manager of ?i ?G (J? 51- hereby
verify the facts as set forth in the ' foregoing document, as being true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904 relating to unworn falsification to authorities.
The foregoing document is based upon information which has been gathered
by my counsel in preparation of the lawsuit. The language of the document is that of
counsel and not my own. I have read the foregoing document to the extent that the
document is based upon information which I have given to my counsel, it is true and
correct to the best of my knowledge, information and belief. To the extent that the
content of the document is that of counsel, I have relied upon counsel in making this
verification.
Date: 2 lgha a tO
CERTIFICATE OF SERVICE
I certify that I am this day serving a copy of the foregoing, attached document, upon the
person(s) and in the manner indicated below, which service satisfies the requirements of the
Pennsylvania Rules of Civil Procedure § 440.
Service by first class mail delivery addressed as follows:
Geoffrey Biringer, Esq.
MidPenn Legal Services
401 E. Louther Street
Carlisle, PA 17013
Date: o2K ;W
) _,
GO AN ALLEN LLC
Joseph N. Gothie, Esq. PA I.D. No. 80390
Moshe Bell-Jacobs, Esq. PA I.D. No. 210233
111 East Market Street, Suite 101
York, PA 17401
V: 717-848-8455
E: jng@gvafirm.com
A
01/29/2010 12:01 17176973938
COUNTRY MANOR WEST
NO. 2, APPLE ALLEY
GARLI5LE, PA 17013
Phone: (717) 497-0900
COUNTRY MANOR WEST
Manufactured _Home Community Lease
a- & 0% aft I&MERAIr mow
PAGE 05/12
e--,20Q?.
jck
LEASE BEGINS: day of
LEASE ENDS: day of 0 do6e- ,20 4 c? •
LANDLORD Is COUNTRY MANOR WEST
AXENANTS
a4 &Arlngaui
B. LEASED PROPERTY ADDRESS IS:
I el ra '! na c t t" , tA "10,5
a t Jr1 L 0.i _?r
C. TERM OF THE LEASE IS:
D. THE LEASE AMOUNT IS $?. iio r cb per
month.
E. MOVE IN DATE. The tenant will move In
on: ?? I vco 4
COUNTRY MANOR WEST PAGE 06/12
01/29/2010 12:01 17176973938
COUNTRY MANOR WEST
NO. 2. APPLE ALLEY
CARLISLE, PA 17013 RULES, REGULATIONS AND AGREEMENTS
REGISTRATION AND RENT:
1. Sy state law, all residents will be registered at the County Tax Office.
2. Residents may not sublet the premises or any portion or part thereof.
3. Rent will be coileoted on the 711h of each month at the Office, paid monthly In advance. Residents ash occupying promisees any portion of a month shall constitute a full month rental Cd for late Pa payments ? tP> d
9 A.M. to 4 P.M. Monday through Friday. A charge of $1.00 per y will be adde late charges are not paid with We rent payment, a $10.00 billing charge will be added to the late charge
invoice.
4. Only those who are replslered at the Office are permitted to live in the home. Guests living in the
home over 15 days must register in the office.
5. No more than five people per home are permitted.
6. The home must be the owners principal residence.
Country anon
PETS:
in order to minimize any Inconvenience to the community residents resulting from pets, In the
West has adopted a strict pet polloy. There are no exceptions to this policy. Pets are PermftW
a be rsvdked,
community as a privilege for tie residents. in accordance with this poky, This his ptinotvi o totl mAY
on an individual basis, at the discretion of Community Management it this policy is .
Residents are advised that failure to adhere to this policy could lead to legal action, which may include
eviction from the community.
1. Then is a maximum of two pets per household allowed.
2. Aggressive breeds of dogs, Including, but not limited to, Pit Bull Terriers, Doberman Pinchers and
Rottwellers are not permitted. Any pet that demonstrates aggressive behavior of any kind in the
community, toward an Individual or another animal, will have to be removed from the oommunity
permanently. (even if the owner is present), or left unattended at any time.
3.
Pets are not permitted to run loose It the community. Pets must be indoors at art times, except when
secured by a leash and walked by their owner. inlu the lots and
4. Residents are required to clean up after their pets anywhere W?? ^ property, Incleddi disposed of an
the
common areas. Pet droppings must be picked up ??
residents garbage can. of othe 5. Pots that disturb the peace of the commurifty, are the
be removed from the common ty upon receipt of noticerom the Community
prove to be a nuisance must
Management. milted.
6. Animal sitting is not per
7. Pet shelters are strictly prohibited.
OTHER CHARGES:
1. Each resident is responsible for the cost of the water they use. Rates are established by Middlesex
Township, and each residers consumption will be determined by actual meter re ngs. he The quarterly
_
minimum will be paid monthly in advance, and excess usage will be billed quarterly. Interst
assessed on any unpaid portion of your water account. The Inte st rate Is 1.5% per mot once unpaid
balance. Each lot will be equipped with a water meter, which is park property.
responsible for loss 01, theft or damage to the water meter.
2. TV cable, water Yne and sewer tine repairs other than INITIAL INSTALLATION are the resident's
responsibility. Damage to these Items will be repalred or replaced at the resident's expense.
3. Any electrical service Provided during placement of a home is adequate for that home of tthe hat time. If.
additional service or repairs become necessary, resulting charges are the responsibility
Cplk1TRY MAh10R WEST PAGE 97/12
01/29/2019 12:01 17176973938
4. New residents must place a $100.00 security deposit upon registration in accordance with the
Landlord & Tenant Act of 1951.
5. h certified letters are written due to rule violations, a fee of $,20 wi i be charged,
6. A tee of $20 will be oharged for checks that are returned by the bank,
7. A SM minimum tie Will be charged for each lawn-cueing by Country Manor. charge of ffi38
s. TV reception problems will be checked at your request. If the TV set is the problem, a per hour will be charged. The resident is responsible for TV cable maintenance on their lot.
r store at an extra charge.
9. Campers, boats, travel trailers. ancer, health in camper
of he community. Country Manor West
10. In order to maintain the appea The tysquency of home
reserves the right to conduct an Inspection of any home in the community. nc will include the
Inspections will not exceed one Inspection per home in a two year period. The Inspect
enterla appearance of the home and shed, and the condition of the horrw's utilities. Any substandard
Items will need to be corroded in a speolfled time frame, should the resident wish to keep the home In the
oommuniy. The fee toy this inspection will be $60.00, and will be charged to the resident at the time of
the inspection,
11. Fees ees stated herein may be increased, subjeot to 30 days prior written notice.
LAWN AND WATER: and toilets
1. ft shall be the resident's responsibility to maintain sewer and water fines. Leaking spigots
must be repaired Immediately to avoid sewage One freeze. items
2. Do not flush anything down your drains such as rags, clothes, hard paper. sanitary napkins or
made of plastic or rubber. Such items should be wrapped in paper and deposited in garbage cans.
3. No we" or swimming pools are permitted. A oommuniy pool membership is Included with the rent.
4. Lawns must be kept neat, dean and mowed to a hoot of three inches at all tines. The management
$20.
reserves Garden ra? may be used to water shrubbery and flowers.
TRAFFIC AND VEHICLES:
1. SPEED LIMITS and STOP SIGNS must be OBEYED.
2. NO repairing vehicles, changing oil or overhauling. Immobilized, disabled, un•inspected, unlicensed or
unwed vehicles shall not be permitted, and must be removed witl5 days. bs, go-carts) within
3. Operating unconventional vehicles, (i.e. mint bikes, dune buggies,
Country Manor property Is prohibited. k third
4. Each lot has adequate parking for two vehicles. Families with more than two vehicles must par
may, m their O a third expense, expand wit
vehicle by the mail boxes. Street parking Is prohibited. Residents
accommodate
size of their parking area with asphalt (stones are not acceptable)
consult management for parking specifications. No Commercial or larger than 112
tan require truck parking a kbuilding is permit-, permitted. Parking vehicles on patios is prohibited.
EXTERIOR IMPROVEMENTS: 8 must 1. All banes must be skirted.
Now home sales and Prwwnad home mule
g Mas to or Everlook brand made exclusively for mobile haomes. Hitches musSKIRTING similar or egUA1qual o
be removed when installing vinyl skirting. acts for mobile
2. METAL AWNINGS N must be i musor i paned and have plywood rool,l drip edge Pm ducts sides, AWNINGS home rise. WOO
shingles, 4'*** gutters and down spouts.
3. STORAGE SHEDS: Each resident must have one, tree standing on their
or equal to Astklns or
permitted 10' x 1 W. Smallest size permitted S' x V. They must be
Lantz Bams, of plywood construction, painted, with shingled roof, and must be Installed before
occupancy. If a larger shed is on the lot during resale, consult Office for any approval. Residents may also
install = resin shed (in addition to, but not in place of the tree standing shed referenced above). Resin
sheds must be permanently secured to the home or the tree standing shed, and should be installed in the
rear of the home or lot.
4. NO ADDITIONS constituting living space, either homemade or factory-built. can be added. Exceptions
are awnings and screen and/or glass rooms. No carports permited.
PAGE 08/12
01/29/2810 12:81 17176973938 COUNTRY MANOR WEST
5. WINDOW AIR CONDITIONERS must be Installed whh wall-mounted supports: No wooden framing from
ground level NO INSTALLATION ON THE STREET oSIDloEsWINDOWS.
anting trees, etc., due to underground such 8. Consult Management concemirtg Improvertw nted b
wiring. Shrubbery must be planted five feet oft street to allow for snow removal. AN shrubbery P18by
residents shell become the property of the park and may not be removed.
7. PAINTING: Your home and adjacent st Wures, if repainted, must be similar to current mobk home
manufacturer color selections or approved by Management. t
S. Item #1 through #7 "'ire a Country Manor BUILDING PERMIT prior to start of improvemen.
UPKEEP: appearance Is considered In
1. Any home or adjacent structure not presenting a neat and well-maintatnsd violation of park rules. Upon receipt of written notice of the violation, should the homeowner fail to
address the vlolaition in the time frame specified, the home will be considered in violation again, and must
be removed from the community
2. No antennas of any kind shall be Installed on or near your home. C6 antennas may be Installed on your
shed, but no higher than home roof.
3. Nothing may be stored on the patio or around the outside of your horns. Place items in storage shed.
4. Any damage to the concrete patio, driveway, lawn, electrical, TV cable, or loss of shrubbery and tree the
shah be the resident'e responsibility. Any Items neglected will be repaired or replaced at the resident's
expense.
5. Country Manor is responsible tot the normal maintenance of your yard light. Call the Office If N does n
light. It you have changed the yard light to a different style Country Manor West will not be responsible for
any maintenance on it.
LAUNDRY:
t. Clotheslines are prohibited, except circular clothes trees, which must be Installed at rear o home.
GENERAL: in a trash can with bid. Trash
1. (fly Houeetnokl crfl 1t?4 will be c onected once a week. it must be kept
furniture and appliances are not
collection fee Is included in monthly rent. Grass clippings, tires, batteries,
collected with the household garbage.
2. No fences permiffed. Concrete blocks are not allowed for use as steps.
S. Any home left abandoned and vacant for 30 days is a violation of these rules. Each subsequent 30 day
period that the home is abandoned and vacant will be considered a new violation.
4. Residents are responsible for the actions and behavior of their children, guests and pets.
5. Any behavior which disturbs the peace and tranquility of the community is prohibited.
talc
6. Any violation of federal, state or local laws and Country Manor West, olting In a imiedem ry Manor West will be
conviction, or occurring on the props y
fired a violation of these rules. Each occurrence wait be considered a new violation.
7. Operating any type of business Is prohibited in the community.
e. 88 guns, pellet guns, air Atlas, slingshots or shooting of any kind are prohibited in the community.
9. Sa Se e work ocompleted at the
outdoor exe?rcisefethe resident must be quipment are prohibited. within 30 days.
10. Ya P
STORAGE:
1 All campers, boats, trailers, etc., must be stored In the provided parking area or off community prop y.
Storage No not included In the rent. tacked, 2. Horne Heating Fuels. Firewood or around your homeUm size pile 4? wide x' high. Kerosene Is not
permitted to be stored on the pa
SWIMMING POOL:
1. Rules, hours and fees are posted at the pool.
RESALE:
1. Under Section 11 of Act 261, park residents are free to sell their homes to a buyer of their choosing.
COUNTRY MANOR WEST PAGE 09/12
61/29/2810 12:01 171769739343
However, Country Manor West reserves the right to screen and approve any Buyer prior to settlement, it
the home is to remain in the community after the sate. The application for residency must be submitted by
the Buyer at least 10 days prior to settlement, and the applicant must be approved prior to closing on the
home. N the ti eocorm?munitt community, and he home must be removed is valid, but the immediately uponMr will
not be considered a resident
settlement.
2. One "For Bale sign may be placed In your window or front yard, The maximum size 18" x 24", similar to
the standard sleet real estate sign.
3. All homes must have a utlky shed. See STORAGE SHEDS, EXCEPTIONS approved by Office in
writing for these storing NOTHING outside.
4. No home may remain In Country Manor If sold on a "gales Agreement." Buyer must submit proof of
ownership, such as a title.
SECURITY DEPOSITS: in accordance with the Landlord Tenant
i. Security deposits of slim must be paid at time of occupancy
Act of 1951. '
2. REFUNDS will occur only when (a) a 3May WRITTEN notice is received by Management prior to
venting Country Manor; (b) all hams as outlined In form "Instructions for Moving a Mobile Home" or
'Resale Residency" are completed.
AGREEMENT.
1. Any signature affixed hereto by resident shall constitute an obligation upon all members for their
immediate family and guest.
2. Rules & Regulations will be amended periodically and will be posted in the country Manor West
Management Office- Amendments shall become a part of this agreement. The rights and duties
expressed in Act 261 "Mobile Home Rights Act of 1976" apply to your residency at Country Manor.
3. Residents are requtred to comply with the Rules, Regulations and Agreements. Any breach of these
rules may result in a warning notice with a specific time frame in which the resident must retum to
compliance with the Rules, Regulations and Agresmerits. If the resident does not return to compliance
within the spectiled lirm frame, each additional day of violation will be conaidered a now violation. Eviction
proceedings may commence if a second or subsequent violation occurs with a six month period from the
date of Initial notice.
4. Country Manor shall not liable for any damage or injury which may be suetafned by the resident or any
other person, as a consequence of the failure, breakage, leakage or obstruclion of water, sewer, waste,
TV cafe, or the electrical, gas or oil system; or by reason of the elements; or resulting from the
carelessness, negligence or Improper conduct on the part of any other resident's or other resident's
agents, guests, licensees, invitees, or successors; or attributable to any Interference with, Interruption of
or failure, beyond oontrol of Country Manor or any services to be furnished orsupplied Country Manor.
Resident must obtain the necessary insurance against those contingencies.
I/We have read the forgoing Rules & Regulations and agree to become a resident of Country Manor,
accepting
said Rules & Regulations. WV9 agree that all said Rules Act No Regulations shall be part of rental agreement.
UWe aoknawledge receipt of the attached copy o ? ???--
Date
4-
Landbrd
Tenant
Mrs.
,.___---..?..?_..._ .--
Tenant
Rev. 3/22/01
01/29/2010 12:01 17176973938 COUNTRY MANOR WEST PAGE 10112
IMPORTANT NOTICE RECIUIREp BY LAW
ACT NO. 261
MORE HO SPAASET pW p K THE, L W ORES Al. OF THEESSEE ?.ESLIME MR ANND R! ONABI ?E. EEMENT WITH THIS
"YOU MAY CONTINUE TO STAY IN THIS PARK AS LONG AS YOU PAY YOUR RENT AND OTHER REASOW&E FEES,
SERVICE CHARGES AND A88ESSMENT9 HEREINAFTER GET FORTH AND ABIDE BY THE RIM OF THE PARK.
ENTRANCE AND EW Y NOT 9E 00LAOED. INsTALLAT10N AND svmoVAL FED MAY NOT BE CHARGED IN
E71CEI6e OF THE ACTUAL ir'?T TO THE HOME PARK OWNER OR OPgIATOR FOR PROVIDING 9UCN SERVICE FOR
re e&
THE WTAU.ATION OR REMOVAL OF A MWI F. IN A FILE HOME APACE.
pROCRIDINGS AT ANY 11Ma srr n... w _ -- - - •- - ACCUSED OF VO ATINtG ARE. NOT
'YOUSHALLN)TVIE, ND WHEN THERE I$ PROOF THAT THE RU SSA NOANRREE ON THE PARK PR?113E8.
ENFORCED WITH TO THE OTHERMOBILEHome RESIDEIJt ---..- _- ^^&AU=L4%en At-""T YOU UNTIL Y
9E IM?IATELY STAfiTCU nw+?? • "".
?? ARE. ENTITLED ? pg gERVICES FROM A SELLER OF YOUR CHOICE AND THE PARK OWNER
SHALL NOT RESTRICT YOUR RIGHT TO DO F YOU DESIRE To w" YOUR M I°ONL +E?rrnG, UNLM THERE PEXISTARK A ESERPAAAinEW? _rnN Y AND MAY
I
NOT CLAIM ANY FEE N CONFIlGT
THE MOgU HOME PARK OWNER MAY RESERVE THE RIGHT TO APPROVE THE PURCHA AS A RESIDENT
IN THE HOME PARK.
YOU
IN THE EIG M 7F A ALE HOME PARK RIGHTS ACT IS 0Y THE ATTORNEY G040 ML OF THE COMMONWEALTH OF MAY LSO A P?AATEE CAUSE OF ACTIIONN- HYOUR ROHTS ARE IVIIOLAT® MANY COITAC7 THE TSTATE
9UREAU OF CONSUMER PROTECTION OR YOUR LOCAL DISTRICT ATTOfi
r
Ten anl 81GNATURE? °=-o4 - , _ ---------------------
Tenant ___ -
Tenant SIGNATURE ----_____ ----
DATE;./i_- ------------ ---- --
'YOU MAY III EVICTED FOR ANY OF THE FOLLOWING REASONS:
t NONPAYMENT OF RENT. VK)UITKTIV OF THE RULES OF THE MOBILE HOME PARK OCCURRING WITHIN A SIX-
A SECOND OR SUIIII tIT
IrIONIFFHTHERE IS A CHANGE IN USE OF THE PARK OR LAND OR PARTS THEREOF.
TERMINATION OF MOVU HOME PARK.
.....,^^amaur-c wlTu THE FOLLOWING PROCEDURES:
8
01/29/2010 12:01 17176973938
V0UN'ft1Y MANOp QVUST
2 APPLE ALLEY
CARII$LE. PA 17018
Ricky Seschrist
126 Peach Lane
CarosW P A 17015
Country Manor West
P.A.N.: SK9140
Lot No. 126
October 15, 2009
Dear M. Seachriat
COUNTRY Mi
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TOM r aftle f911%y brdaehrisl
12sPeech Leme
C arliste PA 17013
Our Records Indicate that, as 01 WW j you have a past due balance 01 1993.64
Your balance may not inhale all late dwg9e nce, and tlydu a on your total balance due l you ha iatnoyt. already dorms so,
please contact #m otw0e to verify your of rent
Until your payment lsreoeWd. you are hereby issued 9Q days npllce of eviation*for non-payment
You are furllur advised that another n 1??bn for you rttrnad?iately; further written notk:ess not requ months Is sufficient
cause to the a Landlord/Tenant
Landlord/Tenant action may be tiled,
It you have received an eviction notice 1KJ?1GB 10 ?? das no a ! deHrY teneiord/Tertarr! proceedings,
whether you receive this notice or not. Receipt
moPiling against you will result in additional charges
if you haw rwetved a Rl from the community.
to you, and could lead your eviction
Thank you for your prompt attention to this matter.
Sincerely.
COUWRY MANOR WEST
7004 0080 0001 9804 6866
a*
!niiiSyY'h;i
r wPOI7?rNb
G
01129/2010 08:34 17176973938 COUNTRY MANOR WEST PAGE 03/03
__-..,.._....,_....._,_.._-,.._
Statement of Account ?. COUNTRY MANOR WEST
Statement Dade : AaM
Ricky Seschrist Country Manor West, Lot No. 1n
120 Pesch Lane Account No. - BKRM
Carlisle PA 17013 Eviction Letter Issued,
Security Deposit tIQ oa 4a*Peld:
Re:
X1,R
??u?t Balar148 m
psy ant= M-onthty GLUM
Date Che*N.o. No. Amount Fixed Chip Lki ies Late Feell)W
Jan 5, 19
Feb 2
'09 252
2!8 x371100
$371.00
January
$371.00
$0.00
,
Mar 2,179 264 $1371.00
0371.00 F*mojy 8371.00
00
W 30.00
3000
APA"
'09
May 4 271
273 WAD March
April .
8371A0
1000
,
Jun 2,'09 283 $
V1.00
M
3 M May 037100 00.00
JU 2. IN 288 .
5371
00 Juno 8M.00 sm
Aug A, W 288 .
$W= July 4371.00 10.00
SM 14, M
Nov 84, TO 300
W
010700
=34
Au"
~
037100
svi-00
OD.00
Doc 14.'09 V497. Baird Lindsey 8 Sep 1371.00 x4 14100
Dec 21,'09 334 November 3371.00 s o0 $600
December 5371.00 SD.00 $410
1'M At"
Total
kkb.kr hmi -moo tern AMOW
Dwember22, 2009 Fllinp Fee $126.75
Total Other ChrP lCrdta
Stetting 9alance $0.00
Total Fixed Ctwgeta $4,452.00
Total l1NPdiss $322.54
Total LOW Fear $128.00
Total Other Oharges & Credits $126.75
Lma toW 31*1.64 ?
Total Salome Due 1,1477
COUNTRy MANOR WEST PAGE 02/03
01/29/2010 08:34 ,17176973938
Statement of Account COUNTRY MANOR WEST
Statement Date : AN 29.2010
Ricky Seschrlat Country Manor West, Lot No. 12$
120 Peach Lane Account No. - SK AM
Carksle PA 17015 Eviction Letter Issued Oct t5- M
Security Deposit: S1Q%QQ Date Pall : Q'QQ
R*:
??,n° Aeeoun Balonc? ¦ ?--?
Daft Chol*41.0. No. Amourwl Fixed Chrgs UTA " Leta FO LOW
January WIDD $6.45 11KOO
February
Marsh
April
May
June
July
MrgUtA
Sept~
Oaober
NOV~
December
BOA
Total IV=
0-MMI WI item Amount
Total other Chrge &Crdte
&Mgdsum rov.
Starling 9alancs $1,147.75
Total Fixed Charges $371.00
Talai WON 50.48
Total Late Pees $24.00
Total Other Gharges & Credits
;.!se. TM Eswwtiii <
Total salonae Pue S t, 6 i. Z
OF �U
'If
1Davit1cD. Buell 41i47. e knee R Simpson
Prothonotary 1St Deputy Prothonotary
Soho rk e, Q
\, �
"
nag Irene E. Morrow
Kis. �E,S
Solicitor ,750 2n'Deputy Prothonotary
Office of the Prothonotary
Cumberland County, Pennsylvania
�Q —69s ' 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, PA 17013 • (717)240-6195 • 'Fax(717)240-6573