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Home My WebLink About10-1422 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS Judicial District, County Of NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case referenced below. I I q- / -a2. 1 &-4-err ADDRESS OF APPELLANT ? 1.11 T . u r 1-7b 2- ! rl' 70 DATE OF JUDG""T Ni TH CASE OF (Plsinfi0) 1 Sil 1 ;eel wt 0 ?1 irlAAA.Pit•C.f Cv Dobd T'47-&7 This block will be signed ONLY when this notation is required under Pa. R.C.P.D.J. No. 10086. This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgment for possession in this case. Siy Wum of FVodxw otary or Deputy was before a District Justice, A COMPLAINT MUST (20) days after filing the NOTICE of APPEAL. in action within twenty PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary ?Q Enter rule upon Cd f t (?C appellee(s), to file a complaint in this appeal L ! , Name of appedee(s) (Common Pleas No. C N) within twenty (20) days after service of rule or suffer entry of ju ment of non pros. sow," of t or ey or agent RULE: To C Kai 4tt_t?j HA appellees) Name of appedee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing Date: of & 6q , 20 /0 Signatu?e or orafary w YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-02 WHITE -COURT FILE TO BE FILED WITH PROTHONOTARY GREEN - COURT FILE YELLOW- APPELLANTS COPY PINK - COPY TO BE SERVED ON APPELLEE GOLD - COPY TO BE SERVED ON DISTRICT JUSTICE PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF , ss AFFIDAVIT: I hereby (swear) (affirm) that I served ? a copy of the Notice of Appeal, Common Pleas , upon the District Justice designated therein on (date of service) 20 , ? by personal service ? by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) , on ,20 ? by personal service ? by (certified) (registered) mail, sender's receipt attached hereto. (SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF -,20 . Signature of official before whom affidavit was made Title of official My commission expires on c?`_ -f ` cv,) ate C\j - ? n 6'b LLI iE Co LL1 LA irr !.l.i H Ls.- - ° R= p ? v 20 Signature of alfiant COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag. Dist. No.: 09-1-02 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS HrUMML, CHAD, El-AL. Nu-w,e -l 1714 MAPLE ST NEW CUMBERLAND, PA 17070 MDJ Name: Hon. ROGER A. ESTEP Address. 1901 STATE ST CAMP HILL, PA Telephone: (717 ) 761-0583 17011 ROGER A. ESTEP 1901 STATE ST CAMP HILL, PA 17011 THIS IS TO NOTIFY YOU THAT: FOR PLAbINTIFF Judgment: (Date of Judgment) 1/28/10 ® Judgment was entered for: (Name) HUMMEL, CHAD, ET AL . Judgment was entered against. (Name) SHEAFFER, TAMMIE K in the amount of $ 1'736.50 Defendants are jointly and severally liable. Damages will be assessed on Date & Time This case dismissed without prejudice. Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judgment for physical damages arising out of residential lease S Amount of Judgment $ 1,650.00 Judgment Costs $ 86.50 Interest on Judgment $ - Attorney Fees $ Total $ 1,736.50 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. "'? 7? I 7?? /Gate -?' agisterial District Judge I certify that this is a true and correct copy o the record of the proceedings containing the judgment. Date My commission expires first Monday of January, 2012 L J VS. DEFENDANT: NAME and ADDRESS rSHEAFFER, TAMMIE K 1002 BRIDGE ST APT/STE 100 NEW CUMBERLAND, PA 17070 L J Docket No.: CV- 0000447 - 09 Date Filed: 12/01/09 , Magisterial District Judge SEAL ACPC 31E--071 DATE PRINTED: 1/28/10 3:33:00 PM .~ ~ ~ -..y, p ...0 Postage $ ,,p ~ , ~~~~ ~--nn~~s 20f0 MAR - I PM 4~ ~~ Certified Fee ~'- vf' \ ~ ~ Return Receipt Fee '~•?. •''•I) r- Here VIJ~l7i't"tL'~~~I„j (at~Ul ~{ 1 1 O (Endorsement Required) (~ u`,``:; o `~ ~ PE(dNSYLV~1(A Restricted Delivery Fee ~I I, I11) ly\. " \ J, 0 (Endorsement Required) , ~ e U ~ - fl ~ Total Postage & Fees ~ ~~~ ~ 5~ 1- `' - L - O ~ Sent To J '- f~ ,(~ p Street, Apt o.; l ~~ n~~ /e C1L Ciry, f te, ZIP+4 ~ ~l~ / t/- ~ ~~~!\ Qom) ((~~. V :~~ ~~. PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check appiicabie boxes.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF C~,,,,~ p~~G„ao~ ; ss AFFIDAVIT: I hereby (swear) (affirm) that I served a copy of the Notice of Appeal, Common Pleas /~ -/~/~.~ ,upon the District Justice designated therein on (date of service) ~~ ~ , 20 y~' v , ^ by personal service ^ by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee. (name) ~ ~. ~ .1 , on ~~ 1 , , 20~('~ ^ by personal service by (certified) (registered) mail. {--r- __.__._ sender's receipt attached hereto. -- /~-' (SWORN AFFIRMED) AND BSCRIBED BEFORE ME ..- ~~~.- - .C4- r~ f THlS ~ DAY OF , 20~~. ~ Signature of affiant Signa ure o1 ofricial de ore wh vi: tivas made Titte o/ official '` ~ -ti. ~w ~~~ ~ -~ ^ ~~ My commission ~Icprr~3 bn ~ ~ , 20 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL • Judicial District, County Of ~ly~~'~(~,D FROM DISTRICT JUSTICEttJ/U~ DGM~EtNT / COMMON PLEAS No. i V ~ 17 ~ t- ~ ~' NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case referenced below. NAM Of APPELLANT . L~ MAG. DiST. NO. OF D.J. DRESS OF APPE ~,,~` CITV /~ ~ ~ ~ ~/ ~y + T l-'7 ZIP CO/DES D TE ~ JUDGM NT ~ _~ IN TNT CASE OF (PMinfilP) ~ ~ ( r,.. .rte ~1-'t Y`kt.~..' `'f ~ ~ ~ t~ ~ ~~.~,ti,(_,(/[•(.-i~'_. .~". • (,:tic YE ET No. SIGNATIAtE OF APPELLANT OR ATTORNEY OR AGE r,.. ~, ~ (..-/ notation is required under Pa. This block will be signed ONLY when this If appellant was Claimant (see Pa. R. .P.O.J. No (6) in action R.C.P.D.J. No. 10088. This Notice of Appeal, when received by the District Justice, wit{ operate as a before a District Justice, A COMPLAINT MUST LED within twenty SUPERSEDERS to the judgment for possession in this case: (20) days after filing the NOTICE d APPEAL. SipAafw- d Piotl~onohry arOegAy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be u§ed ONLY when appe/iant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary ~ x t ~` `'t'(,~(, (,1,tvt.f.~ Enter rule upon ~,~/'l ~{ C~ t_. + CG appellee(s), to file a complaint in this appeal / ,I~ / ~ / Name of appejNee(s) (Common Pleas No. S t/ ° / 7 "~ ~. ~' f'`~ 1 r) within twenty (20) days after service of rule or suffer ern4ry of j ent of non pros. l I +~'-` !~. ~: .. ~ . .: i -' ..... 57gna(ws of t By oragent RULE: To ~E( -~-~ ~ (-c! (,.~ ~ ~.. C~7P''appellee(s) .~ ~~ ~ ,_ Nana o,appeUee(s) (1) You are notified-that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20j days after the date of service of this rule uponyou by personal service or by certified or registered mail (2) N you dQ t-o# file a'eSOmplaint within this time, a JUDGMENT OF NON PROS MAYBE ENTERED AGAINST YOU. (3) The date,gf~setvlce of,this rule if service was by mail is the date of the mailing. ,~ `" ~ Date: '~' .•• p~: ~r ~ ; 20 ~U' Signetwe orPiotlronotary or YOU MUST INCLUDE A COPY OF THE NOTICE OFJUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-02 WHRE-COURT FILE TO BE FILED WITH PROTHONOTARY GREEN -COURT FILE YELLOW -APPELLANTS COPY PIN1t -COPY TO BE SERVED ON APPELLEE GOLD -COPY TO BE SERVED ON DISTRICT JUSTICE CHAD HUMMEL AND IN THE COURT OF COMMON PLEAS NINA HUMMEL, CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF NO. 10-1422 CIVIL vs N C TAMMIE K. SHEAFFER ~=.. ~_ ~ DEFENDANT CIVIL ACTION LAW ~ ' ` -- ~' ~_ ~o ~~~:.; _a f ., NOTICE TO DEFEND ~::'. rv ~~ ~~ _ YOU HAVE BEEN SUED IN COURT. If you wish to defend againstthe claims set forth in the fo~wing 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOTAFFORD 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA (717) 249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notification de esta Demands y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falls de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier sums de dinero reclamada en la demands o cualquier otra reclamation o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes pars usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHAD HUMMEL, and NINA HUMMEL, : PLAINTIFFS DOCKET NO. 10-1422 civil v. TAMMIE K. SHEAFFER, : DEFENDANT CIVIL ACTION -LAW COMPLAINT WHEREFORE COME NOW PLAINTIFFS, Chad Hummel and Nina Hummel, by and through their counsel, Tabitha D. Phillips and J. Palmer Lockard, Esq., on the ~~ day of March, 2010 and aver as follows: 1. Plaintiffs are Chad Hummel and Nina Hummel, married adults both residing at 1714 B Maple Street, New Cumberland, PA 17070. 2. Defendant is Tammie K. Sheaffer, an adult with a listed address at 1002 Bridge Street, Suite 100, New Cumberland, PA 17070. 3. On or about July 26, 2009, the parties entered into a lease agreement pursuant to a lease abstract (hereinafter "Lease Abstract") provided by the Defendant. A true and correct copy of the Lease Abstract is attached hereto, incorporated herein and marked as Exhibit "A". 4. The leased property (hereinafter "Property") is situated at 233 Walnut Street, Lemoyne, Pennsylvania 17043. 5. On or about July 26, 2009, Plaintiffs gave Defendant a cashier's check in the amount of Eight Hundred Twenty-Five ($825.00) Dollars to be applied towards the security deposit pursuant to the Lease Abstract. A true and correct copy of the cashier's check for the security deposit is attached hereto, incorporated herein and marked as Exhibit "B". 6. On or about July 26, 2009, Plaintiffs gave Defendant a cashier's check in the amount of One Thousand Six Hundred Fifty ($1,650.00) Dollars to be applied towards the first and last months' rent pursuant to the Lease Abstract. A true and correct copy of the cashier's check for the first and last months' rent is attached hereto, incorporated herein and marked as Exhibit "C". 7. On or around July 28, 2009, the parties entered into a written lease agreement (hereinafter "Lease Agreement"). A true and correct copy of the Lease Agreement is attached hereto, incorporated herein and marked as Exhibit "D". 8. Pursuant to the Lease Agreement, the term of the lease was to begin on September 1, 2009 and terminate on August 28, 2010. See Exhibit D. 9. On or around August 29, 2009, pursuant to a verbal agreement between the parties, Plaintiffs endorsed two cashier's checks in favor of Defendant, each in the amount of Twenty-Five ($25.00) Dollars, as pro-rated rent for the days of August 30, 2009 and August 31, 2009. True and correct copies of the cashier's checks for the pro- rated rent are attached hereto, incorporated herein and marked as Exhibit "E". 10. On or about August 30, 2009, Plaintiffs moved into the Property. 11. On or about September 1, 2009, Plaintiffs discovered that the Property was infested with fleas. 12. On or about September 4, 2009, Plaintiffs notified Defendant of the flea infestation, requesting that the Defendant cure the problem. 13. On or about September 4, 2009, Defendant told Plaintiffs that she believed steam cleaning the carpets was sufficient to eradicate the flea infestation and refused to sign a contract with a pest control company or get an estimate. 14. From about September 1, 2009 through September 17, 2009, Plaintiffs took multiple measures to eradicate the flea infestation in the Property. 15. On or about September 10, 2009, Plaintiffs notified the Defendant in writing of the extent of the flea infestation, the remedial measures taken to date, and their expectation of a deduction in their October rent for the days that the Property was infested with fleas. A true and correct copy of the September 10, 2009 Letter to Defendant is attached hereto, incorporated herein and marked as Exhibit "F". 16. Photographs of the fleabites Plaintiffs sustained were enclosed with this letter. True and correct copies of the Photographs enclosed with the September 10, 2009 letter to Defendant are attached hereto, incorporated herein and marked as Exhibit "G". 17. On or about September 30, 2009, Plaintiffs made out check number 178 to Defendant in the amount of Four Hundred Ninety-Five ($495.00) Dollars and delivered the same to Defendant's address as payment for October's rent. A true and correct copy of the check register for check number 178 is attached hereto, incorporated herein and marked as Exhibit "H". 18. On or about October 9, 2009, Plaintiffs notified Defendant in writing that the furnace was not supplying heat and that a storm window in the living room could not be opened, and that other specified windows in the Property did not lock and were therefore not secure. A true and correct copy of the October 9, 20091etter to Defendant is attached hereto, incorporated herein and marked as Exhibit "I". 19. On or about October 19, 2009, Plaintiffs notified Defendant of the unsecured and uninhabitable condition of the Property due to missing and boarded-up windows on the Property in addition to a leaking ceiling. A true and correct copy of the October 19, 20091etter to Defendant is attached hereto, incorporated herein and marked as Exhibit "J". 20. On or about October 23, 2009, Plaintiffs again notified Defendant in writing that the furnace was still not heating the Property pursuant to the Lease Agreement. A true and correct copy of the October 23, 2009 letter to Defendant is attached hereto, incorporated herein and marked as Exhibit "K". 21. On or about October 23, 2009, Plaintiffs notified Defendant in writing that they had created a separate escrow account in which the October rent payment would be placed since check 178 had not yet been cashed. See Exhibit "J". 22. On or about October 24, 2009, Plaintiffs vacated the Property due to the uninhabitability ofthe Property. COUNT ONE -BREACH OF CONTRACT 23. Paragraphs 1-22 above are incorporated by reference hereto. 24. Defendant breached the Lease Agreement when she failed to provide Plaintiffs with a habitable Property. 25. Defendant materially breached the implied warranty of habitability when she rented the Property while it was infested with fleas and with anon-functioning furnace, which provided the main source of heat, and by failing to provide locks for several windows in the Property. 26. Defendant failed to repair the uninhabitable Property after receiving written notice from Plaintiffs. 27. The Property was uninhabitable from the first day of the lease term. 28. As of the date of this Complaint, Defendant owes Plaintiffs the sum of Two Thousand Four Hundred Seventy-Five ($2,475.00) Dollars, which is the amount of the security deposit and first and last month's rent. WHEREFORE, Plaintiffs respectfully request this Honorable Court to enter judgment in favor of the Plaintiffs in the amount of Two Thousand Four Hundred Seventy-Five ($2,475.00) Dollars in addition to any other costs the Court deems appropriate. COUNT TWO -UNFAIR TRADE PRACTICES 29. Paragraphs 1-28 above are incorporated herein by reference. 30. Defendant represented to Plaintiffs that the Property was in "good order and condition," when, in fact, the Property was uninhabitable due to a flea infestation, inadequate heat and windows that did not lock. See Paragraph 14 of Exhibit "D". 31. Defendant breached the implied warranty of habitability. 32. Defendant used a Lease Agreement containing a confession of judgment clause waiving Plaintiffs' right to assert a legal defense. See Paragraph 19(d) of Exhibit «D ~, 33. Plaintiffs leased the Property for personal purposes. 34. As a result of Defendant's unfair or deceptive acts or practices, namely her breach of the warranty of habitability, Plaintiffs have suffered a loss of money in the amount of Two Thousand Four Hundred Seventy-Five ($2,475.00) Dollars. 35. Plaintiffs are entitled to actual damages in the amount of Two Thousand Four Hundred Seventy-Five ($2,475.00) Dollars. 73 Pa.C.S. 201-9.2(a). WHEREFORE, Plaintiffs respectfully request this Honorable Court to enter judgment in favor of the Plaintiff in the amount of Seven Thousand Four Hundred Twenty-Five ($7,425.00) Dollars, an award three times the actual damages sustained pursuant to 73 Pa.C.S. 201-9.2(a), but not less than Two Thousand Four Hundred Seventy-Five ($2,475.00) Dollars in addition to any other costs or relief the Court deems appropriate. Date: 'Supervising Attorney J. Palmer Lockard, Esq D # 33681 Widener University School of Law 3605 Vartan Way 2"d Floor Harrisburg, PA 17110 Tel. (717) 541-0320 lawclinichb(a,mail.widener edu Attorneys for Plaintiffs oro ~,~ ~,~ ,.~, r I I ~~^ . ~ ~ Zoo ~ . 7/Z~ /o q ~P+i-1°°~- ~3'~ ~,l (~ S~D ~L~ - ~ s+ ~ Zas i lY1d v~ ~-~, a ~~ ~~ 3 ~~ ~-. J ~ew~ odhe,,~, ! 7oY3 2- ~~~''~`~ '~d-h~ a ~ o `~a-ors ~~'r~ `~ \J,2ar ~~2a~ ~ ~ °~ f ~ 2o~p w~ 1 r va ca.-1~ { ron'' `~-~ sf. o R o~ ~1'.,, n I S f `~~061Z mfn.C-bel~YZ7oY~^ r~,.,,.t.~' Q~~a ~r ~ ~1- e ~e clvKC.~r ~^-~na~c-- ~ - (Z.ec~t rg ~h sura N c2 . l-~ c~.~ afvs4r~c~ I kSC.~ Cxl-~~b~t ",4" MEMBERS 1ST FEDERAL CREDIT UNION . P.O. li. , 40 . MECHANICSBURG, PENNSYLVANIA 17055 ~ NO. 00004452 30 1 Acct: XXXXXXX049 Teller: 1668 Date: 07/26/09Time: 11:28am --------------------------------------------------------- See receipt for reference Check Number: 00 0000445230 Purpose Amount $825.00 Pay to TAMMIE SHEAFFER OR CHAD M HUMMEL Exhibit "g° MEMBERS 1ST FEDERAL CREDTf UMON . P.O. BOX ao . MECHANICSBURG, PENNSYLVANIA 17055 NO. 00004452 31 Acct: XXXXXXX049 Teller: 1668 Date: 07/26/09Time: 11:28am --------------------------------------------------------- See receipt for reference Check Number: 00 0000445231 Purpose Amount $1,650.00 Pay to TAMMIE SHEAFFER OR CHAD M HUMMEL .--- ~X I{Jf~ ~~ C`~ www.Bridl;eStregLRealty com ~x LEASE AGREEMENT THIS LEASE AGREEMENT made this 28th day of July by and behveen Bridge Street Realty, LLC, called Agent for Tammie Sheaffer Hereinafter called KLandlord" and Clod and Nina Huimaal ,hereinafter called "Tenant". N) u ~ L~~fzd c~ w ~/C~ WITNESSETH: R~'~i~ l"' In consideration of the rents and covenants hereinafter set forth and contained on the part of the Tenarrt to be paid, performed and observed, the Landlord does hereby lease unto Tenant, the premises hereinafter described under the conditions set forth herein. 1. TERM: The term of this lease shal be~~ a period of ONE (1) year beginning on the day of September 1, 2009 and terminating on• , 2010, 12:00 P.M. Tenant may move in before fast day of lease, (assuming the existing occupant has vacated the apartment) and Tenant has agreed to pay a prorated rental rent per day (monthly rent divided by number of days in the month =prorated rent per day) due in advance with the first two months rent. Additionally, the Tenant will be responsible for the utilities as of the day of occupancy and will be responsible for contacting the utility companies in advance of occupancy. The fast day of the lease is .Checks may be made payable to Tammie K. Sheaffer, property owner. Prorated rent to be calculates a: $25.84 ger day or for days in August. ` 2. LOCATION: 2 3,~,~a1nu~ met i.emnyne pA_l7, X43,,, one-bedroom first floor apartment with partial furnishings. On-street parking in front of building is not metered. Storage for two bicycles will be arranged under front porch. 3. RE TS: Tenants shall pay Landlord or Agent for the Landlord as rent for the above described r premises, the sum of NINE THOUSAND NINE HUNDRED (59 900) payable in twelve equal ~y~ monthly installments of EIGHT HUNDRED AND TWENTY F r-nr i qRS (581. ner month 1 /-%~ in advance beginning September 1, 2009 and the following month thereafter subsequent to the signing ~l z of this lease. Rent for the month is due on or before the fast (1'~ day of the preceding month. Tenant c~k had provided a Members 1" cashiers check in the amount of 51,650 on July 26, 2009. f> Q ~ ~ ~,~a ~ ~ct60 ~~ ~~ ~h~ Created by T.K.Sheaffer P e t of 6 d a8 ~ X 7/28/2009 S:\233 Walnut Street\Chad and Nina Hummel Apartment LEASE AGREEMENT0807016.doc 4 SECURITY DEPOSIT: Tenant shall be required to provide Landlord at the beginning of the term of this lease the sum of EIGHT HUNDRED AND TWENTY FIVE DOLLARS (~2~ as security for toward the performance of the term of this. Upon expiration of the term of this lease, the Landlord or Agent shall inspect said premises to determine damage, if any, following the removal of Tenant from the property. Any damages to the leased area or any repairs or unpaid utility bills necessitated as a result of the Tenant's use of the leased area shall be done and paid by the Landlord at the expense of the Tenant and deducted from the security deposit of EIGHT HUNDRED AND TWENTY FIVE DOLLARS (5825. This may include having the lock cylinders rekeyed (If keys are not returned or duplicated and given out). The Landlord shall account to the Tenant for the unused portion of the security deposit within thirty (30) days following the expiration of the term of the lease. A 7'W Q ~ HUNDRED AND FIFTY DOLLAR (5250) cleaning fee will be the Tenant's responsibility if the apartment is not returned clean (includes appliances, ceiling fans, and common areas, and removal of ~'~Y all rubbish and personal property and cleaning of the carpets by It's Clean Again by Cathy Carpet. C'+'~ ~ Cleaning. Tenant has provided Landlord with a 5825 security deposit (cashiers check # dated ?' a t 04 Te h as also rovided a check f th f d `fSG.S 23t> "' ~ ~ tn y ~ p or e non-re un able processing fee of 535(cash ). ~( (~ j t S. Additiona~L,a'"st Months Rent Paid in Advsnce• An additional months rent of 5825 will be paid by the Tenant no later than before the first day of the lease which will be applied by the Landlord to the Tenant's Last month of current lease's rent due to the short teen of this lease agreement. This was agreed to by both Tenant and Landlord and pursuant to a discussion with the Tenant due to the short term of this lease agreement. ., .. n. ~ ~ , ~ ~.q.~ ~X4'lihlfi '` l,~(' ~~ (~ ` www.BridggStreetRealtv~r._,0 6. ALTERATIONS: Tenant agrees not to make any alterations, additions, improvements, or other changes to any part of the premises or its facilities without the express written consent of the Landlord. 7 INDEMNIFICATION: Tenant shall indemnify and save Landlord harmless from any liability imposed upon Landlord, adjudicated or otherwise, by virtue of any personal injury or property damage arising from any use of the premises by the Tenant, their agents and invitees, including court costs and counsel fees. Tenant insurance is required. Chris Petrone, Agent for Allstate can be contacted at 717 774 9400. A copy of the insurance is to be provided to the Landlord within 1 day, or August ZS, 2009. ~, REPAIRS: Landlord agrees and covenants to be responsible for any and all major repairs to the exterior of the premises. The Landlord also agrees and covenants to be responsible for all major repairs and repairs of any appliances which are now located on the leased premises, that are not due to the misuse by the Tenant. MaJor repair L defined a: a repair cost of more than 5100. However, in the event that such repairs are necessary due to the negligent acts of the Tenant or its agents, then such repairs shall be performed at the expense of the Tenant. If a fireplace exists, it is the Tenant's responsibility to have the chimney cleaaed annually or be assessed for the chimney cleaning at the termination of the lease. Additionally, the fireplace has been secured with insulation for the winter and during extreme cold weather is best to not be used because the cost of heat exceeds the heat produced. It is very expensive to use the fireplace with the cost of heat today. 9 MAINTENANCE: Tenants agrees to be responsible for snow removal of sidewalk within twenty- four (24) hours. Tenant agrees to use sand not salt during winter months on both asphalt paving and concrete steps and sidewalks. Tenant agrees to hold landlord harmless for any personal injuries that may occur during maintenance activities. Tenant is responsible for replacement of smoke alarm batteries during the term of the lease. Landlord will provide lawn can. Rear yard to be excavated summer 2009 and renovations to garage and basement may commence during tenancy. ASSIGNMENT: The Tenant covenants and agrees not to assign, sublet, or transfer their interest in the premises to any other party not named in this lease without the express written permission of the Landlord. This lease is for TWO Adults and no children only. Any resident for more than S days will result in an additional monthly fce of FIFTY DOLLARS (S50) for each month of residency. There is a laundry hook up for the use of the Tenarrt residing in the apartment ONLY. Should the parties decide to vacate prior to end of this lease, then will not be a refund of rents paid on their behalf l 1. TAXES AND INSURANCE: The Landlord agrees to pay all taxes and assessments levied against the premises during the term of this lease. In addition, the Landlord agrees to be responsible for fire insurance coverage for the premises ineluding the structure of the building. Tenant agt+ees to be responsible for fire insurance coverage on their contents within the leased area. Tenant agress to provide a copy of both their renter's liability and fire insurance polky including a paid in full receipt within fifteen (ls1 days of signing this lease before occupancy on the 889/2009. Additionally, Tenant agrees to provide a copy annually as the insurance policy premium is paid and polky is renewed should tenancy continue paat the one{I) year term ottbis lease agreement. 12. UTiLITiES: Landlord will be responsible for the payme~ of the following utility bills including, water, sewer, anti other related assessments. Tenants will be responsible for payment of 2 ekctrk bi14 and gas for beat and cooking per month, muse, DSL, and telephone during the term of the lease. Tenant will be responsible for securing ail windows including storm doors and windows during the winter months requiring beat. Any utility bills unpaid or placed in Landbrd's name during the term of the kaae as a result of the Tenant's occupancy that have been stated to be the Tenant's responsibility will be deducted from the security deposit. The Tenant is responsible for scheduling and providing access to any needed repair service providers on behalf of tbe Landlord during the term of the kaae. The electric Got water beater is NEW and was installed in 2005. Created by T.K.Sheaffer Page 2 of 6 7n88009 S:\233 Walnut Street\Chad and Nina Hummel Apartment LEASE AGREEMENT0807016.doc ~. ~ j~ ~ ro 4c. ~l~e/mar ~ ~~ ~ www.BridgeStreetRealri.com ~3. ACCESS BY LANDLORD: Tenant agrees to permit the Landlord to enter upon the said premises at all reasonable times to examine the condition thereof. Landlord will enter without informing the Tenant for emergency purposes only. Agent for the Landlord is a licensed real estate broker in PA. 14. SURRENDER OF THE PREMISES: The Tenant covenants with the Landlord that the Tenant has received the premises in good order and condition at the commencement of this lease agreement and agrees to return the premises in similar condition, Tenant will yield said premises in as good order and condition as when the same were rented by the Tenant, with exception of any damage caused by riots, fire, flood, incendiarism, acts of God or public enemy, the elements, ordinary wear and tear and other causes beyond the Tenants control. However, Tenant shall be liable for any repair resulting from negligent acts of the Tenant, its agent, servants, or employees or any other person upon the said premises at the invitation of the T Walk-through pre-inspection sign off sheet is part of this agreement.) The Tenant will insp~ a premises and will acknowledge in writing and accept the condition as acceptable on ~~ Any noted conditions or repairs that are agreed upon will be completed by the landlord within ten (10) business days. WASTE: Tenant agrees to permit no waste of the premises or use the premises for any unlawful purpose. Tenant shall keep the leased area of the premises free and clear of any type of refuse, junk, or other debris. All trash and refuse shall be stored outside the leased premises in appropriate trash containers permitted by local government regulations. Tenant is responsible for one recycle container. If the recycle container is damaged or missing at the termination of the leaso a replacement fee of Twenty DOLLARS (S20) will be assessed for each container. Tenant to provide trash can with lid. Tenant is responsible for placing trash at curb on Monday evenings after dark in garbage bags. And agrees to get the recycle bin as soon as possible after trash pick up on Tuesday in order to avoid the containers remaining on the sidewalks for day at a time. ~s PETS: PET5 ARE PROHIBITTED!!! NO PETS!!!_ ANY ILLEGAL PETS WILL TE INATE THIS LEASE IMMEDIATELY AND THE TENANT WILL INCURR AN ADDITIONAL RENTAL CHARGE OF FIFTY DOLLARS PER MONTH FOR EACH PET! Unless written permission is obtained. SALE. RENT. or MAINTENANCE: The Landlord herein shall have the right to sell the property at any time to any third party without giving notice to the Tenant. Tenant will cooperate with ail property showings as necessary, including allowing a lock box for REALTOR access. These showings may be for the purpose of sale or rental of the building. Entry into the apartment may be necessary for repairs to the building and the Tenant agrees to allow entry by the Landlord as necessary. 1~ EXPIRATION: Both parties hereby agree that either party hereto may terminate this lease at the end of the said term by giving the other party a written notice of at least sixty (60) days prior thereto but in default of such notice, this lease shall continue upon the same terms and conditions as herein contained for a further period of one year and so on, unless or until termination by either party hereto given by the other sixty (60) days written notice prior to the first of the month for removal previous to the expiration of the then current term. However, if Landlord shall have given such written notice prior to the expiration of any term hereby created of his intention to change the tenors, covenants or conditions of this lease; and Tenant shall hold over after the expiration of the time mentioned in such notice; Tenant shall be considered as Tenant under the terms, covenants and conditions mentioned in such notice for a further term ss above described. It is the intention hereof that if the original term shall be renewed or extended, under the terms herein above provided or otherwise, such renewal or extension shall be upon the same terms and conditions of this lease as are effective immediately prior to the expiration of the said original lease. Landlord agrees to terminate this lease if Tenant purchases a property with Bridge Street Reahy, LLC acting as Tenant's Broker in the real estate transaction with the Tenant providing the Landlord with a minimum of a SIXTY (60) day notice from the first of the month. Landlord urxlerstands Tenant is currently seeking employment which may result in a cancellation of this lease prior to the end of this one year lease term. There is no penalty for providing a minimum of sixty {60) days notice to vacate premises from the first of the month, Created by T.K.Sheaffer Page 3 of 6 7/28/2009 S:\233 Walnut Street\Chad and Nina Hummel Apartment LEASE AGREEMENT0807016.doc ~~ y ~/ ~~~FL -~ ~a ~!~ `. www.BridgeStreetRealry.com C~~, 19. DEFAULT: Upon the occurrence of any default such as failure to pay installments of rent when due, failure to perform any teens or conditions of this lease, abandonment by Tenant of the leased premises, or insolvency or the Tenant, the lease shall be deemed to have been breached and thereupon by that fact itself and without entry or other action by the Landlord: a) At the option of the Landlord the rent for the remainder of the tenor of this lease shall immediately become due and payable. b) At the option of the Landlord this lease and term created hereby as well as all the right, title, and interest of Tenant hereunder shall cease and terminate and become absolutely void; Without any right on the part of the Tenant to save and forfeiture by payment of any sum or by performance of any term, covenant or condition broken or defaulted, and the Landlord shall be entitled to recover damages for such event of default in as amount equal to the amount of the rent and other charges reserved for the balance of the term hereof, less the fair rental value of the leased premises or any part or parts thereof, less the fair rental value of the leased premises for the balance thereof. ,. c) At the option of the Landlord, he may lease the demised premises ar any part ar parts thereof to such. + . person ar persons as maybe, in Landlord's discretion seem set without affecting Tenant liability for any lots of rent for the balance of the term. d) In addition to the remedies provided for in this paragraph 14, if Lessee defaults hereunder, the Lessce hereby empowers the Prothonotary or any attonney of any court of record within the Commonwealth of Pennsylvania or elsewhere to appear for the Lessee, and with or without complaint filed, to confess• judgment against the Lessee and in favor of the Lesser, or any other holder of this lease, for the sums, owed by the Lessee or for any default on the part or the Lessee, pursuant to the terms of this lease, with unpaid interest thereon, cost of suit and attorney's fees, amounting to ten (10%) percent of the amount owed by Lessee, upon which judgment or judgments one' or more executions may issue forthwith, upon failure to comply with any of the terms or conditions of this lease. Lessee hereby forever waives and releases all errors in said proceeding, waives stay of execution, the right of inquisi- tion and the extension of time of payment. An affidavit filed by any authorized representative of Lessor shall be conclusive evidence by Lessee's default hereunder. No single exercise of the foregoing power to confess judgment shall be deemed to exhaust the power whether or not any such exercise shall be held by any court to be invalid, voidable ar void, but judgment may be confessed as aforesaid from time to time as often as any of said rent or other charges shall fall due or be in arrears, and such powers may be exercised as well after the expiration of the original term and during any extension or renewal of this lease. When this lease shall be determined by condition broken, either during the original term of this lease ar any renewal or extension thereof, and also when, and as soon as the term hereby created or any extension thereof shall have expired, it shall be lawful for any attorney, as attorney for Lessee, to sign an agreement and file and enter in any competent court an amicable action for judgment in ejectment against Lessee and confess a judgment of ejectment thereon against Lessee and, for and against all persons claiming under demised premises for which this lease shall be sufficient warranty, whereupon, if Lessor so desires a writ of possessioq and, provided that if for any reason after such action shall have been commenced, and same shall be determined and possession of the premises hereby demised remains in ar thereby be restored to Lessee, Lessar shall have the right upon any future defauh or defaults ar upon the termination of this lease as herein set forth, to bring one or more amicable action or actions as herein set forth, to recover possession of said premises or any part thereof. In any amicable action of ejectment, Lessor shall first cause to be filed an affidavit made by it or by someone for it and on behalf, setting forth the facts necessary to authorize the entry of judgment, of which facts such affidavit shall be conclusive evidence, and if a true copy of this lease is filed in such action, it shall not be necessary to file the original, as a warrant of attorney, any rule of court, custom or practice to the contrary. The remedies of Lessor set forth herein shall be cumulative of all rights and remedies available hereunder or otherwise available at law or equity. Created by T.K.Sheaffer Page 4 of 6 7!28/2009 S:\233 Walnut Street\Chad and Nina Hummel Apartment LEASE AGREEMENT0807016.doc ~~ ~Ci ~~~ . ,. ~J, 'I Il J /,~ Y www.BridgeStreetRealty.com 2~,t ENTIRE AGREEMENT: This lease constitutes the sole understanding of the parties hereto and any amendments or additions shall be effective only when reduced to writing and signed by the parties hereto. See addendum to Lease Agreement including rules. 21. PERSONAL PROPERTY: In addition.to the real property as described herein including appliances, furnishings, etc, parties do hereby agree that certain items of personal property will be remain on the premises and may be used and cared for appropriately by the Tenant during the terns of this lease agreement. Most windows except for the Living room have mini blinds and or curtains provided by the Landlord. These blinds are in a maintained and clean condition and should be operable and clean condition at the end of the lease. Tenant may be required to replace any mini-blinds that may become worn or broken at the end of this lease term. Appliances include gas range, Boshe dishwasher, disposal, and side by side refrigerator with water and ice in door, and jacuzzi tub. These appliances and furnishings were clean when the Tenant took possession of the premises and will be return them in similar clean condition and good repair. Any broken appliances should be reported to Landlord with FIVE (5) days. Jacuzzi tub requires special attention to NOT turn on jets unless water level is above the jets. Operating the jets dry will destroy the mechanism. The Jacuzzi is three to four years old. USE: Tenant agrees that the premises shall be used only for asingle-family private dwelling. Tenant agrees to obey ail local laws. No illegal activities will be conducted on the property. 2~ CONDUCT: The Tenant agrees to comply with all laws and refrain from making unreasonable noise and disturbance. This lease will be considered null and void should the behavior of the Tenant become hostile, argumentative, or belligerent to the Landlord, their agents, or other Tenant's residing in the building. The Tenant will have 30 Days to vacate the property and will forfeit any security deposits held by the Landlord as damages due and payable to the Landlord. The purpose of this clause is to protect the Landlord from having a Tenant who is presumably involved with or habitually under the influence of illegal drugs or alcohol to the point that the situation is intolerable for the Landlord. 24. LEAD PAINT NOTIFICATION: The building was constructed prior to 1978 and may contain lead paint. However, lead paint can be dangerous if ingested. Law requires this lead paint notice. 2~S PAYMENT OF RENT: Tenant may contact landlord to report maintenance problems Monday through Friday between the hours of 8:00 A.M. and 6:00 P.M. at 717 774 1700. Rent may be mailed or paid in person on or before the due date at Bridge Street Realty, LLC, 1002 Bridge Street, Suite 100, New Cumberland, PA 17070. Checks should be made payable to: Tammie K. Sheaffer LATE CHARGE: There will be an additional 535.00 Iate charge assessed for all rental payments received after the first day of each month. There will be an additional 510 fee per day for any rental payments paid after the I" of the month. 27. RETURNED CHECKS: All returned checks will be charged a 535.00 return check fee. After two returned checks, rental payments must be made in the form of a money order, certified check, or bank check with a guarantee of availability of funds IN WITNESS WHEREOF, the parties hereto, have executed this lease contract the day and year first above written, intending to be legally bound thereby. ~-~"" ~L {~'~~`'rW" Tenant ]1~ ~ U ~ Date ~ Tenant 2 S 6"1 Date . l~~ Landlord Z ~ Q Date Created by T.K.Sheaffer Page 5 of 6 7/2g/2009 S:\233 Walnut Street\Chad and Nina Hummel Apartment LEASE AGREEMENT0807016.doc ~~ ~ t. { , www.BridleStreetRealtv.com (~ Landlord Date Agent Date Witness Date Guarantee Date Tenant received 2 Keys (Twenty-five dollars (DSO) per key not returned) TENANT WILL BE RESPONSIBLE FOR PAYING FOR NEW LOCK CYLINER REPLACEMENT ALSO IF LOST or Tenant Fails to return all keys. Tenant's Employer's name, address, and employer contact and telephone number: Contact name, address, and telephone number in case of emergency (nearest relative) Make, model, color, and year of car(s) b ~1 d d C : v ~ ~ t o v~ a ~n ~ S C' I ~ R b Name titled C~ ~, d P'1 H H w ,~, ~ 1 License Plate # and State ~ ~ p - 3 3 3 ~ The Apoie Festival is the Iar¢est event in Downtown New Cumberland at the Borou¢6 Park on a Saturday la the Fall. There is a Memorial Dav Parade on Memorial Dav between 11:00 A.M. and 2 P.M.. There is a Halloween Parade on Tuesday night at the end of October 6 P.M. to 8:30 P.M. ?? You are welcome to use the front porch of 1002 to view the parades. If I am in town, I usually have some people over for a small pot luck and BYOB. I provide sodas or spring water. Parking on Bridge Street is not allowed during those activities. Thank you for your Tenancy. And enjoy the apartment. Created by T.K.Sheaffer Page 6 of 6 7/2812009 S:\233 Walnut Street\Chad and Nina Hummel Apartment LEASE AGREEMENT0807016.doc ~. ~ r. ~• / d ~ www.HridaeStreetResily.com Landlord Date Agent Date Witness Date Guarantee Data Tenant received 2~ Keys (Twenty-five dollars (S50) per key not retin~ted) TENANT WILL BE RESPONSIBLE FOR PAYING FOR NEW LOCK CYLINER REPLACEMENT ALSO IF LOST or Tenant Fails to return all keys. Tenant's Employer's name, address, and employer contact and telephone number: Contact Hama, address, and telephone number in case of emergency (nearest relative) Make, model, color, and year of cats) ~ n ~, d d C: ~. ; 4 t ~ r ~ ti; S~ f '1 W 6 Name titled (~ H i d k'1 H ~+„,,~, ~ f License Plate # and State 4r ,) P - 3 3 3 S You are welcome to use the 8ont porch of 1002 to view the parades. if I am in town, I usually have soma people over for a small pot luck and BYOB. I provide sodas or spring water. Parking on Bridge Street is not allowed during those activities. Thank you for your Tenancy. And enjoy the apartment. Created by T.K.Sheaffer Page 6 of 6 728/2009 S:~233 Walnut Strcet~Chad and Nina Hummel Apartment LEASE AGREEMENT0807016.doc ~` ~ <i ~_ _ MEMBERS 1ST FEDERAL CREDIT UNION • P.O. BOX 40 • MECHAMCSBURG, PENNSYLVANIA 17055 ~' NO. 0000453136 Acct: XXXXXXX049 Teller: 1736 Date: 08/29/09Time: 1:36pm --------------------------------------------------------- See receipt for reference Check Number: 00 0000453136 Purpose Amount $25.00 Pay to CHAD M RUNNEL OR TAMMIE SHEAFFER PRO-RATED AUGUST 31ST RENT MEMBERS 1ST FEDERAL CREDTf UNION • P.O. BOX 40 • MECHANICSBURG, PENNSYLVANIA 17055 NO. 0000453135 Acct: XXXXXXX049 Teller: 1736 Date: 08/29/09Time: 1:36pm --------------------------------------------------------- See receipt for reference Check Number: 00 0000453135 Purpose Amount $25.00 Pay to CHAD M RUNNEL OR TAMMIE SHEAFFER PRO-RATED AUGUST 30TH RENT I ~x ~. i l~ i 1~ „ ~ ,, ~~ September 10, 2009 Dear Tammie Sheaffer, You stated in our telephone conversation on Friday September 4, 2009 that you were aware of a flea infestation at 233 Walnut St, Lemoyne, PA before you moved out. You did not make us aware of this before that date, and went so far as to unilaterally move our bed into the most heavily infested carpeted bedroom. We began to receive small red bites concentrated on our feet, ankles, and lower legs immediately after taking residence at this address on August 30, 2009. Tuesday August 1, 2009 these marks were identified by West Shore Plaza CVS senior pharmacist Phillip Moyer as flea bites. We have treated the apartment with 4802 of Ultracide IGR and Adultacide, l6 OZ of NyGuard IGR, and 7 Hotshot flea bombs. This has drastically reduced the flea population in the apartment, but we are still seeing some live aduR fleas as of the writing of this letter. You clearly have consdously provided us with an uninhabitable dwelling. We will be expecting a rent adjustment fvr October 2009 to compensate us for at least the 12 days, which we have had to endure substandard living conditions at your property. Photos of the fleabites in question have been enclosed with this letter. C,'h~ad- MIHummel / Ni~n22~//a_~ Z Humm~~~el rr ~WnG r~i ~/ Ipj c~ ~a,. ~, _......~ . _ -- - --- - - ~~~~~ft~ ~~~,~ I ~ ~ ;fir '~- f~f.. ~.' - ... Y * ~,. f ~ ~ f rx ~ ~ ~ z':. .k~... i ~ ~. ~" . ~.~.,~ ~ I. w ~ ; {'' ~ .1p Yy, "~ i'I"~ '~ ~~ y {4~ k ~ ~~ ~" s~. ~ . x . x ~ ~ ' ^ yi ~. - .~ys~ - Som.= .{ t ~ '"... q, ~~~,~ ~ t a ' K i + ; i t ~ ~ ~~ x Sµ i ~/~YI I YJI I '~ G n :~ ~x~ _ ~~ ~ -_.~+~.:~ Foy :~a+~a~resKC ~. 7 B -~-¢ ~ -~ =~....~a. - - -- - - ~-- _ _~ -~ .,.a _ ~...~.e.. FORD r ~ ~ ! . - - - PAYMENT f '~ l~ C~ s y .,.Fin's1br. OTHER :~ . u,._ ~~ ~_~ • Carry he~ann lo~wald • Char typ. a e+~eroe BM. ' - ~ • add deals on rtrmo wn - ~D . ~ ~ • f Wa++ dVphealw in wMOn Cheek bur ~Y Mauro li."~. r ~ ;'r ,l ~ ~ t.t ~ ! .~ V •~ '~~ i0.0W lit - ~ S.-' . ~ - ~ ~ _ ~ ~ NOT NEG OTIABLE ~ `~ .~_ ~ . ~~ October 9, 2009 Tammie Sheaffer, We have the following grievances with our rental unit at 233 Walnut St, Lemoyne, PA 17043: (I) We are not recieving any heat from the gas boiler. This is the primary source of heat for our dwelling, and that it should provide us with heat is implied in paragraph 12, line 3 of our current lease agreement. (2) One storm window in the living room can not be opened from the inside of the dwelling, and is afire hazard. (3) One window in the bedroom does not lock; providing an insecure living environment. (4) Three windows in the living room do not lock; providing an insecure living environment. We will withhold all rent upon the fifteenth day of these problems remaining unfixed. Chad Humme Nina Hummel (~l "/~ ~t ~~ ~ s~fi~~ rxh~bir "Z` (~ October 19, 2009 Tammie Sheaffer, I spoke with you in person at 1:30 PM on October 19, 2009 while you and maintenance man George were at our residence at 233 Walnut St. Lemoyne. I told you that the ceiling in our bedroom was leaking. You verbally aknowledged me. At 1:45 PM I allowed maintenance man George to enter our apartment along with your girlfriend from Texas. They both viewed the leaking ceiling in our bedroom . Your girlfriend took a picture of the leak with her cellphone. You were clearly aware that the ceiling in our bedroom was leaking on October 19, 2009. If you or or one of you associates do not begin to repair the leak in our bedroom ceiling by November 3, 2009, we will consider our lease null and void. On this same day, a pane of glass was cut from a basement window at the same property. This pane of glass is still missing as of the writing of this letter. This creates an unsecured condition which renders our apartment uninhabitable. Until this window is secured, we will consider our lease null and void. A window above our sliding glass door has been missing since we took residence at 233 Walnut St, Lemoyne PA. Before we took residence at this property, the hole where the window was missing was covered with a'/4 Inch sheet of wood. It is only held in with four 2 Inch beads of light caulking. This window covering could easily be breached by an intruder, and therefore creates an unsecured dwelling. Such an unsecured dwelling is uninhabitable. Until this window is replaced, we will consider our lease null and void. The inner pane of a window in our bedroom has been shattered since we took residence at 233 Walnut St, Lemoyne PA. This creates a very unsafe condition which renders the dwelling uninhabitable. Until this unsafe condition is fixed, we will consider our lease null and void. Citad.H~ mm~ Nina Hummel Exl~ibi~- "~ ~, t Tammie Sheaffer, # 1. Our furnace is again not working. #2. On September 30, 2009, Chad M Hummel hand delivered a personal check in the amount of $495 to 1002 Bridge St., New Cumberland PA, 17070 Suite 100. The check is number 178. I dropped the check in the mail slot in the front door of the above property. As of the writing of this letter, the check has not been cashed. We will create an escrow account in which we will place the funds for which this check was written. #3. We are moving out of 233 Bridge Street, Lemoyne PA on October 24, 2009. Our forwarding address will be 1714 Maple St, New Cumberland PA 17070. Chad Hummel --~t~w~Q c~ ~- ~ o b e r a 3~ a o ~~ /Ny~ina H~u//morel { EX~Ihifi ~`~~ VERIFICATION I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. DATE:_3 l1 'l ~~ ~ i c~ PJ~(~ P~ ~,,..,~ CHAD HUMMEL, PLAINTIFF Widener University School of Law Harrisburg Civil Law Clinic 3605 Vartan Way, 2"a Floor Harrisburg, PA 17110 (717) 541-0320 lawclinichbt~mail.widener.edu CHAD HUMMEL AND NINA HUMMEL, PLAINTIFF, VS. TAMMIE K. SHEAFFER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 10-1422-CIVIL CIVIL ACTION LAW CERTIFICATE OF SERVICE I, Tabitha D. Phillips, Certified Legal Intern for the Plaintiffs Chad Hummel and Nina Hummel in the above-captioned matter, do hereby certify that I have this day served the Defendant with a true and correct copy of the Complaint by placing same in United States Mail, first class postage prepaid, and addressed as follows: Ms. Tammie K. Sheaffer 1002 Bridge Street, Suite 100 New Cumberland, PA 17070 DATE: ITHA D. "PHILLIPS ~ TIFIED LEGAL INTERN Harrisburg Civil Law Clinic Widener University School of Law 3605 Vartan Way, 2"d Floor Harrisburg, PA 17110 717-541-0320 lawclinichb(a~mail.widener.edu CHAD HUMMEL AND NINA HUMMEL, Plaintiff ~fL~~- ~' .Ir`f- :1s t iVL Zo~a ~,~~ ~6 `~ i~~ ~7 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 10 -1422 -CIVIL vs. TAMMIE K. SHEAFFER, Defendant CIVIL ACTION -LAW PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter judgment in favor of the Plaintiff and against the Defendant by default for Defendant's failure to file an Answer in response to Plaintiff's Complaint. I hereby certify that a written notice of intention to take a default judgment was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this Praecipe A copy of the Notice of Intention to Enter Default Judgment is attached hereto as Exhibit "A." Date: I-- /~ ~~ .. , abitha D. Phil ips, Gertifi d Legal Intern ~~ ~~/-- .~ J. Palmer Lockard, Supervising Attorney ID #33681 Harrisburg Civll Law Clinic Widener University School of Law 3605 Vartan Way, 2nd Floor Harrisburg, PA 17110 717-541-0320; f-717-909-0442 IawclinichbCdlmail.widener.edu ~ x h,i h ~ +- "~ CHAD HUMMEL AND NINA HUMMEL, Plaintiff vs. TAMMIE K. SHEAFFER, Defendant TO: TAMMIE K. SHEAFFER DATE OF NOTICE: April 9, 2010 IMPORTANT 10 DAY NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGEMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING. YOU MAY LOSE YOUR RIGHTS TO PROPERTY AS WELL AS OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD 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. Cumberland County Lawyer Referral Service 32 S. Bedford Street Carlisle, PA 17111 (717) 249-3166 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 101422 CIVIL CIVIL ACTION -LAW 10 DAY AVISO IMPORTANTE LISTED ESTA EN REBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARECENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESENTADO CONTRA LISTED. A MENOS QUE LISTED ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y LISTED PUEDE PERDER SU PROPIEDAD U OTROS DERECHOS IMPORTANTES. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Lawyer Referral Service 32 S Bedford Street Carlislt, PA 17111 ~, ~7) 249-3166 Intem Monica D. Cliatt, Supervising Attorney 1. D. #33681 CHAD HUMMEL AND NINA HUMMEL, PLAINTIFF vs TAMMIE K. SHEAFFER DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-1422 CIVIL CIVIL ACTION LAW NOTICE OF ENTRY OF JUDGMENT NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST YOU. ~~ Prothonotary If you have any questions concerning the a Ta /e, please contact: D. Phillips, Certified Le al Intern J. R~`a11~(er Lockard, Supervising Atto I „6. #33681 F1=larrisburg Civil Law Clinic Widener University School of Law 3605 Vartan Way, 2~d Floor Harrisburg, PA 17110 (717) 541-0320; fax (717)909-0442 lawclinichb(c~mail widener edu l~f'r7 PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in triplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: ^ for JiJRY trial at the next term of civil court. ^X for trial without a jury. CAPTION OF CASE (entire caption must be stated in full) Cin a d ~-~.vn one l and N i n es I Lu m ~~ I (Plaintiff) IT vs. ~Ca-mmi~ k . Slno~-PFer (Defendant) vs. n G <... v t.T;' m~,. -~., 6~ ,:~ _.. ~_~ ,r ';~ 1_.. •~ C:._ (check one) ^X Civil Action -Law ^ Appeal from arbitration (other) The trial list will be called on and Trials commence on Pretrials will be held on (Briefs are due S days before pretrials 10-1422-CIVIL No. , Term Indicate the attorney who will try case for the party who files this~/praecipe: Allison C. Gossett, Certified Legal Intern and /Ylli ry C'~e 77i ~/~Ht ~Ca~T', ~s~ - Indicate trial counsel for other parties if known: This case is ready for trial. 6/10/10 Date: Signed: _7~ Print Name: Plaintiffs Attorney for: ~~~ ~~ a ~ 3~~y X93 N a Q ~~w ..~ -a N w is 'T1 ~~ rr~ ~~ { ~.; f -, ~~;~ ~~ ~'t°i~i Jx' BSc ~ E.s~, Widener University School of Law ,,~_ _, ~ L;-I - ' !- f Harrisburg Civil Law Clinic ' ` )~;-;r~Y ~ 'r '~ ~'- 3605 Vartan Way, 2"d Floor Harrisburg, PA 17110 ~~1Q ~,1~ -7 (~~ ~: (717) 541-0320 iawclinichb(a~mail.widener.edu C~.1;`~`"~'. `.Jt.,l~ji i° CHAD ~ NINA HUMMEL, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, DOCKET NO. 10-1422-CV VS. . TAMMIE SHEAFFER, DEFENDANT :CIVIL ACTION LAW CERTIFICATE OF SERVICE I, Allison Gossett, Certified Legal Intem for the Plaintiffs, Chad and Nina Hummel, in the above-captioned matter, do hereby certify that I have this day served the Defendant with a true and correct copy of the Praecipe for Listing Case for Trial, by placing same in United States Mail, first class postage prepaid, and addressed as follows: Tammie Sheaffer DATE: ~ l~ - ~ ~ 1002 Bridge Street, Suite 100 New Cumberland, PA 17070 Allison Gossett Certified Legal Intern CHAD HUMMEL AND NINA HUMMEL, PLAINTIFFS V. TAMMIE K. SHEAFFER, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-1422 AND NOW, this 13`h day of July, 2010, the case having been assigned to this Court for the scheduling of the Non-Jury Trial, IT IS HEREBY ORDERED AND DIRECTED that the Non-Jury Trial will be held on Friday, October 22, 2010, at 1:30 p.m. in Courtroom No. 2 of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, Mary Catherine Scott, Esquire Allison C. Gossett, CLI Weidner University School of Law Harrisburg Civil Law Clinic 3605 Vartan Way, 2"d Floor Harrisburg, PA 17110 ~Tammie K. Sheaffer 1002 Bridge Street, Suite 100 New Cumberland, PA 17070 Court Administrator -' ~'~`5 ~)~3),~ bas ~,D~Pi~S IMa• ~~~ 7! 13IGD ~~ M. L. Ebert, Jr., J. ,~ ~. {-,,:: ~_`-. t . ~_ a c._ r° -~ °~:~ - ;, rr = - -~-~. ~v y, ~ r ~~ L ..,C F1tE0-OFFICE OF THE PROTHOP~OTARY Edmund "Tad" Berger Attorney I.D. # 53407 Berger law Firm, P.C. 2104 Market Street Camp Hill, PA 17011 Phone: (717) 920-8900 Fax: (717) 920-8901 E-Mail: tberger bergerlawfirm.net 2014 OCT 19 PSI 2~ 33 CUMBERLAND COUhITY pENP~SYLWANiA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NINA HUMMEL AND CHAD HUMMEL, Plaintiffs v. Docket No. 2010-1422 CV TAMMIE K. SHEAFFER Defendants Civil Action -Law PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of Defendant Tammi K. Sheaffer in the above-captioned proceeding. Papers may be served upon me at the address set forth below: Edmund J. Berger Attorney I.D. #53407 Berger Law Firm, P.C. 2104 Market Street Camp Hill, PA 17011 (717) 920-8900 (Phone) (717) 920-8901 (F Date: October 19, 2010 Edmund J. Berger IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NINA HUMMEL AND . CHAD HUMMEL, Plaintiffs . v. Docket No. 2010-1422 CV TAMMIE K. SHEAFFER . Defendants Civil Action -Law CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing document, Praecipe for Entry of Appearance, upon the following persons and in the manner indicated. BY FIRST CLASS MAIL Mary Catherine Scott Supervising Attorney Widener Law Clinic Widener University School of Law 3605 Vartan Way 2nd Floor Harrisburg PA 17110 Date: October 19, 2010 Edmund J. Berger Berger Law Firm 2104 Market Street Camp Hill, PA 17011 NINA HUMMEL AND : IN THE COURT OF COMMON PLEAS OF CHAD HUMMEL, :CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFFS, vs. • ~.-~ ~ :DOCKET NO. 10-1422 CV ~ ~, +~ -n --~ TAMMIE K. SHEAFFER, ~~r'-3 -vim u, r- ._._ D c.D ~ ca DEFENDANT :CIVIL ACTION -LAW ~° ~~ ~ ' CERTIFICATE OF SERVICE ~ w z~ ., -~ - -~; I, Adam J. Barr, Certified Legal Intern for the Plaintiffs, Chad and Nina Hummel, in the above-captioned matter, do hereby certify that I have this day served the Defendant with a true and correct copy of the Plaintiffs' Pretrial Statement, by placing the same in United States Mail, first class postage prepaid, and addressed as follows: Tammie K. Sheaffer 1002 Bridge Street, Suite 100 New Cumberland, PA 17070 Date: ~ ~/,~~d Adam J. Barr Certified Legal Intern Widener University School of Law Harrisburg Civil Law Clinic 3605 Vartan Way, 2nd Floor Harrisburg, PA 17110 CHAD HUMMEL AND NINA HUMMEL, PLAINTIFFS V. TAMMIE K. SHEAFFER, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-1422 ORDER OF COURT AND NOW, this 27'h day of October, 2010, after Default Judgment for the Plaintiff and against the Defendant, and after trial before this Court pursuant to Pa.R.C.P. 1037(b)(1), the Court finds that the actual damages suffered by the Plaintiff are $2,475.00. The Court further finds that the Defendant's actions in breaching the contract by failing to provide the Plaintiffs with a habitable property and breaching the implied warranty of habitability were not so egregious or continuous in nature as to warrant treble damages under §201-9.2(a) of the Unfair Trade Practices and Consumer Protection Law, 73 P.S.C.S.A. §201-9.2(a); Accordingly, IT IS HEREBY ORDERED AND DIRECTED that Plaintiff is hereby awarded actual damages in the amount of $2,475.00. By the Court, ~ry Catherine Scott, Esquire Adam Barr, CLI Weidner University School of Law Harrisburg Civil Law Clinic 3605 Vartan Way, 2"d Floor Harrisburg, PA 17110 Edmund Berger, Esquire Attorney for Defendant 2104 Market Street Camp Hill, PA 17011 '~~I., f M. L. Ebert, Jr., Court Administrator ~ ~ DIa'I) y~p ~iAS bas l ~ /YLe`T t ~~, !o z8 ~iv ~r~ J. ~~ c -v .. f~/-,~, TIf ~~ vi ~ -~ ~a ~-~ n `' o yc _f }ca J -~ N w N c~ 0 x~ rT'1 ~, -v ~ ca ~ --+o o~ xn ° r*f D -K NINA HUMMEL AND CHAD HUMMEL, PLAINTIFFS, vs. TAMMIE K. SHEAFFER, DEFENDANT. TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 10-1422 CV CIVIL ACTION - LAW PRAECIPE TO ENTER JUDGMENT c_? C -O3 im :tm r- c`•-s c7 all :> o?? c? Please enter judgment in favor of the Plaintiffs, Nina Hummel and Chad Hummel, and against the Defendant, Tammie K. Sheaffer, on the decision of the Court following a damages hearing, no timely post-trial motions having been filed. See attached Court Order. ASSESSMENT OF DAMAGES: Damages were assessed on the judgment in this action as follows: Pursuant to Court Order, Plaintiffs were awarded actual damages of $2,475.00 DATE: 1 a' l1?' I O DATE: l 3 (V David D. Buell, Prothonotary ? (? Adam J. Barr Certified Legal Intern for Plaintiffs , Mary Cathe 'line Scott l Supervi ' g Attorney/Attorney for Plaintiffs ID # 77581 Widener University School of Law Harrisburg Civil Law Clinic 3605 Vartan Way, 2"d Floor Harrisburg, PA 17110 (717)541-0320 DI P-Q ?D a-;? V 00 e;,\eA CERTIFICATE OF SERVICE I, Adam J. Barr, Certified Legal Intern for the Plaintiffs, Chad and Nina Hummel, in the above-captioned matter, do hereby certify that I have this day served Edmund J Berger, of the Berger Law Firm, with a true and correct copy of the Plaintiffs' Praecipe to Enter Judgment, by placing the same in United States Mail, first class postage prepaid, and addressed as follows: Edmund J Berger Berger Law Firm, P.C. 2104 Market Street Camp Hill, PA 17011 Date: 12,16 / /d Adam J. Barr Certified Legal Intern Widener University School of Law Harrisburg Civil Law Clinic 3605 Vartan Way, 2nd Floor Harrisburg, PA 17110 CERTIFICATE OF SERVICE I, Adam J. Barr, Certified Legal Intern for the Plaintiffs, Chad and Nina Hummel, in the above-captioned matter, do hereby certify that I have this day served the Defendant with a true and correct copy of the Plaintiffs' Praecipe to Enter Judgment, by placing the same in United States Mail, first class postage prepaid, and addressed as follows: Tammie K. Sheaffer 1002 Bridge Street, Suite 100 New Cumberland, PA 17070 Date: I Z 3 O Adam J. Barr Certified Legal Intern Widener University School of Law Harrisburg Civil Law Clinic 3605 Vartan Way, 2nd Floor Harrisburg, PA 17110 r . CHAD HUMMEL AND IN THE COURT OF COMMON PLEAS OF NINA HUMMEL, CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFFS V. TAMMIE K. SHEAFFER, DEFENDANT NO. 10-1422 ORDER OF COURT AND NOW, this 27'" day of October, 2010, after Default Judgment for the Plaintiff and against the Defendant, and after trial before this Court pursuant to Pa.R.C.P. 1037(b)(1), the Court finds that the actual damages suffered by the Plaintiff are $2,475.00. The Court further finds that the Defendant's actions in breaching the contract by failing to provide the Plaintiffs with a habitable property and breaching the implied warranty of habitability were not so egregious or continuous in nature as to warrant treble damages under §201-9.2(a) of the Unfair Trade Practices and Consumer Protection Law, 73 P.S.C.S.A. §201-9.2(a); Accordingly, IT IS HEREBY ORDERED AND DIRECTED that Plaintiff is hereby awarded actual damages in the amount of $2,475.00. By the Court, Sk M. L. Ebe-? 4A V rt, Jr., J. Mary Catherine Scott, Esquire Adam Ban-, CLI Weidner University School of Law Harrisburg Civil Law Clinic 3605 Vartan Way, 2nd Floor Harrisburg, PA 17110 Edmund Berger, Esquire Attorney for Defendant 2104 Market Street Camp Hill, PA 17011 Court Administrator bas