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HomeMy WebLinkAbout10-4156GUMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS Judicial District, County Of Cumberland ):"LEA- 1,/;Ll 116 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. 337 Lincoln Street Carlisle PA 17013 ..._ .,. ,. _....., tel. 5/20/2010 ourtyards of Carlisle K Anna Marie Saladigo & Donald L. DOCKET No. Sr.MTME OF OR ATTORK ENT O s s a CV-,0000025-10 This block will be signed ONLY when this notation is required under Pa. If a ant was Oairnant Pa. R.C.P.D.J. No. 1001(6) i action R.C.P.D.J. No. 1008B. This Notice of Appeal, when received by the District Justice, will operate as a before a District Justice, A COMP T MUST BE FILED within) twenty SUPERSEDEAS to the judgment for possession in this case. (20) days after filing the NOTICE of APPEAL. s0oft-aRom-owy-0" 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 Enter rule upon appellee(s), to file a complaint in this appeal !Jame Of SAW# e($) (Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. RULE: To , appellee(s) Name of appelloe(s) Signature of appellant oratMmey or (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: 20 sfgnatun of P-&---tary or BWw- YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTITRANSCRIPT 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 (90) 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, on sender's receipt attached hereto, and upon the appellee, (name) ,20 ? by personal service ? by (certified) (registered) mail, sender's receipt attached hereto. (SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF Signature of affiant Signature of official before whom affidavit was made Tlde of official my commission expires on 20 ens m Irl COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND May. Dist No,- 09-2-02 MDJ Name. Hon. JESSICA BREWBAKER Address-. 18 N HANOVER ST STE 106 CARLISLE, PA Telephone: (717) 240- 65.64 17013 ATTORNEY FOR PLAINTIFF DEAN E. REYNOSA 2109 MARKET ST SAIDIS FLOWER & LINDSAY CAMP HILL, PA 17011 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS FCOURTYARDS OF CARLISLE 337 LINCOLN STREET C/O STERLING PROPERTY MGT LCARLISLE, PA 17013 J VS. DEFENDANT: NAME and ADDRESS FSA LADIGO, ANNA MARIE, ET AL. 93 COURTYARD DR CARLISLE, PA 17013 L J Docket No.: CV-0000025- Date Filed: 1/27/10 .Judgmehr. FOl3:, PLAINTIFF (Date of Judgment) =5/20/10 ® Judgment was entered for: (Name) Judgment was entered against: (Name) in the amount of $ 2, 278.9, COURTYARDS OF CARLISLE SALADIGO, ANNA MARIE Defendants are jointly and severally liable. Damages will be assessed on Date & Time F1 This case dismissed without prejudice. F1 Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 F] Portion of Judgment for physical damages arising out of residential lease Amount of Judgment $ 2.100.95 Judgment Costs $ 178.00 Interest on Judgment $ 100 Attorney Fees $ -:IID Total $ 2.278.95 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 THEJUDGMENT'-IN TH&COURT OF-COM'MON'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 ---A1 RED EST-FOIT ENTRYOF-ATtSFACTIUWW1TFfTHE-MAGWERIALDTSTRFCT-JUDGE= IFTHE-JUD-GMENT-DES SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. r „w Date I certify that this is a true and Date Magisterial District Judge copy of the record of the proceedings containing the judgment. My commission expires first Monday of January, 2012 AOPC 315-07 , Magisterial District Judge SEAL nATR PRTwTRn: 5/20/10 2:45:00 PM L~ FILED-t~t:--r r~ 2QID J~'id 30 ~~ I~~ 37 C~ 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 r„mhe r~ anc3 AFFIDAVIT: I hereby (sx~nea~ (affirm) that I served ^ a copy of the Notice of Appeal, Common Pleas ~_.~~, upon the District Justice designated therein on (date of service) June 22 , 20 10 ^ by personal ervice 0 ,b (certrtifie ~registe[ed) mail, ~nna Mari 5ala~~ o and sender's receipt attached hereto, and upon the appellee, (name) Donald L. c!;ossard , on June 22 , 20 l0 ^ by personal service ~ by (certified) (registered) mail, sender's receipt attached hereto. (SWORN FFIRMED) AND SUBSCRIBED BEFORE ME S DAY OF June , 20 10 . »afure of official before whom affidavit was made Title of official My commission expires on , 20 A A BARBARA E. STEEL, Notary Public Carlisle Boto, Cumberland County, PA '' My Commission Ex Tres June 7, 2011 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS Judicial District, County Of Ctunberland NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. /Q - ~// S", 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. 337VLincoln Street Carlisle PA 17013 DATE OF JUDGMENT NJ THE CASE OF (Plsir~fil~ lDMawNrl 5/20/2010 otxrtyards of Carlisle ,Anna Marie Saladigo & Donald L. DOCKET No. SIGNATURE OF W WT OR ATTORNEY O M ~.~-.. CV-0000025-10 This block will be signed ONLY when this notation is required under Pa. If a tent was Claimant Pa. R.C.P.D.J. No. 1001(6) in action R.C.P.D.J. No. 10088. This Notice of Appeal, when received by the District Justice, will operate as a before a District Justice, A COMP T MUST BE FILED within twenty SUPERSEDERS to the judgment for possession in this case. (20) days aRer filing the NOTICE of APPEAL. SipnNUndPFotlaralM'oraPwY PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used'bNLYwhen 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 Enter rule upon appellee(s), to file a complaint in this appeal Name ~ appeYee(s) (Common Pleas No. )within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or atfomey or agent RULE: To , appellees) Name of appeMee(sj (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 «~mplaint 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: , 20 Sfgnature o/ProMonotary or DeWRy YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTITRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-02 WHITE -COURT FILE TO BE FILED WITH PROTHONOTARY GREEN -COURT FlLE YELLOW -APPELLANTS COPY PINK -COPY TO BE SERVED ON APPELLEE GOLD - COPY TO BE SERVED ON DISTRICT JUSTICE .~ ~ ~ rti ..o ~ ~ .€ ra ~ Postage $ ti, N Certified Fee ~ ~ ~ ~,.,V1 Postmark ~ Return Receipt Fee ~ (Endorsement Required) _ \ Here 0 ResMcted Delivery Fee (~ (Endorsement Required) ~ O m total Postage $ Fees $ . ~' a sent ro ~ - - - -- -~ --- Q~~t-=~ ---~- l-- ~ ----.. 0 ~fraet. Apt No.: _. " --------------------------- 0 or PO Box No. ~~,_ ~~ S~ #~ lob N - - - ------- -- ------ ----------------------------- Ctry; stare. +4 ------- :rr rr. .~ o ~. • .. - • . , •, ru rl ~` f~ V'1 Postage $ ~ \ Certified Fee O \ O Return Receipt Fee Postmark N ~ (Endorsement Required) ~ Here ~ ResMcted Dellvery Fee ~ '"\ O (Endorsement Required) \\ m Total Postage & Fees r~ Sent To O - ----------- - -~ - - --- - --------------------------------------^------ ~ Street Apt. .; ,~ or PO Box No. ~~ ~---- - - ~~~- :~ :~.-~~~-- ------ ~;>y sire,-Z;t~,~ ~ ~ Q ~~t~ :r , .. - . . N ~• • ..• • . .•~ r0 ..0 fL ~ Postage $ ~ f"r ~ Certlfied Fee ~ ~ Postmark Q Return Receipt Fee ~ (Endorsement Required) Here ` ~ Restricted Delivery Fee (Endorsemem Required) f O ~ Total Postage & Fees m r To 1 ~ or PO Box No. ~ r{ (~ - city, stare, zt~ . ~ I CERTIFICATE OF SERVICE AND NOW, June ~ , 2010, I, Dean E. Reynosa, Esquire, hereby certify that I did serve a true and correct copy of the Proof of Service of Notice of Appeal and Rule to File Complaint by regular U.S. Mail to the Defendant/Appellee, Anna Marie Saladigo addressed as follows: By Regular U.S. Mail: Anna Marie Saldigo 93 Courtyard Drive Carlisle, Pennsylvania 17013 E. Re a, Esquire Sai er Lindsay 2109 Market Str et Camp Hill, PA 17011 (717) 737-3405 Fax: (717) 737-3407 FLOWER ~ LINDSAY ~'rotnvets aruw 26 West High Street Carlisle, PA CERTIFICATE OF SERVICE AND NOW, June ~ , 2010, I, Dean E. Reynosa, Esquire, hereby certify that I did serve a true and correct copy of the Proof of Service of Notice of Appeal and Rule to File Complaint by regular U.S. Mail to the DefendantlAppellee, Donald L. Gossard addressed as follows: By Regular U.S. Mail: Donald L. Gossard 17 N. Hanover St., Apt. F-104 Carlisle, Pennsylvania 17013 D E. Re Esquire aidis, ower & indsay 2109 Market Stree ~. Camp Hill, PA 17011 (717) 737-3405 Fax: (717) 737-3407 SAIDIS, FIAWER Sz LIlVDSAY nriowvExs.~+ruw 26 West High Street Cazlisle, PA CERTIFICATE OF SERVICE AND NOW, June ~_, 2010, I, Dean E. Reynosa, Esquire, hereby certify that I did serve a true and correct copy of the Proof of Service of Notice of Appeal and Rule to File Complaint by regular U.S. Mail to the Magisterial District Judge Brewbaker addressed as follows: By Regular U.S. Mail: Magisterial District Court 09-2-02 Magisterial District Judge Brewbaker 18 North Hanover Street Carlisle, Pennsylvania 1701 E. sa, Esquire Saidis, Flower Lindsay 2109 Market Stre t Camp Hill, PA 17011 (717) 737-3405 Fax: (717) 737-3407 SAIDIS, FIAWER Sz LINDSAY ~r~oawevs..~ uw 26 West High Street Carlisle, PA •i ~, FlLfiJ-Gj r:~~ p ~/ Z~10 Jae ?€} ~~ y~ u # CJ~~~~~ _- . ,,,-r In the Court of Common Pleas of Cumberland County, Pennsylvania COURTYARDS OF CARLISLE UNIT OWNERS ASSOCIATION, INC. Plaintiff, vs. ANNA MARIE SALADIGO and DONALD L. GOSSARD Defendants, No. 10-4156 Civil Term CIVIL ACTION NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATIN ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH 1NFORMAITON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 'r AVISO PARR DEFENDER Conforme a PA R.C.P. Num. 1018.1 Usted ha sido demandado/a en la 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 notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defenses de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion Como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. 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 1NFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. IF YOU DO NOT HAVE A LAWYER CONTACT: CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 In the Court of Common Pleas of Cumberland County, Pennsylvania COURTYARDS OF CARLISLE UNIT OWNERS ASSOCIATION, INC. Plaintiff, No. 10-4156 Civil Term vs. ANNA MARIE SALADIGO and DONALD L. GOSSARD CIVIL ACTION COMPLAINT AND NOW, comes the Plaintiff, COURTYARDS OF CARLISLE UNIT OWNERS ASSOCIATION, INC., by and through its attorneys, Saidis, Flower & Lindsay and respectfully represents as follows: 1. Plaintiff, Courtyards of Carlisle Unit Owners Association, Inc. is a condominium association with its principal office located at 337 Lincoln Street, Carlisle, Pennsylvania, 17013. 2. Defendant, Anna Marie Saladigo, is an adult individual with a last known residence of 93 Courtyard Drive, Carlisle, Pennsylvania, 17013. 3. Defendant, Donald L. Gossard, is an adult individual with a last known residence of 711 North Hanover Street, Apt. F-104, Carlisle, Pennsylvania 17013. 4. On or about July 7, 2005, the Defendants purchased a condominium from COC Associates, as tenants in common. See Deed dated July 7, 2005, attached hereto and incorporated herein as Exhibit "1". 5. The Deed noted that the condominium was subject to a Declaration which had been filed at the Recorder of Deeds for Cumberland County on April 22, 2009 at Miscellaneous Book 610 Page 678. 6. The Declaration notes that the Plaintiff has the authority to set assessments on each condominium. See relevant portions of Declarations attached hereto and incorporated herein as Exhibit " 2". 7. The payment of assessments represents each condominium owners' contribution to maintain the various common areas, to maintain liability insurance and to maintain other services provided by the Plaintiff to the condominium owners. 8. Plaintiff has established monthly assessment fees for each condominium based upon size and location of each individual condominium. 9. Monthly assessment for Defendants' condominium is one-hundred twenty-one dollars ($121.00); although this monthly assessment is subject to re-evaluation and potential increases at any time. 10. Plaintiff has been issuing a three dollar ($3.00) credit to Defendants since a common-area light is connected to Defendants' electricity. 11. The Declaration also permits the collection of interest for any unpaid assessments at the rate of 15 % per annum and the collection of reasonable attorneys' fees for the collection of any assessment. 12. Plaintiff had obtained two (2) prior judgments for earlier unpaid assessments and are only seeking a judgment in this action for outstanding assessments, late fees and attorney's fees from December 2008 through the present and continuing until this case reaches a conclusion. 13. As of May 20, 2010, Defendants had an outstanding balance due of three- thousand seven-hundred eighty-two dollars and ninety-five cents ($3,782.95) which included past due assessments, last fees and partial attorney's fees. This amount reflects fees due from December 2008 through May 20, 2010. See statement dated May 20, 2010, attached hereto and incorporated herein as Exhibit " 3". 14. Defendants' condominium continues to incur monthly assessment fees. 15. Plaintiff continues to incur additional attorney's fees as this case continues. WHEREFORE, Plaintiff demands judgment against Defendants for unpaid assessments from December 2008 through and continuing to the date of the hearing as well as interest on the unpaid assessment and reasonable attorney's fees in the collection of these assessments. Respectfully submitted, SAIDIS, FLOWER & LINDSAY ~,,,,_.j(~ ,2010 By: Date Attorney I.D. 80440 Attorney for Plaintiff 2109 Market Street Camp Hill, PA 17011 Phone (717) 737-3405 Fax (717) 737-3407 dre nosa ~sfl-law.com VERIFICATION I, Sue Whitacre, hereby verify I am authorized to make this verification on behalf of Courtyards of Carlisle Unit Owners Association, Inc. and that the statements made in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Courtyards of Carlisle Unit Owners Association, Inc. By Sue hitacre Date: ~-~ ~ ~ , 2010 . as~~V s~ ~~''-~_ifT ~._IL'Gi_rZ . t: ~... ~ ., .. 2005 JUL 18 Aft 9 1~ DEED MADE THE 7fh day of July, in the year of our Lord Two Thousand Five (2005) BETWEEN COC ASSOCIATES, A Pennsylvania Limited Partnership, hereinafter (Grantor) and ANNA MARIE SALADIGO AND DONALD L. GOSSARD, single persons, , of Cumberland County, Pennsylvania, hereinafter (Grantees WITNESSETH, that in consideration of One Hundred Fifty-five Thousand, Five Hundred Fiffy Dollars and 00/100 ($155,550.00) in hand paid, the receipt whereof is hereby acknowledged, the said grantor does hereby grant and convey to the said grantees, as tenants in common ALL THAT CERTAIN Unit in the property known, named and identified in the Declaration referred to below as "The Courtyards of Carlisle, A Condominium Community", located in the Borough of Carlisle, County of Cumberland and Commonwealth of Pennsylvania which has heretofore been submitted to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa.C.S.A. Section 31 O1, et seq., by the recording in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, of a Declaration dated February 26, 1999, and recorded April 22, 1999, in Miscellaneous Book 610, Page 678, together with all amendments and supplements thereto recorded on or before the date hereof and designated as Unit No. 141 as more fully described in such Declaration, together with the proportionate undivided interest in the Common Elements as defined in such Declaration. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights of way, easements and agreements of record including, but not limited to, those contained in the Declaration and Declaration Plan. BEING part of the same premises which James S. Hall, by Deed dated April 8, 1998 which Deed is recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 175, Page 88, granted and conveyed to COC Associates, a Pennsylvania limited Partnership, Grantor herein. ~OoK ~~ P,rrGE~7~.~ .._..~.w...........~.. _~~.W-.... _ ~. _ ~........~_._- AND the said Grantor hereby covenants and agrees that it will warrant specially the property hereby conveyed. IN WITNESS WHEREOF, said grantor has hereunto set its hand and seal the day and year above written. SIGNED, SEALED AND DELIVERED COC ASSOCIATES, IN THE PRESENCE O A PENNSYLVANI LIMI PARTNERSHIP By: COC, IN , its s e g eral partner . By: Eddie P gari ecr ary Eddie P. Drog esident COMMONW LTH PENNSYLVANIA: COUNTY OF RLAND : SS On this, the ~~ day of , 2005, before me a Notary Public, the undersigned officer, personally a ar d Eddie P. Dn~garis who acknowledged himself to be the President of COC, Enc., the sole general partner of COC Associates, A Pennsylvania Limited Partnership, and that he as such general partner being authorized to do so, executed the foregoing instrument for the purposes therein contained b~~ -:. ~-_~ signing the name of the said Corporetion by himself as such President. ~L ~=f°~~ - ,,~ ~. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Y ..'~~ ~.. HOTARU4t. sFJlt. ~,.. ~~ `'~'_~ ';~r,"~~ { . ~CD,~lpf' d. MAR71N, NOi'ARY PUBLIC ••'''. ,-'~``~~tt LION D~IfiES IWGUS'f 27, ZlO6 ;:: ~ ,""'"~ '~ -~ ••. do here certi that the ._ `~-~ ~ ""~ ~~~ y fy precis re idence and com le ~ post offices; • - ~-,--t ~~ ~: r°: ~- address of the within named grantee is ~3 ~OUA' ~ ~'V . r L~UU.+'~5~-~ PA I fi0~f3 ~• "~ DATED• (5~ 7,t~O5 Att ey for Grantee COMMONWEALTH OF PENNSYLVANIA: County of :ss RECORDED on this day of A.D. 2005, in the Recorder's office ofi the said County, in Deed Book Vol. , Page Given under my hand and the seal of the said office, the date above written. Recorder. eoox 269 PACe4720 EXHIBIT "A" ALL THAT CERTAIN Unit in the property known, named and identified in the Declaration referred to below as "The Courtyards of Carlisle, A Condominium Community", located in the Borough of Carlisle, County of Cumberland and Commonwealth of Pennsylvania which has heretofore been submitted to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa.C.S.A. Section 31 Ol , et seq., by the recording in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, of a Declaration dated February 26, 1999, and recorded April ~2, 1999, in Miscellaneous Book 610, Page 678, together with all amendments and supplements thereto recorded on or before the date hereof and designated as Unit No. 14i as more fully described in such Declaration, together with the proportionate undivided interest in the Common Elements as defined in such Declaration. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights of way, easements and agreements of record including, but not limited to, those contained in the Declaration and Declaration Plan. ~ ~ n ~ tom. C7 70 7Q Rt f'*1 ~ae~C ~ ~ 11r ur an ~~ --•~-x ~cn .. t .m xo ~-. 1 ~t i ~ m ~ ~ ~ ~ ~.r. ~.... , w ~ ~. a Fn ~ z c,~ . ~ r. ~-..-- .r• inr ~v " r/+ r ~ i~ --, ss rrr to ""'~ ° ~ -~ ~ '~C' n .x cn ro ~ 4 ~ w. rt ' ~ -~] C 4~] h3 -.7 '.O G 7 O p 4.~1 µ ~ ~~~" ca .~ v as ra ~ ~ r ~ .c. cn cn o Q .~ . ~.7 ..q.. .-w+ ......... ......... ~.. e.....«.. 1 Certify this to be recorded in Cumberland County pA, ~:, ~;Y+Mi•Y \~`=~ Recorder of Deeds rp .-a. .~ r~- t ~a~ ~aF ~r~i t.~ "~ ~_ W~ .."• '\ N C] "Y. fpq~ Iii 8a0K ~~ ~~E~7~i _..... _ ..._.___...__......~._.r._~._... .._.... G:~UaersWls~CV Rlcourtyards.certificate.wpd: l 2/30/04 THE COURTYARDS OF CARLISLE, A CONDOMINIUM COMMUNITY CERTIFICATE OF SUBSTANTIAL COMPLETION I, Gary E. Weaver, of Tippetts, Weaver and Others Architects, Inc., certify as follows: 1. I am a Registered Architect, License No. X 11624, in the Commonwealth of Pennsylvania. 2. This Certificate is given pursuant to Sections 3414{c) and (d) of the Pennsylvania Uniform Condominium Act, Act of July 2,1980, P.L. 286, No. 82, as amended, and pertains to The Courtyards of Carlisle, A Condominium Community, located in the Borough of Carlisle, Cumberland County, Pennsylvania. The Declarant is COC Associates, a Pennsylvania limited partnership. 3. All structural components and common element mechanical systems of the structure which contains Unit No. 141 of The Courtyards of CazIisle, A Condominium Community, are substantially completed to the extent required of the Declarant so as to permit the use of such unit and any limited common elements appurtenant thereto for their intended use and such unit is substantially completed in accordance with the description set forth in the Declaration and Public Offering Statement. day of 1N ~,. WHERnE~OyF~, this Certificate of Substantial VANIA ) ss: is executed this 1~~ . -~~w-:gwE-~w-- On this, the ~ day of 20~-before me, a Notary Fublic, the undersigned officer, personally ap E. Weaver, known to me (or satisfactorily proven) to be the person whose Warne is subscribe o the foregoing instrument and acknowledged that he executed the same for the purposes therein contained. WITNESS WHEREOF, I have hereunto set my hand and official seal. • ~. 5.. •'t'rh+~~,••taN,•~i • ?:, . _ .. NOTARUIL SEAL ME10DY.3. MAPli1N, NOTARY PUBLIC WEST EARL TWP., COUNTY OF LP1WC0131'EA MY COINMNSSION EXPIRES AUGtJSi 27.2906 Notary c . j~ DECLARATION OF CONDOMINIUM OF THE COURTYARDS OF CARLISLE. A CONDOMINIUM COMMUNITY the holders of mortgages of record on Units relative to the protection of the rights of such mortgagees. C. Subject to the provisions of Articles XIV, XVI and XVIi hereof, the Association shall not have the power, by act or omission, to abandon, partition, subdivide, encumber, sell or transfer any or all of the Common Elements unless holders of at least four-fifths (4/S) of the aggregate Undivided Share of the Condominium have given their prior v~Titten approval. The granting of easements for public utilities or for other public purposes consistent with the intended use of the Common Elements by the Condominium shall not be deemed a transfer for purposes hereof. X ASSESSMENTS A. The Association, acting through the Boazd of Directors in accordance with the By-laws, shall have the power to fix and determine, from time to time, the sums necessary and adequate to provide for the Common Expenses (the "Assessments"), including, but not limited to, such amounts as aze necessary for uncollectible Assessments, budget deficits, any reserves as the Boazd of Directors shall deem necessary and prudent, and such other expenses as aze specifically provided for in the Condominium Act, this Declaration of Condominium or the By-laws. The Association shall make the initial Assessment upon conveyance by Declarant of the first Unit in the Condominium. After the first Assessment has been made, Assessments shall be made monthly or at such other times as 'deemed appropriate by the Association, and shall be based on the annual budget adopted by the Association. Asscssments shall be payable on the first (1 st) day ofthe month unless determined otherv~~ise by the Association. The budget shall include such items as are set forth in Article VI hereof The Association shall also establish, in the fast yeaz of operation, a working capital fund with sums equal to at least two (Z) monthly installments of Assessments for each Unit comprising the Condominium which is sold by Declarant to a Unit Owr-er other than Declarant. Any budget amount approved by the Boazd of Directors shall be deemed approved by the Association, unless such budget amount is rejected by the Unit Owners of Units to which a majority of the votes of the Association are allocated. B. Assessments that are unpaid for over fifteen (15}days after the due date shall bear interest at a rate of fifteen percent (15%) per annum from the due date until paid, or such different rate as may be determined by the Boazd of Directors, and nothing herein contained shall limit the Association's right or ability to charge interest on unpaid Assessments up to the then highest rate permitted by law. In the sole discretion of the Boazd of Directors and to the extent permitted by law, a late charge of up to One Hundred Fifty Dollars ($15Q.00} per Assessment or installment thereof not paid when due may be assessed against a delinquent Unit Owner. Regular Assessments shall be due and payable monthly on the first { 1st) day of each month, unless the Board of Directors 14 shall otherwise determine. C. The Association shall ha~~e a lien on each Unit for any unpaid Assessments. together with interest thereon, awed by the Unit Owner of such Unit. Reasonable attorney's fees (including fees in appellate proceedings} incurred by the Association incident to the collection ofan}' Assessment or the enforcement of such lien, together with sums advanced or paid b}~ the Association in order to preserve and protect its lien, shall be payable by the Unit Owner upon demand and shall be secured b}~ such lien. D. The Board of Direciors may take action as it deems necessary to collect Assessments by personal action, or by enforcing and foreclosing said lien, and may settle and comprise the same, if it shall so determine. Said lien shall be effective from and after the time the Assessment ar late chazge becomes due, and shall have thepriority established by the Condominium Act. Subject to the provisions contained in the Condominium Act regarding lien priorities, the provisions of the Declaration of Condominium shall constitute record notice and perfection of the Iien. However, a lien for unpaid Assessments is extinguished unless proceedings to enforce the lien are instituted v-~ithin three (3) years after the Assessments become payable. The Association shall fiunish to a Unit Owner or the holder of any mortgage of record an a Unit, upon written request, a recordable statement setting forth the amount of unpaid Assessments currently levied against the particular Unit. The statement shall be furnished within ten (10} business days after receipt of the request and is binding on the Association, its Board of Directors and every Unit Owner. The Association shall also promptly furnish to each holder of a mortgage of record on a Unit, written notification of any default if not cured wdthin thirty (30) days. The holder of any mortgage shall have the right to examine the books and records of the Association and to require annual reports and other financial data from the Association. A Unit Owner shall also be personally liable for unpaid Assessments which are made during the period a Unit is owned by such Unit Owner. E. Where the holder of a first mortgage of record on a Unit or other purchaser of a Unit obtains title to a Unit as a result of foreclosure or by deed in Iieu of foreclosure pursuant to a first mortgage of record on a Unit, such acquirer of title, its successors and assigns, shall not be liable for the share of Common Expenses or Assessments by the Association pertaining to such Unit, or chargeable to the former Unit Owner of such Unit, which became due prior to acquisirion of title as a result of the foreclosure, and any Iien of the Association, including specifically any lien relative to fees, charges, late chazges, fines and interest that may be levied by the Association pursuant to Section 3302(a){10}, (I 1) and (12} of the Act, shall be subordinate to the lien of a first mortgage of record which is recorded prior to the due date of the Assessment, to the extent permitted by the lien priority requirements of the Condominium Act. F. The Association, acting through its Board of Directors, shall have the right to assign its claim and lien rights for the recovery of any unpaid Assessment to the Declarant, or to any Unit Owner or group of Unit Owners, or to any third parry. 15 G. Limited Expense Assessments, as described in Article V1 B, shall be levied. assessed and collected in accordance with the provisions of this article. XI MORTGAGES ON UNITS A. Requirements. Any mortgage or other lien on a Unit, and the obligations secwed thereby, shall be deemed to provide, generally, that the mortgage or other lien instrument and that the rights and obligations of the parties thereto shall be subject to the terms and conditions of the Act and this Declaration, including specifically Article XIX G hereof, and shall be deemed ^ to provide specifically, but without limitation, that the mortgagee or lien holder shall have no right: 1. To participate in the adjustment of losses with insurers or in the decision as to whether or not or how to repair ar restore damage to or destruction of the Property; or 2. To receive ar apply the proceeds of insurance to the reduction of the mortgage debt or otherwise, except in the event and to the extent either of a distribution of such proceeds to Unit Owners pursuant to Section 331 Z{g) of the Act or of insurance proceeds in excess of the cost of repair or restoration being received by the owner of the Unit encumbered by such mortgage; or 3'. To accelerate the mortgage debt or to have any other remedies by virtue of waste or alleged waste or other conditions occurring anywhere on the Property other than within the affected Unit, and the obligations secured shall be prepayable, without penalty, upon the happening of any termination of the Condominium or determination not to restore or replace the affected Unit. _ Nothing contained in Article Xi A, or elsewhere in this Declaration, shall give a Unit Owner or any other party priority over any rights of the mortgagee of a Unit pursuant to its mortgage in case of a distribution to such Unit Owner of insurance proceeds or condemnation awazds for loss to or a taking of one or more Units and/or Common EIements. B . Notice of Mortgages. No Unit Owner or prospective pwchaser of a Unit shall del fiver any mortgage, or other lien instrument secured by a Unit, unless it has first notified the Board of the name and address of the proposed mortgagee, and the forms thereof and proposed mortgage have been then or theretofore submitted to and approved by the Board as complying with the provisions of this Article, which approval shall be promptly given or denied and shall not be unreasonably withheld. Any such approved mortgage shall be deemed an "Eligible Mortgage". When an Eligible Mortgage is delivered, the Unit Owner shall simultaneously provide executed or 16 COURTYARBS of CARLISLE L10A c/o Sterling Property Management, Inc. 337 Lincoln Street Carlisle, PA 17013 (717) 258-5800 To '~i Anna Marie Saladigo Donald L. Gossard 93 Courtyard Drive Carlisle, PA 17013 Statement Date s/2o/20 l o Amount Due Amount Enc. $7,664.07 Date Transaction Amount Balance 08/31/2004 Balance forward 0.00 01/01/2005 INV #251. Due 01/01/2005. January 80.48 80.48 01/11/2005 PMT #3656. COC -80.48 0.00 02/01/2005 INV #259. Due 02/01./2005. Monthly Association Fee -Outer Unit 83.20 83.20 02/15/2005 PMT #3686. COC -83.20 0.00 03/01/2005 INV #427. Due 03/01/2005. Monthly Association Fee -Outer Unit 83.20 83.20 03/11/2005 PMT #3701. COC ASSOC -83.20 D.00 04/01/2005 INV #565. Due 04/01/2005. Monthly Association Fee -Outer Unit 83.20 83.20 04/12/2005 PMT #3729. COC -83.20 0.00 05/01/2005 INV #727. Due 05/01/2005. Monthly Association Fee -Outer Unit 83.20 83.20 05/09/2005 PMT #3740. COC -83.20 0.00 06/01/2005 INV #889. Due 06/01/2005. Monthly Association Fee -Outer Unit 83.20 83.20 06/01/2005 CREDMEM #918. Street Light -5.05 78.15 06/08/2005 PMT #3774. COC -83.20 -5.05 07/01/2005 INV #1041. Due 07/01/2005. Monthly Association Fee -Outer Unit 83.20 78.15 07/02/2005 PMT #3784. COC -78.15 0.00 07/15/2005 1NV #1368. Due 07/15/2005. Initiation Fee 166.40 166.40 07/19/2005 PMT #11413. PYRAMID LAND -166.40 0.00 08/01/2005 INV #1200. Due 08/01/2005. Monthly Association Fee -Outer Unit 83.20 83.20 08/01/2005 PMT # 1956. SALADIGO -78. ] 5 5.05 08/01/2005 CREDMEM #1369. Street Light -5.05 0.00 09/01/2005 INV #1362. Due 09/01/2005. Monthly Association Fee -Outer Unit 83.20 83.20 09/01/2005 CREDMEM#1390. Street Light -5.05 78.].5 09/07/2005 PMT#1966. SALADIGO -78.15 0.00 09/29/2005 PMT # 102. SALADIGO -78.15 -78.15 10/01/2005 INV #1527. Due 10/01/2005. Monthly Association Fee -Outer Unit 83.20 5.05 10/01/2005 CREDMEM #1550. street light -5.05 0.00 11/01/2005 CREDMEM #1628. Street Light -5.05 -5.05 11/01/2005 INV #1741. Due 11101/2005. Monthly Association Fee -Outer Unit 83.20 78.15 11/08/2005 PMT #3016. SALADIGO -78.15 0.00 12/01/2005 JNV #2063. Due 12/01/2005. Monthly Association Fee -Outer Unit 83.20 83.20 12/01/2005 CREDMEM #2069. Street Light -5.05 78.15 12/09/2005 PMT #3032. SALF.DIGO -78.15 0.00 01/01/2006 INV #2308. Due 01/01/2006. Monthly Association Fee -Outer Unit 83.20 83.20 CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS DUE DUE DUE PAST DUE Amount Due 0.00 151.00 861.00 151.00 6,501.07 $7,664.07 rage ~ COURTYARDS of CARLISLE UOA c/o Sterling Property Management, Inc. 337 Lincoln Street Carlisle, PA 17013 (717) 258-5800 To Anna Marie Saladigo Donald L. Gossard 93 Courtyard Drive Carlisle, PA 17013 Statement Date s/2o/20 l o Amount Due Amount Enc. $7,664.07 Date Transaction Amount Balance 01/01/2006 CREDMEM #2402. Street Light -5.05 78.15 01/11/2006 PMT #3060. SALADIGO -78.15 0.00 02/01/2006 INV #2396. Due 02/01/2006. Monthly Association Fee -Outer Unit 83.20 83.20 02/01/2006 CREDMEM #2455. Street Light -5.05 78.15 02/10/2006 PMT #3081. SALADIGO -78.15 0.00 03/01/2006 INV #2661. Due 03/01/2006. Monthly Association Fee -Outer Unit 108.28 108.28 03/01/2006 CREDMEM #2668. Street Light -5.05 103.23 03/17/2006 PMT #3096. Anna Saladigo -103.25 -0.02 04/01/2006 INV #2852. Due 04/01/2006. Monthly Association Fee -Outer Unit 108.28 108.26 04/01/2006 CREDMEM #2859. Street Light -5.05 103.21 04/17/2006 INV #2931. Due 04/17/2006. 4/15/06 Finance Charge 1.29 104.50 05/01/2006 INV #3065. Due 05/01/2006. Month]y Association Fee -Outer Unit 108.28 212.78 05/01/2006 CREDMEM #3077. Street Light -5.05 207.73 05/09/2006 PMT #3109. SALADIGO -104.50 103.23 05/15/2006 INV #3144. Due 05/15/2006. Finance Charge 1.29 104.52 06/01/2006 INV #3283. Due 06/01/2006. Monthly Association Fee -Outer Unit 108.28 212.80 06/01/2006 CREDMEM #3297. Street Light -5.05 207.75 06/09/2006 PMT #3120. Saladigo -104.52 103.23 06/20/2006 INV #3355. Due 06/20/2006. Finance Charge 1.29 104.52 07/01/2006 INV #3492. Due 07/01/2006. Monthly Association Fee -Outer Unit 108.28 212.80 07/01/2006 CREDMEM #3506. Street Light -5.05 207.75 07/17/2006 INV #3583. Due 07/17/2006. 7/15/06 Finance Charge 2.60 210.35 08/01/2006 INV #3723. Due 08/01/2006. Monthly Association Fee -Outer Unit 108.28 31$.63 08/01/2006 CREDMEM #3737. Street Light -5.05 313.58 08/15/2006 PMT #3143. Saladigo -104.52 209.06 09/01/2006 INV #3928. Due 09/01/2006. Monthly Association Fee -Outer Unit 108.28 317 34 09/01/2006 CREDMEM #3942. Street Light -5.05 . 312.29 09/15/2006 INV #4226. Due 09/15/2006. Finance Charge 3.90 316.19 10/01/2006 INV #4143. Due 10/01/2006. Monthly Association Fee -Outer Unit 108.28 424.47 10/01/2006 CREDMEM #4158. Street Light -5.05 419 42 10/16/2006 INV #4236. Due 10/16/2006. October Finance Charge 5.24 . 424 66 11/01/2006 INV #4397. Due 11/01/2006. Monthly Association Fee -Outer Unit 108.28 . 532 94 11/01/2006 CREDMEM #4416. Street Light -5.05 . 527.89 11/16/2006 INV #4468. Due 11116/2006. November Finance Charge 6.60 534.49 CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS DUE DUE DUE PAST DUE Amount Due 0.00 151.00 861.00 151.00 6,501.07 $7,664.07 rage ~ COURTYARDS of CARLISLE UOA c/o Sterling Property Management, Inc. 337 Lincoln Street Carlisle, PA 17013 (717) 258-5800 To Anna Marie Saladigo Donald L. Gossard 93 Courtyard Drive Carlisle, PA 17013 Statement Date 5/20/2010 Amount Due Amount Enc. $7,664.07 Date Transaction Amount Balance 12/01/2006 INV #4623. Due 12/01/2006. Monthly Association Fee -Outer Unit 108.28 642.77 12/01/2006 CREDMEM #4642. Street Light -5.05 637.72 12/18/2006 INV #4699. Due 12/18/2006. Finance Charge 7.97 645.69 01/01/2007 INV #4846. Due 01/01/2007. Monthly Association Fee -Outer Unit 118.40 764.09 01/01/2007 CREDMEM #4865. Street Light -5.05 759.04 01/]8/2007 INV #4917. Due 01/18/2007. Late Fee 15.00 774.04 02/01/2007 INV #5066. Due 02/01/2007. Monthly Association Fee -Outer Unit 118.40 892.44 02/01/2007 CREDMEM #5085. Street Light -5.05 887.39 02/15/2007 INV #5139. Due 02/15/2007. Violation Fine 150.00 1,037.39 02/15/2007 INV #5140. Due 02/15/2007. Certified Mailing 4.64 1,042.03 02/19/2007 INV #5144. Due 02/19/2007. Late Fee 15.00 1,057.03 02/23/2007 INV #5159. Due 02/23/2007. Certified Letter 4.64 1,061.67 03/01/2007 INV #5296. Due 03/01/2007. Monthly Association Fee -Outer Unit 118.40 1,180.07 03/01/2007 CREDMEM #5315. Street Light -5.05 1,175.02 03/02/2007 INV #5364. Due 03/02/2007. 28th Late Fee 15.00 1,190.02 03/19/2007 INV #5377. Due 03/19/2007. Late Fee 15.00 1,205.02 04/01/2007 INV #5526. Due 04/01/2007. Monthly Association Fee -Outer Unit 118.40 1,323.42 04/01/2007 CREDMEM #5546. Street Light -5.05 1,318.37 04/25/2007 INV #5636. Due 04/25/2007. late fee 15.00 1,333.37 05/01/2007 INV #5776. Due 05/01/2007. Monthly Association Fee -Outer Unit 118.40 1,451.77 05/01/2007 CREDMEM #5824. Street Light -5.05 1,446.72 05/16/2007 INV #5881. Due 05/16/2007. late fee 15.00 1,461.72 05/30/2007 INV #6122. Due 05/30/2007. 30th late fee 15.00 1,476.72 06/01/2007 INV #6021. Due 06/01/2007. Monthly Association Fee -Outer Unit 118.40 1,595.12 06/01/2007 CREDMEM #6070. Street Light -5.05 1,590.07 06/15/2007 INV #6132. Due 06/15/2007. late fee 15.00 1,605.07 06/30/2007 INV #6374. Due 06/30/2007. late fee 15.00 1,620.07 07/01/2007 INV #6272. Due 07/01/2007. Monthly Association Fee -Outer Unit 118.40 1,738.47 07/01/2007 CREDMEM #6321. Street Light -5.05 1,733.42 07/16/2007 INV #6388. Due 07/16/2007. late fee 15.00 1,748.42 07/30/2007 INV #6633. Due 07/30/2007. 30th late fee 15.00 1,763.42 08/01/2007 INV #6530. Due 08/01/2007. Monthly Association Fee -Outer Unit 118.40 1,881.82 08/01/2007 CREDMEM #6579. Street Light -5.05 1,876.77 08/15/2007 INV #6646. Due 08/15/2007. late fee 15.00 1,891.77 CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS DUE DUE DUE PAST DUE Amount Due 0.00 t 51.00 861.00 151.00 6,501.07 $7,664.07 rage 3 COURTYARDS of CARLISLE UOA c/o Sterling Property Management, Inc. 337 Lincoln Street Carlisle, PA 17013 (717) 258-5800 To: Anna Marie Saladigo Donald L. Gossard 93 Courtyard Drive Carlisle, PA 17013 Statement Date s/2o/20 l o Amount Due Amount Enc. $7,664.07 Date Transaction Amount Balance 08/30/2007 INV #6652. Due 08/30/2007. 30th late fee 15.00 1,906.77 09/01/2007 INV #6790. Due 09/01/2007. Monthly Association Fee -Outer Unit 118.40 2,025.17 09/01/2007 CREDMEM #6839. Street Light -5.05 2,020.12 09/17/2007 INV #6897. Due 09/].7/2007. 15th late fee 15.00 2,035.12 10/01/2007 INV #7034. Due 10/01/2007. Monthly Association Fee -Outer Unit 118.40 2,153.52 10/01/2007 CREDMEM #7083. Street Light -5.05 2,148.47 10/01/2007 INV #7135. Due 10/01/2007. 30th late fee 15.00 2,163.47 10/15/2007 INV #7147. Due 10/15/2007. late fee 15.00 2,178.47 10/30/2007 INV #7386. Due 11/15/2006. 30th late fee 15.00 2,193.47 11/01/2007 INV #7286. Due 11/01/2007. Monthly Association Fee -Outer Unit 118.40 2,311.87 11/01/2007 CREDMEM #7335. Street Light -5.05 2,306.82 11/15/2007 INV #7641. Due 12/17/2007. late fee 15.00 2,321.82 11/30/2007 INV #7643. Due 11/30/2007. late fee 15.00 2,336.82 12/01/2007 INV #7531. Due 12/01/2007. Monthly Association Fee -Outer Unit 118.40 2,455.22 12/01/2007 CREDMEM #7580. Street Light -5.05 2,450.17 12/17/2007 INV #7644. Due 12/17/2007. late fee 15.00 2,465.17 01/01/2008 INV #7788. Due 01/01/2008. Monthly Association Fee -Outer Unit 121.00 2,586.17 01/01/2008 CREDMEM #7837. Street Light -5.05 2,581.12 01/02/2008 INV #7646. Due 01/02/2008. 12/31 Late Fee 15.00 2,596.12 01/15/2008 INV #7886. Due 01/15/2008. 15.00 2,611.12 01/30/2008 INV #7892. Due 01/30/2008. 15.00 2,626.12 02/01/2008 INV #8032. Due 02/01/2008. Monthly Association Fee -Outer Unit 121.00 2,747.12 02/01/2008 CREDMEM #8080. Street Light -5.05 2,742.07 02/15/2008 INV #8134. Due 02/l 5/2008. 15th Late Fee 15.00 2,757.07 02/28/2008 INV #8149. Due 02/28/2008. DJ Judgment-CV-406-07 101.50 2,858.57 03/01/2008 INV #8300. Due 03/01/2008. Monthly Association Fee -Outer Unit 121.00 2,979.57 03/01/2008 CREDMEM #8348. Street Light -5.05 2,974.52 03/17/2008 INV #8401. Due 03/17/2008. 15th Late Fee 15.00 2,989.52 03/31/2008 INV #8413. Due 03/31/2008. 30th Late Fee 15.00 3,004.52 04/01/2008 INV #8559. Due 04/01/2008. Monthly Association Fee -Outer Unit 121.00 3,125.52 04/01/2008 CREDMEM #8607. Street Light -5.05 3,120.47 04/15/2008 INV #8661. Due 04/15/2008. Late Fee 15.00 3,135.47 04/30/2008 INV #8681. Due 04/30/2008. 30th Late Fee 15.00 3,150.47 05/01/2008 INV #8828. Due 05/01/2008. Monthly Association Fee -Outer Unit 121.00 3,271.47 CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS DUE DUE DUE PAST DUE Amount Due 0.00 151.00 861.00 151.00 6,501.07 $7,664.07 rage 4 COURTYARDS of CARLISLE UOA c/o Sterling Property Management, Inc. 337 Lincoln Street Carlisle, PA 17013 (717) 258-5800 To Anna Marie Saladigo Donald L. Gossard 93 Courtyard Drive Carlisle, PA 17013 Statement Date 5/20/2010 Amount Due Amount Enc. $7,664.07 Date Transaction Amount Balance 05/01/2008 CREDMEM #8876. Street Light -5.05 3,266.42 05/15/2008 INV #8927. Due 05/15/2008. 15th Late Fee 15.00 3,281.42 05/30/2008 INV #8940. Due 05/30/2008. 30th Fee 15.00 3,296.42 06/01/2008 INV #9084. Due 06/01/2008. Monthly Association Fee -Outer Unit 121.00 3,417.42 06/01/2008 CREDMEM #9132. Street Light -5.05 3,412.37 06/16/2008 INV #9181. Due 06/16/2008. 15th Late Fee 15.00 3,427.37 07/01/2008 INV #9333. Due 07/01/2008. Monthly Association Fee -Outer Unit 121.00 3,548.37 07/01/2008 CREDMEM #9381. Street Light -5.05 3,543.32 07/01/2008 INV #9440. Due 07/01/2008. late fee 15.00 3,558.32 07/15/2008 INV #9441. Due 07/15/2008. 15th Late Fee 15.00 3,573.32 07/31/2008 INV #9703. Due 07/31/2008. late fee 15.00 3,588.32 08/01/2008 INV #9595. Due 08/01/2008. Monthly Association Fee -Outer Unit 121.00 3,709.32 08/01/2008 CREDMEM #9643. Street Light -5.05 3,704.27 08/15/2008 INV #9724. Due 08/15/2008. August 15th Late Fee 15.00 3,719.27 09/01/2008 INV #9871. Due 09/01/2008. Monthly Association Fee -Outer Unit 121.00 3,840.27 09/01/2008 CREDMEM #9919. Street Light -5.05 3,835.22 09/02/2008 INV #9975. Due 09/02/2008. August Late Fee 15.00 3,850.22 09/04/2008 INV #9968. Due 09/04/2008. Aug 30th Late Fees 15.00 3,865.22 09/30/2008 INV #9992. Due 09/30/2008. Late Fee for September 30th 15.00 3,880.22 10/01/2008 INV #10137. Due 10/01/2008. Monthly Association Fee -Outer Unit 121.00 4,001.22 10/01/2008 CREDMEM #10185. Street Light -5.05 3,996.17 10/15/2008 INV #10251. Due 10/15/2008. Late Fees -Oct 15th 15.00 4,011.17 10/31/2008 INV #10257. Due 10/31/2008. Late Fee -Oct 30th 15.00 4,026.17 1 ]/01/2008 INV #10402. Due 11/01/2008. Monthly Association Fee -Outer Unit 121.00 4,147.17 11/01/2008 CREDMEM #10449. Street Light -5.05 4,142.12 11/17/2008 INV #10498. Due 11/17/2008. Late Fee 15.00 4,157.12 12/01/2008 INV #10646. Due 12/01/2008. Monthly Association Fee -Outer Unit 121.00 4,278.12 12/01/2008 CREDMEM # 10693. Street Light -5.05 4,273.07 12/01/2008 INV #10742. Due 12/01/2008. Late Fees 15.00 4,288.07 12/02/2008 INV #14356. Due 12/02/2008. DJ Filing CV-256-08 89.00 4,377.07 12/15/2008 INV #10752. Due 12/15/2008. Late Fee 15.00 4,392.07 12/30/2008 INV #11046. Due 12/30/2008. Late Fees 15.00 4,407.07 01/01/2009 INV #11190. Due 01/01/2009. Monthly Association Fee -Outer Unit 121.00 4,528.07 01/01/2009 CREDMEM #11237. Street Light -3.00 4,525.07 CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS DUE DUE DUE PAST DUE Amount Due 0.00 151.00 861.00 151.00 6,501.07 $7,664.07 rage 5 COURTYARDS of CARLISLE UOA c/o Sterling Property Management, Inc. 337 Lincoln Street Carlisle, PA 17013 (717) 258-5800 To Anna Marie Saladigo Donald L. Gossard 93 Courtyard Drive Carlisle, PA 17013 Statement Date s/2o/201 o Amount Due Amount Enc. $7,664.07 Date Transaction Amount Balance 01/15/2009 INV #11287. Due 01/15/2009. Late Fee 15.00 4,540.07 01/30/2009 INV #11300. Due 01/30/2009. Late Fee 15.00 4,555.07 02/01/2009 INV #11444. Due 02/01/2009. Monthly Association Fee -Outer Unit 121.00 4,676.07 02/01/2009 CREDMEM #11491. Street Light -3.00 4,673.07 02/16/2009 INV #11541. Due 02/16/2009. Late Fees 15.00 4,688.07 02/28/2009 INV #12291. Due 02/28/2009. Late Fee 15.00 4,703.07 03/01/2009 INV # 11694. Due 03/01/2009. Monthly Association Fee -Outer Unit 121.00 4,824.07 03/01/2009 CREDMEM # 11741. Street Light -3.00 4,821.07 03/02/2009 INV #11553. Due 03/02/2009. late fees 15.00 4,836.07 03/16/2009 INV #11790. Due 03/16/2009. Late Fee 15.00 4,851.07 04/01/2009 INV #11942. Due 04/01/2009. Monthly Association Fee -Outer Unit 121.00 4,972.07 04/01/2009 CREDMEM #11989. Street Light -3.00 4,969.07 04/15/2009 INV #12038. Due 04/15/2009. Late Fee 15.00 4,984.07 04/30/2009 INV # 12290. Due 04!30/2009. Late Fee 15.00 4,999.07 05/01/2009 INV # 12187. Due 05/01/2009. Monthly Association Fee -Outer Unit 121.00 5,120.07 05/01/2009 CREDMEM # 12234. Street Light -3.00 5,117.07 05/15/2009 INV #12285. Due 05/15/2009. Late Fee 15.00 5,132.07 06/01/2009 INV #12303. Due 06/01/2009. Late Fee 15.00 5,147.07 06/01/2009 INV #12444. Due 06/01/2009. Monthly Association Fee -Outer Unit 121.00 5,268.07 06/01/2009 CREDMEM #12491. Street Light -3.00 5,265.07 06/15/2009 INV #12541. Due 06/15/2009. Late Fees 15.00 5,280.07 06/30/2009 INV #13262. Due 06/30/2009. 15.00 5,295.07 07/01/2009 INV #12641. Due 07101/2009. Monthly Association Fee -Outer Unit 121.00 5,416.07 07/01/2009 CREDMEM #12732. Street Light -3.00 5,413.07 07/15/2009 INV #13263. Due 07/15/2009. 15.00 5,428.07 07/30/2009 INV #13264. Due 07/30/2009. 15.00 5,443.07 08/01/2009 INV #12880. Due 08/01/2009. Monthly Association Fee -Outer Unit 121.00 5,564.07 08/01/2009 CREDMEM # 12971. Street Light -3.00 5,561.07 08/17/2009 INV #13265. Due 08/17/2009. 15.00 5,576.07 08/31/2009 INV #13266. Due 08/31/2009. 15.00 5,591.07 09/01/2009 INV #13164. Due 09/01/2009. Monthly Association Fee -Outer Unit 121.00 5,712.07 09/01/2009 CREDMEM #13211. Street Light -3.00 5,709.07 09/15/2009 INV #13267. Due 09/15/2009. 15.00 5,724.07 09/16/2009 INV # 13261. Due 09/16/2009. owner search 46.00 5,770.07 CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS DUE DUE DUE PAST DUE Amount Due 0.00 15 ] .00 861.00 15 ] .00 6,501.07 $7,664.07 Page 6 COURTYARDS of CARLISLE UOA c/o Sterling Property Management, Inc. 337 Lincoln Street Carlisle, PA 17013 (717) 258-5800 To: Anna Marie Saladigo Donald L. Gossard 93 Courtyard Drive Carlisle, PA 17013 Statement Date s/2o/2010 Amount Due Amount Enc. $7,664.07 Date Transaction Amount Balance 10/01/2009 INV #13466. Due 10/01/2009. Monthly Association Fee -Outer Unit 121.00 5,891.07 10/01/2009 CREDMEM #13513. Street Light -3.00 5,888.07 10/01/2009 INV #13562. Due 10/01/2009. 15.00 5,903.07 10/16/2009 INV #13574. Due 10/16/2009. 15.00 5,9]8.07 11/01/2009 INV #13727. Due 11/01/2009. Monthly Association Fee -Outer Unit 121.00 6,039.07 11/01/2009 CREDMEM #13774. Street Light -3.00 6,036.07 11/01/2009 INV #13823. Due 11/01/2009. 15.00 6,051.07 11/16/2009 INV #13839. Due 11/16/2009. 15.00 6,066.07 11/30/2009 INV #14087. Due 11/30/2009. 15.00 6,081.07 12/01/2009 INV # 13991. Due 12/01/2009. Monthly Association Fee -Outer Unit 121.00 6,202.07 12/01/2009 CREDMEM#14038. Street Light -3.00 6,199.07 12/15/2009 INV #14102. Due 12/15/2009. 30th Late fee 15.00 6,214.07 12/30/2009 INV #14110. Due 12/30/2009. 30th late fee 15.00 6,229.07 01/01/2010 INV #14260. Due 01/01/2010. Monthly Association Fee -Outer Unit 121.00 6,350.07 01/01/2010 CREDMEM #14307. Street Light -3.00 6,347.07 01/16/2010 INV #14357. Due 01/16/2010. 15th late fee 15.00 6,362.07 01/30/2010 INV #14605. Due 01/30/2010. 30th late fee 15.00 6,377.07 02/01/2010 INV # 14508. Due 02/01/2010. Monthly Association Fee -Outer Unit 121.00 6,498.07 02/01/2010 CREDMEM #14555. Street Light -3.00 6,495.07 02/16/2010 INV #14622. Due 02/16/2010. 15th late fee 15.00 6,510.07 02/28/2010 INV #14868. Due 02/28/2010. 30th late fee 15.00 6,525.07 03/01/2010 INV #14772. Due 03/01/2010. Monthly Association Fee -Outer Unit 121.00 6,646.07 03/01/2010 CREDMEM #14819. Street Light -3.00 6,643.07 03/15/2010 INV #14879. Due 03/15/2010. 15th late fee 15.00 6,658.07 03/31/2010 INV #15134. Due 03/31/2010. 3/30/10 Late Fee 15.00 6,673.07 04/01/2010 CREDMEM # 14944. Street Light -3.00 6,670.07 04/01/2010 INV #15129. Due 04/01/2010. Monthly Association Fee -Outer Unit 121.00 6,791.07 04/15/2010 INV # 15150. Due 04/15/2010. Attorney fees & costs 710.00 7,501.07 04/16/2010 INV # 15139. Due 04/16/2010. Late Fee 15.00 7,516.07 04/30/2010 INV #15342. Due 04/30/2010. 4/30/10 late Fee 15.00 7,531.07 05/01/2010 CREDMEM #15197. Street Light -3.00 7,528.07 05/01/2010 INV #15338. Due 05/01/2010. Monthly Association Fee -Outer Unit 121.00 7,649.07 05/17/2010 INV #15343. Due 05/17/2010. 5/15/10 Late Fee 15.00 7,664.07 CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS DUE DUE DUE PAST DUE Amount Due 0.00 151.00 861.00 151.00 6,501.07 $7,664.07 Page 7 In the Court of Common Pleas of Cumberland County, Pennsylvania COURTYARDS OF CARLISLE UNIT OWNERS ASSOCIATION, INC. Plaintiff, No. 10-4156 Civil Term vs. ANNA MARIE SALADIGO and . DONALD L. GOSSARD . CIVIL ACTION CERTIFICATE OF SERVICE AND NOW, ~.~.. ~O , 2010, I, DEAN E. REYNOSA, Esquire, of the law firm of SAIDIS, FLOWER & LINDSAY, hereby certify that I did serve a true and correct copy of the foregoing Complaint upon all parties by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, at Camp Hill, Pennsylvania, addressed as follows: Anna Marie Saladigo 93 Courtyard Drive Carlisle, PA 17013 Donald L. Gossard 711 North Hanover Street Apt. F-104 Carlisle, PA 17013 By nE.R a ttorney I.D. 8 40 Attorney for Plaintiff 2109 Market Street Camp Hill, PA 17011 Phone (717) 737-3405 Fax (717) 737-3407 drevnosa(a,sfl-law.com In the Court of Common Pleas of Cumberland County, Pennsylvania COURTYARDS OF CARLISLE UNIT OWNERS ASSOCIATION, INC. Plaintiff, vs. ANNA MARIE SALADIGO and DONALD L. GOSSARD Defendants, No. 10-4156 Civil Term -- :;~' . CIVIL ACTION PRAECIPE FOR ENTRY OF JUDGMENT OF DEFAULT:; TO THE PROTHONOTARY: ~., a• _.. 0 ~~ --~ =~-t, == ;_~ ''r Please enter judgment of default in favor of Courtyards of Carlisle and against the Defendant, Anna Marie Saladigo, for her failure to plead to the complaint in this action within the required time. The complaint contained a Notice to Defend within 20 days from the date of service thereof. Defendant, Anna Marie Saladigo was served with the Complaint on or about June 30, 2010 and her answer was due to be filed on or about July 10, 2010. Attached as Exhibit "A" is a copy of Plaintiff's written Notice of Intention to File Praecipe for Entry of Default Judgment, which I certify was mailed by regular mail to Defendant, Anna Marie Saladigo at her last known address of 93 Courtyard Drive, Carlisle, PA 17013 on July 30, 2010, which is at least 10 days prior to the filing of this Praecipe. Please assess damages as follows: Amount of Damages: $ 3,782.95 FLOWER 6z LIlVDSAY 26 West High Street Cazlisle, PA DAMAGES ASSESSED AS ABOVE: SAIDIS SU1d~VAN LAW a BY: Attorney I.D. #8044( Attorney for Plaintiff 26 West High Street Carlisle, PA 17013 (717) 243-6222 s'/~/, ~ P d a.i~h ~o~c C Ck 30~ d7 "~,~~ CERTIFICATE OF SERVICE AND NOW, August ~, 2010, I, Dean certify that I did serve a true and correct copy c Judgment of Default upon Defendant by depositing, same in the U.S. mail, postage prepaid, at Carlisle, follows: By First-Class Mail: Donald L. Gossard 17 N. Hanover St., Apt. F-104 Carlisle, PA 17013 F~ RIS ~ LINDSAY 26 West High Street Carlisle, PA _. Reynosa, Esquire, hereby f the Praecipe for Entry of or causing to be deposited, Pennsylvania, addressed as 26 West Main Street Carlisle, PA 17013 (717) 243-6222 FILE Cn°"! JOHN E. SLIKE ROBERT C. SAIDIS DANIEL L. SULLIVAN JOHN B. LAMPI CAROL J. LINDSAY DEAN E. REYNOSA MARYLOU MATAS JASON E. KELSO Anna Marie Saladigo 93 Courtyard Drive Carlisle, PA 17013 Saidis Sullivan Law A PROFESSIONAL CORPORATION CAMP HILL OFFICE 26 WEST NIGH STREET 2109 MARKET STREET CARLISLE, PENNSYLVANIA 17013 CAMP HILL, PA 17011 TELEPHONE: (717) 243-6222 -FACSIMILE: (717) 243-6486 TELEPHONE: (717)737-3405 EMAIL: ATTORNEY@SFL-LAW.COM FACSIMILE: (717)737-3407 WWW.SFL-LAW.COM July 30, 2010 Re: Courtyards of Carlisle Go Sterling Property Management v. Anna Marie Saladiao and Donald Gossard. CV-25-10 Dear Ms. Saladigo: REPLY TO CARLISLE Enclosed please find the Important Ten Day Notice for the above referenced matter. Very truly yours, SAIDIS SULLIVAN LAW E. i~ynosa, Esquire DER/jld Enclosure ?~ `~ V W J ~.. 1.i.. In the Court of Common Pleas of Cumberland County, Pennsylvania COURTYARDS OF CARLISLE, Plaintiff, No. 10-4156 Civil Term vs. ANNA MARIE SALADIGO and DONALD L. GOSSARD Defendants, CIVIL ACTION TO: Anna Marie Saladigo 93 Courtyard Drive Carlisle, PA 17013 DATE OF NOTICE: July 30, 2010 IMPORTANT TEN DAY NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR 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 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET, CARLISLE, PA 17013 800-990-9108 SAIDIS, EZAWER Sz in~ms~ 26 West High Street Carlisle, PA LAW By: an E. Reynos ttomey I.D. 80 Attorney for Plaintiffl. 26 West High Street Carlisle, PA 17013 dreynosa@sfl-law.com Phone (717) 243-6222 CERTIFICATE OF SERVICE AND NOW, July ~ 2010, I, Dean E. Reynosa, Esquire, hereby certify that I did serve a true and correct copy of the Important Ten Day Notice upon Defendant by depositing, or causing to be deposited, same in the IJ.S. mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: By First-Class Mail: Anna Marie Saladigo 93 Courtyard Drive Carlisle, PA 17013 an E. Reynosa, Esquire aidis Sullivan Law 26 West Main Street Carlisle, PA 17013 (717) 243-6222 SAIDIS, I~Z~OWER Sz LIlVDSAY 26 West High Streec Carlisle, PA In the Court of Common Pleas of Cumberland County, Pennsylvania COURTYARDS OF CARLISLE UNIT OWNERS ASSOCIATION, INC. Plaintiff, No. 10,4156 Civil Term vs. . ~ ~' :. ANNA MARIE SALADIGO `'' '' ~' ~ and CIVIL ACTION ~ '_ ~:, .. -.~ DONALD L. GOSSARD _ ~ --- ~~ Defendants, ~ = ~' -._ ~ _- _._ .. ,- ~. -- -- PRAECIPE FOR ENTRY OF JUDGMENT OF DEFAU~~~ r~ TO THE PROTHONOTARY: Please enter judgment of default in favor of Courtyards of Carlisle and against the Defendant, Donald L. Gossard, for his failure to plead to the complaint in this action within the required time. The complaint contained a Notice to Defend within 20 days from the date of service thereof. Defendant, Donald L. Gossard was served with the Complaint on or about June 30, 2010 and his answer was due to be filed on or about July 10, 2010. Attached as Exhibit "A" is a copy of Plaintiffs written Notice of Intention to File Praecipe for Entry of Default Judgment, which I certify was mailed by regular mail to Defendant, Donald L. Gossard at his last known address of 17 N. Hanover Street, Apt. F-104, Carlisle, PA 17013 on July 30, 2010, which is at least 10 days prior to the filing of this Praecipe. Please assess damages as follows: Amount of Damages: $ 3,782.95 FLOWER ~ I IlVDSAY 26 West High Street Carlisle, PA ~S SSED AS ABOVE: SAIDIS S IVAN LAW • BY: 'ARY nosa, Esq. Attorney I.D. 0440 Attorney for Plaintiff 26 West High Street Carlisle, PA 17013 (717) 243-6222 s ~~iao Pole c~c~" soloG R-~ ~,~GG3 2 N~,~; ~ e n..~'le~ CERTIFICATE OF SERVICE AND NOW, August ~, 2010, I, Dean E. Reynosa, Esquire, hereby certify that I did serve a true and correct copy of the Praecipe for Entry of Judgment of Default by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: By First-Class Mail: Anna Marie Saladigo 93 Courtyard Drive Carlisle, PA 17013 Dean E. Reynosa, Esquire Saidis Sullivan Law 26 West Main Street Carlisle, PA 17013 (717) 243-6222 SAIDIS, FIAWER Sz LIlVDSAY 26 West High Street Carlisle, PA FILE COPY JOHN E. SLIKE ROBERT C. SAIDIS DANIEL L. SULLIVAN JOHN B. LAMPI CAROL J. LINDSAY DEAN E. REYNOSA MARYLOU MATAS JASON E. KELSO Saidis Sullivan Law A PROFESSIONAL CORPORATION .AMP HIL OFFI .>' 26 WEST HIGH STREET 2109 MARKET STREET CARLISLE, PENNSYLVANIA 17013 CAMP HILL, PA 17011 TELEPHONE: (717) 243-6222 -FACSIMILE: (717) 243-6486 TELEPHONE: (717)737-3405 EMAIL: ATTORNEY@SFL-LAW.COM FACSIMILE: (717)737-3407 W W W SFL-LAW.COM July 30, 2010 Donald L. Gossard 17 N. Hanover St., Apt. F-104 Carlisle, PA 17013 Re: Courtyards of Carlisle c/o Sterling Property Management v. Anna Marie Saladiao and Donald Gossard CV-25-10 Dear Mr. Gossard: REPLY TO CARLI LE Enclosed please find the Important Ten Day Notice for the above referenced matter. Very truly yours, DER/jld Enclosure cc: Courtyards of Carlisle Ronald Johnson, Esquire SAIDI ULLIVA AW . Reyn a, Esquire EXHIBIT ~~ <> In the Court of Common Pleas of Cumberland County, Pennsylvania COURTYARDS OF , CARLISLE, , Plaintiff, No. 10-4156 Civil Term vs. ANNA MARIE SALADIGO and CIVIL ACTION DONALD L. GOSSARD . Defendants, TO: Donald L. Gossard 17 N. Hanover St., Apt. F-104 Carlisle, Pennsylvania 17013 DATE OF NOTICE: July 30, 2010 IMPORTANT TEN DAY NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR 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 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET, CARLISLE PA 17013 800-990-9108 RIS ~ LINDSAY 2G West High Street Carlisle, PA Attorney for Plaintiff 26 West High Street Carlisle, PA 17013 dreynosa@sfl-law.com Phone (717) 243-6222 ~t CERTIFICATE OF SERVICE AND NOW, July ~, 2010, I, Dean E. Reynosa, Esquire, hereby certify that I did serve a true and correct copy of the Important Ten Day Notice upon Defendant by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: By First-Class Mail: Donald L. Gossard 17 N. Hanover St., Apt. F-104 Carlisle, PA 17013 D6an E. Reynosa,~Esquire Saidis Sullivan La 26 West Main Street Carlisle, PA 17013 (717) 243-6222 FLOWER ~ LINDSAY 2G West High Strect Carlisle, PA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Courtyards of Carlisle Unit Owners ^ Confessed Judgment Association, Inc. vs. Plaintiff Q Other File No. 2010-4156 Anna Marie Saladigo and Donald L. ~ Amount Due $3,782.95 Gossard Defendant; s~ Address: 93 Courtyard Drive Carlisle, PA 17013 ~AnnO'l 711 N. Hanover Street Apt. F-104 `7Dra~~ Carlisle, PA 17013 Interest Atty's Comm Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant (s) Personal property PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee (s) as a lis pendens gainst re state of the defendant(s) described in the attached exhibit. Date f ~ - Jy-w1U Signature: Print name: can E. R nosa J~/i~ u ~ /4~ dU '" • a•sa " i ~{~ -SD ~.~ 3o3G D Address: ~ ay9>o~ Attorney for: 26 West High Street Carlisle, PA 17013 Plaintiff ,1~ i ~~''~h`1 ~ S ~ ~=~ Telephone: (717) 243-6222 ~~1.i,1i103 QNtf`1N38W(13 80440 Supreme Court ID No: ZS ~Z add '~ E .~30 OIOt ~d~IOF~~Nl0~fc3 3N1 ~J ~~I~~O-U~ll~ a.oo ~ ~o. • S~ ~ L ~.e WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO10-4156 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Courtyards of Carlisle Unit Owners Associatio, Inc. Plaintiff (s) From Anna Marie Saladigo and Donald L. Gossard 93 Courtyard Drive Carlisle, PA 17013 711 N. Hanover Street, Apt. F-104 Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell Personal property . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEES} as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$3,782.95 Interest Atty's Comm Atty Paid $146.50 Plaintiff Paid Date: OCTOBER 14, 2010 (Seal) REQUESTING PARTY: Name Dean E. Reynosa, Esy. Address: 26 West High Street. Carlisle, PA 17013 Attorney for: PLAINTIFF Telephone : 717-243-6222 Supreme Court ID No. 80440 L.L.$.50 Due Prothy $2.00 Other Costs Da ' , Prothonot By: Deputy ~, COURTYARDS OF CARLISLE UNIT OWNERS ASSOCIATION, INC V. ANNA MARIE SALADIGO AND DONALD L. GOSSARD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2010-4156 CIVIL ACTION -LAW ORDER OF COURT AND NOW, this 2ND day of NOVEMBER, 2010, a hearing on Defendant Donald Gossard is scheduled for TUESDAY, NOVEMBER 9, 2010, at 3:45 a.m. in Courtroom # 3. By the Court, Dean Reynosa, Esquire 26 West High Street Carlisle, Pa. 17013 onald L. Gossard 911 Hanover Manor Carlisle, Pa. 17013 Sheriff sld r~ ~~s ~~~ I ~~~3l~~ Edward E. Guido, J. c a 0 ~ -~ co r~ a ~ ~ x r-- ~ ~ ~-p w rs -' r z o ~ ~' t~ Ay V o~ A -~ ~ ca ~ ~ -~ to , RONNY R. ANDERSON Sheriff JODY S. SMITH Chief Deputy ~°~`~tp of ~unt~Prt~ '~d OFFICE OF THE SHERIFF One Courthouse Square, Room 303 Carlisle, Pennsylvania 17013 November 1, 2010 Cumberland County Court Administration 1 Courthouse Square Carlisle, PA 17013 NOV Q 1LUIU RICHARD W. STEWART Solicitor Enclosed please find a Claim for Exemption, pertaining to Civil Case Number 2010-4156, filed by Donald L. Gossard, which was received in the Cumberland County Sheriff's Office on November 1, 2010 at 1055 hours. Please note that there are two defendants in this case; defendant Anna Marie Saladigo has not yet been served. Please forward a copy of the Notice of Hearing to my attention in the Sheriff's office, however it is the Court's responsibility to notify all parties involved. Thank you for your consideration to this matter. Sharon R. Lantz Staff Assistant . ~ ~ NQV 01 [u1U A '~ IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA WRIT NO. 7 c~ ~ ~' ~ ~ ~~O CIVIL TERM To the Sheriff: CLAIM FOR EXEMPTION I, the above named defendant, claim exemption of property from levy, or attachment: 1. From my personal property in my possession which has been levied upon, (a) I desire that my $300 statutory exemption be (i) set aside in kind (specify property to be set aside in kind): ~~ (ii) paid in cash following the sale of the property levied upon; or (b) I claim the following exemption (specify property and basis of exemption): . __ _ .. . . 2. From my property which is in the possession of a third party, I claim the following exemptions: (a) my $300 statutory exemption: ^ in cash ^ in kind (specify property): (b) Social Security benefits on deposit in the amount of $ ~~ bOO ~6 (c) other (specify amountfJ~~and basis of exemffp//tion): ~TC'~62 ~Q ,, ~ ~ 4 I request a prompt court hearing to determine the exemption. Notice of the hearing of the hearing should be given to me at: ponald Gossard ~i!/ ~lanr~v~ R ~~~v.~R Address G'~ p1,sl~ ~,~, ~ Q~ :~ ~ ~~ Telephone Number I verify that the statements made in this Claim for Exemption 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: ~,~ ~~~i0 THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF OF CUMBERLAND COUNTY: CUMBERLAND COUNTY COURTHOUSE .CARLISLE, PENNSYLVANIA 17013 f717) 240-6390 Courtyards of Carlisle Unit Owners Association, Inc. vs. Anna Marie Saladigo and Donald L. Gossard USA. FIRST-GLA55 FQREVER ~ ~ rP.Y ~:~ , ~~ ~ "L ~ ( ~ • rN ;~,. ~, GF j ~ ~.i + .~ t i ~. t~° ~ a (``i ~ t~ t ~'P ~,~ +7! ~ r+t y~%1 J 33 ~+ w ~i'. r~,, ~J' C ~ h ,^~ .... '• ~ o `~ V 'Y ' ~ ~` U O C , ~'~ ~ `mil -{-., ,.,w l`` ~ ~ 7'+.~ 1•r' rd , -. " ~ ~ v ..,~, f'} R*'1 ~ V ~ (' , i•~~ +ri ~? ~ ~l! ~w. a ~' Q M ,- ti -~ma w ~~ g °~ U COURTYARDS OF CARLISLE UNIT OWNERS ASSOCIATION, INC. VS ANNA MARIE SALADIGO and DONALD L. GOSSARD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2010-4156 CIVIL ACTION - LAW IN RE: CLAIM FOR EXEMPTION ORDER OF COURT AND NOW,, this 9th day of November, 2010, the Defendant Donald Gossard's cla__m for exception of his TV is granted. By t ourt, Edward E. Guido, J. Dean Reynosa, Esquire 26 West High Street Carlisle, PA 17013 e? ,i-'Donald L. Gossard 911 Hanover Manor Carlisle, PA 17013 Sheriff . ml c : N LL aF 51 SHERIFFS OFFICE OF CUMBERLAND COUNTY < Anderson 4??tiL{t ?ttU?f'F'T 91? F IYY11 1? + 'dy s Smith 2012 MAR 23 PM 2:38 .;hief Deputy Richard W Stewart rr - = " CUMBERLAND COUNT'.' PENNSYLVANIA Solicitor case Number 2010-4156 Courtyards of Carlisle Unit Owners Association, Inc. vs. Anna Marie Saladigo (et al.) SHERIFF'S RETURN OF SERVICE states that on October /2010 07:55 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, 10/27 he served a true copy of the within writ of execution, upon the defendant, wit: t. F-1 04, 27, 2010 at 1955 hours, cGossar, ontents and at he same time handing to him s Gossard, by making known unto Donald L. Donald L. Pennsylvania 17013 it of the same. Upon serving the writ of execution, a levy was the said true and correct Carlisle, Cumberland County, f levy pmailed to attorney and letter mailed to defendant on 10-29-10. completed. Postcard and copy o 11/01/2010 Claim for Exemption received in the Sheriffs office on N edule hearing 11/03/2010 ORDER OF COURT - And now, this 2nd day ber 1, 10 at 1055 hours (received via U Mail). Original claim taken to Court Administration November, 2010, a hearing on Defendant Donald November 9, 2010 at 3:45 P.M. in Courtroom # 3. Gossard is scheduled for Tuesday, By the Court, Edward E. Guido, Judge COURT -And now, this 9th day of November, 2010, the Defendant Donald Gossard's claim 11109/2010 ORDER OF for exception of his TV is granted. By the Court, Edward E. Guido, Judge Sheriff, who copy being duly sworn according to law, states that on of the within writ of execution, upon the 12/02/2010 10:23 AM -Sheldon Marshall, Deputy known unto Anna marie Saladigo, at 93 Courtyard December 2, 2010 at 1000 hours, he served defendant, to wit: Anna Marie Saladigo, by Carlisle, Cumberland County, Pennsylvania 1 e01 U3 its contents and at the same time handing to her , Drive, Ca of the same. Pon serving the writ of execution a levy was personally the said true and correct copmailed to attorney and letter mailed to defendant on 12-03-10. completed. Postcard and copy of levy n R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is 0312212012 Ron y returned as STAYED. Defendant Saladigo filed for bankruptcy. SO ANSWERS, SHERIFF COST: $121.76 ^?•------- RON R R ANDERSON, SHERIFF March 22, 2012 . ALL-?. !ni Countysulte shentf, Teleosott. Inc. Y/il ?? J 7? O `?'LJ