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HomeMy WebLinkAbout10-4334COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL Judicial District, County Of Ctvw? FROM ENT DISTRICT JUSTICE JUDGM q 41 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. NAME OF APPELLANT J MAG. DIET. NO. NAME OF D.J. b?/ C E--..- W I L. Sa f? Ir _ ? - o TJ 'Vm" A-. 1 L,4 C4 y I ?OS? ADDRESS APPELLANT CRY STATE ZIP CODE 6 2Ya W AY PON CoU(ZT NtF'c f1,0 Wits" VLilt C PSNnW/1-1 f 70 r-6 DATE OF JU ENT IN THE CASE OF (Pbw A), iU a Ss (DM nela 2L- /0 J t v. JOyCa- WILs'aN DOCKET SIGNATURE OF APPELLANT OR ATTORNEY OR AGENT i-7r - 00 sa 23_ /o This block will be signed ONLY when this notation is required under Pa. If appellant was Claimant (see Pa. R.C.P.O.J. No. 1001(6) in action R.C.P.D.J. No. 10086. This Notice of Appeal, when received by the District Justice, will operate as a before a District Justice, A COMPLAINT MUST BE FILED within twenty SUPERSEDEAS to the judgment for possession in this case. (20) days after filing the NOTICE of APPEAL. of Prof wx"W or Do" 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 W? E575' f5 appeilee(s), to file a complaint in this appeal Name Of aAMMee(s) q )within twenty (20) days after service of rule or suffer entry of judgment of non pros. (Common Pleas No. ?u3&VI -1 Signature otappeNant oratromey orapnf , appellee(s) RULE: To rl-AI I WA Ff 5'/-F Name ofappeaee(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 mad. (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. "v L& Date: CY / J0 .20 Signature o/Protlronofary or napuh' 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 (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 20 Signature of affiant ? o -V LU M C- M a_: CA) Fn COMMONWEALTH OF PENNSYLVANIA NOTICE OF JUDGMENTfT,RANSCRIPT COUNTY OF: CUMBERLAND Mag. Dist. No,: - - PLAINTIFF: RESIDENTIAL LEASE _ 09-3-04 rKATRINA F. ESSIS NAME and ADDRESS -1 MDJ Name: Hon. THOMAS A. PLACEY i7p41 MONTEREY DRIVE Address: 104 S SPORTING HILL RD MECHANICSBURG, PA 17050 MECHANICSBURG, PA L J VS. DEFENDANT: NAME and ADDRESS Telephone: (717) 761-8230 17050 rWILSON, JOYCE 7 ATTORNEY DEF PRIVATE 6240 HAYDON COURT : MECHANICSBURG, PA 17050 GEKAS, GEORGE W I-- J 5291 DEVONSHIRE RD Docket No.: LT- 0000235-10 HARRISBURG, PA 17112 Date Filed: 4/08/10 = THIS IS TO NOTIFY YOU THAT: Judgment: FOR PLArrrrTFF ?X Judgment was entered for: (Name) KATRINA F. ESSIS Judgment was entered against WILSON, JOYCE in a 0 Landlord/Tenant action in the amount of $ 127.50 on 6/22/10 (Date of Judgment). The amount of rent per month, as established by the Magisterial District Judge, is $ 00. The total amount of the Security Deposit is $ .00 Total Amount Established by MDJ Less • Security Deposit Applied = Adjudicated Amount Rent in Arrears $ .00 -$ .00= $ . .00 Physical Damages Leasehold Property $ .00 $ .00= Damages/Unjust Detention $ oo - $ $ . 00 on= $ _on Less Amt Due Defendant from Cross Complaint - $ -00 Interest (if provided by lease) $ -nn L/T Judgment Amount $ 00 ? Attachment Prohibited/ Judgment Costs 42 Pa.C.S: § 8127 $ 127 0 Attorney Fees $ -on ? This case dismissed without prejudice. Total Judgment $ - - 127 , 50 ?X Possession granted. Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ Possession granted if money judgment is no sa Is le y time o eviction. ? Possession not granted. ? Defendants are jointly and severally liable. IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT, IF ANY. IN ORDER TO OBTAIN A SUPERSEDEAS, THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED. HOWEVER, LOW-INCOME AND/OR SECTION 8 TENANTS SHOULD REFER TO Pa.R.C.P.M.D.J. No. 1008 OR 1013 FOR DIFFERENT PROCEDURES REGARDING THIS DEPOSIT. IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE PARTY HAS 30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS OF THE COURT OF COMMON PLEA, CIVIL DIVISION. THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THE 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 JUDGMENTDEBTOR PAYS IN FULL,, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. 4l Date , Magisterial District Judge certl y that t Is is a true an c recj.Qopy-eN y roe Fags contalrnng t he lu grnent. J_W / Date , Magisterial District Judge O A commission expires first Monday of January, 2016. SEAL A C 31SA-08 ;.. .~ .. : Past fhi .a. ,. ... ~^" 4~ -0:,a~='A' I • • ^ ~ et II ~ I • I ~ • 1I • ~ • I I• I I/ I_ .. 1 Y ~, ~ Postage $ ^ ~ Postage $ • ~ cp ~~ PS',,~ ~ Certified Fee ~ R p~jn~ Certified Fee ~~Pa.~Ta~~ Q ~~ Postma , _ ~ Postm .~. ~ Return Receipt Fee ^ ~ p Return Receipt Fee `' Q (Endorsement Regwred) ~ Here +.~ ~ (Endorsement Required) Here ~ ~ Restricted Delivery Fee ^ 1 ,. ~ 2010 7~ ~ Restricted Delivery Fee , ,UL - ~ 201 ' O (Endorsement Required) ,uI„ 0 (Endorsement Required) ' N,," ,~ t4. O7l09l2d10 -Q s<4 ~7l04/3010;,, ' ~ Total Postage & Fees ~ ,w~ p Total Postage 8 Fees ~ ~. ~~ r9 .y~h ~ ,~1'` ent o , ,,r nt o ~/ ` r ~ 4-'-'-'---•--- -~{crmA-s---~----•- / ~QM ~ ------- !~AT_(~LIUA.--°t~_.--._.~SS!5 R r"~ Sheet, AP . o.: ._._ Sher, Apt 11fo.; - - -- , 0 or POBOxNo. j Q ~ ~. °-n- ~.. ~ or PO Box No. ~~1- ,~ ~e¢EY ~,~ Jt City, srate,,~l ~ ~. ~~v1~ CS j~ Q 4 Y'~ ~ 7(,~(~ G ,state. zlP+/~,~ l ~."ftn ~jtt r~i , r 1"t 170~SO PROOF OF S!%iVICE OF Nf,1rTlCE OF APPEAL AND. RULE. TO FILE COIMP~AIMT (This proof of service MUST BE FILED WITHIN 1Ei11(t"D)`DAYS'AFTER fth'rtg of the notice of appeal. Check applicable boxes.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~/4 U ~/ ~ ! ~ ; ss AFFIDAVIT: !hereby (swear) (affirm) that I served ,~.~.I_.t<<~-~ a copy of the Notice of Appea{, Common Pleas ~D 7~' ,upon the District Justice designated therein on (date of service) ' ', 2Q ~p ^ by personal service ~ by (certified) (registered) mail, - sender's receipt attache hereto,. and upon the appellee, (name) It~1-'~iQr~yA _ F• i~,5''S~f _ , on k . 20 /0' ^ by personal service ~ by (certified) (registered) mail, sender's re ipt attached hereto. (SWORN) (AFF{RMED) AND SUBSCRIBED BEFORE ME T S ~,~'' DAY OF , 2p ~ p . Signature of adiant Signa ci b om a a' s e Tithe of o~fFrcal . .. ... . My commission expires on ' v9 , 20 ly .~.... ~~ MI'>fl1012L ~ i0llrA ~ NNiYp tom; OiRtl/INf OOYNW , ~ ~ Ju12s• 2011 ~d1~~A7J+S!`1N~d Inc?~~ ~~ ~~~~~~wn +,~ :6 ~~ ~ ! ln~ ~1 OZ 3~}~~?-t,~-Q~~id __ -~-..--•r -~-------- - -~ --~ . a.vmmvtvvlrtPU. t h VF PENNSYLVANIA COURT OF COMMON PLEAS Judicial District County Of FROM DISTRICT JUSTICE JUDGN~33y/' COMMON. PLEAS No. ~~ _ ..e;e~~ t` / , ' , NOTICE OF APPEAL 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. C~~ H//t--Sc.~N air nrrc~a.w~ ~ rr. 2- `!O N'/4 Y 17GN CUVdt z z. ~ ,v Q ss~ s P,~ NeN/ ~ r K J O ~;~cµ ~: 17d SU ~ ?as'-~ w~t_s Ua - - - - .--- ' ~~~ unct c~ wE'PELLANT OR ATTORt~Y OR AGENT This block will be signed ONLY when this notation is required under Pa. If appepant was Claimant (see 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 COMPLAINT MUST t3E FILED within twenty SUPERSEDERS to the judgment for possession in this case. (20) days after tiling the NOTICE of APPEAL. ariwno„w,ry•ot npuy 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 apps/fee. PRAECIPE: To Prothonotary Enter rule upon /~ ~" J (~ / ,~I~ ~=- c' ~ (S appellee(s), to file a complaint in this appeal Name of apAemee(s) (Common Pleas No. /~/ _ y~3N ~~ ~/~ ~' )within twenty (20) days after service of rule or suffer entry of judgment of non pros. _ ,,._ - ure o/apperianr or atromey or agB<N RULE: To 1 ~` ~ 'l r~, / r~~ ~ f.; / S , appeNee(s) Name o/ePPeNeels) .. ._ _, _. 33 Y :rte m r ~ ,. (1) You are notified that a rule is hereby entered upon you to file a complaint in this 8ppeal wi.rtvtgntyj~Q) days after the date of service of this rule upon yq~r'tJy p~ejsong~! service or by certified or registered mail. ~ , .~ ~ ,, ~ n (2) If,ybu~tld n~ot_Me'a~hlplarnt~within this time, a JUDGMENT OF NON PROS MAYBE ENTERED AGAINST YOI~.: .. t ~, , ~ ~, 1, ~~ (3) Th®~datlk'SAtr7tce ~'# tills service was by mail is the date of the mailir-g. ,. ~~ ~; c L Date: ~ s r r'"' ®* _ - - ~ ~ ~ Signature o/ ProMonotary or Deputy r '" ° YOU MU~T~~~~A~OPY OF THE NOTICE OF JUDGMENTITRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. ~a AOPC 312-02 WHfTE -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 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND ,.a.,;: o~_~ w_~ tai,,i ?J.,r,.~ n;,;, 09-3-04 THOMAS A. PLACEY `'"""` 104 S SPORTING HILL RD MECHANICSBURG, PA T:-~~,,,,,,n,, X717 ~ 761-8230 17050 ATTORNEY DEF PRIVATE GERAS, GEORGE W 5291 DEVONSHIRE RD HARRISBURG, PA 17112 THIS IS TO NOTIFY YOU THAT: Judgment: FOR PLAINTIFF _ _.-- --- ~ Judgment was entered for: (Name) RATRINA F . ES31S Judgment was entered against WILSON, JOYCE in a ^X Landlord/Tenant action in the amount of $ 127.50 on 6/22/10 (Date of Judgment) The amount of rent per month, as established by the Magisterial District Judge, is $ . 00. The total amount of the Security Deposit is $ . 00 Total Amount Established by MDJ Less ~ Security Deposit Applied = Rent in Arrears $ .00 -$ .00= Physical Damages Leasehold Property $_ . 00 - $ . 00= Damages!Unjust Detention $ _ 00 - $ _ 00 = ^ Attachment Prohibited! 42 Pa.C.S. § 8127 Less Amt Due Defendant from Cross Complaint - Interest (if provided by lease) _ L/T Judgment Amount Judgment Costs Attorney Fees ^ This case dismissed without prejudice. Possession granted. ^ Possession granted ifi money judgment i; ^ Possession not granted. NOTICE OF JUDGMENT/TRANSCRIPT RESIDENTIAL LEASE PLAINTIFF: NAlv1E ,~,~~ acoaESs ~AATRINA F. ESSIS ~ 1941 MONTEREY DRIVE MSCHANICSBURG, PA 17050 L -~ vs. DEFENDANT: NAME and ADDRESS WILSON, JOYCE ' 6240 HAYDON COURT MECHANICSBURG, PA 17050 L_ J Docket No.: LT- 0000235 -10 Date Filed: 4/08/10 ~~ ~a ---v- _~< Total Judgment Adjudicated Amou00 $ .00 $ _DO $ _00 $ _00 $ _00 $ 127.50 $ _00 $ 127.50 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ^ Defendants are jointly and severally liable. IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT, IF ANY. IN ORDER TO OBTAIN A SUPERSEDERS, THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED. HOWEVER, LOW-INCOME AND/OR SECTION 8 TENANTS SHOULD REFER TO Pa.R.C.P.M.D.J. No. 1008 OR 1013 FOR DIFFERENT PROCEDURES REGARDING THIS DEPOSIT. IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE PARTY HAS 30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTJTRANSCRIPT FORM WITH THE 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 COPJlE 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 F%AYS IN FULL, SETTLES. OR OTHERWISE COMPLIES WITH THE JUDGMENT. Date `~ t,_/-}'' _ _ ,Magisterial District Judge certi y t at t rs is a true an c rrect copy o t e recor o t e proc Ings contarnrng t o ~udgm2nt. Date ,Magisterial District Judge My commission expires first Monday of January, 2016 ~ SF111 .r F:\FILES\CGrntsU3035 EssiaU3035.3 General Business\Wilson\13035.3.complaintl Revised: 7/20/ 10 l 1:46AM Hubert X. Gilro Es uire , r ~}`~ ~ T MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES ~A .; i ,. ,,• ,, I.D. 29943 tJ~Q ~.'.{_ : ( r~ i ~1,• ~~. 10 East High Street Cazlisle, PA 17013 dui `- `,~+ ~' (717) 243-3341 rte.:':; .,-,, ~_~F°~,,,; ~. Attorneys for Plaintiff KATRINA F. ESSIS, on behalf of IN THE COURT OF COMMQN PLEAS OF CATHY SHUNNARA and CUMBERLNAD COUNTY, PENNSYLVANIA VICTOR SHUNNARA, Plaintiffs v. N0.4334-2010 CIVIL ACTION -LAW JOYCE WILSON, Defendant JURY TRIAL DEMANDED NOTICE Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 MARTSON LAW OFFICES 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 appeazance 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 maybe 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 Plaintiffs. 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 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 REDUCE FEE OR NO FEE: Date: ~~a I f 6 By Hubert X. Gilroy, Esgi 10 East High Street Carlisle, PA 17013 / (717) 243-3341 Attorneys for Plaintiff Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES LD. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff KATRINA F. ESSIS, on behalf of IN THE COURT OF COMMON PLEAS OF CATHY SHUNNARA and CUMBERLNAD COUNTY, PENNSYLVANIA VICTOR SHUNNARA, Plaintiffs v. NO. 4334-2010 CIVIL ACTION -LAW JOYCE WILSON, Defendant JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiff, Katrina F. Essis, on behalf of Cathy Shunnara and Victor Shunnara, by her attorney's MARTSON LAW OFFICES, sets forth the following: 1. Plaintiff, Katrina F. Essis, is an adult individual residing at 1941 Monterey Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Plaintiff is a rental agent for Cathy Shunnara and Victor Shunnara ("The Shunnaras") with respect to the leasing of a certain townhouse located at 6240 Haydon Court, Mechanicsburg, Cumberland County, Pennsylvania 17050 ("The Real Estate") Defendant Joyce M. Wilson, is an adult individual residing at 6240 Haydon Court, Mechanicsburg, Cumberland County, Pennsylvania 17050 ("Tenant"). 4. On October 1, 2004, Fred M. Essis was the owner of The Real Estate, and Mr. Essis entered into a Rental Agreement with the Defendant, a copy of which is attached hereto and marked as Exhibit "A" and is hereinafter referred to as the "Rental Agreement". 5. Subsequent to entering into the Rental Agreement, Fred M. Essis sold the Real Estate to The Shunnaras and The Shunnaras have designated Plaintiff Katrina F. Essis as their agent in connection with handling The Real Estate and these proceedings. 6. The Rental Agreement provided for a tenancy at the property from October 1, 2004, through September 30, 2005, with automatic renewals for one year terms pursuant to paragraph two (2) of the Rental Agreement. 7. Pursuant to an agreement between the parties dated April 11, 2007, a copy of which is attached hereto and marked as Exhibit "B," the monthly rental amount on the property was increased from $775.00 per month to $795.00 per month and the lease agreement on the property was converted to a month to month lease arrangement. 8. Throughout the tenancy, Plaintiff gave Defendant numerous notices to vacate the property and the parties consistently worked out arrangement for a continued rental of the property by the Defendant. 9. On May 7, 2010, Plaintiff gave Defendant notice to vacate and quit the property effective June 1, 2010, on the basis that the month to month tenancy was ended and Plaintiff desired to attain possession of the property. A copy of said notice is attached hereto as Exhibit "C." 10. Despite repeated demands, Defendant has failed and refused to vacate The Real Estate. 11. Plaintiff followed appropriate procedures by commencing this action with the appropriate Magisterial District Court, and these proceedings at this time are the result of an appeal filed to a judgment issued by the Magisterial District Court. 12. Plaintiff seeks an Order of Possession of The Real Estate. 13. Defendant is in violation of the Rental Agreement for refusing to vacate the property after notice from the Plaintiff and Tenant is responsible for all of the Plaintiff s attorney's fees pursuant to paragraph 22 of the Rental Agreement. 14. To date, Tenant has made the monthly rental payments, however, in the event during these proceedings the Tenant fails to make any rental payments as required under the Rental Agreement, Plaintiff seeks a judgment against Tenant in connection with any unpaid rental obligations owing. WHEREFORE, Plaintiff requests relief as follows: 1. Direct the Defendant to vacate the Real Estate. 2. Enter judgment in favor of Plaintiff against Defendant in the amount of Plaintiff s reasonable attorney's fees incurred. Enter a judgment in favor of the Plaintiff against the Defendant in the amount of any unpaid rental obligations. By Respectfully Submitted, MARTSON LAW OFFICES Hubert X. Gilroy, E 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: ~~a t ~ b •. R E N 'T' A L A G R E E M E N T THIS AGREEMENT, entered into this -~~ day of f~P~~oo~/, between here~naLCer called OWNERi~.GEAI~ and hereinafter called TENANT. 1. LOC~ T~I~N: TE~1,=t:\iT leases from OwNERf~~-T a/an ~~~~~~~,,~~~~ apartme.^.t/~h~~s~e No . ~~z ~jn which _s P located at in the City of Count' oc State of _ _ j yo a hereinafter ca_led PRE~I_ScS. 2. LEA E TERM: The ter: is a term beginning on the ~_ day az /),BD ~ Eicher party may terminate this agreement at the end of the term by giving tie other party ac least THIRTY (30) days written notice delivered by certified mail. If no notice is given, this agreement will continue without re-execution upon the same terms as in force immediately before end o= the term. This agreement will not automatica~ly continue at the end of term if TENANT is in default of this agreement. 0 G 3 . RENT: The monthly 'casic re^~c is S `~~ S, '- Payments are to be made IN ADVANCE WITHOUT DEMAND prior to the first day oz each month. Rent payments are to be made by check, cash tdo not mail? or money order and PAID to: Fred Rssis 6220 Carli:sle~Pike_Mechanicsburg, ` PA 17055. .._ 4. LATE CHARGE: If payment is roc received by the 5` day of the month, there ; s a late charge i~:,oosed _ /OI`o LATE FEE A.DD~~: S 7~~v Aster 5th day of ncr.th ^ena:ty wi_1 be 100 of one month`s remit. LATE r~^ ADDGD. S '~ 7 ~ A=cer _Jc:. day of month _here will be 5.00 per day. aL'Cl~:.ona} c arge. 5. OCC*JP~:VTS : "'::e sa,~ ~RE;~ISES shall be occupied by no mere than Q~~ gerscr:s (ad::-ts anu .._ ~o_~e..! Should morn perso.^.s than stated on this pease be oc,.,,Lv=. ~ tha _es_,.._..c=, the ^enthly re.^.ta= payme.^.~ w~,1_ increase by ter c~ ~o~ eat.. perso ~h S y_ m .:t.. _ _ n is must be acprove^ by owner ~in wr__'i"^c. G~:es~.s w--- r.c.. ba ^e_^_-cod to stay -or mo__ thar. ";vG (2? week _ ~ - s. The GC~UPA:~~~ aut::or_ze:_ ..o resiue on ?RS:~1ISnS are. o` . ~{?Y5 _OC~S_ A.*1D. SC?v_C_ TEV~ '" as ed G~koYs E C:-'..ARGES ~ ra • ...._ _ , TEVa.:'~!`' w___ .^.~ C_^.3ry^c~C =CT' a_~ '..OSt ~ lS . _.. t.L: e ~V°.^.t t:~c3t 3~~ keys are ,.^ct r etur::`d a~ c^e t::^e of tar-~inaticn of agreeme^t, or should .'~Ni 4:' r°.~.,_L:YS~ ~ ;C~{j C'.` .:~ r°-r:~y~~^C i~ilc"' rO iO5t i<cv5 , r°-iCE'_'jl. _^.:. t.^.e lOCkS aP.d t:2 CQS~ J~ =dL:.^~w__: ~„^~~ L.^,drgc~c; CC TE~1Ar~1'i'. U~ lnc norma'_ ~1CE' }':CUrS r there will tie a S ser•tic~ charge to unlock doors or rQset circuit bre=leers. _::_s serv_`e _:.~r--~ ~.~_'~ =ncrease to S '7 after o*fice hours_ 7. SEC'JR_T`_' DEPOS_T': "=V,;:VT .has paid a security deposit in the amount rs ;_w77~ °~ :'^is dacosit ;s used for reimbursement of any past due rent, Iat :ar.;eS, IcSJ', da~:aye ~.,?Si.:.^.C CY' aI'?V OC::er 2X~.e^Se a5 a reSUli. rJf TENc~.~'~IT' -, ,,.-- ie~au__. ~.:~. _ s~a_: _e_-c~.rsa C;~`~;C:~,'..,~,-ter the :.osts that exceed the amour. ~.: secur_cy ~e^cs_t :^.e_~. _I~; ti:'v" w; lI receive security dep due a.1he os~t ierg w_t:^. a-: :_e~-_zed__st c_ charges within TH1'RTY (30) days after key ave beer. re_.:r^ed to C~~~~:::c~.~;, , TENANT will never consider this securit eposit as payment o= last month's rent. Should TENANT move prior ernination oz lease or move without giving THIRTY (30) days notice,---i~e-/s ~rfeits the security depesito m W .+a~aaa 8. UTILTTI~S AND SERV{CAS: TENANT s•ha11 be responsible for the payme,~t~ costs, and care of the Lollowing checked utilities and services: UTILITIES: Electric; Gas Heat / Water & Sewer; Trash & Disposal_~ SERVICES : Lawn Care Snow Removal (f^r` CLEANING OF: Sidewalks; Hallways; Stairways; Landings. **Snow and/or ice removal from walks is responsibility of TENANT and must be removed within twenty-four (24) hours.** •. OWNER /T reserves the right to temporarily suspend to PREMISES; utilities or other services for maintenance and repair purposes or to protect property from risk or harm. OWNER/~G'~g°'shall not be liable far damage or injury to TENANT, their family, and guests as a result of suspension oL ~ utility or other service. TENANT shall not use any utilities furnished by OWNER/AGENT in a wasteful manner. If OWNER/GATT supplies electricity to PREMISES, use os. heavy duty appliances and equipment requires the written consent of OWNER/""~- before installation. APPLIANCE AGREEMENT required. 9 . PETS : ~ ~ - _ . 10. USE OF PREMISES:-.PREMISES will be used as a private residence only and will not be used for any charitable or income producing pu=-~oose. ~ TENANT sh all comply with all Federal, State, ar_d Local laws, reguiatiors and ordinances currently in force or enacted after the commencement oz this agreement. s'll. TRASH: . T_asn must be ir. SiALED _~L.AS'Ti~ TR.iSt3 B:~C-S ana placed i ~:OvERb'~ ca:2tairers at designated trash area. Trash cars are to be ulaced Cl r:Jj=de the eVer:i::•-~ ~-- y p_ _or (AFTER 5 P . M. ) to trash pick-up . TEN~.1'3T is respcr_sible for the cost. o= removing any bulky _tems . ^'ENAZVT .s resnonsi:ole for '.<eep_nc recyclable items separate from other trash. TENF1vT is res,:cnsible .or removing trash cars from curb bsr S p.m. cn plc{-up dav. 0 12. RETURNED CHEC:CS: TENANT will pay Ow'NER/T a $ p~~zee fcr any check r~turr~ed by any bank for any reason. _. _ __._ _ 13. ASSIGNMENT AND SUBLETTING: TENANT will nct ass=cr_ this agreement or sublet the PREi~=SF.S to aryoune. An attem ~ b Tom. T Y P` Y ~v~vl to assign. this agreement or sublet the PREMISES shall be null and void and T_NA1'~T shall be in default of this agreement. '14. REPAIRS AND ALTERATIONS: TENANT shall be responsible for damages caused by ~-rs/her negligence and that of -~.-s/her fami 1y or guests . TENANT is responsible for all glass, screen, and storm door repairs. TENANT shall not charge paint cclor, or otherwise redecorate or make alterations to the PREMISES without the prior written consent of OWNER~i. A1'_ alterations, additior_s, or improvements made to the PREMISES shall remain upon and be surrs_^.dered with the PREMISES. Should TENANT move prior to termination of Page 2 of 7 lease, fie./she will be charged for tn.e re-painting of unit (should re-painting be required). 15. CARE AND MAINTENANCE: TENANT shall pay for any fire, plumbing, appliance, or ary other damages to PREMISES caused due to negligence of TENAL~IT, their family, and guests. TENANT will surrender possession of PREMISES to OWNERJ~G`E'M`=' at e.^.d of term i n as gcod order, cleanliness ,• and repair as at the start of this agreement, except for r~asor_able wear and tear. TENA.~vT s~".all notify OwNERjAGENT o,: the need for any repair required. TENANT shall comply with all rules and regulations.. TENANT has signed a PROPERTY INSPECTION SKEET immediately prior to signing of rental agreement as to the conditions •of the unit. 16 . INSURANCE : OAZIER,-'~S i nsurance policy does not cover TENA.NT~ S property. If TENANT does anything to cause OWNER/~:S insurance policy to increase,' TENANT will pay all increased insurance costs. 17. RELIEF FROM DAMAGES: OWNER/-AGENT is not liable for Loss, injury, or damage to ar_y person or property unless the Loss, injury or damage is caused by ,the OWNER/~?~~ intentibnal act or neglect . OWNER/~ will not be liable whatsoever. for any injury or damage caused by water that may leak into the PREMISES. Z8 . RIGHT OF ENTRY • OWi~T'nR/-?~~~ ar_d other authorized agents will have the right to enter PREMISES ac reasonable times for inspection, maintenance and show_ng reasons or in case of an EMERGENCY. Ow1VER/i will do one of the ~1 b - - n r ._ ro_ owing e:.ore en ~er~r_a _ REMISES . a. Give oral notice to TENAN?' a day in. advance; b. Post written notice on the entrance door a day in advance; c. No notice required in an EMERGENCY ~ Z9. EMERGENCIES AND REPAIRS normal office hours of ~~ Yepor~ed immediately. The emergencies is All repairs should be reported between the ~r_e numner Lor '~3 EMERGENCI ES should be reporting any problems and 20. DEFAULT• The TENA~t'=' wi 11 have defau_ced or. this agreement __ any or the follc~.a~ ng apply : a. TENANT fail= ~-~ nay rent or other charges to the 04vVER/AGENT . r..~ S _ ._b . _ _ -_-~NANT -lama es -the _P-REMISES c . T.N~`u'~JT becomes a nuisance to Ow'~1ER/T, of er ter_ants or other property owners . d. T~~daiVT fails to comply with all conditions of t:1i s acr~emer.c, rules & reau_ations. e. TENANT fails to move themselves ar~d t:~eir belcrcings __om the PREM_SES at the end of the term. t . TENANT gives false infor~natian on the rer~tai a^. _D11Cnt1on. g. TENANT abandcns the PREMISES. 21. OWNERIT REMEDIES: If TENANT defaults, OWNER] -1~ may do any or all of the fo.'•.~owinc without giving any NOTICE OF TERMINATION or NOTICE TO QUIT to TENANT before taking action. a. Terminate this agreement without prior notice. b. Sue TEN~vT in court to recover the entire balance of the rent and charges owed for the remaining lease termer Page 3 of 7 c. Sue to recover possession of PREMISES without prior notices. d. Sue to recover unpaid rent, late charges, and damages without prior notice. e. Sue to recover all consequential expenses, damages, losses and reasonable attorney fees resulting from TENANT'S violation of any terms. 22. ATTORNEY'S FEES: =f OWNER/~~T shall enforce the provisions of this rental agreement in any court against the TENANT, OWNER/T shall be entitled as part oz ary court judgment to be reimbursed for all costs and expenses of enforcement including reasonable attorney's fees. 23. DESTRUCTION OF PREMISES: TENANT will give OWNER/A~.cW~ oral notice of any accident, fire or other major damage that happens at the PREMISES within 2a HCURS of the occurrence. TENANT 5ha11 also report any condition that may cause an accident, fire or major damage immediately. If PREMISES is partially destroyed by Lire or other casualty, TENANT shall have the right and option of the following: (1) To continue to occupy the habitable portion of the premises while repairs are being made. (2) Tc terminate t:~e Lease absolutely and receive a refur_d of rer_t paid through the date of transfer of possession to OWNER/~' . 24. DELIVERY OF POSSESSION: If OWNER j,_~'ClQT""~car_not deliver possession of PREMSES to TENANT at the beginning of the term, then the lease term will commence but the requirement to pay rent will cease until the PREMISES is ready Lor occupancy. OWNER/fir shall rot be liable to TENANT for damages clue to inability to give cossession to T~NAs~TT. 25. ILLEGALIUNENFORCEABLE LEASE CONDITIONS: Should any court determine any condition within this agreement to be illegal or unenforceable, only those conditions deemed illecal or unenforceable shall become null ar_d void. All other conditions within ~h~.s agreement shall remain in fore and TL.:AIVT agrees to comp' ;r with t::=^~. - 26 . ADDITIONAL TERMSL CONDITIONS RTDERS AMFriDMENTS : The ter.~~s and cor_dit~ons .n the riders and amendments indicated below are cart o= this /rental agreement : YES `_ ~ -- C eck-1P. ~c --- Pr rig - ~J %~ V Check out ocedu 'YES / NO -- aocliar_ce 4craemerit vES / NO Pet Agreemerit~~p J YES / NO -- ~.ules & Regu_atior~s _ _ _ _ __ ~rES -' . / N0 -__ Emerge:ncy_Irifcrir:at~on YES / NO - - ~j ,R/1 ~'~, _ YES / NO -- ~ vES / NO -- 27. ENTIRE AGR~'F...~NT '_'h_s is t e tota_ agreement between vTNNERj$~,~.~and TENANT. No other agresme-cs are va'_id u:^less in writing and approved ay all parties . '?'his ac~eeme^t ~akes precedent over all other agreements previously executed. 2$. P?ZOCEDURES FOR VACATING: (I ) T NaiJT must provide thi_ cy ( 3 0 i days writ ten notice beginning on tL.e isc day o,". the month . (2 ) TENAiVT agrees to provide unlimited access at the OWNER/A"~~: _= S request for prospective Tenants. (3) X11 Tenar_ts belongings must be removed from the PREMISES. Page 4 of 7 (4) The PREMISES must be thoroughly cleaned including having the carpets professionally cleaned. (5 ) Upon vacating, the TENANT must meet with the OWNER/AGENT to inspect the PREMISES and return the keys. All rights and liabilities herein given to or imposed upon either parties hereto, shall extend to the heirs, executors, administrators, successors, and assigns of such party. Upon signing this agreement I/We the TENANT(S) do hereby understand and accept all rules stated herein. This agreement is approved and entered into this ~~day of , ~j p if. The undersigned TENANT (S) jointly and severally liable understands, agree to and accepts all conditions imposed. - TENANT ER/AGENT ~--~~ ~-~ DATE DATE ~~ ~ ~ .~ DATE T?-BIRD PARTY GUARANTEE The undersigned individual(s) join in ar_d are jointly and severally liable cond_tions of this lease agreement.. urdersigned any rights to occupy the CTrNER/AGENT . IND.VIDUAL the execration of.this Lease agreement for the performance of all ter=ns and This guarantee shall not grant the PREMISES without written consent of ADDR3SS i~T"JIDUAL A ;DRESS DATE DA'L'E Page S of 7 I M P O R T A N T N O T I C E T'dIS PAGE EXPLAINS IMPOF.T.AiVT INFORM_~TION ABOUT `TOUR RIGHTS AND DUTIES AS A TENANT. DO NOT SIGN THIS RESIDENTIAL LEASE UNLESS YOU H.~VE READ AND CLEARLY UNDERSTAND THE INFORMATION ON THIS PAGE. As TENANT, you violate the terms and conditions of this Residential Lease if you: (Z) Fail to make timely payment of rent or other charges to OWNER/-?~G£-i~`P; or (2) Vacate the leased PREMISES without the OWNER/~18S consent prior to the end of the Iease term; or (3 ) Fail to vacate the leased PREMISES at the end of the lease tern; or (4) Fail to perform any of the obligations included in the lease, rules and regulations, the riders or amendments; or (5) Violate any rules or regulations which are made a part of the residential lease. PARAGRAPH 24 - includes a waiver of "NOTICE TO QUIT". When "NOTICE TO QUIT" is ..waived, if you violate the residential lease, the LANDLORD has the immediate right to file a complaint in court seeking an order evicting you from the leased PREMISES. The LANDLORD DOES NOT have the right to bring an action in court seekir_g your eviction unless you have violated your obligation as a TENANT. Even though you are waiving "NOTICE TO QUIT", you will still have an onpcrtunity in court to contest .'the validity of the LANDLORD'S claim for eviction. If you violate the terns and conditicns of the residential lease, the LANDLORD has the right to seek the following remedies against ycu in court: (Z) A Judgment for overdue rent, late charges, repairs and monetary damages caused by your violation of the lease and cordi tiors . (2) r1-~ order for Recovery of Possession through an eviction action. (3 ) ~ Judg~,~ent for unpaid rent for the balance of the lease tern or until another person takes possession of the leased PREMISES as a new Tenant. IF T:-iERE IS MORE T~Ai'VvNE '?'ENANT SIC-NIVG THIS RESIDENT=~~: LEAS=, THE _ENANTS ARE JOIN^?.'r ANJ SF.VE~=_L.,Y LIALE FOR THE PERFOP.`~IANCE CF ALL Tc.NANT' --0BLIGATI_CNS -.THIS ME~~TS__'?' ~~T T:~iE LANDLORD HAS THE RIGH"' "O SUE AV'Y ONE TENANT OR ALL OF THE TENANTS FvR VIOLAT=ONS OF THE LEASE IVC~JDING S~JING ANY -ONE TENANT FOR TF_E FL7~I: AMOL:VT OF THE RENT. AC?~YOWLEDGMENT : I , TH G~TDE RS IGNED TENANT (S ) r ?'TE R= ~ AND JN~ERST~~TD THE ABOVE DISCLOSL'RF. _ ~~~~Y DATE DATE Page 6 of 7 ATTACi~+SENT Ss~EET #Z APPLIANCE AGREEMENT: OWNER/AGENT agrees that TENANT Has been provided with a washer and dryer in working order. Any o~ appliances myy~,st be approved by OWNER'/ in writing. ~, Smot'e' ~ U~ cuc~l,.~..-~ ~~ o~ w ov-e~,~.a°. `~..~ RU'L~.S AND REGULATIONS. TENANT may never store any items on the front porch and must maintain porch and doorways in clean and orderly condition. TENANT agrees not•to damage any wood surf ace, i.e. doors, trim, etc. Shout-d TENANT damage any woodwork, TENANT agrees to pay for total restoration or' replacement as deemed necessary by OWNER/PST. This includes nail holes as' damage. TENANT may not use stick on type hanging attachments on any drywall surf ace . C.~RPETS: Carpets must be cleaned professionally every two (2) years, and, also upon termination of lease. PARKING: Apartment has parking facilities for ~ ( ) car(s). Scaces are directly in front of leased apartment. All other spaces are reserved for tenants. RANT PAYMENT: Rent is due in advance of the first day or month and should be delivered to OWNER/AGs^.~t'?' or. the last day of preceding month. If rent is ma_led, postmark on envelope will be accented as date of payment. If 06v1TER/'-does not receive rent prior to ]rte day of month, late charges wall be as follows: T_`_~re will. be /0 °7/ lace charge on ..c through ( p~~of Every month Or. the /~ the ? ate charge will be 10 ~ o_= one month's rent . Or_ the 1Qth, the late charge will be an additional $5.00 per day.- TEVr1VT agrees if apartment is left dirty or in need of repairs due to TEVi-ii~TT' S regligenCe, T E\T~v~I' will Jay OWNi'tZ/"'-..for any lOSS Of rental due t~ repairs or cleaning rendering apartment ur_available for rental. - G~7il f `2~-~~ T~V "' DATE T~VANT -~ ,} O . cRj:~ DATE S~~`/ DA E Page 7 of 7 ~ni the desk of Fred M. Essis ,~ ~ ~ ~~~ ~ It has always been my intention to minimise costs. Over the years, I have been absorbing these costs. Unfortunately, it has become clear rent will have to be increased to offset these expenses. Effective June i, 2007, rent _ will be increased from $775.00 to $795.00 perm G~~~ ~- { r , ~,~ ~ ~, ~ l ~~'~,. EXHIBIT 'L IVIA1~°rsa~ L~~AR~ORFF ILLLAMS O~rTO GILROY ~ ~ALLER MARTSON LAW OFFICES 1 O EAST HIGH STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE (717) 243-3341 FACSIDIILE (717) 243-1850 INTERNET wwwmartsonlawcom Ms. Joyce Wilson 6240 Haydon Court Mechanicsburg, PA 17050 May 7, 2010 RE: Katrina Essis vs. Joyce Wilson Docket No. LT-0000235-10 Our File No. 13035.3 Dear Ms. Wilson: WILLIAM F. MARTSON JOHN B. FOWLER III DANIEL K. DEARDORFF THOMAS J. WILLIAMS* No V. OTTO III HUBERT X. GILROY GEORGE B. FALLER JR.* DAVID 1~. FITZSIMONS CHRISTOPHER E. RICE JENNIFER L. SPEARS SETH T. MOSEBEY KATIE J. MAXVG'ELL BOARD CERTIFIED CIVIL TAIAL SPECIALIST Our office is the attorney for Katrina Essis who is the rental agent for Kathy and Victor Shunnara who are the owners of the apartment you are residing in at 6240 Haydon Court, Mechanicsburg, PA. The lease you signed initially for your rental agreement was dated October 1, 2004 and provided for a one year term lease. At the time in 2007 when rent was increased, the terms of the lease were modified to a month to month lease. Enclosed is a copy of a statement •that you signed which is also signed by Mrs. Essis on April 11, 2007. Please be advised that the landlord desires to terminate this year lease at the end of the current monthly period effective June 1, 2010. Please accept this letter as a Notice to Quit and you are requested to remove yourself and your belongings from the subject property on or before June 1,2010. If you do not vacate the property, appropriate eviction proceedings will be filed against you. Please be advised that this Notice to Quit is also being given based upon your forfeiture of the lease by breach of the wnditiorls of the ICase agreement based ulron your failure to reasonably provide the landlord with the ability to enter the property for purposes of inspection and determining if maintenance is required: Very truly yo rs, MARTSON W OFFICES u ert X. Troy HXG/srb cc: Mr. Michael Haydon, authorized representative of Ms. Joyce Wilson The Honorable George W. Gekas, Esquire (via facsimile (? 17) 564-6446) Mrs. Katrina Essis Mr. Wilson EXHIBIT F:\FILES~CGrnts\13635 Essis~,130353 Grneral Business~WiLson1130353.jw1 ~r..i. INFORMATION • ADVICE • ADVOCACY SM \~ ~~ ~s~~l The foregoing Complaint is bas+:d upon information which has been gathered by my counsel in the preparation of the lawsuit. The lt~nguage of the document is that of counsel and mot my awn. T have read the document and to the extent that it is based upon imforntation which I have given to my catmsel, it is sue and correct to the test of my lmawledge, inforrnertion and belief. To the extent that the content of the document is that of counsel, X have relied upon counsel in making this verification. This statement at~d verifcation a.remade subject to the penalties of ] 8 Pa. C.S, Section 49t}4 relatir+g td umsworn falsification to aathorities, wbieh provides that if I make knowingly false averments, I may be subject to crununai penalties. trine F. Essis CERTIFICATE OF SERVICE I, Ami J. Thumma, an authorized agent for Martson Law Offices, hereby certify that a copy of the foregoing Complaint was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: The Honorable George W. Gekas 5291 Devonshire Road Harrisburg, PA 17112 MARTSON LAW OFFICES By Ami J. Thu m 10 East Hi Street Carlisle, PA 17013 (717) 243-3341 Dated: July 21, 2010 KATRINA F. ESSIS, on behalf of IN THE COURT OF COMMON PLEAS OF CATHY SHUNNARA and CUMBERLAND COUNTY, PENNSYLVANIA VICTOR SHUNNARA, Plaintiffs v• N0.4334-2010 CIVIL ACTION -LAW ca ^~ ~:- _ _ JOYCE WILSON, ,. c ~ . Defendant JURY TRIAL DEMANDED ~ `` ~' ~T~' r , ; -, ..p ~:~ Answer ~ _„w To Complaint ~~ '~° ~~ And now comes the defendant, Joyce Wilson, and by her attorney, George W. Gekas, Esq., answers the Complaint as follows: 1. Admitted 2. Admitted 3. Admitted, but Defendant's name is spelled Willson. 4. Admitted 5. Admitted 6. Admitted 7. Admitted insofar as this pazagraph avers that the rental amount was increased from $775.00 to 795.00; in all other respects, the averments contained in this pazagraph are denied; on the contrazy, Defendant avers that she never agreed to or signed any document purporting to convert the basic agreement to a month to month. 8. Defendant has no knowledge of the basis for the averments contained in paragraph 8 and therefore demands proof thereof. 9. Admitted 10. Admitted 11. Admitted 12. Admitted 13. The averments contained in paragraph 13 are denied; on the contrary, the Defendant avers that she has never been in violation of the Rental Agreement for refusing to vacate the property or for any other reason and the averments as to attorney's fees are conclusions of law and therefore require no answer. 14. Avers conclusions of law and therefore requires no answer. Wherefore, Defendant requests the Court to enter judgment in favor of the Defendant. NEW MATTER 1. The parties to this dispute are operating under the provisions of the rental agreement attached to the Complaint as Plaintiffs Exhibit A, Which expires on September 30, 2010. 2. The Defendant did not agree to any conversion of said Rental Agreement to a month-to-month agreement. 3. The relief sought by the plaintiff in the complaint cannot be granted, it bring premature under the terms of Plaintiff's Exhibit B. Wherefore, the Defendant urges dismissal of the Complaint and entry of judgment in favor of the Defendant. Res lly Sub , George W. Gekas, Attorney for Defendant VERIFICATION The forgoing Response is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 P.A. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Joyce M. Willson ~,~~ ~~ Hubert X. Gilroy, Esquire Katie J. Maxwell, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 29943 I.D. 206018 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ~GI~~s;~~~' i 1 t'~i '$ aoco ~}uG. tZ 'PM 3~5~ Gtr, ,.~ i:.,.;; °,r r~~, ,; KATRINA F. ESSIS, on behalf of CATHY SHUNNARA and VICTOR SHUNNARA, Plaintiffs v. JOYCE WILSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.4334-2010 CIVIL ACTION -LAW JURY TRIAL DEMANDED PETITION FOR RELEASE OF RENTAL MONEY Plaintiffs, Katrina F. Essis on behalf of Cathy Shunnara and Victor Shunnara, by their attorneys, MARTSON LAW OFFICES, sets forth the following: 1. The above captioned action is alandlord/tenant matter and is an appeal by the tenant of a Judgement of Eviction issued against the tenant in favor of the landlord. 2. Upon filing the appeal in this case, the Defendant/tenant paid $845.00 to the Cumberland County Prothonotary for rent for July 2010 and has recently paid $845.00 as rent for August 2010. 3. Pursuant to Pennsylvania Magisterial District Judges' Rule 1008(d), upon application of the landlord the Court shall release appropriate sums from the escrow account held by the Prothonotary while an appeal is pending to compensate the landlord for the tenant's actual possession and use of the premises during the tenancy of the appeal. Consent to Petition for Release of Rental Money signed by Defendant's Attorney is attached. 4. Petitioner requests this Honorable Court to issue the attached Order specifying that the rental monies paid by the tenant maybe payable to Katrina F. Essis on behalf of Cathy Shunnara and Victor Shunnara. 5. Defendant/tenant has filed an Answer to the Complaint, which Answer merely contests the issue as to whether the term of the lease is over. There are no allegations on behalf of the tenant/Defendant with respect to any claims for damages. WHEREFORE, Petitioner requests that the Court release the rental monies paid by the tenant to the Prothonotary to the landlord/Plaintiff. Respectfully Submitted, MARTSON LAW OFFICES Hubert .Gilroy, Esquire Kattie J. Maxwell, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: August ~ 7 , 2010 KATRINA F. ESSIS, on behalf of CATHY SHUNNARA and VICTOR SHUNNARA, Plaintiffs v. JOYCE WILSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.4334-2010 CIVIL ACTION -LAW JURY TRIAL DEMANDED CONSENT TO PETITION FOR RELEASE OR RENTAL MONEY I, George W. Gekas, attorney for Defendant Joyce Wilson, hereby agree and consent to the entry of an Order directing the Court to release rental monies paid to the Prothonotary by Defendant/tenant to Plaintiff Katrina F. Essis. Date: 1 ~ ~ ~ George W. Gekas, Esquire Attorney for Defendant Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff KATRINA F. ESSIS, on behalf of CATHY SHUNNARA and VICTOR SHUNNARA, Plaintiffs V. JOYCE WILSON, Defendant IN THE COURT OF CO CUMBERLAND COUN NO. 4334-2010 CIVIL ACTION - LAW : JURY TRIAL PRAECIPE ..,, ?. Er `i` y;1 LION PLEAS OF , PENNSYLVANIA This action involves a Judgment for Possession of Real Property. The Defendant filed with the Prothonotary rent owing at the time the Defendant filed an appeal and, pursuant to PA.R.C.P.M.D.J.1008(B), the appeal acted as a Supersedeas for Judgme t of Possession. The docket in this case demonstrates that the Defendant last paidr nt on September 7, 2010 which was rent for September, and that no payments have been made for rent for October or November. Payments for October and November are overdue pursu int to the lease and the applicable Rules. Pursuant to PA.R.C.P„M.D.J.1008(B)please accept this Praeci e as a request that the Supersedeas on this appeal be terminated so that the Plaintiff may procee with the enforcement of the Judgment of Possession of Real Property. Date: November ?' , 2010 Respectfully Submitted, MARTSON LAW OFFI S By Hubert X. Gil oy, squire Kattie J. MIaxwell, ,squire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plain iff Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 29943 10 Bast High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff KATRINA F. ESSIS, on behalf' of CATHY SHUNNARA and VICTOR SHUNNARA, Plaintiffs IN THE COURT OF CO CUMBERLAND COUN 4ON PLEAS OF , PENNSYLVANIA V. JOYCE WILSON, Defendant NO. 4334-2010 CIVIL ACTION - LAW : JURY TRIAL D DIRECTIVE FROM PROTHONOTARY ED Upon confirmation filed by the Attorney for the Appellee of failure of the Appellant to deposit the monthly rent when it became due, the Supersedeas in the abo e case is terminated. By /S ? ,&2G -David D. Buell, C I CUMBERLAND COUNTY PROTHONOTARY OFFICE - GENERAL FUND Check Date: 11/17/2010 * 2004 Case No. Defendant Descriptions Amt Released Receipt 10-04334 ESSIS KATRINA F RENT 845.00 247769 10-04334 ESSIS KATRINA F RENT 845.00 250883 ?a •p\ i 1 4d _ _ .A'W9 Check Amount: 1690.00 INFOCON CORPORATION[L1558HB13385603 David D Buell ORRSTOW N BANK SHIPPENSBURG, PA CUMBERLAND COUNTY PROTHONOTARY OFFICE 60-15031313 GENERAL FUND I COURTHOUSE SQUARE, SUITE 100 CARLISLE, PA 17013 CHECK DATE CHECK NUMBER PAY THIS AMOUNT 11/17/2010 2004 $1,690.00 One Thousand Six Hundred Ninety And 00/100 Dollars TO THE ORDER OF ESSIS KATRINA F 1941 MONTEREY DRIVE 10-4334 G MECHANICSBURG, PA 17050 s SIGNATURE [[800 200 41f' i:0 3 L 3 L 50 3 61: LOB L L L L 7 ill' 09140311162010 Cumberland County Prothonotary's Office Page: 1 PYS380 Check Register Costs & Fees Tran Receipt Case Trans Check Check Check Payee Name - Rel Date Desc No No Amount Date No Amount ESSIS KATRINA F RENT 9/07/2010 PYMT/MONEY ODR 247769 10-04334 845.00 11/08/2010 PYMT/CHECK 250883 10-04334 845.00 11/17/2010 2004 1,690.00 ** Total Amount Released 1,690.00 -----------------------------------End of Listing --------------------------------------------------------------------- KATRINA F. ESSIS, on behalf of CATHY SHUNNARA and VICTOR SHUNNARA Plaintiff JOYCE WILSON Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No. 2010-4334 Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. dam-- C Sign atu Signature L? Roger B Irwin Name (Chairman) IRWIN & McKNIGHT, P.C. Law Firm 60 West Pomfret St Address Marylou Matas Name SAIDIS SULLIVAN Law Firm 26 West High St Address Andrew J Petsu. Jr. Name JOHNSON DIIFFIF. Law Firm 301 Market St Address Carlisle, 17013 Carl i gi ill 17011 Lemoyne 17043 City, Zip city, zip city, Zip ?CL PA10 / Sl 3 I ? ?ti ? ? / Aw a d 7 I We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following g award: (Note: If a ages for delay are awarded, they shall be separately stated.) L? L t7/ r/1 CA l/C7l Q ` r/ I%,? ri l?7 7< ? e s ycc/,1' S`'lG?ll V ,c C 7?„ n...l ?r4,I-P D?li,tlfi? .IC iAIAYffd0_/ i [xLLif?r"U'li_ )?P.S $ A /Y-/) . 06 . Arbitrator, dissents. (Insert name if applicable.) Date of Hearing: ? / S ??- o ( o Date of Award: "ill is )-oc 0 Notice of Entry of Award Now, the day of , 20at?.M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' cornpensation to be paid upon appeal: $-J ? ?_ • Prothonotary Deputy FILED-OFFICE OF THE PROTHONOTARY 2010 DEC 17 PH 1: 12 CUMBERLAND COUNTY PENNSYLVANIA ?OpteS r'+??ISCI, ogy i. BLE U- -[14- F PRAECIPE FOR LISTING CASE FOR i, A'!, 2011 JAi 19 PH 1' 1i " TO THE PROTHONOTARY OF CUMBERLAND COUNTY ,U MBERLAN 1,OU Please list the following case: ? for JURY trial at the next term of civil court. X for trial without a jury. KATRINA F. ESSIS, on behalf of CATHY SHUNNARA and VICTOR SHUNNARA, (Plaintiffs) VS. JOYCE WILSON, ? Civil Action - Law X Appeal from arbitration (other) (Defendant) The trial list will be called on April 5, 2011 and last day for Setting Down Cause for Trial List is March 14, 2011 Trials commence on May 2, 2011 Pretrials will be held on April 20, 2011 (Briefs are due S days before pretrials) No. 2010-4334 Civil Term Indicate the attorney who will try case for the party who files this praecipe: Hubert X. Gilroy, Esquire Indicate trial counsel for other parties if known: George W. Gekas, Esquire This case is ready for trial. Date: January I / , 2011 Signed: 6A?-Vj/ Print Name: Hubert X. Gilroy Attorney for: Plaintiffs pdaN7 LlL a3`17V 4d )s-3 y6 y CUMBERLAND COUNTY PROTHONOTARY OFFICE - GENERAL FUND Check Date: 01/19/2011 Case No. Defendant Descriptions 10-04334 ESSIS KATRINA F RENT 10-04334 ESSIS KATRINA F RENT 10-04334 ESSIS KATRINA F RENT * 2017 * Amt Released Receipt 845.00 252075 307.53 252448 845.00 253064 C c C.7 -n --i -Tt FT1 N --m r-j David D. Buell CUMBERLAND COUNTY PROTHONOTARY7 OFFICE GENERAL FUND 1 COURTHOUSE SQUARE, SUITE 100 C.ARLISLE, PA 17013 CHECK DATE CHECK NUMBER 01/19/2011 2017 Check Amount: 1997.53 INFOCON CORPORATION[L15581-1813385603 ORRSTOWN BANK SFHPPENSBURG. PA 60-15031313 PAY THIS AMOUNT $1,997.53 One Thousand Nine Hundred Ninety Seven And 53/100 Dollars TO THE ORDER OF ESSIS KATRINA F 1941 MONTEREY DRIVE 10-4334 MECHANICSBURG, PA 17050 f 10 - `j.' 3y `Irt eaAe- lron? " 000 20 L 7f1' i:0 3 L 3 L 50 36i: L08 L L L L 7 Pin 8 B 12010701192011 Cumberland County Prothonotary's Office Page: 1 PYS380 Check Register Costs & Fees Tran Receipt Case Trans Check Check Check Payee Name - Rel Date Desc No No Amount Date No Amount ESSIS KATRINA F RENT 12/07/2010 PYMT/CHECK 252075 10-04334 845.00 12/14/2010 PYMT/CHECK 252448 10-04334 307.53 1/03/2011 PYMT/CHECK 253064 10-04334 845.00 01/19/2011 2017 1,997.53 ** Total Amount Released 1,997.53 ---------------- -----------------------------------End of Listing ----------------------------------------------------- CUMBERLAND COUNTY PROTHONOTARY OFFICE - GENERAL FUND Check Date: 02/09/2011 Case No. Defendant Descriptions 10-04334 ESSIS KATRINA F RENT 2 * 2031 Amt Released Receipt 845.00 254823 ??7 C.?3 ?TTi mac' '? Check Amount : INF000UAF R9ION[L1558HB13385603 David D. Buell ORRSTOWN BANK SHIPPENSBURG, PA CUMBERLAND COUNTY PROTHONOTARY OFFICE 60-15031313 GENERAL FUND 1 COURTHOUSE SQUARE, SUITE 100 CARLISLE, PA 17013 U CHECK DATE CHECK NUMBER PAY THIS AMOUNT e 02/09/2011 2031 $845.00 0 Eight Hundred Forty Five And 00/100 Dollars m TO THE ORDER OF ;r ESSIS KATRINA F 1941 MONTEREY DRIVE m 10-4334 MECHANICSBURG, PA' 11050 AUTHO IZED SIGNATURE 11100203111' i:0313L503611: 108 LLLL71111 13400102092011 Cumberland County Prothonotary's Office PYS380 Check Register Costs & Fees Tran Receipt Case Trans Check Check Payee Name - Rel Date Desc No No Amount Date No ESSIS KATRINA F RENT 2/07/2011 PYMT/MONEY ODR 254823 10-04334 845.00 02/09/2011 2031 Total Amount Released Page: 1 Check Amount 845.00 ** 845.00 -----------------------------------End of Listing --------------------------------------------------------------------- CUMBERLAND COUNTY PROTHONOTARY OFFICE - GENERAL FUND Check Date: 03/23/2011 Case No. Defendant Descriptions 10-04334 ESSIS KATRINA F RENT Check Amount: * 2038 * Amt Released Receipt 845.00 256282 INFOCON4CORPORAOTION[L 1558HBI 3385603 David D. Buell ORRSTOWN BANK SHIPPENSBURG, PA CUMBERLAND COUNTY' PROTHONOTARY OFFICE 60-15031313 - GENERAL FUND i COURT14OUSE SQUARE, SUITE 100 CARLISLE, PA 17013 CHECK DATE CHECK NUMBER PAY THIS AMOUNT Q3/23/2011 2036 $845.00 Eight Hundred Forty `Five And 00/100 Dollars TO THE ORDER OF ESSIS KATRINA F 1941 MONTEREY DRIVE G 10-4334 MECHANICSBURG, PA 17050 AUTHORIZED 81GNATURE 110002038111 1:0 3 L 3 L 50 3 61: L08 L L L L 4 Iii' 14321203232011 Cumberland County Prothonotary's Office PYS380 Check Register Costs & Fees Tran Receipt Case Trans Check Check Payee Name - Rel Date Desc No No Amount Date No ESSIS KATRINA F RENT 3/08/2011 PYMT/CHECK 256282 10-04334 845.00 03/23/2011 2038 Total Amount Released Page: 1 Check Amount 845.00 ** 845.00 -----------------------------------End of Listing --------------------------------------------------------------------- CUMBERLAND COUNTY PROTH0NOTARY OFFICE - GENERAL FUND Check Date: 0:/29/20-1 Case No. Defendant 10=04334 ESSIS KATRINA F * 2049 * Descriptions Amt Released Receipt RENT 845.00 258097 Check Amount: 845.00 INFOCON CORPORATION[L1558HB] 3385603 CHECK DATE CHECK NUMBER PAY THIS AMOUNT 04/29/2011 2049 $845.00 David D. Buell ORRSTOWN BANK SHIPPENSBURG; PA CUMBERLAND COUNTY PROTHONOTARY OFFICE 60-1503/313 GENERALFUND I COURTHOUSE SQUARE, SUITE 100 CARLISLE, PA 17013 Eight Hundred Forty Five And 00/100 Dollars TO THE ORDER OF ESSIS KATRINA F 1941 MONTEREY DRIVE 10-4334 MECHACHA NICSBURG, PA 17050. AUTHORIZED SIGNATURE 11100204911' 1:0313L50361: LOB L111I7L11' 0 m m A E 09154604292011 Cumberland County Prothonotary's Office Page: 1 PYS380 Check Register Costs & Fees Tran Receipt Case Trans Check Check Check Payee-Name Rel Date Desc No No Amount Date No Amount ESSIS KATRINA F RENT 4/18/2011 PYMT/CHECK 258097 10-04334 845.00 04/29/2011 2049 845.00 ** Total Amount Released 845.00 ------------------ -----------------End of Listing -------- --------------- ------------------- ------------ --------------- KATRINA F. ESSIS, IN THE COURT OF COMMON PLEAS OF ON BEHALF OF CUMBERLAND COUNTY, PENNSYLVANIA CATHY SHUNNARA AND VICTOR SHUNNARA, PLAINTIFF JOYCE WILSON, -03 rn '- 1 DEFENDANT 10-4334 CIVIL Torn l - r IN RE: VERDICT IN NON-JURY TRIAL Co -o z° rs c3 -n ORDER OF COURT =c C AND NOW, this 10`h day of June, 2011, upon consideration of the evidence presented at Trial in this case on June 1, 2011, this Court finds in favor of the Plaintiff, Accordingly, IT IS HEREBY ORDERED AND DIRECTED that: 1. The Defendant, Joyce M. Wilson, is evicted from the real estate at 6240 Haydon Court, Mechanicsburg, PA, and possession of said real estate shall be delivered to Plaintiffs on or before July 1, 2011. 2. A money judgment in entered in favor of Plaintiffs against Defendant Joyce M. Wilson, in the amount of $5,909.78 which represents the following: A. The sum of $1,690.00 which represents rent unpaid for the months of May and June 2011. B. The sum of $300.00 which represents unpaid sewer fees for two quarters. C. The sum of $3,772.40 which represents attorney's fees incurred by the Plaintiffs. D. The sum of $147.38 which represents costs to file appeal, certified mail costs and costs to list for trial. 3. This Court shall retain jurisdiction over this case to address the following: A. Consistent with 68 P.S. Section 250.512, within 30 days of the Defendant's surrender of the mentioned premises to the Plaintiffs, which shall occur by virtue of Defendant's attorney notifying Plaintiffs' attorney when the premises has been vacated by the Defendant, which shall be no later than July 1, 2011, the Plaintiffs shall provide the Defendant with a written list of any damages to the leasehold premises for which the Plaintiffs claim the Defendant is liable. This accounting shall include an adjustment credit for any escrow deposit Defendant has paid. Plaintiffs shall file of record Plaintiffs' notification as required under this provision. In the event the parties are unable to resolve any disagreement relative to a damage claim of the Plaintiffs or the return of any escrow deposit that may have been made by the Defendant, either party shall have 30 days from the date Plaintiffs serves on Defendant's attorney and file of record said accounting to file a petition with this Court requesting an additional hearing to resolve that issue. B. Also within 30 days from the date Plaintiffs file of record said accounting as required in paragraph 3(A) above, Plaintiffs shall have 30 days from said date to file a petition with this Court raising any additional claims for a request for additional judgment to be issued against the Defendant for damages to the lease hold, any additional rents Defendant may be liable for as a result of holding over beyond the July 1, 2011, date specified above, and any additional attorney's fees Plaintiffs incur relative to enforcement of the provisions of this Order By the Court, / Hubert Gilroy, Esquire tvt` Attorney for Plaintiff CpP1E? o? t( George W. Gekas, Esquire bl! P?F' Attorney for Defendant Court Administrator -- BA S ??1o??e bas KATRINA F. ESSIS, IN THE COURT OF COMMON PLEAS OF ON BEHALF OF CUMBERLAND COUNTY, PENNSYLVANIA CATHY SHUNNARA AND "ra3 = -+ VICTOR SHUNNARA, ern PLAINTIFF 7.=:7, -0 -,r- 'er ? i a V. C z© " JOYCE WILSON, - o `=may C. ) DEFENDANT 10-4334 CIVIL . rn Q1 ?v IN RE: PETITION TO ADJUST JUDGMENT ISSUED IN THE ABOVE CASE ORDER OF COURT AND NOW, this 2nd day of September, 2011, upon consideration of the Plaintiff's Petition to Adjust Judgment Issued in the Above Case, 1. A rule is issued upon the Defendant to show cause why the Plaintiff is not entitled to the relief requested; 2. The Defendant will file an answer to this petition on or before September 23, 2011; 3. A copy of said answer will be filed with this Court; 4. If no answer to the Rule to Show cause is filed by the required date, the relief request by Plaintiff shall be granted upon receipt of a Motion to Make Rule Absolute. By the Court, .? Hubert Gilroy, Esquire Attorney for Plaintiff 41eA g1?l?p? -/George W. Gekas, Esquire Attorney for Defendant Court Administrator •- N"t UA- M. L. Ebert, Jr., J. bas Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY MARTSON LAW OFFICES I.D. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff & FAiWIDEC - 9 pM 12: 5 ,5 '-%UMBERLA D coq , PENNs YLVARIA KATRINA F. ESSIS, on behalf of IN THE COURT OF COMMON PLEAS OF CATHY SHUNNARA and : CUMBERLAND COUNTY, PENNSYLVANIA VICTOR SHUNNARA, Plaintiffs V. NO. 4334-2010 CIVIL ACTION - LAW JOYCE WILLSON, Defendant : JURY TRIAL DEMANDED COURT ORDER AtN AND NOW, this _ day of December, 2011, upon being advised by the parties that an agreement is reached in this natter, it is Ordered and directed as follows: The hearing scheduled in this case for Friday, December 9, 2011, is cancelled. 2. The Order of Court dated June 10, 2011 is modified such that paragraph 2 is replaced with the following: A money judgement is entered in favor of Plaintiffs against Defendant Joyce M. Wilson in the amount of $4,028.77. This amount takes into consideration the original Judgment issued by the Order of June 10, 2011, additional charges that have accrued in favor of the Plaintiffs since that time, a credit for a security deposit Defendant made and credit for payments Defendant has made to the Plaintiffs since 10, 2011. 3. This a final Order of Court in this matter and resolves all issues which this Court retained jurisdiction over pursuant to paragraph 3 of the June 10, 2011, Order. BY THE COURT, ?W' -?? - M.L. Ebert, Jr., Judge cc: ? Hubert X. Gilroy, Esquire V' George W. Gekas, Esquire eo p;Ps ma "I ed )441 F1LEU-ci! !' l .4_ ?4E PROTyo?; {, y r?-g-t'