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Home My WebLink About10-4944 t r PA Supreme Court ID: 204853 Z 61 West Louther Street Carlisle, Pa 17013 Cuz.._ PtVt (?'• ?I (717) 249-1177 f t?' Attorney for Plaintiff ' STEPHEN R. MAITLAND, ESQUIRE DAVID CLAPPER, IN THE COURT OF COMMOM PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . NO. /0 -qqq,- CN. t -far, v. JAMES L. DUNN : CIVIL ACTION - LAW AND EQUITY Defendant 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 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 Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 0 A4- ??? ?9 STEPHEN R. MAITLAND, ESQUIRE PA Supreme Court ID: 204853 61 West Louther Street Carlisle, Pa 17013 (717) 249-1177 Attorney for Plaintiff DAVID CLAPPER, IN THE COURT OF COMMOM PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. V. JAMES L. DUNN Defendant CIVIL ACTION - LAW AND EQUITY COMPLAINT 1. Plaintiff David Clapper, hereinafter Plaintiff is an adult individual who resides at 210 Opossum Lake Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant James Lee Dunn, hereinafter Defendant is an adult individual who resides at 8260 Robin Road, Seminole, Pinellas County, Florida. 3. The amount in controversy, exclusive of interest and costs, exceeds the $8,000 amount for a magisterial district court to hear a landlord-tenant action. 4. Jurisdiction is therefore appropriate in the Cumberland County Court of Common Pleas. 5. On May 7, 2004, Plaintiff and Defendant entered into a written 5 year lease for the property at 204 Ponderosa Road, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as the Property. 6. Defendant lived in the Property for the entirety of the 5 year lease. 7. Defendant was thrown out by Plaintiff due to the excessive drinking of Defendant and his wife. 8. During the term of the lease, Defendant permitted someone to live in the basement of the Property. 9. This person removed wiring from the basement and sold it. 10. Defendant damaged the electrical outlets and the electrical system by: a: Attaching an unsafe number of Christmas lights to the property. b: Pushing electric outlet faceplates into the wall causing shorts 11. Defendant also punched a hole in the ceiling of the Property. 12. Defendant owes Plaintiff $12,812 in unpaid rent. 13. Plaintiff has since sold the Property. 14. The value of the Property was affected by the damage Defendant caused. 15. Defendant has not yet paid back rent. 16. Defendant has not yet paid the interest accrued since the May 7, 2009 close of the five year lease. 17. Defendant did not repair or pay for the damage done to the Property. 18. Defendant has violated the terms of-his five year lease by not making all rent payments on time. 19. Defendant has also violated the terms of his five year lease by not paying interest on late rent payments. 20. Defendant has also violated the terms of his five year lease by not repairing damages made to the Property during the time of his lease. WHEREFORE, Plaintiff respectfully requests this Honorable Court to find in his favor and award damages in excess of Twelve Thousand, Eight Hundred and Twelve Dollars ($12,812.00) for back rent, interest on the back rent, and other damages and remedies as the Court may find equitable. Steph R. Maitland, Esquire Attorney for Plaintiff VERIFICATION I, David Clapper, verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. 7-/?-/6 Date STEPHEN R. MAITLAND, ESQUIRE PA Supreme Court ID: 204853 61 West Louther Street Carlisle, Pa 17013 (717) 249-1177 Attorney for Plaintiff DAVID CLAPPER, IN THE COURT OF COMMOM PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . NO. V. JAMES L. DUNN : CIVIL ACTION - LAW AND EQUITY Defendant CERTIFICATE OF SERVICE I, Stephen R. Maitland, Esq., hereby certify that I have served the Complaint upon all parties of record in this proceeding in accordance with the requirements of Pa.R.C.P. §404 (relating to service outside the Commonwealth) on the following: James L. Dunn 8260 Robin Road Seminole, FL 33777-3412 Steph R. Maitland, Esquire Attorney for Plaintiff PA Supreme Court ID #: 204853 61 W. Louther St. Carlisle, PA 17013 (717) 249-1177 David D. (Buelr (Prothonotary Office of the cProthonotary Cum6er[and County, Pennsy[vania xir&S. Solionage, ESQ Solicitor /6 _ ry Qyy CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE — THE ABOVE ' CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square 0 Suite100 ® CartrsCe, PA 0 Phone 717 240-6195 0 ¶FaK.717 240-6573.