The URL can be used to link to this page

Home My WebLink About11-0486FIL.FO-0I= iCF 2 JAN 19 PM 3: 31 Johnson, Duffle, Stewart & Weidner By: Wade D. Manley, Esquire I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 wdm@jdsw.com JAMES E. GRANDON, JR. and JEAN GRANDON t/d/b/a SLEEPY HOLLOW ENTERPRISES, 3913 Market Street Camp Hill, PA 17011 Plaintiffs V. CHAUDRY ASLAM 5337 Oxford Circle, Apartment 69 Mechanicsburg, PA 17055 Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. J), &19 l v J ARBITRATION 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 (800) 990-9108. 4) ` ?#d5313 / AVISO LISTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mfis adelante en [as siguientes p6ginas, debe tomar accibn dentro de los pr6ximos veinte (20) dfas despu6s de la notificaci6n de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aquf en contra suya. Se le advierte de que si usted falla de tomar accibn 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 reclamaci6n o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mcis aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 Johnson, Duffle, Stewart S Weidner By: Wade D. Manley, Esquire I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 wdm@jdsw.com JAMES E. GRANDON, JR. and JEAN GRANDON t/d/b/a SLEEPY HOLLOW ENTERPRISES, 3913 Market Street Camp Hill, PA 17011 Plaintiffs V. Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CHAUDRY ASLAM 5337 Oxford Circle, Apartment 69 Mechanicsburg, PA 17055 Defendant ARBITRATION COMPLAINT AND NOW, come the Plaintiffs, James E. Grandon, Jr. and Jean Grandon, d/b/a Sleepy Hollow Enterprises, by and through their counsel, Johnson, Duffie, Stewart & Weidner, P.C., and files this Complaint and in support thereof avers as follows: 1. The Plaintiffs, James E. Grandon, Jr. and Jean Grandon, d/b/a Sleepy Hollow Enterprises, are adult individuals residing at 3913 Market Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant, Chaudry Aslam, is an adult individual currently residing at 5337 Oxford Circle, Apartment 69, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The Plaintiff is the owner of certain real property, consisting of residential property located at 4800(A) Charles Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 (the "Property"). 4. The Plaintiff leased the Property to the Defendant from October 1, 2004 to November 29, 2010 (the "Lease Term"). 5. The lease agreement was evidenced by a written Lease Agreement, dated September 29, 2004 and all amendments thereto, and executed by the parties. A true and correct copy of the Lease Agreement is attached hereto as Exhibit "A" and incorporated herein by this reference. 6. The Defendant vacated the property at the end of the Lease Term. 7. The Lease Agreement provided that the tenant will not destroy, damage or deface any part of the property or common areas in that if any portion of the property is destroyed, damaged or defaced, the Defendant would be solely responsible to pay the cost for repairing any damage that is the fault of the Defendant, the Defendant's family or the Defendant's guests. 8. The Defendant returned the property to the Plaintiff at the end of the Lease Term with significant damage. 9. The Defendant breached the Lease Agreement by failing to properly maintain the property during the lease Term. 10. The Defendant breached the Lease Agreement by failing to return possession of the Property to the Plaintiff at the end of the Lease Term in a clean and undamaged condition. 11. As a result of the Defendant's breach of the Lease Agreement, the Plaintiff was then able to re-let the property for a period of a month. 12. The fair rental value of the property is $595.00 per month. 13. As a result of the Defendant's breach of the Lease Agreement, the Plaintiff has been damaged in the amount of $595.00 for loss of fair rental value of the property. 14. As a result of the Defendant's breach of the Lease Agreement, the Plaintiff had to make certain repairs to the condition of the property, including but not limited to installation of new kitchen with appliances, new flooring and painting, painting of the entire unit, replacement of hall carpeting, replacement of broken doors and medicine cabinets, replacements of a bathtub and significant refurbishment of the entire property. 15. As a result of the Defendant's breach of the Lease Agreement, the Plaintiff has been damaged in an amount less than the jurisdictional limit of $50,000.00 for damages and necessary repairs to the Property. 16. Pursuant to paragraph 23 of the Lease Agreement, Plaintiff is entitled to recover costs and expenses of this litigation, including attorneys' fees from Defendant. WHEREFORE, the Plaintiff, James E. Grandon, Jr., d/b/a Sleepy Hollow Enterprises, respectfully demands that this Honorable Court enter a judgment against the Defendant, Chaudry Aslam, and in favor of the Plaintiff in an amount necessary to require scheduling of an arbitration hearing, said sum including but not limited to loss of rental value, costs of repair and refurbishment of the Property, interest, fees, Plaintiff's costs of suit including Plaintiff's attorneys' fees and other further relief as the court may redeem proper. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER By: I Wadd D. Mabley, Esquire Attorney I.D. No. 87244 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Plaintiffs DATE: (((I([( 427709 7123-52 VERIFICATION WE, JAMES E. GRANDON and JEAN GRANDON, d/b/a SLEEPY HOLLOW ENTERPRISES, hereby acknowledge that we are the Plaintiffs in this action; that we have read the foregoing Complaint; and that the facts stated therein are true and correct to the best of our knowledge, information and belief. We understand that any false statements herein are made subject to penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. JAMES E. GRANDON d/bla SLEEPY HOLLOW ENTERPRISES JEANPRANDON d/b/a LEEPY HOLLOW ENTERPRISES DATE: SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson pF Sheriff ' Jody S Smith Chief Deputy a p r' Richard W Stewart Solicitor t_iki%b F APEN- James E. Grandon, Jr. Case Number vs. Chaudry Aslam 2011-486 SHERIFF'S RETURN OF SERVICE 02/25/2011 01:45 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on February 25, 2011 at 1345 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Chaudry Aslam, by making known unto himself personally, at 305 Keith Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. AMANDA COBAUGH, DE TY SHERIFF COST: $37.44 February 28, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF cj Gou!;TySuite S -,tf. f eleos ft n; J JAMES E. GRANDON, JR. and : IN THE COURT OF COMMON PLEAS JEAN GRANDON t/d//b/a : CUMBERLAND COUNTY, PENNSYLVANIA SLEEPY HOLLOW ENTERPRISES, 3919 Market Street Camp Hill, PA 17011 CIVIL ACTION- LAW Plaintiffs V. : NO: 11-486 CIVIL` rnc?a CHAUDRY ASLAM : U) t?3 k 5337 Oxford Circle, Apartment 69 r- ° Mechanicsburg, PA 17055 Arbitration im Defendant i -t co NOTICE TO PLEAD TO: James E. Grandon, Jr and Jean Grandon You are hereby notified to plead to the enclosed Preliminary Objections with twenty (20) days from service hereof or a default judgment may be entered against you. f Mary, . Anater, Esq. Atto ey for the Defendant PRELIMINARY OBJECTIONS To the Honorable Judges of said Court: And now, this 15th day of March, 2011, comes Defendant, to file this Preliminary Objection in the nature of a improper service, in the above captioned matter, for the reasons hereinafter set forth: 1. Plaintiff filed a complaint with the prothonotary of the Court of Common Pleas of Cumberland County on January 19, 2011. 2. Plaintiff served said complaint by sheriff on the Defendant on February 25, 2011. 3. Rule 401 of the Pennsylvania Rules of Court state that service of a complaint must be made within thirty days after the filing of the complaint. 4. Plaintiff did not serve Defendant within that thirty day time frame making service improper and this complaint not properly before the Court. Therefore, Defendant respectfully requests the Court to dismiss Plaintiff s complaint for improper service. THE SHAGIN LAW GROUP, LLC By: Mary 4etersater Supreme Court ID #86977 120 South Street Harrisburg, PA 17101 (717) 221-1111 Attorney for Defendants Dated: J A? 0;lall JAMES E. GRANDON, JR. and : IN THE COURT OF COMMON PLEAS JEAN GRANDON t/d//b/a : CUMBERLAND COUNTY, PENNSYLVANIA SLEEPY HOLLOW ENTERPRISES, 3919 Market Street Camp Hill, PA 17011 Plaintiffs V. CHAUDRY ASLAM 5337 Oxford Circle, Apartment 69 Mechanicsburg, PA 17055 Defendant CIVIL ACTION- LAW NO: 11-486 CIVIL Arbitration CERTIFICATE OF SERVICE I, Mary Peters Anater, counsel for Chaudry Aslam, defendant, hereby certify that on this day, the 16th day of March, 2011, that a true and correct copy of Defendant's Preliminary Objections mailed to the following: Wade D. Manley, Esq. Johnson, Duffle, Stewart & Weidner 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Respectfully submitted, THE SHAGIN LAW GROUP, LLC Dated: By: Mary eters Anater Supreme Court ID #86977 120 South Street Harrisburg, PA 17101 717-221-1111 JAMES E. GRANDON, JR. and : IN THE COURT OF COMMON PLEAS JEAN GRANDON t/d//b/a : CUMBERLAND COUNTY, PENNSYLVANIA SLEEPY HOLLOW ENTERPRISES, 3 919 Market Street Camp Hill, PA 17011 CIVIL ACTION- LAW Plaintiffs `c-71 `f' -- c-D V• :NO: 11-486 CIVIL .c rC0 a C-r CHAUDRY ASLAM 5337 Oxford Circle, Apartment 69 yr - Mechanicsburg, PA 17055 r a Arbitration 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 is 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 Petitioner. 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17103 Telephone No. (717) 249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientas 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 comparencencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormFnte, el caso puede proceder sin usted y un fallo por cualqquier 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. Usted puede perder dinero o propiedad a otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME O VAYA A LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17103 Telephone No. (717) 249-3166 JAMES E. GRANDON, JR. and : IN THE COURT OF COMMON PLEAS JEAN GRANDON t/d//b/a : CUMBERLAND COUNTY, PENNSYLVANIA SLEEPY HOLLOW ENTERPRISES, 3919 Market Street Camp Hill, PA 17011 CIVIL ACTION- LAW Plaintiffs V. : NO: 11-486 CIVIL CHAUDRY ASLAM 5337 Oxford Circle, Apartment 69 Mechanicsburg, PA 17055 Arbitration Defendant ANSWER TO COMPLAINT Defendant Chaudry Aslam, through his attorney, Mary E. Anater, hereby answers this complaint and avers as follows: 1. Defendant is without sufficient facts or knowledge to respond to this paragraph. 2. Admitted. 3. Defendant is without sufficient facts or knowledge to respond to this paragraph. 4. Admitted. 5. Admitted. 6. Admitted. 7. Denied. By way of further answer the document speaks for itself 8. Denied. Strict proof is demanded at trial. 9. Denied. Strict proof is demanded at trial. 10. Denied. Strict proof is demanded at trial. 11. Denied. Strict proof is demanded at trial. 12. Denied. Defendant is without knowledge or information as to current real estate market values to the extent relevant, strict proof is demanded. 13. Denied. Strict proof is demanded at trial. 14. Denied. By way of further answer, Plaintiff has suffered no loses and indeed is seeking normal wear and tear for which Plaintiff, on information and belief, has claimed full economic benefit on the applicable Internal Revenue depreciation schedule and is not entitled to any recovery for property that has been fully depreciated and the Plaintiff has claimed full tax benefit for. Strict proof is demanded at trial. 15. Paragraph calls for a conclusion of law to which no response is necessary. 16. Denied. Paragraph 23 of the Lease Agreement says the tenant will pay legal fees for eviction not for other recoveries. NEW MATTER 17. Plaintiff, on information and belief, has claimed full economic benefit on the applicable Internal Revenue schedule and is not entitled to any recovery for property that has been fully depreciated and the Plaintiff has claimed full tax benefit for. WHEREFORE, Defendant asks this Honorable Court to dismiss Plaintiff's complaint. COUNTER CLAIM 18. Plaintiff did not provide defendant with a written list of damages and return Defendant's security deposit within 30 days of the termination of the lease. 19. Defendant is entitled to recover double is security deposit for Plaintiff s unlawful retention of said security deposit. WHEREFORE, Defendant, Chaudry Aslam, demands this Honorable Court to enter a judgment against the Plaintiff, James E. Grandon, Jr., d/b/a Sleepy Hollow Enterprises, for double the amount of Defendant's security deposit as well as any other equitable relief as this Honorable Court may see fit. Dated: Vlflll Respectfully submitted, THE SHAGIN LAW GROUP, LLC r _ By: Mary Peters Anater Supreme Court ID #86977 120 South Street Harrisburg, PA 17101 717-221-1111 Attorneys for Defendant JAMES E. GRANDON, JR. and JEAN GRANDON t/d//b/a SLEEPY HOLLOW ENTERPRISES, 3919 Market Street Camp Hill, PA 17011 Plaintiffs V. CHAUDRY ASLAM 5337 Oxford Circle, Apartment 69 Mechanicsburg, PA 17055 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW : NO: 11-486 CIVIL Arbitration CERTIFICATE OF SERVICE I, Mary Peters Anater, counsel for Chaudry Aslam, defendant, hereby certify that on this day, the 8th day of April, 2011, that a true and correct copy of Defendant's Answer/New Matter faxed/ mailed to the following: Wade D. Manley, Esq. Johnson, Duffle, Stewart & Weidner 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Respectfully submitted, Dated: THE SHAGIN LAW GROUP, LLC By: Mary Peters Anater Supreme Court ID #86977 120 South Street Harrisburg, PA 17101 717-221-1111 Attorneys for Defendant JAMES E. GRANDON, JR. and : IN THE COURT OF COMMON PLEAS JEAN GRANDON t/d//b/a : CUMBERLAND COUNTY, PENNSYLVANIA SLEEPY HOLLOW ENTERPRISES, 3919 Market Street Camp Hill, PA 17011 CIVIL ACTION- LAW Plaintiffs V. : NO: 11-486 CIVIL CHAUDRY ASLAM : _ 5337 Oxford Circle, Apartment 69 F Z Mechanicsburg, PA 17055 Arbitration 3 - Defendant .Sr wCky. WITHDRAWAL PRELIMINARY OBJECTIONS - ' co To the Prothonotary: Defendant wishes to withdrawal his preliminary objections. Plaintiff has provided Defendant with a copy of the Praecipe to Reinstate Complaint that was not included in the papers Defendant was served. Dated: //'/// Respectfully submitted, THE SHAGIN LAW GROUP, LLC By: Mary Peters Anater Supreme Court ID #86977 120 South Street Harrisburg, PA 17101 717-221-1111 Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA James E. Grandon, Jr,, d/b/a Sleepy Hollow Enterprises 2011-486 Plaintiff NO. -486 (}7 VS.? .{D c? Chaudry Aslam c? RULE 1312-1 Defendant O The Petition for Appointment of Arbitrators shall be substantially in the --+ Following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: I, Wade Manley, , counsel for the laintiff efendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is $11,458.33 The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Wade Manley, Esquire, 301 Market Street, PO Box 301, Lemoyne, PA 17043-0109 Mary E. Anater, Esquire, 120 South Street, Harrisburg, PA 17101 WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. petition, Esq., and a ILo? b -r- = c': Crr-I Respectfully submitted, Q ? $'a t{, OD Pd a11 Nm W 5 9y ORDER OF COURT AND NOW, , 200 , in consideration of the foregoing captioned action (or actions) as prayed for. Esq., and Esq., are appointed arbitrators in the above By the Court, Kevin A. Hess, P.J. CERTIFICATE OF SERVICE AND NOW, this 7th day of July, 2011, the undersigned does hereby certify that I served a copy of the foregoing Petition for Appointment of Arbitrators upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Mary E. Anater, Esquire The Shagin Law Group, LLC 120 South Street Harrisburg, PA 17101 JOHNSON, DUFFIE, STEWART & WEIDNER IA, t+"' ' By: V_ Wade D. Man ey, Esquire I Jr IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA James E. Grandon, Jr., d/b/a Sleepy Hollow Enterprises Plaintiff : NO.2011-486 2 rr c f {Tt vs. Chaudry Aslam RULE 1312-1 Defendant D C-) :z C) w The Petition for Appointment of Arbitrators shall be substantially in the -`-+ ? Following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: I, Wade Manley, , counsel for the laintiff efendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is $ 11,458.33 The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Wade Manley, Esquire, 301 Market Street, PO Box 301, Lemoyne, PA 17043-0109 Mary E. Anater, Esquire, 120 South Street, Harrisburg, PA 17101 WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, Nq?t ORDER OF COURT a w 30'11(0 U'd(As9y AND NOW, 200 , in consideration of the foregoing petition, Esq., and Esq., and Esq., are appointed arbitrators in the above captioned action (or actions) as prayed for. f, cv By the Court, Lt..C) = CL_ cm CD N <>- Kevin ess, P.J. WE 1 j= C/) ?aI- ? i < A?aler; ?s ;:2 Uj =5 coQ Lc?ad? iJ. MaK Icy, G- r y r a-r C) c'7 ?i ao? % -? 4. cw P d °` 11 Yawl e ram ?-? 0 L ?o ?t.V1 sk 8 mil T j Plainti c)-\CL F?, Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No. t ? - 8 b 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. Sig ature ignature ignature afhk? 1? ?? .S Istame (Chairman) Name Name J r ?-lM 1 S' t?a.4d.4`'"J J? LA ?n CLLR. w 6 Q?l Law Firm q Law Firm Law Firm Address Address Address Carl i V 17013 P14 17291, /10?46 i 70.u City, Zip City, Zip City, Zip Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the folio ing award: (Note: If damages for delay are awarded, they shall be separately stated.) a &Y-\ P i n 0s nc 1 c 'o-VI S coca . Arbitrator, dissents. (Insert name if Date of Hearing: Date of Award 3-2o - t2- 3 -20 -12 Notice of Entry of Award Now, the a0?A day of 1W4ce-l , 20 /a , at /a-02-/ , P .M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ ;-116 ..D By: Deputy f'F oTHO ..s? ; 211 MAR 20 PM 12: 24 PENNSYLVANIA ?Iq r y /??e'kr5 ?h ct ?r L- S? AK? JAMES E. GRANDON, JR. IN THE COURT OF COMMON PLEAS OF d/b/a SLEEPY HOLLOW CUMBERLAND COUNTY, PENNSYLVANIA ENTERPRISES, Plaintiff vs. CIVIL ACTION - LAW ma) NO. 11-0486 CIVIL ? ; CHAUDRY ASLAM, Defendant ORDER =, - AND NOW, this ?q day of March, 2012, the appointment of Renee Knicos, Esquire, as a member of the Board of Arbitrators in the above-captioned case is VACATED. Susan Hartman, Esquire, is appointed in her place. BY THE COURT, Hess, P. J. Kathy Shaulis, Esquire Chairman V Susan Hartman, Esquire Court Administrator Fri - r= -rJ '"'7 t ry -?C-_t cz, t __4 , rlm C.mp??'S tea, ed JAMES E. GRANDON, JR. and JEAN GRAINDON t/d/b/a SLEEPY HOLLOW ENTERPRISES, Plaintiffs V. CHAUDRYI ASLAM Defendant IN THE COURT OF COMMON PLEA$:, CUMBERLAND COUNTY, PENNSYL N[A CIVIL ACTION - LAW NO. 11-486 ARBITRATION PRAECIPE TO ENTER JUDGMENT AND NOW, this 29' day of May, 2012, no appeal having been taken from the Arbitrators' Award in the above captioned matter, kindly enter judgment on the award in favor of Plaintiffs and against Defendant, Chaudry Aslam, in the amount of $8,100.00. JOHNSON, DUFFIE, STEWART & WEIDNER By, Wa a D. Manley JUDGMENT ANO NOW, this SD day of , 2012, judgment is entered as above requlested in favor of Plaintiffs and against Defendant, Chaudry Aslam, in the amount of $8,100.00. PROTHONO RY By: cxvt4 %14. S60 o ?-215a3(o b CQ WDL?44 CERTIFICATE OF SERVICE HEREBY CERTIFY that this th day of fk 2012, 1 served a true and correct copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Mary E. Anater, Esquire The Shagin Law Group, LLC 120 South Street Harrisburg, PA 17101 JOHNSON, DUFFIE, STEWART & WEIDNER By; W " Wa a D. M nley, Esquire J?wl?s ? r 1 rar d-1 ! o cr1 loci ?'y?-r1 PlaaiA-& ntiff v? t(L1v-? Defendant u? In The Court of Common Pleas of Cumberland County, Pennsylvania No."? - C) 4 6 10 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. ?04 S ig ature ignature ignature I S1 4 ?s t? Jam", A ? .. 7k ame (Chairman) Name Name Law Firm Law Firm Law Firm P6 x l 2-2-9 1 - -rn o x L? -J ?. , Address Address Address City, Zip City, Zip city, zip Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) M,LAccL A? od.oa iv,_c vnGiaGs Pla . Arbitrator, dissents. (Insert name if applicable. Date of Hearing: 3 20 - /2 Date of Award: J _20 - 12, Notice of Entry of Award Now, the ?20 ?q` day of lWatt c. , 20 /,;2 , at /a - !-)-/ , ,0 .M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. TRUE COPY FROM RECORD Arbitrators' compensation to be paid upon appeal: $ In Testimony whereof, I hero unto set my hand and the seal of sold Court at Carlisle, Pa. TN S. ?_.day of. 124 .20 L?? Prothonotary WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-486 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JAMES E. GRANDON, JR. AND JEAN GRANDON T/D/B/A SLEEPY HOLLOW ENTERPRISES Plaintiff (s) From CHAUDRY ASLAM, 305 KEITH ROAD, MECHANICSBURG, PA 17050 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY AND FUNDS OF THE DEFENDANT LOCATED AT 305 KEITH ROAD, MECHANICSBURG, PA 17050. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) 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 $8,100.00 Interest Atty's Comm % Atty Paid $2'18.38 Plaintiff Paid L.L. $.50 Due Prothy $2.25 Other Costs Date: 6/22/12 (Seal) David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name : WADE D. MANLEY, ESQUIRE Address: JOHNSON, DUFFIE, STEWART & WEIDNER 301 MARKET STREET P.O. BOX 109 LEMOYNE, PA 17043-0109 Attorney for: PLAINTIFF Telephone: 717-761-4540 Supreme Court ID No. 87244 .. ? 1• ?fftt?r^^?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLN io o:.a CIVIL DIVISION 2 PH 3: PRAECIPE FOR WRIT OF EXECUTION James E. Grandon, Jr., et al Plaintiff Chaudry Aslam vs. Defendant Interest Address: Arty's Comm 305 Keith Road Costs Mechanicsburg, PA 17050 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) All personal property and funds of the Defendant located at 305 Keith Road, Mechanicsburg, PA 17050. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland 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) All personal property or funds of the Defednant attached to Metro Bank account number 53 674169 7, 5032 Simpson Ferry Road, Mechanicsburg, PA 17050. and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). F1 (Indicate) Index this writ against the garnishee (s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date June 20, 2012 Signature: Print Name: Wade D. anley Address: 301 Market Street Q W l Lemoyne, PA 17043 Plaintiffs 31.(4q if Attorney for: It K Telephone: 717-761-4540 LA a. Ou I6.OOk w `Gr-I OV?k 1b.So n • Sa u cr 3 C] Confessed Judgment E] Other File No. 11-486 'Jf"'3ERLAND COUNTY w3 Amount Due $8,100.00 Supreme Court ID No: 87244 a. .s-->,P- d . ? . SO LL YA ? ?, ?sS,&4 SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Anderson ,f dy S Smith ,hief Deputy , . "' ~' ~~ ~~~`~ Richard W Stewart Solicitor ' ` ,'~~ ~ ~'; James E. Crandon, Jr. (et al.) Case Number vs. Chaudry Aslam 2011-486 SHERIFF'S RETURN OF SERVICE 07/02/2012 01:45 PM -Ryan Burgett, Deputy ,being duly sworn according to law, states that on July 02, 2012 at 1:45 PM hours, served the requested Writ of Execution and Claim for Exemption Form by "personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Chaudry Aslam at 305 Keith Road, Hampden Township, Mechanicsburg, PA 17055, informed Defendant of contents of same and levied upon personal property as directed. Postcard and copy of levy mailed to attorney and letter mailed to defendant on 07-03-12. 08/20/2012 Ronny R. Anderson, Sheriff. who being duly sworn according to law, states this writ is returned SATISFIED. SHERIFF COST: $234.55 (PAID BY DEFENDANT) SO ANSWERS, August 20, 2012 RONI~(Y R ANDERSON, SHERIFF -~ s_x' ~~ DISTRIBUTION PLAINTIFF James F.. Grandon, Jr. and Jean Grandon T/D/B/A Sleepy Hollow Enterprises WRIT NO. 2011-486 James F.. Grandon, Jr. and Jean Grandon T/D/B/A Sleepy Hollow Enterprises -vs- Chaudry Aslam Real Debt $ 8,100.00 Interest Attorney's Comm. Writ Costs, Atty 248.38 Writ Costs, Pltff. Miscellaneous Attorneys Fees $ 8,248.38 Sheriff s Costs: Docketing $ 18.00 Poundage 162.00 Law Library .50 Prothonotary 2.25 Service Mileage 10.00 Postage 1.80 Advertising Garnishee Postpone Sale Bad Check Charge Surcharge 20.00 Levy 20.00 TOTAL ~ 234.55 Defendant Paid to Sheriff ~ 8,582.93 Advance Costs 150.00 Total Collected ; 8,73293 DISTRIBUTION Pd. To Pltff. 8 8,248.38 Refund of Adv. Costs 150.00 Sheriff's Costs 211.81 So Answers: n R. Anderson riff ..~ s ' ',, >~ +;%~