HomeMy WebLinkAbout11-1395
LJC PROPERTIES, LLC,
Plaintiff
V.
KENNETH DOWNING, Individually,
and ALLISON PAQUETTE, Individually,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Docket No.:
: Civil Action - Law
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Defendants
NOTICE TO DEFEND
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 the 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 Plaintiff.
You may lose money or property or other rights
important to vou.
ill L -P
YOU SHOULD TAKE THIS PAPW>-r
YOUR LAWYER AT ONCE. IF Y(
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, PA 17013
1-800-990-9108
717-249-3166
AVISO
LLEVE ESTA DEMANDA A UN
ABOGADO INMEDIATAMENTE, SI NO
TIENE ABOGADO O SI NO TIENE EL
DINERO SUFICIENTE DE PAGAR TAL
SERVICIO. VAYA EN PERSONA O
LLAME POR TELEFONO A LA OFICINA
CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR
ASSOCIATION
32 SOUTH BEDFORD
STREET CARLISLE, PA 17013
1-800-990-9108
717-249-3166
(2) 1_
Pa - gia•GU
Le han demandado a usted en la corte. Si usted
quiere defenderse de estas de estas demandas
expuestas an las paginas signientes, usted tiene
veinte (20) dias de plazo al partir de is fecha de
la demanda y is notificacion. Hace falta asentar
una comparencia escrita o en persona o con un
abogado y entregar a la corte en forma escrita
sus defensas o sus objeciones a las demandas en
contra de su persona. Sea avisado que si usted
no se defiende, le corte tomara medidas y puede
continuar la demanda en contra suya sin previo
aviso o notificacion. Ademas, la corte puede
decidir a favor del demandante y requiere que
usted cumpla con todas las provisiones de esta
demanda. Usted puede perder dinero o sus
propiedades u ostros derechos importantes para
usted.
Iq *J
0 k# 3 a7U5
THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL COURT DIVISION
LJC PROPERTIES, LLC,
Plaintiff
V.
Docket No.:
KENNETH DOWNING, Individually,
and ALLISON PAQUETTE, Individually, Civil Action - Law
Defendants
COMPLAINT
1. Plaintiff is a Pennsylvania corporation with its principal place of business located at
2933 North Front Street, Harrisburg, PA 17110.
2. Plaintiff is the owner of a certain property located at 207 West First Street, Boiling
Springs, PA 17007. ("premises")
3. Defendants Kenneth Downing and Allison Paquette are adult individuals who reside at
207 West First Street, Boiling Springs, PA 17007.
4. On or about September 30, 2010, Plaintiff and Defendants entered into a written lease
for the premises for an initial term of years. Thereafter, the Defendants had the option to renew
the lease for a period of one year. A true and correct copy of the lease for the premises is
attached hereto and incorporated herein by reference as Exhibit "A."
5. The monthly rental for the premises was $1,550.00, which was due and payable on the
first day of each month.
6. Defendants have failed and refused to pay rent from January 1, 2011 through
September 30, 2011, inclusive. The outstanding rent for this period is $13,950.00.
7. By virtue of their failure to pay all rent and other charges due under the lease,
Defendants are in breach of their obligations under the lease.
COUNTI
IN EJECTMENT
8. The allegations contained in paragraphs 1-7 inclusive are incorporated herein by
reference as though set forth at length.
9. On or about January 14, 2011, Plaintiff served Defendants with a ten day notice of
intent to terminate the lease. Defendants refused to vacate the premises after the expiration of the
ten day termination period. A true and correct copy of the thirty day notice is attached hereto and
incorporated herein by reference as Exhibit "B."
10. By virtue of Defendants' breach of their obligations under the lease and by virtue of
Plaintiffs termination of the lease, Plaintiff is entitled to possession of the premises.
WHEREFORE, Plaintiff demands judgment against Defendants for possession of the
premises.
COUNT II
FOR MONEY
11. The allegations contained in paragraphs 1-10, inclusive, are incorporated herein by
reference as though set forth at length.
12. Pursuant to the lease, Defendants are indebted to Plaintiff for unpaid rent and late fees
in the amount of $13,950.00, cleaning charges of $575.00, and reasonable attorneys' fees for a
total of debt of at least $14,525.00. Additional rent and other charges may accrue subsequent to
the filing of this Complaint.
WHEREFORE, Plaintiff demands judgment in his favor and against Defendants in the
amount of $14,525.00, plus any additional charges for rent and other charges which may become
due and payable between the filing of this Complaint and trial.
DATE: 213111
Respectfully submitted,
Ak"-f fit. .
Michael M. Jerominski, Esquire
PA ID No. 92977
2933 North Front Street
Harrisburg, PA 17110
(717) 233-4101
Attorney for Plaintiff
THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL COURT DIVISION
LJC PROPERTIES, LLC,
Plaintiff
V. Docket No.:
KENNETH DOWNING, Individually,
and ALLISON PAQUETTE, Individually, Civil Action - Law
Defendants
VERIFICATION
I, Louis J. Capozzi, Jr., Esquire, being duly sworn, do hereby depose and state
that I am authorized to make this verification on behalf of LJC Properties, LLC, and that
the facts alleged therein are true and correct to the best of my information, knowledge,
and belief.
Date: _ s ! ?;
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S & L ASSOCIATES
2933 N Front Street
Harmsburg, PA, 17110
(717) 232-4966
Lease - RENTAL AGREEMENT
In consideration of the agreements of the Tenant(s), known as the owner,
hereby rents him/her the dwelling located at 207 W. First Street, Boidixag Springs, PA, for the period
commencing on the Ist day of October, 20110 and monthly thereafter until the 30* day of September,
2011, at which time this agreement is terminated. Tenant(s), in consideration of Owner's perwn tting bim
to occupy the above premises, hereby agree(s) to the following terms- The sure of S 1,550.00 as a security
deposit plus the first month's rent of $1,550,00 receipt, which upon acceptance of ibis rental agreement,
the Owner/Agent of said premises hvreinafter teftned to as Owner, shaJI apply said amount as follows:
Monthly Rent in the amount of 51,550.00
Security Deposit in the amount of $1,550.00
In the event that this agreement is not accepted by the Owner or his authorized agent, within 3 days, the
total deposit received shall be refunded. T'ertant hereby offers to rent from the Owner the premises situated
in the city of Boiling Springs, County of Cumberland, State of Pa., described as.207 W, First Street upon
the following terms and conditions:
I. TERM The term hereof shall corrucnence on October 1, 2010.
(check one of the following alternatives);
Until 3 z c' I I '? d?
[) Either shall terwtinate the slime by giving the other party 30 days written notice delivered by certified
mail, provided that tenant agrees not to terminals prior to the expiration of 12 months, Tenant bgrcee to
cooperate with Owner in the showing of the premises for sale or rc-rental and agrees to make premises
accessible and in "show condition" once notice is given to vacate.
2. RENT Dent shall be 51,550.00 per month, payable in advance, upon the 1" day of each calendar
month to Owner or his authorized agent, at the following address: 2933 North Front Street, Harrisburg,
PA. 17110 or at such other places Owner may designate In the event that Owner provides self addressed
envelopes and/or payment booklet, it shall be for tenant's convenience only. Prompt payrnent of rent shall
be tenant's responsibility regardless of whether tenant has a supply of envelopes or payment booklet. Rent
must be paid in full and no amount subtracted from it. The first moath's rent is to be paid when the Tenant
signs this lease, Tenant may be rzquired to pay other charges to Owner tinder the terms of this lease, They
are to be called "additional rent", Added rem charges can result when Owner or his agent must pay for
any expenses which are the tenant's :esponsibilitics under the terms of the lease. Late charges, anorncy's
fees and any expenses related to the enforcement of this lease shall be classified as "additional )cent." This
additional rent is payable as rent, together with the next monthly rent due. If tenant fails to pay additional
rent on rime, Owner shall have the same rights against tenant as if it were a failure to pay rent. Lease
violation penalty fees shall be classified as additional rent,
The whole amount of rent is duc and payable when this lease is effective; Payment of resit in
installments is for tenant's convenience only. If tenant defaults, Owner may give notice to tenant that rent
may no longer be paid in instaJlrnents, and the entire rent for the remaining part of the term will be due
Sand payable.
4. 'USE The premises shall be used as a residence by the undersigned tenant with no more than 1
occupant,'and for no other-purpose, without written consent of the Owner. Occupancy by guests staying
over 7 days will be a violation of this provision. In the event any other people occupy and live in i
I A
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rental, without Owner's written consent, it will cotlstitute a breach of tlus tease, and the Owner at his sole
option may issue a Lease'Violation Notice or terminate this lease
5. UTILITIES Tenant shall be responsible for all utility bills V? 4: c.-Y"
6. HOUSE RULES In the event that the premises area portion of a building confining more than one unit,
or a single family dwelling, Tenant agrees to abide by any and all house rules, whether promulgated
before or after the execution hereof including but not limited to rules with respect to noise, odors, disposal
of refuse, pets, parking and use of common areas. Tenants agree to use carpeting or area rags on any bare
wood floors above another dwelling, Tenants agree to provide their own trash cans and to bring him in
after collection,
7. MAINTENANCE, REPAIRS OR ALTERATIONS Tenant acknowledges that,the pmrnises are in
good order and repair, unless otherwise indicated herein. Tenant shall at his own expenae, and at all times,
maintain the premises in a clean and sanitary rhanner including all equipment, appliances, furniture and
f irnishings therein and shall surrender the same at termination hereof is as good condition as received ,
normal wear and tear excepted, Once notice is given to vacate, Tenant agrees to keep the premises in
"show condition", "Show condition" means as clean, orderly and undamaged as when received. Upon
vacating, Tenant shall deliver premises vacant and clean. In the event the premises are returned in
condition poox enough to prevent Owner from re-renting to a qualified new tenant, Tenant shall be
responsible for rent lost as well as the cost of restoration of the rental to the condition it was at the
commencement of this lease. Tenant shall be responsible for damages caused by his negligence and that of
his family, invitees or guests.
> PAINT Tenant shall not point paper or otherwise redecorate without the prior written consent of the
Owner. All paints, materials and work plans must be approved in writing by Owner or his authorized
agent. Tenant shall be responsible for paint spills/clean-ups or damages as a result of paint related work
> GROUNDS Tenant shall be required to irrigate and maintain any surrounding grounds, including the
trimming of lawns, trees, shrubbery and keep same clear of leaves, rubbish and weeds. Tenant is
responsible for snow and ice removal from walks, driveways, steps and any areas where safety should be
observed. It is agreed that Tenant shall not use any salt on stoops or walkways.
> LEADERS AND GUTTERS Tenant is responsible for keeping leaders and gutter's, if any, free of
leaves, sticks and any accumulations that may occur. If the property is heavily treed, leaders and gutters
may need cleaning several tunes a year.
> BASEMENTS AND GARAGES In the event The dwelling hag a basement or garage, use of the
basement or garage i3 not included in the rent, nor shall it be considered living space. Any use of the
basement or garage shall be at Tenants own risk. Tenant agrees to be responsible for maintaining these
areas properly.
y WINDOWS Tenant is responsible for the cleaning and maintenance of the windows on the premises. If
any window(s) or screen(s) become damaged or broken as a result or during the term of this tenancy, the
Tenant will be responsible for repair(s), Tennant agrees to observe care axtd caution when installing and
removing any window unit air conditioners.
> ADDITIONAL ITEMS Storm doors are not included in the rental. Light bulbs shall have wattage of
no higher than 60 watts. Should Tenant attach any fixtures, blinds or any other objects to the real property
by nails, screws or glue, it is agreed thal these objects will remain with the premises and be may be subject
to cost of rernoval at Owners discretion. Tenant shall not install or authorize installation of any wiring on
the premises which requires the drilling of holes into the dwelling, without Owner's written consent. In the
event a requested serviceman is unable to gain access to premises for agreed repairs, Tenant shall be
responsible for a service charge of 535.00 payable as "added rent". Tetagtrt is responsible for all repair.
Should Tenant neglect mairnenance responsibilities, Owner or agent may assume them on Tenants behalf
and any expenses incurred by Owner in connection therewith shall be additional rent (added rent), payable
to Owner on demand.
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7172452651
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8. ORDINA.NCIES & STATUTES Tenant shall comply with all statutes, ordinances and,irequirements of
all municipal, state and federal authorities now in force, of which may hereafter be in force pertaining to
the use of the premises.
9. DISPOSITION OF PERSONAL PROPERTY In consideration of the rental agreement all personal
property located in the residence is and shall always be property of S & L Residential Properties L.L.C.
10. SPACE "AS IS" Tenant has inspected the promises Tenant states that they are in good order and
repair and takes premism "as is".
11, ASSIGNMENT AND SUBLETTING Tenatit shall not assign this agreement or sublet any portion of
the premiseSJ v` l r ?? t ?a-?: • V1 ?? -? IV's 12. PETS No pets shall be brought on the premises without prior written consent of the owner.
13. PESTS Tenant agrees to be responsible for the extermination of any insect or wildlife pest infestation
during or as a result of the tenant's occupancy. Tenant shall be responsible to immediately remedy any
such infestations as soon as any pest problem is observed.
14. APPLIANCES The dwelling may contain various appliances, such as stoves, microwave ovens,
refrigerators, dishwashers, laundry machines, garbage disposals and compactors, central or individual air
conditioners, dehumidifiers, automatic garage door opener, etc- These appliances are not included in the
rent, but tine use of theta may be allowed for the tenants convenience only. If Tenant wishes to use these
appliances, Tenant shall assurne responsibility for care, repairs and maintenance. If appliances are
equipped with manuals and/or waarientee papers, Tenant shell not lose or discard these documents, and
will be responsible for their return.
If Tenant does not agree to be responsible for the appliances, but rather use his own, he may request that
Owner's appliances be removed from the premises. All washer/dryer ittstallation,s must be approved and
authorized by Owner in writing. Tenant agrees to replace all water supply hoses to washing machine that
show any signs of wear.
I.S. PLUMBING STOPPAGES Tenant is responsible for all plumbing stoppages and cesspool Fitt ups.
Tenant is responsible for the cleanup of waste spills as a result of arty plumbing stoppages.
16. RIGHT OF ENTRY FOR PERIODIC INSPECTION The Owner or his agent may enter the
premises with prior consent of the tenant, or with 24 hours written notice to any tenant on the premises to
be entered. The Owner may enter during reasonable hours abd for the purpose of inspecting the premises,
making necessary or agreed repairs, decorations, alterations or improvements, supplying necessary or
agreed services, or exhibiting the dwelling unit to prospective or actual purchasers, mortgagers,
prospective tenants, workmen, contractors, or insurance inspectors. The Owner shall be deemed to have
given 24 hours written notice by posting a notice in a noticeable place staring such intent to enter, at least
24 hours before the intended entry, or in the event uodce to vacate has been given by the tenant, the
Owner shall have tenant's authorization to shoe the promises at any and all reasonable times, regardless of
whether the tenant is present or not, However, in the event of an emergency constituting a danger to life,
health or property, the Owner or his agent may enter the property at any given time without the consent of
or notice to the tenant. The Owner shall have the right to enter the property at any given time for repairs.
17. INDEMNIUCATION Owner shall not be liable for any damage or injury to the tenant or any other
person or to any property, occurring on the premises or any pert thereof, or in common areas unless such
damage or injury is the proximate result of the negligence of the Owner, his agents or employees. Tenant
agrees to hold Owner harmless from any claims from damages, no matter how caused.
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18. POSSESSION If Owner is unable to deliver possession of the premises at the Commencement hereof
Owner shall not be liable for any damages caused thereby, nor shall this agreement be void or voidable,
but Tenant shall not be liable for any rent until possession is delivered. Tenant May terminate this
agreement if possession is not delivered within 30_ days of the com=cnecment of the term hereof. In the
evert this agreement is terminated by the tenant and/or' the owner, any monies paid by tenant and/or owner
shall be deemed damages against the party in default.
•r x?rarr_t tt? . ... . IET h$ze`s- b), ststanf; T.arol?fiC?bpoelrli r,'S.arfd?
20. DEPOSIT REFUNDS The balance of all deposit refunds shrill be refunded within 60 days from the
date possession is delivered to Owner or his authorized agent together with a statement showing arty
cbargcs made against such deport by owr3er. Tenant agrees to provide Owner/Agent, with the address of
his new residence and include it in the Notice of Intention to vacate form,
21. WM VER No failure of Owner to enforce any term hereof shall be deemed a waiver, nor shall any
acceptance of partial payment be deemed a waiver of Owner's right to the full amount thereof. This lease
supersedes any other lease on the premises during the term stated herein.
22. DEFAULT If Tenant shall fail to pay rent when due, or perform any perm hereof; after not less than
three (J) days written notice of such default given m a manner required by law, the Owner, at Iris option,
may terminate all rights of the tenant herein, unless Tenant within said time shall cure such default, If
Tenant abandons or vacates the premises while in default of the payment of rent, Owner may consider any
property left on the premises to be abandoned and may dispose of the same iA any mmner- If the leaksc is
canceled or rent or added rent is not paid on time, or Tenant vacates the premises, Owner may in addition
to other remedies take any of the following steps: Enter the premises and remove the tenant and any
person or property; Use dispossess, eviction or other legal method to take back the premises. If the lease is
ended or Owner takes back the premises, rent and added rent for the unexpired term becomes due and
payable. Owner may re-rent the premises and Tenant shall be responsible for Owner's cost of rerenting.
Owner's corn shall include the cost of repairs, decorations, broker's fees,. attorney's fees, advertising and
preparation for renting. Tenant shall continue to be responsible for rent, expenses, damages and losses.
Any rent received from the re-renting shall be applied to the reduction of money the tenant owes. Tenant
waives all rights to return to the premises after possession is returned to owner by a court. Tenant agrees
to waive rights to trial by a jury in any matter which comes up between the parties under or because of this
lease.
23. ATTORNEY'S FEES [n any legal action to enforce the terms hereof or relating to the premises, the
Owner or agent shall be entitled to all costs incurred in connection with such action, including a
reasonable attorney's fee. Tenant acknowledges all attorney's fees shall. be classified and billed to tenant
as "added rent,"
24. NOT] CES Any notice which either party may or is required to give;, may be given by mailing the
same, by certified mail, to Tenant at the premises, or to Owner at the address shown below or at such
other places as may be designated by the parties from time to time, This includes notification or requests
for repairs. Tenant is required to notify Owner in writing of Intention to Vacate or Intention to Renew at
least 60 days before the expiration of this lease, Tenant agrees to immediettely notify Owner or Agent in
writing by certified mail of any dangerous or hazardous conditions existing on the premises.
25. HOLDING OVER Any holding oN,er after expiration hereof, with the consent of the Owner, shall be
construed as a Knonth to month tenancy in accordance with the terms hereof, as applicable. The term and
conditions of this lease will continue to apply.
26. TIME Time is of the essence of this agreement.
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27.1NSURANCE Tenant is responsible for fire insurance coverage on premises. Tenant agrees to obtain
and maintain a mandatory " Renter's,Znsuraace" policy and to provide Owner or agent with a copy of
policy within seven (7) days of lease execution. In the event Tenant fails to provide Owner with a copy of
a valid "Banter's Insurance" policy as agreed. Owner may issue a Notice of Lease Violation to the tenant
and may obtain insurance on the tenant's behalf at the tenant's expense. In the event a written Notice of
Lease Violation is issued to the tenant, the tenant shall correct the violation within five (5) days.
28. SUCCESSORS This lease is binding on all parties who lawfully succeed to the rights or take the
place of the Owner or Tenant.
29. TENANCY & SERVICE OF PROCESS Every tenant who signs this agreement agrees to be fully
responsible jointly and severally for all items agreed herein, and furthermore agrees to be the agent of the
other tenants and occupants of the premises and is both authorized and required to accept on behalf of the
other tenants and occupants, service of summons and other notices relative to the tenancy,
30. TELEPHONE Tenant agrees to maintain a telephone in the dwelling during the term of this lease,
and to famish Owner or agent with the telephone number within five (5) days frvrn taking occupancy.
Tenant shall be responsible for any telephone company installation charges, if applicable.
31. FENCES Fences that currently exist are not included in the rental. Tenant agrees to be responsible for
maintaining any existing fence, gates.
32. LOCKOUTS Should Tenants look himself out of their dwelling and be unable to gain access through
their own resources, they may call a professional locksmith or the Owner to let him in, and will be
responsible for damages if any. Tenant shall be responsible for the cost of the locksmith and also to
provide the Owner with new keys if the locks are changed, If Owner is called upon to, let Tenants in, there
will be a S50 Charge.
33. CLEANING PEE In the event the premises are returned in condition poor enough to require a
cleaning service, or in the cage of an authorized or unauthorized pet residing at the premises during the
term of this lease, a cleaning fee of 5575.00 is to be paid by Tenant. This fee represents the cost of
cleaning and preparation for reoccupancy. Owner will waive this fee if premises are returned and if
retuned in as good condition as received at commencement of this lease.
34. BANKRUPTCY If (1) Tenant assigns property for the benefit of creditors, (2) Tenant files a
voluntary petition or an involuntary petition is filed against Tenant under any bankruptcy or insolvency
law, or (3) &trustee or receiver of Tenant or Tenants property is appointed, Owner may give Terwtat 30
days written notice of the cancellation of the term of this lease. If any of the above is not filly dismissed
within the 30 days, the term shall end as of the date stated in the notice, Tenant must continuo to pay rent
without offset.
35. WITHHOLDING RENT Under no circumstances may any rent be withheld in full or in part,
regardless of any expenses incurred by Tenant, regardless of the condition of the premises, or the legality
of the premises. Rent must be paid to Owner or Owner's agent only. Non-payment or payment to any
other party is a violation of this Lease Agreement and cause for immediate eviction,
36. SMOKE ]DETECTOR(S) FIRE EXTINGUISHER Tenant(s) acknowledge that the dwelling is
equipped with smoke detector(s). Tenant(s) agree to test the smoke detectors) on a regular basis (2-3 times
per month); and rot report any problem with rhetn immediately to owner in writing. Tenant agrees to
replace the battery for the smoke detector as necessary with a new alkaline battery.
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37. FIREPLACE If premises have a fireplace, Tenant agrees to exercise safety measures when it is in
use. Tenants agree to assume responsibility for keeping the chutney clear of any buildup or obstructions
during their tenancy,
38. WATERBEDS Tenant shall not have a waterbed on the premises without the written consent of the
Owner.
39. ILLEGALITY If any part of this lease is not legal according to local laws, the rest of the lease will be
unaffected. Illegal activity of Tenant(s), invitees or guests on premises constitutes a breach of this lease.
40. OPTION TO RE-NEW LEASE Tenant has the option, providing the arras and conditions of this
lease have been complied with and satisfied, to re-,hew this agreement for a period of one year, at an
annual increase of 525.00 additional per month, subject to Owner's approval. If the Tenant wishes to
renew, a new lease will be prepared.
13. BREACH OF LEASE If rent is over seven (7) days late, Owner will construe non-payment as a
breach of this lease, constituting Tenan`t's 30 days Notice to Vacate. Also, in the event agreements made in
this lease are broken by texomt, the security deposit will be forfeited at Owner's option. Owner may
continue the lease or terminate any or all of the tenant's rights herein. Im the event a written Notice of
Lease Violation is issued to the tenant,ihe tenant shall correct the violation within five (5) days
42. ENTIRE AGREEMENT The foregoing constitutes the entire agreement between the parties and
maybe modified only by an official change of tams, notice issued by the owner/agent in writing, or a
writing signed by both parties. The following exhibit has been made a part of this agreement before the
p i s execution hereof: _
V -.1 C.,
41 ACKNOWLEDGMENT Tenants hereby acknowledge that they have read, understand and agree to
all parts of this document, and have?rceeived a copy,
THE UNDERSIGNED TENANT(S) ACI(NOWLIEDGES RECEIPT OF A. COPY HEREOF.
DATE:, .1 3 c
OWNER4C ?, `.: ;-? TENANT 2,-%? ------
ADDRESS: 29 North Front ree
Harviaburg,1PA t1b J SSA y .. t`?,.+ et., S
PHONE : (717) Z 3.4101
'1
EVICTION NOTICE
(NOTICE TO QUIT)
DATE: January 14, 2011
TENANT(S): Ken Dowling and Allison Paquette
ADDRESS: 207 West First Street, Boiling Springs
You are hereby notified that you currently owe $1,575.00 in past due rent and late charges. In
addition, you owe $12,400 under the terms of your lease for rent from February 2011 through
September 2011. The rent due each month is in the amount of $1,550.00; The rent past due covers
unpaid rent for September 2011.
THIS IS A DEMAND FOR PAYMENT. You must pay the full amount owed that is stated in this
notice within the next ten (10) days. If you fail to make full payment of the amount due, your right
to possession of the property will be terminated and eviction proceedings will begin immediately.
Only full payment of the amount owed will prevent the termination of your lease. No partial
payments will be accepted without the written consent of the landlord.
Pay Rent Immediately to: Louis J. Capozzi, Jr.
Address:
2933 North Front Street
HarrisburLy, PA 17110
Phone: (717) 233-4101
Landlord Signature
POSTED BY: (Name of Person Posting Notice)
? delivering a copy of notice to the named tenant
? posting a copy of the notice on the main door of the property, no one actually being present at the
residence
E EXHIBIT
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson Sheriff r c ; A
Jody S Smith FE D
Chief Deputy
Richard W Stewart
Solicitor f L Pi i `t ! 4 x
F LJC Properties, LLC
vs. Case Number
Kenneth Downing (et al.) 2011-1395
SHERIFF'S RETURN OF SERVICE
02/10/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Allison Paquette, but was unable to locate her in his
bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Allison
Paquette. Request for service at 207 W. First Street, Boiling Springs, Pennsylvania 17007 is vacant.
02/10/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Kenneth Downing, but was unable to locate him in his
bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Kenneth
Downing. Request for service at 207 W. First Street, Boiling Springs, Pennsylvania 17007 is vacant.
However, The Boiling Springs Postmaster is still delivering Kenneth Downing's mail to 207 W. First Street,
Boiling Springs, Pennsylvania 17007.
SHERIFF COST: $59.40
February 10, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
u +?5 SrE:'itt. ,
David -D. Buel
Prothonotary
Office of the Prothonotary
Cum6erfancf County, 'ennsyfvania
/1- /39
ORDER OF TERMINATION OF COURT CASES
7�yrkS. Sofionage, ESQ
Solicitor
CIVIL TERM
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 • Suite100 • Carlisle, TA • (Phone 717 240-6195 • 'Far 717 240-6573