The URL can be used to link to this page

Home My WebLink About01-2505COMMONWEALTH OF PENNSYLVANIA NOTICE OF JUDGMENT/TRANSCRIPT ;OUNTY OF: CU~BERT.~,N'D CIVIL CASE ~,u,) C,~ r~.~ PLAINTIFF t~AME &ndAE,E,RE~5 09 - 2 ' 01 FBA~R, KATHLEEN ~ ~'J'.~'--' .:. 227 W POMFRET ST PAULA P. CO~R~ CAELI$~.E, PA 17013 ~'~'?~' i CO[TRTHOUSE SQUARE / J CARLISLE, PA VS. T~,.,,~,,.~ (717~ 240-6564 17013-0000 U0-ENSEN, DENISE, ET AL. ~ 141 W LOUTHER ST CARLISLE, PA 17013 KATHLEEN BA~R / .~ _1 227 W [~OMFRET ST DocketNo.: CV-0000019-01 ~ CARLISLE, PA 17013 Date Filed: 3/19/01 CROSS COMPLA NT 001 THIS IS TO NOTIFY YOU THAT: Judgment: FOR DEF]~DAN~ ~'] Judgment was entered for: (Name) [--~ Judgment was entered against: (Name) in the amount of $ .00 on: (Date of Judgment) ~./3R./~1 ~ Defendants are jointly and severally liable. (Date & Time) ~--] Damages will be assessed on: Amount of Judgment $ .00 Judgmenl Costs $ .00 Interest on Judgment $ .0 --]This case dismissed without prejudice. Attorney Fees $ .00 Total $ .00 Amount ot Judgment Subject to ~--] AttachmentJAct 5 of 1996 $. Post Judgment Credits $ Post Judgment Costs $ ~] Levy is stayed for__ days or [] generally stayed. ============ Certified Judgment Total $ [--~ Objection to levy has been filed and hearing will be held: * See at tached Date: " Place: Time: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDG .MENT~P,jA~SCRIPT FORM WITH YOUR NOTICE OF APPEAL. 3/28/0, Date (.,~.~. J.,~'~ _~,uv~, _,=~*/ .,m , District Justice I certify that this is a true ~'d co~r~co~'py ~/~the r~r~,~/~/,"~ings.cor~g the judgment. 3/28/0t Date ~_____~t,~,.~4'-- L ~'~[F"'__ ~~ , District Justice My commission expires first Monday o! January, 2006 SEAL AOPC 315-99 ;OMMONWEALTH OF PENNSYLVANIA NOTICE OF JUDGMENT/TRANSCRIPT ~ ;OUNTY OF: CTJN~ERI..~LND CIVIL CASE · MarJ O,~r N,~ PLAINTIFF. NAME 3n~1 ADDRE:5.~ 09 - 2 - 01 ~B~, ~THLE~ ~ DJr-4~ ...... 227 W POMF~T ST PAU~ P. ~ ~LISLE, PA 17013 ~LISLE, PA VS. ,,,.~.~.~ {717~ 240-6564 17013'0000 UJ~S~, D~ISE, ET ~. ~ 141 W LO'HER ST ~LISLE, PA 17013 ~THLE~ ~ ~ ~ 227 W PO~T ST DocketNo.: CV-0000019-01~ ~LISLE, PA 17013 Date Filed: 3/19/01 CROSS COMPLAINT 001 THIS IS TO NOTIFY YOU THAT: Judgment: FOR F~'I Judgmen(was entered for: (Name) ,'r'm~'m~; ~'] Judgment was entered against: (Name) 'nam'g_. in the amount of $ _ 110 on: (Date ol Judgment) [~ Defendants are jointly and severally liable. (Date & T~me) [~ Damages will be assessed on: Amount of Judgment $ .00 Judgment Costs $ .00 Interes( on Judgment $ . E~ This case dismissed without prejudice· Attorney Fees $ o 01] , Total $ . [~] Amount of Judgment Subject to Attachment/Act 5 of 1996 $ Post Judgment Credits $ Post Judgment Costs $ [] Levy is stayed for days or ~ generally stayed. ============ Certified Judgment Total $. E~ Objection to levy has been filed and hearing will be held: * See attached Date: Place: .. Time: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARYICLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU 3/28/0t Dale ~'~ ~~ // ,DistrictJustice , certify that this is a true ~corr~c~f/he r~~roceedi~/ontaining the judgment. 3/28/01 Date ( ~~k ~~~ .District Justice My commission expires~rst Monday of January. ~6 SEAL AOPC 315-99 COMMONWEALTH OF PENNSYLVANIA · . -. ~ COUNTY OF: cm,m~R~,~m NOTICE OF JUDGMENT/'rRANSCRiP.i. ~,',g D,s, No. PLAINTIFF: CIVIL CASE PA~ p. CO~ 141 W ~HER BT ~'~' 1 ~THOUSE SQU~ ~ISLE, PA 17013 ~LISLE, PA DEFENDANT: VS. - ~.~,o,~ (717) 240-6564 17013-0000 ~, ~TE NAMEa,tOADDRESS 227 W PO~T ST ~LISLE, PA 17013 ~TE ~ L J 227 W POM~ET ST ~OocketNo.: ~-0000019-01 ~LISL~, ~A 17013 Date Filed: 1/05/01 THIS IS TO NOTIFY YOU THAT: Judgment: FOR ~ Judgment was entered for: (Name) ma=~: ~ Judgment was entered against: (Name) ~R~: n~TR;. ~ in the amount of $ . ~ on: (Date of Judgment) ~ Defendants are jointly and severally liable. (Date & Time) ~ Damages will be assessed on: Amount of Judgment $ . Judgment Costs $.. .00 ~This case dismissed without prejudice· interest on Judgment $. .00 A~orney Fees $ . Amount of Judgment Subject to Total $ . ~ AttachmenFAct 5 of 1996 $. Post Judgment Credits $ ~ Levy is stayed for days or ~ generally stayed. Post Judgment Costs $ ~ Obje~ion to levy has been filed and hearing will be held: Ce~ified Judgment Total $. ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMEN~?,.~SCRiPT FORM WITH YOUR NOTICE OF APPEAL. AMoYp~O31m5?~S'On exp,res first Monday of January, 2006 SEAL NOTICE OF APPEAL · ...MM,f~dnf/EALTH OF I~NNSYLVAHIA COURT Of ~ PLEAS r-ROM J~mClAL reSTRICT DISTRICT JUSTICE JUDGMENT NOTICE OF APPEAL hlotice is gi~fl that the cq:pelkznt has filed in the above Court of Common Pleas an c~Peal fTom the judgment mfldered by ~ ~t~ ~ ~ ~ date and in the case ~ below- 1008B. 'fiX)'/(6)/n act/on before Disb'Jct ~JSt/ce, he MUST This Notice of Appeal, when received by She District Justice. will czperate as a SU~RSEDEAS to she judgn~nt for pmsess~on in this case ~'/£E ,4 COII/IPI. AINT wi#'#n tweflly (20) ~ after S.~n~/zJre a' Fru/i,~..~,¥ or De/x~y PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section c~ faro ~ I~e usec; ONLY wh~ ~ was DEFENDANT (see Pa. Ff.C.P.,J.P. No. IOOf(?) Jn a~tion bede ~ ,Justice. PRAECIPEz To P, othcx~,tary (I) yau m notified that a rde is hereby eflte~ed upc)n Y°u to file a axnplaint in thb appeal within twenty (2Q) days after the dote °f (2) if yQu do not fib a cornp~nt within this time, a JUDGMENT Of G PRC~ WILL BE ENTERED AGAINST YOU. COURT FILE TO BE FILED WITH PROTHONOTARY PROOF OF SERVtCE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT ~ Tni,s proD,: of ~:e,'~ice MII,~; I' BE F .E£ WJ 'H N ?F.A/;' ;t),~ [,~,~ Y,~ AFTER l~lin,~ tile ,)or ce of ap~. eal. Check applicable boxe~) COMMONWEA[.'I'H OF PENNSYLVANIA COUNTY OF .............................................. ; s~ AFFIDAVIT: '.-=, ..... ~ ....... ; .. .... .. ,...~ ........................................... . by personal serwce [~ by [certii'ied) {registere~) mail. sender's ................................. ,~ .......... -.'! b~,. p~,rst.~n ii - ' - '"':: ............. ~ .............................................................. ;~ se,'v~ ~, U by ',cerhhed} {registered} mini, se,der's receipt attached here ;~-'J ,~.'~,J l~;fther ~h.'t! I ~;rve(1 ~e R i ~ o F , IC(, ' o a ~l a..,, ~,np, .W i,~ ~he abov~ Nc.hoe of Appeal ~Jpon lhe ;~ppelleelsl to who~ " ..... · ................. .G - ,:::,. ,,'~.~ :~': .; E i, ft~ Stgnature of affial~t .... ~- ~-~.lma~-~'~' ~r- NOTICE OF APPEAL ~_~_ - - -- ' --w~r~m ~ .......... __/ ~ ~ mKT DiSTaICT JUSTICE JUD~ENT , '~t - ;:-'.. . NOTICE OF APPEAL ~ b ~ ~ ~ ~ ~ ~ ~ ~ a~ ~o~t of ~ ~ ~ ~ ~ ~ ~ t~ ~tr~ ~ ~ ~ ~ ~ w~ ~ ~ ~Y ~ ~s ~ ss ~,~ 1~1(6) in ~ ~ ~ct ~t~, ~ ~' I~E ' ~S m ~ ~ ~ ~ ~ ~is ~ FILE A C~AINT ~thin t~ fili~ ~ ~T~ of A~AL. ~ ~ot~V ~ TO ENTER RULE TO FILE C~PLAINT AND RULE TO FILE pRAEClPE .._. ~ ~ ~gp:.p. ~. ~(1) i~ ~ ~ ~t ~. __ ~y ~ ~ ~ ~FE~Nt is . · ~.~... ,~ ~ .~...-~- / . ~ b ~ ~ i~ ~ ~ w~ t~ (20) ~ ~ ~ ~ o~ (2) ff ~ ~ ~ b a ~i~ w~ t~ ~, a ~ ~ ~ P~S ~L ~ ~gED ~T ~ COURT FILE PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT ' fThi& proof of service MUST BE FILED WITHIN TEN ( 1t~l DA YS AFTER filing the notice of aPPeal. Check apl~liceble boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF J} / J ~j"~ ~/¢~,~ AFFIDAVIT: I h~reby SWear or affirm t~at I serve~ ~he R~,e was a~druss~ on _~ ~ ~CCOmpanymg theaboveNoticeofAn~eal .... wuR~ (AFFIRMED) AND SUBSCRIBED BEFORE ME ' ."~ PROTHONOTARY CUMBERLAND COUNTY COUR'THOU~ ONE COURTHOUSE SQU*~qE CARLISLE, PA pRAECIPE FOR WRIT OF EXECUTION {MONEY juoGMENTSI p.R.C.P. 3101 to 3149 IN THE coURT OF COMMON pLEAS OF r~,CTt~ ~ ~ ............. ~ CoUNTer, P~NNsVLV6N~A 2505 Term, I9 ..... ludgment No ......... VS. pRAECIPE FOR wRIT OF EXECUTION K~%~EI ~ a/]C/a ....................... {MONEY juDGMENT) To the ProthonOtary: ISSUE WRIT OF EXECUTION IN THE ABOVE MA'Vi'ER, County penna.; Directed to the Shefi[f of... {I) Ba~ a/kin gat..hl...e~.. ? ...................... DefendantiS); against ......... Garnlsheeis); (2) · . ......................................... O) and against .................. {4) and index this writ 13at'r .......................................... Kate Bat"I: a/k/a ..K~t..t~....e~.. ............ . Defendant(s)and (a) against.- ;7. ............... . ...................... ..... Rank of I.a~s...1~. ......................... .. G~rnisheetS), against ..... ~ .............. . ........................... {b) ..................................... . -nme of the Garnishee{S) as fol{OWS · . endens against the real property of the Defendantts) in me - : ;;~cl;La~l¥ describe propert,)' , $. 1~164-80 {5) Amoant due .................... 1,164.80 ........ plus costS. Interest from Total ............ ........ Dated ...................... n ne~e~htllabove~twuldbe¢°mP ~ fiodexntto[theeae:ufi°nm~.h.e.b.ot~mhonean~¥.~Rule31~( e.,.:,.~ te t.~ .~"_'.~.~.',.o, .. ~.~..~., ,,,,~,,,,~ ' ' ' '" ' ' ' DENISE A. JENSEN : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 01-2505 CIVIL TERM KATE BARR a/k/a : KATHLEEN BARR : CIVIL ACTION - LAW FRANCINE BRAXTON WALLACE : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2505 CIVIL TERM KATE BARR a/k/a KATHLEEN BARR CIVIL ACTION - LAW INTERROGATORIES TO GARNISHEE To: Bank of Landisburg (Garnishee) You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you: 1. At the tirre you were served or at any subsequent time did you owe the Defendant any money or were you liable to her, on any negotiable or other written instrument, or did she claim that you owed her any money or were liable to her for any reason? Answer: 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the Defendant? Answer: 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the Defendant or in which Defendant held or claimed any interest? Answer: 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the Defendant had an interest? Answer: 5. At any time before or after you were served did the Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefor?. Answer: 6. At any time after you were served did you pay, transfer or deliver any money or property to the Defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the Defendant against you? Answer: 7. State the name of the owner or authorized signators of any accounts which you have in the name of Defendant, the number of each such account, and the amount in such account at the time of service of these interrogatories and at the time of answering of these interrogatories. Answer: GLENN C. VAUGHN At~rney for P{~idti~ ID No. 07484 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-2505 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY; To satisfy the debt, interest and costs due FRANCINE BRAXTON WALLACE, Plaintiff (s) From KATE BARR A/K/A KATHLEEN BARR, 227 WEST POMFRET ST., CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell . (2) You are also directed to at~ach the property of the defendant(s) nnt levied upon in the possession of BANK OF LANDISBURG, 5125 SPRING ROAD, SHERMANSDALE, PA 17090 - ALL BANK ACCOUNTS GARNISHEE(S) as follows: and to notify the gamisbee(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) Ifproperty 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 aa above stated. Amount Due $1,164.00 L.L. $.50 Interest At~y's Comm % Due Prothy $1.00 At~y Paid $94.2~ Other Costs Plaintiff Paid Date: JUNE 27, 2002 CURTIS R. LONG (Seal) ~ Deputy REQUESTrNO PARTY: Name GLENN C. VAUGHN Address:22 SOUTH BEAVER ST. YORK, PA 17401 Attorney for: PLAINTIFF Telephone: 717-84~-9689 Supreme Court ID No. 7484 ~27 ~J ~,~,.,:.f 34. C.~l,'sl~,v~ t'~o~3 125 Fc~ner~ AmX.S~ ,.~ CLaZ.S S~T mR~ Z, ~.e m~r,o ~A~S, ~ou APP~CE PERS~ALLY OR OR osJ~C~XOSS ~ ,s~ c~ms s~, ~ A~ZSS~ ~OU. rOU ~a~ UA~S~n ~ ~u~ ~y BE ~R~D AGAINST Y~ B~ ~ ~ H~THOUT ~RTHER ~ICE ~R ~Y ~Y CLAI~ IN THE ~I~ OR ~R ANY OTi{ER C~IN OR ~L[EF ~O~STED B~ ~ PLAZ~IFF. YOU ~Y ~S~ HOHEY OR P~PER~ OR OTHER RIGHTS IH~RT~T ~ y~. YOU SHOULD T~ ~HIS PAPER ~ Y~R ~YER' AT ONCE. IF YOU ~ ~ HAVE A LA~ER OR CA~ AF~RD O~, ~ ~ THE TgLEPIIOE OR TH~ OFFICE SET ~RTH BE~W ~ FIND O~ ~ERE YOU C~ G~T LEaL HELP. CI-~E~OD[3NI~BARASSOCIATION - 2 LIBERTY AVEN3E CARLISLE PA 17013 717 249 3166 COMPLAINT Kathlenn Barr Docke~ # CV-0000019-01 227 W. Pomfret St. Carlisle, PA 17013 (Appellant) Denise Jensen Civil # 01-2505 141 W. Louther St. Carlisle, PA 17013 (Appellee) Francine Wallace ] 25 Fenncrton Rd. Paoli, PA 19301 (Appellee) I) In response to thc original complaint filed ~inst mc at Docket # CV-19-01 before District Justice Corrcal (D. J. Corrcal), I attcst that thc above appellees bmkc written contracts for room, board, transportation and supervision for thc students Sasha Edlcman (age 1:5) and Ashley Wallace (age 14), students at thc Central Pennsylvania Youth Ballet (CPYB). Exhibit I and2 2) These students were removed from my home by their above named parents on November I 1, 2000, without notification prior to that date. 3) Furthermore, there was no notification whatsoever, of any dissatisfaction with their placement in my home. 4) Said coat, acts vsx're for the school year, Scptcmber through June 2000-2001, with monthly payments of $800 each, and a security deposit of $800 each. S) D. J. Correal datcrmined in her attachment to Notice of Judgment dated 3/28/01 that thc (Jcnsen) contract was flawed and the (Jenscn) addendom was not enforceable. 6) D. J. Con, al dctermincd that all parties failed to adcclnatcly communicate. 7) D. J. Corrcal awarded zero dollars in damages to either party. 8) Although I have attempted to place other tenants in my home to recover lost income, I have been unable to do so. 9) This has resulted in considerable financial distress. 10) On the atlcmoon the girls were removed from my home (November I 1, 2000), I was shocked and stunned by the written acco~tions brought against me. Exhibit # 3 11 ) At that time I was informed by Mm. Jensen that I had broken the contract and the girls would be removed from my home immediately. 12) In good faith, I provided a home for Sasha Edleman and Ashley Wallace, through the terms nfthe contract for board, room, Iransportation and supervision. 13) There was ample opportunity for dissatisfaction to be brought to my attention, to wit: 13 a.) Both girls communicated frequently with their parents. 13 b.) Sasha Edleman had free access to e-mail through my personal computer and she frequently spoke with her mother by phone. 13 c.) Ashley Wallace spoke daily with her family on her own private phone line, paid for by her family and located in her room. 13 d.) Mrs. Wallace was in my home nearly every weekend, September through November 1 lth 13 e.) M.rs. Edlenum and I spoke several times by phone. 13 f.) Mrs. Edleman visited in my home two weekends prior to November 1 lth, spending over two hours in conversation with me on one occasion. 13 g.) I was told by Mrs. Edleman that Sasha had made an excellent edjusunent and was doing the best she had ever done in school. 14) At no time was I told by either parent or child that anything was wrong, but received only positive comments from parents. 15) On several occasions, I spoke with each girl privately and asked iftbere were any problems. 16) At no time were any problems expressed, with the except/on of Sasha's complaint ofber bedroom beIng cold, for which I was taking steps to alleviate, and told her of those steps ( ex'wa bedding, the offer of a temporary electric, ' area with plastic), micro furnace and the covering ofan exposed window 17) It must be noted that several written complaints (Exhibit 3) occurred during the two to three weeks prior to November 1 lth, during which the seasons were changing, it being warm one day or a part of one day and chilly during another. 18) Furthermore, during this same time, the girls Sasha and Ashley were extremely busy with their school and dance schedules, (Ashley having added more dance hours to her schedule), and both girls were absent from my home while visiting with parents on the weekends, returning late Sunday evenings, thus limiting time available to talk among ourselves. 19) I had no opportunity to attempt corrections, as I was unaware of any complaints beyond Sasha's, of a cool room. 20) Written complaints regnrd/ng my daughter's antion of visiting with two male fiiends in her room, in early September, reflected a one-time incident which I discussed with her and which was never repeated. 21) On one occasion, a young man known to my daughter and myself flora regional church events, spent a Septeraber night in my home with my permission and supervision, as I judged he was certainly no threat to anyone living under my roof. 22) Sasha Edleman and Ashley Wallace had no contact with the young man other than exiting the house in the morning, as we all lei~ for school. 23) When Sasha Edleman and Ashley Wallace entered my home, both families were aware that I was and am a single parent and was raising a 17 year old daughter, which requires considerable juggling of time and energy. 24) Both families were aware that I was employed full time as a primary school teacher. 25) As such, there are specific times of the year when my professional duties are more intensive and time consuming. 26) At no time did I fail to provide food, board, mmsportation or supervision. 27) I regularly sat with the girls as they ate, so that they would not be alone at the table; I provided opportunities for shopping lrips and a visit to the PA Renaissance Faire; I also provided special Halloween decor and special favors; and during my most busy time, I assisted Ashley Wallace in developing and conslructing a project for a class nt school. 28) My home was thoroughly cleaned on a regular weekly basis, with the short=term exception of the time period two to three weeks prior to November I 1, during which housekeeping vms erratic due to the ex'~emely busy schedule we were keeping. 29) When Mrs. Sensen and Mrs. Wallace arrived on the afternoon of November 1 lth, my daughter and I were in the midst ora thoroughly cleaning our home. 30) The written statement of complaints (Exhibit $) presented to me by Mrs. Jensen was later addressed, point by point and copies sent to both Mrs. Jensen and Mrs. Wallace. Exhibit 4 3 I) The majority of complaints in (Exhibit $) seem to apply to Sasha Edleman only. RELIEF REQUESTED I request that the appellees, Denise Jensen and Francine Wallace, honor their conuact and reimburse the appellant Kathleen Barr the amount of $7,900 (seven thousand, nine hundred dollars), which reflects only pan of the income owed her for the time period ofNovember 1 !, 2000 through June 30, 2001. Had the appellees honored their contracts, the appellant Kathleen Bart would have received $5. 600 (five thom'and, six hundred dollars) )?om each, for a total of $ ! i, 200 (eleven thousana~ two hundred dollars) December 2000 through June, 2001. Further, the appellant, Kathleen Barr asks thru she be reimbursed for the costs incurred by her for this litigation, as set out in the contracla. Exhibits ! and2. These costs are as follows on this 18th day of May, 2001: 02/09/01 Initial Consultation, Killian and G-ephart $200.00 04/27/01 Cumberland Co. Prothonota~'s Office $ 45.25 05/09/01 Post Office, certified mailings $ 7.48 $252.73 I state that the facts set forth in this complaint are tree and correct ~o the best of my knowledge, information and belief. Kathleen Ban- ~' / ~ "~ / CONTRACT FOR BOARD AND ROOM SCHOOL YEAR 20u:> TO 20_6 I This is an agreement between Kathleen Bart and b e '~ I~ ~ ] Cn~d-- the pa nt/s of ~aS¼0-- Ed e provide a private room, boa d, tramponation, and supe~ision for the school year, begi~ing S~tembe and endin June 3020 ~ ~ g By signing this a~eement, ~] enscn is/are commi~ing t~es finmci~y to a tot~ of $8,~ for the above time p~od. * $I6~ Fint pa~ent upon rese~ing the room, which indudes: *$8~ S ' eptember s rent, *$8~ Deposit for the fo~owing pu~oses: *fbr damage to structure, ~mishings, and appliances, caused by the student beyond the no~ "wear and te~" ofoc~pation. P~enm ~e to be notified when such d~age comes to my attention. Receipm for repair or r~lacement w~ be provided md ~nds deduced. The parent/s w~ be l~pomible for my md ~ excess cosm necessa~ to effe~ r~r or replacement. *an emergen~ rese~e fbr unpl~d or emergen~ e~enses of the *Late pa~ent fee. Pleme see below. *The parent/s w~ be notified if ~uds ~m the d~osit ~e used. Receipts w~ be provided for each e~eme. ~ un~ed ~nds w~ be returned when the student leaves ~s h~ehold, afi~ m invento~ and impe~ion of the student's room is peffo~ed. If ~p~r and/or replacement of ite~ is in process, the b~ance of the unused ~nds w~ be returned within 30 da~. *Mont~y pa~enm of $8~ are due by the fi~t of each mon~ (u~s othe~e a~nged): O~ober, November, December, Janua~, Febma~, Ma~, Ap~, May md June. Since I d~end on these fe~ to hdp pay food, tra~pomtion, s~ice and ene~ costs, it is necessa~ that th~ be on time. A S% fee of $40 w~ be cha~ed if~e mont~y pa~ent is late wither a five day notification, ~u~y the 25th day of the p~vi~s month. This w~ be deduced from the d~osit . and the parent/s notified by phone and receipt. Please note, I am committing a portion of my home and my time and energy toward the support of your daughter for the term of this contract. I expect your commitment of the $8,000 fee for the same time. If you- r ' ...... - e~P°~le'~'n~he~smelent-o f the~school-woutd- entex- my-home_asa, bearder. I. OBLIGATIONS OF KATHLEEN BARR Meals and Nutritional Guidance- As a trained Home Economist recognizing the nutritional needs of a teen in a very demanding physical training program, I will endeavor to provide an appropriate meal pattern and diet for your child. This will include consultation, monitoring, adjusting and advising. It is understood that there may be conflict between the demands of the program for a minimum standard of weight and the needs of the student's body for optimum nutrition. If an adequate diet pat/em is not followed, injuries will. The conflict may also lead to eating diserders. Concems in this regard will immediately be taken up the student and parents. Healthy, well-balanced meals/snacks will be served with consideration to food likes/dislikes. Ifa meal is not acceptable to thc student, she may use leftovers fi.om a previous meal, or make herself an altcmativc (with my ok) from food in thc freezer or pant~ff. Brealc.C~ast x fll be make-your-o~ from a variety of accessible choices .I cxpact boarders to be up early enough to eat a reasonable breakfast. Lunches may be carried to school in a thermal container ! will provide. These are to be made by thc student on the prcvioas night. Altcmativcly, the student may chose to buy her lunch at school, in which case I will provide $2.00 a day. Dinners will be provided according to the student's schedule. This will be a hot meal available at the dance school to be warmed up, or upon the student's return home aRcr her last class. ~ Thc Carlisle Community of schools expect the majority of students to walk. My home is within 8-10 blocks of both Lamberton Middle School and Carlisle High School. Morning transportation can be provided iftbe student can be independently prompt, as I must also meet a schedule in thc morning. Thc dance barn and warehouse are within walking distance of Carlisle High School and busing is available from Lambenon Middle School. Transportation will be provided to return home fi.om dance classes. Transportation to and from practices and special events is provided within the greater Carlisle/Harrisburg areas. This includes transportation to thc Harrisburg International Airport or to the Harrisburg Train/Bus Station. Transportation outside a 35 mile radius of Carlisle will be charged at $.25 a mile. Day trips to Philadelphia, Baltimore and Washington D.C. and environs are acceptable. I do not travel to N.Y.C. or to Pittsburgh. Train and bus service is available from Harrisburg for these cities. Communication: Students entering CPYB are embarking on a strenuous and taxing stage of their lives, not only physically, but academically and personally. It is my job to help the student meet these new challenges in a supportive family setting. I will support and counsel each student as needed and provide a regular family council time to help the student integrate as easily as possible within this new life, away from her family. Your child will be welcomed as a complete member of this family. I respect each student as an individual, and I require from each student a respect of self, of other students living here, and of myselfand my family. ! expect to be in contact with parents on a regular ~asis, especially in the beginning of the year and to express and concerns to parents and student. E-Mail is available. The student may choose to have a private line established in her own room at her own expense. The downstairs phones are available for use with a calling card. ~ Bedspread, blankets, sheets and towels are provided. Sheets and towels are laundered weekly; blankets and bedspreads as necessary. Nails, screws or other such fixtures may not be added to walls or doors, nor moved without my permission and supervision. A bulletin board, laundry hamper and mirror, and wastebasket are provided in each room. There is access to a vacuum, mop and dusting tools. All trash is to be placed in appropriate receptacles by Thursday night. Laundry facilities are in the basement and include washer, d~er, ironing board and drying rack or clothes line. The student must provide her own iron and flat-rack drying system. Space for bicycle storage is available. It is strongly suggested that bikes have a strong lock and it is imperative that a helmet is worn. STUDENT OBLIGATIONS *The student will respect herself, other girls in the household and Kate. Our dogs, Puma and Russell B. are to be treated kindly. *The student may not drink, smoke, or take other than prescribed prescription drugs. *It is the student's responsibility to keep her room in order by vacuuming and dusting weekly. Equipment and supplies are provided. *There are to be no candles, incense, matches or lighters in the student's room. *Guests of the opposite sex may be entertained only in the first floor common rooms. *Carlisle has a curfew policy, requiring all students under the age of Ig to be home by 1 lpm. When the student is out oftbe house other than at dance classes or activities, I expect to know where the student expects to be und the approximate time when she will return. For a student to attend a party or activity at any home, I must be provided with a home address and the phone number of the parents hosting.( I will contact these prior to the party or activity, to be sure there will be active supervision and a no alcohol/drug policy in effect.) *The student is expected to pick up afier herself in the common areas of the home: returning personal items to her room, placing recyclable items in appropriate containers, returning food containers to the refrigerator and placing used dishes in the appropriate containers. *Wet clothing must not be lefi on floors or furniture. *Lights and other electrical appliances are to be turned offwhen the student is leaving an area. This is especially important when the student is the last person to leave the room/house. *The student is to be provided with her own spending allowance and to purchase her own personal supplies, including laundry detergent. *The student will be responsible for her personal lanndiy. She will be assigned a scheduled personal laundry day afier a family council discussion. Non-assigned days will be available on a first-come, first-serve basis. *Each evening the student is responsible to make her own lunch or to noti~ Kate that she will need money to buy a lunch the following day. *The student is responsible for wakening independently and for leaving the house in a timely manner in the mornings. *The student is responsible for common kitchen tasks: + emptying and cleaning her thermal lunch container and returning the cooler packs to the freezer. + keeping soiled dishes and glasses off the counter-tops and out of the sink area. + refill ice cube trays and water filter pitcher as they are used. + wash and refill a jnice pitcher when the last serving has been used. KathleenBarr, .~-~-~_ ~c~n-~r~ (student)and --"--' (parent/s) agree to abide by the above contract. Signed ~~) CONTRACT FOR BOARD AND ROOM SCHOOL YEAR 20.~ TO 20_ This is an agreement between Kathleen Barr and C l l] ~., On~ ~(~O~]fl the parent/s of ASh}~ ~4&l~aC~to pmvid~ a private ~om, board, ) transpo~ation, and supe~ision for the school year, begin~ng September~ and ending June ,20~. By sig~ng this agreement,O~ i~ ~ ~ ~ ~are com~in~ the~elves financi~y to a to~ of $8,~ for ~!~ove txme period. * $16~ Fint pa~ent upon rese~'ing the ~om, which includes: *$8~ September's rent, *$8~ Deposit for the fo~owing proposes: *for damage to structure, ~mishings, md applimces, caused by the student beyond the no~ "wear and te~" of oc~pation. Parenm a~ to be notified when such d~age comes to my attention. Receipm for repair or ~lacment w~ be p~vided md ~nds deduced. The parent/s w~ be responsible for any and ~ excess costa necessa~ to effe~ r~air or ~placement. *an eme~enff rese~e for unplanned or emergency e~enses of the student. *Late pa~ent Fee. Plebe see b~ow. *The pa~nt/s w~ ~ notified if ~nds ~rom the d~osit are used. Rece~p~ w~ be p~v~ded For each e~eme. ~ unused ~nds w~ be returned when the sm&nc leaves this household, an invento~ and ~mpe~ion oFche student's ~om is perFo~ed. IFrepair ~d/or replacement oFite~ ~s in process, the b~ance oF~e unused ~nds w~ be returned w~ch~n 30 da~. *Mont~y pa~enu oF~8~ are due by the fi~t oFeach month (u~ess othe~se a~anged): O~ober, November, December, ~anua~, Febm~, Ma~h, Ap~, May and June. Since I depend on these kcs to help pay ~bod, trampo~afion, se~ice and ene~ c~, ~t is necessa~ that the~ be on time. A 5% Fee of $40 w~ be cha~ed iFthe mont~y pa~enc ~s late wkhout a five day notification, usury the 25th day o~the previous month. This w~ be deducted ~om the deposit an~ the parent/s notified b~ phone and receipt. · ase note, I am committing a portion o£my home and my time and energy toward .rt of your daughter ~'br the term of this contract. I expect your commitment of the e for the same time. If your daughter leaves the Central Penna. Youth Ballet for ~, all remaining months' room and board must be paid at the time she leaves. A possible only if another student of the school would enter my home as a boarder. id would be for the time period that new student would be living at my residence. l]~is..n~ot paid at the time your daughter might prematurely leave, ~ ~ a/~a/ "&~...~.L.~.would also be responsible for any court/lawyer expenses necessary for Barr to recover the remaining balance. OBLIGATIONS OF KATHLEEN BARR { Nutritional Guidance. As a trained Home Economist recognizing the nutritional ~ teen in a very demanding physical training program, I will endeavor to provide ,riate meal pattern and diet for your child. This will include consultation, g, adjusting and advising. It is understood that there may be conflict between the the program ~'br a minimum standard of weight and the needs of the student's body 'm nutrition. If an adequate diet pattern is not followed, injuries will. The conflict may , eating disorders. Concerns in this regard will immediately be taken up the student S. althy, well-balanced meals/snacks will be served with consideration to food :es. Ifa meal is not acceptable to the student, she may use leftovers from a previous ~ake berself an alternative (with my ok) from food in the freezer or pantry. Breakfast ake-your-own" from a variety of accessible choices .I expect boarders to be up early eat a reasonable breakfast. Lunches may be carried to school in a thermal container I lc. These are to be made by the student on the previous night. Alternatively, the ty chose to buy her lunch at school, in which case I will provide $2.00 a day. Dinners ~vided according to the student's schedule. This will be a hot meal available at the )ol to be warmed up, or upon the student's return home after her last class. ttion: The Carlisle Community of schools expect the majority of students to walk. My /thin 8-10 blocks ofboth Lamberton Middle School and Carlisle High School. 'ansportatiun can be provided iftbe student can be independently prompt, as I must a schedule in the morning. The dance barn and warehouse are within walking distance High School and busing is available from Lambertun Middle School. Transportation ~vided to return home from dance classes. ~nsportation to and from practices and special events is provided within the g~eater arrisburg areas. This includes transportation to the Harrisburg Intemational Airport or · isburg Train/Bus Station. Transportation outside a 35 mile radius of Carlisle will be $.25 a mile. Day trips to Philadelphia, Baltimore and Washington D.C. and environs .~ble. I do not travel to N.Y.C. or to Pittsburgh. Train and bus service is available from for these cities. Communication: Student~ entering CPYB are embarking on a strenuous and taxing stage of their lives, not only physically, but academically and personally. It is my job to help the student meet these new challenges in a supportive family setting. I will support and counsel each student as needed and provide a regular family council time to help the student integrate us easily as · possible within this new life, away from her family. Your child will be welcomed us a complete member of this family. I respect each student as an individual, and I require from each student a respect of self, of other students living hexe, and of myself and my family. I expect to be in contact with parents on a regular basis, especially in the beginning ofthe year and to express and concerns to parents and student. E-Mail is available. The student may choose to have a private line established in her own room at her own expense. The downstairs phones are available for use with a calling card. Housekeeoing: Bedspread, blankets, sheets and towels are provided. Sheets and towels are laundered weekly; blankets and bedspreads as necessary. Nails, screws or other such fixtures may not be added to walls or doors, nor moved without my permission and supervision. A bulletin board, laundry hamper and mirror, and wastebasket are provided in each room. There is access to a vacuum, mop and dusting tools. All trash is to be placed in appropriate receptacles by Thursday night. Laundry facilities are in the basement and include washer, dryer, ironing board and drying rack or clothes line. The student must provide her o~ iron and fiat-rack drying system. Space for bicycle storage is available. It is strongly suggested that bikes have a strong lock and it is imperative that a helmet is worn. STUDENT OBLIGATIONS *The student will respect herself, other girls in the household and Kate. Our dogs, Puma and Russell B. are to be treated kindly. *The student may not drink, smoke, or take other than prescribed prescription drags. *It is the student's responsibility to keep her room in order by vacuuming and dusting weekly. Equipment and supplies are provided. *There are to be no candles, incense, matches or lighters in the student's room. *Guests of the opposite sex may be entertained only in the first floor common rooms. *Carlisle has a curfew policy, requiring all students under the age of 18 to be home by 11pm. When the student is out of the house other than at dance classes or activities, I expect to know where the student expects to be and the approximate time when she will return. For a student to attend a party or activity at any home, I must be provided with a home address and the phone number of the parents hosting.( I will contact these prior to the party or activity, to be sure there will be active supervision and a no alcohol/drug policy in effect.) *The student is expected to pick up after herself in the common areas of the home: returning personal items to her room, placing recyclable items in appropriate containers, returning food containers to the refrigerator and placing used dishes in the appropriate containers. *Wet clothing must not be left on floors or furniture. *Lights and other electrical appliances are to be turned offwhen the student is leaving an area. This is especially important when the student is the last person to leave the room/house. *The student is to be provided with her own spending allowance and to purchase her own persona/supplies, including laundry detergent. *The student will be responsible for her personal laundry. She will be assigned a scheduled personal laundry day after a family council discussion. Non-assigned days will be available on a first-come, first-serve basis. *Each evening the student is responsible to make her own lunch or to notify Kate that she will need money to buy a lunch the following day. he student is responsthle for wakening independently and for leaving the house in a timely manner in the mornings. *The student is responsible for common kitchen tasks: + emptying and cleaning her thermal lunch container and returning the cooler packs to the freezer. + keeping soiled dishes and glasses offthe counter-tops and out oftbe sink area. + refill ice cube trays and water filter pitcher as they are used. + wash and refill a juice pitcher when the last serving has been used. I[oe e_ ' Iq ' 438',3 ' -- (parenffs) agree to abide by the above contract. Signed .~-~4;ff~---~~ J Date:~ tOd)C~) Witnessed Date: ........ ' '" · ~ , .r.'~ )~ .,n.~'.-- ,o,._...;....~..,..~- b.,-.,' ,-,._re,.,.,e..-,-~.,-.,~./,~.., -,&.,~,-:.:.. ,e.n,o..-' a.o,],..-,-' ,' . ' " ~, - ,' -' , -,,t~ ~ · ' ,:~ · . , l, L..eJ ~.~,..~. ,*,'~.'d~.~. r...l~.l~...).el. 7~lk 4,v-~--/~, i~, Iv,lq.. 1,3 ', -- [rJ-P.t(.~ ~%. , t - , .4 ', . "- ~--! ..... · eo-.,'/~ /~ t"./.~ 4','-..,d., /,"~,-' wa-'-,..-"t:,,'n.e-5 qa~,.~,,.....~ ,,,~=e ... ,"t o~,ee,_~, to ';'".'o .4 .. O.I'~;,cr ,~.. ~-,.,,..~./ _ _; .~ h..., ., ~, ..P- ~, ,... - 'l;..i, "~ ,2? t . . . . '~ re//Ia~ .omwa.~ c./d. yatt :U,o.,.,..,,.~.: .,~_/,.,,.. a,.~.,,....,.-,.., ~.~.,./-,~:,., .~? c.'~ '~..:~,:~,;., 'A ~,,,~z/ :~o.,45_ A~ ~ 4~sv~,;' t..i,'¢ ,~.~- ;j..'.~.'~ 'r~ ~,-r~.,,.~..... ~'~- ~, ~.',.~_~...%'%';';" "=5- O ..-.-~og:rr~d ~ Orr'l=' &~- tel'.' ~ '. ~ i. '~v . z". a.( · f ~ !/'o. ~ ~z,~,tXe.,e. /s · /i ~ ~' ,. b' / . / ~" I)}~t;~ '1,..''=4 .' · / · I ,a ...._.' qo/i/,we e 6'ae,~,se.~,r_ / v.4, f, Ob~t, re: lie /oeAP_.,e *q-/'h,,~ h'a a. .x. ,,..-t, ,~Z~ 7." ~.,..'-,'~ .; C, ? .'~ h i.~ ',.' Mrs. Wallace: ' Dear Mr. and Mrs. lensen and at your appearance on November 19th, complete with a list of ways in which you felt I violated our cooed - were presented To say that I was shocked --ct, is an understatement- Accusatxons During our recent conversation when you first returned to Carlisle ~rom the West by Mrs. ]easen. Sasha's state of mind and excellent school record. After M~. hour vath my daugl~.l~.r. Y ,__~ o,~ vcrsaiion with you, CoaSt, you were full of praise for . . ou said you felt that Ivleghen s . ___~.,a ~entaroundahalf .., _~ r~,rinnalaierpnu,,-vvn ~nd Mr. jen~l, ,,,-- sp~ ~ --,- .~sitive ouu~'~,, .... p~scnce cnntnbuted to baSna = ~.~ for Sasha to remain in Carlisle for the rest of her High was told thai the decision had been made and to atteOd the CPYB during thai time. You were veW positive about her experience and seemed to suggest that she would remain in my home. At no time was there any School years home nearly evetw weekend since concern or question raised. Mrs. Wallace has been in my ' school started. At no time did she voice any concern. ' I believe pertain to written concerns, some of which . a single I am going to address each of your As these were addressed to me m Ashle~ Wallace and most to Sasha Edleman. document, I will respond in a like manner. I feel that there were some instances in which I failed to communicate xvhh a parent but that there were also mitigating circumstances- . 19th, have health insurance. I did speak with Mrs. lensen on at least two occaswns I. I had been asked to find a physician for Sashe Edlemen, who did not and does not, as funds. During of November regarding this. She said that waS the next thing on her list as soon as there were one phone conversation I gave her the number for pennsylvania's KIDS medical insurance , umber and that that number was_ _. o. ,a r that she call!lh.i n.mber and Mrs. eeen vrogram, she t.o.~,a m.~ ,~._a_. .... weeks, 1 again gave _n? ,i~_n,.a tw Doctor's omces. willing to tak '° · have two sources for em.erg _ ~--'----~inaiion thai these was _. ~ l aid not pursue thts. Wc . -,,--~,~,~,,~uth inlaaetneo~t~t,,' · '. ida School. I recently signed the good h~alm, - - -- of Carlisle Hospital aha n~a,,,, the emergency room ' - · , :- -ade ava,lable ai Carl,s? ,-fl these plu, some .... md be adequate. A pnys~.ca.~ ~,~. ,_,_'_'_a i, to the school, as :~asna na~ ,~ ;;rwork for this and han~l-aenw,-~ '~)n the table. others which looked important for her, heal back in our house dining the day when we are not home. ILl has never 2. I turn the Granted, this is too cool for comfort. I expect the people re-enter the home. My daughter, Ivleghan regularly did been below 66 degrees as set on the thermostat. . the,Ostat to be turned up whenuall around 3 pm This was also a t~me of late Fall fluctuating this when she returned home, us Y'' temperatures, some days chilly, some days warm. Sasha never info,ed me that the~ejau~ problem, or that she was uncomfortable. Had she done so, ! would have told her to oscar upon arriving home. ~ _ .~...~0~"- · of Sasha's bed. This does tend to be a cool · h,., ..... · u,~.,,~,--- side Meghan and I had spent several hours on .... Tbere is a healing duct room as it has two walls on the outside of the hoUSes~reen area on the sleeping porch to provide Saturday, November ! Sth, placing plastic over the some protection on that side. Sasha ~ told me her room wes cold. I suggested leaving her door I o~en a little a night. There is also an upper transom window which could have been tipped to ~I~,,., o~r ~ir,~,tn~inn Sasha never mentioned household noise being a problem..1 a. lso. o..ff~, ed_ m,~ ................ . . ' · ~ -- --.~-:~h my d,~,aht used last year. I also zola her m her an electric, ceramic disk, micro furnace, win,,.....j _,~...er , keep her closet door closed as the closet is uninsulated in my 100+ year old house. Warmer clothing could have been obtained by taking her clothes out of the closet the previous night. The micro furnace was never used in her room, to my knowledge. This weekend, 1 offered her flannel sheets, as the nights have turned cold. Sasha refused these. I was not ignoring this problem. 1 was offering appropriate reraedtes. 4. (There is no 3.) I was home from my school on Friday, November 10, after completing two days of conferences for the parents of my 2nd graders. When I got up to get the girls offl ooticec~ that both Sasha and Ashley were ~ tired. Their body movements were lethargic and facial attitudes were less responsive and animated that normal. I told both girls that I feared for their health if they continued without sleep. I said I felt it was time for a health day before they would become ill. I checked to see that they had no school work, tests, or projects due which they assured me they did not. (Since they had been visiting and traveling with you for several weekends, after dance classes were over, the girls had not been getting their Sunday of relaxation which was so important to their physical functioning. Ashley was maintaining a new, more rigorous dance schedule.) Both girls returned, a little reluctantly, but it seemed x~4th obvious relief, to their rooms and slept until afternoon. Both girls went to dance classes that afternoon and returned home in high spirits. Sasha was dancing around the dining room chortling about how well she felt and saying "This is how it feels to have enough sleep!" I had planned to talk with each set of parents about the active schedule the girls were keeping and the need for more sleep. I made sure my schedule was clear on Sunday afternoon and evening (Nov. 19) as I wanted to bring this up when you returned with the girls. I never thought to call, as this was no emergency, bat within the range of daily decisions which I felt was normal to make. [ assume that at least one of the girls mentioned this. If it was a problem, I would have expected to hear from a parent after Sunday, Nov. 12th, or earlier, as both girls were in frequent, often daily, contact with their families. 5. I believe Sasha may have mentioned she had to carry her books long distances. My daughter did too last year. Sasha could easily have stopped at the school office and made her " lack of a locker known, or asked me speciftcally to call. I did observe her wearing a light jacket, but I also observed her wearing a heavier one. The afternoons have only this last week (Nov. 13-17) turned cold. Previously the afternoons have been frequently warm. Some mornings, when Sasha has been downstairs on time, she has ridden to within 2 blocks of the school. This is a regular routine. Frequently, teens do not like to wear heavy outer garments. At age 15, I assume a girl is able to make the decision over what weight coat she needs. Sasha has been coming down late in the last two to three weeks. I normally fix a hot '.; breakfast for the girls two to three times during the week. I have not been able to do this recently · because they have been do~n so late. Sasha has walked a number oftimes in the morning because she could not be ready between 8:15 and 8:20. I have checked several mornings to make sure both girls were up, because both had expressed they were so tired. Getting up on time is a girl's responsibilit)'. This is stated in the contract. 2 6. ! contacted CPYB in September askine where shoes could be fitted. ! was told there were no longer any local (Carlislc/I-larr/sburg) b~sinesses doing this. I was told that girls USually mail-ordered these, lC believe I mentioned this to Sasha. l~oYudl~dhna°vteft~l[omwe~ae thc mt.s.take..n assumption that anoth pair that two companies do come to wcu up on !fils. However. ljus. t became ~ea~ra? tile CPFB toff! shoes. There have beenJTve opportunities since 3~eptember fi~r such fittings· Each has been posted by flyer at the representatives !!o fittings between approx£mately 4 8 30 PM. me. ant!obviously t[id not toke . . . .. IlXareh°use. The compan~ I was rarely tn the YYarehouse advantage of the opportuntt~ I SaMta never m~e. ntionedthis to · -~. hat!no w,~ -: ,,j nnowmg this. since 7. A male fl'/end ot'Meghan,s did spend one-tim_e, only basis. He had co _ one night on daughter s church v th ---, - m~e .frnm out of-state to att . ' ' the couch tn our hving room on a .,ou_ ~oup. t ms groan dn~o ~, .... end the Renaissance ~:o;.~.: "normal-looking,, teens involved. I ,- v,.~ ,uv= outer "odd I~-~' -'-,~ ,,!th my people. ! did not want irn o,_~_.bon, or our church for · . . _ - outing characters', as well as h _.., ,,~ a tartly mexper/en,,o,~, bern. g. w~ll,ng to accen~ 0, · ,,,~u young clnver, to dr/-- ~ "' '"'~ .young probably should not have allOWed this. ! did s/eep with my door open and he left as ,,~ nome to Ytrginia. ! morning ! knew the boy well and dtd not feet he would create a nrol~;~ · we did in the happened in/ate September. l£it was before now, as each of great concern to either git/, it should have come up r ,--,,~m. t must note that this was in regu/ar contact w/th her family. This young man does look' decided people based on who th ly odd. In our ho ey are, not on how they look. Hav~__m~: ho.w. ever, we emphasize my share °fbeingjudged on "looks". Some,-t~ t~VeCl throu~,h t~ ,,~. . ,~- ',,- mPptc era ! had teens rebel by acting out, dr/nking, doing drugs, having early sex, or dressing in weird ways. I believe underneath far outweigh other choices. I try to maintain high personal standards. Meghan is very that weird dress and a decent person vehement about her standards. She is not a follower. She sets the standards and she has or' fr/eadships because of this. Please note that when you both came hack to the house o~°st a lot Saturday evening, November 18tlL there were about 25 ! 8th birthday party. They teens behavior, and were calm and orderly and having a good for Meghan,s they were being supendsed, carpeting two rooms t/me. There was normal teen There were both weird and ' normal' looks in dress. 8. Again, in September, there was one/no/dent o£Meg having two young men upstairs in her room. I had returned fl'/ends buzz/ng Meg in her room over the intercom. She told me she had her room and I reminded her of home from an unremembered errand, but do remember ~th her previous to ,or:__ the house rule and to ,~ *~,~- ~ two fi/ends, naming them, in yond the that it esl' ?'n come do s rs. !had di that even though there is .... ,, was reprimanded It t, ..... ~e ,. ,~ no mates ' ' floor, ! an item in the contract ban-/ng y~un~''~" t nappeoed since· I ... would not have "thrown your daughter out of!be house" for breaking this rule. men above the ground would have been an occasion for discussion between us. Rather, it 9. ! must admit that my housekeeping has not been good over the last month. Conference time is the busiest and most demanding time of!be Year in the Elementary school. ! putting my time at home into the g/r/s, not the house. I frequently put in 18-20 hour days between my . teaching pos/t/on and seeing to the transportation have been and good meals for your girls. I 3 still made it a point to have a sit-down meal for Ashley and Meghan shortly aRer Ashley came home from dance. I also usually sat with Sasha while she ate, although I know a couple of nights I collapsed on the couch· After both girls had eaten, I cleared up food, and Prepared for the next da,v. I often napped, then would get up around 2 or 3 ~Paperw. o. rk. I felt it was important not to bre-'- ~'- . .am to continue work on my school .ocmanclin · . . . u~ me g,ri s.routine, because mine was · g dunng th,s time On the weekends, I was tak, ng my daughter to college . ponod. Ifetther of you would have -.~---, - , ,g. and dusting ware on low nriori~,, '"~ ·couta nave exvlained ,t._, ,~. " · - ,nut tnts was. of short duration. My cocker docs have an allergic ~kin problem and he has a strong odor. I've been taking him to the vet, but he hasn't been bathed as much as he sbould, during this Period. Ut the present time, he has healed. My conferences were finally over and I did major cleanup work the weekend of the 18th and 19th. weekend. The house was vacuumed prior to Meg's party and as you entered to voice your displeasures, Meghan and I were in the act ora major clean-up. My house does tend to get cluttered, but this does not interfere with safety. If the house was a 'shock', it was NEVER mentioned and both families have been in and out of the house frequently. My cellar is typical of the old "finished" basements in this area. The stone walls are mortared" with a sandy combination that sirs down onto the edges oftbe floor in some areas, most notably the laundry area. It's one of'the things I want to improve, but have not yet gotten to it. I recently gave the laundry area a good vacuuming. I had bought a rug, which I attempted to put dow~ last weekend, but it was slightly too largn. I had not yet bought a replacement. The washer and dryer, table and top oftbe freezer are wiped on a regular basis. Please note that I have attempted ~mprovements. I have recognized the sidewalk with dog feces as a problem, lhave a gate partly put together in my basement lo bar them.from this area. I did Ixy to keep this cleaned up daily, but I know there was some problem. The time between arriving home and picking up Ashley was filled with errands and the Preparation of the evening meal. I sometimes did not have the time to check the sidewalk, or honestly forgot, in the rush to get things done .The dogs were not regular about using that area. When I returned home with Ashley and the bike, I know I had asked her several times to wait until I cou/d clean up the walk. This involved my opening the house and walking through to the back door for a trowel and plastic hag. At no time did she wait for me to do this. I repeat, neither family expressed a concern over any of this prior to the 19th. Iflhad been questioned, ! would have replied in the manner above, wait until I had cleaned up the walk. and would have again asked her to On looking over the contract, I find that the only specific v/olation was by my daughter having males above the I st floor o~oc time. I neglected to · inform Sasha's parents about the problem vath the doctor and the. lack ofsh. oc fittm, g services. These were not contractual I have made it a point to try to s~t down w~th the g~rls when they return home from dance matters. and either eat with them or, in Sasha's case, have a cup often and talk with her while she ate. I know I asked several times if things were going okay. Early in their stays, I told both girls that I was not a mind-reader. They would have · I counted on to tell me ~fthere was something wrong. Earlier in the year, Sunday to be a "down day" when I could spend a little extra time with them. Since both girls have been out ofthe house on weekends lately, this time has not been available. 4 I received nothing but ~ from both sets of parents and no indications of ,,cu ~s She came mrougtt the aoor that the girls were going to be removed from my home ,mmediately. Mr. and Mrs. Jensen remained standing as Mrs. Jensen delivered her tirade, even though I asked all of you to be seated. This was an obvious psychological ploy to intimidate. I do fael ' that ,f Sasha and Ashley had been willing to talk with me, or if paronts had made known their dissatisfaction, then things might have been different. I do feel that expectations on both sides were different. I also feel that minor events were blown up out of proportion. My signature on the notes ofthe 19th attests to the fact that I read the document and discussed it with you both. I do not agree that this is a fair document or that I violated our contract. In fairness, I had no knowledge of your coneems, nor was not given a chance to make any changes. In good faith, I have maintained a home for both girls. I have put eftbrt into making a home-like atmosphere. I took Ashley and a school friend to the Renaissance Faire and encouraged her to have friends over. I spent several hours, during my conference preparation time, showing her how to build a "Jamestown" house for her social studies project. Both girls showed an interest in counted cross stitch in the fall and I provided fabric, threads, scissors and pattern books for their little projects. None of the.ve were returned when the. I; left my hou.~.e. During Hallox¥ucn, I provided Halloween mugs and treats for thc girls. Sasha regularly borrowed from our collection of VCR tapes to take next door to watch movies with her friend next door. I felt thc conversation on November 19 to be an attack on me. I don't believe I deserved such an attack. I do believe that communication, or lack thereof, was at the root of the problems expressed. I also know that my few weeks of work overload con~buted to the problems. At thc same time, during this period, both girls were leading an active life with their parents and I did not have the opportunities I might have had to be with the girls in a relaxed time period to discuss concerns of theirs. As we talked on the 19th, a lot was made of Sasha's "being still a baby". [ do not consider a 15 year old, boarding away from home to be a "baby". I do expect a teen in my home to be able to take care of basle needs herself. Some ofwhat I was verbally accused of neglecting to right, were personal concerns of the girl. As a parent of a teenager who has been through a lot emotionally, I have worked very hard to help her become strong, sacrificing some of my own choices in life so that this could happen. Perhaps Sasha still needs some of that sort of time, before she is ready to be on her own. I have the distinct feeling that this was carefully planned, based on Mrs. Sensen's displeasure, as Mrs. Wallace hardly said a word during the time in my living room. As I had said earlier, to go t~om being heartily praised to this kind of an aUack was very disconcerting. I am not a person comfortable with attack. I try, in my work and in my personal life to settle disputes by consensus. Again, without knowing anything was wrong, or being given the opportunity to change, I feel the contract was broken by you. Please see my attached letter directed to each family. 'DENISE A. JENSEN : IN THE COURT OF COMMON PLEAS OF vs. : CUMBERLAND COUNTY, PENNSYLVANIA KATE BARR a/k/a : NO. 01-2505 CIVIL TERM' KATFILEEN BARR : CIVIL ACTION - LAW You have been sued in Court. if you wish to Le hah demando a. nsted an Ja coho. Si usted defend again:st thc claims SCl forth in thc following . pages, you must take action within tWcnty (20) quiere defendersc de estas de. mandas eXpunstas en la days after paginas siguicntas' nstcd (iunc veint¢ (:20) dias, dc plazo this complaint and notice are sen, ed, by entering a el partir de la fccha de la demanda y la notifiCacion. w~inen appearance personally or by an attorney and Hace faila aSentar una Comparuncia escrita o un perSona filing in writing with thc Coutl your defenses or o con un abogado y unlregar a la eerie en forma cScrila Objections to the claims set forth against you. You are sns defensns o sus objeciones a las demundas cn Contra Warned tha! i.f you fail to do so, without you and · thc case may proceed de sus persona. Sea avisado que si usted no se defiende, a judgement may bc cntarcd against you la coBe Iomara medidns y puede conlinuar by thc Court without further notice for any money Contra suya sin previn avlso o notificacion. Ademas, la la demanda an claimed in the Complaint or for any other claim or relict eerie pucdo dccidar a favor del demandante y requierc requested by the Plaintiff. You may lose money or que nsted eumpla non Iodas las provisionas do esta property or other rights important to you. demanda. Usted puede perder dincro o YOU SHOULD TAKE THIS PAPER TO YOUR u olra~ dcrichos inporlanlns para aslcd, sus propicdades I-~WYER AT ONcr~. IF YOU DO NOT HAVE A LLEVE ESTA DEMANDA A UN ABOGADO lAWYER OR CANNOT AFFORD ONE, GO TO OR NO TIENE fiL DINERO SUFUCIEHTE DE PAOAR Ilvi~dEDIATEblEN*i~ SI NO TIENE ABOGADO O SI TELEPHONE THE OFFICE SET FORTH BELOW TO TAL SERVICIO, VAYA 1~/ PERSONA O LLAJV~ FIND OUT WHERE YOU CAN GET LEGAL, H~LP. .. PeR TELEFONO A lA OFICINA CUYA DIRECCION SE ENCuENTRA EXCRITA ABA JO PARA AVERI(3UAR DONDE SE PUEDE CONSEGUIR A~ISTENCIA LEGAL, Lawyer Referral Service Cumberland County Bat- Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 or 1-800_990.9108 DENISE A. JENSEN : IN THE COURT OF COMMON PLEAS OF vs. ' CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-2505 CIVIL TERM KATE BARR a/k/a KATHLEEN BARR : CIVIL ACTION - LAW COMPLAINT AND NOW this ~ day of May, 2001, comes Denise A. Jensen, and by her attorney, Glenn C. Vaughth Esquire, files the following Complaint pursuant to a Rule issued on April 27, 2001, and served upon her on May 10, 2001: 1. The Plaintiff, Denise A. Jensen, is an adult individual who resides 141 West Louther Street, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant, Kate Barr a/k/a Kathleen Bart, is an adult individual who resides at 227 West Pomfret Street, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff`and the Defendant entered into a contract for board and room under which the Plaintiff's daughter, Sasha Edelman, a 15 year old female child would reside in the home of the Defendant while attending Carlisle Senior High School and the affiliated Central Pennsylvania Youth Ballet program. A true copy of the contract, which began on September 1, 2000, is attached hereto with an Addendum dated August 25, 2000, as Exhibit "A'. 4. Sasha Edelman moved into the home ofthe Defendant on or about September 1, 2000, and began to reside with the Defendant. 5. The contract was terminated by the Plaintiff`on or about November 19, 2000, for numerous valid reasons as itemized in Exhibit "B', attached hereto. 6. The Defendant agreed in Exhibit "B" to refund the $800.00 deposit and $320.00 prorated rent for November, 2000, and to release any further claims or actions against the Plaintift~ all as set forth in Exhibit "B". 7. Exhibit "B" constitutes a valid and binding Settlement Agreement and a novation of the contract. 8. The Defendant has, upon demand by Plaintiff, failed and refused to pay tile $1,120.00 promised to the Plainfiffand owing as a result of the breach of the original contract by the Defendant and the justifiable termination thereof by tile Plaintiff. WHEREFORE, the Plaintiffrequests judgment in her favor and against the Defendant in the amount of $1,120.00 plus interest and costs of suit. Respectfully submitted, Glenn C. Va~gh~squire Attorney for Plaintiff ID No. 07484 22 South Beaver Street York, PA 1740 I (717) 845-9689 I am pleased to be able students to offer two spaces in my home for students of ~he of the Centra/Pennsylvania Youth Ballet. Two fully furnished private rooms are available, one with a double and the other with a three-qu~e~ bed. The students share I 2 baths with my daughter and myself. My location allows students ~ · easy access to the downtown area of Carlisle and is within walking distance of two libraries, the movie theatre, shopping and cultural sites. I am within 8-10 blocks of both the Middle and the High schools. My family consists of Meghan, age 17 and a Senior at Carlisle High School, two dogs: Puma and Russell, and a parakeet named Marquee. My son Matthew does not live with us, but visits regularly. We have moved to Carlisle a little over a year ago. I am busy restoring our yard and adding bits of paint, paper and fixtures to the downstairs of our 100 year old home. Meg and I enjoy reading and movies. We have quite a library of videos. We also camp and are trying to spend more time in our kyaks. Meghan is active in our church, writes poetry and works at a local res/raurant. I sing in our church choir, am an active needlework stitcher and enjoy participating in Canoe Club activities. I have had a great deal of experience working with young people. I am presently a second grade teacher, but have also worked to the middle and high school levels. For the last two years, I provided foster care for the private agency, Mentor. in a previous career, as a Home Economist for Pennsylvania State University, I worked closely with the teens in the 4-H program. I very much enjoy young people. I also have a strong background in nutrition, and experience in creating "special needs" diet patterns. I expect sRIdents in my home to be part of the family. I will try to supply support and guidance for your daughter and to make her feel at home here. CONTRACT FOR BOARD AND ROOM SCHOOL YEAR 20~ TO 20._ This is an agreement between Kathleen Bart and ~er~i6e.~ --.Jer~e/q the parent/s of_ ~e:~i~c~ &de-[mca ~3 to provide a private room, bo~d, t~mponation, and supe~ision for the school ye~, beginning S~tember ~ md ending June~ 20o~ ~OoO - .h~ By sig~ng this agreement, ~e.~ ~ is/are commi~ing :~sdves financi~y to a tort of $8,~ for the above time period. ~ $I~ Fi~t pa~ent upon ~serving ~e ~om, which includes: *$8~ S~tember's ~nr, *$8~ D~osit fbr the lo'owing pu~os~: *fbr da~ge to stm~re, ~mishings, and applimces, caused by the student beyond the no~ "we~ and tear" ofocmpation. P~ents are to be notified when such damage comes to my attention. Receipts for r~air or ~placement w~ be provided md ~ds deduced. The p~ent/s w~ be respomiNe for my md ~ excess costs necess~ to effect repair or r~lacement. *an emergenff rescue for unplanned or ~ergenff e~emes of the student. *Late pa~ent fee. Ple~e see bdow. *The p~ent/s w~ be notified if~nds ~m the d~osit ~e used. Receipts w~ be provided for each e~eme. ~ unused ~nds w~ be ~mrned when the student leav~ ~s h~ehold, a6er an invento~ and impe~ion of the student's room is pe~brmed. lfr~r and/or replacement of items is in process, the b~ance of the unused ~nds w~ be ~mrned within 30 daN. ~MontMy pa~ents of $8~ are due by the tint of each month (u~ess othe~ise a=mged): O~ober, November, December, Janus, Febma~, M~ch, April, May md June. Since I depend on these f}es to hdp pay food, tr~po~uon, semite md ene~ costs, it is necessa~ that they be on time. A 5% f}e of$~ w~ be ch~ed if the money pa~ent is late without a five day no~fication, usury the 25th day of the previous mon~. This w~ be deducted from the d~osit and the p~ent/s notified by phone md ~ceipr. Please note, I am committing a portion of my home and my time and energy toward the support of your daughter for the term of this contract. I expect your commitment of the $8,000 fee for the same rime. ~'y,~,,r ao,,gg__~_~r !::v-~ :~ C~:.:.~ p~:-~._-, yc...:.t, u?,d,~;, for My ~¢~e~, ~ .-:.m2._'_~$~g .~_o..~ L~'.,~,~,~ ~,a k~,~,a _.,:: ~ r~- -t~e-time'shek, nn~3. ........... r~crhe ~hnrd wn,,Icl enr~t myJaeme-as-a-boarde~. .... "-'~ w°~?"~,;k!e _Ce ......... OBLIGATIONS OF KATHLEEN BARR Meals and Nur~/~;onal C~,;A,~ As a trained Home Economist recognizing the nutritional needs cfa teen in a very demanding physical training program, I will endeavor to provide an appropriate meal pattern and diet/'hr your child. This will include consultation, monitoring, adjusting and ' ' ' adv,s~ng. It ~s understood that there may be conflict between the demands of the program for a minimum standard of weight and the needs of the student's body for optimum nutrit/on. If an ad~uate diet pattern is not followed, injuries will. The conflict may also lead to eating disorders. Concerns in this regard will immediately be taken up the student and parents. Healthy, well-balanced meals/snacks will be served with consideration to food likes/dislikes. Ifa meal is not acceptable to the student, she may use leftovers from a previous meal, or make herself an alternative (with my ok) from food in the freezer or pantry. Breakfast will be "make-your-own" from a variety of accessible choices .I expect boarders to be up early enough to eat a reasonable breakfast. Lunches may be carried to school in a thermal container I will provide. These are to be made by the student on the previous n;ght. Alternatively, the student may chose to buy her lunch at school, in which case I will provide $2.00 a day. Dinners will be provided according to the student's schedule. This will be a hot meal available at the dance school to be wanned up, or upon the student's return home after her last class. ~on: The Carlisle Community of schools expect the majority of students to walk. My home is within 8-10 blocks of both Lamberton Middle School and Carlisle High School. Morning lnmsportation can be provided if the student can be independently prompt, as I must also meet a schedule in the morning. of Carlisle High The dance barn und warehouse are with/n walidng distance School and busing is available from I.aimberton Middle School. Transportation will be provided to return home from dance classes. Transportation to and from practices and special evems is provided within the greater CarlisleffHarrisburg areas. This includes transportation to the Harrisburg International Airport or ~o the Harrisburg Train/Bus Station. Transportation outside a :35 mile radius of Carlisle will be ch~gcd al $.2:5 a mile. Day trips to Philadelphia, Baltimore and Washington D.C. and environs arc acceptable. I do not travel to N.Y.C. or to Pittsburgh. Train and bus service is available from Hamsburg for these cities. ~ Students entenng CPYB are embarldng on a sirenuous and taxing stage oftheir lives, not only physically, but academically and rso these new challenges in asu----' ffpOr~lve retail settino ..~. ..... y j o ~o net? the student m Y o. I -.a ~u eet needed and provide a regular family council tim ppor~ and counsel each student as POssible with/n this new life, away fro- ~-- ~- e..to ~elp the student integrate ..... ., member of this family. I respect each student as an individual, and I require from each student a · ,- ,,.t o~ w~lcomed as a complete respect of self, of other students living hem, and of myself and my family. I expect to be in · contact w~th parents on a regular basis, especially in the beginning of the year and to express and concerns to parents .and s.m. ~,,t. E-Mall is available The student may choose to have a private ]~e ~stablished in t · ex,nsc. The downstairs phones are available for use ncr own room at her own with a calling card. ~ee~y; blankets and bedspreads ash ..... : . are Bedsp .r~l, blankets, sheets and towels are provided. Sheets and towels may not be added to walls or doors n ........ ~,~,__ss~.. Nails, screws or omer such bulletin board, laundry hamper and · ~ t~-,-~on ana supervision. A m~rror, and wastebasket are pmwded in each room. There is access to a vacuum, mop and dusting tuols. All trash is to be placed in appropriate receptacles by Thursday night. Laundry facilities are in the basement and include washer, d~yer, ironing board and drying rack or clothes line. The student must provide her own iron and flat-rack drying system. · .S .pace for bicycle storage is available. It is sUongly sugges~l that bikes have a s~,ong lock and it ~s ~mperative that a helmet is worn. STUDENT OBLIGATIONS · The student will respect herself, other girls in the household and Kate. Our dogs, Puma and Russell B. are to be treated kindly. · The student may not drink, smoke, or take other than Prescribed Prescription drugs. · It is the student's resPOnsibility to keep her room in order by vacuuming and dusting Equipment and supplies are provided, weekly. · There are to be no candles, incense, matches or lighters in the student's room. · Guests of the opPOsite sex may be entertained only in the first floor conunon rooms. · Carlisle has a curfew POlicy, requinng When the student is out of the all students under the age of ill to be home by 1 lpm. house other than at dance classes or activities, I expect to know where the student expects to be and the approximate time when she will return. For a student to attend a party or activity at any home, I must be provided with a home address and the phone number of the parents hosting.( I will contact these prior to the party or activity, to be sure there will be active supervision and a no alcohol/drng POlicy in effect.) *The student is expected to pick up after herself in the common areas of the home: returning personal items to her room, placing recyclable items in appropriate containers, returning food containers to the refrigerator and placing used dishes in the appropriate containers. *Wet clothing must not be left on floors or furniture. *Lights and other elec~eal appliances are to be turned offwhen the student is leaving an area. This is especially important when the student is the las~ person to leave the room/house. *The student is to be provided with her own spending allowance and to purchase her own personal supplies, including laundry detergent. *The student will be responsible for her personal laundry. She will be assigned a scheduled personal laundry day after a family council discussion. Non-assigned days will be available on a first-come, first-serve basis. ach evemng the student m responsible to make her own lunch or to notify Kate that she will need money to buy a lunch the following day. *The student is responsible for wakening independently and for leaving the house in a timely manner in the mornings. *The student is responsible for common kitchen tasks: + emptying and cleaning her thermal lunch container and returning the cooler packs to the freezer. + keeping soiled dishes and glasses off the counter-tops and out of the sink area. + refill ice cube trays and water filter pitcher as they are used. + wash and refill a juice pitcher when the last serving has been used. -- (parent/s) agree to abide by the above comract. Date: ~..,Lt ~:x~. Witnessed ~ Date: VERIFICATION I, Denise A. Jensen, hereby verify that all ofthe statements made in the foregoing Complaint are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: FRANCINE BRAXTON WALLACE IN THE COURT OF COMMON PLEAS OF vs. CUMBERLAND COUNTY, PENNSYLVANIA KATE BARR a/k/a · NO. 01-2505 CIVIL TERM KATHLEEN BARR · CIVIL ACTION. LAW 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 aider this complaint and notice are served, by entering a written appearance personally or by an 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 Plainti~ You may lose money or property or other rights important to you. YOU SHOULD HAVE A TAKE THIS PAPER TO YOUR LAWYER AT ONCE· IF YOU DO NOT LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. AVISO Le hah demando a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en la paginas siguientes, usted tiene veinte (20) dias, de plazo el partir de la fecba de la demanda y la,not~ficac~on. Hace faita asentar una comparenc~a 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 sas persona· Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidar a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u ostras derichos inportantes para usted. EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ~'- ~:~w ~o~uL'IENTE DE PAGAR TAL SERVICIO, VAYA ENCUENTRA ESCRITA AB,adO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 or 1-800-990-9108 FRANCINE BRAXTON WALLACE ' IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 01-2505 CIVIL TERM KATE BARR a/k/a KATHLEEN BARR : CIVIL ACTION - LAW COMPLAINT AND NOW this ~ day of May, 2001, comes Francine Bra×ton Wallace, and by her attorney, Glenn C. Vanghn, Esquire, flies the following Complaint pursuant to a Rule issued on April 27, 2001, and served upon her on May 23, 2001: 1. The Plaintiff, Francine Braxton Wallace, is an adult individual who resides at 1100 Lafayette Road, Wayne, Montgomery County, Pennsylvania ! 9087. 2. The Defendant, Kate Ban' affk/a Kathleen Barr, is an adult individual who resides at 227 West Pomfret Street, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff. and the Defendant entered into a contract for board and room under which the Plaintiff's daughter, Ashley Wallace, a 14 year old female child would reside in the home of the Defendant while attending Lamberton Middle School and the affiliated Central Pennsylvania Youth Ballet program. A true copy of the contract, which began on September 1, 2000, is attached hereto as Exhibit "A". 4. Ashley Wallace moved into the home of the Defendant on or about September 1, 2000, and began to reside with the Defendant. 5. The contract was terminated by the Plaintiff'on or about November 19, 2000, for numerous valid reasons as itemized in Exhibit "B", attached hereto. 6. The Defendant agreed in Exhibit "B" to refiind the $800.00 deposit and $320.00 prorated rent for November, 2000, and to release any further claims or actions against the Plaintiff, all as set forth in Exhibit "B". 7. Exhibit "B" constitutes a valid and binding Settlement Agreement and a novation of the contract. 8. The Defendant has, upon demand by Plaintiff, failed and refused to pay the $ I, 120.00 promised to the Plaintiffand owing as a result of the breach of the original contract by the Defendant and the justifiable termination thereof by the Plaintiff. WHEREFORE, the Plaintiffrequests judgment in her favor and against the Defendant in the amount of $I, 120.00 plus interest and costs of suit. Respectfully submitted, · G/'~6n C. V~,l~uire Attorney for Pl~i~iff ID No. 07484 22 South Beaver Street York, PA 17401 (717) 845-9689 CONTRACT FOR BOARD AND ROOM SCHOOL YEAR 20 TO 20_. This is an agreement between Kathleen Barr and ~/'/)~ O~a 30~1 ~_~/~£~. the parenc/s of ~,~ ] fl~ to provide a private room, board, transpo~ation, and supe~ision fbr the school year, beginning September ~ md ending June~ 20~ By signing this agreement,~,l ~ flB~ J0hfl ~/a/a~ commi~ing the~elves finmci~y to a total of$8,~ fbr the above time period. * $I~ Fimt pa~ent upon rese~ing the room, which includes: *$8~ S ' ~tember s rent, *$8~ Deposit ~br the fo~owing pu~oses: *for damage to st~, ~mishings, and appliances, caused by the student b~ond the no~ "wear and tear" of occupation. P~nts are to be no~ed when such damage comes to my attention. Receipts for ~pair or replacement w~ be p~vided and ~nds deducted. The parent/s wi~ be respomible for any md ~ excess costa necess~ to effect repair or r~lacement. *m emergen~ rese~e for unplanned or ~ergenq, e~emes of the student. *Late pa~ent fee. Plebe see bdow. *The parent/s w~ be notified if ~nds from the deposit ~e used. Receipu w~ be provided for each e~eme. ~ unmed ~nds w~ be returned when the student leav~ t~s household, a~er m invento~ and inspe~ion of the student's room is performed. If repair and/or replacement ofiten~ is in process, the b~ance of the unused ~nds ~ be returned within 30 da~. *Mont~y pa~enm of$8~ a~ due by the fi~t of each month (u~ess othe~ise a~ang~): O~ober, November, December, Jmua~, Febma~, March, Apr', May md June. Since I depend on these t~es to hdp pay food, ~mpo~ation, se~ice and enemy costs, it is necessa~ that they be on time. A S% f~e of $40 w~ be ch~ed if the money pa~ent is l~e with~t a five day notification, usury the 2Sth day of the pr~i~s month. This w~ be deducted from the deposit and the parent/s noticed hy phone an~ receipt. EXFIBIT "A" Please note, ! am committing a portion of my home and my time and energy toward the support of your daughter l-bt the term of this contract. I expect your commitment of the $8,000 fee for the same time. If your daughter leaves the Central Penna. Youth Ballet Ilar any reason, all remaining months' room and board must be paid at the time she leaves. A refund is possible only if another student of the school would enter my home as a boarder. The refund would be/:iar the time period that new student would be living at ~:ly, residence. ]If the balance is not paid at the time your daughter might prematurely leave, -~would also be responsible friar any court/lawyer expenses necessary friar Kathleen Burr to recover the remaining balance. OBLIGATIONS OF KATHLEEN BARR Meals and Nutritional Guidance: As a trained Home Economist recognizing the nutritional needs of a teen in a very demanding physical training program, I will endeavor to provide an appropriate meal pattern and diet friar your child. This will include consultation, monitoring, adjusting and advising. It is understood that there may be conflict between the demands of the program for a minimum standard of weight and the need.~ of the student's, body ./br optimum nutritiol~ If an adequate diet pattern is not followed, injuries will. The conflict may also lead to eating disorders. Concerns in this regard will immediately be taken up the student and parents. Healthy, well-balanced meals/snacks will be served with consideration to food likes/dislikes. Ifa meal is not acceptable to the student, she may use lettovers fi.om a previous meal, or make herself an alternative (with my ok) from food in the freezer or pantry. Breakfast will be "make-your-own" from a variety of accessible choices .I expect boarders to be up early enough to eat a reasonable breakfast. Lunches may be carried to school in a thermal container 1 will provide. These are to be made by the student on the previous night. Alternatively, the student may chose to buy her lunch at school, in which case I will provide $2.00 a day. Dinners will be provided according to the student's schedule. This will be a hot meal available at the dance school to be wanned up, or upon the student's return home after her last class. ~ The Carlisle Community of schools expect the majority of students to walk. My home is within 8-10 blocks of both Lamberton Middle School and Carlisle High School. Morning u'ansportation can be provided if the student can be independently prompt, as I must also meet a schedule in the morning. The dance barn and warehouse are within walking distance of Carlisle High School and busing is available fi.om Lamberton Middle School. Transportation will be provided to ~turn home from dance classes. Transportation to and fi.om practices and special events is provided within the greater Carlisle/Harrisburg areas. This includes transportation to the Harrisburg International Airport or Fo the Harrisburg Train/Bus Station. Transportation outside a 35 mile radius of Carlisle will be charged at $.25 a mile. Day trips to Philadelphia, Baltimore and Washington D.C. and environs are acceptable. 1 do not travel to N.Y.C. or to Pittsburgh. Train and bus service is available from Harrisburg for these cities. Communication: Students entering CPYB are embarking on a strenuous and tuxing stage of their lives, not only physically, but academically and personally. It is my job to help the student meet these new challenges in a supportive family setting. I will support and counsel each student as needed and provide a regular family council time to help the student integrate as easily as possible within this new life, away from her family. Your child will be welcomed as a complete member of this family. I respect each student as an individual, and I require from each student a respect of self, of other students living here, and of myself and my family. I expect to be in contact with parents on a regular basis, especially in the beginning of the year and to express and concerns to parents and student. E-Mail is available. The student may choose to have a private line established in her own room at her own expense. The downstairs phones are available for use with a calling card. ~ Bedspread, blankets, sheets and towels are provided. Sheets and towels are laundered weekly; blankets and bedspreads as necessary. Nails, screws or other such fixtures may not be added to walls or doors, nor moved without my permission and supervision. A bulletin board, laundry hamper and mirror, and wastebasket are provided in each room. There is access to a vacuum, mop and dusting tools. All flash is to be placed in appropriate receptacles by Thursday night. Launchy facilities are in the basement and include washer, dryer, ironing board and drying rock or clothes line. The student must provide her own iron and flat-rack drying system. Space for bicycle storage is available. It is strongly suggested that bikes have a strong lock and it is imperative that a helmet is worn. STUDENT OBLIGATIONS *The student will respect herself, other gifts in the household and Kate. Our dogs, Puma and Russell B. are to be treated kindly. *The student may not drink, smoke, or take other than prescribed prescription drugs. *It is the student's responsibility to keep her room in order by vacuuming and dusting weekly. Equipment and supplies am provided. *Them are to be no candles, incense, matches or lighters in the student's room. *Guests of the opposite sex may be entertained only in the first floor common rooms. *Carlisle has a curfew policy, requiring all students under the age of 18 to be home by I lpm. Wben the student is out of the house other than at dance classes or aetivities, I expect to know where the student expects to be and the approximate time when she will return. For a student to attend a party or activity at any home, I must he provided with a home address and the phone number of the parents hosting.( I will contact these prior to the party or activity, to be sure there will be active supervision and a no alcohol/drug policy in effeot.) *Thc student is expected to pick up after herself in the common areas of the home: returning personal items to her room, placing recyclable items in appropriate containers, returning food containers to the refrigerator and placing used dishes in the appropriate containers. *Wet clothing must not be left on floors or furniture. *Lights and other electrical appliances are to be turned off when thc student is leaving an area. This is especially important when the student is the last person to leave the room/housc. *The student is to he provided with her own spending allowance and to purchase her own personal supplies, including laundry detergent. *The student will he responsible for her personal laundry. She will be assigned a scheduled personal laundry day after a family council discussion. Non-assigned days will be available on a first-come, first-serve basis. ach evening the student ~s responsible to make her own lunch or to notify Kate that she will need money to buy a lunch the following day. *The student is responsible for wakening independently and for leaving the house in a timely manner in the mornings. *The student is responsible for common kitchen tasks: + emptying and cleaning her thermal lunch container and returning thc cooler packs to the freczer. + keeping soiled dishes and glasses offthe counter-tops and out of the sink area. + refill ice cube trays and water filter pitcher as they are used. + wash and refill a juice pitcher when the last serving has been used. KathleenBarr, J~hl~..c,~ (student)and ~l~o~ ~t~ ] o-C..P-_ (parent/s) agree to abide by the above contract. Signed'.'~/~'~'c') C'~)~L..~' Date: ~Z~. Witnessed Date: 19'lt~O,,q, II/A,/ao VERIFICATION I, Francine Braxton Wallace, hereby verify that all of the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Francine Braxton Wallace ' DENISE A. ,rENSEN : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 01-2505 CIVIL TERM KATE BARR a/Ida KATHLEEN BARR : CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Tina Strausbaugh, secretary to Glenn C. Vaughn, Esquire, do hereby eertit~ that on the 25th day of May, 2001, I mailed a copy of the Complaint via certified mail, addressed as follows: Ms. Kathleen Bart 227 Pomfi'et Street Carlisle, PA 17013 Tina Strausbaugh, Secretary /\ Glenn C. Vaughn, Esquire L) 22 South Beaver Street York, Pennsylvania 17401 (717) 845-9689 FRANCINE BRAXTON WALLACE : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 01-2505 CIVIL TERM KATE BARR a/PYa KATHLEEN BARR : CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Tina Strausbaugh, secretary to Glenn C. Vaughn, Esquire, do hereby certify that on the 8th day of]uric, 2001, I mailed a copy of the Complaint via certified mail, addressed as tbllows: Ms. Kathleen Barr 227 Pomfret Street Carlisle, PA 17013 ~{'n~ Strausbaugh, S~cret~[~j Glenn C. Vaughn, Esquir~ 22 South Beaver Street York, Pennsylvania 17401 (717) 845-9689 DENISE A. JENSEN : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 01-2505 CIVIL TERM KATE BARR a/Ida KATI-ILEEN BARR : CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Tina Strausbaugh, secretary to Glenn C. Vaughn, Esquire, do hereby certit~ that on the 20th day of June, 2001, I mailed a copy of the Complaint via regular mail, addressed as follows: Ms. Kathleen Barr 227 Pomfi'et Street Carlisle, PA 17013 She refused to claim it by certified mail after notices on May 29, June 4 and June 13, 2001. Tina Strausbaugh, Secretary /\ Glenn C. Vaughn, Esquire 22 South Beaver Street York, Pennsylvania 17401 (717) 845-9689 FRANCINE BRAXTON WALLACE : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 01-2505 CIVIL TERM KATE BARR a/k/a KATHLEEN BARR : CIVIL ACTION - LAW PRAECIPE FOR JUDGMENT Enter judgment in favor of Plaintiff and against Defendant, Kate Barr a/k/a Kathleen Bart, for want of $1,120.00, plus eight months' interest to July 19, 2001, at the legal rate, for a total of $1,164.80. (X) Assess damages as follows: Debt $1,120.G0 Interest from $ 44.80 TOTAL $1,164.80 (X) I ~ that th~ foregoing ass~sment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. (X) Pursuant to Pa.R.C.P. 237 (Notice of praecipe for final judgmaat or decree), I certif3' that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attom~., of Record. (X) Pursuant to Pa.R.C.P. 237.1, I certifx., that written notice ofthe intention to file this praecipe was mailed or delivc~d to the perry against whom judgment is to be entered and to his/her Attorney of Record, if any. after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. DATE: ' for Plal'ntiffs Attome~ 22 South Beaver Street, York, PA 17401 (717) 845-9689 Supreme Court ID No. 07484 ~t.gg2 _~ , 2001, JUDGMENT IS ENTERED AS ABOVE. NOW, Prothonotary/Clerk, C~vil l~on FRANCrN-E BRAXTON WALLACE I'N TH3E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2505 CIVIL TERM KATE BARR aJk/a KA TI-ILEEN BARR CIViL ACTION- LAW To' Mrs. Kate Bart 227 Pomfret Street Cartisle, PA 17019 Date of Notice: July 10, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM ~ DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER fi~PORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Lawyer Referral Service of the York County Bar Association 137 East Market Street York, Pennsylvania 17401 (717) 854-8755 ~'~GI/~ C. Vau~,~uire 22 South Beaver gtreet York, Pennsylvania 17401 (717) 845-9689 cc: Francine B. Wallace FRANCINE BRAXTON WALLACE : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO, 01-2505 CIVIL TERM KATE BARR a/k/a KATHLEEN BARR : CIVIL ACTION - LAW NOTICE OF FILING JUDGMENT (x) Notice is given that a Judgment in the above captioned matter has been entered against you in the amount of $1,120.00, plus eight months' interest to July 19, 2001, at the legal rate, for a total of $1,164.80 on ~ ,2001. (x) A copy of all documents filed with the Prothonotary in support of the within judgment are enclosed. If you have any questions concerning the above case, please contact: NAME: Glenn C. Vaughn. Esquire ADDRESS: 22 South Beaver Street York, PA 1740 l TELEPHONE NUMBER: (717) 845-9689 (This Notice is given in accordance with Pa.R.C.P. 236.) Notice sent to: Ms. Kate Barr 227 Pomfret Street Carlisle, PA 17019 DENISE A. JENSEN : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 01-2505 CIVIL TERM KATE BARR a/k/a KATFILEEN BARR : CIVIL ACTION - LAW PRAECIPE FOR JUDGMENT Entcrjedgment in favor of Plaintiff and against Defendant, Kate Ban' a/Ua Kathlcen Ban', for want of $1,120.00, plus eight months' interest to July 19. 2001. at the legal rate. for a total of $1,164.80. (X) Assess damages as follows: Debt $1,120.00 Interest from $ 44.80 TOTAL $1,164.80 (X) I certify that the foregoing assessment of damages is for specified amounts alleged to be duc in the complaint and is calculable as a sum certain from the complaint. (X) Pursuant to Pa.R.C.P. 237 (Notice ofpraecipe for final judgment or decree), ! certify that a copy of this praecipe has bcen mailed to each other party, who has appeared in the action or to his/her Attom~' of Record. (X) Pursuant to Pa.R.CP. 237.1, I certi~, that x~Titten notice of the intention to file this praecipe was mailed or delivered to the par~., against whom judgment is to be entered and to his/her Attom~' of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praceipe and a copy of the notice is attached. Glenn C. %u Attorne.v for Plain6ffs 22 South Beaver Street, York, PA 17401 (717) 845-9689 Supreme Court ID No. 07484 NOW, ~.~~, 2001, JUDGMENT IS ENTERED AS ABOVE. DENISE A..[ENSEN : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ~ : NO. 01-2505 CIVIL TERM KATE BARR a/k/a KATHLEEN BAKR : CIVIL ACTION - LAW To: Ms. Kate Bart 227 Pomfrei Street Carlisle, PA 17013 Date of Notice: July 19, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Lawyer Referral Service of the York Coumy Bar Association 137 East Market Street York, Pennsylvania 17401 (,717) 854-8755 22 South Beaver Street York, Pennsylvania 17401 (717) 845-9689 cc: Denise A. Jensen PRAECIPE FOR WRIT OF EXECUTION {MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 D~qIS~ A. ~ ........................................... IN THE COURT OF COMMON PLEAS OF ~tR]( COUNTY, PENNSYLVANIA 01-2505 - VS. Judgment No ......... ~erm 19 ..... KA~ ~ a/k~a PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER. ~ ........ County, Penna.; (I). Directed to the Sheriff of ............... a/k/a Kathleen Barr ." Kate ~vr ............................................. (2) against ......... ;; ............................ ............................................................................. Defendant(s); Bank o.~ ~...s~.. ................................................. Garnishee(s); (3) and against ............ (4) and index this writ .r,3..t.e' ~_~r a/k/a ......................................................... (a) against ....................... ...................................................................... Defendant(s) and Bank of Landis~urg .................................. (b) against ................................................... 5125 SpcFi.ng Road, Sh~'le, .P.~. 1.79.9.0. ...................... Garnishee(s), as a lis pendens against the real property of the Defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property)* a~l bank accounts , $ 1,164.80 (5) Amount due .................... Interest from .................... 1,164.80 -' t Total ............ rtus cos s. NOTE WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-2505 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF PERRY cOUNTY: To satisfy the debt. interest and costs due DENISE A. JENSEN, Plaintiff (s) From KATE BARR AIK/A KATHLEEN BARR, 227 W. POMFRET ST., CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell . (2) You are also directed to attach the properly of the defendant's) not levied upon in the p°ssessi°n of BANK OF LANDISBURG, 5125 SPRING ROAD, SHERMANSDALE, PA 17090 - ALL BANK ACCOUNTS GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an at~achraent 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 propefi'y of the defendant (s) or otherwise disposing thereof; . (3) if property of the de fendant(s) not levied upon an subject to attachment is found in the p°ssessl°n 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 $1,164.80 L.L $.50 Interest At~'s Comro % Due Prothy $1.00 Arty Paid $81.25 Other Costs Plaintiff Paid Date: MAY 20, 2002 CURTIS R. LONG prothonotaoj, Civil Division REQUESTING PARTY: Name GLENN C. VAUGHN, ESQUIRE Address: 22 SOUTH BEAVER STREET YORK, PA 17401 Attorney for: PLAINTIFF Telephone: 717-845-9689 Supreme Court ID No. 7484 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DENISE A. JENSEN : NO. 01-2505 CIVIL TERM VS. KATE BARR a/k/a KATHLEEN BARR CIVIL ACTION - LAW FRANCINE BRAXTON WALLACE NO. 01-2505 CIVIL TERM VS. KATE BARR a/k/a KATHLEEN BARR CIVIL ACTION - LAW NOTICE OF FILING JUDGMENT (x) Notice is given that a Judgment in the above captioned mq~r has been entered against Garnishee, Bank of Landisburg, in the amount of 5; 2.328.60 on ,~ ~ IX ,2002, upon the admissions of the Garnishee in answers to Interrogatories. ~- ' -- (x) A copy of ail documents filed with the Prothonotary in support of the witl~judgment Prothonotary Civil Div. (~ If you have any questions concerning the above case, please contact: NAME: Glenn C. Vaughn. Esa_uim ADDRESS: 22 South Beaver Street York. PA 17401 TELEPHONE NUMBER: (717~ 845-9689 {This Notice is given in accordance with Pa.R.C.P. 236.) Notice sent to: Bank of Landisburg 5125 Spring Road Shermansdale, PA 17090 DENISE A. JENSEN : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 01-2505 CIVIL TERM KATE BARR a/k/a : KATHLEEN BARR : CIVIL ACTION-LAW FRANCINE BRAXTON WALLACE : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 01-2505 CIVIL TERM KATE BAILR a/k/a : KATHLEEN BARR : CIVIL ACTION-LAW PRAECIPE FOR ENTRY OF JUDGMENT UPON ADMISSIONS OF OARNISH~.E Please enter judgment in favor of Plaintiff, Denise A. Jensen and against the Garnishee, Bank of Landisburg, for the amount of$1164.80 plus costs of Court and enter judgment in favor of Fran¢ine Braxton Wallace and against the Oamishee, Bank of Landisburg, for the amount of $1164.80 plus costs of Court.&,;,, ',,~,...' ' ~;~._: ....='-: c.f _ _e,¥s~ ~ _,.._ ..~o;o ,A'C~; ' Judgment entered in favor of the Plaintiffs individually in the amount of$1164.80 ---~' ~ ' ' ' .......... : ~,2'"? ~3 I f C gai Bank f Landi b ......... - -~-..,- j---,~ ......... ~, US costs 0 ourt a nst o S Ilrg, Oamishee. DATE:. DENISE A. JENSEN : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : YS. : NO. 01-2505 CIVIL TERM KATE BARR a/k/a : KATHLEEN BARR : CIVIL ACTION - LAW FRANCINE BRAXTON WALLACE : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : VS. : NO. 01-2505 CIVIL TERM KATE BARR a/k/a : KATHLEEN BARR : CIVIL ACTION - LAW INTERROGATORIES TO GARNISHEE To: Bank of Landisburg (Garnishee) You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you: 1. At the time you were served or at any subsequent time did you owe the Defendant ~_~ money or were you liable to her, on any negotiable or other written instrument, or did she cl~ that you owed her any money or were liable to her for any reason? ~i'.".:Z Answer: ~o ~ C~ 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in par~ by the Defendant? Answer: ~0 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the Defendant or in which Defendant held or claimed any interest? Answer: 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the Defendant had an interest? Answer: ~s 5. At any time before or after you were served did the Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefor Answer: 6. At any time after you were served did you pay, transfer or deliver any money or property to the Defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the Defendant against you? Answer: ~o 7. State the name of the owner or authorized signators of any accounts which you have in the name of Defendant, the number of each such account, and the amount in such account at the time of service of these interrogatories and at the time of answering of these interrogatories. · ,,A'rH~.'m~l' L. ~ 3605345 $ 326.61 as of 7/23/02 Answer: ~'rtm~ L.B.~RR 366922331 $5,776.13 as of 7/23/02 GLENN C. VAUGHN Attorne~ for Pf. gidtif~g' -- ID No. 07484 FrancJne Braxton Wallace ! IN THE COURT OF COMMON PLEAS OF I THE 41st JUDICIAL DISTRICT OF PENNSYLVANIA, i PERRY COUNTY BRANCH Versus Kate Barr a/ka/Kath/een Ban- I Ne. Garnishee Bank of Landisburg SHERIFF'S RETURN And now July 19,2002: Served the within name The Bank of Landisburg the defendant(s) named herin, personally at herplace of residence in Landisburg Borough Perry County, PA, on July 19, 2002 at 8:30 o'clock AM by handing to Tom Cook, Executive, an adult member of family, 1 true and attested Vice President copy(les) of the within Writ of Execution, Interogatorries and made known to him the contents thereof ' Sworn and subscribed to before me Jay of_ .,.~-~ I~/ , ~ So answers I NO'~I~-- I Deput:y Sheriff of Perry County BLO(~AFIELD BORO., FE~Y COUNTY M~COMMISSION ~XPIRBI~L'B. ~6. 2004 Denise Jensen IN THE COURT OF COMMON PLEAS OF THE 41et JUDICIAL DISTRICT OF PENNSYLVANIA, PERRY COUNTY BRANCH Ver~u~ Kate Barr a/ka/Kathleen Barr Garnishee Bank of Landisburg No. ~ And now July 19,2002: Served the within name The Bank of Landisburg the defendant(s) named herin, personally at herplace of residence in Landisburg Borough Perry County, PA, on July 19, 2002 at 8:30 o'clock AM by handing to Tom Cook, Executive, an adult member of family, 1 true and attested Vice President copy(les) of the within Writ of Execution, Interogatorries and made known to him the contents thereof Sworn and subscribed to before me this ,~,/~f ~ I So answers day of .53-0. [¥ , ? ~0 3- I I IIIIIl~,~B'l:..l:t~%.flrf~llUC 1 i Deputy Shedff of Perry County I ~fffCO~l~ON EX~RE~ F~B. !6.2004 J