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HomeMy WebLinkAbout11-5640COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS 9TH Judicial District, County Of CUMBERLAND NOTICE OF APPEAL FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT COMMON PLEAS No. ?? (o yiJ -K- / 1 l eax NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District Judge on the date and in the case referenced below. Richard E. Gregory, Jr., Kayce R. Campbell Honorable Susan K. Day w id I T 5 I A I t LIP GDDE 25 Fairfield Street Carlisle PA 17015 DATE OF JUDGMENT IN THE CASE OF (Plaintiff) (Defendant)' 06/13111 Robin Toner V5 Richard E. Gregory, Jr., Kayce R. Campbell DOCKET No. SIGNATTE OF APPELLANT OR ATTORNEY OR AGENT CV-0000038-2011 ) //n This block will be signed ONLY when this notation is required under Pa. If appellant was Claimant (s R. C. D. No. 1001(6) in action R.C.P.D.J. No. 100813. This Notice of Appeal, when received by the Magisterial District Judge, will before a Magisterial District Judge, A COMPLAINT MUST BE FILED operate as a SUPERSEDEAS to the judgment for possession in this case. within twenty (20) days after filing the NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before Magisterial District Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon Robin Toner appellee(s), to file a complaint in this appeal Name of appellee(s) (Common Pleas No. / (0 q6 611: ) within twenty (20) days service of rule or suffer entry of judgment of non pros. agent RULE: To Robin Toner Name of appellee(s) , appellee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY 13E ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. /I h Q / a- e ( l Date /3 20 // 6 Signature of Pr tho taryor Deputy YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-05 FILED-OFFICE OF THE PROTHONOTARY 2011 JUL 13 PM 4: 19 OO PYLVAFOtI T 9l . 7 5'?d 'a rl c 4H 3 11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND q Mag. Dist. No: MDJ-09-3-03 MDJ Name: Honorable Susan K. Day Address: 229 Mill Street P.O. Box 167 Mount Holly Springs, PA 17065 Telephone: 717-486-7672 Kara W. Haggerty, Esq. Abom & Kutulakis Up 2WHigh St Carlisle. PA 17013-2922 Disposition Summary Docket No MJ-09303-CV-0000038-2011 MJ-09303-CV-0000038-2011 Judgment Summary Participant Kayce R. Campbell Richard E Gregory, Jr. Notice of Judgment/Transcript Civil Case Robin Toner V. Richard E Gregory, Jr., Kayce R. Campbell Plaintiff Defendant Robin Toner Richard E Gregory, Jr. Robin Toner Kayce R. Campbell Joint/Several Liability Individual Liability $7,639.98 $0.00 $7,639.98 $0.00 Judgment Detail ("Post Judgment) Plaintiff and judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $7,423.23 $0.00 $7,423.23 Filing Fees $171.00 $0.00 $171.00 Server Fees $45.75 $0.00 $45.75 Docket No: MJ-09303-CV-00000388011 Case Filed: 2/15/2011 n o -1 C _. --I = M C -- ° r r rn Ca -o '85 41 T, (-) 3 =C) Disposition Di; bsitutdn Date Default Judgment for Plaintiff 06/13/2011 Default Judgment for Plaintiff 06113/2011 Amount $7,639.98 $7,639.98 In the matter of Robin Toner vs. Richard E Gregory, Jr.; Kayce R. Campbell on 6/13/2011 the disposition is Default Judgment for Grand Total: $7,639.98 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 COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT O-ErtFER-T+*, -6F-E61MM0N t ER3; -ALL *TME--- COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE'JUDGMENT MAY FILE A` REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. Date Magisterial District Judge Susan K. `Day " I certify that this is a true and correct copy of the record of the proceedings containing the judgment. Date Magisterial District Judge Susan K. Day MDJS 315 Page 1 of 1 Printed: 06/14/2011 10:10:14AM 11! ;7 n n CUMBERLAND COUNTY PENNSYLVANIA FILED"OFF ICL O THE PROTHONO TAR 2011 JUL 22 PM 3: b 3 CUMBERLAND COON lY PENNSYLVANIA PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.) COMMONWEALTH ,9F PENNSYLVANIA COUNTY OF l.- a M?e?/ /,(, od'. ; ss AFFIDAVIT: I hereby (swear) (affirm) that I served -5040 ?a copy of the Notic of Appeal, Common Pleas No. 11 upon the Magisterial District Judge designated therein on (date of service) 7lam-, 20 ? by personal service 9--by (certified) (registered) mail, 7se der's receipt attached hereto, and upon the appellee, (name) M I,(orhae l 14.._X hear, LS? ulrL , 20 ? by personal service? (certified) (registered) mail, sender's receipt attached hereto. (S ? SAFFIRMED) AND SUBSCRIBED BEFORE ME S '??? DAY OFC, 2011 gnature of official befo a whom affidavit was made COMMONWEALTH OF PENNSYLVANIA b L Signature of affiant Notarial Saal Shannon L. Freeman, Notary Public Cackle Boro. CuffftrWW County MY Commiaaion Expilift AprN 7, 2013 Member, Pennsylvania Associallon of Notaries itle of officiol My commission expires on +720/3 AOPC 312A - 05 ¦ Complete Items 1, 2, and 3. Also complete item 4 if Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: M? 0 /3aoc r`iQknf ?I?? `SP0Y-5 5, Agent ? Addre Name) C.-Pate of Deli Is ds1lVWy address different from item 1? ? Yes If YES, enter delivery address below: -W No ,ppe 3. ,S,.ervice uwcertifled Mail ? Expre?s?Vlafl P C3 Reg(steredLJ,Ke-turn Receipt for Merchandise ? insured mail ? C.O.D. J 4. Restricted Delivery ? (Extra Fee) ? Yes 2. Article Number 7008 3230 0002 8005 4954 (Yn3na w from service lab PS Form 3811, February 2W4 Domestic Return Receipt 102595-02-M-15p:. • Complete items 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the maiipiece; or on the front If space permits. 1. Article Addressed to: ScOA? tct Cl:? P R l 7 0} 3 A. X Name) Is delivery address different from item 1 If YES, enter delivery address below: 4. Restricted Delivery? (Extra Free) ? Yes 3. Service Type ;KCerVW Mail ? Express Mail ? Registered ? Return Receipt for Memhwx iae ? Insured mail ? C.O.D. 2. Article Number (rr&wwfmmsantaskbe!) 7010 3090 0003 2132 3550 PS Form 3811, February 2W4 Domestic Return Receipt 102596-o2-101-1540 ROBIN TONER Plaintiff V. RICHARD E. GREGORY, JR. 25 Fairfield Street Carlisle, Pennsylvania 17013 KAYCE R. CAMPBELL 25 Fairfield Street Carlisle, Pennsylvania 17013 Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2011- 5640 CIVIL ACTION-LAW CIVIL TERM c cx? ?rn C-1 - ?- rn_ en aa CO c3 Z) ` _ y-L, Co $, _J 1) NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by 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 plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service (ARIS) 155 South Ninth Street Easton, Pennsylvania 18042 Telephone: (610) 258-6333 r It ROBIN TONER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2011- 5640 CIVIL ACTION-LAW COMPLAINT CIVIL TERM NOW, comes Plaintiff, Robin Toner ("Toner"), by and through her attorneys, BARIC V. RICHARD E. GREGORY, JR. 25 Fairfield Street Carlisle, Pennsylvania 17013 KAYCE R. CAMPBELL 25 Fairfield Street Carlisle, Pennsylvania 17013 Defendants SCHERER LLC, and files the within Complaint and, in support thereof, sets forth the following: 1. Plaintiff, Robin Toner, is an adult individual with a residence address of 6962 Sherman Street, Milton, Florida 32570. 2. Defendant, Richard E. Gregory, Jr. ("Gregory"), is an adult individual with a residence address of 25 Fairfield Street, Carlisle, Pennsylvania 17013. 3. Defendant, Kayce R. Campbell ("Campbell"), is adult individual with a residence address of 25 Fairfield Street, Carlisle, Pennsylvania 17013. 4. Toner is the owner of a certain rental residential real estate property known as 408 Zion Road, Carlisle, Pennsylvania ("leased premises") 17013. 5. On or about December 22, 2008, the parties entered into a Pennsylvania Residential Lease Agreement ("Lease Agreement"). A true and correct copy of the Lease Agreement is attached hereto as Exhibit "A" and is incorporated by reference. 6. The term of the Lease Agreement was December 24, 2008 through December 31, 2010. 7. The Lease Agreement set rent at $1150.00 per month during the second year of the lease. 8. The Lease Agreement provides for a late charge in the amount of $75.00 for rent more than 5 full days late. 9. The Lease Agreement provides that Gregory and Campbell are to pay for water, sewer, electric, trash, lawn and shrubbery care. 10. The Lease Agreement provides that Gregory and Campbell are to fill oil tank to same level upon vacation of the property. 11. The Lease Agreement provides that all payments due from Gregory and Campbell to Toner are considered to be Additional Rent. 12. The Lease Agreement provides that Gregory and Campbell are to pay repairs under $50.00 per repair. 13. The Lease Agreement provides that Gregory and Campbell may end the lease and move out before the End Date of the Lease only with written permission of Toner, and only if Gregory and Campbell continue to pay all rent until the End Date of the Lease, or until a new tenant is approved by Toner and a new lease takes effect, whichever happens first. 14. On or about February, 2010, Gregory gave verbal notice that Gregory and Campbell intended to vacate the property by the end of May 2010. 15. In March of 2010, Toner contacted a realtor to list the lease premises for rent. 16. On or about April 26, 2010, Toner advised Gregory and Campbell of their payment obligations in writing. A true and correct copy of the letter is attached hereto as Exhibit "B" and is incorporated by reference. 17. On or about May 31, 2010 Gregory and Campbell vacated the leased premises. 18. Toner has received no rent from Gregory and Campbell since May, 2010. 19. The Lease Agreement provides that Toner may deduct repair costs and any unpaid rents from the security deposit. 20. On or about November 16, 2010, Toner notified Gregory and Campbell that the leased premises had been rented as of November 1, 2010 and provided an itemized statement of the amounts due under the Lease Agreement totaling $7,923.23 minus the security deposit of $1,000.00. A true and correct copy of the letter is attached hereto as Exhibit "C" and is incorporated by reference. 21. The Lease Agreement provides for the recovery by Toner of legal fees and reasonable costs. 22. To the date hereof, Toner has incurred costs of $216.75. 23. To the date hereof, Toner has incurred legal fees of $848.75. BREACH OF CONTRACT TONER v. GREGORY and CAMPBELL 24. Plaintiff incorporates by reference paragraphs one through twenty-three as though set forth at length. 23. Defendants have breached their obligation to pay rent, late charges, water charges, electric charges, lawn and shrubbery care, cleaning and repairs for the leased premises to Toner. 24. Defendants have breached their obligation to pay legal fees and costs of Toner. 25. As a direct and proximate result of these breaches, Toner has not been paid rent, late charges, water charges, electric charges, lawn and shrubbery care, cleaning and repairs for the lease premises properly due from the Defendants. WHEREFORE, Plaintiff requests judgment in her favor and against Defendants for the sum of $7,988.73, plus costs and attorney fees incurred by Plaintiff to the date of award. Respectfully submitted, 4aRIC CHERER C D. Naylo , Esq I. D. # 83760 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 VERIFICATION The statements in the foregoing Complaint are based upon information which has been assembled by my attorney in this litigation. The language of the statements is not my own. I have read the statements; and to the extent that they are based upon information which I have given to my counsel, they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsifications to authorities. DATE: I Qt?n ' M-'C'? L) Robin Toner r ? ROBIN TONER Plaintiff V. RICHARD E. GREGORY, JR. 25 Fairfield Street Carlisle, Pennsylvania 17013 KAYCE R. CAMPBELL 25 Fairfield Street Carlisle, Pennsylvania 17013 Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2011- 5640 CIVIL TERM CIVIL ACTION-LAW CERTIFICATE OF SERVICE I hereby certify that on July 28, 2011, I, Tricia D. Naylor, Esquire, of Baric Scherer LLC, did serve a copy of the Complaint, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Kara W. Haggerty, Esquire Abom & Kutulakis, L.L.P. 2 West High Street Carlisle, Pennsylvania 17013 Iricia D. Na" re i a [,I r OM I? ULAKIs I AUG 17 PM Kara W. Haggerty, Esquire Attomey I.D. #: 86914 z' J M B E R L A N D 2 West High Street Carlisle, PA 17013 PEN N SYL=EA It F[s'1 (717) 249-0900 ROBIN TONER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 2011-5640 CIVIL TERM RICHARD E. GREGORY, JR. and KAYCE R. CAMPBELL, CIVIL ACTION - LAW Defendants ANSWER TO COMPLAINT NOW, comes Defendants, Richard E. Gregory, Jr. and Kayce R. Campbell, by and through their attorney, Kara W. Haggerty, Esquire of Abom & Kutulakis, LLP, and files the within the Answer, and in support thereof sets forth the following: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. By way of further answer, the Lease Agreement was not attached to the Complaint provided to the Defendants in this matter. 6. Denied. It is specifically denied as to the term of the Lease Agreement as the Lease Agreement is not attached to the Complaint therefore strict proof thereof is demanded. 7. Denied. It is specifically denied the Lease Agreement set rent at $1,150.00 per month during the second year of the lease and further proof thereof is demanded. Denied. It is specifically denied the Lease Agreement provides for a late charge in the amount of $75.00 for rent more than five full days late, and strict proof thereof is demanded. 9. Admitted in part, denied in part. It is admitted that Gregory and Campbell were to pay for water, sewer, electric, trash, lawn and shrubbery care. It is specifically denied that the Lease Agreement provides for such as the Lease Agreement is not attached to the Complaint. 10. It is specifically denied that the Lease Agreement provides that Gregory and Campbell are to fill the oil tank to the same level upon vacation of the property as the Lease Agreement is not attached to the Complaint. 11. Denied. It is specifically denied that the Lease Agreement provides that all payments due from Gregory and Campbell to Toner are considered to be additional rent and strict proof thereof is demanded. 12. Denied. It is specifically denied that the Lease Agreement provides that Gregory and Campbell are to pay repairs under $50.00 per repair and strict proof thereof is demanded. 13. Admitted in part, denied in part. It is admitted that Gregory and Campbell may end the lease and move out before the end date of the lease with written permission of Toner and if Gregory and Campbell continue to pay rent until the end date of the lease or until a new tenant is approved by Toner and a new lease takes affect, whichever happens first. It is specifically denied that this information is in the Lease Agreement as the Lease Agreement is not attached as an exhibit. 14. Admitted in part, denied in part. It is admitted that Gregory gave verbal notice that Gregory and Campbell intended to vacate the property. It is specifically denied as to the dates alleged as to the notice and the moving date and strict proof thereof is demanded. 15. Denied. It is specifically denied that in March of 2010, Toner contacted a realtor to list the leased premises for rent, and strict proof thereof is demanded. 16. Admitted in part, denied in part. It is admitted that on April 26, 2010, Toner did advise Gregory and Campbell of their payment obligations in writing. It is specifically denied that a true and correct copy of the letter is attached to the Complaint provided to the Defendants. 17. Admitted. 18. Denied. It is specifically denied that Toner has received no rent from Gregory and Campbell since May 2010 and strict proof thereof is demanded. 19. Denied. It is specifically denied that the Lease Agreement provides that Toner may deduct repair costs and .any unpaid rents from the security deposit. By way of further answer, the Lease Agreement is not attached to provide proof of such provision and strict proof thereof is demanded. 20. Admitted in part, denied in part. It is admitted that on or about November 16, 2010, Toner notified Gregory and Campbell that the leased premises had been rented as of November 1, 2010 and provided an itemized statement of amounts alleged to be due. It is specifically denied that the amounts listed in the November 16, 2010 letter are due under the Lease Agreement. It is further denied that a true and correct copy of the letter is attached as Exhibit C to the Complaint provided to Defendants. 21. Denied. It is specifically denied that the Lease Agreement provides for the recovery by Toner of legal fees and reasonable costs. 22. Denied. It is specifically denied that to date hereof, Toner has incurred costs of $216.75, and strict proof thereof is demanded. 23. Denied. It is; specifically denied that to date thereof, Toner has incurred legal fees of $848.75, and strict proof thereof is demanded. BREACH OF CONTRACT TONER V. GREGORY AND CAMPBELL 24. Defendants incorporate by reference paragraphs one through twenty-three as though set forth at length. 25. This paragraph is listed as averment 23 in Plaintiff's Complaint however should be averment 25. Denied. It is specifically denied that Defendants have breached their obligation to pay rent, late charges, water charges, electric charges, lawn and shrubbery care, cleaning and repairs for the leased premises to Toner, and strict proof thereof is demanded. 26. This paragraph is listed as averment 24 in Plaintiff's Complaint however should be averment 26. Denied. It is specifically denied that Defendants have breached their obligation to pay legal fees and costs of Toner, and strict proof thereof is demanded. 27. This paragraph is listed as averment 25 in Plaintiff's Complaint however should be averment 27. Denied. It is specifically denied that as a direct and approximate result of these breaches, Toner has not been paid rent, late charges, water charges, electric charges, lawn and shrubbery care, cleaning and repairs for the leased premises properly due from the Defendants, and strict proof thereof is demanded. WHEREFORE, Defendants request the Complaint be denied and judgment issued in their favor. Respectfully submitted, ABOM & KUTULAKIS, L.L.P. DAB Kara W. Haggerty, Esqui e r Attorney ID No. 8694 `. 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Defendants AND NOW, this 17" day of August, 2011, I, Sally Evans of Abom & Kutulakis, UP, hereby certify that I did serve a true and correct copy of the foregoing Answer to Complaint by depositing, or causing to be deposited, same in the United States Mail, first-class mail, postage prepaid addressed to the following: Tricia D. Naylor, Esquire BARIC SCHERER UC 19 West South Street Carlisle, PA 17013 Attorney for Plain tiff 1 / Sally Evans ROBIN TONER Plaintiff V. RICHARD E. GREGORY, JR. KAYCE R. CAMPBELL Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C , NO. 2011- 5640 CIVIL TERM i ' tf)? Na r apO a CIVIL ACTION-LAW ' c'.> Dc's C)-71 MCI Dc W C)M --4 PRAECIPE TO ATTACH EXHIBITS Please attach and file the within Exhibits to Plaintiff's complaint filed July 28, 2011 in the above captioned matter. Date: * I I Tric D. Naylor, I.D. to. 83760 Baric Scherer LLC 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff CERTIFICATE OF SERVICE I hereby certify that on August 24, 2011, I, Tricia D. Naylor, Esquire, of Baric Scherer LLC, did serve a copy of the Praecipe to Attach Exhibits, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Kara W. Haggerty, Esquire Abom & Kutulakis, L.L.P. 2 West High Street Carlisle, Pennsylvania 17013 RESID EN TII TEASE LR This form Tecommended and approved for, but not restricted to use m the members.of:the Pennsylvania Association of REAITORSr (PAR). I LORD' BUS SS RELAT NS WITH PA LICENSED BROKER T3R?I2" (Company) PHONE_ , ADDRESS, FAX _ LICENSEE(S) DesignateAge t ~? Yes $_ No BROKER IS THE AGENT FOR LANDLORD. OR-Of'cleckei below): Broker is NOT the Agent for Landlord and is Wane ? AGENT FOR TENANT -? TRANSACTION LICENSEE TEN ANT'S $ SINESS RELATIPkSffi MIIT?H PA LICENSED BROKER BROKER (Company) Eh-?t' (lt Ili PHONE S3'. ADDRESS <, -, 1773 j FAX Z? LiCENSEEtat -- Designated Agent? ? Yes o BROKER IS THE AGENT FOR TENANT OR (if checked below): Broker is NOT-the Agent for Tenant and is Wait: ,<AGENT'-'OR LANDLORD ? SUBAGENT-FOR LANDLORD" ? TRANSACTION LICENSEE; ` When thesame tiroker•is Agent-for Landlord and Agentfor Tenant,,Brokel is a'Dual.Agent. All,-of Broker.As Iigensees are. also Dual Agents -UNLESS there. are separate Designated Agents for Landlord and Tenant. If the same Licenseeis designated for Landlord and Tenant,ahe Licensee is a Duat Agent. Brsoker(s) may perform services to assist unrepresented parties in complying-with the-terms .of this Lease. PARTIES 1 1.. This LEASE, dated 1-2-1 2 LANDLORD(S) ,., - - Is between 3 .2 4 TENANT{S) -Q called "Landlord;" rind 3 4 s 611 d"Tenant;' for s 7 the Property located at s r?r'1 it,? j I6 7 called "Property." s 9 Each Tenant is individually responsible for all obligations of this Lease; mcludinig-reli late fees, damages and other hosts. s 10 2. CO-SIGNERS 11 Co-signers k IZ 10 12 11 13, Each Co=si 12 goer is individually responsible for all obligations of this Lease, including rent, late fees, damages and other costs. Co- 13 14 Signers do not have the right to occupy the Property as a Tenant without the Landlord's prior written perniai ion. 14 1s 1 LANDLORD CONTACT INFORMATION:. .15 16 Rental Pa, ments:_ r "C Maintenance R u sts: t lc,I 17 Payable to: Contact: { 1s 18 Address: 17 19 t Address: r 18 .. _ t 20 Phone 19 Phone #: !-1 a f 20 21 Fax #: Fax #: 17, 21 RENTAL TERM 22 4. START AND END DATES'-0F LEASE (also called "Term") 23 (A) Start Date: 23 1 18 .ti `p 1 r 24 (B) End Date: -?---? -, at a.m /p.m. 23 at a.m./p.m. 24 II 2s 5. RENEWAL TERM (check one) - 26 11 This Lease will AUTOMAMCALLY;RENEW-for a term of 2e 27 "Renewal Term') at the`End-Date ofthis=Lease ox at the end of any Renewal Term unless: (also called the 26 !! 27 28 l . Tenant gives Landlord at least dais written notice befoi e.End pate>?r before the end of.any Renewal Term, OR 28 29 2. Landlord gives Tenant at least days written:notice before End Date or before the eiid of any Renewal'Telm 29 30 This Lease will TERMINATE-on. the End Date unless extended in writing. 30 31, Tenant Initials LR Page 1 of 5 ;,r F Landlord Initials 31 s .. COPYRIGHT PF,"MVANIA ASSaCIAWON OF REAL 007 Pennsylvania Association of REALTORS' 03/07 Exhibit "A" ' RENT AND DEPOSIT \ 32 6. RENT 33 (A) Rent is due in advance without demand ou or before the ?r{ day'of each IOnth 32 33 34 (B) ,. , ? . j% yey? ??y The total Rent due, each month is: ........ ... Za .$ I ( 34, 35 (C) 36 (D) The total amount of R t e during the.Tenm is, .?.... '' $.. If Rent is more than L days Jate, Tenant pays a Late Charge of ...::' $ 35 36 - 37 (E) .- .._... All other payments :due from Tenant to Landlord, including Late Charges or utility charges, are, cogsid d lobe Additional 37 38 Rent. Failure to pay this Additional Rent is a breach of the Lease. in the same way as failing to pay the regular Rent. , 38 39 (F) Tenant agrees that all payments will be applied against outstanding Additional Rent that is due before they will be applied 39 40 41 .(G) against the current Rent due. Tenant will pay, a fee,"of $ _ for any payment that is returned by any financial institution for any reason. Any 40 41 42 43: (H) Late Charges will continue to apply until -a valid payment isrgoeeeved. ? Landlord will acce t the followin method f t IrC h M O d 13/ 42 p : g s o paymen : as oney r er Personal Check 43 44 ? Credit Cards ? Other'. D Other: - da 45 7, PAYMENT SCHEDULE Due Date Paid Due 45 . 46 - (A) Security Deposit, held in escrow by. $ l?c3a • $ - 46 47 Held at (financial institution): 47 as (B) First month's rent: ZMNZ CA_. $_ $ as 49 (C) Other: rnA7 u- ?-1f $ 49 50 (D) Other: $ $ 50 51 Total Rent and security deposit received t9 date : ......... ....::. ........................$ 51 52 Total amount due ............. 53 8. RETURN OF SECURITY DEPOSITS (see Information Regarding Security Deposits on back) 53 54 (A) When Tenant moves from the Property, Tenant will return 4.11 keys and give. Lan dlord written notice of Tenant's new mail- 54 55 ing address where Landlord can return the Security Deposit. 55 56 (B) Within 30 days after Tenant moves from the Property, Landlord will give Tenanta written list of any damage to the Property 56 57 that Landlord claims Tenant is responsible for. 57 56 (C) Landlord may deduct repair costs and any unpaid rents from Tenant's Security Deposit. Any remaining Security Deposit 58 59 will be returned to Tenant within 30 dais after Tenant moves from the Property. 59 '.c??VlI41r CASE AND iTSE OF PROPERTY f'73 ? 1=X-jV. 0VcvN r;-- ; 60 9. USE 61 (A) OF PROPERTY AND AITTAORIZED OCCUPANTS --A V 1 A { Ten nt ill P id n t ONLY t Se ?' 60 a w use roper fete, y as a res e ce . I 61 62 (B) Not more than people wi •v Property. List all other occupants who are not fisted as Tenants in 62 63 64 - paragraph 1: -' ewa A rM V'r. 4k-T.irA?.r t^+ ?? L.+aar4 !'0,ti`t.Q c r? (?4^• 63 ?sa ? 65 10. POSSESSION J65 66 (A) Tenant may move in (take possession of the Property) on the Start Date of this Lease. 66 67 (B) If Tenant cannot move in within :? -"ys after Start Date because the previous tenant is still there or because of 67 68 property damage, Tenant's exclusive rights are to: e8 69 1. Change the starting date of the Lease to the day when Property is available. Tenant will not owe rent until Property is 69 70 available; OR 70 71 2. End the Lease and have all money already paid as rent or security deposit returned, with no further liability on the part 71 72 of Landlord or Tenant. 72 73 11. LANDLORD'S RIGHT TO ENTER 73 74 (A) Tenant agrees that Landlord or Landlord's representatives may enter the Property at reasonable hours to inspect, repair, 74 75 or show the Property. Tenant does not have to allow possible tenants to enter unless they are with the Landlord or 75 76 Landlord's representative, or they have written permission from the Landlord. 76 77 (B) When possible, Landlord will give Tenant 1V hours notice of the date, time, and reason for the visit. 77 78 (C) In emergencies, Landlord may enter Property without notice. If Tenant is not present, Landlord will tell Tenant who was 78 79 there and why within 24 hours of the visit. 79 sq (D) Landlord may put up For Sale or For. Rent signs on or near Property. so 81 12. CONDITION OF PROPERTY AT MOVE IN 81 82 Tenant has inspected the Property and agrees to accept the Property "as-is," except for the following: e2 83 r'M 83 84 , 84 65 Tonant Initialst Lk Page 2 of 5 " Landlord Initial si' -- -- -ss es 13. 87, 88 89 90 APPLIANCES >jNCLUDED 5 2(Stove Refrigerator Dishwasher _ -? Washer 0 Dryer ? Garbage Disposal 0. Microwave Air Conditioning 414 14 r ,i> 040s ? Other El Other Landlord is responsible for repairs to appliances listed above unless otherwiti a stated here: b 1.i. n4arCnuo4?V? k""A r, LX1 U tti t ?'t Co _e tl t,h\\ PtV b E r f (7N&t c ?? ?t+t3, 1i -? ss 8T ea sa 90 91 14. , UTILITIES AND SERVICES Landlord and Tenant agree to pay for the charges for utilities and services provided for the 91>: - 92 Property as marked below. If a service is not- marked as being paid by the Landlord, itis the responsibility, of Tenant to,;,pay for 92 93 that,service. Landlord is not responsible: for loss. of service if interrupted by circumstances beyond the Landlord's control.: 93 94 Landlord Tenant Landlord Tenant 94 95 pays payspays pay 95.. ss ? ? 6eelt?ng ESs-- ? Fk ?ff Conditioning 96 97 ? A Electricity ? L;" Cable Television 97 l- 98 ? eat ? ? 98- 99 ? of Water ? ??r 99. 100 ? Gold Water- ? 9%. aintenance of Common Areas 100 101 . ,/ ? ash Removal t,d ? Pest/Rodent Control :S 101 102 El L ewage Fees ? - now/lee Removal 1 1.02 103 104 wer Maintenance ? t'Telephone Service V ? ?? ? S u b 1a3' 105 and Lawn hr b ery Care ? ? - ! D/ H 104 ? eater Maintenance Contract ? ? 105 106 y Comments: 0A V- 90k ? 6r 111A . _T nrA fA_ 61'%A (; Jen n 1-1 A-?, [)Obi n t T - 106, 107 G <' VA -,r\ - b t 1._P 4 f* r. L :ea T - S 1 107 108.15. TENANT'S CARE OF:PR PERTY . ? -1 108 109 110 (A) Tenant will: No ?3noA:W& ob No wm ,?t DS 1 K h 109 . eep t e Property clean and safe. 1P 110. 111 2. Dispose of all trash, garbage and any other waste materials as required by Landlord and the law. 111 112 3. Use care when using any of the electrical; plumbing, heating, ventilation or other facilities or appliances on the 112. 113 Property, including any elevators. 113 114 4. Tell Landlord immediately of any repairs -needed and of any potentially harmful health or environmental conditions. 114 113 11 5. Obey all laws. (o, fkkl e foo?ors VnA tt, 05'0- Dt > p-q- ecq k r, 'r 115 6 (B) Tenant will not: 116 117 1. Keep any flammable, hazardous and/or explosive materials on the Property. 117 118 2. Destroy, damage or deface any part of the Property or common areas. 118 119 .3. Disturb the peace and quiet of other tenants or neighbors. . 119 120 4. Make changes to the propert)4 such as painting or -remodeling, without the written permission of Landlord. Tenant 120 121 agrees that any changes or improvements made will belong to the Landlord. 121 122 5. Perform any maintenance or repairs on the Property unless otherwise stated in the Rules and Regulations, if any. 122 123 (C) Tenant is solely responsible to pay the costs for repairing any damage that is the fault of Tenant or Tenant's family or 123. 124 guests. 124 12516. SUBLEASING AND TRANSFER 125 126 (A) Landlord may transfer this Lease to another landlord. Tenant agrees that this Lease remains the same with the new landlord. 126 127 (B) Tenant may not transfer this Lease or sublease (rent to another person) the Property or any part of the Property without 127 128 Landlord's written permission. 128 12917. PETS 129 130 Tenant will not keep or allow any-pets on any part of the Property, unless checked below. 130 131 ? Tenant may keep pets with Landlord's written permission according to the terms of the attached Rules and Regulations. 131 132 18. RULES AND REGULATIONS 132 133 (A) Rules and Regulations for use of the Property and common areas are attached. ? Yes L7 No 133 134 (B) Any violation of the Rules and Regulations is a breach of this Lease. 134 135 (C) Landlord may change the Rules and Regulations if the change benefits the Tenant or improves the health, safety, or welfare 135 136 of others. Landlord-agrees to provide all changes to Tenant in writing. 136 137 (D) Tenant is responsible for Tenant's family, and guests obeying the Rules and Regulations and alllaws. 137 138 19: SMOKE DETECTORS AND FIRE PROTECTION SYSTEMS 138 139 (A) Landlord has installed smoke detectors in the. Property.- Tenant will maintain and regularly test smoke detectors to be sure 139 140 they are in working order, and will replace smoke detector batteries as needed: 140 141 (B) Tenant will immediately notify Landlord or Landlord's agent of any broken or malfunctioning smoke detectors. 141 142 (C) Failure to properly maintain smoke detectors, replace smoke detector batteries or notify Landlord or Landlord's agent of any 142 143 broken or malfunctioning smoke detectors is a breach of this Lease. 143 144 (D) Landlord may provide additional fire protection systems for the benefit of Tenant. Responsibility for maintaining these sys- 14.4 145 tems is stated in the Rules and Regulations, if any. 43 146 ;- (E). Tenant Will pay for damage to the Property if-Tenant fails -to. maintain smoke detectors or other fire protection systenk. 147 Tenant Initials- { ,?-` LR ;Page 3 of 5 Landlord initials. ta i 3 14s 20. LEAD-BASED PAINT HAZARD DISCLOSURES FOR PROPERTY BUILT BEFORE 1978 148 ' 149 roperty was built in or after 1978. This paragraph does not apply. 149 150 Property was built before 1978. Landlord and Tenant.must provide information in this paragraph. 150 .151 (A) Landlord does not know of any lead-based paint or lead=based paint,hazards' on the Property unless stated below: 951 152 Landlord knows that.there is lea&based paint, or that-there-are lead-based paint hazards on the Property. Landlord; . u 153 must explain what Landlord knows about the lead-based paint and hazards, ;including how Landlord learned that it Is , -1t3` 154 there, where it is, and the condition of painted walls, trim and other surfaces. Landlord must give Tenant any other 154 1s5 information Landlord has about the -lead-based paint and lead=based paint hazards. 155: 156 (B) Landlord has no reports or records about lead-based paint or lead-based paint hazards on the Property unless staff 156 . 157 ed below: 157 , 158 Landlord has given Tenant all available records and reports about lead-based paint or lead-based paint hazards .on Ise 159 the Property. List records and reports: -- 159 160 160 161 (C) Tenant initial all that are true: 161 162 y? ?Tenant has received the pamphlet Protect Your Family From Lead in Your Home. 162 163 ; Tenant has read the information given, by Landlord in paragraph 20 (A) and (B) above. 163 164 lenant has received all records and-reports that Landlord listed in paragraph 20 (B) above. 164. 165 (D) La> 6rd and Tenant certify, by signing this Lease, that the information given is true to the best of their knowledge. its 166 21. DESTRUCTION OF PROPERTY 166 167 (A) Tenant will notify Landlord or Landlord's agent immediately if the Property is severely damaged or destroyed by fire or b 167 168 any other cause. Tenant will immediately notify Landlord or Landlord's agent of any condition in the Property that could' 16s- 169 severely damage or destroy the Property. ios 170 (B) If the Property is severely damaged or destroyed for any reason: 170 171 1. Tenant may continue to live on the livable part of the Property and pay a reduced rent as agreed to by Tenant and 171 172 Landlord until the damages are repaired, OR 172 173 2. If the law does not allow Tenant to live on the Property, this Lease is ended, 173 174 (C) If Lease is ended, Landlord will return any unused security deposit or advanced rent to Tenant. 174 175 (D) If Tenant, Tenant's family, or Tenant's guests cause damage by fire or by other means; this Lease will remain in effect and 175 176 Tenant will continue to pay rent, even if Tenant cannot occupy the Property. 176 177 22. INSURANCE AND RELEASE 177 178 (A) Tenant understands that Landlord's insurance does not cover Tenant, Tenant's property, or Tenant's guests. Tenant is advised 178 179 to obtain property and liability insurance to protect Tenant, Tenant's property and Tenant's guests who may be injured while 179 180 J on the Property. / 180 181 C IF CHECKED; Tenant must have insurance policies providing at least $t property insurance 181 182 and $ , C liability insurance to protect Tenant, Tenant's property and Tenant's guests who may be 182 183 injured while on the Property. Tenant must maintain this insurance through the entire Term and any Renewal Term. Tenant 183 184 will provide proof of insurance upon request. 184 185 (B) Landlord is not legally responsible for any injury or damage to Tenant or Tenant's guests that occurs on the Property. 185 186 (C) Tcnant is responsible for any loss to Landlord caused by Tenant, Tenant's family or Tenant's guests, including attorney's fees. 186 ENDING LEASE 187 23. LANDLORD REMEDIES IF TENANT BREACHES LEASE 187 188 (A) If Tenant breaches Lease for any reason; Landlord's remedies may include any or all of the following: 188 189 1. Taking possession of the Property by going to court to evict Tenant. Tenant agrees to pay Landlord's legal fees and 18s 190 reasonable costs, including the cost for Landlord or Landlord's agent to attend court hearings. 19a 191 2. Filing a lawsuit against Tenant for rents, damages and unpaid charges, and for rents and charges for the rest of the Lease 191 192 term. If Landlord wins (gets a money judgment against Tenant), Landlord may use the court process to garnish 192 193 Tenant's wages and take Tenant's personal goods, furniture, motor vehicles and money in banks. 193 194 3. Keeping Tenant's Security Deposit to be applied against unpaid rent or-damages, or both. 194 195 (B) If Tenant breaches Lease for any reason, Landlord. can begin eviction proceedings without written notice. 195 196 TENANT WAIVES OR GIVES UP TENAN'T'S RIGHT TO ANOTICE TO MOVE OUT UNLESS A DIFFERENT 196 197 NOTICE PERIOD IS STATED HERE:. 19,7 198 198 Ise 24. TENANT ENDING LEASE EARLY. 199 200. Tenant may end this Lease and move out of the Property before the End Date of-the Lease or any Renewal Term only with writ- 209 201 ten permission. of Landlord,-and only if 201 202 (?lr ...+.,?-? 1V33?t°nnt r Al??a .. 202 203 (B) r J r iwlire'}- "r?rras0 9 .203 204 (C) Tenant continues to pay all rent until the End Date of the Lease, or any Renewal Term; or until a new tenant is approved by 2o4 gas Landlord and a' new lease takes effect, whichever happens first. 205 206 25. ABANDONMENT 206 207 (A) If Tenant Abandons Property while Rent is due and unpaid, Landlord has the-right to-,take possession of the Property-izmrre-- 20r 208. diatel nd tosz It the Property to. another tenant 20,8 209 Tenant Initialsr- LR Page 4 of 5 Landlord Initials: a sos 210 (B) Any of Tenant's personal property or possessions remaining on the Property after Tenant. moves out will be considered-to- 210 211' be abandoned property. Landlord will have the right to remove and dispose of any abandoned property in any manner det- 211,; 212 emined by Landlord. Tenant will pay for the cost of removal and disposal of abandoned property. 212 213 26. SALE OF PROPERTY 213 214 (A) If Property is sold, Landlord will give Tenant in writing: 214 215 1. Notice that the Security Deposit has been given to the new landlord, who will be responsible for it. 215 216 2. The name, address and phone number of the new landlord and where rent is to be paid, if known. -- 216 217 (B) Tenant agrees that Landlord may transfer Tenant's Security Deposit and advanced rent to the new landlord_ 217 218 (C) Landlord's responsibilities to Tenant under this Lease end after the. Property has been sold and the Lease transferred to a new landlord 218 218 (D) If Landlord sells the Property during the Lease or any Renewal Term, Landlord has the right to terminate this Lease if 219 220 Landlord gives at least "ZD days written notice to Tenant. Tenant is not entitled to any payment.of damages. 220 221 27. IF GOVERNMENT TAKES PROPERTY 221 222 (A) The government or other public authority can take private property for public use. The taking is called condemnation. 222 223 (B) If any part of the Property is taken by the government, Landlord will reduce Tenant's rent proportionately. If all the Property 223 224 is taken or is no longer usable, this Lease will end and Tenant will move out. Landlord will return to Tenant any unused 224 225 Security Deposit or advanced rent. 225 226 (C) No money paid to Landlord for the condemnation of the Property will belong to Tenant. 226 ADDITIONAL TERMS 227 28. TENANT HAS FEWER RIGHTS THAN MORTGAGE LENDER Landlord may have a mortgage on the Property. The 227 228 ri hts of the mortgage lender come before the rights of the Tenant. (Example: If Landlord fails tomake mortgage payments, the 228 229 mortgage lender could take the Property and end this Lease.) 229 230 TENANT MAYBE WANING OR GIVING UP TENANT'S RIGHTS. TENANT UNDERSTANDS THAT IF THERE IS 230 231 A FORECLOSURE, THE NEW OWNER WILL HAVE THE RIGHT TO END THIS LEASE. 231 232 29. CAPTIONS The headings in this Lease are meant only to make it easier to find the paragraphs. 232 233 30. ENTIRE AGREEMENT This Lease is the entire agreement between Landlord and Tenant. No spoken or written agreements 233 234 made before are a part of this Lease unless they are included in this Lease in writing. No waivers or modifications of this Lease 234 235 during the Term of this Lease are valid unless in writing signed by both Landlord and Tenant. 235 236 NOTICE BEFORE SIGNING: If Tenant has legal questions, Tenant is advised to consult an attorney. 236 237 If Landlord or Tenant are represented by a licensed real estate broker, Tenant and/or Landlord acknowledge receipt of the 237 238 Consumer Notice as adopted by the State Real Estate Commission at 49 Pa. Code §35.336 and/or §35.337. 238 239 By signing below, Landlord and Tenant acknowledge that they have read and understand the notices and explanatory infor- 239 .240 mation set forth in this Lease. 240 241 WITNESS . _?.? TENANT DATE 241 242 WITNESS `'---_ TENANT r-?- DATE 242 243 WITNESS TENANT DATE 243 244 WITNESS, DATE 244 245 WITNESS DATE 245 246 WITNESS DATE 24G 247 WITNESS ,?-- }..?--- - --LANDLORD DATE ; 247 248 WITNESS LANDLORD DATE 248 249 Brokers'/Licensees' Certifications By signing here, Brokers and Licensees involved in this transaction certify that: (1) The information 249 250 given is true to the best of their knowledge; AND (2) They have told Landlord of Landlord's responsibilities under the Residential Lead- 250 251 Based Paint Hazard Reduction Act (42 U.S.C. §4852d), described in the Lead Hazard Disclosure Requirements (see Lead-Based Paint 251 252 Hazards Notice). Brokers and Licensees must make sure that Landlord gives Tenant the information required by the Act. 252 253 BROKER FOR LANDLORD (Company Name) K e-4, 253 254 ACCEPTED BY -" 7 ...,? .ti? • ,,.,,... __ - DATE la ., ev. l. 254 255 BROKER FOR TENANT (Company Name) 255 256 , ACCEPTED BY _ DATE 256 257 IF LANDLORD TRANSFERS LEASE TO A NEW LANDLORD 257 258 As part ofpayment received by Landlord, (current Landlord) now transfers to 258 259 (new landlord) his heirs and estate, this Lease and the right to receive.the rents and other benefits.. 259 260 WITNESS LANDLORD DATE 260 261 WETNESS LANDLORD DATE `261 LR Page 5 of 5 f U fit 1 L.. w'. 9 k; Richard Gregory Kayce Ryan Campbell 408 Zion Road Carlisle, PA 17015 April 26, 2010 As per our telephone conversation in February, 2010, you gave notice you would be moving out of property at 408 Zion Road. My understanding is that you would be moving out as of end of May 2010. The contract was signed for a two year rental, term is through December 2010. If the property is rented to another party of my satisfaction before December 2010, your obligations (ex. Rent, water bill, electric bill, yard maintenance etc.) will end as of the signing of new lease. The original heating was fuel oil, when the contract was started there was $384.00 worth of fuel in tank, agreement was to pay property owner this amount. Please contact property owner (Robin Toner @ 717-385-0280) or property management (Wayne Deacon @ 717-497-0184), if any further questions. Sincerely, Robin Toner Exhibit "B" Postal CER.1 OED MAI L RECEIPT 1:3 (0?,hesfic Mail Only; No In surance Coverage Provided) CO -I- For delivery information visit ,- - our at wwwuspsxom?, ilk UWL . C3 s _ Er- m Postage $ SPRIN?s ? ?r fl~ Certified Fee ru p Return Receipt Fee Z ark cy, ?e p (Endorsement Required) 1fi p Restricted Delivery Fee (Endorsement Required) C3 Lrl f -U otal Postage & Fees $ - ru Sent To ! Er p p ------------------------- Street, Apt. ------------- ---------------------------------- f N or PO Box No. or ---------------------- ------------------------------------------------ 1 ' Ciry, State, ZIP+4 0.. 800 See Op yerse for Insbuctiol ' I , r filill Richard E Gregory Jr. Kayce Ryan Campbell 25 Fairfield Street Carlisle, PA 17013 November 16, 2010 I am notifying you per my attorney Michael A. Scherer, that as of November 1, 2010 the house at 408 Zion Road, Carlisle was rented. The contract that you signed was for a two year term from December 24th, 2008 until December 31, 2010. 1 received notice from you that you were moving out as of the end of May, 2010. As stated in the letter sent to you dated, April 26, 2010, and per your contract under Ending Lease, you are responsible for all bills pertaining to house until December 31, 2010 or until house is rented. As stated above the house was rented as of November 1, 2010 therefore under contract you are now responsible for any outstanding bills. I expect to hear from you within 10 days from date of receiving this letter to pay in full or make payment arrangements; you may contact me at 717-385-0280 or my email address is tonerrobin@gmail.com. If I do not hear from you within 10 days of receiving this letter I will be contacting my attorney and his fee will be added to the total amount along with any other expenses incurred in this matter. Rent for 5 months: $6125.00 $1150.00 +$75.00 late charge Water bills: $267.41 April, May, June $123.01 July, Aug., Sept., $108.30 Oct., $36.10 Electric bills: $124.11 July 2 - Jul 12, $8.72, July 13 - Aug 9, $21.14 Aug. 10 - Sept. 9, $23.77 Sept. 10 - Oct 7, $24.38 Oct. 6, - Oct. 31, $46.10 Lawn care: $280.00 Cleaning, repairs, replace drapes, removing and disposing of debris from attic and garage: $725.00 Oil in tank: $384.00 UGI Gas: $17.71 Minus Security Deposit: $1000.00 Total: $6923.23 Sincerely, Robin Toner Exhibit IV' cc: Michael A. Scherer Postal. CERTIFIED MAIL, RECEIPT 0 D, Only; Provided) rq m Ul H ' S rru Postage 9 tO ?g Certified Fee '"?11 0 Return Receipt Fee 1.2 __30 r Here a (Endorsement Required) t` O Restricted Delivery Fee j,llli O !Endorsement Required) Q' Total Postage & Fees $ s- t C3 7Sent / t__-O pt. a.; ! IY O or PO Box No. 1 G{ ,? 4 yrf5+ 41 Jr CD aaon?Mi?DC Lf-7oLn Oa o Z o I I r i iw r%.E0 i.. i lp io - WO .WIN .:..P•l r: lf? ?-?- Cfl C3,. ? 4.J D r V W Q W F--- r.+ < C= COO W i W C Q ?.r C= C >, p O CC Gr r N _i t o N CD 4 A r O I/ C3 r3 m L7 0 0 a-? iri' •-•? +ril y Q n = _ Z its I©? : d zuw +? = D DO a :?7 z Y? Wk X H Z ? 23 a _ = fU Z+ Q CO -W •- e O n,E 0 0 t ra L U +L-' .- -- -.....? o CD _ C/) . m -o a C3 W >>, 5 O L• `C -N - L O U O to p _V N LO M YNU r ti i 1 ROBIN TONER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 11-5640 CIVIL RICHARD GREGORY, JR. and KAYCE R. CAMPBELL, Defendants ORDER AND NOW, this I' day of December, 2011, the appointment of Michelle Sommer, Esquire, as a member of the Board of Arbitrators in the above-captioned case is VACATED. Joshua Autry, Esquire, is appointed in her place. BY THE COURT, Hess, P. J. ? Rolf Kroll, Esquire Chairman "' Court Administrator :rlm eopi f s may t-d i all y l/ / h, :z m Fri - r-- < ?;. _ ; ROBIN TONER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2011-5640 CIVIL TERM RICHARD E. GREGORY, JR., CIVIL ACTION-LAW MM _4; KAYCE R. CAMPBELL, xa Defendants PRAECIPE TO SATISFY r TO THE PROTHONOTARY: --; Cn ,a Kindly mark the judgment entered in the above-captioned action against the Defendants, Richard E. Gregory, Jr. and Kayce R. Campbell as satisfied. Respectfully submitted, BARIC SCHERER LLC ABOM &KUTULAKIS LLP 4Trici Naylor, quir J son . utu a is, saq e for Kara W. I.D. #83760 agge Esquire 19 West South Street D. # Carlisle, PA 17013 West Iig Street (717) 249-6873 Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff Date: June 19, 2013 Date: J� Ulf i • (�l,Ah�'� SoPd aE' copooc)°? 2Q ag E CERTIFICATE OF SERVICE I hereby certify that on July 2,2013,I,Lori Duncan,of Baric Scherer LLC,did serve a copy of the Praecipe To Satisfy,by first class U.S. mail, postage prepaid, to the parties listed below, as follows: Richard E. Gregory, Jr. Kayce R. Campbell 3747 Kimberly Lane Dover, Pennsylvania 17315 Lori Duncan