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Home My WebLink About01-3163 '~MMOf4~WIALTH Of PENNSYLVANIA NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT ~ ]]4 ~2g[~l~lS C~?~C~., ~'-23--01 COMMON PLEAS No, 01-3163 Civil ?em NOTICE OF APPEAL Notice is g/yen that ~ appellant has fibd in the abeve Court of Common Hem an appeal from the judgment rendered by the Distdct Justice on the date md in the case ~ bek~ ,i~B'- il be r~lned ONLY when this notafian is required un,er P~ Rt',J,. ~"-If appe~a~tlt~CLAIMAN~R.O.p.J.p. 'llliS Notice of Appeal. when mceivacl by the District Justice. will apemte as ~ lO01(~'[nactionbeforeDistrictJusUce, heMUST SUPERS to ~e judl~ for po, ese, on in ~ds ~ FILE A COMPLAINT within twen~ (20) days after filing h~ NOTIOE of APPEAL. Signature o~ Prolho~o~ry or Deputy PRAECIPE TO ENfER RULE TO FILE COMPLAINT AND RULE TO FILE (This section o~ fotm ~o be usecl ONLY wflen appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in actJon before Disl~ict Justice. IF NOT USED, detach from co~y of no#ce ol appeal to be setved upon appellee). PRAECIPEz 1'o Pro~notory Enter nJie upan , appdee(s), to file a compkzint in this cq:ped (Common Pbas hkx ) within twenty (20) days after service of rub or suffer entry of judgment of non pros RULE8 To , amd~s~ ~ af ~aelm~(s) (1) You ore nofific*d that a rde k hereby entered upon you to fib a campkzint in this appeal within twenty (20) days after the date of (2) If you do not fib a camplaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of maing. ,19 . COURT FILE TO BE FILED WITH PROTHONOTARY PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proc! of service MUST BE FILED WITHIN TEN 110) DAYS AFTER filing tl~e notice o! appeal~Check applicable boxes) COMMDNWEALTH OF PENNSYLVANIA COUN OF AFFIDAVIT: t hereby swear or affirm that I served I"] a copy of the Notice of Appeal, Common Pleas No , upon the District Justice designated therein on (date of service) . [] by personal service [] by (certified} <registered) mail. sender's receipt attached hereto, and upon the appellee, (aaron) __, on ,19 [] by personal service [] by (certified) (registered) mail, sender's receipt attached hereto. [] ~nd further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to whom tl~e Rule was addressed on , 19 [] by personal service [] by (certified) (registered) mail, sender's receipt attached hereto. SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF 19 Signature of afhant COMMONWEALTH OF PENNSYLVANIA COUNTY OF: Cr.,~*~I'~I~.I.~,.N'D NOTICE OF JUDGMENT/TRANSCRIPT r_,,., ... "L^ NT FF' CIVIL CASE 09-3-01 ~rAYANOS, JOHN ,~.',,a...: H0r. 213 N.PRINCE ST HAROLD E. BENDER SHIPPENSBUR. G, PA 17257 ^.~a~ 81 WALNUT BOTTOM ROAD P.O. BOX 361 / VS. SHI PPHNSBUI~-G, PA DEFENDANT' NAME ar~ AOORE$$ ',~,~.,-,.n,~ (717~ 532-7676 17257-0361 I-SCHANTZENBACH, RYAN MATTHEW, ET AL~. 36 S.QUEHN ST SHIPPHNSBIIR. G, PA 17257 JOHN VAYANO8 L_ _1 213 N.PRINCE ST [ Docket No.: CV-0000056-01 SHIPPENSBUR. G, PA 17257 Date Filed: 3/23/01 THIS IS TO NOTIFY YOU THAT: -- Judgment: FOE J-~ Judgment was entered for: (Name) ~-~.."~.~a~,,-~A~_~': gv~,~ J-~ Judgment was entered against: (Name) VA¥'AlffCtR_. ,TORN' in the amount of $ _ t~t3on: (Date of Judgment) 4./34/~1 J-]Defendants are jointly and severally liable. (Date & Time) ~ Damages will be assessed on: ~Amount of Judgment $ ,00 Judgment Costs $ ,00I ~-~ This case dismissed without prejudice. Interest on Judgment $ ,00. Attorney Fees $ ,00 Total $ .00 Amount of Judgment Subject to J--]Attachment/Act 5 of 1996 $_ Post Judgmenl Credits $. [] Levy is stayed for_ days or ~ generally stayed. Post Judgment Costs $ Certified Judgment Total $ [--~ Objection to levy has been tiled and hearing will be held: 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 JUDGMENTFTRANSCRIPT FORM WITH YOUR No'rICE OF APPEAL. ~'~ '-~ <"/~/ Date ~/~-~/~ '~ ~ . District Justice IIcerhfy that lhis is a true and correct copy of the record of the proceedings containing the judgmeni. Date , District Justice .mmission expires first Monday of January, 2006 SEAL JPC 315-99 COMMONWEALTH OF PENNSYLVANIA NOTICE OF JUDGMENT/TRANSCRIPT COUNTY OF: CUMBERLAND CIVIL CASE 09' 3 '01 ~VAYANOS, JOHN HAROLD E. BENDER SHIPPENSBUP, G, PA 17257 A~.~,~s 81 WALNUT BOTTOM ROAD P.O. BOX 361 / VS. 8HIPPENSBURG, PA DEFENDANT' NAME an,3 ADDRESS Tale,hone t717) 532-7676 17257-0361 r-BCHA-N'TZ~2~BACH, RYRN MATTHEW, ET AL~. 36 S.QUEEN ST SHIPPENSBUP..G, PA 17257 JOHN VAYANO S I_ _1 213 N.PRINCE ST IDocketNo.: ~V.0000056.01 8HIPPENSBUEG, PA 17257 [Date Filed: 3/23/01 THIS IS TO NOTIFY YOU THAT: -- Judgment: FOP~ ~-~] Judgment was entered for: (Name) TT~'~.It~w~rT~.. ~-1 Judgment was entered against: (Name) VA'Val~'OR, in the amount of $ _ OD on: (Date of Judgment) 4./~4/t31 '--]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 Attorney Fees $ . Total $ .00 Amount of Judgment Subject to I--] Attachment/Act 5 of 1996 $. Post Judgment Credits $ ~ Levy is stayed lot days or ~'~ generally stayed. Post Judgment Costs $ Certified Judgment Total $ ['--~ Objection to levy has been filed and hearing will be held: 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 JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. /7/~,~¢'//'~/ Date ,~--~~ ~ ,DislrictJustice I certify that lhis is a true and correct copy of the record of the proceedings containing the judgment. Date , District Justice My commission expires first Monday of January. 2006 SEAL AOPC 315-99 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: ~u~EE.[,A.N~ NOTICE OF JUDGMENT/TRANSCRIPT J uad D,~, NO PLAINTIFF: CIVIL CASE 09-3-01 FVAYANOS, JOHN -I .~Jr~.~ ~o, 213 N.PRINCE ST J HA~.OLD E. BENDER SHIPPENSBURG, PA 17257 ^'~"" 81 WALNUT BOTTOM ROAD P.O. BOX 361 I- VS. SHI PPHNSBUP~G., PA DEFENDANT: ~AME a~o AODRESS T*,,,O.. (717) 532-7676 17257-0361 %CHANTZENBACH, RYAN t~.TTHEW, ET SHIPPENSBU'RG, PA 17257 JOHN VAYANOS L_ 213 N.PRINCE ST [OocketNo.: CV-0000056-01 SHIPPENSBU~.G., PA 17257 [Date Filed: 3/23/01 THIS IS TO NOTIFY YOU THAT: -- Judgment: FOR [-~ Judgment was entered for: (NameJ .'r~,~.. ~'] Judgment was entered against: {Name) ~'v'~zc~g_. ,"rc~m~ in the amount of $ _ n[~ on: (Date of Judgment) 4./34./{)1 ~---~ Defendants are iointly and severally liable. (Date & Time) [] Damages will be assessed on: Amount of Judgment $ .0~ Judgment Costs $ .00 ]This case dismissed without prejudice. Interest on Judgment $ , Attorney Fees $ . Total $ .0 Amount of Judgment Subject to [~ Attachment/Act 5 of 1996 $ Post Judgment Credits $ [] Levy is stayed for. days or [] generally stayed. Post Judgment Costs $ Certified Judgment Total $ ~-~ Objection to levy has been filed and hearing will be held: -- 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 JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. Dale .D,str,ct ust,ce I certify thai this is a true and correct copy of the record of the proceedings containing the judgmenl. I Date , District Justice I My commission expires first Monday of January, 2006 SEAL AOPC 315-99 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CO31~R[~,.,_ND NOTICE OF JUDGMENT/TRANSCRIPT ~ag D,~., .~ PLAINTIFF' CIVIL CASE 09- 3-01 I-VAYANOS, JOt]N DJ'~ar~ Hon 213 N.PRINCE ST HAKOLD E. BENDER SHIPPENSBURG, PA 17257 ~o,c,, 81 WALNUT BOTTOM ROAD P.O. BOX 361 [- J VS. SHI PPENSBIIRG, PA 0EFENDANT: r.,.p~., (717) 532-7676 17257-0361 r-SCHANTZENBAC~, RYAN MATTHEW, ET AL~. 36 S.QUEEN ST SHIPPENSBD~G, PA 17257 JOHN VAYANOS / 213 N.PRINCE ST [Docket No.: CV-00000~6-01 8HIPPENSBU~G, PA 17257 /Date Filed: 3/23/01 THIS IS TO NOTIFY YOU THAT: -- Judgment: ~'-~ Judgment was entered for: (Name) ~'-~ Judgment was entered against: (Name) VA¥~I~R_. Jcm-~ in the amount of $ _ t3~1 on: (Date of Judgmenl) 4./~4./01 J'~ Defendants are jointly and severally liable. (Date & Time) ~ Damages will be assessed on: Amount of Judgment $ .0'~ Judgment Costs $ . O0 ~---] This case dismissed without prejudice. Interest on Judgment $ .0 0 Attorney Fees $ . Total $ .0 Amount of Judgment Subject to ~'--~ Attachment/Act 5 of 1996 $ Post Judgment Credits $ [] Levy is stayed for__, days or [] generally stayed. Post Judgment Costs $ Certified Judgment Total $ ~--~ Objection to levy has been filed and hearing will be held: 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 JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. Y ~/-~/ Date /-'~ ~ ~ , District Justice I certify that this is a true and correct copy of the record of the proceedings containing the judgmenl. I Date , District Justice IJ My commission expires first Monday of January, 2006 SEAL AOPC 315-99 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: ~;uH~E~ NOTICE OF JUDGMENT/TRANSCRIPT Mag D,s, No PLAINTIFF: CIVIL CASE NAME a~cl ADDRESS 09-3-01 I-V~Y~O~, JOHN OJ~ame H0n 213 N.PRZN~ GT ~0~ g. B~ 8HIPP~SB~G, PA 17257 ~,es~ 81 W~UT B~M RO~ P.O. ~X 361 ~ VS. SHIPP~SB~G, PA DEFENDANT: ~AM~ ~ ADDRESS ,.,.,~o.. (717) 532-7676 17257-0361 ~Z~. RY~ ~. ET 36 S. O~ ST BHIPP~BB~G, PA 17257 JO~ VAY~O8 L j 213 N.PRIN~ ST OocketNo.: ~-0000056-01 SHIPP~SB~G, PA 17257 Date Filed: 3/23/01 THIS IS TO NOTIFY YOU THAT: Judgment: FOR ~ Judgment was entered for: (Name) ~ann~: ~ Judgment was entered against: (Name) VAVa~R: in the amount of $ _ a~ on: (Date of Judgment) ~ Defendants are jointly and severally liable. (Date & Time). ~ Damages will be assessed on: Amount of Judgment $ .0 Judgment Costs $ .00 ~This case dismissed without prejudice. Interest on Judgment $ .00 AEorney Fees $ .00 Total $ .0 Amount of Judgment Subject to ~ AUachmenVAct 5 of 1996 $ Post Judgment Credits $ ~ Levy is stayed for days or ~ generally stayed. Post Judgment Costs Ce~lfied Judgment Total $ ~ Objection to levy has been filed and hearing will be held: 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 JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. ~'.-~/7~-~'/ Date Z/~'/~ ~ ~ , District Justice I certify that this is a true and correct copy of the record of the proceedings containing the judgmenL Date , Distr ct Justice J My commission expires first Monday of January, 2006 SEAL AOPC 315-99 CGMM~ ~EALTH Ol~ PENNSYLVANIA NOTICE OF APPEAL · ,~ COCIRT Q(f COMMON PLEAS FRO~ JUOICIAL DfSTRICT DISTRICT JUSTICE JUDGMENT NOTICE OF APPEAL Noflce is given 1hat 1he al~Ndfc:nt has fiiKI in the above Court of Ccxnman Pbos an q:ped from ~he judgment tundra'ed by the Distr~ Justice an the CVl9 · ~ Notice of Apped, whefl mcelved by fne Dis~'ict Justice, will ~ as o lO01(~}'lnc~'tiotll~,tol~Di~iotJij~t~,heMU~T SUPERSE~AS ,. ~e judgment f~ I:csses~n in t~is cas~ FILE A COMPLAINT within twenty (20) tiling ~ NOTICE ot APPEAL. PRAECIPE TO Ei~.,K RULE TO FILE COMPLAINT AND RULE TO FILE ~ ~-'tio~ ot ~ ~o I~e Lined ONLY ~ ~ w~ DEFENDANT (~ Pa. ~,.P.J.P. No. ~001(7) in ,qctio~ ~ Di~ict ,l~b'~e. IF NOT USED, oL..~l~ ~ r. op/ ol nonce ol ~c~e~l ~o be ~em/ed ~ PRAECIPE~ To Ente~ rule upan , al~dlee(s), to file c, canV3k~ ~n ~is c,pped (C;,,.,,,~ Plem Nc~ ) within twanty (20) days ~ service of rule m suffer efltry of juc~ant of ~n pros, COURT FILE 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 the rtotice Of appeal. Check applicable boxe~) COMMONWE~H~LVANIA~... ~d,* COUNTY OF ~s AFFIDAVIT: ) hereby swear or affirm that I served ~ a copy of'the Notice o~ Appel. Common Pleas No. ~(' ~ ~ . u~n the D~strict Josl~ce ~esignated there~n on (date of ~ervice) v ~ ~,~ ~ ~ ~ . ~ by per~nal ~rvice ~ by (certified) (registered) mail. sender's receipt attached ~ereto. and upon Ihe appellee, fname) / . on .19 ~ by ~rsonal se~ice ~ by (cedi(led) (registered) mad. sender's r~eipt attach~ hereto. ~ and further that I served the Rule to File~Complaint accompanying the above Notice of Appeal upon the appellee(s) t° wh°m NOTARIAL SEAL M~L~I~ L Sotlenber~r, Not~fy Pub~J _F~fle, F~ldln County My uomnl~on Expires OCL '~u, '..~ ~ 02% ~ ~ .~ . ~J~e~P~ePrlnzC~)~by~M) I JOHNS. VAYANOS, ~ IN THS COURT OF COMMON PLEAS OF Plaintiff ~ uu~BERLAND COUNTY, PENNSYLVANIA v. ~ No. 01-3163 RYAN SCHANTZERBACH, ~ DOUGLAS KIRCK, JEROME ~ JAMES, JASON ILGENFRITZ, ~ AND STEVE MADDEN, ~ Defendants ~ LANDLORD/TENANT AND NOW, this /~ day of , 2001, having been advised that Duane Stone, Esq. is prohibited by reason of his employment from serving as an arbitrator, his appointment is hereby vacation. In his stead, ~ is appointed. BY THE CO~T, ~P.J. SAIDIS SflUFF, FLOWER & LINDSAY 26 W. lii~h Street Carlisle. PA JOHN S. VAYANOS, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA : vi. : :NO 01- 3163 : RYAN SCHANTZENBACH, : DOUGLAS KRICK, JEROME JAMES,: JASON ILGENFRITZ, AND STEVE : MADDEN, Defendants :LANDLORD/TENANT ORDER OF COURT AND NOW, this ~-'~(. day of i~_ ~-~f" ,~2001, in consideration of the foregoing ~etition, ,~--~.~.'/~ ~ , ~'sq., ~'~'~'~ , Esq., and ~'/-~"~f.~-~ ~ , Esq., are appointed arbitrators in the ab~e-c~ptioned action as prayed for. BYTHECOURT, ,p.j. JOHN S. VAYANOS, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA : V. : :NO 01- 3163 : RYAN SCHANTZENBACH, : DOUGLAS KRICK, JEROME JAMES, : JASON ILGENFRITZ, AND STEVE : MADDEN, : Defendants :LANDLORD/TENANT PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Galen R. Waltz, Esquire, counsel for the Plaintiff in the above action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of the Plaintiff in the action is $1,094.71 plus attorney fees. 3. Defendant filed an Answer to the Complaint. The following attorneys are interested in the case as counsel or am othenvise disqualified to sit as arbitrators: WHEREFORE, YOUR Petitioner prays this Honorable Court to appoint throe (3) arbitrators to whom the case shall be submitted. Respectf~y/~u bmitted, ~ CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Complaint upon Ryan Schantzenbach, for Ryan Schantzenbach. Douglas Krick, Jerome James, Jason Ilgenfritz, and Steve Madden. by depositing same in the United States Mail. first class. postage pre-paid on the ,,,~' ' day of ,J,~ ~ ,2001, from Carlisle, Pennsylvania, addressed as follows: Ryan Schantzenbach 534 Spruce Street Hellertown, PA 18055. TURO LAW OFFICES tz, Esq~V~ 28 South Pitt Street~'~ Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff JOHN S. VAYANOS, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA : V. : :NO 01- ~3 (;: ,~. : RYAN SCHANTZENBACH, : DOUGLAS KRICK, JEROME JAMES, JASON ILGENFRITZ, AND STEVE : MADDEN, Defendants :LANDLORD/TENANT NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims . set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint of 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 JOHN S. VAYANOS, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA : Vi, :NO01- -~i(,3 C~, RYAN SCHANTZENBACH, : DOUGLAS KRICK, JEROME JAMES,: JASON ILGENFRITZ, AND STEVE MADDEN, Defendants :LANDLORD/TENANT COMPLAINT 1. The Plaintiff, John S. Vayanos, is an adult individual who currently resides at 213 North Prince Street, Shippensburg, Cumberland County, Pennsylvania, 17257. 2. The Defendant, Ryan Schantzenbach, is an adult individual who currently resides at 534 Spruce Street, Hellertown, Pennsylvania, 18055. 3. The Defendant, Douglas Krick, is an adult individual who currently resides at 1209 East Powderhom Road, Mechanicsburg, Pennsylvania, 17055. 4. The Defendant, Jerome James, is an adult individual who currently resides at R.D. #6, Box 6579, Spring Grove, Pennsylvania, 17362. 5. The Defendant, Jason Ilgenfritz, is an adult individual who currently resides at 1100 West Powderhom Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 6. The Defendant, Steve Madden, is an adult individual who currently resides at 36 South Queen Street, Shippensburg, Pennsylvania, 17257. 7. On or about May 30, 1999 Defendants Jason Ilgenfritz, Douglas Krick, Ryan Schantzenbach and Jerome James entered into a Lease for a term of one (1) year beginning May 15, 1999 and ending May 15, 2000 with an option to rent an additional year for all tenants on the Lease. 8. The Defendants Jason Ilgenfritz, Douglas Krick, Ryan Schantzenbach and Jerome James exercised their option to rent from the Plaintiff a second year beginning May 15, 2000 and ending May 15, 2001 the property known and numbered as 36 South Queen Street, Shippensburg, Pennsylvania, 17257. 9. On or about September 2000 Defendant, Steve Madden became a month- to-month tenant at the 36 South Queen Street, Shippensburg, Pennsylvania, 17257 property and resides in that property through May 15, 2001. 10. All of the Defendants agreed to pay the monthly rent of $900.00 per month utilities. 11. The Defendants failed to pay the rent for February 15, 2001 and March 15, 2001. 12. The Defendants were provided notice that they failed to pay the agreed upon rent. 13. Subsequent to the notice regarding the failure to pay rent, the tenants failed to pay $900.00 of that $1,800 due and owing. THEREFORE, Plaintiff respectfully requests this Honorable Court to render a decision in favor of the Plaintiff requiring the Defendants to pay the outstanding $900.00 plus costs of this suit totally $1,094.71 and attorney fees. Respectfully Submitted TURO LAW OFFICES Date 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff VERIFICATION I verify that 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. ~4904 relating to unswom falsification to authorities. CERTIFICATE OF SERVICF I hereby certify that I served a true and correct copy of the Complaint upon Ryan Schantzenbach, Douglas Krick, Jerome James, Jason Ilgenfritz, Steve Madden, by depositing same in the United States Mail, first class, postage pre-paid on the ///,/'~ day of _"J ~ .~ ,2001, from Carlisle, Pennsylvania, addressed as follows: Ryan Schantzenbach 534 Spruce Street Hellertown, PA 18055. Douglas Krick 1209 East Powderhorn Road Mechanicsburg, PA17055 Jerome James R.D. #6, Box 6579 Spdng Grove, PA 17362 Jason Ilgenfritz 1100 West Powderhom Road Mechanicsburg, PA 17055. Steve Madden 36 South Queen Street Shippensburg, PA 17257 TURO LAW OFFICES Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff LAW Ol~C~ A PROFESSIONAL CORPORATION 26 WI~ST HIGH IAMI~ D. FLOWER CARLISLE, PENNSYLVANIA 17013 JOHN I~. SLII~ TELEPHONE: (717) 243-6222- FACSIMILE: (717) 243-6486 ROB£RT C. SAIDIS I~MAIL: attomey~ssfl-i~w.com GEO~I~'Y S. SI-RIFF www.~fl-law,com ]AMES D. FLOWER, JR. CAMP HILL, PA 1701! CAROL J. LINDSAY IOHNNA ~. KO~CKY ~:ACSiMr~: KARL M. LEDEBOHM THOMAS E. FLOWF. R November 7, 2001 Mr. Job. n Wayanos 213 North Prince Street Shippensburg, PA 17257 Dear Mr. Wayanos= Enclosed please find a Notice scheduling the hearing of the Board of Arbitrators in the above-captioned matter. The defendants, other than Mr. Ryan Schantzenbach, should take notice that Mr. Schantzenbach may represent hi~melf pro se, but may not proceed to represent anyone else. If you choose not to participate in the hearing, judgment will be entered in favor of the defendant and against you individually. You and your counsel should proceed to protect your individual interests if you deem it necessary. Very truly yours, ,//s~~F, FLOWER & LINDSAY ' ~dis RCS/pm Enclosure cc: Teri Henning, Esq. Andrew Sheeley, Esq. Galen Waltz, Esq. Ryan Schantzenbach Douglas Krick Jerome James Jason Ilgenfritz Steve Madden IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW JOHN S. VAYANOS, : NO. 01-3163-CIV TERM : Plaintiff : VS. : RYAN SCHANTZENBACH, DOUGLAS : KRICK, JEROME JAMES, JASON : ILGENFRITZ and STEVE MADDEN, : : Defendants : ANSWER TO PLAINTIFF'S COMPLAINT 1. Denied. Defendants are without information suff~cient to form a belief as to the truth of the allegation in Plaintiff's Paragraph 1 and therefore same is denied. 2. Admitted. 3, Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted. 9. Denied. Defendants are without information sufficient to form a belief as to the truth of the allegation in Plaintiff's Paragraph 9 and therefore same is denied. 10. Admitted. 11. Admitted and denied. It is admitted that Defendants felled to pay rant for the months of February 15, 2001 and March 15, 2001. However, it is denied that Defendants have any obligation to pay said rent as a result of Plaintiff's actions toward Defendants and the uninhabitable condition of the premises including, but not limited to such matters as no heat having been provided for a period of approximately one to one and one-half (1 - 1 1/2 yrs), leaking toilets (the toilet on the 2nd floor was leaking into the kitchen sink below), several holes in windows, no locks on doors, permanently clogged toilet on first floor, and such other various violations of Plaintiff's obligations to Defendants pursuant to the terms of the mentioned lease agreement between the parties. 12. Denied. Plaintiff made no demand for payment of rent as alleged. 13. Denied. Plaintiff provided no notice to Defendants. Additionally, Defendants had no obligation to Plaintiff, nor is any rent owing. WHEREFORE, Defendants request this Honorable Court to enter Judgment in favor of Defendants and against Plaintiff. Respect~lly submitted, RY/(N SCHANTZEN~ACH, Pro Se Individually and for Douglas Krick, Jerome James, Jason Ilgenfi'itz and Steve Madden VERIFICATION I, RYAN SCHANTZENBACH, being duly authorized to do so, hereby verify individually and on behalf of all of the Defendants named in the within action, namely, RYAN SCHANTZENBACH, DOUGLAS KRICK, JEROME JAMES, JASON ILGENFRITZ, and STEVE MADDEN, having full authority to do so, that the statements made in the foregoing Answer 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. Section 4904 relating to unswom falsification to authorities. s / R~'AN SCH-ANTZ'ENBACH CERTIFICATE OF SERVICE I hereby cer[~ that I have sewed a true and correct copy of the Answer attached hereto upon the Plaintiff, John S. Vayanos, by forwarding a copy of same to his counsel, Galen R. Waltz, Esquire, of 28 South Pitt Street, Carlisle, PA 17013, by depositing the same in the United States Mail, First Class, postage pm-paid on the"~c~~'' day of June, 2001. 'RY'AN S(~HAN'¥ZEI~ACH, Pm Se Individually and for Douglas Krick, Jerome James, Jason Ilgenfrltz and Steve Madden PENNsYLvANIA PLAIN LANGUAGE HOUSE I.I:. SE Notice to Tmmt: This Lezse contai~ ~ of consumer right~ If you do not meet your Lease obligations, you my lose your security de~t. You my also be evicted and sued for t Lease, you are waiving certain important rights. The wJt~dlord and Tenant agree to lease the House on the following tarmac House Address Bank for Securi~ $ .*...-~C~.~ U~i~--a~n~s~d~l~l~lo~: Ow~,s- O~- O~ 0 eJ~ric OIm~mb~ O~m~eal O~ o or me ~enent. Only a Tenant named above may usc the is ~ es may be ~ by law. House. How~vor, this still remains subject to limits on who may legally occupy an House ofthls size. ' If Temnt fails to timely perform any t~m in this Lease (sUch es paying rent on tlm~_), Landlord may use th~ security. ~. ~ .~ ~ possession Landlord shall not be liable If. the Landlord uses tbe security, Tenant shell (upon notice · from Landlord) restore th~ security. That amount is due, if ~t emmot ~v~ Tenant possession on the be~i~nlng dn~ of when billed, es added tent. At all times Landlord shall have th~ Te4n~ Rent stsrts at tho beginning of ~.~ ~ unless when possession is available). Landlord must give possessionIf Tenent (i) fully performs eli terms of this Lense, (ii) within a reasonable time, or else Tenant may cancel and p~ys rent on time, and (iii) leaves the House in good obtain a ~fund of money deposited. Landlord will notify onndition on tho last day of the Te~m, then Landlord will Tenant when possession is avn!)~b~ The ending date of tbe rsturo the seonrity being held, in accordance with law. Teennt Term will not change, may not apply security to pay mot. 3. Rent, nddadrent The nmt for eech month must be paid If Landlo~d sells or leesas the Houas, Landlord may give by the fu~t day, at Landlord's address. Landlord need not will look'only to the new buyer or lessee to return the give notice ~o pay the reot. Rent must be paid in full without security, end Landlord will be deemed released from all deduction. The lust month's rent (nmi any partial month's liability end obligations. Landlord may put the security ~en0 will be paid when Tenant signs this Lense. Tenant amy nnywhere permitted by luw. Tenant's security will earn of this Lease**Whethor or not stated es such, those other in, rest only when and as ~ by law. chergas are considered "added rent.- Added rent will be 7. Utili~sandservires Tenant will anenge and pey for ell billed and is payable as mat, toge~er with the ne~t monthly rent duc. If Tenant fails to pay the added rent on time, utilities anti services, except the militias to ha paid by Landloai Landlord shay have thc same rights against Tenant as if a~ stated above. Landlord has no obligation to provide (or Tenant felled to pay ~ li~biHty for not providing) thc utilities Landlord pays for. 4. 'l~erm The ~ will end on the da2 stated above, eansed by Tenent's act or n~lect' moy be mpeited by Landlord Tenant must not use a dishwasher, washing machine, 5. Notices Any bill, statement, approval, consent, dyer, freezer, heater, ventilator, air cooling equipment or permission or notien must be in writing. If to 'l~."nnnt' it must other appliance unless installed by Landlord or with be delivtn'ed or mailed to the Tenant at the House. If to Landlord's written consent. Tenant must not usc more Landlord, it must be mailed or delivered to Landlord's electric than the House cnn safely cmy. nddreas. It will be.core,dared delivered on the day mailed (or Landlord may stop service of the plumbing, heating, if not nudled, wben left at d~ proper addreas). They must beelevator, elr cooling or elecirk2l systems, becanse of accident' given by (i) certified or registered mail, return receipt eme~ency, mpein or ch nngas, until the work is comple~c. requested or (ii) hand deliver/with written receipt. Each pan~ must accept and claim thc notice given by the other. 8. &Iterations Tenant must obtain Landlord's prior Landlord will notify Tensut if Landlord's nddrass ehangas, written consent to install any paneling, flooring, "built in" 6. Security Tenant gave security to Landlord in the paint or wallpaper the House. Tenant must not change or amount stated above. ~ ascurity has been deposited in the impair the plumbing, veetilatlng, air conditioning, electric or Bank named above and delivery of this Lease is notice of theheating systems. If consent is given, the alterations and deposit. If the Bank is not named, Landlord will notify installations will become the property of Landlord when completed and paid for. They will remain as pa~ of the show that this Lease is so subject and subordinate; Tenanl fl'~use at the end of the Tenn. However, Landlord may authorJans Lnn~ord to sign these eertificete(s) foF Tenant. A demand that Tenant remove the alterations nnd instailndons =b~O~ the e~...d o,f the T~J.'~L If Lafldlm, d waots th~m fe~oye~ new °wn~' may want 'l~nsnt to r~maln as a unant under this J-mu'lo~ Mil give Tenant at least 1S-days' notice before the Lease. If the new owner requests, Tenant will sign an and of the Term. Tennnt will comply with the demand at agreement recogeL~ng that. Thh is know as ~t.- "'~ "~ Mmm ,~ nays. At net, Landl~d may M,, ~ L.~j d._ me ri°me OF Inon la re]ten, Landlord may rancel IMs-Leas~ Hen. Landlord's cests shall be added rent. "-' t.--~ v. ~,,~,~ ,,~ on notice M Tenant, The cancehdon dam win be at least 30 days ai~r the notice. If the Lease is cencelle~ Tanant must 9. ~ Tenent must ~ good ce~ of the House nd deliver the House to Landlord on the cancellation date, all equipment, ptc~e~'y and fixtures in iL Landlord will rup~r together with all rent du~ to that date. The entire payment for ~ plumbing, heating and electrical systems, unless caused ny taidng belonp to Landlord. Tenant assigns to Landlord by Tenant's act or neglect. In that case Tenant most, at any interest Tenant amy .l~t. ve to any pe~t of the payment. Tenant's enst, nuk~ nil sepelrs and replacements. If Tenant ..._Tennnt si?l. l_not ~ a elmm. for the value of 0m nnnsining falis to maim a needed repair oF mp~ment, Landlmd may term, or tor 'l~lant s interest in the I ~.n,~ do iL Landlord's ousts will be added rent. - -' 16. Constmc0onordenmlltlon O~m~c~ionordenmll~on 10. Firo, .aecide.n.t, def.~, ts, damage .Te. nant must give may be pa~ hi oF near the Htm~. This shall not affect Landlord immediate notice of fire, accident, damage, or Tenant's obligethien hi this Lease, even if it int~ems with damage within a reasonable time or cancel this Lease. If · .17. No liability for tenant's property Landhird is not Landlord mPah~, Tanent simll pay rent only to the dste of fha fire or damage, and will resume paying rent when ~ House responsible for (a) loss, theft or damage to the Tenant's lX~lxm/, or (b) hijmT censed by tbe Tanant*s lx~t~/or its is usable. Lacdlord may cancel the Lease upon 3-days' notfce use. Landlord does to Temmt. If LandloFd cenceis, rent will be paid to the date of not carry fmumace for Tanent,s penonal the fire or da~ pmp~. Tenant will obtain and pay for that insurance. negligence. Landlord is not liable to Tenant for pe~tting or ,-,~u~mu may glve'lensnt pannissian to use it. Tenant will use rofnsing envy of anyone into the House. ~e ~en at Tenant's own risk and nm~ pay all fees Lm~llord Tenant must pay foF damages an~ end expenses of ~ Len~ord's pannissio~may be caccelled at any time. Landlord mhil~ng to any claim asislng ~.om any act or negienti9. A~anelnthin Tbe House may be part of an -owacts* of Tenant. If an action is. brought against Lmidl0rd because of association,*' "community association," "recreational Tenant's act or neglect, Tenant will defend Landlord at Tenant's expense, with an atto~ey of LandloFd's choice, association" or similar group. In that case, all of the Tenant is responsible foF all acts or neglect of Tanant*s association's roles and mgnlalfons nmst be obeyed. · family, employees, guests or hivitees. 20. Sidewailm, step% t~,nces and balconies The House e at reasonable hours to: seonir, inenect_ e~t~,-,~- ~ ~ apply ~ Ihe sidewalks, st~ tmTace and balcony, a~e spociM rutes, tor ~e stdewalks, steps, terrace and uecmes is necessary or desirable. At reasonable hours belceny. Landlord will no~y ~ of such roles. lnsL~see~ordf ~show.~h~..Honse to ix~ible buyen, leaden or Tennnt must keep the sldewe!ks, steps, tennce and ecs (or me entire ~onse or land, or for the House). Landlord will try to give re.a,s, onable notice, except in ~bai~ny clean and f~e from snow, n.c~ leaves and may or, or ,en t m. st al! i, Sond No coozing ~s uhowan on the sidewalk?, steps, terrace or 8al...c..on. Y. T~ent may mx _~',~p_ plan~ or mmll a lance or eny .= , ,..~ua~.m nas u~ ngl~t to ~'emove and stose them any other person to use the House. Tenan~ must get tsn~ce and balcony in gend rel~F. LandloFd's written pemtission each time Tenant wants to assign or sublet. Permission to ~ or sublet is ~ ,,,,v.. for that aangnment or sublease. Tennnt renmns bound to the shall sign a ceflifieate an~finnJng the following: (I) this tenns of this Icese aftra' an nsignment or sublet is perndttsd, l-man is in full f~ce and unebenged (or jf cfunged, how it even if l.]ndlo~l accepts money from the new assignen or was chan~; (2) LandloFd has fully performed all of the subtenont. The umount ecceptnd will be credited against terms of this Lease and Tenant. has no claim against money due from Tenant, as Landlord shall determine. The Landlord; (3) Tanant is fully perfl~ming all tbe terms of the assignce or subtenant does not become LandloFd's tenant. · Lenan and wH] anotinac to do so; (4) rent and added rant 3~nnnt ~s ruponsihie for acts and neglect of any pe~son in the have been paid to date; and (5) any other reasonable House. including a new assignee or subMnent. statement required by Landlord. The eertificato will be 14. Subordination and attoFnment This Lease and ndd~asedt°tbelm~Landl°rdchecses. Tenant's rights am subject acd subordinate (infe~or) to all prusant and ~utum: (a) lanses ~oF th~ House or tbe lend on 22, (:_ .m~t~.. _7~-,~.'s dehub If.Tam__t hiis to ~mely which it stands, (b) mortgages on the leases ~ the House or coFr~ct a defamt, Lnndl~d may ax'met it at'lbmnt*s expanse. land. (e) agreements securing money i~id or to be paid to a Lnndlord's casts to con'ant the d~'ault shill be added rent. lender, nd (d) terms, conditions renewals, changns of any :23. Teonnt's dut~ to obey laws and rL~qlnt~ons Tenant kind and extensions of the moFtgnges, leases oF lander must, at Tenant's expanse, ~mt,~y comply with all laws, n~r~-mants. For e~onple, if the House oF land is sold hi u orders, rul~s, requests and dimetlons of all gnvernmanfal court proceeding known as "foreclosure," the new owner authorities, t.andloFd% insuru~, Ik~erd of Fit~ Underv~te~s. may cancel this Lense before the Term ends. Tensnt must oF slmilm' groups. Tenant will pron~y deliver to Landlord promptly execute any certifioste(s) that Landlord requests tonotices from any authority, or group. Tenant will not do 24. Tenant's default The followins are not the only paYmlt, damagcs, lessesendenpenses, whlmutof~ rights and remedies. They are in addition to those provided or pmnltted by law. 28. Rules Tenant must comply with these Rul~: Notice of A. T~nant'~ VFairer o.f Notices. Landlord ~hall ~ot b~ new Rules will be given to Tenant. Tenant receives no rights ~ ~mty 6~t ~fum~M *m~fw ~Af r~Ar ~ rfc~pw (1). The comfort or rights of other neighbors must not be yr~m (leto*a) raw Honea. Landlord may give Tenant a tmninatino notice (but Lndlord is not oblJpted to give ~ .(2) Nonoehallowedc~theror~ Nothingn~y beesedi~lzot notica). If give~ the terminmtno notice wm rote the date the m, Pieced on or attscbed to firu escapes, sitis, windo~s ~r Term will end. Tenant must leave the House and give eztedorwalisoftheHouseorinthehallwaysorotherw. A_s. coutinnss to be responsible se stated in this Leese. - (4) Tenent must give to Landimd keys to all lecks. Dours B. If Tenant's application for the House contains any must be loet~_ at all limes. V~ must be locl~ when material mi55h~-ment of faot, that is a defanlL Tenant is out. All Jceys must be returned to Landlord at the C. If (I) the Lesse is tezminated; or (2) rent or added rent is end of the Term. not paid no ~ or (3) Tenant vacates the House; or (4) the T~,u has ended; or (~) Tenant has dehulted in any obligaliou (~ House floors must be covered by carpets or rugs. No under this Lease, Landlord may, in additiou to other rights wats~ are allowed in the House. enter the House and remove Tenant and any person or in Mte Hous~ Feeding them fTm~! the House, sidewalks, steps, the House smd (c) sue for money damages. (7) (]arbuge disposal rules must be followed. Plumbing Hc~*~. the following takes place: (I) Rent end added tmlt for thc unexpJred Te~n becomes due (8) LaandEymechines, Jfeny, am used atTenant,s fislcand and payable at ouce~ (2) Landlord may relet the House and anything in it. The (9);_Imprupedy pariced cars may be removed without notice reLetting may be for any tmn. Lendlord may cl~ any rent at .Tenant's cusL (or no rent) and give allowances to the new tenant. Landlord may, at Tenent*s expense, do any work Landlordvensnoably (I0) Tenant must not allow the cleaning of the windows or for mating. *llment xemalns.liable and is not released em~pt ns provided by law. (11) Tenent sbuil oueserve ene~),. (3) Any mnt mcaived by Landlord for the re.renting thail be (12) TemmtwiillceeptheHousesa~endclesn, andwillnot used first to pay Landlord's expanses and last to pay any store or bring bnTn~dons or flantmable materials into the amounts Tenant owes under th~s Lease. Landlord's expenses House. include the ousts of getting possession and re-renting the (13) Tenant will not threw enytbing from the House, or hang House, including, but not only, reasonable legal less, brokers or ~halce anything fxum sidewalks, steps, windows, tcflaces fees, cleaning and repairing costs, decorating costs and or balcouies. advertising costs. (4) From time to time Landlord may bring actions for 29.' Representations, changes in Lease Tenant has read this waiver of Landlord's rights. Tenant is not entitled to any '1~ are no o~ TMs Lease may be changed only by an excass of rents collected over the rent paid by Tenant to agl~ement in writing signed by and delivered to each pafly. 30. Landlord unable to perform Lan,d, lord m. ay be (~ Money t~ved by Landlord from the next tenant (other de.~yed or unable M:.. (a) carry out Lan.~.ord s prmmses or than the monthly rent) shall not be cousidered ss part of the rent paid to Landlord. Landlord is entitled to all of it. If~ts, (b) provide any servien or u~lity ~quired to be Landlord miata the House, the feet that all.or par ofllm next provided, ~c) malce any required repair or change to the tenent*s ~ is not collected does not al~ct Tenant's liability, Hoese, or (d) supply any equipment or appliances required to Landlord has no duty to collect the next tenant's rent. Tenant be .supplied. Tenant's obligations are not affected it* that must continue to pay rent, damages, losses and expenses, results f~m settling insurance claims, obtaining estimates, without otYset, weather, labor or supply problems, public authorities, Tenant's act or neglect, or any other cause not fully within E. Tenant.will pay Landlord all reasonable costs and Landlord'srensonsbleen~rul. expenses Landlord incurs to enforce Ibis Lease. This includes attomey*sfessandcourtnosts. 31. Endofterm AttheendoftbeTere~Tmumtmustlcave 25. No jury frlal Z~mdAm~u~ ~mr M*f~f rAf~'~Ar ~o wear and tear. Tenant will remove all of Tenent's property, aguins.t the other~ ~or any me. er concerninE ~ Lea~ or all damages to the House caused by moving. Tenant will the House. restore the House to the 'nsme or better condition ns nt the 2~. No mdvw, ~gality Landlord's aCCelX~ of rant or failure to enforce m~y term in ~ Lesse is not a waiver of 32. Space 'ns is" Tenant has iuspac~d the House. Tenant any of Landlmd's rights. If a term in this Lease is illegal or stnt~_ they are in good order and repair end takes the House unenfomesble, the rest of this Lease renudns in full force, asia. 27. Insolvency If(1)Tensntnssigusprepe~yf~-thebenefit 33. QuietF, aJoymnot 8ubject to the tnons of this Lense, ns of c~dito~, or (2) a non=benlm~ptcy mmen or n~e, iver of long as Tenant is not in default, Tenant may peaceably and Tenant or Tenant's pmpmy is appointed. Landlord may give quietly have,, hem and enjoy the House ~ the Tenn. .... ..... ' Noneofthem shall beliableto Temnt e~to any otherpmen for Obligations end when Landlfod's interest in the House is dmnage to the vehicles or any of ils contmts, or othor pmpe~.-.,,~,~u s agenm or employees. · Any vehicle or personal · shall be removed by Tenant within 1 day a~er delive:y of e°nverdanreonly. They should not be used to intupet tbe l. mst written notice to Tenant. If Tenant does not remove it, Landloni may .nnnov~_ the property fn~n the nren. at 'r~n.eo 35. Landlord's consent lfTonant requires Landlord's Isnotresponm'bleforordinarywearandtear. -- consent to any att and such consent is not given, Tennnt's ._o?y ~ is to ask .the Court for a dee~ judgment to 41..Broker Tenant states that no broke, r assisted with 36, Lim~ofreeove~agnlnstLandlord Tenant is limited 42. CareofHouseegnmnda Tanantwillkrepthegreonds to Landlord's interest in the House for pnymont of n judgntnt or othor court tz~edy against LandlonL neat and clean. Vehicles must be d~ven or Im'ked only in driveways or the gnrnge, ..... -_- _ ~ned by all Mu~es. If more thnn one Truant sine mis t,q,.~ m,d. ,t.km ...... ~ Landlmd delivers to mat caen ts folly r~spenslble for performine all obli-.~-- -_~Z_' . "--' ---- "'~Y mu ne joint ann several This means m ~m.s~, nun mr aH payment[. ~anUARANTY OF PAYMENT AND PERFORMANCE Date of ~uarantv .... tor and addrtss ................. ~ ..................................................... L ...... ...................... w.s..,..* ~- ..... '~- ~,.,--., ~mmut mix oemnnaln~ thlt tim Tmmnt 7. ,~nan~s This Guaranty can b~ onl · · ~ Y bY wriUen agreement m~ned by all pm~es to tl~ Lease and this Ous~nty. Signatures WITNESS: ......................... GUARANTOR: ........... STATE OF COUNTY 0F ss.: STATE 0P COUNTY OF ss.: fO~t~flm befmm me. n Nom~ Publ~ in and Im~°anlly :~-.-~ ~' f~ of Imfom me. a Natn~ PnMic in and ~qmusmn a nan~ by Mmdmnlf n tach oflleet, ----'- m~ smrd~ fin' ~ho pmpmm thmln msmah~d. -------- PENNSYLVANIA PLAIN LANGUAGE HOUSE LI:.ASE Notice to T~m.q: This Lease contains waivers of consumer rights. If you do not meet your Lease obligations, you may lose your security deposit. You my also be evicted and sued for money dan~ By si?lng tMs The Landlord and Tenant saree to leue the House on the following terms~ Lease1.4~A, o-'2A r~date~ * ~ Yeu'ly rut ............................................ l, Un ~mu~y~a~va~ of ~e ~L Only a ~n~t nm~ a~ve may us~ ~ is ~ ~ ~y ~ ~ ~ ~ ~Y~ n~s s~. 2. ~ ~ ~ ~on l~.~ s~ m ~ ~ If ~ ~ ~ ~ ~, ~t ~ (~ ~ · it ~ ~ ~t ~ ~ ~ ~nlng ~n~ of ~m ~o~ ~ ~ ~ty. ~at ~nt is due, · e ~. ~t s~ at ~e ~gi~ng of ~e ~ u~ms ~ ~t ~ ~ ~ ~ ~ ~ ~ ~ (~t ~1 ~ ~ ~le ~ ~ is a~le). ~ ~t ~ ~ ff ~t ~) ~y ~ ~ ~ of ~ ~ (ii) ~ a ~nable fim~ ~ ~ ~n~t may ~ ~d pays ~nt on time, and (iii) leaves the House in go~ o~n a ~d ~ m~ey ~. ~ will n~ ~fi~ ~ ~ ~t ~y ~ ~e ~ ~ ~ will ~m~ ~n~ly~~t 3. ~ad~ ~t~~m~d ff~~~H~l~ ~ ~e ~t ~y, nt ~l~'s ~d~s. ~ n~ n~ will I~k only to ~e new buy~ or les~e to ~tum the ~ ~ m ~y ~ ~t ~t m~ ~ ~d ~ ~11 ~t s~u~, ~d ~dl~ ~11 ~ d~ ~le~M ~m all ~ ~ ~ ~n~'s ~t (~d ~y ~ m~'s li&biH~ ~ obligations. ~n~o~ may ~t ~e ~ty ~0 ~H ~ ~d ~m ~ s~ ~ ~ ~t ~y ~whe~ ~i~d by law. ~n~t's secud~ will of ~s ~. ~ ~ not sm~ as such, ~ose o~ h~ ~y w~ ~ n ~ ~ law. chis ~ ~sM~ "~d~ ~nL' ~d~ ~nt will ~ ~nt due. If ~nt fMls to pay thc added ~nt on time, u~ ~ ~ ~ ~ ~fi~ ~ ~ ~d ~ ~ n sm~ a~ ~ hn no oblation m ~ ~ndl~ s~l ha~ ~e s~c fighu against ~ant as if liabfli~ f~ not ~i~ ~ ufiOfi~ ~ ~ys for. 4. ~m ~e ~ will end on the date smted a~v~ ~~'s~~~~ T~nt mu~ n~ ~ a ~shwnsh~, ~j~ ~hine, 5. Notices Any bill, statement, approval, consent, ~, ~, ~, ~la~, ~r ~H~ ~t ~ ~ ~ mint ~ h ~ ~ m ~ it mu~ o~er appliance unless installed by Landlo~ or with ~ ~i~ ~ mailed ~ ~ ~nnnt at ~e Hour. If to ~ndlo~'s wfi~en consent. Tenant must not use mo~ ~dl~, it must ~ m~l~ ~ deli~d to ~ndl~'s ~c ~ ~ ~ ~ ~y ~. n~. R ~H ~ ~ ~ ~ ~ ~y ~ (~ ~ndl~ my ~ s~i~ of ~e plumbi~, heating, given ~ (i) cmified or ~gis~d mail, ~tum ~eipt ~, ~ ~ ~ ~ ~ is ~pl~ ~ ~ (ii) ~d d~ wi~ ~ ~ei~ ~h ~ mm ~ nd ~m ~e n~ ~ by ~e ~. 8. Alte~tions ~nant must obmin ~ndlo~'s prior ~ ~ ~ ~t ~'s ~ c~ ~ ~t m i~ ~y ~ fl~, '~flt in" 6. Secufl~ ~nant gav~ security to ~ndlo~ in ~e ~nt ~ wnll~ ~e H~. ~snt m~ not ~an~c or B~ ~ ~ ~ ~ ~ ~ b n~ ~ ~ heating syst~s. If c~sent is ~, the al~tions and de~i~. If ~e Bnk is not name, Landlo~ will notify installations will ~ome ~e ~ of ~ndl~ when completed nnd paid for. They will remain as part of the show that this Lasso is so subject and subordinate. Tenant Hou.se at the end of the Term. However, Landlord may authorizes Landlord to sign these ce~ficate(s) for Tenant. A demand that Tenant remove the alterations and instalintious new owner may want Tenant to ~ ns a tenent trader tlis bef°~ the and oftheTerm. If Landlord wants them removed, Lease. If the new owner requests, Tenant will sign an Landlord will give Tennnt at lcest 15-days, notice bofore theagreement ~:ognizing that. This is know as ,,attonm~ent.- end of the Term. Tenant will comply with the demand at Tenant's own cost. Landlord is not required to do or pay for 15. Condemnntinn ~Condemnation" means that a legal any work unless slated in this Lease. authority can taha the House or land by paying Landlord. If alian is filed en th~ House for any mason relating to If all of the Hens~ and land is talum, tha Term and Tenant,s Tenant, Tenant must irnmedln~ly pay or bond the amount of rights shall end when the anthadty tal~s title. If any part of ~. R.epnh~ Tenant must tak~ g~..nsec= of the House and deliver th? House to Landlord on the eanenHatlon date the plumbing, heating and eleotrlcel systnne, ouless caused any taking belongs to Lan~ord. Tenant assigns to Landl~d by Tenant's net or neginet. In that ease Tennnt must, at any interest Tenant may have to any pan of the payment. Tenant's cost, mak~ ali repah~ and replacementa. If Tenant Tenant shall not mat-,, a claim for ~ha value of the remalnin~ do it. Landlord's costs will be added rent. 10. l~iro, accident, defeets~ damage Tenant must glv~ ~may be ~ in or near the House. This shall not a~et Landlord immndiate notice of fire, aeeldent, damage, or 'tanant's obhgntious in this Lease, even if it inten%,res with dnngnrous or defective condition. Landlonl may repalr, tha Tenant's ventilatlen, view or enjoyment of the Ho~_,~. damage within a rensoanbin time or cannel this Lense~ If . 1'/. No liability for tenant's property Landlord is not Landlord rel~drs, Tennnt shall pay rent only to the date of the fire or damage, and will resume paying rent when the House ~sponsible for (a) Ions, theft or dumagn to tl~ Tenant's is usable. Landlord may cancel ~e Lease upon 3-days' notice property, or (b) in.~my ~ansed by fha Tenent's p~opan~ or its to Tenant. If Landlord ceneels, rent will be paid to the date of use. Landlord dens not ceny insunnce for Tenant's penonal tbe fi~ or damage. Pn~paltY. Tenant will obtaln and pay for timt insm. ance. IL Liability Landlord is not llable for loss, expens~ or 18. P~ POoI~ lm~ and othar reemalou a~ negliganen. Landlord is not llabla to Tenant for pannlt~ing orI-;andl~d may give Tsuant pennlssiou to use it- Tsunnt will use refvsing ent~ of anyone into the House. ~e area at Tensnt's own risk and umst pay all fses ~ Tenant must pay for dnmagns soffered and expenses of eim~es. Landlord's pannlssio~may be cencellad at any time. Landlord relating to any claim arising ~ any act or neglect l!). Ansneintlon The House may be pan of an "owne~' of Tenant- If an ectinn is brought against Llmdioni bi~anse ofassociation," "eommunlty ansoeiation," "reereatlonal Tenant's ant or neglect, Tenant will defend Landlord at ansooiatlon" or similar group. In that case, all of the Tenant's expense, with an attorney of Landlord's choice. Tenant is re~ponslble for MI nets or neglect of Tenant's association's roles and regulations must be obeyed. · family, employees, guests or invitecs. 20. Sidewalks, steps, terraces and hnlennles 'l'ne House ri)ay have sidewalks, steps, a I~rrsce or halcony. The l~.s of 12. Entry hy Landlord, signs Landlord may enter'the lids Lease apply to the sMewalks, ~ t~race and haleouy, House at rnssonable hours to: repair, inspect, extm-ndnate, and they um eonsidemt pan of ~e House. The Landlord may install maintain, replace or perform other work that Landlord make special roles for thc sidewalks, steps, re,rune and decides is necessary or desirable. At reasonable hours b~lcony. Landlord will notifyTennnt ofsoch roles. Landlord may show the House to lX~slble bnye~, leaden or Tenant must keep the sidewalks, steps, terrace and lessees (of the entire House or land, or for the House). balcony clean and f~e'from snow, ice, leaves and ~oagn. Landlord will try to give reasonable notlen, except in Tenant must keep all sedans and drains in ~ repair. No ~. Landlord may place "for sale" or "for rent~ signs eooklng is allowed on the sidewalks, steps, terrace or on Iha Hnene. hakony. Tenant may not ~ plants, or install a fen~ or any addition, on the sidewalks, s~'pa, ten'ace or belcony. If Teennt 13. AnsL~nment up4 s~blenso Tenant must not assign all or does, Landlord has the right to remove and stm~ them at pan of ~ Lea~ or sublet all ~r pan of the House, or pennlt Tenant's expense. Tenant shMi maintain the sidewalks, Stela, any other person to use the House. Tenant must get terrace and belronyingoodrepak Landlord's writ~n permisslon each ~ Tenant wants to for that ~ or sublease. Tenant remalus bound to the shall sign a conificate co~ifirming the folinwin~: 0) this terms of this lense after an nsa~ent or sublet is pandittod, Lense is in full force and unchangnd (or if clmngnd, how it even if Landlord aceepta money from the new nssignen or was changed); (~) Landlord Ires fully perfonnad M! of the subtenant. The amount aecepted will be credited against terms of this Lease and Tenant has no claim against money due from Tenant, ns Landlord shall determine. The Landlonl; (3) 'llmant is fully perforating MI the terms of the nsalgnen or sabtanant does not become Landlord's tenant. Lease and will continou to do so; (4) rent and added rent Tenant is n~ponslbl~ for aeis and neglect of any pe~onin the have been paid to date; and ($) any other reasonable House, iecludin~ a new nssignen or subtenant, statement required by Landlord. The eenlfieate will be 14. Subordination and attornment This Lease and nddressed to the party Landlord chousns. Tenant's rights um subject and sobordlnate (in~rior) to MI 22. CorrecRng 'l~-,~t's defaulls If Tenant fails to ~imely present and fatore: (a) leases for the House or the land on which it stands, ('o) mortgages on the leases or the House orcotrcet a defunlt, Landi~d may cel~ect it at Tenant's axpense. Innd. (e) ngn~,.'"mants securing mouey paid or to be paid to a Lnndloul's co~s to c~reet the default shMi be nddnd ~ent- lender, and (d) terms, conditions renewals, chnngns of any 23. Teannt~s dnt~ to obey In,~s and ~'t~uintinns Tenant kind and extonalons of the mortgages, leases or lender must, at Tenant's expense, ptmnptly oumply with all laws, agreements. For example, if the House or land is sold in a orders, rains, requests and dictions of all ~overnmental court pro,x, edlng known ns :'foreclosure," the new owner antlmritles, Landlord's insore~, Beard of Fins Unde~wil~s, mn}, cancel this Lense before the Term ends. Tenant must or similer gtoupa. Tenant will l~omptly deliver to Landlord premptly execute nny cenificiie(s) that Landlord requests to notices from any authority or group. Tenant will not do 24. Tenant's default The following are not the only pay rant, damases. 1 _t,~__ ande0tlxmt~wiflmutofrset. rights and remedies. They are in addition to those provided or permitted by law, 28. Rules Tenant must comply with these Rules. Notice of A. Tcnant~t Waiwr o.f Notices. Landlord shall not be now Rules ~ be ~zv~ to ~ Tenant recuives no rights req~red to gi~e Temznt a noti~e of d~,~_,~ oran oppargani~ M com~ 6~zr~ ~fM~a~o ~ Ab ;~A~M ruccA, f (I) The comfixt or rishts of other nuishbors must not be ~'~m ('le,,~*c) tAs Hoffse. Landlord may give Tenant a notice). IF Slvan, the termi,**ion notice will ~ flu date them, placed on or attached to fi~ escapes, sills, windo~,s ~r Term will end. Tenant must leave the House and alye extefiwwsiis offl~eHcoseorlnlhehallwaysoro~hwaxuL~ Landlord the keys on or before the tmninstion ,t,,,_ ~'e~ant (3) Bicl~lus must be stored in dasisnated aruss. continuss to be lmponslble as ststrd in thls Lease. (4) Tenant maat sire to Landlord lcL. ys to aU locks. Doors B. If Tenant's application for the House contains any must be locked at all times. Windows must be 1o~___ when m**,'dal misstatement of fact, that is a default. Tenant is out. All keys must be returned to Landlord at the C. IF (1) the Lusse is tmuinated; or (2) rent er edded rent is end of tbs Tram. not Puid on time; or (3) Tanant vacates the Honse; or (4) the Tern has ended; or (5) Tenant has dohulted in any oblilafion ($7 House floors must be covered by carpets or mfs. No and remedias, take any of the followin~ steps: (a) pancofully(6) DoFS, cats, bltds or other anlm,I, or pats a~e not silowed enter the House and remove Tenant and 'any person or in the Hous~ Feeding them fi~an thc House, sidewalks, steps, the Honse and (c) sun fix money damases. (7) Garbage' dlsposui rules must be followed. Plumbing D. If this Lease is terminated, or Landlord takes back the fixtures and all o*Jw,- properly and equipment must be used (I) Rent and edded rant for the unoxpix~l Term becomus doe und payable at once. (8) Laund~ mncldn~, if any, are used at Tenant's risk mid cost. Instructions must be followed. (2) Landlord may relat the House and anything in it. The ~) Improperly parked cars may be removed witimut notice telatfins may be fix any tenn. Landlord may cha~e any rent at Tenant's cost. may, at Tenant's expense, do any work Landlord rusunably (10) Tenant must not allow the cleauin~ of the windows or ~reis nceded to put the H°u~ in gnod repair and to psepare itother Pan of tbs Honse fl~m the ontside. ranfins' Tencnt remains liable and is not relussed except (11) Tanant shall consetye aner~. as provided by law. (3) Any rent received by Landlord fix the re-reatin~ shall be(12) Tenant will keep the House sef~ and c!-_~, and will not used first to pay Landlord's expenses and last to pay any store or bring hazardous or flammable materials into thc amounts Tenant owes under this Lease. Landlord's expenses House. include the coots of ~otting possession and re-ranfinS the (13) Teusnt will not throw anythins fi. om tbeHonse, or hah~ House, includlnL but not only, reasonable ingal fees, brolo~sor sh._~ anythin~ from siclewsl~; steps, windows, teffaces fees, cleaning and repairing costs, decorating costs and or hlcouies. (4) From time to time Landlord may bring actions for 29. ~tations**.h*,,~es in Lease Tanant has read this waiver of Landlord's rights. Tenant is not entitled to any ~ are no ~ This Lease may be ~ only by an excess of rents collncted over the rent paid by Tenant to qliemant in wrifinS si~ned by and delivemi to each panT. Landlord under this Lease. (~ Money t~ceived by Landlord fi'om the next tenant (other 30. Landlord nnable to perform Landlord msy be dehyed er tmf*ble to: (al carry out 12ndlr~a', ,,,,,,,,~.~.... rent paid to Landlord. Landlord is entitled to all of it. IF a~2t~msuts, (b) prtwido any se~iec or utility requi~i to be provided, (c) make any required repair or changn to the I ~"dlmd feints the Honse, tbe fact that all or pan of tbe next Honse, er (d) supply any equipmant or appliances required to tenant's rent is not collected does not affect Tenant's liability, be supplied. Tenant's oblisations are not affected if that Landlerd has no duty to collect the next tenant's rent. Tenant results from settlins insurance claims, obtsiuing estimates, must continue to pay rent, damages, losses and expenses, without off3et, weather, labor or supply problnms, public authorities, Tenant's act or neglect, or any other cause not fully within F.. Tenant will pay Landlord ail reasonable costs and Landlord's ruannabln coniml. attorney's fecs and coun costs. 31. Endofterm At the and of the Term, Tanantmustlusve the House clean and in snod condMon, subject to o~dlna~ atrialbyj~inan~actionorpromding bronghtl~ either inmliafions, alterations and decorations. Tenant will repair ~ fAe ~AeG/or *my ;;M~r c~ncm-~f~ ~Ab/,fuss or all dama~as to the House caused by moving. Tenant will Ab Horfs~. restore the House to the same or better condition as at the 26. No wldver, Jlle~lity Landlord's acceptance of rent or hJlam to an~ any term in tl~s Lease is not a waiver of 32. Space "us is* Tmumt has inspected the House. Tenant any of Landlmd's rights. IF a term in this Lea~ is ille~ai ors~*~_ they are in snod erda- and relM~r and takes the House unan~ffcusble, the rest of this Lease remains in full force, as is. 27. Insolvuicy IF(1)Tanantas, si, .snspropeflyfixthebenofit 33. QuietEqjoymont Subjert to the temis of this Leasc, as of c~dltors, er (2) a non-bankruptcy trustee or mcuiver of long as Tenant is not in defanlt, Tenant may peaceably and Tenant er Tenant's property is appointed, Landlord may siva quietly have, hold and anjoy the House for the Tem~ 3~. Vehicles The use or storage of Tenant's oF ny other 37. Paflles bound by lense This Lease i~ · . --=-o '" '" ....... pnfli wfully succeed Temnt with paricing, moving or hnndling Tenant,s or any othe~ Ih~ agent of Tannnt or such other penon and not of ~ "'~ '~ ox mc tlouse, OF a lender in pas~,~s___~on. Lmu, lord,s obligations end --- N°n~ofthnn shall be Hable toTerdmt(~to any otherlm~n for when Landlord's interest in the House is the ~et or omission of any employee, or for the loss of or tnuufon~d, Any am Lmdlord may do may be perf(mned by danmg~ to tbe vehlcles or any of ils cnments, nr other pmpatty. Landlmd's agents or employses. which m the opunon of Landlord, zs consideml abandoned, 39. Pam~aph bendhp ~ paragraph headings are for shall be removed by Tennnt within I day after deHve~ of cmtwmienceenly. Theysbeuldnotbe,mM_tojnt~lx~ttheLnue. written notice to Tenant. If Tenant does not remove it, Landlord maY remove the propa~t fmm the area, ntTanant,s 40. Fm'nbldngs IftbeHousuisfumisbed, the fumltum and .,.~.:.~_ ,,._., .... ------o- . ~usco oy, any ~.her iMms ate ~ as is. If an inventory is supplied, · ,.,-,.~. hms mmunes ~ ,~o,,..,.. and ~'-":'- · · Tanant will indanmify and dofand Landlord for nil liabm~i~s~ each 12m~ shall si~n a e°pY' At tbe and °f the Tenu, Tenant shall mturo them clean and in good orde~ nd mpek Tenant 35. LandioFd's consent If Tenant requires Lnndlord's isnotrespansiblnfoFordlnm.ywserandtear. consent to any net and such consent is not given, Tenant's 41. Bn)keF Tenant states that no broker assisted with only ~ht is to ask thn Cmut for a decimtory judgment to force Landl~d to give consent. Tennnt ngreas not to nuke leasing the Ho~e, except the Brok~ nemed in tbe hsuding oF any claim against LandloM for money (or sulym~ct anX sum this Lease. Tenant will pay Landlord any money Landlord from the rent) because such e~msant was not given. ' may spend if this mttemant is incmTect. 36. Lbnit of rseovety np. lnst Lnndlonl Tenant is limited 42. Caro of Home, ~ounds Tenant will keep the ~rounds to LandloFd's interest in the House for payment of a neat and clean. Vehicles must be driven or parked only in judgment oF other court remedy against Landlord. ,-,,v~ mb, nco oy mi pmues, i~ more titan one 'l'enant signs this lease, their liability will be Joint and several Thk means that each b fully respoaslble for performhg all obligations, and for all payments. WITNESS: WITNESS: ......... ..j. . GUARANTY OFPAYMENT AND PERFORMANCE ~}ateofGunrunty .. ~.~.~ . ' ' Ouarnntor and addrus ......................................... .................................. mmmu to. me paymmlt of nwa and othe~ money c~ ..... ; ~ mmou~ any cotmiuOa, it mcmoe~ but ts not ~v exC~hn~m ~ d-l'~se-~ ~h~e---n~-.-e?~eet _This Ou?.n.?.~ll not be affected by any chnn~e in fhe ~ whatsoever. This fnclud~_ h.t ,..,,,, n.,.~*,~., · , ,,. -.~ ,,. ,~'~-wnm. ~ r~ ~raaranty Mil tuna n~ even if i am not a,party u) those chanses' - .................... ,,, 4. Walv~*ofNo~ce t do not have to bo Jnfmmed about any default by Tenant. lwaivenod~ofnonpaM~fnh. S. Perf~mauee IfduTenantdefauhs, d~eLm~dlordmayrequiremetope~fonnwithoutf.tmdenund]~bT~m~ Walvm' ofJury ~ial ?. C~han~ 'l~sOusnntymml~ehans~onlybyv~ffenasmunm~sisnedbyallpa~instothotmt~and~Gu~. Signature WITN~$: ....................................... · · ............................. GUARANTOR: ........................................................................... ~TATE 0F {X)UNTY OF ss.: ~TATE 0F COUNTY 0F ss.: f(~the uf before me, a Nout~, Publlc in sad fOn~the of before me. a I~ PUMJe In and ~he fame h' tho ~ptt.,~.~,~__ __ ~-teh eontahed. ~ In The Court of Common Pleas of ~. Cumberland County, Pennsylvania No. O/-, 20 % OATN We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office wit~ ~Chairman &WA.RD We, the undersigned arbitrators, having been duly appointed and sworn {or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) Arbitrator, · dissents· (Ins. ga~t' ~ame/i f applicable) Date of Hearing: ~/f~ ~Z, ~.OOl ~f ~ Date of Award: ~2~_A ,~,~(3m, ~ ~rman NOTICE OF ENTRY OF AWARD award was entered upon the docket and notice thereof given by mail to the parties or their attorneys· Arbitrator's compensation to be .~.~ ~ ~.,/~ paid upon appeal: - '- Prothonotary