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HomeMy WebLinkAbout11-8895Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Robert C. Bales, Jr. vs. Jodi L. Bales Qt cclltt j/ " 1,111 DEC 22 Phi 2: 30 CUMBERLAND COUNTY PENNSYLVANIA Case Number 2011-8895 SHERIFF'S RETURN OF SERVICE 12/05/2011 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Jodi L. Bales, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Perry County, Pennsylvania to serve the within Complaint and Notice according to law. 12/13/2011 Perry County Return: And now, December 13, 2011 I, Carl E. Nace, Sheriff of Perry County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Jodi L. Bales the defendant named in the within Complaint and Notice and that I am unable to find her in the County of Perry and therefore return same NOT FOUND. Request for service at 1210 Mountainview Road, Shermansdale, Pennsylvania 17090 the Defendant was not found. 12/14/2011 10:15 AM - Elizabeth Muller, Deputy Sheriff, who being duly sworn according to law, states that on December 14, 2011 at 1015 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jodi L. Bales, by making known unto herself personally, at The Cumberland County Sheriffs Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. ELI ETH MULLER, DEPUTY SHERIFF COST: $53.44 December 16, 2011 SHERIFF'S OFFICE OF CUMBERLAND COWDYO FILE U= THE PROTHONOTARY SO ANSWERS, RON R ANDERSON, SHERIFF Goun`"s 11te 8henn. le„ ^.;.,Yt. Inc. M SHERIFF'S RETURN In the Court of Common Pleas Of the 41St Judicial District of Pennsylvania- Perry County Branch No. 2011-8895 Cumberland Co. Robert C. Bales, Jr. & Kelly A. Bales VS Jodi L. Bales 1210 Mountainview Road Sherman Dale, PA 17090 Carl E. Nace, Sheriff, who being duly sworn according to law, says that he made a diligent search and inquiry for the within named Defendant(s) to wit Jodi L. Bales, but was unable to locate him/her in his bailiwick. He therefore returns the within Complaint for the above named Defendant(s) Jodi L. Bales at 1210 Mountainview Road, Shermans Dale, PA 17090. NOT FOUND. DEFENDANT MOVED TO 1310 YORKSHIRE PLACE, ENOLA, PA 17025. Sincerely, Sworn and subscribed to before me this / 3A day of , 2011. F PENNSYLVANIA Carl E. Nace Sheriff of Perry County MARWET F. FUCKINGER, Mctvy NUIC Bloomfield Boro. Parr, Coijrity ROBERT C. BALES JR.and KELLY A. BALES, husband and wife, Plaintiffs. : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA V :NO. 11-8895 CIVIL ACTION c n a µ mcu C- zz? m JODI L. BALES Defendant. Xc) -? CO '?1 expanse WRITTEN DEFENSE Attached you will find the defendant's written defense for civil action NO. 11-8895. Each complaint has been reviewed, examined and a rebuttal has been assigned. I am aware and have noted complaints that I shall be held fully responsible for; however, it is mainly the complaint of beyond normal wear and tear damage that I ask the court to render judgment in my favor. The "premises" were "lived" in for over 12 years, housing the productive lives of two children and their entourage of friends. We began residing at the property when the children were 7 and 8 years of age and vacated the premises at 18 and 20 years of age, therefore the majority of their adolescent lives resided at the property. The increase of rent from $500 a month to $1000 a month is the main reason the property was vacated. I refused to sign a new lease prepared by the landlords. The roots of my family were planted at the property and by no means would I ever intentionally cause damage to the property. In the twelve years that I resided there Robert and Kelly Bales never set foot pass the doorway or requested an inspection of the property. The majority of the decoration, paint and wallpaper, was completed prior to the landlords obtaining ownership of the property. COMPLAINTS 1. AGREE 2. AGREE 3. AGREE 4. DISAGREE, Residing in Enola, PA 5. AGREE 6. AGREE 7. AGREE 8. AGREE 9. AGREE, However I was unaware that I was required to provide a forwarding address. Address was given to the landlord via Robert Bales III (also former resident at property) 10. DISAGREE, The beginner's carpet, ceramic tile and paint was beyond required replacement. Over 12 years was a lot of time to get the quality of life from the grade of material originally installed by builders. 11. AGREE, there was some damage caused to the property, however, the carpet, paint and ceramic tiles were in need of replacement. 12. AGREE 13. AGREE 14. DISAGREE, repairs is a loosely utilized word in this complaint and also confused with necessary replacement by the landlord. 15. AGREE, repetitive of complaint #13 16. AGREE, but not responsible for all repairs listed on the Contractors proposal 17. AGREE, repetitive of complaint #13 18. AGREE 19. DISAGREE, failed to "cure" the breach, I was never given any notice or numerous opportunities by the Plaintiffs. Once move out date was communicated to the plaintiff there was no further communication except for some harassing texts and emails from Robert Bales Jr. against our (Plaintiff, Robert Bales Jr and Defendant, Jodi Bales) daughter (Alicia Bales) and her boyfriend. 20. AGREE, that Defendant paid all of the costs; however, not all damage was incurred by Defendant. There are "normal wear and tear" costs that Plaintiff should have to be responsible for. 21. AGREE It is my request that this Court only award the costs of "damage" to the property and not the "normal wear and tear" replacement that the landlords should be responsible for after 12 and half years of tenant residency. I understand this is a very unique case as the defendant and plaintiff are ex-spouses, however, I would like the court to understand the notice to evacuate the premise was given because the landlord doubled the rent from $500 to $1000 and in an email communication dated 9/8/11 from the landlord to tenant, the landlord stated if I was unable to pay $1000, the landlord was contacting his attorney and shopping for a real estate agent. Also, if I did not sign the lease and return by 9/22/11, the defendant would post a "Notice to Quit" on the front door. The defendant told me if I was unhappy with his actions to sue him, if not then "shut the hell up". This was not a man to discuss lease negotiations; therefore, I had no choice but to evacuate before being evicted. This only allowed me one month and a few days in order to find another residence while going to school fulltime at HACC and working at Bethany Village. I did my absolute best to repair any damage to the property, spackling in the drywall, sanding and painting, shampoo carpets and steam clean tile floors. It is my plea to the court that all of the disagreements and closing statement be considering upon judgment. Respectfully, odi Bales 1310 Yorkshire Place Enola, PA 17025 (717) 579-5520