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HomeMy WebLinkAbout11-8921 SHARON GARMAN, V. JENNIFER LOPIANO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PPNTATCVT VAATTA CIVIL ACTION- LAW NO. 8921-2011 Defendant NOTICE TO DEFEND t`7 ev CD zrn rn z Lor- C-), -am ::u tV ?a r- X r> z C) z co-n 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 32 S. BEDFORD ST. CARLISLE, PA 17013 Dated: I Lf l l By: F L SALZMANN HUGHES, P. C. George F. Douglas, III, Esquire Supreme Court I.D. #61886 354 Alexander Spring Road, Suite 1 Carlisle, PA 17015 Phone: (717) 249-6333 Attorney for Plaintiff SHARON GARMAN, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION- LAW JENNIFER LOPIANO, NO. 8921-2011 Defendant COMPLAINT AND NOW, comes the Plaintiff, Sharon Garman, by and through its undersigned attorneys, Salzmann Hughes, P.C., and avers in support of its Complaint against Defendant as follows: 1. The Plaintiff, Sharon Garman is an individual residing at 1116 Karen Drive, Unit 1, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant, Jennifer Lopiano, is an individual residing at 1141 Pheasant Drive North, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff, as the landlord entered into a Residential Lease Agreement with the Defendant, as the tenant, on June 21, 2011 for the rental of 1116 Karen Drive, Unit 2, Cumberland County, Pennsylvania. A copy of the lease is attached as Exhibit "A". 4. The rent payments per month were $800.00 beginning on June 1, 2011. The Housing Authority of Cumberland County paid $552.00 on behalf of the Defendant and the Defendant was to pay $248.00 per month plus utilities. 5. 'The Defendant was evicted from the property on December 12, 2011. A large amount of debris was left by the Defendant. A number of walls needed to be repaired and painted. 6. "The cost of removing the debris and painting the walls totaled $769.00. 7. The cost to replace four missing door knobs was $72.00. 8. The cost to replace the damaged stove was $380.54. 9. The Defendant did not make any rent payments and the amount of rent owed at the time of the eviction was $1,488.00. 10. The total damages are $1,488.00 in unpaid rent, $1,221.54 for repairs and the cost of the filing fee in District Court of $122.83 for a total of $2,709.54. WHEREFORE, The Plaintiff respectfully requests this Honorable Court enter judgment in favor of the Plaintiff and against the Defendant in the amount of $2,709.54. Respectfully submitted, SALZMANN HUGHES, P. C. George F. Douglas, III, EsclUire Attorney for Plaintiff Attorney ID: 61886 SALZMANN HUGHES, P.C. 354 Alexander Spring Road, Suite 1 Carlisle, PA 17015 SHARON GARMAN, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, : PENNSYLVANIA V. CIVIL ACTION- LAW JENNIFER LOPIANO, NO. 8921-2011 Defendant 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 unsworn falsifications to authorities. (? ; mil'-? ????CJ?`' `?C3./'---? s (? Sharon Garman SHARON GARMAN, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION- LAW JENNIFER LOPIANO, NO. 8921-2011 Defendant CERTIFICATE OF SERVICE I, George F. Douglas, III, of Salzmann Hughes, P.C., hereby certify that a copy of the foregoing Complaint was served this date by depositing the same in the Post Office at Carlisle, Pennsylvania, first class mail, postage prepaid, addressed as follows: Jennifer Lopiano c/o Amy Hirakis, Esq. Mid-Penn Legal Services 401 E. Louther St., Suite 103 Carlisle, PA 17013 Respectfully Submitted, SALZMANN HUGHES, P.C. Date: 1 2- L1 By: eorge F. Douglas, III, E uire Attorney ID: 61886 354 Alexander Spring Road, Suite 1 Carlisle, PA 17015 (717) 249-6333 SHARON GARMAN, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION- LAW JENNIFER LOPIANO, NO. 8921-2011 c x Defendant rnCV --c ? m Cq ACCEPTANCE OF SERVICE "?G C:) p r? -G -.i `4) I accept service of the Complaint on behalf of the Defendant, Jennifer Lopiano, and certify that I am authorized to do so. 0?0 Date