HomeMy WebLinkAbout04-4905COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS NOTICE OF APPEAL
Judicial District, County Of FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. (w/- VQ&- ev I
NOTICE OF APPEAL Ft'?u( ; <,ep4 3Q, Jcov
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on
the date and in the case referenced below.
NAME OF APPELLANT SVgA.t 6k DIST. NO. NAME OF D.J.
-4 SMLaN6 Pn*?y ""I41it h I MAG. 07- 3 -Os C79 y t E Jq. ?LDE2
ADDRESS OF APPELLANT CITY STATE ZIP CODE
Po RtrrT 11:11.4 Eta DF(s(3V(Le P4 171 o S- otot 4
DATE OF JUDGMENT I IN THE CASE OF (Plainm ?kds QN IN, f-004 (Defendant)' J?Pa?
Atu6DSr 31D ZOO 1 Sh NDU?(ulr?s 3reP?ttw ?A, LaK. a SA1 oV SNnr? I- PET A L .. 7
. I SIGNATURE OF APPELLANT OR AWORNEY OR AGENT
DOCKET NO CL,FC,KN
L,- - 0000 a 27 - 0 `f 9?2a?y s-??PN?N "' gnu
This block will be signed ONLY when this notation is required under Pa, f ppell as Claimant (see Pa. R.C.P. D.J. No. 1001(6) in action
R.C.P.D.J. No. 1008B.
This Notice of Appeal, when received by the District Justice, will operate as a befor istnct Justice, A COMPLAINT MUST BE FILED within twenty
SUPERSEDEAS to the judgment for possession in this case.
(20) days after filling the NOTICE of APPEAL.
Sonaton, of Piofhonotaiy 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 District Justice. IF
NOT USED, detach from copy of notice of appeal to be served upon appellee.
PRAECIPE: To Prothonotary
Enter rule upon appellee(s), to file a complaint in this appeal
Name of appellee(s)
(Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
Signature of appellant orattomey or agent
RULE: To , appellee(s)
Name of appellees)
(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 BE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of the mailing.
Date: 20
Signature of prothonotary or Deputy
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTITRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
AOPC 312-02
COURT FILE TO BE FILED WITH PROTHONOTARY
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN rEN (10} DAYS AF ;"ER itimg of fhe notice of appe ?, Ctreck apphcabte hrfxez;.7
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ss
AFFIDAVIT; ( hereby (swear) (affirm) that ; sc"ved
a copy of the Notice of Appeai, Gommorr Pleas No upon the pis2r1ct Justice designated herein ui,
date of service . T10 `-'
{ } _ t_,} by persona( serve y tnertlfied} {registered) mau,
sender's receipt attact:ed rwpto_, and opan the appellee, (,wmiii , on
Xi L by personal service (, by (eedlfied) {registered} mail,
s auger" recel"A att.,!Choo i"eir*eto.
(SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS DAY Or . 20
.
natu re of rff.rot
Ssna;Lire of ofticisf befoo, whom efFldavit was made
Wtle of oTTaai
!'1 N
My commission expires On . 20
r. X,
p rmP`
1r ,
u
f
AOPC 312A - 02
.. vuvrJNWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Mag 015( NO.'.
09-3-05
Dd Name Hon
GAYLE A. ELDER
Address. 507 N. YORK ST.
MECHANICSBURG, PA
Ta(eppdne_ (717 ) 766-4575
SM LONG HOLDINGS
PO BOX 10614
HARRISBURG, PA 17105
NOTICE OF JUDGMENT/TRANSCRI
PLAINT+FF: RESIDENTIAL LEASE
NAME and ADDRESS
rSM LONG HOLDINGS
PO BOX 10614
HARRISBURG, PA 17105
L
VS.
DEFENDANT: NAME and ADDRESS
17055 rSALOV, SHARON L., ET AL.
347 STONEHEDGE LANE
MECHANICSBURG, PA 17055
L
Docket No.: LT-0000227-04
Date Filed: 8/17/04
w
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLAINTIFF
Judgment was entered for: (Name) SM LONG HOLDINGS,
Judgment was entered against CLECKNER, JEFFREY W
Landford/Tenant action in the amount of $ 2,128.50 on 8/30/04
The amount of rent per month, as established by the District Justice, is $
The total amount of the Security Deposit is $ .00
(Date of Judgment)
. 00.
Total Amount Establish d RJ 6ess - Security Deposit Ap li d
Rent in Arrears $ 1, ? g • o? -$ W?
Physical Damages Leasehold Property $ 300.00 -$ .00
Damages/Unjust Detention $ 00 - $ -00
Less Amt Due Defendant from Cross Complaint
Interest (if provided by lease)
UT Judgment Amount
Attachment Prohibited" Judgment Costs
42 Pa.C.S. § 8127 Attorney Fees
11 This case dismissed without prejudice.
0 Possession granted.
Possession granted if money judgment
Possession not granted.
Total Judgment
Post Judgment Credits
Post Judgment Costs
Certified Judgment Total
in a
Adjudicated A ount
$_ 1,69.00
_ $ 300.00
- $_ .0n
- $ .00
$ .on
$ 1,990.00
$- 138.50
$ on
$ 2,128.50
satisfied by time of eviction.
Defendants are jointly and severally liable.
IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN
TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS
OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT, IF ANY. IN
ORDER TO OBTAIN A SUPERSEDERS, THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF
THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL I$ FILED.
IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE PARTY HAS
30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF
COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION.
THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THE NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER
ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT
OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE.
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 DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES,
OR OTHERWISE COMPLIES WITH THE JUDGMENT.
?) , Date / ?. k i 7 , District Justice
certif tha thi' is a true and correct c py of t he rec oproceedings containing the judgment.
Date District Justice
X commission expires first Monday of January, 2006 SEAL
C 315A-03
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND
May. Dist. No.'.
09-3-05
OJ Name. Hon.
GAYLE A. ELDER
aaaass_ 507 N. YORK ST.
MECHANICSBURG, PA
reieanoe:(717) 766-4575 17055
SM LONG HOLDINGS
PO BOX 10614
HARRISBURG, PA 17105
NOTICE OF JUDGMENT/TRANSCRIF
PLAINTIFF: RESIDENTIAL LEASE
NAME Id ADDRESS
FSM LONG HOLDINGS
PO BOX 10614
HARRISBURG, PA 17105
L
vs.
DEFENDANT: NAME and ADDRESS
rSALOV, SHARON L., ET AL.
347 STONEHEDGE LANE
MECHANICSBURG, PA 17055
L
DocketNo.: LT-0000227-04
Date Filed: 8/17/04
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLAINTIFF
?X Judgment was entered for: (Name) SM LONG HOLDINGS,
Judgment was entered against SALOV, SHARON L.
Landlord/Tenant action in the amount of $ 2,128.50 on 8/30/04
The amount of rent per month, as established by the District Justice, is $
The total amount of the Security Deposit is $ .00
(Date of Judgment)
.00.
Total Amount Establish id bbyY DJ 00 Less Security Deposit Apli d
Rent in Arrears $ ?, 690. - $ U? _
Physical Damages Leasehold Property $ 300.00 -$ .00
Damages/Unjust Detention $ 00 - $ .00
Less Amt Due Defendant from Cross Complaint -
Interest (if provided by lease)
UT Judgment Amount
? Attachment Prohibited/ -? Judgment Costs
42 Pa.C.S. § 8127 Attorney Fees
? This case dismissed without prejudice.
0 Possession granted.
Total Judgment
in a
Adjudicated69A p urb
1
$
300.00
$ .00
$ .00
$ .00
$ 1,990.00
$ 138.50
$ .On
S 2,128.50
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
? Possession granted if money judgment is not satistled by time of eviction.
r?
LJ Possession not granted. ? Defendants are jointly and severally liable.
IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN
TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS
OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT, IF ANY. IN
ORDER TO OBTAIN A SUPERSEDEAS, THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF
THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED.
IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE PARTY HAS
30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF
COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION.
THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THE NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER
ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT
OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE.
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 DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES,
OR OTHERWISE COMPLIES WITH THE JUDGMENT.
Date /,o'? ?• ??(?'/?? ( District Justice
I certify that this is a true and correct c pd y of the recordof the proceedings containing the judgment.
Date , District Justice)
My commission expires first Monday of January, 2006 SEAL
AO C 315A o3
C) o
o -n
r;rr C? ia7p?
ri
W z?t:?
r C.
cXf
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 OF PENNSYLVANIA
COUNTY OF (?iv1 &p7, JA j lb ; ss
AFFIDAVIT: I hereby (swear) (affirm) that I served
a copy of the Notice of Appeal. Common Pleas No. /,'ti en toe District Justice desi0nated the?•nin on
n
4
(date of service}' ? , 20 p L7 by personal service Eby (certified) (registered} mate
sender's receipt attached hereto, and upan the appellee, (narne)s?fi4??a_J?, S? Lout 1fddr*w' G°n
20 p Ej by personal service by {eeref ed) treyisterd) mall.
sender's receipt attached hereto.
(SWORN} FFiRMED) ANDS gCRIBED BEFORE ME
THIS DAY OF 200 .
Signature of o%icol before whom, affil wit was made
Title of ofec al
My commission explrc-ill gaol 20
Steven B. Worley, Notary Public
East PennsboroTwp., Cumberland Counry
My Commission Expires Dec. 10, 2004
m5 rnber, Pennsylvania Association of N=rics
? r ? SN}nUhure of,yGaDt
AOPC 312A - 02
I ti OF YCNNbYLVANIA
COURT OF COMMON PLEAS
CI g?Judfcial District, County Of rV.# 1zL-0V'b
440'A???" ?x?7 0j2,r sv
COMMON PLEAS No. py- S/QXr
NOTICE OF APPEAL r- led ; '5?P'}, :)L?..7cby
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on
the date and in the case referenced below.
- c-
0 -RM 1014 1 HAa.ws Pa 1-710
DATE OF JUDGMENT IN THE CASE OF (PlaintM L oA14
A %147- 310 200 S h LOINK "i)LbIYQ s 5-m "cei j,. LooA,
DOCKET No. SIGNATURE
L'r- - oooo 227 - O5? <1
This block will be signed ONLY when this notation is required under Pa. ajAppE
R.C.P.D.J. No. 10086.
This Notice of Appeal, when received by the District Justice, will operate as a beforel
SUPERSEDEAS to the judgment for possession in this case. l
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
(DefaOd.Ol "I
SNAIi'uo L, tT A L " R' W.
y S?PNEN K. LOWJ
Claimant
Justice, A COMPLAINT MUST BE FILED within twenty
(20) days after filing the NOTICE of APPEAL.
Signature ofP honotaryor 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 District Justice. IF
NOT USED, detach from copy of notice of appeal to be served upon appellee.
PRAECIPE:. To Prothonotary
Enter rule upon
Name of appellee(s)
(Common Pleas No.
appellee(s), to file a complaint in this appeal
) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
Signature of appellant or attorney or agent
RULE: To , appellee(s)
Name of 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 MAYBE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of the mailing.
Date: 20
Signature of Prothonotary or Deputy
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
AOPC 312-02
COURT FILE
COMMONWEALTH OF PENNSYLVANIA
r )i InITV nF- CUMBERLAND
Mag. Dist. No.:
DJ Name. Hon.
09-3-05
GAYLE A. ELDER
Ado'- 507 N. YORK ST.
MECHANICSBURG, PA
Teiephone: (717 ) 766-4575
17055
SM LONG HOLDINGS
PO BOX 10614
HARRISBURG, PA 17105
NOTICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF: RESIDENTIAL LEASE
NAME and ADDRESS
FSM LONG HOLDINGS
PO BOX 10614
HARRISBURG, PA 17105
L J
Vs.
DEFENDANT: NAME and ADDRESS
rSALOV,. SHARON L., ET AL.
347 S91ONEHEDGE LANE
MECHANICSBURG, PA 17055
L J
DocketNo.: LT-0000227-04
Date Filed: 8/17/04
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLAINTIFF
?X Judgment was entered for: (Name) SM LONG HOLDINGS,
Judgment was entered against SALOV, SHARON L. in a
® Landlord/Tenant action in the amount of $ 2,128.50 on 8/31/04 (Date of Judgment)
The amount of rent per month, as established by the District Justice, is 9; .00.
The total amount of the Securitv Deposit is $ .00
Total Amount Established by J Less - Security Deposit ApDligd =
Rent in Arrears $ 1.695.00 - $_ •UO
Physical Damages Leasehold Property $ 300.00 - $_ 00
Damages/Unjust Detention $ 00 - $_ -no
Less Amt Due Defendant from Cross Complaint -
Interest (if provided by lease)
UT Judgment Amount
? Attachment Prohibited/ Judgment Costs
42 Pa.C.S. § 8127 Attorney Fees
? This case dismissed without prejudice.
Possession granted.
? Possession granted if money judgment
? Possession not granted.
Total Judgment
Post Judgment Credits
Post Judgment Costs
Certified Judgment Total
$
t
Adjudica1ted Amou0n0
690
$ 300.00
$ .00
$ _00
$ _on
$ 1,990-00
$ 138.50
$ _00
$ 2,128.50
? Defendants are jointly and severally liable.
IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN
TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS
OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT, IF ANY. IN
ORDER TO OBTAIN A SUPERSEDEAS, THE APPELLANT MUST DEPOSIT WITH THE PROTHHONOTARY/CLERK OF COURTS THE LESSER OF
THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED.
IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE P4RTY HAS
30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF
COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION.
THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THE NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER
ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT
OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE 114TERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES,
OR OTHERWISE COMPLIES WITH THE JUDGMENT.
COMMONWEALTH OF PENNSYLVANIA
,.,,, i,.,TV CUMBERLAND
No.:
DJ Name'. Hon.
09-3-05
GAYLE A. ELDER
Address. 507 N. YORK ST.
MECHANICSBURG, PA
T.i.,„one: (717) 766-4575
17055
SM LONG HOLDINGS
PO BOX 10614
HARRISBURG, PA 17105
NOTICE OF JUDGMENT/TRANSCRIPT
RESIDENTIAL LEASE
PLAINTIFF: NAME and ADDRESS
FSM LONG HOLDINGS
PO BOX 10614
HARRISBURG, PA 17105
L J
Vs.
DEFENDANT: NAME and ADDRESS
FSALOV, SHARON L., ET AL.
347 97ONEHEDGE LANE
MECHANICSBURG, PA 17055
L J
DocketNo.: LT-0000227-04
Date Filed: 8/17/04
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLAINTIFF
® Judgment was entered for: (Name) SM LONG HOLDINGS, in a
Judgment was entered against CLECKNER, JEFFREY W
® Landlord/Tenant action in the amount of $ 2.128.50 on 8 30/04 (Date of Judgment)
'6 .00.
The amount of rent per month, as established by the District Justice, is
The total amount of the Security Deposit is $ .00
Total Amount Established b?SJ 0Uuess • Security Deposit ApWWd =$ AdjudicatedArrlounb
Rent in Arrears $ , 6 - $_ pp = $ 11 b63yy0000.0000
Physical Damages Leasehold Property $ 300.00 -$_ -00
Damages/Unjust Detention $ 00 -$ _ no = $
Less Amt Due Defendant from Cross Complaint - $ .00
Interest (if provided by lease) $ -00
UT Judgment Amount $ 1,990.00
? Attachment Prohibited? Judgment Costs $ 1 38.50
42 Pa.C.S. § 8127 Httorney Fees $ -00
? This case dismissed without prejudice. Total Judgment $ 2,128.50
Post Judgement Credits $
® Possession granted. Post Judgment Costs $
Certified Judgment Total $
? Possession granted if money judgment is no sa Is le y Ime o evlc u>n.
? Possession not granted. ? Defendants are jointly and severally liable.
IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN
TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS
OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT, IF ANY. IN
ORDER TO OBTAIN A SUPERSEDEAS, THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF
THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED.
IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE PARTY HAS
30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF
COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION.
THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGIAENT/TRANSCRIPT FORM WITH THE NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER
ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT
OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE .
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 DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES,
OR OTHERWISE COMPLIES WITH THE JUDGMENT.
Date District Justice
s a true an correct copy or ure record of t proceedings Containing me iu gment.
Date District Justice
ORIGINAL
Stephen M. Long and Susan Long,
t/b/a S.M.L. Luxury Townhouses and
S.M. Long Holdings
Plaintiff
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-4905 Civil
CIVIL ACTION'- LAW
Sharon L. Salov and Jeffrey Cleckner
Defendant
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 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, 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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108 or (717) 249-3166
AVISO
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas
que se presentan mAs adelante en las siguientes paginas, debe tornar accibn dentro de los
proximos veinte (20) dias despu€s de la notificaci6n de esta Demanda y Aviso radicando
personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por
escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le
advierte de que si usted falla de tomar accibn como se describe anteriormente, el caso puede
proceder sin usted y un fallo por cualquier suma de dinero recl.amada en la demanda o cualquier
otra reclamacion o remedio solicitado por el demandante puede set dictado en contra suya por la
Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos
importantes para usted.
LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE.
SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA.
ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO
CONSEGUIR UN ABOGADO.
SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE
AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A
PERSONAS QUE CUALIFICAN.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108 or (717) 249-31166
Stephen M. Long and Susan Long, IN THE COURT OF COMMON PLEAS
t/b/a S.M.L. Luxury Townhouses and CUMBERLAND COUNTY, PENNSYLVANIA
S.M. Long Holdings
Plaintiff
NO.
V.
CIVIL ACTION - LAW
Sharon L. Salov and Jeffrey Cleckner,
Defendant
COMPLAINT
AND NOW, come Plaintiffs and file this Complaint at law setting forth in support
thereof as follows:
1. Plaintiffs herein are Stephen M. Long and Susan Long, husband and wife, of
Harrisburg, Dauphin County, Pennsylvania.
2. Plaintiffs are doing business trading as S.M.L. Luxury Townhouses and also
known as S.M. Long Holdings.
3. Defendants are Sharon L. Salov and Jeffrey Cleckner, formerly of 347
Stonehedge Lane, Mechanicsburg, Pennsylvania.
4. On the 22nd day of March, 2004, Plaintiffs and Defendants signed a written
agreement for Defendants to rent from Plaintiff, the property of Plaintiffs situate at 347
Stonehedge Lane, Mechanicsburg, Pennsylvania, 17055. A, copy of this Agreement is
attached hereto as Exhibit A.
5. Defendants were in occupancy of the premises from approximately the 26th
day of March 2004 through the 2nd of September, 2004.
6. Pursuant to the terms of the lease agreement, the monthly rental was
$1,250.00, for the term of one year.
Plaintiffs have violated the terms of the lease agreement in the following
respects:
A. Defendants have failed to pay rent for the months of July and August,
for a total monthly rental due of $2,500.00.
B. Defendants have damaged the property by melting siding with a
outdoor charcoal grill, resulting in a cost of repair of $600.00.
C. Defendants flushed non-flushable paper towels down the commode,
in violation of the lease agreement, causing sewer blockage! and causing the line to have
to be flushed out and partially rebuilt at a cost of $1,600.00.
8. Under the terms of the lease agreement, Defendants owe ?..a for the
balance of the year/7 months or $8,750.00.
9. Plaintiffs have demanded and Defendants have refused to pay the sums.
10. Under the terms of the lease agreement, Defendants are required to pay
reasonable attorney's fees and other costs of bringing action under this lease agreement.
2
Defendants in the amount of $11,450.00,
reasonable attorney's fees.
together with interest, costs of suit and
Respectfully submitted,
/Fy?/f' I?
Date
WHEREFORE, Plaintiffs respectfully request judgment in their favor against
KENNETH A. WISE, ESQUIRE
Attorney I.D. No. 16142
Graiybill & Wise, P.C.
126 Locust Street
P. O. Box 11489
Harrisburg, PA 17108-1489
(717) 238-3838
Attorney for Plaintiffs
THIS IS A LEGAL DOCUMENT.
Iq ?
DO NOT SIGN THIS LEASE AGREEMENT
UNTIL YOU HAVE READ IT CAREFULLY.
Coversheet
LEASE AGREEMENT
THIS IS A LEASE.
The Owners names are: Susan M. Long and Stephen M. Long
The Tenant(s)' name(s) are: Sharon Salov and Jeffrey Cleckner
Tenant(s)' Social Security Number: Sjtt-u ,t- tt, 2. y y_ c, p q
je 1m' IS 5- S4-b39'1
Tenant(s)' Driver's License Number: &,arm iiyiagcy
JeR aa1v5S?
Tenant shall rent property from the Owners;
Susan M. and Stephen M. Long a.k.a. SML LUXURY TOWNHOMES
a Townhouse located at 347 Stonehedge Lane, Mechanicsburg, Pa 17055: ("premises")
The Lease begins on APRIL 1ST, 2004
The Lease ends on MARCH 31ST, 2005
Owners and Tenant(s) agree upon the following terms and conditions:
RENT
The rental payment is $15,000 per year.
Tenant must pay the rent in monthly installments of $1250.00 on the first day of each month
in advance. The rental payment must be made out to s. M. LONG and arrive at
P.O. BOX 10614 HARRISBURG, PA 17105-0614 by the first of the month
Tenant shall also pay to Landlord an additional $34.00 per month
the cost of sewer rental and trash removal charged by the Municipality.
LATE FEES AND CHARGES
2. Tenant shall pay a late charge of $10.00 per day beginning on the 2nd day of each month
for any and all unpaid balances.
In order to avoid late charges, the monthly rent payment and any additional fees must arrive at.
P. O. BOX 10614 HARRISBURG, PA 17105-0614 by the first. of the month.
If any rent check is returned to Owner by a bank for insufficient funds or any other reasons,
Owner will charge Tenant a $50.00 service charge in addition to any other charges which Owner
must pay.
WAIVER OF NOTICE TO QUIT
1 Tenant agrees to surrender the premises when the lease ends for whatever reason
(default, expiration or otherwise) without notice from Owner whatsoever.
Tenant will not require Owner to provide the usual notice to quit. If Owner tries to get back the
premises for any reason whatsoever, Tenant specifically waives the right to three (3) months
notice and to fifteen (15) or thirty (30) days notice or any other notice required under the Landlord
and Tenant Act of 1951, as amended.
Tenant agrees that no notice whatsoever shall be required.
TERMINATION AND RENEWALS
4. This lease agreement shall automatically end at the end of the lease term unless both
parties agree in writing before the end of the lease term. At the end of the lease term,
Owner may raise the rent or change any part of this lease. Owner also may get the
premises back at the end of the lease term.
2
UTILITIES
5. Owner and Tenant agree that the cost of utilities shall be paid as follows:
UTILITY/SERVICE
Heating of Premises TO BE PAID BY
Heating of Water for Premises Tenant -
Electricity Tenant
Gas Tenant
Water Tenant
Sewage Tenant
Trash Tenant
Telephone Tenant
Cable TV Service Tenant
Janitor Service Tenant
Air Filtration Devices Tenant
Water Filtration Devices Tenant
Lawns care Tenant
Landscaping Home Association
Leaf Removal Home Association
Snow Removal -Parking Lots & Main Sidewalks Home Association
'From Door to Main Sidewalk & Pati Home Association
o must be done by
Homeowners Association Dues Tenant
HVAC Service Landlord
Landlord
Owner shall have the right temporarily to stop the services of any utility in the event of an
accident affecting the same or to make repairs or alterations made to the Building.
USE AND CARE OF PREMISES
6. Care. Tenant shall be careful in the use of the premises, the appliances, and all other
parts of Owners property. including, but not limited to, washer and dryer, electric range,
refrigerator, trash compactor, dishwasher and garbage disposal. In the event that any of the
foregoing appliances shall not be repairable, Owner will, at Tenant's expense, replace said
appliance. Owner shall have full discretion as to whether any given appliance shall be repaired
or replaced. When this lease ends, Tenant shall repair all appliances not in working condition,
at Tenant's expense. Tenant shall not use expansion type screw; in walls to hang anything,
In the event that any holes are created, the tenant must at their expense make repairs to owner's
satisfaction, e.g. unnoticeable. Owner shall deduct the cost of the repairs from Tenant's security
deposit.lf the security deposit does not cover the cost of repairs, Tenant shall pay the excess.
3
IF NOT ACCEPTABLE BY OWNER TENANT MUST PAY TO HAVE THE PREMISES
PROFESSIONALLY CLEANED OR RESTORED TO ORIGINAL CONDITION IF NOT
ACCEPTABLE BY OWNER SO NEXT OCCUPANTS CAN TAKE IMMEDIATE POSSESSION.
Tenant shall not permit or allow any smoking of any kind in the Townhouse.
7, Use. Tenant may not conduct a business or profession in the premises.
Tenant may do nothing more than live in the premises.
Tenant shall not permit or allow anything to be done or kept upon or within the premises which
will interfere with the rights of the other occupants, annoy them with unreasonable noises or
otherwise. Tenant shall not commit or permit any nuisance in the premises.
Tenant shall not commit or allow any immoral or illegal act in the premises.
Tenant shall comply with all rules and regulations of the Homeowners and/or
Condominium Association.
RULES AND REGULATIONS CONCERNING USE AND OCCUPANCY
8. Tenant must obey the following rules in order to stay in the premises:
A. No dog, cat or other animal of any kind will be brought, permitted or kept in the
Townhouse or elsewhere on the Owner's property without Landlord's signed (Pet Addendum).
In addition to the penalties contained in this lease,
against Tenant for any animal found on the premises.
Owner may assess a $1001month charge
4
PETADDENDUM
We the undersigned agree to pay for professional carpet cleaning
When we vacate the leased townhouse located at
,47 Stonehedge Lane Mechanicsburg, Pa 17055
If cleaning of the carpets does not remedy the stains and or odors and other associated
damages with our use of the townhouse by us and our pets,
We agree to pay all associated costs for replacement to ORF's CARPET for the said
damaged carpets and floors.
If tenants remain for a period of ten years or longer, this repair and replacement
agreement is invalid do to average wear and tear and you will not be charged for cleaning
or repair of the carpets.
TENANTS:
Sharon Salov A W.U,0 P. DATE 311E 1 oy
Jeffrey Cleckner 6!!y- DATE 3010
OWNERS:
Susan M. Long j( /? lYl l.?wk DATE 3 - 2-'- -U
Stephen M. Long _ DATE y
B. Tenant(s), members o7hifamily, his (their) visitors and servants shall not at
any time make any noise or do anything which disturbs any other resident or interferes with
the rights, comfort, or conveniences of any other resident. Musical or sound reproducing
instruments or singing within the Townhouse shall be inaudible outside the apartment
between 11 o'clock each night and 9 o'clock the following morning.
5
C. No resident shall place or permit to be placed or maintained any sign or advertising
matter or device or any roof aerial or other structure in any window of the Townhouse
or elsewhere or upon the Owner's property. No resident shall place or permit to be
placed or maintained any awning, screen, shade or blind) in or at any window of the
Townhouse without prior consent of the Owner. Damage to storm doors and windows
due to negligence will be the responsibility of the Tenant.
D. Tenant shall use plumbing and electrical installations only for their intended purposes
and shall be fully responsible for the maintenance of same and for cleaning
any stoppages in waste water lines.
DO NOT FLUSH FEMINE HYGINE PRODUCTS OR PAPER TOWELS DOWN TOILET.
E. Maximum occupancy: no more than 2 person(s) will be permitted to occupy the unit,
designated as the Townhouse at 347 STONEHEDGE LANE MECHANICSBURG PA 17055
IF ANY UNRECORDED GUESTS ARE REPORTED, YOU WILL BE CHARGED 550.00 PER DAY PER GUEST.
Tenant(s) agree(s) that Owner may change these rules from time to time
as may be required to protect the Townhouse or Owner's other property or add to Tenant's
enjoyment of it.
G. Tenant is required to sign the release of liability document if they utilize the use of the
STONEHEDGE PRIVATE FITNESS ROOM.
H. Any window or other glass broken during the term of this lease shall be the
responsibility of Tenant.
Tenant shall be responsible for routine maintenance of the HVAC filters
and the refrigerator water filter.
J. Tenant must place all trash and rubbish in bags inside containers. Tenant shall keep
the premises in good and sanitary condition.
K. Tenant shall not change locks or install additional locks, without the written consent of
Owner.
.Tenant shall not use or store any kerosene or space heaters in the premises.
6
RIGHTS AND RESPONSIBILITIES
9. Delivery of Possession by Owner. If, due to circumstances beyond
Owner's control, the premises shall not be ready for Tenant to move in at the beginning of
the lease term, this leased proportionately until the premises are ready. Owner shall not
be responsible for delay. If the premises shall not be ready sixty (60) days after the
beginning of the term, Tenant shall have the right to cancel this lease by written notice
delivered to owner at any time after sixty (60) days, but not after the unit is ready. This
cancellation shall be Tenant's only remedy. Upon such cancellation neither party
shall have any further rights against the other. Owner shall repay any
deposit made by Tenant. If Tenant shall move in before the beginning of
the lease term, the terms of this lease shall apply. Tenant shall pay, before moving in,
rent for the same period from the date of moving in to the beginning of the lease term.
10. Damage by Fire. If the premises are damaged by fire or other casualty.
Owner shall repair within a reasonable time.
Rent shall continue unless the casualty renders the unit unlivable, in
which case this lease shall terminate. Tenant, upon payment of all rent
to the date the unit is surrendered, shall not be liable for any further
rent. If only a portion of the premises is unlivable, the Tenant may,
with the mutual agreement of Owner, choose to continue in possession and
shall be entitled to a reduction in the amount of rent. Tenant may
still end the lease if repairs are not made within ninety (90) days.
7
11. Property Damage and Personal Iniury.
Tenant agrees that Owner shall not be responsible for property damage or
personal injury occurring on the premises unless the damage or injury
results directly from Owner's negligence. Tenant must buy, at Tenant's
expense, a Tenant's Homeowner's Policy to insure against personal injury
to Tenant, other occupants, guests, or visitors, that occurs on the premises.
12. Right of Entry Owner, or any person authorized by Owner,
shall have the right to enter the unit at reasonable times to inspect, replace appliances as
needed, and to show the unit to prospective tenants.
Owner shall give Tenant notice of his or their intention to enter, if possible.
Notification shall not be necessary in case of emergency.
SECURITY DEPOSIT
13. Tenant paid as security deposit by personal check in the amount of :
TWELVE HUNDRED FIFTY DOLLARS
before moving in to the unit. The security deposit shaft be held by Owner as
security for the payment of all rent and other amounts due from Tenant to Owner, for the
Tenant's performance of this lease and against any damages to the premises or Owner's
property caused by Tenant, Tenant's family, other occupants or guests.
Following the termination of this lease, Owner shall return the security deposit, less
any deductions from it on account of amounts owed by Tenant to Owner, by check payable
to all persons signing this Iease.Tenant must furnish a mailing address in writing within
thirty (30) days after moving out. If Tenant does not provide this mailing address, the
security deposit may not be returned.
8
MISCELLANEOUS
15. Subordination. Any bank or other party with a lien or mortgage on the
premises has a stronger claim to the premises than the Tenant. Tenant agrees, on
request, to sign papers in favor of any such lienholder. If Tenant fails to do so, Owner
may do so in the name of Tenant.
16. Assigning and Subletting. Tenant shall not assign this lease or sublet all or
any portion of the premises without Owner's prior written consent.
17. Declaration of Governing Laws. Any disputes shall be decided in
Pennsylvania under Pennsylvania law.
18. Cumulative Remedies. There are many remedies which Owner may use
against Tenant. Owner may use art of them or some of them. Owner may even use
remedies which might not be in this lease.
19. Entire Agreement and Modification This lease is the entire agreement
between owner and Tenant. Any other agreements shall be void unless they are
signed by both Owner and Tenant. Any agreement signed before this lease is void.
20. Lease Binding Upon Heirs Executors Administrators. Successors and
Assigns. The term "Tenant" shall mean everyone who signed this lease as Tenant. The
liability of each such person shall be joint and several. Each tenant shall be responsible for
Tenant or by any such person to Owner, shall bind all persons signing this lease as
Tenant. The term 'Tenant' shall also refer to any persons named as heirs, executors,
administrators or successors of Tenant as if the full rental payment. Notice given by
Owner to any person named as they were in every case named in this lease.
10
21. Severability. If any provision of this lease shall be declared invalid or
unenforceable, the remaining provisions of this lease shall continue in full force and effect.
IN WITNESS WHEREOF, the parties hereto, intendling to be legally bound hereby,
have hereunto set their hands and seals the date and year first-above written.
TENANTS:
Date: 3 1 ? 10 L' Sharon Salov
Jeffrey Cleckner
OWNERS:
Date: 7 y b Susan M. Long
/ ---- (SEAL)
Stephen M. Long
11
VERIFICATION
Upon my personal knowledge or information and belief, I hereby verify that the
facts averred in the foregoing Complaint are true and correct to the best of my
knowledge, information, and belief. I understand that false statements or averments
therein made will subject me to the criminal penalties of 18Pa.C.S. § 4904 relating to
unsworn falsification to authorities.
Date: may, 2ao
VERIFICATION
Upon my personal knowledge or information and belief, I hereby verify that the
facts averred in the foregoing Complaint are true and correct to the best of my
knowledge, information, and belief. I understand that false statements or averments
therein made will subject me to the criminal penalties of 118Pa.C.S. § 4904 relating to
unsworn falsification to authorities.
Date:
SUSAN LONG
CERTIFICATION
I hereby certify that I am this day serving a true and correct copy of the attached
Complaint on the following individual by First Class U.S. Mail addressed as follows:
Sharon L. Salov and Jeffrey Cleckner
347 Stonehedge Lane
Mechanicsburg, PA 17050
SGT O?i
Date
KENNETH A. WISE, ESQUIRE
Attorney I.D. No. 16142
Graybill & Wise, P.C.
126 Locust Street
P. 0. Box 11489
Harrisburg, PA 17108-1489
(71'7) 238-3838
Attorney for Plaintiffs
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Prothonotary
County of Cumberland
Cumberland County Courthouse
Carlisle, PA 17013
Re: Long V. Salov et al
No.: 044905 Civil
Dear Sir:
Enclosed you will find defenses/objections to the claims set
forth by Stephen and Susan Long. I am responding after the
twenty days because the attorney representing the plaintiff sent
paperwork to me with postage due on October 25 and I did not
pick up the envelope because I did not recognize the name of the
sender. 1 did receive the package by regular mail on Tuesday,
November 16th.
Respectfully,
; "V.
Sharon Salov
DEFENSES/OBJECTIONS TO COMPLAINT
1. Approximately four days after moving into the property at 347 Stonehedge Lane
Mechanicsburg, PA 17055 we began experiencing it problem with the plumbing.
The toilet in the downstairs bathroom began overflowing and could not be plunged
clear. This problem was reoccuring and the landlord) failed to fix the problem until
the neighbors complained of raw sewage overlowing in the front yard of the property.
We used only paper products appropriate for the system. We did not flush anything
that was not suitable to the system. As I have stated, the problem began only four
days into the lease term. Please see the letter written to Mr. and Mrs. Long on July 8.
(Attachment #1). Upon moving into the property we did notice there was a sink hole
developing in the front yard and the sidewalk had begun to pull away from the yard.
The hole was developing immediately above the sewage pipe. This hole had became
a source of concern for the entire neighborhood because they all feared there was
a problem with the building of the townhouses and that they would have problems with
their sewage systems as well (see attachment #2). Mr. Long took responsbility
for the problem until we announced to him that we were breaking the lease and moving.
2. Mr. and Mrs. Long agreed to giving us the month of July free of rent because of all the
problems we had with the property (see attachment #3). On August 1 Mr. and Mrs.
Long began showing up every day demanding the August rent payment. At that point
we were still not sure we would continue to be tenants of the Longs because they began
to exhibit very demanding behavior. Our decision was made final on August 12 at 10:40
p.m. when Mr. and Mrs. Long showed up at the property demanding money. They blew
their hom continuoulsy for several minutes, flashed their headlights and flashlights in the
windows of the house, and rang our phone several times. I went to the door and Mrs.
Long stated that they wanted their money. I told Mrs. Long that we were not paying
because we are moving out of the property and I told her she was to file paperwork with
the District Justice. She said they would. She walked away and then Mr. Long ran up
the sidewalk and demanded that we get out immediately. He was screaming and
cursing at me to "get out now". Approximately four days later we received notice from
District Justice Elder of a possession hearing on August 26th. I attended the hearing
and on August 30th, she granted possession. We had already moved out of the
property completely by that date. (see attachment 44) 1 told the Judge on that day Vt
Mr. Long had sued his last tenants for $8,000 (as per Mr. Long) because they too
moved out before the end of their lease and that all we wanted was to get out and
away from Mr. and Mrs. Long.
3. We paid a security deposit of $1250.00 before madrig in which covers the repair of the
siding. (attachment #5)
4. There is no stipulation in the attached lease agreement (plaintiff exhibit A) stating
that we are responsible for any remaining rent, fees or costs if we move out
before the end of the lease term.
We, the defendants in this case ask that you consider our objections and find that the
plaintiff is not granted a judgement of $11,450.00.
Respectfully submitted,
De ndants
Date_ 111,111 Q q
A 46AJOJ? -# I July 8, 2004
Dear Steven and Susan Long;
I know that you expected to come and pick up the rent for July but we are not paying at this time.
We have been thinking and talking about how we would handle the ;situation and this is the best way that
we know how. We obvioulsly need to get your attention about hove we feel about what has been going on
with the house at 347 Stonehedge Lane.
As you are aware we moved into this property at the end of March and began having problems the
first week we were here. I phoned you and explained that we were having problems with the downstairs
toilet That was the first overflow. As you are also aware, there were several, at least 6 overflows in the 3
months that we have been in this house. Each and every time we had a problem one of us called you and
you would respond in most cases several hours later. Your response usually came in the late hours of the
night and then you would spend a few hours working on the problem both indoors and out regardless of
the time of night. Many of those nights you would enter the house without warning while we were sleeping.
1 can recall at least one night you showed up and came in unannounced while I was getting out of the
shower. Each time you attempted to fix the problem you never ones offered to clean up the mess that
was created and simply left if for us to worry about As I have told you I spent many hours cleaning the
water and debris from the bathroom and then was forced to clean the carpet numerous times because the
smell of sewage was so strong. You had told us on numerous occassions that you would send "your
man" to come and extract the water and clean the carpet but that newer happened. As you know, I have
all the nasty pictures to show if I need to. The neighbors are also aware of how it looked and smelled. We
waited and waited for you to have the problem fixed but all we kept hearing from you is that you did not
have the money to fix it or that no one wanted the job. This was your responsibility to fix and it took
months until there was any action. The last straw was the night of my parent's 40th anniversary party
which had to be cancelled the night of the party because the sewer line was overflowing AGAINI I called
you early in the morning to tell you what had happened and you res;*nd 4 hours later. You told me that
you "fixed it'' but shortly after you left it overflowed again. 1 called you at 3:10 p.m. and you stated that you
would be right over. You did not show up until after 9:00 p.m. that night and only after Jeff called you two
times to tell you that the water was running all over the downstairs. Again you spent hours outside in the
dark trying to fix the problem with no luck. That episode cost us a ffm hundred dollars because we had a
caterer lined up and we had to cancel just a few hours before the party. They require at least 48 hours
notice. About 1:00 a.m. Service Masters showed up to clean up what they could. On Monday of that
week Service Masters called to say they were coming to get their equipment and asked if I knew if they
were to rip up the carpet. The woman stated that they usually do that when the overflow involves sewage.
She said she was unable to reach you so she said they would just come and pick up the equipment and
leave the carpet and smell exactly as it was. I spend days trying to get the smell out. By this time mold
and mildew were beginning to form on the molding, in the closet, and under the furniture and the smell
was not coming out no matter how many times 1 cleaned the carpet You stated to me shortly after this
incident that you would take care of it and that you would try to have your insurance company reimburse
me for all carpet cleaning, rugs, towels and furniture that had been ruined. Of course that did not work out
and you never offered to payout of your pocket for any of the expenses. Meanwhile you kept telling us
how broke you are and that you cannot get the problem fixed until you get some money. I recall you even
asking me if I knew any loan sharks. You also stated to me that you would like to have given me some
incentive to stay in the property but that would be impossible because you were broke. You had talked
about us moving to another one of your properties but that it would be somewhat difficult to do that
because you would have to kick out the tenant that lived there. This lastest and worst incident took place
in late May, one month after we got hens. Shortly after we had another overflow and this time your
solution was to remove the cap from the pipe outside so that when it filled up it would overflow outside, not
inside. This worked out ok expect that the pipe overflowed constanitlyy spilling raw sewage in the front
yard. There was food from the garbage disposal, toilet paper, and feces laying in the yard. It would run
out constantly. You did state to me several times that you were working on getting it fixed by going to
lawyers, the Attorney General and by speaking to the Homeowners Association. You kept telling me that
no one was taking responsibility for fixing the problem but that wasn`t my problem. Our problem was the
inability to use the toilet downstairs for a few months, the smell of the carpet and now the outside, the
inconvenience of having you here all hours of the night trying to fix the problem, and the mold and mildew
that was growing day by day. Still you gave excuse after excuse why it was not getting fixed. Finally in
Mid June a group of men showed up (not hired by you) to fix the pipe. When the raw sewage began
flowing from the pipe outside the neighbors were getting fed up as well. The fact that the pipe was fixed
was probably due to their complaints. They stated to me that they were not happy with the situation. This
was a severe health hazard to everyone in the neighborhood at this point The problem was fixed in one
day and you showed up that night and stated to me that you would have someone at the house in a day or
two to tear up the carpet, replace the carpet, and srub and paint the molding to get rid of the mold and
mildew Ac I Stnted the nrnh1Pm %Afn- fivnei in tmirl Iiin r I t i'i n-I Iw it r. . • •• 1:1 1
have everything fixed right after the pipe was repaired. We did not need to call you, you knew what had to
be done and you didn't do anything until you knew we were very upset You then showed up every day
that week unannounced, letting yourself in with your key. On July 4th you showed up unannounced at
10:00 p.m. stating you were having the carpet done on the morning of July 5, a holiday for those that work.
We had plans for a cookout at our house which again had to be canceled because you didn't have the
courtesy to check with us first to make sure that day was ok. The carpet job was not done thoroughly, and
the smell remained. You had told me a month ago that you would get rid of the carpet, especially the
carpet in the hall because it was very damaged and smelly. You then show up unannounced again on
July 6 to tell me that the carpet cleaners are coming that same day. I was not prepared for company that
day so you decided to just walk in after ringing the doorbeti one tirne. The carpet cleaners came and
cleaned as best they could but the smell remains. The carpet in the hallway that was saturated by sewage
numerous times needs to go.
For these reasons Jeff and I are getting out of this house. It has been a nighmare living here and
having you as a landlord. You have been irresponsible in dealing with the sewage problem, you come to
the house unannounced and then use your key whenever you feel Eke it and you have not completed the
job in dealing with the mold and mildew. I do not want to hear how broke you are or how many drugs you
are on. I want to live peacefully in a house that I am paying to live In. In addition to all of this there is still
an issue with the trash. You told me you would set up the account and the trash, now two weeks old, still
sits here. You also stated to me a couple of months ago that you expect the house to be "posted"
because you had not paid sewer and trash for years. We refuse to live like this any longer. We are not
paying July's rent because we feel that you owe us at least a free month for all we have put up with and all
the money that we have spent. In addition, I am looking for a new place and as soon as I find one we will
be out of here. If we don't find a place by August you can use our security deposit to pay for August and
then you will owe us nothing upon us moving out. I will have the siding out back fixed before we move and
I will have the carpet cleaned and the small holes in the wall patched prior to us moving out.
Unless you can come up with a better solution this is how it is going to be. We have put up with
far too much already and t am not about to go through this anymore.. We have been patient with you and
even a bit understanding, but enough is enough. We are paying for too much money here to be living like
this. I have numerous witnesses to what has been going on and even the neighbors have been talking. It
is time to cut our losses and move on. If you want to propose something different, please put it in writing
and send it. Please do not show up at our door before calling and speaking to one of us directly.
Sincerely,
Sharon Salov
Jeffrey Cleckner
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O BOX 10614 H.4WSB URG, PA 17105'-0614
(717)-612-9613
July 10, 2004
JEFF & SHARON,
(CW
WHAT CAN WE DO TO SAT143FY YOU?
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SML PR Os ERTYHOLDINGS C?u D?
P O BOX 10614 ILL RRISB URG, PA 17105-0614 `' ?? 1 1n1
717'-612-9613 C
July 15, 2004
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JEFF & SHARON,
Thank you for your prompt response,
We are amenable to the terms you stated in the
attached letter; we accept the term:)-.
We agree to not coming unannounced, unless
emergency and no one representing us will bother
you unless you are notified.
You agreed ii the letter to take full re ponsibility for
all utilities and pay the lease on time, f that is what
you want rather than paying me after I bill you
(I will send copies of bills) that is fu Le-
I am glad that you are staying, after a.i the problems
that have occurred, we hope that we cua as you said
in your letter "start with a clean slate ; we very
much want to keep you as tenants as long as you
wish to stay.
Thank you,
Stephen & Susan Long
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Any q s ' ins ab ut anything plecxse call us so we
can a . re the issues quickly and efficiently.
COMMONWEALTH OF PENNSYLVANIA
(-01 INTV OF- CUMBERLAND
Mag Dist. No
DJ Name Hon.
09-3-05
GAYLE A. ELDER
Address: 5 07 N. YORK ST.
MECHANICSBURG, PA
Teiepnone' (717) 766-4575
-4 Li
(Q-?vrw?c.,?
NOTICE OF UDGMENTITRANSCRIPT
PLAINTIFF: RESIDENTIAL LEASE
NAME and ADDRESS
17055
I-SM LONG HOLDINGS
PO BOX 10614%.
HARRISBURG, PA 17105
L J
VS.
DEFENDANT: NAME and ADDRESS
FSALOV, SHARON L., ET AL.
347 STONEHEDGE LANE
MECHANICSBURG, PA 17055
SHARON L. SALOV L J
347 STONEHEDGE LANE Docket No.: LT-0000227-04
MECHANICSBURG, PA 17055 Date Filed: 8/17/04
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLAINTIFF
FX Judgment was entered for: (Name) SM LONG HOLDINGS,
Judgment was entered against SALOV, SHARON L. in a
7Landlord/Tenant action in the amount of $ 2,128.50 on 813)104 (Date of Judgment)
The amount of rent per month, as established by the District Justice, is .00.
The total amount of the Security Deposit is $ .00
Total Amount Establish yd 84 J less - Security Deposit Ap lig d =
Rent in Arrears $ • 0 - $ • ? 0
Physical Damages Leasehold Property $ 300.00 - $ . 00 =
Damages/Unjust Detention $ -on - $ _ 00
.Less Amt Due Defendant from Cross Complaint -
Interest (if provided by lease)
UT Judgment Amount
Attachment Prohibited/ Judgment Costs
42 Pa.C.S. § 8127 Attorney Fees
This case dismissed without prejudice.
Fx-l Possession granted.
Possession granted it money judgment
Possession not granted.
Total Judgement
$ Adjudica?ed?rr?ouot
0
$ 300.00
$ _on
$ .00
$ _00
$ 1.gg0_00
$ 138.50
$ -no
$ 2,128.50
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
? Defendants are jointly and severally liable.
IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PAI#TY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN
TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS
OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT, IF ANY. IN
ORDER TO OBTAIN A SUPERSEDEAS, THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF
THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED.
IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE PARTY HAS
30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF
COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION.
THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THE NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER
ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT
OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE.
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 DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES,
OR OTHERWISE COMPLIES WITH THE JUDGMENT.
U Id?6y Date 4_' La. t b 1, i". l District Justice
Cer I yytthat this is a true an correct copy o the recor o the procee Ings co ntaming t -he judgment.
Date , District Justice
My commission expires first Monday of January. 2006. SEAL
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1
Stephen M. Long and Susan Long, : IN THE COURT OF COMMON PLEAS
t/b/a S.M.L. Luxury Townhouses and : CUMBERLAND COUNTY, PENNSYLVANIA
S.M. Long Holdings
Plaintiff
NO. 04-4905 Civil
V.
CIVIL ACTION - LAW
Sharon L. Salov and Jeffrey Cleckner,
Defendant
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 twenb( (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 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, 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 ATA REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108 or (717) 249-3 166
AVISO
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas
que se presentan mds adelante en las siguientes piginas, debe tomar acci6n dentro de los
pr6ximos veinte (20) Bias despuds de la notificaci6n de esta Demanda y Aviso radicando
personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por -
escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le
advierte de que si usted falla de tomar acci6n como se describe, anteriormente, el caso puede
Stephen M. Long and Susan Long,
t/b/a S.M.L. Luxury Townhouses and
S.M. Long Holdings
Plaintiff
V.
Sharon L. Salov and Jeffrey Cleckner,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
COMPLAINT
AND NOW, come Plaintiffs and file this Complaint at law setting forth in support
thereof as follows:
1. Plaintiffs herein are Stephen M. Long and Susan Long, husband and wife, of
Harrisburg, Dauphin County, Pennsylvania.
2. Plaintiffs are doing business trading as S.M.L. Luxury Townhouses and also
known as S.M. Long Holdings.
3. Defendants are Sharon L. Salov and Jeffrey Cleckner, formerly of 347
Stonehedge Lane, Mechanicsburg, Pennsylvania.
4. On the 22nd day of March, 2004, Plaintiffs and Defendants signed a written
agreement for Defendants to rent from Plaintiff, the property of Plaintiffs situate at 347
Stonehedge Lane, Mechanicsburg, Pennsylvania, 17055. A copy of this Agreement is
attached hereto as Exhibit A.
WHEREFORE, Plaintiffs respectfully request judgmemt in their.favor against
Defendants in the amount of $11,450.00, together with interest, costs of suit and
reasonable attorney's fees.
I k Off, `0 ?l
Date
Respectfully submitted,
KEVIN TH A. WISE, ESQUIRE
Attorney I.D. No. 16142
Graybill & Wise, P.C.
12E'; Locust Street
P. 0. Box 11489
Harrisburg, PA 17108-1489
(717) 238-3838
Attorney for Plaintiffs
3
THIS IS A LEGAL DOCUMENT.
DO NOT SIGN THIS LEASE AGREEMENT
UNTIL YOU HAVE READ IT CAREFULLY.
Cover sheet
LEASE AGREEMENT
THIS IS A LEASE.
The Owners names are: Susan M. Long and Stephen M. Long
The Tenant(s)' name(s) are: Sharon Salov and Jeffrey Cleckne:r
Tenant(s)' Social Security Number: Si Lu0-'c. 1? 2 • u y- 0
1? 'r IS i- t,-t, 39 -1
.Tenant(s)' Driver's License Number: Sj-,&rn AlylaS!jq
Jo4 ab i4 S9 )
Tenant shall rent property from the Owners;
Susan M. and Stephen M. Long a.k.a. SML LUXURY TOWNHOMES
a Townhouse located at 347 Stonehedge Lane, Mechanicsburg, Pa 17055; ("premises").
The Lease begins on APRIL 1ST, 2004
The Lease ends on MARCH 31ST, 2005
Owners and Tenant(s) agree upon the following terms and conditions:
RENT
1. The rental payment is $15,000 per year.
Tenant must pay the rent in monthly installments of $1250.00 on the first day of each month
in advance. The rental payment must be made out to S. M. LONG and arrive at
P.O. BOX 10614 HARRISBURG, PA 17105-0614 by the first:of the month.
Tenant shall also pay to Landlord an additional $34.00 per month
the cost of sewer rental and trash removal charged by the Municipality.
1
LATE FEES AND CHARGES
2. Tenant shall pay a late charge of $10.00 per day beginning on the 2nd day of each month
for any and all unpaid balances.
In order to avoid late charges, the monthly rent payment and any additional fees must arrive ec.
P. O. BOX 10614 HARRISBURG, PA 17105-0614 by the first of the month.
If any rent check is returned to Owner by a bank for insufficient funds or any other reasons,
Owner will charge Tenant a $50.00 service charge in addition to any other charges which Owner
must pay.
WAIVER OF NOTICE TO QUIT
3. Tenant agrees to surrender the premises when the lease rinds for whatever reason
(default, expiration or otherwise) without notice from Owner whatsoever.
Tenant will not require Owner to provide the usual notice to quilt. If Owner tries to get back the
premises for any reason whatsoever, Tenant specifically waives the right to three (3) months
notice and to fifteen (15) or thirty (30) days notice or any other notice required under the Landlord
and Tenant Act of 1951, as amended.
Tenant agrees that no notice whatsoever shall be required.
TERMINATION AND RENEWALS
4. This lease agreement shall automatically end at the end of the lease term unless both
parties agree in writing before the end of the lease term. At thE; end of the lease term,
Owner may raise the rent or change any part of this tease. Owner also may get the
premises back at the end of the lease term.
2
a-
UTILITIES
5. Owner and Tenant agree that the cost of utilities shall be paid as follows:
UTILITY/SERVICE
Heating of Premises
Heating of Water for Premises
Electricity
Gas
Water
Sewage
Trash
Telephone
Cable TV Service
Janitor Service
Air Filtration Devices
Water Filtration Devices
Lawns care
Landscaping
Leaf Removal
Snow Removal - Parking Lots & Main Sidewalks
*From Door to Main Sidewalk & Patio must be done by
Homeowners Association Dues
HVAC Service
TO BE PAID BY
Tenant
Tenant
Tenant
Tenant
Tenant
Tenant
Tenant
Tenant
Tenant
Tenant
Tenant
Tenant
Home Association
Home Association
Home Association
Home Association
Tenant
Landlord
Landlord
Owner shall have the right temporarily to stop the services of any utility in the event of an
accident affecting the same or to make repairs or alterations made to the Building.
USE AND CARE OF PREMISES
6. Care. Tenant shall be careful in the use of the premises, the appliances, and all other
parts of Owner's property. including, but not limited to, washer and dryer, electric range,
refrigerator, trash compactor, dishwasher and garbage disposal. In the event that any of the
foregoing appliances shalt not be repairable, Owner will, at Tenant's expense, replace said
appliance. Owner shall have full discretion as to whether any given appliance shall be repaired
or replaced. When this lease ends, Tenant shall repair all appliances not in working condition,
at Tenant's expense. Tenant shall not use expansion type screws in walls to hand anything,
In the event that any holes are created, the tenant must al their expense make repairs to owners
satisfaction, e.g. unnoticeable. Owner shall deduct the cost of the repairs from Tenant's security
deposit.lf the security deposit does not cover the cost of repairs, Tenant shall pay the.excess.
3
IF NOT ACCEPTABLE BY OWNER TENANT MUST PAY TO HAVE THE PREMISES
PROFESSIONALLY CLEANED OR RESTORED TO ORIGINAL CONDITION IF NOT
ACCEPTABLE BY OWNER SO NEXT OCCUPANTS CAN TAKE IMMEDfATE POSSESSION.
Tenant shall not permit or allow any smoking of any kind in the Townhouse.
7_ Use. Tenant may not conduct a business or profession in the premises.
Tenant may do nothing more than live in the premises.
Tenant shall not permit or allow anything to be done or kept upon or within the premises which
will interfere with the rights of the other occupants, annoy them with unreasonable noises or
otherwise. Tenant shall not commit or permit any nuisance in the premises.
Tenant shall not commit or allow any immoral or illegal act in the premises.
Tenant shall comply with all rules and regulations of the Homeowners and/or
Condominium Association.
RULES AND REGULATIONS CONCERNING USE AND OCCUPANCY
8. Tenant must obey the following rules in order to stay in th4a premises:
A. No dog, cat or other animal of any kind will be brought, permitted or kept in the
Townhouse or elsewhere on the Owner's property without Landlord's signed (Pet Addendum).
In addition to the penalties contained in this lease, Owner mar assess a 51001month charge
against Tenant for any animal found on the premises.
4
PETADDENDUM
We the undersigned agree to pay for professional carpet cleaning
When we vacate the leased townhouse located at:
347 Stonehedge Lane Mechanicsburg, Pa 17055
If cleaning of the carpets does not remedy the stains and or odors and other associated
damages with our use of the townhouse by us and our pets,
We agree to pay all associated costs for replacement to ORF's CARPET for the said
damaged carpets and floors.
If tenants remain for a period of ten years or longer, this repair and replacement
agreement is invalid do to average wear and tear and you will! not be charged for cleaning
or repair of the carpets.
TENANTS:
Sharon Salovw•.tim?• DATE 31'1 oy
Jeffrey Cleckner ???---?- DATE 3010Y
OWNERS:
Susan M. Long DATE
Stephen N1. Long DATE y
3 7-
B
. Tenant(s), members of his (their) family, his (their) visitors and servants shall not at
any time make any noise or do anything which disturbs any other resident or interferes with
the rights, comfort, or conveniences of any other resident. Musical or sound reproducing
instruments or singing within the Townhouse shall be inaudible outside the apartment
between 11 o'clock each night and 9 o'clock the following morning.
5
C. No resident shall place or permit to be placed or maintained any sign or advertising
matter or device or any roof aerial or other structure in any window of the Townhouse
or elsewhere or upon the Owner's property. No resident shall place or permit to be
placed or maintained any awning, screen, shade or blind in or at any window of the
Townhouse without prior consent of the Owner. Damage to storm doors and windows
due to negligence will be the responsibility of the Tenant.
0. Tenant shall use plumbing and electrical installations only for their intended purposes
and shall be fully responsible for the maintenance of same and for cleaning
any stoppages in waste water lines.
00 NOT FLUSH FEMINE HYGINE PRODUCTS OR PAPER TOWELS DOWN TOILET.
E. Maximum occupancy; no more than 2 person(s) will be permitted to occupy the unit,
designated as the Townhouse at 347 STONEHEDGE LAN1= MECHANICSBURG PA 17055
?F ANY UNRECORDED GUESTS ARE REPORTED, YOU WILL BE CHARGEO $50.00 PER 00.Y PER GUEST.
F. Tenant(s) agree(s) that Owner may change these rules from time to time
as may be required to protect the Townhouse or Owner's other property or add to Tenant's
enjoyment of it.
G. Tenant is required to sign the release of liability document if they utilize the use of the
STONEHEDGE PRIVATE FITNESS ROOM.
H. Any window or other glass broken during the term of this lease shall be the
responsibility of Tenant.
1. Tenant shall be responsible for routine maintenance of the HVAC filters
and the refrigerator water fitter.
J. Tenant must place all trash and rubbish in bags inside containers. Tenant shall keep
the premises in good and sanitary condition.
K. Tenant shall not change locks or install additional locks, without the written consent of
Owner.
Tenant shall not use or store any kerosene or space heaters in the premises.
6
RIGHTS AND RESPONSIBILITIES
9. Delivery of Possession by Owner. If, due to circumstances beyond
Owner's control, the premises shall not be ready for Tenant to move in at the beginning of
the lease term, this leased proportionately until the premises are ready. Owner shall not
be responsible for delay. If the premises shall not be ready, sixty (60) days after the
beginning of the term, Tenant shall have the right to cancel this lease by written notice
delivered to Owner at any time after sixty (60) days, but not after the unit is ready. This
cancellation shalt be Tenant's only remedy. Upon such cancellation neither party
shall have any further rights against the other. Owner shall repay any
deposit made by Tenant. If Tenant shall move in before the: beginning of
the lease term, the terms of this lease shall apply. Tenant shall pay, before moving in,
rent for the same period from the date of moving in to the beginning of the lease term.
10. Damage by Fire. If the premises are damaged by fire or other casualty.
Owner shall repair within a reasonable time.
Rent shall continue unless the casualty renders the unit unlivable, in
which case this lease shall terminate. Tenant, upon payment of all rent
to the date the unit is surrendered, shall not be liable for any further
rent. If only a portion of the premises is unlivable, the Tenant may,
with the mutual agreement of Owner, choose to continue in possession and
shall be entitled to a reduction in the amount of rent. Tenant may
still end the lease if repairs are not made within ninety (90) days.
7
11. Property Damage and Personal Injury.
Tenant agrees that Owner shall not be responsible for property damage or
personal injury occurring on the premises unless the damage or injury
results directly from owner's negligence. Tenant must buy, at Tenant's
expense, a Tenant's Homeowner's Policy to insure against personal injury
to Tenant, other occupants, guests, or visitors, that occurs on the premises.
12. Right of Entry. Owner, or any person authorized by Owner,
shall have the right to enter the unit at reasonable times to inspect, replace appliances as
needed, and to show the unit to prospective tenants.
Owner shall give Tenant notice of his or their intention to enter, if 12ossibte.
Notification shall not be necessary in case of emergency.
SECURITY DEPOSIT
13. Tenant paid as security deposit by personal check in the amount of :
TWELVE HUNDRED FIFTY DOLLARS
before moving in to the unit. The security deposit shait be held t)y Owner as
security for the payment of a)) rent and other amounts due from Tenant to Owner, for the
Tenant's performance of this lease and against any damages to the premises or Owner's
property caused by Tenant, Tenant's family, other occupants or guests.
Following the termination of this lease, Owner shall return the security deposit, less
any deductions from it on account of amounts owed by Tenant to Owner, by check payable
to all persons signing this Iease.Tenant must furnish a mailirig address in writing within
thirty (30) days after moving out. If Tenant does not provide this mailing address, the
security deposit may not be returned.
8
MISCELLANEOUS
15. Subordination. Any bank or other party with a lien or mortgage on the
premises has a stronger claim to the premises than the Tenant. Tenant agrees, on
request, to sign papers in favor of any such lienholder. If Tenant fails to do so, Owner
may do so in the name of Tenant.
16. Assigning and Subletting. Tenant shall not assign this lease or sublet all or
any portion of the premises without Owner's prior written consent.
17. Declaration of Goveming Laws. Any disputes shall be decided in
Pennsylvania under Pennsylvania taw.
18. Cumulative Remedies. There are many remedies which Owner may use
against Tenant. Owner may use all of them or some of them. Owner may even use
remedies which might not be in this lease.
19. Entire Agreement and Modification. This lease is the entire agreement
between Owner and Tenant. Any other agreements shall be void unless they are
signed by both Owner and Tenant. Any agreement signed before this lease is void.
20. Lease Binding Upon Heirs. Executors, Administrators. Successors, and
Assigns. The term "Tenant" shall mean everyone who signed this lease as Tenant. The
liability of each such person shall be joint and several. Each tenant shalt be responsible for
Tenant or by any such person to Owner, shall bind all persons signing this tease as
Tenant. The term "Tenant" shall also refer to any persons named as heirs, executors,
administrators or successors of Tenant as if the full rental payment. Notice given by
Owner to any person named as they were in every case named in this lease.
10
21. Severability. If any provision of this lease shall be declared invalid or
unenforceable, the remaining provisions of this lease shall continue in full force and effect.
IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby,
have hereunto set their hands and seals the date and year first-above written.
TENANTS:
Date: 3 L1 Sharon Salov(SEAL)
Jeffrey Cleckner(SEAL)
OWNERS:
Date, Susan M. Long (SEAL)
rI 1
Stephen M. Long
L)
11
VERIFICATION
Upon my personal knowledge or information and belief, I hereby verify that the
facts averred in the foregoing Complaint are true and correct to the best of my
knowledge, information, and belief. I understand that false statements or averments
therein made will subject me to the criminal penalties of 18Pa.C.S. § 4904 relating to
unsworn falsification to authorities.
Date: 2pO
VERIFICATION _
Upon my personal knowledge or information and belief, I hereby verify that the
facts averred in the foregoing Complaint are true and correct to the best of my
knowledge, information, and belief. I understand that false statements or averments
therein made will subject me to the criminal penalties of 181"a.C.S. § 4904 relating to
unsworn falsification to authorities.
',rr
Date: ID A
SUSAN LONG
CERTIFICATION
I hereby certify that I am this day serving a true and correct copy of the attached
Complaint on the following individual by First Class U.S. Mail addressed as follows:
Sharon L. Salov and Jeffrey Cleckner
347 Stonehedge Lane
Mechanicsburg, PA 17050
& - (lei O,i
Date
ENNETH A. WISE, ESQUIRE
Attorney I.D. No. 16142
Graybill & Wise, P.C.
126 Locust Street
P. (). Box 11489
Harrisburg, PA 17108-1489
(717) 238-3838
Attcrney for Plaintiffs
Curtis R. Long
Prothonotary
office of the Protbonotarp
Cumberlaub Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
641 - OV q6,S* CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573