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HomeMy WebLinkAbout12-4273 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS Iitrar-int 1lictrint_ County 1 ?. nn sic D i aAt NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT L ?- ' 7? N PLEAS N o. COMMO NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Distri? Justice on the date and in the case referenced below. NAME OF APPELLANT MAG. DIST. NO. NAME OF D.J. - D? c w??+ I auA J m QEf `/ SAN R50>J Iris -04-? KF V+ , . ' ? ADDRESS OF APPELLANT CITY STATE `15 EA51 L our"E S"O'A9',LJ5 L'c rA -- ZIP CODE 17LDIS DATE OF JUDGMENT IN THE CASE OF (Pla"On M PaksA P6 "S' Irt ?. ?1?0 P,+aD ?rnB? +? SRS t? DOCKET No. SIGNATURE OF APPEUJWT OR ATTORNEY OR AGENT ? 3 - ?q ?? ?? - C? d?po? `l3- ?14I ? ? . ?+r??'k?-21.07---? ?I This block will be signed ONLY when this notation is required under Pa. If appellant was Claimant (see Pa. R.C.P.D.J. No. 100 1(6) in action R.C.P.D.J. No. 10088. This Notice of Appeal, when received by the District Justice, will operate as a before a District Justice, A COMPLAINT MUST BE FILE within twenty SUPERSEDEAS to the judgment for possession in this case. (20) days after filing the NOTICE of APPEAL. Sowft a of Prothonotary or D"W 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. 101(7) in action before Distr? ct Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon m K9_1I 6t* ?,. ?4DWEf?T hJJD ?5)WLPk appellee(s), to file a complaint in th is appeal _ Name of appellees) (Common Pleas No. e''l' I ) within twenty (20) days after service of rule or suffer entry of judgment 01`I non pros. 0 AAA- 'Signature-of appellant or homey or agent RULE: To appellee(s) Name of aAwfts(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 pate 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 / Id e l YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE AOPC 312-02 or APPEAL. WHITE- COURT FILE TO BE FILED WITH PROTHONOTARY GREEN - COURT FILE YELLOW - APPELLANTS COPY PINK -COPY TO BE SERVED ON APPELLEE GOLD -COPY TO BE SERVED ON DISTRICT JUSTICE - • . Q ;Lw ?? "7743 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 ss AFFIDAVIT: I hereby (swear) (affirm) that I served ? a copy of the Notice of Appeal, Common Pleas upon the District Justice designated therein on (date of service) 20 ? by personal service ? by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) cs ,20 ? by personal service ? by (certified) (registered) mail, sender's receipt attached hereto. (SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF Signature of official before whom affidavit was made Signature of affiant Title of official My commission expires on , 20 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Notice of Judgment/Transcript Civil _ Case Mag. Dist. No: MDJ-09-2-02 MDJ Name: Honorable Jessica Brewbaker Address: 18 North Hanover Street, Suite 106 Carlisle. PA 17013 I Telephone: 717-240-6564 Kimberly S Sanderson 75 East Louther St Carlisle. PA 17013 Disposition Summary Docket No MJ-09202-CV-0000073-2012 MJ-09202-CV-0000073-2012 MJ-09202-CV-0000073-2012 MJ-09202-CV-0000073-2012 Judgment Summary Participant Kevin M Sanderson Kimberly S Sanderson Marisa L Hoopert Shyla R Rakers Marisa L Hoopert, Shyla R Rakers V. Kevin M Sanderson, Kimberly S Sanderson Plaintiff Defendant Marisa L Hoopert Kevin M Sanderson Marisa L Hoopert Kimberly S Sanderson Shyla R Rakers Kevin M Sanderson Shyla R Rakers Kimberly S Sanderson Joint/Several Liability Individual Liability S4.123.00 $0.00 $4.123.00 $0.00 $0.00 $0.00 $0.00 $0.00 Docket No: MJ-09202-CV-000007: Case Filed: 4/30/2012 Disposition Judgment for Plaintiff Judgment for Plaintiff Judgment for Plaintiff Judgment for Plaintiff $4,12 $4,12 S S 1-2012 06/11 /2012 06/11/2012 06/11/2012 06/11 /2012 Judgment Detail ('Post Judgment) In the matter of Marisa L Hoopert, Shyla R Rakers vs. Kevin M Sanderson; Kimberly S Sanderson on 6111/2012 the judgment was awarded as follows: Judoment Component Joint/Several Liability Individual Liability Deposit Applied Amou t Civil Judgment $4,000.00 50.00 54.000. 0 Costs $123.00 50.00 $123.00 Grand Total: $4,123.00 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY /CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, 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 MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. r Date Magisterial District Judge Jessica Brewbaker MDJS 315 Page 1 of 3 Printed: 06/11/2012 1:44:08PM ah '' Marisa L Hoopert, Shyla R Rakers Docket No.: MJ-09202-CV-0000073-2012 T Kevin M Sanderson. Kimberly S Sanderson I certify that this is a t,ue and correct copy o the record o the proceedings containing the judgment. Date Magisterial District Judge I rr01 MDJS 315 Page 2 of 3 Printed: 06/11/20121, 1:44 68PM Marisa L Hoopert, Shyla R Rakers Docket No.: MJ-09202-CV-0000073-2012 V Kevin M Sanderson, Kimberly S Sanderson Participant List i Plaintiff(s) Marisa L Hoopert 421 Cornman Rd Carlisle. PA 17013 Shyla R Rakers 421 Cornman Rd Carlisle PA 17013 Defendant(s) - Kevin M Sanderson 75 East Louther St Carlisle, PA 17013 Kimberly S Sanderson 75 East Louther St Carlisle, PA 17013 a i MDJS 315 Page 3 of 3 Printed: 06/11/20121 ' 1:44:08PM n r ? Ge?irfa.Fr.- ru Fea Return ReceiPt _ (Endorsement Rectu reti3 CI Restricted Delivery Fee ent Requuedj } (Endorsem CI e ? Total Postage 8, Fee - Sent T:) ru ?= Street AP ° r' or PO Box No. City. State, ZIP+4t I PROOF OF SERVICE OF NOTICt: (This proof of service MUST BE FILED WITHIN TEN (7 COMMONWEALTH OF PENNSYLVANIA COUNTY OF C i u^bel'1&4 d ; ss AFFIDAVIT- I hereby (swear) (affirm) that I served a copy of the Notice of Appeal, Common P (date of service) 20 sender's receipt attached hereto, and upon , 20A)- ?.., sender's re eipt attached hereto. (SWORN) (AFFIRMED) AND SUB CRIBED BEFORE: ME T 5 _? DAY OF bodu? Signature of official before whom ai wit was e Title of official My co Teram "" Ab?Cb - 20 MY co,„, a ?i 'aw,r ' "30 postma* Here' ----- --------- 5 -- ---------------- ) ') -D 13 - DEAL AND RULE TO FILE COMPLAINT AFTER filing of the notice of appeal. Check applicable boxes.) 'Id-13, upon the District Justice designated therein on U by personal service ? by (certified) (registered) mail ppellee, (name) NW A ') -C ( A, C on y personal service by certifie ) (registered) mail. ?I Signal re of affiant r _ o ;° = C C= C4 .. ? X- i COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL Judicial District, County Of x ' FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. i NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case referenced below. KAML ur PJ'MLuw i Mnla. Wt. ? . nv rvwNt yr v ?. Y ADDRESS OF APPELLANT CITY STATE DP CODE DATE OF JUDGMENT IN THE CASE OF (PfeWdf) - (De(endarM)' va This block will be signed ONLY when this notation is required under Pa. If appellant wasNC/aimant (see Pa. R.C.P.D.J. No. 1009(6) in action R.C.P.D.J. No. 1008B. This Notice of Appeal, when received by the District Justice, will operate as a before a District Justice, A COMPLAINT MUST BE FILED within twenty SUPERSEDERS to the judgment for possession in this case. (20) days after filing the NOTICE of APPEAL.. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appeflee. PRAECIPE: To Prothonotary Enter rule upon s'i ? appellee(s), to file a complaint in this appeal Name of appegee(s) (Common Pleas No. within twenty (20) days after service of rule or suffer entry of judgment of non pros. 'Signattue of appellant or atfomey of agent RULE: To (`asp appellee(s) Name of appegee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY 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 s .. '6 of ry or Deputy 717 YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-02 WHITE- COURT FILE TO BE FILED WITH PROTHONOTARY GREEN - COURT FILE YELLOW -APPELLANTS COPY PINK - CAPV TA RF SFRVFn nN OPPFI I FF 6OI D - COPY Tn BF SERVED ON DISTRICT JUSTICE MARISA L. HOOPERT AND IN THE COURT OF COMMON PLEAS OF SITYLA R. RAKERS, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs No. 2012-4273 V. Civil Term KEVIN M. SANDERSON AND KIMBERLY S. SANDERSON, -. - Defendants cn t- ? -<> cs? C- < -0 c-3 r NOTICE You have been sued in court. If you wish to defend against the claims set forlfi in` & following pages, you must take action within twenty (20) days after this complaint and notice ai served, by entering a written appearance personally or by an attorney and filing in writing with the court, your defenses or objections to the claims set forth against you. You are warned that ii 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 claij or relief requested by the plaintiff. You may lose money or property or other rights important tc you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATI( ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service (ARIS) 155 South Ninth Street Easton, Pennsylvania 18042 Telephone: (610) 258-6333 MARISA L. HOOPERT AND SITYLA R. RAKERS, Plaintiffs V. KEVIN M. SANDERSON AND KIMBERLY S. SANDERSON, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2012-4273 Civil Term COMPLAINT OF MARISA L. HOOPERT AND SITYLA R. RAKERS AND NOW come Plaintiffs Marisa L. Hoopert and Shyla R. Rakers, by and through attorneys, Baric Scherer LLC, averring as follows: 1. Plaintiffs are Marisa L. Hoopert and Shyla R. Rakers (hereafter "Plaintiffs"), individuals currently residing at 421 Cornman Road, Carlisle, Cumberland County, Pennsylvania 17013 2. Defendants are Kevin M. Sanderson and Kimberly S. Sanderson (hereinafter "Defendants"), adult individuals currently residing at 75 East Louther Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. On February 21, 2010, Plaintiffs executed a contract for the sale of a 2003 Chevrolet Blazer (hereinafter "contract of sale") (a true and correct copy of whi4 is attached as Exhibit A) with Defendants. 4. Under the terms of the contract, Plaintiffs, in addition to paying for the vehicle': operating expenses (insurance, registration, etc.), would pay to Defendants $80. every other week, until a balance of $6,500.00 was completely paid. 5. Plaintiffs made, and Defendants accepted, every payment through February 20 6. Under the terms of the contract of sale, a payment was due on February 18, 201 7. On February 17, 2012, Defendants repossessed the 2003 Chevrolet Blazer in breach of the contract of sale. 8. The breach occurred several days after a family dispute between Plaintiff Shyla Rakers and Defendant Kimberly Sanderson, her maternal aunt, the result of was that Plaintiff Shyla R. Rakers was going to limit exposure of her children to Defendant Kimberly Sanderson. 9. Plaintiffs had by February 17, 2012, paid Defendants over $4000.00 under the terms of the contract of sale. COUNT I-BREACH OF CONTRACT 10. Paragraphs 1 through 9 are incorporated by reference as though set forth fully herein. 11. Defendants breached the contract of sale, causing damage to Plaintiffs in excess of $4000.00. 12. Plaintiffs request judgment against Defendants in the amount of $4000.00 WHEREFORE, Plaintiffs respectfully request a judgment be entered in the favor and against Defendants. COUNT II-UNJUST ENRICHMENT 13. Paragraphs 1 through 12 are incorporated by reference as though set forth fully herein. 14. Defendants, by repossessing the 2003 Chevrolet Blazer, after accepting over $4000.00 in payments from Plaintiffs, have been unjustly enriched. 15. Plaintiffs request judgment against Defendants in the amount of $4000.00. WHEREFORE, Plaintiffs respectfully request this Honorable Court enter judgment in favor of Plaintiffs and against Defendants as follows: (a) a monetary award of $4000.00; (b) attorney's fees and costs of suit; (c) such other relief as this court determines reasonable and just. Respectfully submitted, BARIC SCHERER LLC Tr7 Date: G Alk Bret P. of er, sq. I.D. 309180 19 West South Street, Carlisle, PA 17013 717-249-6873 717-249-5755 (fax) Attorney for Plaintiffs Kevin and Kimberly Sanderson (Sellers) do hereby agree to sell to Shyla Rakers and Mitzi Hoopert (Buyers) a 2003 Chevrolet Blazer (VIN number 1GNDT13X33K186821) with the following provisions: The Sellers have financed the vehicle with Memberslst Federal Credit Union in the amount of $6500.00. The Buyers agree to make minimum payments to the Sellers in the amount of $80.00 biweekly, beginning February 19, 2010. Any additional monies paid to the Sellers by the Buyers will be applied to the loan; there is no prepayment penalty on the loan and the Buyers may at anytime pay the full amount of the loan. When the total amount due on the loan has been satisfied, the Sellers agree to sign over the vehicle title to the Buyers. Payments may be made by personal check, however, if a check should be returned by the bank for any reason, the Buyers agree to pay the Sellers a $35.00 returned check fee and payments from then on must be cash or money order. The Sellers agree to provide the Buyers with receipts as proof of payments made and monthly updates of the current amount due on the loan. Because the vehicle is being financed, full coverage insurance is required. A Progressive Insurance policy has been purchased by the Sellers through Wolfe insurance in the Sellers' name as owners of the vehicle and with the Buyers listed as additional drivers on the policy. Six months of insurance premiums have been included in the loan and the Buyers will not have to reimburse the Sellers separately for this amount. After the initial six months, the Buyers agree to reimburse the Sellers the cost of the insurance every six months prior to renewal of the policy. The current amount of the premium is $224.00 every six months if paid in a lump sum. Any increases in the premium will be the responsibility of the Buyers. No other drivers will be permitted to drive the vehicle. The Buyers must immediately inform the Sellers of any incident requiring a report to the insurance company. Both Buyers must maintain a valid driver's license. The Buyers will be responsible for any and all routine maintenance, needed repairs and yearly inspections as required by state law. Failure by the Buyers to perform needed maintenance/repairs to the vehicle resulting in the vehicle no longer being drivable will not absolve the Buyers of the remaining amount due on the loan. The Buyers agree to reimburse the Sellers for the annual registration of the vehicle prior to the expiration date of the current registration. The Sellers agree to register the vehicle each year and provide the Buyers with the registration sticker. The Buyers have no claim to the vehicle until the total amount of the loan is satisfied; the Sellers have the right to repossess the vehicle at any time to protect the Sellers interests. If any of the above conditions are not met by the Buyers, the Buyers will forfeit the vehicle and all payments made to date, and will immediately su render the vehicle to the Sellers, voiding this agreement. Set1?- r? ?' (Buyer) (Date) (8zr) (Date) ??G?L1?JG 0 ? L? CJ J ? f (sr) (Date) (Seller) (Date) t,? ?, 6 -4- A VERIFICATION I verify that the statements made in the foregoing COMPLAINT OF MARISA L. HOOPERT AND SITYLA R. RAKERS 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 falsification authorities. Marisa L. Hoopert DATE: ?--6 - / z VERIFICATION I verify that the statements made in the foregoing COMPLAINT OF MARISA L. HOOPERT AND SITYLA R. RAKERS 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 falsification authorities. L Shyla R. Rakers DATE: CERTIFICATE OF SERVICE I hereby certify that on August 6, 2012, 1, Bret Shaffer, Esquire of Baric Scherer LLC, did serve a copy of Plaintiff's COMPLAINT OF MARISA L. HOOPERT AND SITYLA R. RAKERS, by both certified mail and first class U.S. mail, postage prepaid, to the parties listed below, as follows: Kevin M. Sanderson and Kimberly S. Sanderson 75 East Louther Street Carlisle, Pennsylvania 17013 Bret Shaffer, Esquire MARISA L. HOOPERT AND IN THE COURT OF COMMON PLEAS OF SITYLA R. RAKERS, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs No. 2012-4273 V. Civil Term KEVIN M. SANDERSON AND r KIMBERLY S. SANDERSON,, Defendants PRAECIPE TO ATTACH EXHIBITS To the Prothonotary: Because the Notice attached to the Complaint of Marisa L. Hoopert and Shy1a R. i filed on August 6, 2012, listed the incorrect bar association, please docket the attached notice, the letter accompanying said notice, and a certificate of service. Date: B 7 b ;21 Respectfully submitted, BARIC SCHERER LLC v w Bret P. Shaffer, Esq. I.D. 309180 19 West South Street, Carlisle, PA 17013 717-249-6873 717-249-5755 (fax) Attorney for Plaintiffs a aCD I MARISA L. HOOPERT AND IN THE COURT OF COMMON PLEAS OF SITYLA R. RAKERS, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs No. 2012-4273 V. Civil Term KEVIN M. SANDERSON AND KIMBERLY S. SANDERSON, Defendants 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 served, by entering a written appearance personally or by an attorney and filing in writing with the court, your defenses or objections to the claims set forth against you. You are warned that you fail to do so, the case may proceed without you and a judgment may be entered against yol by the court without further notice for any money claimed in the complaint or for any other cla or relief requested by the plaintiff. You may lose money or property or other rights important 1 you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATI( 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 BARK Attorneys at Law SCHERER LLC David A. Baric Michael A. Scherer Tricia D. Naylor Bret P. Shaffer Kevin M. Sanderson and Kimberly S. Sanderson 75 East Louther Street Carlisle, Pennsylvania 17013 19 West South Street Carlisle, Pennsylvania 170131 (717) 249-6873 (717) 249-5755 - Fax bshaffer@baricscherer.com August 7, 2012 Re: Complaint of Marisa L. Hoopert and Shyla R. Rakers Cumberland County Court of Common Pleas, Docket No. 2012-4273 Mr. and Mrs. Sanderson, The Complaint in the above-docketed matter included the incorrect bar association contact information on the Notice. Please find a corrected notice attached with this letter, listing the Cumberland County Association, which has also been filed to the docket in this matter. Very truly yours, ENCL BARIC SCHERER LLC Bret P. Shaffer, Esq. cc: file CERTIFICATE OF SERVICE I hereby certify that on August 7, 2012, I, Bret Shaffer, Esquire of Baric Scherer LLC, did serve a copy of the foregoing Praecipe to Attach Exhibits, Notice, and August 7, 2012 addressed to Defendants by first class U.S. mail, postage prepaid, to the parties listed below, as follows: Kevin M. Sanderson and Kimberly S. Sanderson 75 East Louther Street Carlisle, Pennsylvania 17013 Bret of er, E q ire