HomeMy WebLinkAbout12-4350-'LE 0-0 hi r:
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C I E iCy rid t
29 12 JUL 13 PM 2: 2 5
CUMBERLAND COU8Tl
1 2?Y? ?w\ , PENNSYLVANIA
tom- IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVAT
V.
P-,,/ 35-0
NO. CIVIL TERM
Defendant :
PETITION TO PROCEED IN FORMA PAUPERIS
The Petitioner, Loz n.: 1 U Q, , in the above-captioned matter
petitions this Court for permission to proceed in forma pauperis. As set forth in the attached
which is incorporated herein by reference, Petitioner is unable to pay the fees and costs
commence these proceedings.
WHEREFORE, Petitioner requests that this Court enter an order permitting her to
forma pauperis.
Date ,Petitioner
to
in
y
IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V.
t . : NO. CIVIL TERM
UU .
Defendants
AFFIDAVIT IN SUPPORT OF PETITION
TO PROCEED IN FORMA PAUPERIS
1. I am the Defendant in the above matter and because of my financial condition am
pay the fees and costs of prosecuting, defending, or appealing the action or proceeding.
2. I am unable to obtain funds from anyone, including my family and associates, to
of litigation.
3. I represent that the information below relating to my ability to pay the fees and costs
and correct.
(a) Name: R q . 0
Address:
If you are presently employed, state
Employer:
Address:
Salary or wages per month:
Type of work:
to
costs
true
(b)
If you are presently unemployed, state
Date of last employment:
Salary or wages per month: ---
Type of work: t ?-
(c) Other income within the past twelve months
Business or profession:
Other self-employment:
Interest:
Dividends: / I
Pension and annuities: l I ?-t
Social Security benefits: r r\r "SAOD- a t
Support payments:
Disability payments:
Unemployment compensation and
supplemental benefits:
Workman's compensation:
n r? ? Public Assistance:
Other:
(d) Other contributions to household support
(Wife)(Husband) Name: 0 b4
If your (husband) (wife) is employed, state
Employer: _ 0
Salary or wages per month:
Type of work: n P
Contributions from children: n I p
(e) Property owned
Cash:
Checking Account:_
Savings Account:
Certificates of Deposit: ??-
Real Estate (including home):
Motor vehicle: Make
Year
Cost (( Amount owed
Stocks; bonds:
Other: '
(f) Debts and obligations
Mortgage: /
Rent: Q . 0 M p
Loans: ` +- M - (q) Y ? too ?1
Monthly Expenses: }mL ?,3SZ . " J
(g) Persons dependent upon you for support
(Wife) (Husband) Name:-a (Children, if any:
?? k I 1
Name tl i b14Age: `ZZ
A AA o n4-,\
4. I understand that I have a continuing obligation to inform the court of improvement
financial circumstances, which would permit me to pay the costs incurred herein.
5. I verify that the statements made in this affidavit are true and correct. I understand
statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn
to authorities.
my
false
cation
Date: ?Z ??? ?
>d-- N?3 5o Cam' i
November 29, 2011
TO ALL TENNANTS:
The AMVETS Board of Directors has announced some changes regarding who
should be contacted regarding plumbing, electrical, heating and miscellaneous
repairs. Since all work has to be pre-approved, in the future, please direct your
requests on to one the names listed below and in the order they appear:
Leon Smith 717-440-3002 and if not available call-
Jim Collins 717-386-0226 and if not available call---
Walt Earnest 717- vye- C 940
There have been no changes made with respect to housekeeping services.
On another topic, if you are having food, mail or any item delivered to you, please
include the number of your motel room with vour address Mail and other articles
cannot be accepted at the AMVETS. Thank you.
Sincerely,
E. Leon Smith
U-
VALLEY MOTEL
1580 Ritner Highway
Carlisle, PA 17013
December 19, 2011
Dear Tenant:
This is a friendly reminder to ask each of you to be mindful of your neighbors and
to keep the noise levels at a minimum. We have heard on a couple of occasions that
disturbances have occurred resulting from loud parties, domestic arguments, etc.
We don't expect any of you to be subjected to this type of an environment and if it
occurs in the future, we ask that you call the Carlisle Police Department at 243-
5252. Tenants engaging in this type of behavior will be asked to leave.
Sincerely,
E. Leon Smith
717-440-3002
Al
Id
DATE: FEBRUARY 13, 2012
TO: VALLEY MOTEL TENANTS
FROM: AMVETS POST #0274
SUBJECT: NEW POLICIES TO BE EFFECTIVE IMMEDIATELY
Since the AMVETS acquired the Valley Motel several months ago, we have been taking step
to make your stay with us a more pleasant one. For example, we have installed cameras or
the outside of the units to ensure your safety and we remain focused on upgrading the
interior of the rooms. We are in the process of having our Dish Network upgraded for your
convenience, and we will continue to improve our services whenever possible. We do nee(
your help however, in helping us to improve the appearance of the outside of the motel as
well as helping us to reduce monthly operating costs. Therefore, the following is a list of
policies that will become effective immediately and we ask that each of you help us in
achieving these objectives:
• Do not place boxes etc. outside the rooms. If it is to be disposed of, take it to the
dumpster. (Boxes need to be broken down/smashed to fit into the dumpster Laun
items only may be placed outside the room on Monday's for housekeeping to coNle
• Chairs, tables etc. outside your room must be taken inside when you are finished us?ng
them each day. E
K
• It is permissible to have a small microwave oven or small refrigerator in the rooms
the building was not designed to support major appliances. Therefore, if you curre
have any appliance other than a small microwave, small refrigerator, toaster etc., y
rent will be increased by $10.00 per month effective March 1, 2012 to offset the
additional electricity cost.
• Going forward, furniture and other property cannot be moved or transferred from ne
room to another without specific permission from the AMVETS.
4
p
JJ--I{3
Date: April 21, 2012
To: Lori Nailor
From: AMVETS #274
Subject: Maximum Occupancy
Lori:
This is to confirm our conversation of April 19, 2012 regarding) ber of tenants that are
permitted to occupy any one room at the Valley Motel. As statefi*M our conversation, tenantA Wn
a room where two beds are provided shall not be permitted to have more than two guests occupy
room at any time.
We assume that you have complied with our policy and we thank you for your co-operation. Thank
you.
t ,a
l ?-- I/ ? o C.v.,l
DATE: May 23, 2012
TO: VALLEY MOTEL TENANTS
FROM: AMVETS COMMANDER
SUBJECT: PROCEDURAL CHANGES
We have had a number of problems relating to mail delivery. Some tenants have had mail lost and
others have concerns about when their mail will be delivered. So, in order to accommodate everyone a
much as we can, we are putting the following policy in place immediately:
IT WILL BE THE RESPONSIBILITY OF EACH TENANT TO VISIT THE MAIL BOX THAT IS LOCATED BESIDE THE
AMVETS MAILBOX ALONG THE RITTNER HIGHWAY TO RECEIVE YOUR DAILY MAIL. HOUSEKEEPING WILT
NO LONGER BE DELIVERING OR REMOVING TENANT MAIL FROM THE MAILBOX.
In order to make improvements as needed, we would like for you to let us know if you are having any
issues with your air conditioners, plumbing, furniture that needs repaired or replaced, etc.
)I-105-11 'C J` l
AMVETS POST 0274
1580 RITNER HIGHWAY
CARLISLE, PA 17013
TO: LORI NAILOR, UNIT 19
FROM: AMVETS COMMANDER
SUBJECT: NOTICE TO VACATE PREMISES
DATE: June 9, 2012 P'yj
• On May 1, 2012 your rental payment was short in the amount of $40.00. We agreed to allow
you to pay the $40.00 along with your regular monthly payment of $6Q0.00 on June1. This
promise was not kept. I
>P?
• In April of this year an incident occurred involving your son who became belligerent when
confronted about his staying in your unit. On April 19 following this incident we advised you
that your unit could not house more than two people over night
• On June 8, 2012 when I called on you regarding your past due rent, I noted that six people
occupying the unit. When asked if your son and his family were living with you again, your
was that they only spent the night
• As of June 9, you are past due in the amount of $180.00 plus $40.00 owed for May, a total of
$220.00. It appears that your current unit is not affordable to you and since You have failed to
comply with our occupancy policy, we are advising you that you must vacate the premises by
Friday, June 15, 2012. All personal belongings must be removed from the premises by that tin
since arrangements are being made to install a new lock.
-COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS NOTICE OF APPEAL
Judicial District, County Of FROM
MAGISTERIAL DISTRICT JUDGE JUDG MENT
COMMON PLEAS No.
413
6
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 Ma isterial District
Judge on the date and in the case referenced below.
NAME OF APPELLANT MAG. DIST. NO. NAME OF MDJ
l02 1 09-3-02l.- 'o. ?. y -
ADDRESS OF APP LANT 1 1 CITY STATE
1 S S (3 +` n er L`' w Rrv l ZIP CODE
?`7 v t
DATE OF JUDGMENT IN THE CASE OF a(tiainarr) n
an
0-1 - Q Go t ,
oy-N (^
t T\ ?s LO ? \ ?/('')0M l F_
DOCKET No. SIGNATURE OF APPELLANT OR ATTORNEY OR AGENT
20 ?- - L 0000 0 1 R
This block will be signed ONLY when this notation is required under Pa. f appellant was Claimant (tee Pa. R.C.P.D.J. No. 10 91(6) in action
R.C.P.D.J. No. 100813.
This Notice of Appeal, when received by the Magisterial District Judge, will before a Magisterial District Judge, A COMPLAINT MU ST BE FILED
operate as a SUPERSEDEAS to the judgment for possession in this case. within twenty
(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 Ma isterial District
Judge. 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 t is appeal
Name of appellee(s)
(Common Pleas No. / ... y 3 ) within twenty (20) days after service of rule or suffer entry of judgment o non pros.
? 4
1
0A
Signature of appellant or atto ey or agent
RULE: To L? I -?-? 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 I ate 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: V-1 20 )
-Signat ? f
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF I PAEAL.
AOPC 312-05
1. ff
THE'Rt? 6I?€C ?, ;,
2012 JUL 13 PM 2: 2
N PEN LNO COUNT"
VANIA
-COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND Notice of .IUCIC,f17ent/TPaRS t'IPt
Residential Lease
Mag. Dist. No: MDJ-09-2-02
MDJ Name: Honorable Jessica Brewbaker Leon Smith
V.
Address: 18 North Hanover Street, Suite 106 Lori Nailor
Carlisle, PA 17013
Telephone: 717-240-6564
Amy Ellen Hirakis, Esq.
Midpenn Legal Services Docket No: MJ-09202-LT-000008 -2012
401 E Louther St Ste 103 Case. Filed: 6/25/2012
Carlisle, PA 17013
Disposition Details
Grant possession.
Grant possession if money judgment is not satisfied by the time of eviction. Yes
No
Disposition Summary
Docket VN plamti? Defendant Disposition Qua
MJ-09202-LT-0000080-2012 Leon Smith .
Lori Nailor Judgment for Plaintiff 07!03/2012
Judgment Summary
PBrtiQiI?J JoinUSeveral Liability Individual Liability
Leon Smith $0.00 Amou
$0.00
Lori Nailor $0.0
$0.00 $124.33 $124.3
Judgment Detail ("Post Judgment)
In the matter of Leon Smith vs. Lori Nailor on 7/03/2012. the judgment was awarded as follows:`
The amount of rent per month, as established by the Magisterial District Judge, is $600.00
Judament Component JointlSeveral Lia ility Individual Liability Deposit Applied
Costs $0.60 $124.33 oun,
$124.3
Grand Total: $124.3
Portion of judgment for physical' damages arising out of residential leaser
IN AN ACTION INVOLVING A RESIDENTIAL LEASE,. ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR PO SESSION
WITHIN TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/ LERK OF
COURT OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUD MENT, IF
ANY. IN ORDER TO OBTAIN A SUPERSEDEAS, THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF CO RTS THE
LESSER OF THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED. HOWEVER, LO -INCOME
AND/OR SECTION 8 TENANTS SHOULD REFER TO Pa.R.C.P.M.D.J. NO. 1008 OR 1013 FOR DIFFERENT PROCEDURES REGARDING THIS
DEPOSIT.
IF A PARTY WISHES ONLY TO APPEAL 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/ LERK 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 THEN TICE OF
APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGE , 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,
OR OTHERWISE COMPLIES WITH THE JUDGMENT. SETTLES ,
MDJS 315A
Page 1 of 3 Printed: 07/03/2012 1 1: 6:29AM
wIUJ,3.3-1OA Page 2 of 3
Printed: 07/03/2012 1
COMMONWEALTH OF PENNSYLVANIA l , U' 0-413 56 C-Il
COURT OF COMMON PLEAS PLAINTIFF: NAME and ADDRESS
County Of ?umt?.? a nC? ?? }rJ 5h UL? cZ V
5? ? ? ?5 ,? ?.?. I i"I dIS
? C ? cz. J
vs.
DEFENDANT: NAME and ADDRESS
t-A u") L1
C?c2?;St? PrA, C)L
I Common Pleas Docket No. I I
TENANT'S SUPERSEDEAS AFFIDAVIT (NON-SECTION 8)
FILED PURSUANT TO Pa.R.C.P.M.D.J. No. 1008C(2)
I, V Dip i l o k (print name and address Mere),
have filed a notice of appeal from a magisterial district court judgment awarding to my landlord
of real property that I occupy, and I do not have the financial ability to pay the lesser of three (3) ti es my
monthly rent or the judgment for rent awarded by the magisterial district court. My total household i come
does not exceed the income limits set forth in the supplemental instructions for obtaining a stay pe ding
appeal and I have completed an in forma pauperis (IFP) affidavit to verify this. I hav ave not (cross out the
one that does not apply) paid the rent this month.
I verify that the statements made in this affidavit are true and correct to the best of my knowle dge
information and belief. I understand that false statements herein are made subject to the penalties of 18
Pa.C.S. § 4904, relating to unsworn falsification to authorities.
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Date SIGNATURE F TENANT
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AOPC 312-08 (B)
3
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
V. Sd
NO.'?- 3CIVIL TERM
W n.. + 10 9
Defendants
ORDER OF COURT
AND NOW this r O day of , 2012, upon consideration of the
attached Petition and Affidavit, the petitioner is allowed to proceed in forma pauperis.
BY THE COURT,
,Judge
Distribution
Plaintiff: ?t0f1 Y?n? c-)
C w
`
Name m
Address CD
X21i51? L-10 c °
a
Defendant: UR i not 2CD Z
Name *&-
L`?g0'\L i e r 4u
Address
or'r 'S w ` ho n e-
pn i C vNa -e k } U'r C9