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HomeMy WebLinkAbout12-4930i M x :a Katie J. Maxwell, Esquire s: Attorney I.D. No. 206018 -? MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER _ c MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff .y _J v DORIS E. FAHNESTOCK and : IN THE COURT F COMMON PLEAS OF MAX A. FAHNESTOCK, CUMBERLANDCOUNTY, PENNSYLVANIA Plaintiffs V. NO. 2012 - 9130 CIVIL TERM REBECCA GREEGER, Defendants NOTICE You have been sued in court. If you wish to defend against the claims set forth in following pages, you must take action within twenty (20) days after this Complaint and Notice served, by entering a written appearance personally or by attorney and filing in writing with the cc your defenses or objections to the claims set forth against you. You are warned that if you fail to so, the case may proceed without you and a judgment may be entered against you by the court with, further notice for any money claimed in the Complaint or for any other claim or relief requested the Plaintiffs. You may lose money or property or other rights important to you. i-= YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DON T 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 LAWYI1,R, THIS OFFICE MAY BE ABLE PROVIDE YOU WITH INFORMATION ABOUT AGECIES THAT MAY OFFER LEG L SERVICES TO ELIGIBLE PERSONS AT A REDUCE F 13E OR NO FEE: Cumberland County Bar As ciation 32 South Bedford Stre Tt Carlisle, Pennsylvania 1 013 Telephone (717) 249-31,66 X03' r k1-J? y dl8 T _ 1 F TILEST Tents\8549 Fahnestock\8549.19\8549.19.eom.wpd Katie J. Maxwell, Esquire Attorney I.D. No. 206018 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DORIS E. FAHNESTOCK and IN THE COURT OF COMMON PLEAS OF MAX A. FAHNESTOCK, CUMBERLAND COUNTY, PENNSYLVANI, Plaintiffs V. : NO. 2012 - 143 b CIVIL TERM REBECCA GREEGER, Defendants COMPLAINT AND NOW, come the Plaintiffs, Max A. Fahnestock and Doris E. Fahnestock, by through their attorneys, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, in support of their Complaint, aver as follows: 1. Plaintiffs are Doris E. Fahnestock and Max A. Fahnestock, adult individuals at 23 South Baltimore Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 2. Defendant is Rebecca Greeger, an adult individual residing at 927 North West Carlisle, Cumberland County, Pennsylvania 17013. 3. Defendant entered into a lease with Plaintiffs on November 20, 2004, to rent property located at 17 South Baltimore Avenue, Mt. Holly Springs, Cumberland Pennsylvania. A copy of the Lease is attached as Exhibit "A." 4. The term of the Lease was from for one year and renewed year to year November 30, 2010. 5. The monthly rent obligation was set at $675.00. 6. As of November 30, 2010, the parties operated under a month-to-month lease wi the same terms as the lease attached hereto and marked Exhibit `A.' 7. Defendant was routinely past due on her rent.! As of January 8, 2011, Defendant Plaintiff $7,175.00 in past due rent. (see letter to Defendants dated January 8, 2011, attached and marked Exhibit `B.') 8. On February 29, 2012, Defendant executed a contract extending her lease March 31, 2012, in exchange for her promise to pay all past due rents and utilities by June 30, 2 12. (A copy of the contract is attached hereto and marked Exhibit `C') 9. Defendant vacated the property in April 2012. 10. Defendant last paid rent in December 2010, when she made a partial payn $175.00. 11. Defendant owes rent for the remaining portion of December 2010, the entire 2011, and January through April 2012 as follows: TIME PERIOD BALANCE OWED December 2010 $ 500.00 January 2011 through December 2011 $8,100.00 January 2012 through April 2012 $2,700.00 12. Defendant failed to remove personal property from the property, and Plaint incurred significant costs to remove and dispose of Defendant's trash. Plaintiffs' costs for tr removal and cleanup of property were $3,223.00. 13. Defendant left the property in a damaged condition which Plaintiffs were forcec repair. Plaintiffs' costs in repairing the property were $2,792.06 after Defendant's security depc was applied to the cost of the repairs. 14. Defendant failed to replace the fuel oil that she used as required in paragraph 9 Rider A of the lease. The cost to the Plaintiffs to replace the fuel oil was $1,031.25. WHEREFORE, Plaintiffs respectfully request this Honorable Court to enter judgment in th favor and award Plaintiffs $18,346.31 plus costs and interest. MARTSON LAW OFFICES Date: U f--f I (2 By: Katie J. ell, Esquire I.D. No. 06018 10 East High Street Carlisle, PA 17013 (717) 2433341 Attorneys!for Plaintiffs for °of to t THIS IS A DEBT COLLECTION FIRM ATTEMPTING TO COLLECT A DEBT FOR DORIS AND MAX FAHNESTOCK. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT "A" `h1389-f{uuse Icasc. plain language. 5-86 ©1984 Julius t)lumberg, Inc{., Publisher, NYC I0013 THIS IS A LEGALLY BINDING LEASE THAT WILL BECOME FINAL WITHIN THREE BUSINESS DAYS. DURING THIS PERIOD YOU MAY CHOOSE TO CONSULT AN ATTORNEY WHO CAN REVIEW AND CANCEL. THE LEASE. SEE SECTION ON ATTORNEY REVIEW FOR DETAILS.* HOUSE LEASE The Landlord and the Tenant agree to lease the House for the Term and at the Rent st ted, as follows: The words Landlord and Tenant include all landlords and all tenants under this Lease. Landlord Aaris.. ...&.Max.A,..Fahneatock.......... Tenantulph.Sawles,..Jr...&.Re cc&.ODortnell. 23 S. Balftt&e Ave., Mt. Holly Springs' PH,, ,r, ^^^Ir' ^ ,II dull r,nmn who will lie, in Alwnmo^l. inch mun it. Ihi, Leos. It. ...................................... ................................ .......... .............................................................. Zip House (including grounds on which it is located)17.. S -Baltimore. Ave.., . Mt.. Holly. Springs,.TA .17065......... . Add-, ....... (See. Ri)der. A) .......................... . ................................................................................... Date of Lease.....N?mber_ 20 2004 Rent for the Term is $ 700.00. Per. M0 ............ 19""' .. The Rent is payable in advance on the first da.of.each.mont.h, Three ( Term 3)......... Yearnd 11 Days as follows: .................................................... .............s. . .a.. 11/20/04 If by check: Make payable to A. Fahnest Beginning ................................19....... 11/30/07 at 23 S. Baltimore Ave. If.by cash: Deliver Ending ...................................19........ Security $.....700..00...... deposited at .................. M. &..T..Bank,. Mt.; Holly. S . {arix> s .PA... ]am,•nn.l :,d,he....l Ix,11A.?„?„ Il.^I1,..^.i„?..,., I,1„ , ..... ................. . . . . . . . . . . . . . . .. ... . . . . . .. . .................. .............................................................. Broker. The Landlord and the Tenant recognize ............. ? A4trwaph • zl. fQT• fl4tum • r 8? S ......... ..... Not;..AppliQa ble ............................. . ...... .............................................................. . ............................................................... ............................................................... as the Broker who brought about this Lease. The ........... shall a the Broker's commission. Additional agreements Landlord. ript. responsible. for. loss..to. Tenant'.& -personaL. pro arty .......... ............ (See. Paragraph. LS) ................... . ...................................................................... ...........Rider. A. dated. Navernber.. 20,..2004. ...................................................................................... .......................................... * Rent fran 11/20/04 thru 11/30/04 shall be at no cost. ......... ................................................ .................................... Rent fran 12/1/04 thru 12/31/04 will be $500.00. ........................................................ :.............. ............................ ............................... Full rent of $700.00/MD. will comra-ce on. 1/1/05 and rlm ............................................................................................................. to the end of the term. ....................................................................................................................... 1. Possession and Use 2. Rent 3. Additional Rent 4. Security 5. No Assignment or Subletting 6. Violation, Eviction and Re-entry 7. Damages 8. Quiet Enjoyment 9. Utilities and Services 10. Tenant's Repairs and Maintenance It. Landlord's Repairs 12. Access to House 13. No Alterations or Installation of Equipment Table of Contents I, Possession and Use The Landlord shall give possession of the House to the Tenant for the Term. The Tenant shall take possession of a0d use the House only as a private residence. Only a Tena t signing this Lease and the children of that Tenant may live in the House. The Tenant shall not use the House fora any business, professional, unlawful or hazardous purpose. Tice Tenant must not allow the House to be vacant for extended periods. to• Vicki• • (daughter. of ,landlords,) , or ,one, , of • , landlords. 14. Fire and Other Casualty 15. Liability of Landlord and Tenant 16. Subordination to Mortgage 17. Tenant's Letter 18. Notices 19. No Waiver 20. Survival 21. Renewal Lease 22. Furniture 23. End of Term 24. Binding 25. Full Agreement 26. Attorney Review 2. Rent The Tenant shall pay the Rent to the andlord at the Landlord's address. 3. Additional Rent If the Tenant fails to comply with any reement in this Lease, the Landlord may do so on behalf of he Tenant. The Landlord may charge the cost to comply t the Tenant as 'Instructions to preparer: if you are not a real estate broker or salesperson licensed by the New Jersey Real Estate Conunission, you ntay 41ete this language. "additional rent". This includes reasonable attorney's fees incurred by the Landlord as a result of the Tenant's violation of any Lease agreement. The additional rent shall be due and payable as Rent with the next monthly Rent payment. Non- payment of additional rent gives the Landlord the same rights against the Tenant as if the Tenant failed to pay the Rent. 4. Security The Tenant has given to the Landlord the Security stated above. It shall be deposited or invested by the Landlord and bear interest or yield other earnings as required by law. The balance of the interest or earnings, after deduction for the Landlord's administration expenses allowed by law, shall belong to the Tenant. The Tenant's portion of the interest or earnings shall be permitted to compound, or shall be paid to or credited for the benefit of the Tenant as provided by law. The Security shall be held in trust by the Landlord during the Term of this Lease, including any renewal or extension. It shall be used as security for the Tenant's compliance with the Tenant's obligations under this Lease. The Landlord may deduct any costs resulting from the Tenant's failure to comply with any agreement in this Lease. If the costs exceed the Security, the Tenant shall pay the additional amount to the Landlord. If the Landlord uses any of the Security during the Term, the Tenant shall promptly restore the Security to its original amount. The Security is not to be used by the Tenant for the payment of Rent without the Landlord's written consent. Within 30 days after the end of the Term, the Landlord shall return to the Tenant (a) the Security and the Tenant's portion of the interest or earnings, less any charges made under this Lease, and (b) a statement itemizing the interest or earnings and any deductions. This shall be done by personal delivery, registered or certified mail. If the Landlord's interest in the Building is transferred, the Landlord shall (a) turn over the Security plus the Tenant's portion of the interest or earnings to the new Landlord and (b) notify the Tenant of the name and address of the new Landlord. Notice must be given to the Tenant within 5 days after the transfer, by registered or certified mail. The Landlord shall then no longer be liable to the Tenant for the Security plus the Tenant's portion of the interest or earnings. The new Landlord becomes liable to the Tenant for the return of the Security plus the Tenant's portion of the interest or earnings in accordance with the terms of this Lease. 5. No Assignment or Subletting The Tenant may not do any of the following without the Landlord's written consent: (a)assign this Lease, (b) sublet all or any part of the House or(c) permit any other person to use the House except as a temporary guest. 6. Violation, Eviction and Re-entry The Landlord reserves a right of re-entry which allows the Landlord to end this Lease and re-enter the House if the Tenant violates any agreement in this Lease. This is done by eviction. Eviction is a court procedure to remove a tenant. The Landlord may also evict the Tenant for any one of the other grounds of good cause allowed by law. Eviction is started by the filing of a complaint incourt and the service ofa summons on a tenant to appear in court. After obtaininga judgment for possession and compliance with the warrant of removal, the Landlord may re-enter and take back possession of the House. If the cause for eviction is non-payment of rent, notice does not have to be given to the Tenant before the Landlord files a complaint. If there is any other cause to evict, the Landlord must give to the Tenant the notice required by law before the Landlord files a complaint for eviction. 7. Damages The Tenant is liable for all damages caused by the Tenant's violation of any agreement in this Lease. This includes reasonable attorney's fees and costs. After eviction the Tenant shall pay the unpaid Rent for the Term or until the Landlord re-rents the House, if sooner. If the Landlord re-rents the House for less than the Tenant's Rent, the Tenant must pay the difference until the end of the Term. If the Landlord re-rents the House for more than the Tenant's Rent, the Tenant is not entitled to the excess. The Tenant shall also pay (a) all reasonable expenses incurred by the Landlord in preparing the House for re-renting and (b) commissions paid to a broker for finding a new tenant. g. Quiet Enjoyment The Landlord has the right toenter into this Lease. If the Tenant complies with this Lease, the Landlord must provide the Tenant with undisturbed jpossession of the House. 9. Utilities and Services The Tenant shall arrange and pay for all utilities and services furnished to the House, including the following: (a) Heat (c)lElectric (e) 'Nash Removal (b) Hot and cold water (f) Selvage The Landlord is not liabl for any inconvenience or harm caused by any stoppage or re uction of services beyond the Landlord's control. This doe not excuse the Tenant from paying Rent or the Landlord f om promptly taking corrective action. 10. Tenant's Repairs and Maintenance The Tenant shall: (a) Pay for all repairs, replacements and damages caused by the act or neglect of the Tenant, the Tenant's family and domestic employees. (b) Keep and maintain the House and grounds in a neat, clean, safe and sanitary condition. Vehicles may be driven or parked only in the d iveway or in the garage. The Tenant shall not allow injury to the landscaping. (c) Take good care orthe House and all equipment and fixtures in it. (d) Keep the furnacelclean.(See Rider A, 1. ) (e) Keep the walks and driveway free from dirt, garbage, snow, and ice. (f) Keep nothing in Ithe House which is inflam- mable, dangerous or might increase the danger of fire or other casualty. (g) Promptly notify the Landlord when there are conditions which need repair. (h) Promptly removei from the House all garbage and debris and take to the curbifor collection. (i) Use all electric, plumbing and other facilities safely. 0) Donothingtocaus?acancellation oranincrease in the cost of Landlord's fire or (liability insurance. (k) Use no more electricity than the wiring or feeders to the House can safely Barry. (1) Obey any written instructions of the Landlord for the care and use of appliances, equipment, and other personal property in the House. (m) Do nothing to destroy, deface, damage, or remove any part of the House. (n) Do nothing to dest oy the peace and quiet of the Landlord, other tenants or persons in the neighborhood. (o) Promptly comply with all orders and rules of the Board of Health or other authorities governing the House which are directed to the Tenant!, 11. Landlord's Repairs The Landlord shall make s?ny necessary repairs and replacements to the vital facilitie serving the House within a reasonable time after notice by the Tenant. _ I 12. Access to House II 16. Subordination to Mortgage The Landlord shall have access to the House on 'this Lease and all renewals of t is Lease shall be reasonable notice to the Tenant to (a) inspect the House, (b) subordinate to all present and future mort gages on the House make necessary repairs, alterations, or improvements, (c) and grounds. In a sale of the House and gro unds arising out of supply services, and (d) show it to possible buyers, mortgage lenders contractors and insurers a court proceeding known as foreclosur e, the holder of a , . mortgage on the Ilouse and grounds may nd this Lease. The The Landlord may show the House to rental applicants Tenant shall sign all papers needed to sub )rdinatc this Lease at reasonable hours on notice to the Tenant within 3 months any mortgage the House and grou ds. If the "tenant before the end of the Term. re o fuses re, the Landlord may sign the pope s on behalf of the The Landlord may enter the House at any time without 'Tenant. notice to the Tenant in case of emergency. 17. Tenant's Letter At the request of the Landlord, the 'enant shall sign a 13. No Alterations or Installation of Equipment letter stating that (a) this Lease has not bee effect, (b) the Landlord has fully per amended and is in ormed all of the The Tenant may not make any changes or additions to Landlord's agreements in this Lease, (c) the Tenant has no the House without the Landlord's written consent. This rule rights to the House, except as stated in this Lease, (d) the includes but is not limited to: Tenant has paid all Rent to date, and (e) he Tenant has not (a) Installation of panelling, flooring, built-in ec- paid Rent for more than I month in adva also list all the property attached to the tic ec. The letter shall use which is owned orations, partitions, moldings, orally other fixture drilled Into by the Tenant. or attached to the floors, walls, or ceilings. (b) Installation of any locks or chain-guards. 18. Notices (c) Painting, wallpapering, or other decorations. All notices given under this Lease must be in writing. (d) Installation of any equipment or wiring. Each party must accept and claim the n other. Unless otherwise required by law ti otices given by the e ma be iv b (e) Change in the plumbing, cooking, air con- , (a) personal delivery, or (b) certified n y y g en y ail, return receipt ditioning, electrical or heating systems. requested. Notices shall be addressed to t to Landlord at the All changes or additions made without the Landlord's address written at the beginning of this Tenant at the House. Lease and to the written consent shall be removed by the Tenant on demajnd. All changes or additions made with the Landlord's 19. No Waiver written consent shall become the property of the Landlord when completed and paid for by the Tenant They stall Tile Landlord's failure to enforce an agreement in this . remain as part of the House at the end of the Term unless' the Lease shall not prevent the Landlord fr om enforcing the I Landlord demands that the Tenant remove them. The Ten nt agreement for any violation occurring at later time.. shall promptly pay all costs of any permitted changes a nd additions. The Tenant shall not allow any mechanic's lien other claim to be filed against the House If an lien l i or i 20. Survival 1 f an a ree t i hi L . y or c a filed against the House, the Tenant shall have it promp m s tly y g men n t s ease is cons of the Lease shall remain in effect. ry to law, the rest removed. 21. Renewal Lease The Landlord must offer the Tenant a renewal lease to 14. Fire and Other Casualty take effect at the end of the Term unless the Landlord has good cause as defined by law. The renewal The Tenant shall notify the Landlord at once of any AN lease may contain or other casualty in the House. The Tenant is not required; to reasonable changes, including any change must offers renewal lease, the L Landlord Rent when the House is unusable. If the Tenant uses part in the Term. If the shall notify shall the Tenant the renewal lease of the House for living purposes, the Tenant must pay R@nt at least Ito ( ays before lays before ( end pro-rata for the usable part. of the Term unless the tenancy is month to t oath. The Tenant must notify the Landlord of the Tena is acceptance or If the House is partially damaged by fire or other casualty rejection of the renewal lease at least 90 da . before the end of the Landlord shall repair it within a reasonable time. Titis the Ternt. If the Tenant fails to notify th e Landlord of the includes the damage to the House and fixtures installed by Ole Tenant's acceptance, it will be considered a rejection. If the Landlord. The Landlord need not repair or replace anything Tenant does not accept the renewal lease the Tenant must installed by the Tenant. vacate the House at the end of the Term. Either party may cancel this lease if the House is so damaged by fire or other casualty that it cannot be repaired 22• Furniture within 90 days. If the parties cannot agree, the opinion of a If the House is leased in furnished con ition, the Tenant contractor chosen by the Landlord and the Tenant will be shall maintain the furniture and furnishings in good orderand binding on both parties. repair. A list of the furniture and furnishing is attached to this Lease as "Rider A". The Tenant's signature This Lease shall end if the House is totally destroyed. The m Rider A means that the list is accepted as correct and all Tenant shall pay Rent to the date of destruction terns arc in good . condition. If the fire or other casualty is caused by the act or neglect of the Tenant, the "Tenant's family or domestic employees, the Tenant shall pay for all repairs and all other damages. 15. Liability of Landlord and Tenant The Landlord is not liable for loss, injury, or damage (o any person or property unless it is due to the Landlord's act or neglect. The Tenant is liable for any loss, injury or damage to any person or property caused by the act or neglect of the Tenant, the Tenant's family or domestic employees. 23. End of Tenn At the end of the Term the Tenant hall (a) leave the Houseclean,(b)removealloftheTenant's roperty,(c)repair all damage including that caused by movi g, and (d) vacate the House and return it with all keys to the Landlord in the same condition as it was at the beginning o the Term, except for normal wear and tear. If the Tenant leaves any property i the House, the Landlord may (a) dispose of it and charge a Tenant for the cost of disposal, or (b) keep it as abandone property. 24. Binding This Lease is binding on the Landlord and the Tenant and all parties who lawfully succeed to their rights or take their places. 25. Full Agreement The parties have read this Lease. It contains their full agreement. It may not be changed except in writing signed by the Landlord and the Tenant. 26. Attorney Review I. Snub- hr AnorneY. The Tenant or the Landlord may choose to have an attorney study this lease. if an attorney is consulted, the attorney must complete his or her review of the lease within a three-day period. This lease will be legally binding at the end of this three-day period unless an attorney for the Tenant or the Landlord reviews and disapproves of the lease. 2. Counting the Thne. You count the three days from the date of delivery of the signed lease to the Tenant and the Landlord. You do not count Saturdays, Sundays or legal holidays. The Tenant and the Landlord may agree in writing to extend the three-day period for attorney review. 3. NoticeojDisapproval. Han attorney for the Tenant or the Landlord reviews and disapproves of this lease, the attorney must notify the Broke s) and the other party named in this lease within the three-day period. Otherwise this lease will be legally binding as written The attorney must send the notice of disapproval to the Broker(s) by certified mail, by telegram, or by delivering it rsonally. The telegram or certified letter will be effective upon sending. The personal delivery will be effective upon tilivery to the Broker's office. The attorney may also, but nee not, inform the Broker(s) of any suggested revision(s) in the lease that would make it satisfactory. Signatures The Landlord and the Tenant agree to the terms of this Lease by signing below. If a party is a corporation, this Lease is signed by its proper corporate officers and its corporate seal is affixed. D Witnessed or tI LU¢ attested by: Max A. tFahnestock Landlord - - - - - - - - - - - - - - - - - - - - - - As to Landlord `?? » ^ w' a AA L Doris E. Fahnestock Landlord _ sneer. 1 r. Tenant As to Tenant enter - - - - - - - - - - - - - - - Re ca 0 Donne Tenant 'Instructions to prepares If you are not a real estate broker or salesperson licensed b), the New Jersey Real Estate Commission, you nrar delete this language. Rider A Attached to and made a part of House Lease for premises located at 17 S. Baltimore Avenue, Mt Holly Springs, PA. dated by and between Ralph Samples, Jr. & Rebecca ODonnell, Tenants and Doris E. & Max A. Fahnestock, Landlords. 1 IM 0(d) Change to: Landlord will maintain the (furnace. 2, Tenant shall not under any circumstance burin any combustible material in the fireplace. 3. Tenant shall not place or use any heavy furniture (such as water beds, safes, etc.) in the house without writtenl permission of the Landlord. 4V1 0(b) Add: Alleyway to the North side of the roperty shall not be used for parking except for stopping and/ unloading. Parking Area is provided at the East end of the for Tenant (2 spaces shall be designated) use. Landlord, at his discretion, shall manage the use of the parking lot. 5.114 O(b) Add: Landlord will direct and perform tie maintenance of the grounds, with assistance from the Tenant' Tenant will be responsible for the flower beds and snow removal from the front sidewalk. Garden area will be shared by Tenant and Landlord. 6.AI Add: Landlord reserves the right to build, ect or alter the property (including house and grounds). Te nt shall be properly notified and Tenant's quiet enjoyment shall be maintained. 7. No pets are permitted except the one (1) cat resently owned by the Tenant Tenant assures that the cat is d , house trained, spayed and will be maintained in the house. Witten permission must be obtained from Landlord for any additional ts. Any damage caused by Tenants pet shall be corrected at the expense of the Tenant as deemed necesary by the Landlord. 8.1-?22 Add: Landlord has provided an electric range and regrigerator for Tenant use. 9. Tenant acknowledges that the fuel tank is full a time of occupancy. Upon vacating the premises Tenant at his expense, will refill the tank to a full condition. Landlord: (.( <<.J? v M*A.ahnestock pa te CL 1.71 PIN- Doris E. Fahn toc Date y Tenant: / f 0 /0 p mple, Date ?D o2Qt?? Rebecca ODonnell Date EXHIBIT `B" 23 S. Baltimore Avenue MT. Holly Springs, PA 17065 January 8, 2011 Rebecca Cdr 17 S. Baltimore Avenue Mt. Holly Springs, PA 17065 Re: 17 S. Baltimm Avenue Mt. Holly Springs, PA 17065 Dear Becky, Enclosed is your Watw/Sewer/Trash bill which is dui for payment on 2/1 it 1. Also, I want to remind you that your Lease termin@M4 on 11/30110 and that a verbal month to month Loewe now applies. Presently, as of January 2011, your past due rem iw $t,175.00 which has to be addressed ASAP along with other resolved issues previously discussed. Sincerely, ?"4 Max A. ?ahnestock Encl. I EXHIBIT °°C" 23 S. Baltimore Avenue Mt. Holly Springs, PA 17065 February 28, 2012 Ms. Rebecca Greeger 927 N. West Street Carlisle, PA 17013 Re: 1. Letter dated 1227/11 from Max A. Fahnestock to Rebecca Greeger relative To House Lease at 17 S. Baltimore Ave., K*. Holly Springs 2. Letter dated 2/26112 from Rebecca Greeg* to Max A. Fahnestock requesting extension of termination date Dear Becky, I am willing to extend the termination date to March 31, 2012 provided the following are met. 1. That you keep me informed of your activities dative to the vacating showing me your schedule and status necessary to accomplish th termination date of March 31, 2012. 2. That you perform your vacating in accordance w?th the term and conditions expressed in the Original Lease and all Amendments and correspondence related to the Lease. 2. That you pay all associated costs and expenses in due time (Rents-Utilities-Damages) to the Landlord no later than June 30, 2012. This letter will be binding upon the signatures of th Tenant (Rebecca Greeger) and the Lan (Max A./Doris E. Fahnestock). Please sign both copies and return them to me. 1'II return a completed, executed copy to you. Sincerely Max A. Fahnestock Agreement Si star 9 .N5 *Tenant Land lo Landlord 4 --'ClIQ Date Date _3-3-\ Date P. S. Thank you for your payment of the W-S-T bi 11. ?:opy of receipt enclosed. VERIFICATION The foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and my own. I have read the document and to the extent! that it is based upon information which I have given to my counsel, it is true and correct to the be$t of my knowledge, information and belief. To the extent that the content of the document is !that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject ? o the penalties of 18 Pa. C.S. Sectio 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. MAX FA FSTn S?) 0"? DORIS F , ?. N-- ' TOCK SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff H Qti,gt15` p# :°trrlf[rr7y Pal i HCN is{Ry Jody s smith Chief Deputy 2812 SEP -6 AM 10: 12 Richard W Stewart ;(j(? Solicitor AND COUNTY - YLVANIA Doris E. Fahnestbck (et al.) vs. Case Number . Rebecca Greeger 2012-4930 SHERIFF'S RETURN OF SERVICE 08/24/2012 08:04 PM - Shawn Gutshall, Deputy Sheriff, who being duly swom according to law, states that on August 24, 2P12 at 2004 hours, he served a true copy of the within Complaint and Notice, upon the within named defe dant, to wit: Rebecca Greeger, by making known unto Josh Stamer, Fiance to Rebecca Greeger and adult in charge at 927 N. West Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct co of the same. N>KDM UTSHALL, bEPUTY- SHERIFF COST: $34.45 August 29, 2012 SO AN EERS,/z 4 / SW Z RON R ANDERSON, SHERIFF (c) CountySuite Shenff, Teleosoft, Inc.