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HomeMy WebLinkAbout12-6677IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA George P. Stojkovich, Jr., Civil Action Plaintiff, v• No. 2012 - `~'`/'7 Z~ ° --~ ~~ Becky Shetron N~ z ~ ° , Defendant r - ~° ~~• _ x NOTICE ~ « ~~ .~~` You have been sued in Court. If you wish to defend against the claims set forth in the following page, 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 claims 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. Lawyer Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Telephone: 1-800-990-9108 (PA ONLY) or 717-249-3166 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans With Disabilities Act of 1990. For information about accessible facilitie ~ia3.7s ~~..~~ c~ ~say~' ~~~~~ and reasonable accommodations available to disabled individuals having business before the court, please contact the office of the Court Administrator. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA George P. Stojkovich, Jr., Civil Action Plaintiff, v. Becky Shetron, No. 2012 - Defendant COMPLAINT NOW COMES, George P. Stojkovich, Jr., by and through his attorneys, Sharpe & Sharpe, LLP, and files the following complaint against Becky Shetron, on the following cause of action: 1. Plaintiff is George Stojkovich, Jr. (hereinafter "Stojkovich"), an adult individual residing at 10 Cabin Lane, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant is Becky Shetron (hereinafter "Shetron"), an adult individual residing at. 8 Goodhart Street, Walnut Bottom, PA 17266. 3. Stojkovich leased property to Shetron with a property address of 402 West Main Street, Walnut Bottom, PA Cumberland County, 17266. A true and correct copy of the lease (the "Lease") is attached hereto as Exhibit "A" and hereby incorporated herein by reference. 4. At the time, Shetron took possession of the property, the premises had been renovated completely and no one had lived in the premises since renovations were made. 5. Under the Lease, Shetron was responsible to deliver the premises back to Stojkovich in as good condition as when delivered to Shetron, ordinary wear and tear excepted. 6. Shetron terminated the lease on January 31, 2012. 7. When Shetron left the property, she failed to return it in the same condition with only ordinary wear and tear. 8. The premises were left damaged in the following respects: a. The washer discharge box was cracked during the tenancy (Landlord made temporary repairs during the term). b. Water from a new washing machine was allowed to overflow which damaged the kitchen ceiling and soffit. c. Seven balustrades were displaced from the banister to the second floor and screw buttons missing. d. Pipes under kitchen sink were displaced causing leaks. e. Broken cabinet hinge. f. Damaged trim around base of fire place. g. Expandable insulation was improperly installed in family room window. h. Black soot was left on second floor hall ceiling and stairway. i. Extra bedroom (purple) had holes in walls and tenant left in poor repair condition with excessive spackle and improper sanding before painting. j. windows were repainted using flat paint instead of satin to match sills. k. Small (tan) bedroom had damaged drywall throughout. I. Second floor bathroom had black soot on walls and light fixtures. m. House was full of black dust and soot and needed thorough cleaning. n. Cat odor, stains and paint on carpet. o. Kitchen and second floor bathroom had grime in the grout. p. Broken countertop on kitchen island and two broken drawers. q. 26 light bulbs missing. r. Cracked window jams at joints. s. Damage to side door by curtain rod. t. Damage to yard. 9. In order to restore the premises to acceptable condition, Stojkovich hired subcontractors to make repairs at a total cost of $4,471.09. Copies of the invoices are attached hereto as Exhibit 'B." and hereby incorporated herein by reference. 10. Stojkovich did collect a security deposit of $1,100.00 which offset the costs of repair. 11. The Lease provides that Stojkovich may collect attorneys' fees as a result of Shetron's possession, use or misuse of the premises. Attorneys' fees will be not less than $500.00 through the filing of the complaint and $1,000 for prosecution of this case to arbitration. WHEREFORE, plaintiff George Stojkovich, Jr. demands judgment in his favor for $3,371.09, or other amounts shown to be due him, interest thereon as appropriate, and costs of suit, including attorneys' fees permitted by contract, which amount is within the jurisdictional limits. of arbitration. „ ,., S By: V ~ ~ J. M Dowell pe, sq. Att ney for Plaintiff 25 Lincoln Way East C mbersburg, PA 17201 Pa. Id. No. 37505 ~ /~ _~ •- A v~ 'j F / ~~ / I REAL ESTATE LEASE This Lease Agreement (this "Lease") is dated December 1, 2010 by and between GEORGE P. STOJKOVICH, JR. ("Landlord"}, and Becky Shetron (`Tenant"). The parties agree as follows: PREMISES. Landlord, is consideration of the lease payment provided in this Lease, leases to Tenant Becky Sheton ("the "Premises"} located at 402 West Main Street, Walnut Bottom, Pa. 17266. TERM. The Lease term will begin on December 31, 2009 and will continue on a Month to Month Lease. LEASE PAYMENTS. Tenant shall pay to Landlord lease payments of $1,100.00 payable in advance on the first day of each month, for a total lease payment of $1,100.00. Lease payments shall be made to Landlord at 401 West Main Street, Walnut Bottom, Pa. 17266, which may be changed from time to time by Landlord. SECURITY DEPOSIT. At the time of the signing of this Lease, Tenant shall pay to Landlord, in trust, a security deposit of $1,100.00 to be held and disbursed for Tenant damages to the Premises or other defaults under this Agreement (if any) as provided by law. POSSESSION. Tenant shall be entitled to possession on the first day of the term of this Lease, and shall yield possession to Landlord on the last day of the term of this Lease, unless otherwise agreed by both parties in writing_ At the expiration of the term, Tenants shall remove its goods and effects and peaceably yield up the Premises to Landlord in as g good as condition as when delivered to Tenant, ordinary wear and tear excepted. OCCUPANTS. No more than 6 person(s) may reside on the Premises unless the prior written consent of the Landlord is obtained. PETS. Pets shall not be allowed without the prior written consent of the Landlord. At the time of signing this Lease, No Pet Allowed. FURNISHINGS. The following furnishings will be provided by Landlord: STOVE TOP, DISHWASHER, OVEN AND MICROWAVE. Tenant shall return all such items at the end of the lease term in a condition as good as existed at the beginning of the lease term, normal wear and tear excepted. STORAGE. Tenant shall be entitled to store items of personal property in the storage basement for the term of this Lease. Landlord shall not be liable for loss of or damage to, such stored items. Tenant shall not be entitled to the access of the attic. { ~~, y ~6' PROPERTY INSURANCE. Landlord and Tenant shall each be responsible to maintain appropriate incnrance for their respective interests in the Premises and property located on the Premises. RENEWAL TERMS. This Lease shall automatically renew for an additional period of Month to Month per renewal term, unless either parry gives written notice of termination no later than 30 day prior to the end of the term or renewal term. The lease terms during any such renewal term shall be the same as those contained in this Lease. KEYS. Tenant will be given 2 key(s) to the Premise. If all keys are not returned to Landlord following termination of the Lease, Tenant shall be charged $35.00. LOCKOUT. If Tenant becomes locked out of the Premises, Tenants will be chazged $5.00 to regain entry if lockout occurs more than once per month. MAINTENANCE. Landlord shall have the responsibility to maintain the Premises in good repair at all times and perform all repairs necessary to satisfy any implied warranty of habitability except that Tenant will be responsible for -MOWING ALL GRASS (FRONT, BACK AND BOTH SIDES) LEAF REMOVAL UTILITIES AND SERVICES. Landlord shall be responsible for the following utilities and services in connection with the Premises: -Water, Sewer, Tenant shall be responsible for the following utilities and services in connection with the Premises: -Electricity PP&L -Telephone Service -Cable Service -Garbage/Trash disposal (Provided by IES)7 Tenant acknowledges that Landlord has fully explained to Tenant the utility rates, charges and services for which Tenant will be required to pay (if any), other than those to be paid directly to the utility company furnishing the service. Tazes. Taxes attributable to the Premises or the use of the Premises shall be allocated as follows: REAL ESTATE TAXES. Landlord shall pay all real estate taxes and assessment for the Premises. TERMINATION UPON SALE OF PREMISES. Notwithstanding any other provision of this Lease, Landlord may terminated this lease upon 30 days' written notice to Tenant that the Premises have been sold. HABITABLEITY. Tenant has inspected the Premises and fixtures (or had had the Premises inspected on behalf of the Tenant), and acknowledges that the Premises are in a reasonable and acceptable condition of habitability for their intended use, and the agreed lease payment are fair and reasonable. If the condition changes so that, in Tenant's opinion, the habitability and rental value of the Premises aze adversely affected, Tenant shall promptly provide reasonable notice to Landlord. Tenant will complete a house inspection worksheet prior to moving in. DEFAULTS. Tenant shall be in default of this Lease if Tenant fails to fulfill any lease obligation or term by which Tenant is bound. Subject to any governing provisions of law to the contrary, if Tenant fails to cure any financial obligation within 5 days (or any other obligation within 10 days) after written notice of such default is provided by Landlord to Tenant, Landlord may take possession of the Premises without further notice (to the extent permitted by law}, and without prejudicing Landlord's rights to damages. In the alternative, Landlord may elect to cure any default and the cost of such action shall be added to Tenant's financial obligation under this Lease. Tenant shall pay all costs, damages, and expenses (including reasonable attorney fees and expenses) suffered by Landlord by reason of Tenant's defaults. All sums of money of chazges required to be paid by Tenant under this Lease shall be additional rent, whether or not such sums or charges are designated as "additional rent". The rights provided by this paragraph are cumulative in nature and are in addition to any other rights afforded by law. LATE PAYMENTS. For each payment that is not paid within 1st day after its due date, Tenant shall pay a late fee of $5.00 per day, beginning with the day after the due date. HOLDOVER If Tenant maintains possession of the premised for any period after the termination of this Lease ("Holdover Period"), Tenant shall pay to Landlord lease payment (s) during the Holdover Period at a rate equal to the normal payment rate set forth in the Renewal Terms paragraph. CiJMiJLATIVE RIGHTS. The rights of the parties under this Lease aze cumulative, and shall not be construed as exclusive unless otherwise required by law. NON-SUFFICIENT FiJNDS. Tenant shall be charged $30.00 for each check that is Returned to Landlord for lack of sufficient funds. ACCESS BY LANDLORD TO PREMISED. Subject to Tenant's consent (which shall not be unreasonably withheld), Landlord shall have the right to enter the Premises to make inspections, provide necessary services, or show the unit to prospective buyers, mortgagees, tenants, or workers. However, Landlord does not assume any liability for the care or supervision of the Premises. As provided by law, in the case of an emergency, Landlord may enter the Premises without Tenant's consent. During the last three months of this Lease, or any extension of this Lease, Landlord shall be allowed to display the usual "For Rent" signs and show the Premises to prospective tenants. INDEMNITY REGARDING USE OF PREMISES. To the extent permitted by law, Tenant agrees to indemnify, hold harmless, and defend Landlord from and against any and all losses, claims, liabilities, and expenses, including reasonable attorney fees, if any, which Landlord may suffer or incur in connection with Tenant's possession, use or misuse o£the Premises, except Landlord's act or negligence. DANGEROUS MATERIALS. Tenant shall not keep or have on the Premises any article or thing of a dangerous, flammable, or explosive character that might substantially increase the danger of fire on the Premises, or that might be considered hazardous by a responsible insurance company, unless the prior written consent of Landlord is obtained and proof of adequate insurance protection is provided by Tenant to Landlord. COMPLIANCE WITH REGULATIONS. Tenant shall promptly comply with all laws, ordinances, requirements and regulations of the federal, state, county, municipal and other authorities, and the fire insurance underwriters. However, Tenant shall not by this provision be required to make alterations to the exterior of the building or alterations of a structural nature. SUBORDINATION OF LEASE. This Lease is subordinate to aay mortgage that now exists, or may be given later by Landlord, with respect to the Premises. ASSIGNABILITY/SUBLETTING. Tenant may not assign or sublease any interest in the Premises, nor assign, mortgage or pledge this Lease, without prior written consent of Landlord, which shall not be unreasonably withheld. NOTICE. Notices under this Lease shall not be deemed valid unless given or served in writing and forwarded by mail, postage prepaid, addressed to the parry at the appropriate address set faith below. Such addresses may be changed from time to time by either party by providing notice as set forth below. Notices mailed in accordance with these provisions shall be deemed received on the third day after posting. LANDLORD• George P. Stojkovich, Jr. 10 Cabin Lane Shippensburg, PA 17257 532-8406 OR Cell 717-729-6406 TENANT: Becky Shetron 44~ west Main Street Walnut Bottom. Pa. 17266 Such addresses maybe cb$nged from time to time by either party by Providing notice as set forth above. GOVEIItNIlYG LAW. This Lease shad be con~ued in accordance with the taws of the State of Permsyivama. E~N17lE2E AGP~EEMENT/A~ME1~1D~I+IENT. This I~,ease cornains the e~rtire agreemetrt of the parties and there are no other promises, condi#ions, understandings or otl~ agreemerrts, whether oral or writteq r to the subject matter of this Lease_ This Lease may be wed or amended in writing, if the writing is signed by the party obligated under the amendment. SEVERABILLITY. If any portion of this Lease shall be held to be invalid or unenforceable for any reason, the remaining provisions shall continue to be valid and e~orceable. If a court finds that arty provision of this Lease is .invalid or unenforceable, but that by limiting such provision it would become valid and erble, then such provision shall be deemed to be written, t~nstrued, and eflforced as so limited_ WA-1[VER_ The failure of either party to enforce any provision`s of this Lease shad not be construed as a waiver or limitation of that party's right to subsequerrtly enforce and compel strict compliance with every provision of this Lease. BIlYDING EFFECT: The provisions of this Lease sl~lt be binding upon and inure to the benefit of parties and their respective legal representatives, succes.~ors and assigns. ~~ ~~~ GEORGE P. JKQVICH, JR. DATE TENANT'S: _ :~ ~ ~C~Ci~ ~ ~~ DATE RESIDENTIAL LEASE DLSCI,4SURE OF Il~iFORMATION ON LEAD-BASED FAINT OR LEAD-BASED FAII~T HAZARDS Warning S Housing built before 2978 nr~y contain lead based paid Lead from paint, pair dips and dust can pose health hazards if not ~ propexly. Lead expostue is especially harmful to young drildren and pregnant womeaa. Before renting pre-1978 housing, landlords mNSt disclose the preseruae of known ka~i-based paint and/or lead based paint hazards m tt~e dwelling. Tenants must also receive a federally approved pamphlet on poisoning j3ret!elltiOII. Landlord`s Disclosure (a} Presence of lead-based paint and/or Lead-based paint hazards (check ('i} or (u~ below}: {i) Known lead-based paint and/or lead-based paint hazards are pr+~tt in the housing (explain): {ii) X Landlord has no knowledge of lead-based paint and/or leadbased paint hazards in the housing. (b} Records and repa~rts available to the lancll©rd {Check (i) or (~i) below}: (i) Landlord has provided the Tenazrt with all available records and reports pig to Iea~-based paint and/or lead-based paint hazards in the hang {list dociuaents}: {ii) X Landlord has no reports or records pertaining to lewd-based paint and/or le2td-based paint ha~rds m the housing. Tenants Acknowlerl~nent (uritisl) (c) Tenant has received copies of all information listed above. (d) Tenant has received the pamphlet Protect Your Family From Lead In Your Hume. Cerkific~tion of Accwacv The following parties have reviewed the information above and certify, to the nest of their kno that the information they have provided is true aFUl acc~e. tZ~ GEORGE P. STOJKOVECI3, JR. DATE i~ ~` ~~/ t"Ba"; DAVE ~~~~~~ 13 ~4 Ro~s~e Road 5hippenshur~, PA 17257 Ph. 717-5 X2-61 ~2 branECtrtzartin !i ~ot-nail.cnn~ Name /Address Broot: Side Attn: George ~tU2 Watntrt Bottom Rd. Stuppcnstnvg, PA 17257 Estimate Date Estimate # 2f7/2012 3?~1i LlovcLR. r~ zzµ w~t-M~str~ walvu.~~'Bottom, i',4 Y7a66 Bill To George Stojkovich 10 Cabin Lane Shippensburg,PA 17257 Invoice Date 2nzno12 Terms Due on receipt Repairs to: 402 W. Main St. Walnut Bottom, PA 17266 Cleaned entire house: 318.00 - basement: vacuumed cob webs off walls, swept up nails and screws, removed cardboard box stuck to the floor, vacuumed entire basement floor of all debris. - first floor: wiped all walls with spit and span to remove black soot, wiped all doors, wiped ail woodwork around windows, wiped all baseboards, cleaned inside windows, light fixtures, kitchen cabinets, cleaned oven inside, cleaned stove top to remove burnt rings on burners, wiped all owmters down and island, complete cleaning of bathroom. -second floor: wiped black soot from ceiling going up the steps and hall, wiped sit wails three bedroorr-s, hall and bathroom with spic and span to remove black soot, wiped all doors, wiped all woodwork around windows, wiped all baseboards, clean inside windows, IigM fixtures, complete cleaning of bathroom. Window to the right side of fireplace. Had spray insulation along bottom edge and ran down the wail. 65.00 - scrap out excess insulation - seal with painters caulk -sand the wall, prime and paint to match Replaced 8 ft. piece of molding around fireplace base. 25.00 Repaint ceiling in stairway and hall. Ceiling was originally painted with flat white paint and was unable to 340.00 wipe clean of soot. -Prime aad paint stairway and hall ceiling. ' ~ 3 ,Z l~ ~ ~ Salmi Tax (6.0%) ~~' , ~~ ~ ~,~., / T~MI i~- Page 1 ~lavcLR. T~w~wia~ 224 WeftMaiwStveet Wa~ttut$ott~rns ~A 17266 BiA To George Stojkovich ZO Cabin Lane Shippensburg, PA 17257 Invoice Date zrz2no12 Terms Due on receipt Purple bedroom: 375.00 - wails needed to be sanded down due to excessive spackle used to fill in holes on all walls also filled in remaining holes in all walls. -fixed small holes in ceiling and wiped off footprints. - prime and paint in tan color all walls. Small bedroom: 340.00 - repair holes in walls - ptlme and painted all walls tan color Prime and Paint window trim on ] 0 windows. (paint missing on outside edge of trim} 180.00 Recaulk around windows and doors due to cracks in caullcing and touch up with satin paint to match 275.00 Repair island in kitchen: 175.00 - removed island wunter top that was not centered - removed liquid nail from underside of counter top and top side of cabinets - reinstalled counter top - replaced two damaged drawers ~ Cleaned grout in file floor in kitchen and second floor bathroom: 439.00 -steamed cleaned and resealed grout Sales Tax (6 0%) . $o.oo TOtal $2,532.00 Page 2 LlovaLR. r~~ 224 We~t'Mai.-tiSLYeet Walv-utBotton+s ~+4 17266 &II To Goorge Stojkovich 10 Cabin Lane Shippensburg,PA 17257 Invoice Date 1/25/2012 Terms Due on receipt Estimate for repairs to: 402 W. Main St. Walnut Bottom, PA 17266 Water damage to kitchen ceiling due to washer on second floor over flowed at the washer water hook up / discharge box: - Cut out aad netape area where water damaged - Cut out damaged comer bead and t+eplace with new corner bead - Mud and sand to finish drywall - Prime and paint ceiling and bulk head Water damage to both sides of tub is upstairs bathroom: - Cut out damaged drywall and replace - Mud and sand to finish drywall - Prime and paint ,~ LABOR /MATERIALS ~ ./ 725.00 ,~~~ 7 U` ~/.. ~` Sales Tax (6.0°y6) ~ ~ Total s~2s.oo 1090 S. MAIN STREET CHAMBERS$URG PA. 17202 PHONE :1-717-263-9151 FAX :1-717-253-7226 FROM : ROB UCHIMA - KITCHEN SPECIALIST - CELL # 1-301-573-4361 TO: prostreetFalcon c@hotmail.com PAGES: one GATE: 2/2! 12 SUBJECT: 402 west main QUOTE 830 -DRAWER FRONT & DRAWER BOX TO AN ANDOVER OAK CABINET - $37.00 + TAX ~ ~~ ~~` ~e ~~~(~ ~~ ~ ~r~~~~s ~a. ~:JJLOLVV ., ___ __. . Vapor Jet P~~ional Cleaning Servie~s, Inc. Carpet, Floors, Uphalstbsry, F'ine/y~~r ~~~ Janitorial 140 We9t Orange Street Shippertsaburg, PA 17267 717-632-3790 or 717-267.042p or 717-243 7582 PA 1->~0-692.6012 MD 1-8.441-0g34 January 31,2012 George StojKovic 40'1 W Main Street Watnut Bottom PA 17266 717-728.6406 Former tenants had a pet Carpet leaning as follows; tat Bedroom 14x12 2tut Bedroom 10x16 Haf! eo Bedr+oom 9x3 3rd Bedroom 9x15 4th Bedroom 19x14 Hall 18x3 Family Room 11x21 Dining Room 20x10 Living Room 18x15 Steps 13 370.42 Tax 392.85 1fi$ 160 27 13:5 ass 54 231 200 270 Will clean carpet for $350.00 (includes tsx) Yapor Jet Professional Cleaning 3orvice~, tnc. Carpet, t=Coors, Upholstery, FirelVt/ater R~tiotnitlon, Janitorial ~4o wa>,t oranges sveet . Shipponsburg, RA '[7257 777-632-3790 or 71? 267-0420 or 717-243-7582 PA 1-800-692.60"12 MD 1-600-447-0834 January 31,2012 Geo-ge 3tojkovic 402 W Main Street Walnut Bottom PA 17266 717-729-84~ General House Cleaning as follows: Empty house (tenants h~lVrs moved out) 2 t3afhrooms full cleaning wash down wafts due to black film Kitchen Cabirt~s in & out and fbor Clean 20 tilt in ~virWOws in (t)121CIc fllni On winnows) and silts Sweep basement dua bo dirt and Waits allover floor Wash doss and t>asebo2u~ds Remove light globes to wash due to dust and biaclc film Clan oven due to oven leaner residue all Over' inside Clean burner on stove mP due to bumf on residue Wash down alt walls due to blade film Tote! X300.00 1 D $318.00 I hereby verify that the facts set forth in the foregoing instrument are true and correct to the best of my knowledge, information and belief, and that I make this verification subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to Authority, as authorized by the Judicial Code and Pennsylvania Rules of Civil Procedure. Date: ~ ~- J Z- IN THE COURT OF COMMON PLEAS OF THE 39t" JUDICIAL DISTRICT OF PENNSYLVANIA -. r~-~d~~] COUNTY BRANCH = ~ ` `' i- 3 i George P. Stojkovich, Jr., ) Civil Action -Law -__ Plaintiff ) ` r '~`"~ ::~, ~' ~ f vs. ) Case No. 2012-6677 . ~,_a'; -~- - Cp., .: ai Becky Shetron ) T_ ~ "-~ Defendant ) Divorce ACCEPTANCE OF SERVICE I, Pamela L. Purdy, Esquire, attorney for Defendant in the above-captioned matter, do acknowledge that I have received a true and attested copy of the Plaintiff's Complaint filed in the above-captioned matter on October 29, 2012. I certify that I am authorized to accept service on behalf of Becky Shetron. Date: ~.~ ~/'L__ ~~ Pamela L. Purdy, Esqui Attorney for Defendant SHARPS ~ SHARPS, LLP A TTOKh'FY1 AT LAtR' 257 Lincoln Way $ast Chambersburg, PA 172C! (717) 263-8447 - ~ ~~ Pamela L. Purdy, Esquire Supreme Court I.D. #85783 1820 Linglestown Road Harrisburg, PA 1711© PH: (717) 221-8303 FX: (717) 221-8403 plpurdy@verizon.net Attorney for Defendant GEORGE P. STOJKOVICH, JR., Plaintiff v. BECKY SHETRON, Defendant t ~ i ~ ~'l.i ~~t}t, 1 __;~,,. __, ,I. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 2012-6677 CIVIL ACTION-LAW PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly enter my appearance on behalf of Defendant, Becky Shetron, in the above- captioned matter. Date: ~~ ZL ~ ~~ ( ~ Pamela L. Purdy, Esquire (J PA ID No. 85783 1820 Linglestown Road Harrisburg, PA 17110 (717) 221-8303 r' CERTIFICATE OF SERVICE The undersigned certifies that on this~~ day of November, 2012, a true and correct copy of the foregoing Praecipe was served via first-class mail, postage prepaid, upon the following: J. McDowell Sharpe, Esquire Sharpe & Sharpe, LLP 257 Lincoln Way East Chambersburg, PA 17201 Allison Gossett, Legal Assistant to Pamela L. Purdy ,,~j c a~ ~; r i i 212 SEC -3 P !2~ ~~ CbMBERL~I`dD C0~1NTY PEl~~SYLVt~"tl~ Pamela L. Purdy, Esquire Attorney ID No. 85783 1820 Linglestown Road Harrisburg, PA 17101 (717} 221-8303 tel (717) 221-8403 fax plpurdy@verizon. net Attorney for Defendant GEORGE P. STOJKOVICH, JR., Plaintiff v. BECKY SHETRON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 2012-6677 CIVIL ACTION-LAW DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT AND NOW, comes Defendant, Becky Shetron, by and through her attorney, Pamela L. Purdy, Esquire, and files this Answer to Plaintiff's Complaint, and in support thereof, avers the following: 1. Admitted. 2. Admitted. 3. Admitted in part, denied in part. It is admitted that Plaintiff leased.a~roperty to Defendant with a property address of 402 West Main Street, Walnut Bottom, PA, Cumberland County, 17266. Denied as to the rest of the averments set forth in Plaintiff's Paragraph 3. By way of further answer, the lease attached by Plaintiff is not the lease executed by the parties. A true and correct copy of the lease executed by Plaintiff arad VERIFICATION I, Pamela L. Purdy, the attorney for Defenda+~t Becky Shetron, have read the foregoing Defendant's Answer to Plaintiff's Complaint. I verify that the averments in this Answer are true and correct and based upon the information provided to me by Becky Shetron, who is unavailable to sign this document at this time. I understand that I am to secure Becky Shetron's signature through a separate Verification when she is available; I then will submit said Verification via Praecipe to Attach with the Prothonotary's office. I further understand that any false statements he72in are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsifications to authorities. Dated: ~G~~ 3 ZQI '~ ~ P meta L. Purdy ~~` ~'~is Lase ree~ent ~itlEds ""} zs da~e~~~~~~, Zfl~~ ~ a hetvveen +~~~ ~''. ~TC)~K€3'~'~~ .. ("~.~nndlord~~, a~ { ;~_ ~~~ ~"'~'+~a"}. 'F. he p;~es agree as fa~v~s: ~~.E~ES.. L.aua~d~ord, in dera~~ cif a lease ~~ provided in ~~ ~ea.~e, ~ea.~~ to Te~amt~.~h~~~,~r ~`~th~e "~ses~ k at ~ l~+n S~ ~ak~ut B~ottam, Pa. ~ ~2fif . t ~~ ~ leaS$ t~'m I b~eg~ tin ,~~~' ~~ ~~~~ ~j !~ C: . , ~~ ~~ e Q~~ f ~. _ w L~A.:E PA,Y~lV~'~",. ~'ea~ant ~ pay to .dlcsrd i p~~~s of.t,~~~~'~ p~a~rsble in adva~e on the of'ea+ ~ ~- ~ ~ loge Pa~~ of.~~~l~~~t,r :~ pay~~nents s~~ n~ to Z~ord at ~ 1 ~~~ qtr, ~~~ ~ttorn, ~'a.. 1'T2~, hieh ~ ~e ~h~m~ fi t to time ~~ L;~ord. ~~CU~~ ~E~ ~ t time of ~ ~~g t~~'ths £,~ T'enarrt ~~ pay tc~ ~.~cl~ord, in ~~ a seevrity d~e.~t o~~ ~ ~~~ tea be hae~d and ~rsed for 'het doges tQ the .Premises or v#;her de;~aa€dts ~ tl~ een~eent ~~ ~ as pro~d~ ~ ~a~. 1'~#~~~-.4~~. ~`et s~ be erred to p~ossessi~ ~ ~ day o~'t~ term ca~t~s Lase, and ~~ yield pr~~~~on to fiord can the ~ day o~'the terra c-f ~~ Lease, ~+~ss otherwise a;~ ~ ~~ in ~v~.ting. At a e~pi~ion otr t t+~n~, Tit sham remove its goods and e~ec~s and gt,~y yield ~ the Pry ~ ~ as gocx~ a ro~tion as ~~ de~iv~erec~ to Tes~~t, on~i~arary vie- acrd teas ed. tIS~ +f3F P~4~[5'F~S/A~11'~,.N~~`~!,~. ~'enant s~~ ~y and use tf~ Premises a de1~~g ~n~. T shah n~ L~rord of any ~ ended ab~ fi ~ ~re~i~ r~ tats thaw the :~ d~ of e~.tded si~c~_ t~:`~'`A~C~~`S,. ~o n~re ~ ~~s n~.y ~~~ on ~~ ~'re~ase~s ~le~ t pn4r ~t~:en +cans ofd I,ar~a~ is r~~atained. PE'I'. ~'e~ sll n~ be a~,c~wed. ~-rtht~~t the arior Witten consent of the Lannd~o~rd. ~t the t~ of sitgt~g thixs ~,~ease, ,r~ ~ ~ i~a~ ~CTI~~'S~I~t~~ ':~ ~a~lav-~ng f~~i~n~ ~~ prov'ed by dlord: ~~t~'~. ~'+~~, _, ~V`~I' .~~ ~k-~i~.(~''~A.'~. ~rnt s tm~ ~ s~ items at the ~d of the t~ a cvnc~€on. gc' as exi~tec~: at the g of the lease tend nor r and tear exceed.