HomeMy WebLinkAbout02-0779COMMONWEALTH OF PENNSYLVANIA
NOTICE OF APPEAL
COURTOFCOMMONPLEAE FROM
JUDICIAL DiSTRiCT DISTRICT JUSTICE JUDGMENT
NOTICE OF APPEAL
Notice is given that the ol~ellant hos filed in the alx~,e Court of Common Pleas an _~,'~ol from the judgment rendered by the ~istrict Justice on the
dote and in the cose mentianed belo~
CiTY STATE ZIP
1550 Wi 11 i nm~ Grov~ ~d.. T~ 1 0SA t~=~hnnl m~l~,~g PA 17055
~~ ~ ~ (~) ---
~ ~ M. K~i~
2-7-02 ~illi~ ~e ~iat~ ~T~~~A~~.~.
P~lip C. ~ig~ti
CV 8 ~i~ R~, ~lisle PA 1701 ·
LT LT-000002~02
~ ~ck wi~ ~ ~ ONLY ~, ~is ~ is ~ui~ u~ P~ ~3~ ~ '~11~ ~ OLAI~NF (s~ ~.
~KR~aS ~ ~ ~ ~s~, thi~.s6 ~ FILE A OOM~AINT wi~in ~ (20) da~
PRAEClPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
~ ~t~ ~ ~ ~ ~ ~ ONLY wh~ ~ll~ ~ DEFEN~NT (s~ ~. RC. RJ.R ~. 1~1(7) in ~ti~ ~e ~i~ J~e.
IF ~T USED, ~h ~ c~y of notre of ~1 to ~ ~ u~ ~1~).
PRAECIPE: To ~ry
E~ m~ u~ ~ ~e ~~ , a~s), ~ fl~ a c~int in ~s
RULE~ To Willi~ ~e ~iat~ , ~s~
(1) You am notified that a rule is hereby entered upon you to file a complaint in Ibis appeal wi~in twenty (20) days after the date of
seevice 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 WILL BE ENTERED AGAINST YOU.
(3)Thedate,~fservic.~thisruleifse~vicew~sbymai~i~he~ate~frn~r~(/n)/~/~%~`~)tJ ,
COURT FILE TO BE FILED WITH PROTHONOTARY
AOPC 312-90
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 the notice of appeal, Check applicable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF .; SS
AFFIDAVIT: I hereby swear or affirm that I served
[] a copy of the Notice of Appeal, Common Pleas No~
(date of service)
, upon the District Justice designated therein on
., [] by personal service [] by (certified) (registered) mail, sender's
receipt attached hereto, and upon the appellee, (name) . , on
., [] by personal service [] by (certified) (registered) mail, sender's rece pt attached hereto.
[] and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the, appellee(s) to whom
the Rule was addressed on . ........ [] by pe~:sonal service [] by (certified) (registered)
mail, sender's receipt attached hereto.. ..... ; ......
SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME _ _
THIS DAY OF
-~i9~hatur¢ o~-~,~ii~~'
My commission expires on ................................................
.COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND
Mag. Dist, No.:
09-3-05
DJ Name: Non.
GAYL~ A. ELDER
~e,e: 507 N. YORK ST.
MECHANICSBURG, PA
T, lephone: (717) 766-4575 17055
NOTICE OF JUDGMENT/TRANSCRIPT
RESIDENTIAL LEASE
PLAINTIFF: NAME and ADDRESS
FWILLIAMS GKOV'B ASSOCIATES
P.O.BOX 176
CAMP HILL, PA 17011
/
VS.
DEFENDANT: NAME and &ODRESS
FKOABEL, ANNE
WMS. GROVE MHP
1550 WMS.GROVE RD-LOT105A
~CHANICSBUKG, PA 17055
Docket No.: LT- 0000025-02 I ~
Date Filed: 1/29/02
I
in a
(Date of Judgment)
.00.
ANNE M. KOABEL
WMS. GROVE MHP
1550 WMS.GROVE RD-LOT105A
MECHANICSBURG, PA 17055
S IS 70 NOTIFY yOU THAT:
~'I? Judgment: · FOK. pLAINTIFF
;E~ Judgment was entered for: (Name) ~ILLIAMS GROVE ASSOCIATES
Judgment was entered against KOABEL, ANNE M
~ Landlord/Tenant action in the amount of $ 81.50 on 2/0~/02 .
The amount of rent per month, as established by the District Justice, is $
The total amount of the Security Deposit is $ .00
J
_J
Total Amount Established by DJ. 0 ~es_.s~;Security Deposit A.p~)l~d
Rent in Arrears $
Physical Damages Leasehold Property $ o 00 -- ~ .00
Damages/Unjust Detention $ _00 $' .00
Less Amt Due Defendant from Cross Complaint
r~ Attachment Prohibited/
Victim of Abuse (Act 5, 1996)
r-]This case dismissed without prejudice.
~-] Possession granted.
--"]Possession granted if money judgment i,'
~ Possession not granted.
[~ Levy is stayed for days or ~] generally stayed.
E~ Objection to Levy has been filed and hearing will be held:
= Adjudicated Amou~
= $
- $ .oo
Interest {if provided by lease) $ _ DO
L/T Judgment Amount $ _ O0
Judgment Costs $ 81_. 50
Attorney Fees $ _ o o
Total Judgment $ 81.50
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
not satisfied Dy time o! evlcuon.
~ Defendants are jointly and severally liable.
Date:
Time:
Place:
IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN
TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/C LERK OF COURTS
OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL'INCLUDE AN APPEAL OF THE MONEY JUDGMENT, IF ANY. IN
ORDER TO OBTAIN A SUPERSEDE .A,S ,THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF
~"THR~E ~ON'I'Hs R'EN;r O~ fri~lE R:Ei~.'~0ALLY iN 'ARREARS ON THE DATE THE APPEAL IS FILED.
· IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE PARTY HAS
30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF
COURTS'OF THE COURT OF COMMON PLEAS, CIVIL DIVISION.
THE PARTY FILING AN APPEAL MUST INCLUDE A COP~IOF TI-)f~ NOT[CE OF JUDGMENT/TRANSCRIPT FORM WITH THE NOTICE OF APPEAL.
~/7td~Z__Date ./~. (/. ~'~'f"Ce.,'7 ,District Justice
II cedify tl~at this is a true and correct cdpy of the.record'of the proceedings containing the judgment.
Date , District Justice
My commission expires first Monday of January, 2006. SEAL
WILLIAMS GROVE ASSOCIATES,
Plaintiff
ANNA M KOABEL,
Defendant
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 0 ~' 7~7~ CIVIL TERM
.AFFIDAVIT
1. I, Anna M. Koabel, am the defendant in the above-captioned action, which is an
appeal from a judgment rendered by District Justice Elder on February 7, 2002, awarding Plaintiff
possession of the lot on which my mobile home resides.
2. My rent for this lot, located at 1550 Williams Grove Road, Lot 10SA, Mechanicsburg.
Cumberland County, Pennsylvania is $266 per month and is due by the l0th of the month. My
rent for February 2002 will be paid with the filing of this appeal· The rent for March is due on or
before March 10, 2002.
3. I verify that the statements made in this Affidavit 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 to authorities.
Date:
Anna M. Koabel, Defendant
WILLIAMS GROVE ASSOCIATES
Plaintiff
Vo
ANNA M. KOABEL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
· NO. CIVIL TERM
PRAECIPE TO PROCI::.I:I~D IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Anna M. Koabel, Defendant, to proceed in forma, pauperis.
I, Philip C. Briganfi, attorney for the party proceeding in forma pauperis, certify that I believe the
party is unable to pay the costs and that 1 am providing free legal services to the party. The party's affidavit
showing inability to pay the costs of litigation is attached hereto.
l~hilip C. B~'ganti
Attorney for Defendant
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (t0) DAYS AFTER filing the notice of appeal. Check applicable boxes)
THIS ............... DAY OF ..............
S~gn,~ture o~ o!fic;a~ before wh, em a,,?ida~it was made
7'itle o! ofhcia!
My commission exp res on
I verify that the st~ments
correct.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF _..C.~_~C~_ ~ .- ;SS
AFFIDAVIT: I hereby swear or affirm that I served
[~'a of the Notice_of Common Pleas No,Oa-.~.~ ~/~,,'/~,f...,:~. the District Justice therein
Appeal,
copy
upon
designated
on
(date ofservice).,~,,_~ 13 ,~ , ~ by personal service ~y (certified) ~?t~r~d) mail, sender's
receipt a~ache~ herd~'and upon the appellee, (namer ~;~,~. ~. ~C,~ on
~<~t~/~, ~0~ ..... D by personal servi~e ~y (certified~ ~~ii', ~r~-~ipt att~h~%~reto.
~nd furth~ tffat I served the Rule to File~ Complaint accompanying the above Notice of Appeal upon the appellee(s) to whom
the Rule was addressed on ~~.~ ~-~, D by personal service ~ by (certified)~)
mail, sender's receipt attached hereto.
/ ' ' ~ Signature of a~iant
Z ~
in this Affidavit are t~e ~d~5~
I understand that false statements herein are made
subject to the penalties set forth under 18 P.S.
relating to unsworn falsification to authorities.
Sec. 4904,
Philip/."' Brigan~ '--
Postage
Certified Fee
(Endorsement Required)
Restricted Delivery Fee
(Endorsement Required)
Total Postage & Fees
Total Postage & Fees
Johnson, Duffle, Stewart & Weidner
By: David J. Lanza
I.D. No. 55782
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Plaintiff
MARKLAND PROPERTIES, INC. t/d/b/a :
WILLIAMS GROVE ASSOCIATES, :
:
Plaintiff :
:
ANNA M. KOABEL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-779 CIVIL
CIVIL ACTION - LAW
IN EJECTMENT
NOTICE TO DEFEND
To the Defendant:
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after this complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defense or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the court without further notice for any money claimed in the
complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other
rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty A venue
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
Johnson, Duffle, Stewart & Weidner
By: David J. Lanza
I.D. No. 55782
301 Market Street
P. O. Box 109
Lcmoyn¢, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Plaintiff
MARKLAND PROPERTIES, INC. t/d/b/a :
WILLIAMS GROVE ASSOCIATES, :
:
Plaintiff
V. :
ANNA M. KOABEL, :
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-779 CIVIL
CIVIL ACTION - LAW
IN EJECTMENT
AND NOW, this day of April 2002, comes the Plaintiff, MARKLAND PROPERTIES, INC., by
and through its undersigned attorneys, Johnson, Duffle, Stewart & Weidner, and files this Complaint, and in
support thereof avers as follows:
1. Plaintiff, Markland Properties, Inc., is a Pennsylvania Corporation trading as Williams Grove
Associates, a Pennsylvania limited partnership, having a place of business at 20 Erford Road, Suite 215,
Lemoyne, Pennsylvania 17043.
2. The Defendant, Anna M. Koabel, is an adult individual who currently occupies a mobile home
at Williams Grove Mobile Home Park, 1550 Williams Grove Road, Lot 105A, Mechanicsburg, PA 17055.
3. On or about October 3, 1999, Plaintiff and Defendant entered in a Lease wherein Defendant
leased Lot 105A in the Williams Grove Mobile Home Park from Plaintiff in accordance with the terms set
forth in the Lease, a true and correct copy of which is attached hereto as Exhibit "A".
4. On September 25, 2000, Defendant executed a copy of the Rules and Regulations for
Williams Grove Mobile Home Park, which Rules and Regulations were incorporated into the aforesaid
Lease, and which are attached hereto and included in Exhibit "B".
5. Defendant is in violation of the aforesaid Lease in so far as Defendant has violated numerous
Rules and Regulations.
6. Defendant has allowed her dog and her children to run loose in public areas and on other
residents' lots.
tenants.
Defendant's children have vandalized other residents' lots and have harassed neighboring
8. Plaintiff has received numerous complaints from neighboring tenants regarding conduct of
Defendant. True and correct copies of complaints and Defendant's acknowledgment thereof are attached
hereto as Exhibit "B".
9. On or about January 18, 2000, Plaintiff provided a Notice of Violation of Park Rules and
Regulations to Defendant by certified mail, which stated the following violations:
Your dog is running loose, is left outside unleashed, is running in public areas
and on other Resident's lots, is defecating on your lot and other Resident's
lots and such defecation is not being cleaned up.
2. Your children are trespassing on other Resident's lots.
3. Your guests are parking in unauthorized parking spaces.
A true and correct copy of this Notice is attached hereto as Exhibit "C".
10. Qn or about June 5, 2000, a "Second Notice of Violation to Park Rules and Regulations" was
sent by Plaintiff to Defendant by certified mail which set forth the following violations:
Your dog is running loose, is left outside unleashed, is running in public
areas and on other Resident's lots, is defecating on your lot and other
Resident's lots and such defecation is not being cleaned up, and is
becoming a nuisance and menace to other Residents.
You have adopted a cat without authorization of Management, your cat
is running loose without being leashed and your cat is left outside
unattended.
3. Your children are trespassing on other Resident's lots.
The behavior of your daughter, Anna, is disturbing the peace and
tranquility of the community.
A true and correct copy of the Second Notice is attached hereto and a part hereof as Exhibit "D" and
is incorporated herein by reference as if set forth in full.
11. Defendant is in violation of the aforesaid Lease in that she has allowed her children to display
pornographic photographs of Defendant and Defendant's pornographic web site to minor children of
neighboring residents in the Williams Grove Mobile Home Park.
12. On or about October 17, 2001, a "First Notice of Violation of Park Rules and Regulations" was
sent by Plaintiff to Defendant by certified mail which set forth the following violations:
Your children have used profane and abusive language; You had a loud
party which disturbed the peace and tranquility of the park; and your quests
did not conduct themselves properly while visiting you, including
drunkenness.
A true and correct copy of the aforesaid Notice is attached hereto as Exhibit "E".
13. On November 7, 2001, Plaintiff sent a "Second and Final Notice of Violation of Park Rules
and Regulations" to Defendant by certified mail, which set forth the following violations:
Your children have used profane and abusive language and they have
disturbed the peace and tranquility of the park.
A true and correct copy of the aforesaid Second Notice is attached hereto as Exhibit "F".
14. On or about December 20, 2001, Plaintiff served a Notice to Quit upon Defendant. A true and
correct copy of the aforesaid Notice is attached hereto as Exhibit "G".
15. On or about January 9, 2002, Plaintiff sent yet another "First Notice of Violation of Park Rules
and Regulations" to Defendant by certified mail, which set forth the following violations:
The persons permitted to occupy your home are yourself, your son and three
(3) daughters. Your ex-husband Charlie, must move immediately. Also, your
guests disturb the peace and tranquility of the park and trespassed on
another tenant's lot.
A true and correct copy of the aforesaid First Notice is attached hereto as Exhibit "H".
16. On or about February 11, 2002, Plaintiff sent a "Second and Final Notice of Violation of Park
Rules and Regulations" to Defendant via certified mail which set forth the following violations:
Your ex-husband, Charles, must move immediately out of the park. He ia not
on the Lease and is creating problems with other tenants, disturbing the
peace and tranquility of the park and showing public intoxication.
HE HAS TEN (10) DAYS TO MOVE. IF NOT MOVED BY 2/21/02, WE WILL
CONSIDER HIM A TRESPASSER AND HAVE HIM ARRESTED.
A true and correct copy of the aforesaid second Notice is attached hereto as Exhibit "1".
17. The notices sent to the Defendant allege more than two (2) violations of the Park Rules and
Regulations of the Williams Grove Mobile Home Park within a six (6) month period.
18. Defendant, despite receiving the foregoing notices has failed to correct the violations and
continues to engage in the conduct set forth therein.
19. Plaintiff has suffered damage as a result of Defendant's willful violation of the Lease in so far
as residents of Williams Grove Mobile Home Park have expressed their intention to terminate or not to
renew their leases due to Defendant's conduct.
20. Pursuant to the terms of the aforesaid Lease, Defendant's Lease constitutes only a month to
month Lease which automatically renews in the absence of written notice of non-renewal by either party.
21. Plaintiff provided written notice of non-renewal to Defendant on March 6, 2002. The aforesaid
Notice included the following language:
Your Lease will expire on April 9, 2002.
We will not be renewing your lease; therefore, you must move from the property by
April 9, 2002.
A true and correct copy of this Notice of Non-Renewal is attached hereto as Exhibit "J".
22. By virtue of the expiration of Defendant's Lease, Plaintiff is entitled to immediate possession
of the Lease premises.
23. By virtue of Defendant's breaches of the aforesaid Lease, Plaintiff is entitled to immediate
possession of the leased premises.
24. As set forth in the Lease, attached as Exhibit "A" and the Notices attached hereto as Exhibit
"K", Defendant is required to pay rent in the amount of Two Hundred Sixty-Six Dollars ($266.00) per month.
25. Defendant has failed to pay rent from and after February, 2002. Defendant has incurred late
fees in the amount of One Hundred Three Dollars and Ninety-One Cents ($103.91).
26. Defendant has paid no water fees from and after January 10, 2002, as required by the Notice
attached as Exhibit "J".
27. The aforesaid water fees equal Seventy-One Dollars and Ninety-Three Cents ($71.93)
through April 10, 2002, as set forth in the documentation from Water Saver Systems, attached as "Exhibit
28. Plaintiff has been forced to incur costs in the amount of Eighty-One Dollars and Fifty Cents
($81.50) for the purpose of obtaining a judgment from the District Justice.
29. Pursuant to the Lease attached as Exhibit "A", Defendant must reimburse Plaintiff for "legal
costs, cost of collection, court costs..."
30. Plaintiff is expected to incur costs in the amount of Two Thousand Dollars ($2,000.00) for
collection of the unpaid rent and eviction of Defendant.
31. Plaintiff is entitled to damages in the amount of Three Thousand Seventy Dollars and Sixty-
Two Cents ($3,070.62), calculated as follows:
Unpaid rent through April 2002 $796.00
Unpaid water through April 10, 2002 $71.93
Late fees $103.91
District Justice filing fees $81.50
Attorney fees $2,000.00
Interest at 6% from April 10, 2002 through May 10, 2002 ~
Total $3,070.62
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter judgment against
Defendant in the amount of Three Thousand Seventy Dollars and Sixty-Two Cents ($3,070.62) and for
possession of the real estate at Lot 105A, Williams Grove Mobile Home Park, 1550 Williams Grove Road.
Respectfully submitted,
JOHNSON, DUFFLE, STEWART & WEIDNER
By: ,~
David O. Lanza
Attorney I.D. No. 55782
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
Telephone (717) 761-4540
Attorneys for Plaintiff
:155081
I, Dienne Fagan, Property Manager, verifies that the statements made in this Complaint are true and
correct to the best of my knowledge, information and belief. I understand that false statements made herein
are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities.
Date:
MARKLAND PROPERTIES, INC. t/d/b/a
Dianne Fagan, Pretty Manager
CERTIFICATE OF SERVICE
AND NOW, this I ~bl't~day of April 2002, the undersigned does hereby certify that he did this date
serve a copy of the foregoing CIVIL COMPLAINT upon the other parties of record by causing same to be
deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as
follows:
Anna M. Koabel
Williams Grove MHP- Lot 105A
1550 Williams Grove Rd.
Mechanicsburg, PA 17055
JOHNSON, DUFFLE, STEWART & WEIDNER
By: &.'~anza ·
Exhibit A
Williams Grove Mobile Homes
C/O ID.L. FAGAN
P.O. BOX 176
CAMP HILL, PA 17001
WmU SG OVS SSOCIA SS as ndlord
as Te~t (s).
The L~ord hereby leases ~to the Tenet
1~ Wtll~s Grove ~oad, Mech~ceburz, Pa, lgO~, C~berl~d cowry, for t2e
~ole p~pose of establi~inE res2dence~ ~d rom no other p~pose~ for the te~
lease a~ll auto~tically be renewed each month on the 10~ of each month ~ess
either the Tenet or the ~dlord ~11 notify the other p~ty ~ writing
th~ty (30) days ~ advice. Tenet occupy~g pr~ses
sh~l constitute a full month rental.
~e ~dlord hereby ac~owledges receipt from the Tenet the sum of $1~.~
as a sec~ity deposit to be held ~ F~S~BA~ ~,PA 17543
Pa. for the rent~ te~ to sects the ~ent of ~'~'ses to the leasehold
premises ~or defa~t in rent thereof, it is ~derstood that no ~t of the
sec~ity de.sit is to Be considered as the last rent~ due ~der the te~s
of t~s lease.
Sec~ity de.sit will be rended with~ thirty (30) ~s of retention
of this lease a~eement or u~n s~render ~d accept~ce of ~he leasehold
premises, whichever first occ%rs, (provided a th~ty (30) ~y ~I~ notice
is received by ~dlord prior to vacating leasehold ~ises) if leasehold
premises is left in cle~ ~d ~d~aged condition, ~d if Tenet is otherwise
in compliance with the provisions of this lease a~eement. FA~E OF
T~T TO P~V~E ~ L~L0~ ~I~ H~/~
T~INATION OF THIS ~SE OR ~N S~ ~ ACC~CE OF T~ ~0~
PR~IS~ SH~ ~I~E ~ L~ FROM ~ LI~ILI~ T0 ~ S~I~
D~0SIT.
Tenet a~ees to use the leased premises o~y for the personal residence
of Tenet and the following re~stered persons:
age ~'~'~ relationship
age ~ r e 1 a t i on shi~,~ ~fA_
Tenant agrees to register guests residing in leased premises for a period
The Tenant agrees to allow no more than one pet to ~[~e in residence
Tenant agrees to pa~ an additional fee of $10.00 per month for said pet with
rental payment due the lOrn of each month.
Tenant acknowledges receipt of the current Rules amd Regulations which
shall be part of this lease ag~'eement. Te---t agrees that all registered persons
of this lease, guests and/or visitors of said persons will abide by all Rules
and Regulations of Williams Grove Mobile Homes. Parties agree that said Rules
and Regulations may be amended and such amendment at, all be binding upon all
RESID]NTS after a thirty (30) da~ written notice of the Rules and Regulations
is mailed to Tenant.
The Tenant understands that the cost of UTILITIES TO S~VE ~ PR~4ISES
SHALL BE PAID by Tenant except the cost of water supply, sewerage and garbage
collection.
The Tenant agrees that the Landlord .b.ll have the right, temporarily, to
stop the service of any utilities whether the same be paid for by the L~mdlord
or Tenant in the event of malfunction affecting the utilities, or to facilitate
alterations and/or repairs made in the premises or elsewhere on Landlord's
property. Landlord a~T1 not be liable for failure to supply utilities or for
alterations of services when such failure shall be beyond Lmndlord'e control or
is required to enable L~mdlord to service or repair installations, and Tenant
eBall not be entitled to any ~eductions in rent.
The Tenant agrees that the Landlord ~-11 not be liable for property
or personal injury occurtng in the leased pren~tsee or elsewhere on I~mdlord'e
property unless the a-,~ge or injury results directly from Landlord's negligence.
The Tenant shall not assign or sublease the leased premises and a~ such
proposed assi~ment s~t~ll result in am immediate breach of this rental agreement.
IN WITNESS WHEREOF, the parties hereto ~teu~-~ to be legally bound have
executed this Agreement the day and year~.fi~ above written.
~ndlord
fsr
Williams Grove MoBile I-Iome
~/O D.L. FAGAN
P.O. BOX 174
CAMP l~LL, PA 1700!
(re~Aaed a~d effective, date
Re~isCrotioa, ~ent, and Ch&rges=
1. B~ etate law, e.ll residents will be reentered at ~e c~t~ C~ office.
2. Ail ~rso~ reS~g in ~' ~me; ie~zea ~ ~et ~tbi ~e~s~r~-~e ....
~memt. ~ pe~ is ~t~ed ~r rea~eat o~ed ~ ~ch constitutes
exCra c~ge of $10.~ per m~.. No ~to ~e pl~t~ed ~ c~t o~ed
rented ~hlle ~a. No ~e t~ tvs ve~clea ~e ~tted ~r ~t.
3. ~ ~se ~ra~ reentered ~t~ c~e ~-~enc ~ ~tted to ~Ye ~ t~
~se. ~ ~ra~ asr re~stered at t~e of ~c~e (except neub~s or
le~l12 adopted ch~en)c~s~itute8 ~ e~ra c~Ae o~ $~.~ ~r ~nC~.
~eats liy~ ~ C~e ~ over 1~ ~a conoCigutea ~ ex~a c~ge o~
~. Rents ~ll be collected at t~e office at the bo~n-4~ of each ~nth. Rent
due b2 the lei of eac~ ~nt~, ~d ~nt~y ~ a~v~ce. Residents occup~
~emiooa ~ ~rtion of a month ~ c~8tit~te a ~ ~ ront~. A
of Si.~ ~r ~ w~l be ~dde~ ~cr late ~ats.
Other
1. Ney re~eata ~t place a aec~lty de. sit of one ~a~'a reat~ fee u~
re~sCration ~ ~ ~cor~ce ~th t~e x~m~d ~ Te~t Act of 19~1. Be~
will occ~ o~ ~en a 30 ~ written notice ia received by ~=~nt
to vacat~ ~l~s Grove ~bile ~ea, ~ges to t~ leaae~ld
~e ~ld ~d ~1 due reno ia ~d. F~e of the t~t ~o ~de t~
l~ord vit~ ~s new ad.ess ~ vrit~g u~n te~=t~ of C~e le~ or u~
~rend~ ~d accept~e of the .leaso~ld ~e~aea ~-~ relieve t~
fr~ ~ l~ty ~er ~ ~ord ~ Te~t Act cf l~l ~ ~o~r~ ~el~
Sec~ty
~. If certified letters ~e ~itten due to ~e ~o~ti~, a fee of $10.~
be c~ged.
~. A fee of ~10.~ ~1 be c~ged f~ chec~ t~t ~e ret~ed b2 t~e
~ electric~ a~ice ~oy~ded d~ pl~enenC of a ~e ia ade~te f~ t~t
~e at t~t t~e. Xf a~tio~ ae~wicA ~ re~ ~ ~s~.,
c~ges ~ ~ res~ib~lt2 of ~e ~e~a~t.
Residents v~ ren~ lot spacec Not ~re ~ ~ o~ t~ .,a/~ ~e ~o~e
~1 be ~ed'on a noble ~e lot ~d It ~t be located at a ~ to be
de~t~d by ~e ~e~nt. ~ t~ ~or ~o~e ~t~le ~C be
~ ~ spayed stud ~th ~1 copper tub~g c~ecti~ to' t~ ~b~e ~e.
Foot~ of c~ b~c~ or co.fete ~ be ~t~led at ~d level to ~ev~t
s~g ~Co t~e ~o~. O~ ~, rac~ ~ ~o~e bottles ~t be
~Ced ~ ~tc~ ~b~e ~me ~d to ~ve ~f~t~ ~ou~ut t~ c~t.
~o~ ~fet~e, ~r oil t~ ~or ~o~e bottle to noble ~e ~
~ater ~pe8 must be ~a~d ~h t~e~ota~ or a~~-~ ~t~ tO
freeze. T~ ~t~tion of a the~a~t to re.re t~ t~rac~e ~d
~ao be enjoyed. ~o w~k ~o~d be ~c~ed before ria~ o~
wearer. ~ ~-~2e rea~t~ .fr~ frozen uat~ ~a ~ be ~e
of the tenet of lo~ a~ce. ~-~ ~ta ~. ~e a~era~ ~ese ~
~bile B~e Renters~ ~e go re~ ~ ~ to ~b~e ~e berrie ~
we~ ~d te~ ~t be aaa~ed by te~t ~r it ~ be ~cted fr~ the
de~t ~ ~ccr~ce with She ~rd & Te~t Act ~f 19~1. Rea~a ~e
res~ible to re~ le=~-~ s~ta ~d to.et f~ities to
~e~a~e~. ~--~m~ is res~naible to ~ap water ~s f~ ~ter ~.
AIl residents =~q ~ve their g~b~e rea~ for collection once a wee~. ~bage
-- ~d tr~ c~s e~ll be Eept cle~ ~d free fr~ offe~ve odors. G~ge
be placed ~ plastic hags ~d de.sited ~ g~b~e c~s.
Do not ~u~ ~th~g ~ 2o~ ~na ~ aa rags, clothes, ~d ~per,
s~ti~y ~p~a er items ~de cf pl~ic or ~bber. Such items e~d be
wrap~d ~ ~r ~d de.sited ~ ~ge c~.
1. Pets are allowed only in resident o~ned homee.
2. All petsj~i~cludi~g cats~ must be leashed when outside and are not to be left
outside '~attsuded. Pet owners shall be responsible for clean Up of a~ feces
of their pe~ and for disposing of it in a snsitar~ --~er.' Pets are ~ot alleged
in public areas or on other late.
General:
1. Residents are responsible for the actions or behavior of their child~en, gUests
and pet.
2. Any behavior which disturbs the peace and tranquility cf t~e comnm£t~ ia
pr o~ibit ed.
Any violation of federal~ state, or local laws a~d ordinances shall be a
violation of these rules and regulations.
Operating any t~pe of business which invites the general public into the cou~t
is prohibited.
5. Ar~y a.m.~e to the concrete petio~ drive, la~n~ electrical, T V cable~ water line,
sewerage line or loss of ah~ubber~ and tree life sha~l be the resident'e
responsibility. Any item neglected will be repaired or replaced at reeident's
1. One for sale sign ~a~ be p~aced in window of mobile hone.
Under sectian ll pf Act ~l ~'Nobile Home Rights Act of l~?~", t~e resident may
sell the ~obile hone belonging to the resident, but i~, ffollowing the sa~e, the
mobile home is to remain in the cou~t with a new owner, Nanagement ~ reserve
the right to approve the purchaser off ~a~d mobile ho~e as a resident. If the new
puncher is not approved by Hanagement, the sale ~ll be valid, but the new
purchaser will not be considered a resident, and the mobile home ~iil be required
to be removed from the court immediately.
3. Nc one ma~ reside in Williams Grove Nobils HoBee court unlens registered ~ith
the Management.
1. An~ signature affixed hereto by resident sh~l constitute an mbli~ation upon
members of ~hetr i~ediate family and guests.
~ules a~d Re~Aluti~ne ~ill be amended periodically a~d ~ll be peet~ in the
lattud~ roan and in the o£~ice lobby. A~y a~end~ente shall become · part of this
agreement. T~e rights and duties expressed i~ Act ~ '~obile Hone Rights Act
of l~" apply to ~our reaidoncy at Williams Grove Habile Hones c~t.
3. Any violation Of these Rules, Regulations and Ag~emente may be grounds for
eviction.
~illia~ Grove ~obile Homes shall not be liable for any damage or injury which
ma~ he sustained by the resident or an~ other person, as a consequence of the
fsiluret breakage, leaRaga, or obstruction of water, sewer, waste, TV cable, or
the electrical, gas or oil system; or by reason of the elemamte~ or resulting
from the carelessness, negligence or i-proper conduct an the part of any other
resident ur the residentSs or. other residunto8 agents, gaeste, licensees, ln-
viteesg ~signoes or successo~s~ or attributable to a~ interference witht
interruption of or failure, beyond control cf Williams Grove Habile Homes or
any service to he furnished or ~upplied by ~illiams G~cve Hcbile Hames.
Resident must obtain the necessary inaxtrance against these contingencies.
I/~e have read the foresoing Rules and Regulations und agree to become a resident
of ~illiams Grove Nobile Hones accepting and consenting to said Rules and Regula-
tions. I/we agree that all enid Rules and Regulations -~-~1 be part of rental
agreement. I/we acknowledge receipt of the attached copy of Act No.
275 g~Zon~, I~ §u~§[, ~o4~zo~Z
p~c~E o~ ~c [2) 4" x ~" x 48"
WILLiAMS GROVE MOBILE HOME PARK
MECHANICSBURG~ PA
MOBILE HOME PARK RULES AND REGULATIONS
,.a rentnofnaidbvthetonth(tOth)ofthernonth.(poatma~cnnenvaiopeMIdeterminedate)' Ifrentand
[~em~e ec'~ °a~ ~J ca~l;)~a~'* n o't reoelved ~oy t~e tenth (15th) of the month, legal .~ion will com menoe.
I~ Lakakae: 10% (h~ rent is n°t paid by the ten~ ('iOth) °f the re°nth'}
1. Lot must be kept neat and ordedy at ell ames.
2. Storage is not eltdwed on the patio or around the home. The pabo muat bo maintelned In good =oncil~on.
3. Home muat be completely eki~tod (~dthlfl 30 day~ for new reeldmnt8) v,~ vlnyl el~rilng. When upgradiag the skiing
on existing homes in the park, vinyl skirting must be used.
4. Lawns must be mowed, trimmed and raked. Any shmbbe~, bu, ehms, p~a,n_~,., or trees must be atmmed.
5. No form ofadveftiaing parmittodon tdt except proparlylnatelled For Sele' elgne.
6. Do not ob~uct or accumulate on any sidewalk, yard, driveway, or street, any debris, trash, refuse, snow or ice,
or ch~dren's toys. ·
7. T.V. antennas eonatmctod on standard poles may not e~ceed 20 feet or eelf-euppo~ng towem may not exceed
35 feel No guy lines allowed. No satellite dishes allowed measuring over 38 inches.
8. thstafla'don of awnings, skirling, storage buildings, steps or e~doeures must have wflttan park owner approval
Where/when appilcabin, building permka must be obtained trna the incal governing body.
g. Only proper outdoor furniture is ailowed on palio.
10. Fuaitonka and sheds must be kapt painted and free of rust and must not isak- Management reserves the dght t°
inspect any fuel o~ tonka et any tlme for vio[atisns, and, ff a viciaiton shooed occur, the resident w~ be required to
remove said fuel ali tank(a}. ResldentAVto~e homeowner wiil eiso be responsible for any and el~ cea involved
Tn any dean up of any hazardous mateliai caused by leakage of their fuel oil tank(e) Including but not limited to
edmlnlain~ve cca~ incurred by the perk owner. Any Resident/Mobile Home Owner who maintains a fuai oil
tank(e} must euppty to perk owner a copy of their homeownei~e policy that states they h~ve sufficient ooverege to
pay for any and all coats invoNed in ciean up of hazardous matedais caused by leakage of their fuai oil tank(a).
All fuai oli tents must be e 275-gallon, t 2 gauge, ho~ontal tank with ~' togs pieced on ~vo [2) 4'xa'x48' ilntois.
11. NO fences may be erected vAthout the permission of Management and as sitpuleted in CREEKS AND LAKES.
Any fence that Is erected upon permission of Management w~l be per specifications required by the Ownem.
Current spec~ca~ons requlre that any fence erected must be a bhaTndink compoei~n and installed by a reputable
oonttactdr.
12. Trash cansmust beatoredetmar of home. Trash pegs must not boatoredout~de. Centa[nereshould paplaced
elong the streat at the edge of the lawn for pick-up the niaht before the ragu a~ echeduied trash day.
13. Ciotheeiin~ are prohibited, but one circular ctdthes ~ee located et rear of home ia permitted.
14. House numbers must be on the street aide/front of the more home.
15. New homes coming into the park must have a detachable hitch and the proper its-downs required by the
16. Only manufactured awnisgs are ellowed and must be the length of Patio and are anchored c°rredi~Y par T°w~ehJP
17. ' Only one (1) shed is allowed and must be fecto~ manufactured. The shed must bo sturdy, have a good
appearance, and be properly anchored propedy so it vail not blow over in a vandatorm. MexTmum size 10' x 12',
18. Cement blocks vaIl not bo permitted to be used as atepe into a mobile hom~. Onty standard, sturdy stairs will be
permitted end must bo maintained and painted at all times.
19. All window air conditioners must be properly inetelisd and correctly auppoded, poel~vely no preps to the ground
will bo parmitfed.
20. Children~ playground equipment (swing sets, e~) am not permlt[~d unless home owner pro~de~ to Management
person(s) using such equipment, and, there ki sufficient space to erect or install such equipment.
Laundn~ -
1. No one is allowed to uae more than two washers and two dP/em et one time.
2. Washers and d~yers must be attended at all ~mss when in usa
3. Do not overload or abuse the washing machines er d~yers. In ease of trouble, turn the ay,itoh off on the
machine end inforrs Management immediately.
4.. Rugs, carpets, heavy bed siethlng and heavy weadng appersi must not be washed in the machines
5. The laundry building and equipment should be IMt siean and orderly for your neighbor.
6. D~lng yards are to be used for d~ng clothes outslpe.
7. The doom to the tsundly building ~ be locked et ail itmes. Any resident that desires to use these Laundry
cl~e~ must obtain a key from management and will be responsible for any damage or cleonlng of the tsundry
fa~c~iliit es if such shou{d occur, il, said Reaident should ieee thair key, a $25.00 fee w~l pa charged for replacement
ofsuchkey. Manegementreservesthe ghttocloeathel~undryfadll~esatenytime-
(~enerai
1. Res]dents must a-~surse the following responsible'des associated with personal property(s) or person(s) in
(a) Maintain tight sewer/sapCo drains, if the sewer/septic line is clogged through restder~s ne¢Igenca,
res[dent will be billed for the repairs. Do not ~ush anything this ls not sctusie down the commode or any
drain (i.e. diapers, doth, paper, sanita~ napkins, plasti= or rubber items}. Residents will be responsible
for any cost invsived In clearing of any wastswat~ sewer lines that is caused by Re~denfs Improper use.
(b) Maintain ~bt water lines end repe~r any leaks Immediately. if any leak is detected on the outaideAnaide
of the home, Management rese~es the right to dlsconnec~ water supped to the homo Immediately unll[
such repair is comOeted, if such leaks ere not repairsd [mmediafoly and c~use damage to owner's water
(c) Resident ki responaibin for the conduct and dersege by hisJher children or guest(a)' Any resident found
guilty of m~ciouo mischief will be evicted.
; (d) Children are prohibited on vacant lots. Res[dent assumes responsibility for their children.
Trespassing on the lot of another res[dent is not permitted.
Loud pa~es are prohibited. Noise must be held to s minimum ~t alt tlme~ especially after 10 PM.
!e~) Bray and arrow, BB gun, Pe!tst guns and air ~es are pr°hibiteq In the park' Any discharging of a firearm
In the Park is prohibited. ·
(g) Opamflng any type of business 'is prohibited in the perk.
(h) Resident Is permitted to invite such vendors as tradesmen, delivery men, or suppllem of various goods
(i) Resident must give park owner a thirty- (30) day no,ce when planning to move from park. Home may
not be rersoved frets the park unless ali rent fees, oha~ges or assessrsents are paid to the end of the
tenn. No,ce must be In w~itng.
Resident convicted of a felony shall be subject to eviction proceeo~ngo per the Mob, s Horse Rights Act.
(10 An abund~ed home left in the perk for thirty days or more may bu entered bY the Park °w~er t° secure
responsible for safeguarding home er ~ contents.
(i) Alt homes must be equipped with pmpe~Y installed, oparaUe heat tape, which must extend d~wn Into
water pit.
(m)A beck. check valve muaf be installed on your Water line.
(n) Do nat tamper with the pa~s steofdcai se~ise [roster box~ breaker, w~dng, etc.) for your home. 100 AMP
oe~ce breaker will be provided, if necessary. Lessee is responsicle for the cost of upgra'~eg to 200 AMP
so.ice if required. A quafnted clectflsian must do ~ work.
(o) ,NI homes must be equipped with a fire e~tingukiher end bard-wired smoke detector.
(p) in the event you wish to sell your home ~ithln the park, you must noEy park management ffyour home
was previously been cited to be in vio!a~on of any ~e and regul~on pe~ieg to the condltkin, you must
correct the vlotsflon(s) prior to resale of the home or the horse must be removed from the park upon
resale. All rent must be paid to date or home cannot be transferred to the new owner.
(q)Fbes of any kind In the park ere prohibited.
(r}Fireworks or other explosives ere absolofaiy pmhlblted In the Park at all t~rn ss-
(s) Drurlk~.rLness, use of or eslling of drugs, [rsmersl conduct, including Prsfane or abusive language' wlil be
grounds for ev ~on fTom the perk
(t) Any bebevisr thst disturbs the peace~and tranqulltiy af th o corsmunity s proh bited.
(u) Any vislt~oh of federal, state, or local laws and ordinances shall be a vinla~on of these ru[e~ and
(v) Reaidenis em requestsd to edvi~e management ff they are leaving thor m°b~ hems f°r an extenped ~ay'
please advise the day of pepar~ure and rstum.
(w) Resident must pay all real estate taxes assessed against his/her homo, and, upon request by the perk
owner, must furnish proof of peymenL
Management resewes the right to rsake addi~ons or changes to the regula~ons. Vlctations of thee regulaf~ons
horace, the assigned opa~e allotted for cars and the assigned otze stloftsd for Iot~ fi, upon request by park owner,
res[dent fails to move h[~her property, the park owner may do so et resldenfs risk. Re.dent hereby gives to the
which may resell
I (WE) HAVE REAO THE FOREGOING RULES AND REGULATIONS AND AGREE TO ABIDE BY ALL RULES AND
REGULATIONS AS SET FORTH. RESiDENT(S) UNDERSTAND AND AGREE THAT A VlOLATION OF THE RL1LES
Rev. 8/'00
ACT NO. 2.61 IMPORTANT NOTICE REQUIRED BY LAW
'q'HE RULES SET FORTH BELOW GOVERN THE 'I~RMS OF YOUR LEASE OR OCCUPANCY AGREEMENT WITH
TI:IlS MOBILE HOME pARK. THE LAW REQUIRED ALL OF THESE RULES TO BE FAiR AND REASON/~3LE."
"YOU MAY CONTINUE TO STAY IN THIS pARK AS LONG AS YOU PAY YOUR RENT AND OTHER REASONABLE
FEES, SERVICE CHARGES AND ASSESSMENTS HEREINAFTER SET FORTH AND ABIDE bY THE RULES OF 'rilE
PARK. EN'~%a, NCE AND EXIT FEES MAY NOT BE CHARGED. INSTALLATION AND REMOVAL FEES MAY NOT BE
CHARGED IN EXCESS OF THE ACTUAL COST TO THE MOBILE HOME pARK OWNER OR OPERATOR FOR
PROVIDING SUCH SERVICE FOR THE INSTALLATION OR REMOVAL OF A MOBILE HOME IN A MOBILE HOME
SPACE."
"YOU MAY BE EVICTED FOR THE FOLLOWING REASONS:
(1) NONPAYMENT OF RENT.
(2) A SECOND OR SUBSEQUENT VIOLATION OF THE RULES OF THE MOBILE HOME PARK OCCURRING
WITHIN A SIX-MONTH PERIOD.
(3) IF THERE IS A CHANGE IN USE OF THE PARK LAND OR pARTS THEREOF.
(4) TERM[NATION OF THE MOBILE HOME PARK."
"YOU SHALL ONLY BE EVICTED IN ACCORDANCE WiTH THE FOLLOWING PROCEDURE:
(1) A RESIDENT SHALL NOT BE EVICTED BY ANY SELF-HELP MEASURE. pARK OWNER
(2) PRIOR TO THE COMMENCEMENT OF ANY EVICTION PROCEEDING, THE MOBILE HOME
SHALL NOTIFY YOU IN WRITING OF THE pARTICULAR BREACH OR VIOLATION OF THE LEASE OR pARK. RULES
AND ~EGULATIONS BY CERTIFIED OR REGISTERED MAIL
(a) IN THE CASE OF NONPAYMENT OF RENT, THE NOTICE SHALL STATE THAT EViCTiON
pROCEEDiNG MAY BE COMMENCED IF THE MOBiLE'HOME RESIDENT DOES NOT PAY THE OVERDUE RENT
WiTHiN 20 DAYS FROM THE DATE OF SERVICE iF THE NOTICE iS GIVEN ON OR AFTER APRIL 1 AND BEFORE
SEPTEMBER 1, AND 30 DAYS IF GIVEN ON OR AFTER SEPTEMBER '1 AND BEFORE APRIL 1 OR AN ADDITIONAL
NONPAYMENT OF RENT OCCURRING WITHIN sIX. MONTHS OF THE GIVING OF THE NOTICE MAY RESULT IN
IMMEDIATE EVICTION PROCEEDING.
(b) IN THE CASE OF A BREACH OF THE LEASE OR VIOLATION OF THE PARK RULES AND
REGULATIONS, OTHER THAN NONPAYMENT OF RENT, THE NOTICE SHALL DESCRIBE THE pARTICULAR
BREACH OR VIOLATION. BY THIS SECTION, AND UPON A SECOND OR SUBSEQUENT VIOLATION OR BREACH
OCCURRING WITHIN SD( MONTHS, THE MOBILE HOME PARK OWNER MAY COMMENCE EVICTION
PROCEEDINGS AT ANY TIME WITHIN {~O DAYS OFTHE LAST VIOLATION OR BREACH."
"YOU SHALL NOT BE EVICTED WHEN THERE IS PROOF THAT THE RULES AND REGULATIONS YOU ARE.
ACCUSED OF VIOLATING ARE NOT ENFORCED WITH RESP~ECT TO THE OTHER MOBILE HOME RESIDENTS OR'
NONRESIDENTS ON THE PARK PREMISES."
"IN ADDITION, NO EVICTION pROCEEDING FOR NONPAYMENT OF RENT MAY..BE COMMENCED AGAINST YO[~
UNTIL YOU HAVE RECEIVED NOTICE BY CERTIFIED MAIL OF THE NONPAYMENT AND HAVE BEEN GIVEN TO
PAY THE OVERDUE RENT 20 DAYS FROM THE DATE OF SERVICE IF THE NOTICE IS GIVEN ON OR AFTER
APRIL 1 AND BEFORE SEPTEMBER 1 , AND, 3(3 DAYS IF GIVEN ON OR AFTER SEPTEMBER 1 AND BEFORE APRIL
1. NoWEVER~ ONLY ONE NOTICE OF OVERDUE RENT IS REQUIRED TO BE SENT TO YOU DURING ANY SD(-
MON'B-: PERIOD. IF a SECOND OR ADDITIONAL VIOLATION OCCURS WITHIN SIX MONTHS FROM THE DATE OF
Exhibit B
February 02, 2000
Anna KoabeI
1550 Williams Grove Road#10Sa
Mechanicsburg,PA 17055
De. Diane,
I am sorry for the complaints made about the dog, ect.I have taken actions to correct this problem. And It hasn't
happened since than. I would hope that I will be able to continue to rent this Lot as I do not have any where to move
my Trailer at this time,But I will start to look for land and will let you know,Whan I do.Thank you for everything.
Sincerely,
Anna Koabel
Craig and Annette Shearer
1550 Williams Grove Road, #103
_M__ec_~h a_ _ni~e_s.b u r g, ?A 1'~0_55
(717) 766-13o6
January 8, 2000
Williams G-rove Associates
c/o Diane L. Fagan
P.O. Box 176
Camp Hill, PA 17001
Re: Lot Rent Increase
Dear Ms. Fagan:
We are in receipt of your letter informing us of once again, since Williams Grove
Associates has taken ownership of the park, that our lot rent is increasing. I believe your letter
stated due to increased costs of rurming the park, which would have us to believe, since your
ownership, the cost have increased sixty-five ($65.00) dollars per month per mobile home.
. As mobile home owners, not renters with the option of picking up andjustmoving,_the ....
justification seems lacking. Since the change of ownership, all ~ve have endured, is numerous
outages of electric, water loss, (which caused our hot water heater to blow an element, which
caused us to incur a repair bill) and roads being tom up and never repaired properly, (due to
additional units being added) loss of the laundry mat, loss of laundry lines, loss of overflow
parking for guests, more children and pets running through our yard without permission, other
adults walking through our yard, day and night, leaving behind cigarette butts, etc., with little if
any respect for our property and maintenance.
I realize as an adult, writing this letter is simply a way for us to vent our unhappiness and
displeasure with Williams Grove Associates and more than likely will fall on deaf ears.
~6wever, we ~ wah~ Go s~-~te, s~nce our owners~)--o-f6~ home, ~'[~'10T~n-ffhas never-beffff la~,-- .....
we have caused no problems, keep our home and lot in exemplary condition and to our avail,
keep getting ridiculous additional charges, that certainly have not aided in our quality of living.
Perhaps, you are unaware, two (2) years ago when we moved in, we took into
consideration the low lot rent, one hundred sixty-five ($165.00) dollars at that time, which
seemed fair and acceptable to live in a park, with a roller coaster all but in it, which that and the
amusement park itself provide much noise, the fact that a Speedway is within just a few miles,
which we also get severe noise and pollution from, then of course there's the marsh swam
Y P
(which is an eye sore and health issue, because surrounding neighbors have been seen throwing
everything from garbage to their dog feces in) and the fact that we have to incur a charge each
month to maintain flood insurance, due to the fact that Williams Grove Mobile Home Park is a
terrible flood plain.
Williams Grove Associates
January 6, 2000
Page 2
To state the short message of this letter, we as home owners see little if any improvement
of the park since your ownership, in fact, the few rules which were previously enforced, are now
miserable again to contend with. For example, a few months ago, I called, there was a strange
car parked in our parking lot, your receptionist informed me to write a letter, that is ridlculoua, I
am to have no parking for the duration it takes my letter to arrive and be reviewed and actually
acted upon·
d The tenants in the new double-wide you crammed in the cul-de-sac we live in, let their
og, bark and run all hours of the day and night: The dog defecates in our yard and ~'thr0~gh
disturbing u~ constantly. The children that live their have no respect at all, they nm in and out of
our yard, nde their bicycle s dangerously close between our vehicles m our driveway. When they
· have guests, they park in such a way it is nearly impossible to back our cars out of our parking
Basically, as is, we live in our home, pay unreasonably high lot rent and are forced to
tolerate all the inconvenience of your so-called improvements to the park, upon one occasion, I
was late for work, the men delivering a double-wide took it upon themselves, to block the only
bridge out of the park with a half of double-wide for over thirty (30) rains, the amusement park,
the race track, the marsh land, and a bunch of disrespectful, unruly neighbors and park tenants,
because again, this place is a free for all!
Not all people who reside in trailer parks allow their children to nm amuck, their pets to
destroy others' peace ap.d property, park non-operatable vehicles all over the place· Speaking of
which, perhaps, you could inform us, why your maintenance man, Bill, has been allowed to
leave a non-operatabIe van in what's left of the overflow parking for the past approximate six (6)
months, it is an eyesore, it is in the way and since he currently has two (2) lots, why do we have
to tolerate its obtrusiveness? Let him park it in one of his lots and look at the ugly thing every
day!
You wi11 note our lot rent check, certainly reflects your fifteen ($15.00) dollar rent
increase, but as far as we're concerned, we may have to pay it, but at least we should have is the
satisfaction for our money to express our displeasure. Your answer to this may be the obvious, if
we don't like it, we can leave, and our obvious answer to that will be, as soon as it is hmuanly
possible for us to do so, that is exactly what we will do. However, the big picture is, you lose
tenants, who never try to bother anyone, who respect the rights and priviIeges of our neighbors,
who contain and monitor our children's behavior, who keep their one (l) pet secured in their
own home at all times, who pay every month on time or even early. Perhaps when the park is
filled with tenants much like your most recent find; you will discover your error.
Very truly yours, f f~,
~ ,~ ,/.(../
Annette andCraig Shearer
1550 ~illiams Grove Road, #103
Mechanicsburg, PA 17055
(717) 766-1306
March 13, 2000
Williams Grove Associates
c/o D.L. Fagan
P.O. Box 176
CampH~O1...~
Dear Ms. Fagan:
I trust you have received all lot rent checks and our account is now back to being current.
Again we apologize for the oversight.
I.am: writing; as isthe policy o~Willi~ GroVe AssoCiates to complain a~t the
above'refe.renCed familj; th~~ ~a~ly:in'~hi~ ~'~' ~arlier letter referred ~0,.and. lodge
,,complaints. ~;
Over the past weeks, my husband and myself, continually request the children; Maria,
Anna and Loma to stay out of our yard, away from our vehicles, to NO avail!l!!! Things in our
yard (a snowman our son built) have been destroyed, my vehicle has received a ding, trash has
been found, we, as have our neighbors, w/massed on numerous occasions the children sitting on
the bumpers of our vehicles, leaning against them with their bikes, this is unacceptable, this is
our property and we should not have to tolerate this, since our vehicles are located on your
property would that make any damage received your financial responsibility7 We both make
monthly vehicle payments!
In addition, the children will sit in the middle of the road on their bikes and not move
when they see oncoming cars, the one gift will actually try to grab onto the bumper of moving
vehicles to be pulled on her bike, I assume should she hit the back of my car, that would be my
fa.u!t? There vehicles (van and blue station wagon), along w/th all different types, numerous
vtsnors, day and night, still park in the middle of the cul-de-sac making it terrible for us to try to
leave our own driveway.
Ms. Anna Koble is rarely, if ever home in the evenings and the children are permitted to
run all over the place with little or no respect for others pro~rty and/or privacy!
This evening, when my Daughter and myself arrived home for the evening, Maria and
Loma were sitting on their bikes in our driveway and did not move until told to do so. Shortly
after we went into our home, the gifts began yelling and basically just behaving obnoxiously to
my other neighbor and the children at Lot #104, they are also unwelcome there, so since a week
or so ago, they stand in our yard, or our driveway, scream, antagonize and fight, which is very
disruptive and armoying!!!! I went out and told them to remove themselves from our driveway,
Williams Grove Associates
March 13, 2000
Page Two
away from my veh/nle and reminded Maria that they were not welcome over here, I received
grie-l'lSom a smart-mouth-e-fl~'l--lyehavefl~hfldr-Whu then weat~over, her-i~lotheh Axma-cam~to-
her door, I was doing dishes at my kitchen sink and could see her looking over here and pointing.
My neighbm, Dixie, was out doing yard work, later told me she was screaming f- - - - this, f- - - -
that, shortly thereafter, over comes pregnant, unwed, toenaged sister, Allison, to my door to get
smart with me and tell me I should ask nicely for her sister to stay away from my property, all
the while her friend stood in my driveway and Dixie heard her state, "I should spit on her car,"
the yard is yours, my vehicle, my husband's vehicle and the mobile home, belong to us, we
should not have to take this kind of harassment and garbage every day! Are children and unwed
toens now running the park7 I assure you, they are.not running our lives, paying our bills!
Again, I say, this is not how this neighborhood used to be, the eul-de-sae's residents
respected each other, their property and tried to get along, this family is making life intolerable
and we implore you to do something about them, these children nm day and night and feel they
have every right and freedom to do so! The actions of there Mother certainly seem to indicate
their own mimicked behavior! Other,vise, our only alternative is to involve the Police and/or
Children and Youth Services.
Very truly yours,
~ett~ Craig Shearer
~ ~ /
Exhibit C
i ~°i '
PS Form 3800, April 1995
PS Form 3800, April 1995
WILLIAMS GROVE MOBILE HOME PARK
WILLIAMS GROVE A~SOCIATES
C/O D.L. FAGAN
P.O. BOX 176
CAMP HILL, PA 17001
717-737-3299
DATE: January 18, 2000
FIRST NOTICE OF VIOLATION OF
pARK RULES D_ND REGULATIONS
TO:
ANNAM. KOABEL, ETAL
LOT 105A (LOT C)
WILLIAMS GROVE MHP
THIS LETTER IS LEG/~L NOTICE TO YOU PURSUANT TO 68 P.S. 398.3 THAT YOU HAVE
VIOLATED YOUR LEASE TERMS AND RULES AND REGULATIONS IN SO FAR AS:
1. Your dog is running loose, is left outside unleashed, is running in public
areas and on other Resident's lots, is defecating on your lot and other
Resident's lots and such defecation is not being cleaned up
2. Your children are trespassing on other Resident's lots
3. Your guests are parking in unauthorized parking spaces
IF YOU SHOULD FAIL TO CORRECT...THESE y!OLATIONS.!~DIATEL¥ OR IF YOU SHOULD
VIOLATE mY oTHER ~ '6R"~ULAT~ ~N' ~X Mo~ OF THE DATE OF THIS
NOTICE, THE OWNERS INTEND TO COMMENCE EVICTION PROCEEDINGS AGAINST YOU
'i~DIATELY.
PLEASE CORRECT THESE VIOLATIONS IM~f~DIATELY. THAlqK YOU FOR YOUR
COOPERATION.
WILL~I~ GROVE ASSOCIATES
CERTIFIED
RETURN RECEIPT REQUESTED
cc: FILE
WILLIAMS GROVE MOBILE HOME PARK
WILLIAMS GROVE ASSOCIATES
C/O D.L. FAGAN
P.O. BOX 176
CAMP BILL, PA 17001
717-737-3299
Date: January 18, 2000
ALTERNATE NOTICE TO MOBILE HOME PARK RESIDENT
To:
Anna M. Koabel, Etal
Lot #105A (Lot c)
Williams Grove ~P
We have this day sent you by certified mail a first notice that you have
violated certain rules and regulations established in the park. A duplicate copy
of the legal notice is enclosed for your information.
Willia~us ~ove Associates
cc: file
Exhibit D
· C=mplete Items 1, 2, and 3. Also complete
item 4 if ResMcted Delivery Is desired.
· Print your name sad address on the reverse.
so that we can return the card to y~u.
· Attach this card to the back of the mallplece,
or on the front If space permits,
PS Form 3811, July lg~9 ' ' '
D, Is delivery ~ddress different from item 1 ?1 i'-I Yes
If YES, enter delivery addr~!a below: Fl No
I~( CertJf~ed Mall D Express Mall
[] Registered n Return Receipt for Merchandise
[] insured Mall [] C.O.D.
4. Restricted Delivery? [Ex~a Fee) ri Ye~
Z 193 432 571
US Postal 8ewlce
Receipt for Certified Mall
No Insurance Coverage Provided.
ot L
· C=mplete h'ems 1, 2, and 3. Also complete
item 4 if Restricted Delivery Is desired.
· Pdnt your name and address on the reveme
so that we can return the card to y6u.
· Attach this card to the back of the mallpieca,
or on the front if space permits.
C. Signet
v .... ~ ~ I,~J r'3Addi~.~e
D. is deih~ry address different from Rem 171 ~] Yes
~f YES, enter delivery address below: C3 No
3. Se Type
~ed Mall
r'9 Registered
[] Insured Mall
E3 Express Mail
~] Return Receipt for Merchandise
[] C.O.D.
2. ArfleieNumber(Copyfromle~c,~ebeO ~ --
¥3
PS Form 3811, July 19~9 ' Domestic Return Receipt
4. Restricted Delivery? ~ Fee)
[] Yes
Z 193 432 571
US Postal Service
Receipt for Certified Mail
No Insurance Coverage Pmvfded.
Do not u
WILLIAMS GROVE ASSOCIATES
WILLIAMS GROVE M/~P
C/O D.L. FAC=AN
P.O. BOX 176
CAMp HILL, PA 17001
717-737-3299
DATE: June 5, 2(
SECOND AND FINAL NOTICE OF VIOLATION O
PARK RULES AND REGULATIONS
TO:
ANNA KOABEL, ETAL
LOT 105A
WILLIAMS GROVE MOBILE HOME PARK
THIS LETTER IS LEGAL NOTICE TO YOU PURSUANT TO 68 P.S.
VIOLATED YOUR LEASE TERMS AND RULES AND REGULATIONS IN SO
1.
00
398.3 THAT YOU HAVE
FAR AS:
Your dog is running loose, is left outside unl~ ~shed, is running in
public areas and on other Resident's lots, is d~fecating on your lot
and other Resident's lots and such defecation is Lot being cleaned up,
and is becoming a nuisance and menace to other ~esidents
You have adopted a cat without authorization of Management, your cat
is running loose without being leashed and you= cat is left outside
unattended
Your children are trespassing on other Resident's lots
The behavior of your daughter, Anna, is dist' rbing the peace and
tranquility of the community
SINCE YOU HAVE VIOLATED OTHER RULES AND REGULATIONS IN TI ~ PARK PER OUR PRIOR
· L. FAGAN~ ~AGER
CERTIFIED
cc: FILE
WILLIAMS GROVE MOBILE HOME PARK
WILLIAMS GROVE ASSOCIATES
C/O D.L. FAGAN
P.O. BOX 176
CAMP HILL, PA 17001
717-737-3299
Date: June 5, 2000
ALTERNATE NOTICE TO MOBILE HOME PARK RES ENT
To: Anna Koabel, Etal
Lot 105A
Williams Grove MHP
We have this day sent you by certified mail a second and final notice that you ~ve violated certain rules and
regulations established in the park. A duplicate copy of the legal notice is enclosed for your information,
Williams Grove ~oclates
Property Manage'~''~
cc: File
WILLIAMS GROVE ASSOCIATES
Plaintiff
ANNA M. KOABEL
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2000 4578 Civil
: CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I hereby certify that the foregoing Complaint was sent by first class mail, postage
prepaid this date to the following:
Anna M. Koabel
Williams Grove Mobile Home Park
1550 Williams Grove Road
Lot 105A
Mechaniosburg, PA 17055
Phillip Briganti, Esq.
Attorney for Defendant
Legal Services Inc.
8 Erving Road
Carlisle, PA 17013
Respectfully Submitted,
DATE: September/C, 2000
WiX, WENGER & WEIDNER
Kevin S. Blanton, Esq.
508 North Second Street
P.O. Box 845
Harrisburg, PA 17108-0845
(717)234-4182
Attorneys for Plaintiff
Exhibit E
· Complete items 1, 2, and 3. Also complete
item 4 ~f Restricted Delivery is desired.
· Print your name and address on the reverse
so that we can return the card to you.
· Attach this card to the back of the mailpiece,
or on the front if space permits.
PS Form 3811, August 200~
B. Rsceived by (FWntecl Name)
[] Agent
i--~ Addressee
D. Is delivery address diffemnt from ltern l ? [] Yes
if YES, enter delivery address below: [] No
3. 8erv~ce'P
[] Registered
[] Insured Mall
4. Restricted Deliver3,? (Extra Fee)
700__1 0320~000!. 6701 9357
Domestic Return Receipt , ~r
DYes
WILLIAMS GROVE MOBILE HOME PARK
WILLIAMS GROVE ASSOCIATES
C/O D.L. FAGAN
P.O. BOX 176
CAMP HILL, PA 17001
717-737-3299
DATE: 10/17/01
FIRST NOTICE OF VIOLATION OF
PARK RULES AND REGULATIONS
TO:
Anna Koabel
Williams Grove MHP - Lot 105A
1550 Williams Grove Rd.
Mechanicsburg, PA 17055
THIS LETTER IS LEGAL NOTICE TO YOU PURSUANT TO 68 P.S. 398.3 THAT YOU HAVE VIOLATED
YOUR LEASE TERMS AND RULES AND REGULATIONS IN SO FAR AS:
Your children have used profane and abusive language; You had a loud
party which disturbed the peace and tranquility of the Park; and your
guests did not conduct themselves properly while visiting you~ including
drunkenness.
IF YOU SHOULD FAIL TO CORRECT THESE VIOLATIONS IMMEDIATELY OR IF YOU SHOULD VIOLATE
ANY OTHER RULE OR REGULATION WITHIN SIX MONTHS OF THE DATE OF THIS NOTICE, THE
OWNERS INTEND TO COMMENCE EVICTION PROCEEDINGS AGAINST YOU IMMEDIATELY.
PLEASE CORRECT
COOPERATION.
CERTIFIED
RETURN RECEIPT REQUESTED
THESE VIOLATIONS IMMEDIATELY. THANK YOU FOR YOUR
WILLI~..AM,~ROVE ASSOCIATES
PROPERTY MANAGER
cc: FILE
WILLIAMS GROVE MOBILE HOME PARK
WILLIAMS GROVE ASSOCIATES
C/O D.L. FAGAN
P.O. BOX 176
CAMP HILL, PA 17001
717-737-3299
Date: 10/17/01
To:
ALTERNATE NOTICE TO MOBILE HOME PARK RESIDENT
Anna Koabe 1
Williams Grove ~p - Lot 105A
1550 Williams Grove Rd.
Mechanicsburg. PA 17055
We have this day sent you by certified mail a first notice that you have violated certain rules and regulations
established in the park. A duplicate copy of the legal notice is enclosed for your information.
ates
Property Mana~el:~
cc: File
Exhibit F
7001 1940
0~305 87t3
0927
WILLIAMS GROVE ASSOCIATES
WILLIAMS GROVE MHp
C/O D.L. FAGAN
P.O. BOX 176
CAMP HILL, PA 17001
717-737-3299
DATE: 11/07/01
SECOND AND FINAL NOTICE OF VIOLATION OF
P/LRK RULES AMD REGULATIONS
TO:
Anna Koabel
Williams Grove ~P - Lot 105A
1550 Williams Grove Rd.
Mechanlcsburg. PA 17055
THIS LETTER IS LEGAL NOTICE TO YOU PURSUANT TO 68 P.S. 398.3 THAT YOU HAVE
VIOLATED YOUR LEASE TERMS A/FD RULES AND REGULATIONS IN SO FAR AS:
Your children have used profane and abusive language: and they have
disturbed the peace and tranquility of the Park.
SINCE YOU HAVE VIOLATED OTHER RULES AND REGULATIONS IN THE PARK PER OUR PRIOR
NOTICE, THE
I~4EDIATELY. YOU
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
OWNERS INTEND TO
CO}94ENCE EV,~ION PROCEEDINGS AGA/NST
D. L. FAGAN, PRO~R~y MANAGER ~
cc: FILE
WILLIAMS GROVE MOBILE HOME PARK
WILLIAMS GROVE ASSOCIATES
C/O D.L, FAGAN
P.O. BOX 176
CAMP HILL, PA 17001
717-737-3299
Date: 11107101
ALTERNATE NOTICE TO MOBILE HOME PARK RESIDENT
To;
Anna Koabel
Williams Grove ~P - Lot 105A
1550 Williams Grove Rd.
Mechanicsburg, PA 17055
We have this day sent you by certified mail a first notice that you have violated certain rules and regulations
established in the park. A duplicate copy of the legal notice is enclosed for your information.
cc: File
catas
: P;o;er'b/Ma ~a'~r~'~
Exhibit G
NOTICE TO QUIT DUE TO VIOLATION OF LEASE
NAME OF LANDLORD:
NAME OF TENANT:
WILLIAMS GROVE ASSOCIATES
ANNA KOABEL
DATE OF LEASE:
LEASED PREMISES:
OCTOBER 3, 1999
LOT 105A, WILLIAMS GROVE MHP
MECHANICSBURG, PA 17055
DATE OF NOTICE TO QUIT: DECEMBER 20, 200t
TO: ANNA KOABEL, ETAL
YOU ARE HEREBY GIVEN NOTICE TO QUIT THE LEASED PREMISES
DUE TO A BREACH OF A CONDITION OF YOUR LEASE AND RULES AND
REGULATIONS, TO WiT:
1. YOUR CHILDREN HAVE USED PROFANE AND ABUSIVIE LANGUAGE IN
THE PARK
2. YOUR CHILDREN HAVE DISTURBED THE PEACE AND TRANQUILITY
OF THE PARK
3. YOUR GUESTS DID NOT CONDUCT THEMSELVES PROPERLY WHILE
VISITING YOU IN THE PARK
4. YOUR GUESTS SHOWED PUBLIC DRUNKENNESS IN THE PARK
5. YOU CREATED A LOUD NOISE DISTURBANCE IN THE PARK BY
HOLDING A PARTY OUTSIDE/INSIDE YOUR HOME
YOU MUST LEAVE THE LEASED PREMISES WITHIN FORTY-TWO (42)
DAYS. (BY JANUARY 31, 2002)
IF YOU DO NOT LEAVE THE LEASED PREMISES AND GIVE
POSSESSION OF THE LEASED PREMISES TO LANDLORD WITHIN THE
ABOVE PERIOD, LANDLORD WILL BEGIN APPROPRIATE LEGAL ACTION
TO HAVE ~OI~REMOVED FROM THE LEASED PREMISES.
D~-I'~ FAGAN,X~ROPERTY MANAGER
SERVED THIS ~'/-h DAY OF ~C~ C--~ 2001.
Exhibit H
· Complete items 1, 2, and 3. Also complete
item 4 If Restricted Delivery I$ desired.
· Print your name and address on the reverse
so that we can return the c~ard to you.
· Attach this cad to the back of the mallplece,
or on the front if space permits.
1. A~ticle Addressed to:
B. Received by (Pdnted Name)
[] .~t
[] Addressee
4. Restricted Delive~? (Extra Fee) i-I Yes
2. Article Number
PS Form 3811, August 2001 / DomesUc Return Receipt
WILLIAMS GROVE MOBILE HOME PARK
WILLIAMS GROVE ASSOCIATES
C/O D.L. FAGAN
P.O. BOX 176
CAMP HILL, PA 17001
717-737-3299
DATE: 119/02
TO:
FIRST NOTICE OF VIOLATION OF
PARK RULES AND REGULATIONS
Anna Koabel
Williams Grove ~P - Lot 105A
1550 Williams Grove Rd.
Mechanicsburg. PA 17055
THIS LETTERIS LEGAL NOTICE TO YOU PURSUANT TO 68 P.S. 398.3 THAT YOU HAVE VIOLATED
YOUR LEASE TERMS AND RULES AND REGULATIONSIN SO FAR AS:
~e only persons permitted to occupy your home are yourself, your son
and three daughters. Your ex-husband. Charlie, must move i~mediately.
Also. you 9uest disturbed the peace and tranquility of the Park and
trespassed on another tenant,s lot.
IF YOU SHOULD FAIL TO CORRECT THESE VIOLATIONS IMMEDIATELY OR IF YOU SHOULD VIOLATE
AN.Y OTHER RULE OR REGULATION WITHIN SIX MONTHS OF THE DATE OF THIS NOTICE, THE
OWNERs INTEND TO COMMENCE EVICTION PROCEEDINGS AGAINST YOU IMMEDIATELY.
PLEASE CORRECT THESE VIOLATIONS IMMEDIATELY. THANK YOU FOR YOUR
COOPERATION.
D. L. FAGAN ~
PROPERTY MA~IAGER
CERTIFIED
RETURN RECEIPT REQUESTED
cc: FILE
WILLIAMS GROVE MOBILE HOME PARK
WILLIAMS GROVE ASSOCIATES
C/O D.L. FAGAN
P.O. BOX 176
CAMP HILL, PA 17001
717-737~3299
Date: 1~ 102
· ALTERNATE NOTICE TO MOBILE HOME PARK RESIDENT
To! Anna Koabel
Williams Grove MHP - Lot 105A~
1550 Williams Grove Rd.
Mechanicsbur§, PA 17055
We have this day sent you by certified mail a first notice that you have violated certain rules and regulations
established in the park. A duplicate copy of the legal notice is enclosed for your information.
Williams Gr,qve~socJates
by: D.L. Fagan '~..,.
Property Manager
cc: File
Exhibit I
· Complete Items 1, 2, and 3, AJso complete
item 4 if Restricted Delivery ia d~ired.
· Print your name and address on the reverse
so that we can return the card to you.
· Attach this c~rd to the back of the mailplece,
or on the front if space permits,
[] Agent
0 ~dmssee
B. Received by (
D. Is delive~ address different from item 17 ~]Yes
If YES, enter deliver3/address below: [] No
4. R~trlcted Delivery? (Extra Fee) [] Yes
7001 25t0 0009 2218 1638
PS Form 3811, August 2001
Domestic Return Receipt 102595-01-M-2509
WILLIAMS GROVE ASSOCIATES
WILLIAMS GROVE M~P
C/O D.L. FAGAN
P.O. BOX 176
CAMp HILL, PA 17001
717-737-3299
DATE: 2/11/02
SECOND AMD FINAL NOTICE OF VIOLATION OF
PARK RULES AND REGULATIONS
TO:
Anna Koabel
Williams Grove ~P - Lot 105A
1550 Williams Grove Rd.
Mechanicsburg. PA 17055
THIS LETTER IS LEGAL NOTICE TO YOU PURSUANT TO 68 P.S. 398.3 THAT YOU HAVE
VIOLATED YOUR LEASE TERMS AND RULES AND REGULATIONS IN SO FAR AS:
YOur ex-husband, Charles, must move immediately out of the Park.
He is not on the lease and is creating problems with other
tenants, disturbing the peace and tranquility of the Park and
showing public intoxication.
HE HAS 10 DAYS TO MDVE. IF NOT MOVED BY 2/21/02, WE WILL CONSIDER HIM
A TRESPASSER ANDHAVE HIM ARRESTED.
SINCE YOU HAVE VIOLATED OTHER RULES AND REGULATIONS IN THE PARK PER OUR PRIOR
NOTICE, THE OWNERS INTEND TO COMMENCE EVICTION PROCEEDINGS AGAINST YOU
IMMEDIATELY.
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
cc: FILE
WILLIAMS GROVE MOBILE HOME PARK
WILLIAMS GROVE ASSOCIATES
C/O D.L FAGAN
P.O. BOX 176
CAMP HILL, PA 17001
717-737-3299
Date: 2/11/02
To:
ALTERNATE NOTICE TO MOBILE HOME PARK RESIDENT
Anna Koabel
Williams Grove MHP - Lot 105A
1550 Williams Grove Rd-
Mechanicsburg. PA 17055
We have this day sent you by certified mail a first notice that you have violated certain rules and regulations
established in the park. A duplicate copy of the legal notice is enclosed for your information,
cc: File
Willi~G~_e~ r~ ms ove sociates
by: D, L. Fagant,x ..~..- ,
Property Mani~r ~~
Exhibit J
March 6, 2002
WILLIAMS GROVE ASSOCIATES
C/O D.L. FAGAN
P.O. BOX 176
CAMP HILL, PA 17001-0176
Mm Anna Koahel
Williams Grove lVlttP - Lot 105A
1550 Williams Grove Road
Mechanicsburg, PA 17055
NOTICE OF NONRENEWAL OF LEASE
Dear Mrs. Koahel:
Your lease will expire on April 9, 2002.
We will not be renewing your lease; therefore, you must move from the property by April
9, 2002.
If you wish to have your ex-husband apply for occupancy effective April 10, 2002, please
have him fill om the application that was mailed to you February 20, 2002, and return to
us immedime~y.
D.L. FaganX~
Manager ~
Cc: David Lam'a> Esquire
Certified Mail, Return Receipt Requested
Regular Mail
Served this 5~ day of March 2002.
POSTED ON PREMISES
Exhibit K
04/03/2002 8i:84 727-737-54b3 FAGA~4 ACCOUN'IING PA~E 85
WILLIAMS GROVE ASSOCIATES
WILLIAMS GROVE MHP
CIO D.L. FAGAN
P.O. BOX 176
CAMP HILL, PA 17001
(717) 737~3299
DATE:
TO:
FROM:
November 30, 1999
All Residents
Management
Due tO increased costs in operating the park, please be advised of the following:
Effective January 1, 2000, the rent sail be increased $15_00 per monlh for all
Residents who live in the Park.
Your current lease and the Rules and Regulations estabrk~hed inthe park will remain
in effect. All other applicable fees per the Rules and Regulations will remain in
effect.
Please make sure all rent checks are made payable to Williams Grove
Associates and mailed to P.O. Box 176, Camp Hill, PA 17001.
Thank you very much for your past cooperation and we look forward to your
continued occupancy in the Park.
Best wishes for a Happy Holiday.
04/03/2002 0Z:04 717-737-5453 F~GAH ACCOUNTING PAbE 04
WILLIAMS GROVE ASSOCIATES
WILLIAMS GROVE MHP
CIO D.L. FAGAN
P.O. BOX 176
CAMP HILL, PA 17001
(717) 737-3299
DATE:
TO:
FROM:
November 28, 2000
All Residents
Management
Due to increased costs in operating the park, please be advised of the following:
Effective January 10, 2001, the rent will be increased $10.00 per month for all
Residents who live in the Park,
Your current lease and the Rules and Regulations established in the park will remain
in effect. All other applicable fees per the Rules and Regulations will remain in
effect.
Please make sure all rent checks are made payable to Williams Grove
Associates and mailed to P.O, Box 176, Camp Hill, PA 17001.
Thank you very much for your past cooperation and we look forward to your
continued occupancy in the Park.
Best wishes for a Happy Holiday.
04/03/2002 01;04 ?~7-?$7-54b3 FaGaN ACCOUNYZNa PA~E 83
WILLIAMS GROVE ASSOCIATES
CIO .D.L. FAGAN
P.O. BOX t76
CAMP HILL, PA 17001
717-737-3299
DATE: NOVEMBER 19, 2001
TO:
ALL RESIDENTS
WILLIAMS GROVE MHP
FROM: D.L. FAGAN
.PLEASE BE ADVISED THAT WE WILL BE INSTALLING WATER METERS AND
READING DEVICES ON EACH INDIVIDUAL LOT AT THE PROPERTY.
THIS WORK WILL COMMENCE IN THE VERY NEAR FUTURE.
OUR CONTRACTOR WILL NEED TO GAIN ENTRANCE TO THE WATER PIPE
UNDER YOUR HOME; THEREFORE, PLEASE REMOVE YOUR SKIRTING IN THE
WATER PIT. AREA. WE WILL NOT BE RESPONSIBLE FOR ANY DAMAGE
CAUSED.
EFFECTIVE JANUARY 1, 2002, THERE WILL BE A RENT REDUCTION OF $10.00
PER MONTH AND ALL RESIDENTS WILL START PAYING FOR THEIR OWN
WATER, SEWER AND TRASH REMOVAL.
OUR METER READING COMPANY (WATER SAVER SYSTEMS, INC) WILL DO THE
MONTHLY BILLING THAT WILL REFLECT THE FOLLOWING CHARGES:
MONTHLY SEWER/TRASH (FLAT FEE) $ 16.00
MONTHLY WATER FEE (BASED ON CONSUMPTION)
MINIMUM BILLING FOR 3000 GALLONS PER MONTH $ 9.75
ADDITIONAL CHARGES ($.0049 PER GALLON IN EXCESS OF
3000 GALLONS PER MONTH)
YOU WILL BE RECEIVING A MONTHLY SILL FROM WATER SAVER SYSTEMS,
INC, , FOR THESE UTILITIES, THE AMOUNT DUE ON THIS BILLING SHOULD BE
ADDED TO YOUR MONTHLY RENT CHECK AND PAID DIRECTLY TO WILLIAMS
GROVE ASSOCIATES. DO NOT SEND ANY PAYMENTS TO WATER SAVER
SYSTEMS, INC.
IF YOU HAVE ANY QUESTIONS, PLEASE CALL WATER SAVER SYSTEMS, INC.
AT 1-800-227-3141.
Exhibit L
04/88/2002 21:28
717-737-5463
FAGAN ACCOUNTING
PAGE 01
WILLIAMS GROVEASSOCIATE$
C/O D.L. FAGAN
P.O. BOX 176
CAMp HILL, PA 17001
(717)737-3299 FX: (717) 737-5463
PAGE 1
ANNA i~. KOAB~.L
WILLIAMS GROVE MI4P - LOT 10SA
1550 WILLIAMS GROVE ROAD
MECHANICSBURG, PA 17055
STATEMENT DATE: 4/15/2002
ACCOUNT NUMBER: C-KOABEL
STATEMENT OF ACCOUNT
CHARGES
1/ 1/2002 OPENING BALANCE
1/ 9/2002 CE~T LTR INVOICE 10.00
1/10/2002 IATVOICE 266.00
26.60
1/23/2002 LATE FEE INVOICE
1/25/2002 COURT INVOICE 81.50
2/10/2002 INVOICE 266.00
2/11/2002 CERT LTR INVOICE 10,00
2/14/2002 MO PAYMeNT-THANK YOU
2/20/2002 LATE FEE INVOICE 26.60
3/10/2002 INVOICE 266.00
3/10/2002 WATER INVOICE 41.11
3/20/2002 LATE FEE INVOICE 30.71
4/10/2002 INVOICE 266.00
4/10/2002 WATER INVOICE 30.82
308.00
318.00
584.00
610.60
692.10
958.10
968.10
610.60 357.50
384.10
650.10
691.21
721.92
987.92
1,018.74
AMOUNT DUE:
$1,018.74
Current 31 - 60 61 - 90 90+ TOTAL DUE
327.53 333,71 357.50 0.00 ~,o18.74
04~,03/'2002 Or: 84
.or WIL~N6 ~RO~E CIO DL FAGAN
FAGAN AccOUN'I~.I_NG,
03/23/02 Page 2
~F.~ING DATES
~T~ p,~gI~S
TO
02/14 03/15
4300 5900
~0 ~0 1BO0
4300 6700 ~0
~790~ ~6~0
256~0 37~00 l~7OO
~3600 23700 ~0~00
100 200 tO0
~600 ~00 ~00
20200 32000 11~0
[0100 1~0 5300
10O 200
17700 25000 7306
39000 4~00 220~
5100 7700 2600
42~ 5~0
9400 13~00
5~00 7709 2700
2300 3600 ~300
1400 2200 800
~ R~ ' NO B~LL
01/~4
460~ ~00 ~00
6600 9~0 3000
9300 [3500
~2/01
02/14 03/15
4100 5900
N0 ~ING · ~
D2/14 03/15
ZOO0 2900
7400 [3200
7000 9900
1900 2900
3EO0 5306
9900 11800
7500 11600
6300 8000
3200 3500
7300
300~ 4500
3600 4700
12/01 12/O[
HO R~ING ' HO BILL
gl/LO 03/15
g2/14 03/i5
5900 9~00
TOTAL
GAL ~L~,TER SE~m, CHA~.C~¢-S
USAGE Ct~'GES CHARGES
9.75 [6.00 " 25.75
9.75 16.00 " 25.75
9.75 16.00 · 25.75
26.41 16.00 · 42,41
35.72 16.00 , 51.72
52.38 16.00 68.38
,44,54 16.00 60,54
9,75 16.00 ' 25.75
9.75 16,00 · 25.75
52.57 16.00 · 65.87
~.02 16.00 37.02
9.75 [6.00 = 25.75
(~ 16.00 " 46.82
9.75 16,00 · 25.75
9.75 16.00 25.75
9.75 16,00 ' 25,75
14.65 16,00 " 30.65
9.75 16.00 25-75
9,75 16,00 25.75
9.75 16,00 25.75
9.75 16.00 · 25.75
935 [6.00 · 25.75
9.75 16.00 ' 25.76
15.63 [6.00 31.63
1800 9.75 16.00
2535
900 9.75 16.00 25,75
5800 23.47 16.00 39.47
2900 9.75 16.00 25.75
~000 9,75 16.00 ' 25.75
~00 9.75 16,00 25.75
1900 9.75 16.00 25.75
4100 15.14 16,00 31.14
7400 31,31 16.00 ' 47.31
1700 9.75 16.00 25.75
300 9,75 16.00 25.75
2tO0 9.75 16.00 25.75
1500 9.75 16.00 , 25.75
1100 9,75 16,00 25.75
4010 14,70 16.00 30.70
3~00 10.24 16.00 26.24
04/t3/2002 01:04 717-737-5463 FAGAN ACCOUNTING PAGE 07
445 G~U)VE C/O DL FAGAN
02/22102 Pa9~ 2
READING DATES
~'TER RE~DIHG~ GAL WATER. $BWER TOTAL
NA~E TENANT ADi3RESS FRO4 TO USA6E CHARC~S CHARGES CHA~GES
01/16 02/14
2300 4300 2000
4500 6600 2i00
1800 ~300 2500
5100 13200 7100
~ 19500 27900 8400
36 11600 25600 14000
~937 7900 13600 5700
99~0 100 100 0
9939 2200 4600 2400
9940 9900 20200 10300
9941 4800 10100 5300
9942 lO0 100 0
9943 ANNAM. KOA~EL 1550 WMS C~OV[ RD#IONA~ 6300 17750 g400
gg44 ....... 36300 39000 2700
g945 2400 5100 2700
9946 2~00 4200 2100
~9947 4600 9400 4800
{gg48 2500 5000 2500
~9949 2900 5600 2?00
~9950 1400 2300 900
Igg51 600 1400 800
51/10 01/16
~9952 NO RE~ING · NO gILL
01/16 02/14
19953 2200 4~00 2400
I9954 3000 6600 3600
)9955 4400 9300 4900
12/0[ 12/01
)9956 NO READING · NO BILL
01/16 02/14
19957 2400 4100
12/01 12/01
)9968 NO RE~ING - NO BILL
01/[6 02/14
]9959 700 2000 1300
)9960 3100 7400 4300
}9961 3800 7000 3200
39962 900 1900 100O
39963 1700 3500 1000
)9964 3400 9900 6500
39965 3500 7500 4000
)9965 3800 6400 2600
)9967 2400 6300 3900
39968 1800 3200 1400
39969 5200 7300 2100
29970 1600 3000 1400
1800 3600 1800
~9971 12/01 12/01
09972 NO READING , NO BILL
01/~ 01/10
o99 · ,o>
09974 2800 5900
9.75 16.00 25.75
9.75 16,00 25,75
9,75 16.00 25,75
29.84 16.00 ' 45.84
36,21 16,00 52.21
63.65 16.00 - 79,65
22,98 16.00 ' 38.98
9.75 16.oo(A) - 25.75
9.75 16.00 ·25.75
45.52 16.00 -61.52
21.02 ~6.00 -37.02
9.75 16.O0(A) - 25.75
16,00 57.11
[6.00 ' 25.75
9.75 16,00 ' 25.75
9.75 16,00 · 25.7~
18.57 ~6.00 34,57
9.75 16.00 - 25.75
9,75 16.00 · 25.75 '
9.75 16.00 = 25.75
9,75 16.00 - 25.75
9.75 16,00 ' 25.75
I2,69 16.00 28.69
19,06 16.00 35,06
1700 9.78 16,00 - 25.75
9.75 16.00 " 25,75
16,12 16,00 32,12
10,73 16,00 · 26.73
9,75 16.00 ' 25.76
9.75 16.00 ' 25,75
26.90 16.00 - 42.90
14.65 16.00 30.65
9.75 [6.00 25.75
14.16 16.00 30.16
9,75 1,6.00 25,75
g.75 16.00 ' 25.75
g,75 i6,00 = 25,75
9.78 16,00 ' 25.75
3100 10.24 16,00 - 26.24/
Johnson, Duffle, Stewart & Weidner
By: David L. Lanza
I.D. No. 55782
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Plaintiff
MARKLAND PROPERTIES, INC.
WILLIAMS GROVE ASSOCIATES,
Plaintiff
ffd/b/a
ANNA M. KOABEL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-779
CIVIL ACTION - LAW
IN EJECTMENT
.PRAEClPE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Kindly enter judgment by default in favor of the Plaintiff, and against the Defendant, for possession of
the real estate at Lot 105A, Williams Grove Mobile Home Park, by reason of the failure of the Defendant to
answer the Complaint within twenty (20) days of the date of service, and in the amount of $3,070.62.
It is hereby certified that written notice of intention to file this Praecipe was mailed to the Defendant at
Williams Grove Mobile Home Park, 1550 Williams Grove Road, Lot 105A, Mechanicsburg, Pennsylvania
17055 on January 31, 2003, said Notice being mailed certified mail after the default occurred and at least ten
(10) days prior to the date of the filing of this Praecipe. A true and correct copy of the aforesaid Notice is
attached hereto and made a part hereof.
Date:
:210619
JOHNSON, DUFFIE' 3TEWART & WEIDNER
I'rl Postage $
r~ --
ex- I Cert,fled Fee ~.... ~
~ (Endowment Req~l~) { ~ i ~ } /
St~t ~t ~: ..... ~' ' ' .................................
~ ~~;;~-~-~;--~-~-~,,~---~-~.~._.~ ............... .'.~
Johnson, Duffle, Stewart & Weidner
By: David $. Lanza
I.D. No. 55782
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043~0109
(717) 761-4540
Attorneys for Plaintiff
MARKLAND PROPERTIES, INC.
WILLIAMS GROVE ASSOCIATES,
ANNA M. KOABEL,
Plaintiff
Defendant
t/d/b/a
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-779 CIVIL
CIVIL ACTION - LAW
IN EJECTION
TO:
Anna M. Koabel
Williams Grove Mobile Home Park
1550 Williams Grove Road, Lot 105A
Mechanicsburg, PA 17055
DATE: January 31, 2003
IMPOR TA NT NO TICF
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS
TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF
THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE
YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING
OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
Cumberland County Bar Association
2 Liberty A venue
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
:167586
JOHNSON, DUFFLE, STEWART & WEiDNER
David J. Lanza
Attorney I.D. No. 55782
COMMUNITY BANKS, N.A.,
Plaintiff
Vo
WILLIAM WITKOSKI,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 02-2917 CIVIL TERM
:
: CONFESSION OF JUDGMENT
: CIVIL ACTION - LAW
PRAECIPE FOR JUDGMENT UPON ADMISSION
To the Prothonotary:
Please enter judgment in favor of the plaintiff against the garnishee, Waypoint Bank, in
the amount of Five Thousand Twenty Eight and 65/100 ($5,028.65) plus interest and costs of
suit, for the following property of the defendant:
Any and all funds found in the following checking and saving accounts held in the
name of William Witkoski:
(a)
Checking account number 1000012699, having an approximate balance of
$1,562.55,
(b)
Savings account number 101082551, having an approximate balance of
$3,466.10.
Garnishee admitted in the answer to interrogatories that it was in possession of said property.
Respectfully Submitted,
SAIDIS, SHUFF, FLOWER & LINDSAY
Date:
2109 Market Street
Camp Hill, PA 17011
(717) 737-3405
Attorney for Plaintiff
COMMUNITY BANKS, N.A.,
Plaintiff
Vo
WILLIAM WITKOSKI,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 02-2917 CIVIL TERM
:
: CONFESSION OF JUDGMENT
: CIVIL ACTION - LAW
PRAECIPE FOR WRIT OF EXECUTION
UPON JUDGMENT ENTERED UPON ADMISSION
To the Prothonotary:
Issue a writ of execution upon a judgment entered upon admission in the above matter:
1. directed to the sheriff of Cumberland County;
2. against Waypoint Bank, garnishee;
3. and index this writ
(a)
(b)
against William Witkoski, defendant, 417 Country Club Road, Camp Hill,
PA 17011
against Waypoint Bank, 17 West High Street, Carlisle, PA 17013, as
garnishee;
and levy upon the following:
(a)
Any and all funds found in the following checking and savings
accounts in the name of William Witkoski, in the possession of
Waypoint Bank, as garnishee, as admitted by Waypoint Bank, in its
Answers to Interrogatories to Garnishee filed in the above-captioned
matter:
(i)
Checking account number 1000012699, having an approximate
balance of $1,562.55,
(ii)
Savings account number 101082551, having an approximate
balance of $3,466.10.
Date:
Amount due:
Interest from 8/28/2002:
Attorneys fees
Costs
$5,028.65
(to be added)
(to be added)
(to be added)
Respectfully submitted,
SAIDIS, SHUFF, FLOWER & LINDSAY
By:
e/¢ . § , Esquire
~o ~urt3lff'i~ #24848
2109 Market Street
Camp Hill, PA 17011
(717) 761-1881
Attorney for Plaintiff
COMMLrNITY BANKS, N.A.,
Plaintiff
Vo
WILLIAM WITKOSKI,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 02-2917 CIVIL TERM
: CONFESSION OF JUDGMENT
: CIVIL ACTION - LAW
NOTICE OF JUDGMENT UPON ADMISSION
TO: William Witkoski
Waypoint Bank
You are hereby notified that on .029.n_x.~ ~:~
entered against you in the above captioned case:
,2003 the following judgment has been
Judgment in favor of Community Banks, N.A., Plaintiff, and against Waypoint Bank,
Garnishee in the amount of Five Thousand Twenty Eight and 65/100 ($5,028.65) and for the
following property of the Defendant, William Witkoski, being any and all funds held in the
following checking and savings accounts in the name of William Witkoski:
(a)
Checking account number 1000012699, having an approximate balance of
$1,562.55,
(b)
Savings account number 101082551, having an approximate balance of
$3,466.10,
together with interest and costs. Judgment is entered pursuant to Pa. R.C.P. 3146(b), Garnishee
having admitted in the answer to interrogatories that it was in possession of said property.
Prothonotary
I hereby certify that the proper person/entity to receive this notice under Pa. R.C.P. 236 is:
William Witkoski
Waypoint Bank
417 Country Club Road
17 West High Street
Camp Hill, PA 17011 Carlisle, PA 17013
Steven R. Williams
Wix, Wenger & Weidner, PC
508 N. Second Street
Harrisburg, PA 17101
Date:
Respectfully submitted,
SAIDIS, SHUFF, FLOWER & LINDSAY
By: ~
CS p e ne c,
2109 Mar~
Esquire
#24848
Street
Camp Hill, PA 17011
(717) 737-3405
Attorney for Plaintiff
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND) NO 02-2917 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTy:
To satisfy the debt, interest and costs due COMMUNITY BANKS, N.A., Plaintiff (s)
From WILLIAM WITKOSKI, 417 COUNTRY CLUB ROAD, CAMP HILL, PA 17011
(1) You are directed to levy upon the property of the defendant (s)and to sell .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of WAYPOINT BANK, 17 WEST HIGH STREET, CARLISLE, PA 17013 - ANy AND ALL FUNDS
FOUND IN THE FOLLOWING CHECICING AND SAVINGS ACCOUNTS IN THE NAME OF
WILLIAM WITKOSICI IN THE POSSESSION OF WAYPOINT BANK, AS GARNISHEE, AS
ADMITTED BY WAYPOINT BANK, IN ITS ANSWERS TO INTERROGATORIES TO
GARNISHEE _ CHECKING ACCOUNT NUMBER 1000012699, HAVING AN APPROXIMATE
BALANCE OF $1,562.55 - SAVINGS ACCOUNT NUMBER 101082551, HAVING AN
APPROXIMATE BALANCE OF $3,466.10
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the oss
of anyone other than a named garnishee ou are ' · . P ession
garnishee and is enjoined as above state~,y drrected to notify him/her that he/she has been added as a
Amount Due $5,028.65 L.L.
Interest FROM 8/28/2002
Atty's Corem %
Due Prothy $1.00
Atty Paid $54.50
Other Costs
Plaintiff Paid
Date: MARCH 6, 2003
(Seal)
REQUESTING PARTY:
Name GEOFFREy S. SHUFF, ESQUIRE
Address: 2109 MARKET STREET
CAMP HILL, PA 17011
Attorney for: PLAINTIFF
Telephone: 717-761-1881
Supreme Court ID No. 24848
CURTIS R. LONG
;;' DeputY-