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HomeMy WebLinkAbout13-6612 } WRIT OF EXECUTION (MONEY JUDGMENTS) & ATTACHMENT - P.R.C.P. 3101 TO 3149 c eta Ryan T. Hunter Writ No. 2013 -CV- 07268 -NT Z� . - f - , Gn _ C) VS. Amount Due: $4,518.00 �.<.. cA' Michael Quick X_CD co WRIT OF EXECUTION NOTICE TWs paper is a writ of Execution. It has been issued because there is a iud meet against you. It macause vour property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lay«Ter can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. The law provides that certain property cannot be taken. Such property is said to be exempt. There is a debtor's exemption of $300.00. There are other exemptions, which may be applicable to you. Attached is a summary of some of the major exemptions. You may have other exemptions or other rights. MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300.00 Statutory Exemption 2. Bibles, School Books, Sewing Machines, Uniforms and Equipment 3. Most Wages and Unemployment Compensation 4. Social Security Benefits 5. Certain Retirement Funds and Accounts 6. Certain Veteran and Armed Forces Benefits 7. Certain Insurance Proceeds 8. Such other Exemptions as may be provided by law If you have an exemption. you should do the following promptly: (1) Fill out the attached claim form and demand for a prompt hearing. (2) Deliver the form or mail it to the Sheriff's Office at the address noted. You should come to court ready to enlain your exemption. If you do not come to court and prove your exemption, you may lose some of your property. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH 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. DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17101 (717) 232 -7536 �W'szr) �� WRIT OF EXECUTION (MONEY JUDGMENTS) & ATTACHMENT P.R.C.P, 3101 TO 3149 COMMONWEALTH OF PENNSYLVANIA, COUNTY OF DAUPHIN CIVIL ACTION — LAW Ryan T. Hunter Writ No. 2013 -CV- 07268 -NT 568 Race Street Harrisburg, PA 17104 Amount Due: $4,518.00 VS. COSTS Plaintiff Paid: $66.00 Michael Quick Sheriffs Costs: $93.64 336 5th Street This Writ: $37.75 New Cumberland, PA 17070 TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs against Michael Quick, Defendant(s). (1) You are directed to levy upon the property of the defendant(s) and to sell his, her (or their) interest therein. (2) You are also directed to attach the property of the defendant not levied upon in the possession of as Garnishee(s) as follows: ANY AND ALL PERSONAL PROPERTY. NOTE OF RESIDENCE: MR. QUICK RESIDES ON SECOND FLOOR FACING RENO ON CORNER OF 5TH AND RENO. and to notify the Garnishee(s) that: (a) an attachment has been issued; (b) except as provided in paragraph (c); the Garnishee is enjoined from paying any debt to or for the account of the Defendant and from delivering any property of the Defendant or otherwise disposing thereof, (c) the attachment shall not include any funds in an account of the Defendant with a bank or other financial institution (i) in which funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or Federal law, or (i) the first $10,000 of each account of the Defendant with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt execution, levy or attachment under Pennsylvania or Federal law. (ii) each account of the Defendant with a bank or other financial institution in which funds on deposit exceed $10,000 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or Federal law. (iii) any funds in an account of the Defendant with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the Defendant's general exemption provided in 42 Pa.C.S. Sect. 8123. (3) if property of Defendant not levied upon and subject to attachment is found in the possession of anyone other than a named Garnishee, you are directed to notify such other person that he or she has been added as a Garnishee and is enjoined as above stated. WITNESS, the Honorable Todd A. Hoover, President Judge of the Court of Common Pleas of Dauphin County at the City of Harrisburg, Friday, November 01, 2013. Stephen E. Farina, Prothonotary By: Deputy Requesting Paid Ryan T. Hunter, Plaintiff 568 Race Street Harrisburg, PA 17104 (202) 550 -0020 or (202) 531 -2120 AND NOW, Writ Re- Issued Stephen E. Farina, Prothonotary ou tiv of Cumber, RONNY R.ANDERSON :► f ,. RICHARD W.STEWART Sheriff �,� r' Solicitor JODY S.SMITH `R .. -a f•., Chief Deputy ; OFFICE OF THE SHERIFF m rrn m ,::-_ One Courthouse Square, Room 303 _r� Carlisle, Pennsylvania 17013 December 13, 2013 c_, Ryan T. Hunter vs Michael Quick Dauphin County Writ No. 201 3-CV-07268-NT Cumberland Co. Writ No. 13- 612 Property Claim Determination To Whom It May Concern: Reference is made to Property Claim dated December 5, 2013, entered by Ashley R. Fetsko, Dauphin CountyWrit of Execution No. 2013-CV-07268-NT (Cumberland County Writ No. 13-6612), Ryan T. Hunter vs Michael Quick. Ronny R. Anderson, Sheriff, has determined that the claimant, Ahsley R. Fetsko, in the above mentioned property claim, is the owner of the property set forth in the claim. So An`rs: KVet• R1 R. Anderson, Sheriff BY /,f_. .a. cc Ashley R. Fetsko, Claimant Michael Quick, Defendant Ryan T. Hunter, Plaintiff NOTICE OF PROPERTY CLAIM Ryan T. Hunger In the Court of Common Pleas Dauphin County, Pennsylvania VS Michael Quick No. 2013-CV-07268-NT Civil Term Writ of Execution (Cumberland County Writ# 13-6612) TO THE DEFENDANT AND ALL OTHER PARTIES IN INTEREST: You are hereby notified that a property claim, a copy of which is attached hereto has been filed by Ashley R. Fetsko, claiming property listed therein. Unless an appraisal of the property is requested within(10) days from the date of this notice, the Sheriff without making an appraisal will accept the value of the property set forth in the claim. .• Cie Faa, Date 12'05//3 �► S f of Cumberland County BY iA■ /! Cc Ashley R. Fetsko, Claimant Michael Quick, Defendant Ryan T. Hunter, Plaintiff PROPERTY CLAIM In the Court of Common Pleas of Cumberland County,Pennsylvania Writ No.c9sG\ _('v - 0-1&(D 8 7 VS TO THE SHERIFF OF CUMBERLAND COUNTY,PENNSYLVANIA The property listed below and levied upon in this case is not the property of the defendant,but is the property of the undersigned. A list of the claimed property and the values thereof are: LIST OF PROPERTY VALUE 1 1�JCDCIO■P_`(- AOvb--QQ_ L �j(c \M � �- a� SO.V'r\ �{ o c 9 % 0\ THE CLAIMANT OBTAINED TITLE TO THE PROPERTY AS FOLLOWS: I it --e(4_.) Y'') - • n 0 h au-e Date Claimant gia 1111 tv State of Pennsylvania: �! County of Cumberland R5\c \-e H H \`. {'YX. being duly sworn according to law,deposes and says that the above list in the p perry claim are correct and true.. IFTAI Sworn and subscri -• let he nrP m- +' day of ��i ' AA,,�a ,/. �-� 's � Claimant 1 rf ' ' . NOTARY PUBLIC Ca s e o, mberland County My Commission Expires April 4,2017 1 CD\c,9s- -T LS' -C%\-,nA $ ac) b ■ coc_Ve\i e 06 -k-c}-\t , V\QE)\e' s a , ,\(Yl C)._\(\c,,_ 5 a 4 3,0 0 YY-) ``"- L �-e c_or 1) 7 \ce 1a5 - c, 6 &.vip._ -4---Es ;)- -(2.- \ x 4 3(.. 0 4to0 '0 Yj C CQD COUA__)) Y\--t..... ZS a " S- 330 £101 JditJ S f !2,, ,x„... .4,,.f _ R lir 11 r i o'.r i `,4,, 4; _j. /`.I1$$' ,-;0q, 4s. , ! ..x7 , .,A;k L, la PP)O1 °'s�3 23 AEA 9: 2 ! ru ` ERLNHJ PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RYAN T. HUNTER : No. 2013-CV-07268-NT : Civil Action- Law vs. : CUMBERLAND COUNTY t : WRIT# 13-6612 MICHAEL QUICK TO THE PROTHONOTARY: Enter objection to the sheriff's determination of ownership of the property of Ashley Fetsko. Date: December 23, 2013 HUNTER, OBJECTOR (Plaintiff) 1 12/22/13 231 Pa.Code Rule 3206.Sheriffs determination in faeor of claimant;objections;amount of bond;delheryof property,interpleader. pijose Dania Rule 3206. Sheriff's determination in favor of claimant; objections; amount of bond; delivery of property; interpleader. (a) If the sheriff determines that the claimant is prima facie the owner of the property in whole or in part, the sheriff shall file in the prothonotary's office the claim, the determination of ownership including the valuation of the property, and shall send by ordinary mail copies of the determination and valuation to the claimant, the plaintig the defendant, and all other execution creditors and claimaints of the property. (b) Any execution creditor or defendant may, within ten days after the date of mailing of the copy of the determination and valuation, file with the prothonotary, and with the sheriff an objection to the determination substantially in the form provided by Rule 3260. The sheriff shall send by ordinary mail a copy of the objection to all other parties. Upon the filing of the objection an interpleader shall be at issue in which the claimant shall be the plaintiff and all other parties in interest shall be defendants. The only pleading shall be the claim, all averments of which shall be deemed to be denied. (c) If no objection is filed the levy on the claimed property shall be deemed abandoned. (d) Upon abandonment of the levy, the sheriff shall return the claimed property to the person from whom it was taken. If the claimed property was found in the possession of a person other than the claimant, the sheriff shall, before returning it, give forty-eight hours notice to the claimant of the abandonment of the levy and the intention to return the property to a person other than the claimant. (e) If an execution creditor or a defendant files an objection, the claimed property shall remain subject to the levy unless the claimant within ten days from the filing of the objection files a bond as provided in Rules 3207(d)and 3208, in which event the sheriff shall withdraw all levies on the claimed property and deliver the same as provided in Rule 3207(d). Source The provisions of this Rule 3206 adopted August 30, 1965, effective March 1, 1966; amended April 8, 1997, effective July 1, 1997, 27 Pa.B. 2045; amended April 12, 1999, effective July 1, 1999, 29 Pa.B. 2281. Immediately preceding text appears at serial pages (243939)to (243940). No part of the information on this site may be reproduced far profit or sold for profit. This material has been drawn directly from the official Pennsylvania Code full text database. Due to the limitations ofFITML or differences in display capabilities of different browsers,this version may ditEr slightly from the official printed version. wom.pacode.comisecure%2Fdata/231/chapter3oo0/s32o6.html 1/1 231 Pa. Code Rule 3260. Objection to sheriff's determination. Page 1 of 1 he PcT anaylvitnis le:d; Rule 3260. Objection to sheriff's determination. (Caption] TO THE PROTHONOTARY: Enter objection to the sheriffs determination of ownership of the property: Date: (Objector,Attorney,or Agent) Official Note Adopted August 30, 1965, effective March 1, 1966. No part of the information on this site may be reproduced for profit or sold for profit. This material has been drawn directly from the official Pennsylvania Code full text database.Due to the limitations of t 1TML or differences in display capabilities of different browsers,this version may differ slightly from the official printed version. http://www.pacode.com/secure/data/231/chapter1000/s3260.html 12/22/2013 • r fLraitlf.• _ x 11: 27 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RYAN HUNTER • No. 2013-CV-07268-NT Plaintiff • v. • CUMBERLAND COUNTY • WRIT No.: 13-6612 MICHAEL QUICK • Defendant • CIVIL ACTION PETITION TO DETERMINE TITLE AND PROVIDE FOR DISPOSITION OF PROPERTY CLAIMED UNDER 231 PA CODE RULE NO 3211 AND NOW, this /f th day of February, 2014, comes Ryan Hunter,by and through his attorney, Kathryn Nonas-Hunter, and files this Petition and avers as follows: 1. Plaintiff Ryan Hunter is an adult individual who resides at 568 Race Street, Harrisburg, PA 17104. 2. Defendant Michael Quick is an adult individual who resides at 336 5th Street, 2nd floor, New Cumberland, 17070. 3. Ashley R. Fetsko (hereinafter"Claimant")is an adult individual who resides at 336 5th Street, 2nd floor,New Cumberland, 17070, with Defendant, as his paramour. 4. Claimant filed a Property Claim, claiming property listed therein in the above- referenced writ on December 5, 2013. 5. On December 13, 2013, the Sheriffs office determined that Claimant was the prima facie owner of the property listed in the claim. 6. Plaintiff filed an objection to the Sheriff's determination on December 23, 2013. 7. The above-referenced action stemmed out of Defendant, who leased real property from Plaintiff, without Plaintiff's consent and in violation of the lease,moving Claimant and her dog, into Plaintiff's real property. 8. Although Defendant had repeatedly violated the lease in other regards, Plaintiff, in an effort to amicably resolve the dispute, offered settlement,whereby Claimant would become a tenant of the real property. 9. Both Defendant and Claimant refused to sign a new lease, thereby refusing Plaintiff's proposed settlement. 10. Plaintiff brought a landlord/tenant action at the Magesterial District Justice, claiming, inter alia, Defendant violated the lease by moving his girlfriend, Claimant, and her dog into the real property without his permission or consent. 11. The Magesterial District Justice found in favor of Plaintiff, giving immediate possession of the real property back to Plaintiff and awarding damages in the amount of $5,070.00 together with costs of suit and interest. 12. Claimant now seeks to claim the property levied as her own in an effort to reduce likelihood that Defendant will make any payment on the judgment. 13. Claimant has filed the Property Claim without any evidence of ownership of the property listed. 14. The Property Claim, which was sworn to in the presence of a notary, contains false information. Specifically, Claimant stated "...since he had lived alone only a few months..." Defendant's lease was executed on March 4, 2012. Defendant lived alone for over a year before Claimant began living with him. A true copy of Defendant's lease is attached hereto as Exhibit A. 15. It is believed and, therefore, averred that Claimant has knowingly made this false statement under oath and the remainder of her statement, including her Property Claim, should not be taken as true or correct. 16. Justice will not be achieved until the Court determines the true owner of the property as Defendant and authorizes the property to be levied and sold at a Sherriff's sale. WHEREFORE, Plaintiffs respectfully request this Honorable Court determine title to the claimed property and provide for the disposition of the property. Plaintiff further respectfully requests the Court award Plaintiff the costs of the filing of this Petition, attorney's fees and interest. Respectfully Submitted, Aegr7 Kathryn Nonas-Hunter, Esquire Sup. Ct. I.D. #308437 Attorney for Plaintiff HOBBS&HUNTER, LLC 257 East Market Street York, Pennsylvania 17403 (717) 793-2398 EXHIBIT "A" RESIDENTIAL HOUSING LEASE AGREEMENT THIS HOUSE LEASE AGREEMENT (hereinafter "Agreement") is entered into, this ,2012 by and between: The Lessor: Ryan Hunter and Kathryn Nonas-Hunter, (Hereinafter "Landlord") and the Lessee: ch / QuicK (Hereinafter "Tenants") In regards to the Property: --� 5-7-0 Ka ce S'1 p„, (Hereinafter "Residence") The Landlord and Tenant(s) do hereby agree to abide by the terms set out in this Agreement. The terms of this Agreement are as follows: THE RESIDENCE In consideration of the rent payment to be paid by Tenant(s) and the other covenants and agreements herein contained,the Landlord agrees to rent to Tenant(s)the Residence. Tenant(s) shall use the Residence only for residential purposes. Tenant(s) shall not use or allow the use of the Residence in any way that interferes with other Tenant(s) use and enjoyment of the Residence or neighboring property. Tenant(s) shall not use the Residence for any illegal or improper use. Additionally, the Tenant(s) shall comply with all Zoning Ordinances, Protective Covenants and Deed Restrictions. The Tenant(s) agrees that the Residence shall be a non-smoking environment. The Tenant(s) agrees shall be liable for any damage caused as a result of smoking. The Tenant(s)agrees that no more than two (2)residents are allowed to occupy the Residence. Visitors who stay in the Residence longer than seven(7) days are considered occupants and Tenants will be in violation of the Lease. The Residence includes 1 bedroom; 1 bathroom. MQ Parking is not available with the Residence. 1 v M v/ A,,.- I. PAYMENT SCHEDULE AND DETAILS '�4'y 2r�j V1 The Tenant(s)agrees to pay a Monthly rate of Nine Hundred Orly dollars($989 USD). Payment shall be made in the form of Check,postmarked on or before first of each month or personally handed to Lessor during the entire length of this Agreement. Payments shall be made to Ryan T. Hunter at 568 Race Street, Harrisburg PA, 17104, or at such other place as the Landlord and Tenant(s) agree upon. Should a Tenant(s)'s payment be returned for insufficient funds, the Tenant(s) shall be liable to the Landlord for sixty five dollars($65) as enalty. lk 9i N 4 Should a Tenant(s)'s payment of rent be e p arked after the first of the month c or tendered directly to Lessor after the4 day of the month, the Tenant(s) shall be liable �' ; _ to the Landlord for $20 per day, with reoccurring charges every day until the rent is ' actually tendered. t\ ``, The Tenant(s)agrees to deliver a Security Deposit to the Landlord in the amount of Nine (" Hundre-diglaty dollars($2)16)(hereinafter "Deposit") at the execution of this Agreement. The Deposit will be returned to the Tenant(s) at the end of this Agreement or within 30 days, less an itemized list of deductions for incidentals or violations of the Lease, pursuant to Pennsylvania law. The Tenant(s) is not entitled to interest on the Deposit. The Deposit may not be used by either party for any payment due under this Agreement. The parties acknowledge that the Landlord will be permitted to deduct from the Deposit any amounts for reasonable cleaning and repair of damages to the Residence when the agreement is terminated. Ordinary wear and tear is excepted. II. LENGTH OF AGREEMENT This Agreement shall egin [Iki��.h 1S I v7O/o2 and will remain in effect until !'YirrCh I S D.oi' unless renewed or extended pursuant to the terms herein and shall be based on a monthly term. • / / III. TERMINATION After expiration of the leasing period, this agreement is automatically renewed from month to month,but may be terminated by either party giving to the other a sixty (60) day written notice of intention to terminate. The premises shall be considered vacated only after all areas including storage areas are clear of all Tenant(s) belongings, and keys and other property furnished for Tenant(s) use are returned to Landlord. Should the Tenant(s) hold over beyond the termination date or fail to vacate all possessions on or before the termination date, Tenant(s) shall be liable for additional rent and damages, which may include damages due to Landlord's loss rent from new Lessees, court costs, interest and reasonable attorneys fees. IV. DEFAULT If Tenant(s) fails to fulfill or perform any obligation under this Agreement, Tenant(s) shall be in default of this Lease. Tenant(s) shall receive 4 days' notice by Landlord who shall provide Tenant(s) with a Notice to Quit demanding Tenant(s)cure the default(i.e. provide payment of rent). In the event Tenant(s) does not cure a default, Landlord may at Landlord's option cure such default and the cost of the cure will be added to Tenant(s) financial obligations under this lease, or Landlord will be permitted to declare Tenant(s) in default of the Agreement and Landlord re-enter the premises and re-take possession of the Residence, in which case, Tenant(s) waive any notice of termination or notice to quit. After default, Tenant(s)may be held liable for the balance of the unpaid rent under this Agreement if Landlord cannot re-let the Residence during the remaining time of Agreement. In the event a Default occurs and Tenant(s) is/are insolvent and unable to pay any amount due,the undersigned Co-signer shall serve as a guarantor. All liabilities shall shift to the Co-signer as though they were the Tenant(s) and all financial responsibilities and cost under the Agreement will be due in full, immediately to Landlord from Co- signer. V. TENANT(s) RESPONSIBILITIES The Tenant(s) agrees to accept responsibility for the following: The Tenant(s) shall comply with all obligations imposed upon Tenant(s) by applicable provisions of building, housing, and health codes; maintain the Residence in good condition during the entire length of this Agreement and shall neither cause nor allow any abuse of the facilities therein. The Tenant(s) shall inform the Landlord of any condition that may cause or has caused damage to the Residence. If the Residence, or any part of the Residence, is partially damaged by fire or other casualty not due to the negligence or willful act of the Tenant(s) or an agent of the Tenant(s)or an act of God or natural disaster, the Residence will be repaired by the Landlord as soon as possible and there will be an abatement of rent corresponding with the time during which the Residence was untreatable. However, • • Landlord will not be responsible for ANY act of God or natural disaster. Should a flooding of the premises or damage due to a natural disaster occur, Landlord will make efforts to repair the Residence to inhabitable standards within a reasonable amount of time. In exchange, Tenant agrees to grant Landlord a grace period to fix any outstanding damage incurred as a result of the natural disaster or flooding. If Landlord is unable to complete required repairs within that time frame, either party voluntarily claim no-fault termination of the Agreement by thirty days written notice to the other party. Upon the termination or expiration of this Agreement the Tenant(s) shall redeliver the property, amenities, furniture, appliances and any other applicable aspects of the Residence, in as good condition as at the commencement of the Agreement or as may be agreed to in writing by both parties. Reasonable wear and tear from use and obsolescence to the Residence shall be accepted. Furthermore, the Landlord retains a Landlords Lien on all personal property placed upon the premises to secure the payment of rent and any damages to the Residence after termination of the Agreement. Tenant(s) shall make Residence available at Landlord's request. Landlord will give reasonable or as much notice as possible prior to entry. VI. TRANSFER and SUBLETTING Tenant(s) will not transfer, sublet, or assign the Lease without first obtaining written consent of the Landlord. Before transferring, subletting or assignment of the Lease, Tenant(s) must first: 1) make a written request to Landlord; 2) submit on Landlord written application, information on the new Tenant(s); 3)pay a processing fee of $350.00; AND 4) pay Landlord two (2) months rent as additional/liquidated damages, which may be refundable to Tenant(s) at the end of the Agreement, if there are no additional damages. VII. PET(S) Should the Tenant(s) desire to keep a pet(s) on the said premises, Tenant(s) will first get approval from Landlord, at such time providing information regarding the species, pedigree and number of pets. The Tenant(s) also agrees to pay Landlord a nonrefundable "Pet Deposit" in the amount of three hundred fifty dollars ($350)per pet. Said "Pet Deposit" is due at the signing of the lease. Tenant(s) agrees to immediately pay for any injury, damage, loss, or expense caused by the pet(s) and to indemnify Landlord from any damages or injury caused to any person who seeks compensation from Landlord. In this regard, it is expressly understood that at no time shall the Tenant(s) apply any part of the "Pet Deposit" towards such amounts due, but rather, the Tenant shall make restitution immediately and separately from the "Pet Deposit." It is further understood that such restitution shall be made over and above any rent paid. Should the Tenant(s) fail to comply with any part of this portion of the lease, the Landlord reserves the right to revoke permission to keep the pet. In such event,the Tenant(s) agrees to permanently remove the pet(s) from the premises within 48 hours of receiving written notice thereof. Failure to comply with same shall be grounds for immediate termination of the lease and forcible eviction. VIII. LEAD-BASED PAINT Tenant(s) acknowledge Landlord has furnished Tenant(s)with information regarding lead-based paint. To the best of his knowledge, information and belief, Landlord states there is not lead-based paint and/or lead-based paint hazards in the housing. Tenant(s) have received the pamphlet Protect Your Family From Lead in Your Home. Tenant(s) waive the opportunity to conduct a risk assessment or inspection for the presence of lead- based paint and/or lead-based paint hazards. Tenant(s) expressly release Landlord from any and all liability from injuries caused from lead-based and/or lead-based paint hazards on said premises. IX. UTILITIES: Tenants are not responsible for any utilities. Free Cable and Internet. Tcnant(s)(s) understand and agree that this Lease agreement and all of its provisions may be enforced against all Tenant(s)(s)who sign it. Landlord may inconsistently and selectively enforce any part or the entire Lease agreement against any Tenant(s)(s) individually or against any combination of Tenant(s)(s) together. /t, /sl l c 11 Signed and agreed to this Day of 2012 intending to be legally } /•;bo nd: Tenant -� l ",< Landlord / 1 �i Co-Sign/Parent/Guardian • IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY,PENNSYLVANIA RYAN HUNTER No. 2013-CV-07268-NT Plaintiff . v. : CUMBERLAND COUNTY • . WRIT No.: 13-6612 MICHAEL QUICK . Defendant : CIVIL ACTION VERIFICATION I, RYAN HUNTER, do hereby verify that the facts set forth in the above foregoing pleading are true and correct to the best of my personal knowledge or information and belief, and that any false statements herein are made subject to the penalties of Section 4904 of the Crimes Code(18 Pa. C.S. Sec. 4904)relating to unsworn falsification to authorities. Date: /7- �1 HUNTER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RYAN HUNTER No. 2013-CV-07268-NT • Plaintiff v. : CUMBERLAND COUNTY WRIT No.: 13-6612 • MICHAEL QUICK Defendant • CIVIL ACTION CERTIFICATE OF SERVICE I, Kathryn Nonas-Hunter, Esquire,being duly sworn according to law, doth depose and say that I served a copy of the "Petition to Determine Title and Provide for Disposition of Property Claimed Under 231 PA Code Rule No. 3211" to the Person named below,by restricted/certified mail, as follows: Michael Quick Ashley Fetsko 336 5a' Street 336 5th Street New Cumberland, PA 17070 New Cumberland, PA 17070 Respectfully submitted, Date: c9//D II g Kathryn nas-Hunter, Esquire Sup. Ct. I.D. #308437 Attorney for Plaintiff HOBBS &HUNTER, LLC 257 East Market Street York, Pennsylvania 17403 (717) 793-2398 RYAN HUNTER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. : CIVIL ACTION — LAW : NO. 13-6612 MICHAEL QUICK, Defendant IN RE: PETITION TO DETERMINE TITLE AND PROVIDE FOR DISPOSITION OF PROPERTY CLAIMED UNDER 231 PA. CODE RULE NO. 3211 ORDER AND NOW, this 2 (0 day of February, 2014, a hearing on the above-captioned Petition is set for Wednesday, March 12, 2014, at 10:00 a.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. Nonas-Hunter, Esquire For the Plaintiff 14i hael Quick Defendant .1<hley Fetsko Claimant :rim itqrk BY THE COURT, 4 Kevin Hess, P.J. C1=, kLO ti IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • RYAN HUNTER No. 2013 -CV- 07268 -NT Plaintiff v. CUMBERLAND COUNTY WRIT No.: 13 -6612 MICHAEL QUICK Defendant CIVIL ACTION MOTION TO REQUEST CONTINUANCE TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, TO WIT, this day of March, 2014, comes the Plaintiff, Ryan Hunter, by and through his attorney, Kathryn Nonas- Hunter, Esquire, who respectfully represents: 1. Ryan Hunter, is the Plaintiff in the above - referenced case. 2. Plaintiff is scheduled to appear at a hearing in regards to the Petition to Determine Title and Provide for Disposition of Property Claimed Under 231 PA Code Rule No. 3211 on March 12, 2014 at 10:00 A.M. before the Honorable Kevin A. Hess. 3. Counsel for the Plaintiff is requesting a continuance to the March 12, 2014 Court appearance because she has a conflict in her schedule. She is scheduled for a Pre -Trial Conference for Custody at the York County Judicial Center before the Honorable Andrea Marceca Strong on March 12, 2014 at 10:30 A.M. 4. Counsel requests the hearing be rescheduled. WHEREFORE, the Petitioner respectfully requests that this Honorable Court continue the hearing in regards to the Petition to Determine Title and Provide for Disposition of Property (1) Claimed Under 231 PA Code Rule No. 3211. Respectfully submitted, Kathryn Nonas-Hunter, Esquire Sup. Ct. I.D. #308437 Attorney for Plaintiff HOBBS & HUNTER, LLC 257 East Market Street York, Pennsylvania 17403 (717) 793-2398 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RYAN HUNTER No. 2013 -CV- 07268 -NT Plaintiff v. CUMBERLAND COUNTY WRIT No.: 13 -6612 MICHAEL QUICK Defendant CIVIL ACTION CERTIFICATE OF SERVICE I, Kathryn Nonas- Hunter, Esquire, being duly sworn according to law, doth depose and say that I served a copy of Plaintiff's "Motion To Request Continuance" to the Person named below, as follows: Michael Quick 336 5th Street New Cumberland, PA 17070 Ashley Fetsko 336 5th Street New Cumberland, PA 17070 3/Slig 0/004 - tf/Lt&i Date athryn onas-Hunter, Esquire Sup. Ct. I.D. #308437 Attorney for Plaintiff HOBBS & HUNTER, LLC 257 East Market Street York, Pennsylvania 17403 (717) 793 -2398 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RYAN HUNTER No. 2013-CV-07268-NT Plaintiff v. CUMBERLAND COUNTY WRIT No.: 13-6612 MICHAEL QUICK Defendant CIVIL ACTION ORDER AND NOW, TO WIT, this /A '6( day of 117 d4,61..) , 2014, upon consideration of the within "Motion To Request Continuance", of the above-named Plaintiff, by his attorney, Kathryn Nonas-Hunter, Esquire, is hereby Ordered that Plaintiff's request is granted and Hearing in regards to the Petition to Determine Title and Provide for Disposition of Property Claimed Under 231 PA. Code Rule No. 3211 is rescheduled for the 44,t day of 6tiaj .24)- 2014 at // /UV A.M. /-1)1c2r BY THE COURT: RYAN HUNTER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. : CIVIL ACTION — LAW : NO. 13-6612 MICHAEL QUICK, Defendant IN RE: OBJECTION TO SHERIFF'S DETERMINATION ORDER AND NOW, this day of April, 2014, after hearing, the Objection of the plaintiff to the Sheriff s Determination of ownership of the property of Ashley Fetsko is DISMISSED and, with the exception of one Xbox 360 and one Brinkman grill, the determination of the Sheriff is AFFIRMED. The Xbox and grill shall remain subject to the levy. In all other regards, the Petition of the plaintiff to "Determine Title and Provide for Disposition of Property" is DISMISSED. ,Xatluyn Nonas-Hunter, Esquire For the Plaintiff 7Michael Quick Defendant Fetsko Claimant Sharon Lantz Office of Cumberland County Sheriff :rim a .ec 4iy ccc BY THE COURT, :70 i v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RYAN HUNTER No. 2013 -CV -07268 -NT Plaintiff v. CUMBERLAND COUNTY WRIT No.: 13-6612 MICHAEL QUICK Defendant : CIVIL ACTION at\coie6 INTERROGATORIES IN AID OF EXECUTION TO: MICHAEL QUICK ; -- --•,�.: • -� V 1 Your are hereby required to answer the following interrogatories under oath within 30 days pursuant to Rules No. 3117 of the Pennsylvania Rules of Civil Procedure and return them to the undersigned counsel for Plaintiff. These interrogatories shall be deemed continuing so as to require further and additional answers if you obtain any additional or subsequent information. No answer is to be left blank. 1. Please describe specifically all real estate owned by you in the Commonwealth of Pennsylvania, and .state the liens against each parcel of real estate with the present principal balance owing on each lien and the payee to whom the obligation is owed by name and address. 2. Identify each bank account held by you by the name of the bank, the address and the account number together with the present balance in each account. 3. List all vehicles and equipment owned by you and give the following specific information as to each. a. Model, year and make. 1104 b. Serial number or vehicle identification number. c. Registration plate number. II Ov'\ e - 600e d. Usual location of vehicle/equipment during the day. jj y ,, e. Usual location of vehicle/equipment during the evening. ( J A- 'i f. Information relating to any encumbrance on the vehicle including the name and address of the encumbrance holder and the amount of the encumbrance at the present time. 116p4,. g. Present value of each vehicle or piece of equipment. n4 W. 4. Please list any stocks, bonds, mutual funds and money market accounts held or owned by you by account name and number and balance in the account or number of shares in the account. r1M� 5. List all certificates of deposit held by you by name of institution where the deposit is located and the number of the certificate and the amount thereof. Yl iN t 6. Attach a copy of your Federal Income Tax Return for 2013 together with all scheduled thereto to this interrogatory. 7. List all of your furniture and other items of tangible property and the approximate value of each item. wC- 8. Have you transferred any property sincethe date this action was instituted to any other person? If so, identify the property specifically together with the name and address of the transferee and the amount, if any, received as consideration for each transfer. wt 9. State the amount of cash you have on hand at this time and at what location the cash is held. (I - t Date: Kathryn Norias-Hunter, Esq ire Sup. Ct. T.D. #308437 Attorney for Plaintiff HOBBS & HUNTER, LLC 257 East Market Street York, Pennsylvania 17403 (717) 793-2398 COMMONWEALTH OF PENNSYLVANIA COUNTY OF &ouvk (trlav) : ss Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Michael Quick, who being duly sworn according to law, deposes and says that the facts set forth in the foregoing Interrogatories are true and correct to the best of his knowledge, information and believe. SWORN AND SpBSCRIBED to before me this 3 day of krb,1 , 2014 Notary Public MICHAEL QUICK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RYAN HUNTER No. 2013 -CV -07268 -NT Plaintiff v. CUMBERLAND COUNTY WRIT No.: 13-6612 MICHAEL QUICK Defendant CIVIL ACTION CERTIFICATE OF SERVICE I, KATHRYN NONAS-HUNTER, ESQUIRE, attorney for the Plaintiff, hereby certify that I have on the day of April, 2014, served a copy of the "INTERROGATORIES IN AID OF EXECUTION" by personal hand delivery, upon the persons and to the addresses indicated below: MICHAEL QUICK 336 5th Street New Cumberland, PA 17070 KATHR NONAS-HUNTER, SQUIRE 1(L CLIMBERL A1't tJ `'Q COUPS i`,' IN THE COURT OF COMMON l kWd ,CUMBERLAND COUNTY, PENNSYLVANIA RYAN HUNTER No. 2013 -CV -07268 -NT Plaintiff v. CUMBERLAND COUNTY WRIT No.: 13-6612 MICHAEL QUICK Defendant CIVIL ACTION MOTION TO COMPEL AND NOW, this 22nd day of May, 2014, comes Ryan Hunter, by and through his attorney, Kathryn Nonas-Hunter, and files this Petition and avers as follows: 1. Plaintiff Ryan Hunter is an adult individual who resides at 568 Race Street, Harrisburg, PA 17104. 2. Defendant Michael Quick is an adult individual who resides at 336 5th Street, 2nd floor, New Cumberland, 17070. 3. On April 1, 2014, Plaintiffs counsel served Interrogatories in Aid of Execution upon Defendant by personal hand -delivery. 4. Pursuant to the Pennsylvania Rules of Civil Procedure, the Defendant was required to file responses to the discovery requests within thirty (30) days of service. Accordingly, responses to the outstanding discovery were due on May 1, 2014. 5. On May 6, 2014 Plaintiff's counsel left a voicemail message for Defendant requesting status of the interrogatories. The message went unanswered. 7. As of the date of preparing this Motion to Compel, the Defendant has failed to provide any discovery responses to the repeated discovery requests. 8. The information sought in Plaintiffs discovery requests is relevant and material to collecting on Plaintiff's judgment. 9. Defendant has not filed a formal objection to the discovery requests. WHEREFORE, Plaintiff requests the Court to enter an order compelling Defendant to provide full and complete responses in writing to the discovery requests previously presented within the next twenty (20) days, and pay $300 towards Plaintiffs attorney's fees incurred to prepare and present this Motion. Respectfully Submitted, •.9-7 .,-2-1- G�� Kathryn Nonas-Hunter, Esquire Sup. Ct. I.D. #308437 Attorney for Plaintiff HOBBS & HUNTER, LLC 257 East Market Street York, Pennsylvania 17403 - (717) 793-2398 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RYAN HUNTER No. 2013 -CV -07268 -NT Plaintiff v. CUMBERLAND COUNTY WRIT No.: 13-6612 MICHAEL QUICK Defendant CIVIL ACTION CERTIFICATE OF SERVICE I, Kathryn Nonas-Hunter, Esquire, being duly sworn according to law, doth depose and say that I served a copy of the "Motion to Compel" to the Person named below, by restricted/certified mail, as follows: Date: Michael Quick 336 5th Street New Cumberland, PA 17070 Respectfully submitted, 9Y,7,11— Weil&) Kathryn Nonas-Hunter, Esquire Sup. Ct. I.D. #308437 Attorney for Plaintiff HOBBS & HUNTER, LLC 257 East Market Street York, Pennsylvania 17403 (717) 793-2398 RYAN HUNTER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION — LAW MICHAEL QUICK, Defendant : NO. 13-6612 CIVIL TERM IN RE: PLAINTIFF'S MOTION TO COMPEL ORDER OF COURT AND NOW, this 30th day of May, 2014, upon consideration of Plaintiff s Motion to Compel, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. IZthryn Nonas-Hunter, Esq. HOBBS & HUNTER, LLC 257 East Market Street York, PA 17402 Attorney for Plaintiff .ichael Quick 336 Fifth Street New Cumberland, PA 17070 Defendant, pro Se :rc CaD leS 02Z1. SPO/ri BY THE COURT, Christylee L. Peck, J. it._ ,'i;() HOSO Tit!, 2C ' Ju . P11 1: C3 �t', ri COUr7 'r' PENN Y�VAI IA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RYAN HUNTER No. 2013-CV-07268-NT Plaintiff • V. CUMBERLAND COUNTY • WRIT No.: 13-6612 MICHAEL QUICK • Defendant : CIVIL ACTION PETITION TO MAKE RULE ABSOLUTE AND NOW, this day of 01 , 2014, comes Ryan Hunter, by and through his attorney, Kathryn Nonas-Hunter, and files this Petition and avers as follows: 1. Plaintiff Ryan Hunter is an adult individual who resides at 568 Race Street, Harrisburg, PA 17104. 2. Defendant Michael Quick is an adult individual who resides at 336 5th Street, 2nd floor, New Cumberland, 17070. 3. On April 1, 2014, Plaintiffs counsel served Interrogatories in Aid of Execution upon Defendant by personal hand-delivery. 4. Pursuant to the Pennsylvania Rules of Civil Procedure, the Defendant was required to file responses to the discovery requests within thirty(30) days of service. Accordingly, responses to the outstanding discovery were due on May 1, 2014. 5. On May 30, 2014, a Rule was issued upon Defendant Michael Quick to show cause within twenty(20) days why the relief requested should not be granted . 6. Defendant has failed to respond within the allotted time or file an objection. 7. The Motion to Compel and the request for Three Hundred Dollars ($300) in attorney's fees for failure to respond should be granted. WHEREFORE, Plaintiff requests the Court to enter an order compelling Defendant to provide full and complete responses in writing to the discovery requests previously presented within the next twenty(20) days, and pay$300 towards Plaintiffs attorney's fees incurred to prepare and present the Motion to Compel. Respectfully Submitted, .0 /7-?2 —f17/47 Kathryn Nonas-Hunter, Esquire Sup. Ct. I.D. #308437 Attorney for Plaintiff HOBBS &HUNTER,LLC 257 East Market Street York, Pennsylvania 17403 (717) 793-2398 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RYAN HUNTER No. 2013-CV-07268-NT Plaintiff • v. CUMBERLAND COUNTY : WRIT No.: 13-6612 MICHAEL QUICK • Defendant CIVIL ACTION CERTIFICATE OF SERVICE I, Kathryn Nonas-Hunter, Esquire, being duly sworn according to law, doth depose and say that I served a copy of the "Petition to Make Rule Absolute" to the Person named below, by first class mail, as follows: Michael Quick 336 5th Street New Cumberland, PA 17070 Respectfully submitted, '' 10//2-1 J/ Kathryn onas-Hunter, Esquire Sup. Ct. I.D. #308437 Attorney for Plaintiff HOBBS &HUNTER,LLC 257 East Market Street York, Pennsylvania 17403 (717) 793-2398 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RYAN HUNTER No. 2013 -CV -07268 -NT Plaintiff V. CUMBERLAND COUNTY WRIT No.: 13-6612 MICHAEL QUICK Defendant CIVIL ACTION ORDER AND NOW, TO WIT, this S. day of /aiv/K..s' , 2014, it is hereby Ordered this Honorable Court compels Defendant to provide full land complete responses to the discovery 4 is«G tZ ywe requests within twenty (20) days .1111111_ le• 010••!•:.•• fr&I Lk_ A K. AJ r- 8/sPy -rf BY THE COURT: ua : it wv s- 9nv i z =r; :a CD CD 2°111AUG 27 +,27 Al'i1!:33 CUMBERLANDCO PENNS YLVA N ' T ( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RYAN HUNTER No. 2013 -CV -07268 -NT Plaintiff v. CUMBERLAND COUNTY WRIT No.: 13-6612 MICHAEL QUICK Defendant CIVIL ACTION PETITION FOR CONTEMPT 1. Petitioner is Ryan Hunter and the Plaintiff in the above -referenced civil action. 2. Respondent is Michael Quick and the Defendant in the above -referenced civil action. 3. On April 1, 2014, Plaintiff's counsel served Interrogatories in Aid of Execution upon Defendant by personal hand -delivery. 4. Pursuant to the Pennsylvania Rules of Civil Procedure, the Defendant was required to file responses to the discovery requests within thirty (30) days of service. Accordingly, responses to the outstanding discovery were due on May 1, 2014. 5. On May 30, 2014, a Rule was issued upon Defendant Michael Quick to show cause within twenty (20) days why the relief requested should not be granted. 6. Pursuant to the Pennsylvania Rules of Civil Procedure, the Defendant was required to file a response on the Rule to Show Cause within twenty (20) days of service. Accordingly, a response to the Rule to Show Cause was due on June 19, 2014. 1 7. On August 5, 2014, an Order was entered to compel Defendant to provide full and complete responses to the discovery requests within twenty (20) days, or suffer sanctions. 8. Pursuant to the Pennsylvania Rules of Civil Procedure, the Defendant was required to file responses to the discovery requests within twenty (20) days of service. Accordingly, responses to discovery requests were due on August 25, 2014. 9. Plaintiff respectfully requests $800 in counsel fees and costs to prepare, file, and serve the original Motion to Compel,the Petition to Make Rule Absolute and the instant Petition for Contempt. 10. Plaintiff respectfully requests, if Defendatn fails to provide the requested discovery requests, or pay the attorney's fees, the imposition of incarceration and/or any other relief this Court deems appropriate until Respondent fully complies with the Court's Order. WHEREFORE, Plaintiff requests your Honorable Court hold Defendant in contempt of Court for willfully failing to comply with the Court's Order and order Defendant to pay reasonable counsel fees and costs to prepare and file this Petition in the amount of $800. Plaintiff further requests that the Court incarcerates Defendant if he fails to respond and/or any other relief this Court deems appropriate. 2 Respectfully submitted, .-7.7/— 9iufi Kathryn Nonas-Hunter, Esquire Attorney for Plaintiff Sup. Ct. I.D. #308437 257 East Market Street York, Pennsylvania 17403 (717) 793-2398 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RYAN HUNTER No. 2013 -CV -07268 -NT Plaintiff v. CUMBERLAND COUNTY WRIT No.: 13-6612 MICHAEL QUICK Defendant CIVIL ACTION CERTIFICATE OF SERVICE II,,nKathryn Nonas-Hunter, Esquire, attorney for the Plaintiff, hereby certify that I have on the 25 day of / 10.64- , 2014, served the attached "Petition for Contempt" by first class mail, postage prepaid, upon the persons and to the addresses indicated below: Michael Quick 336 5th Street New Cumberland, PA 17070 Kathryn Nonas-Hunter, Esquire Attorney for Plaintiff Sup. Ct. I.D. #308437 257 East Market Street York, Pennsylvania 17403 (717) 793-2398 4 RYAN HUNTER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. : CIVIL ACTION — LAW : NO. 13-6612 MICHAEL QUICK, Defendant IN RE: PETITION FOR CONTEMPT ORDER AND NOW, this Z 3 a day of August, 2014, hearing on the above matter is set for Wednesday, October 1, 2014, at 3:00 p.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. BY THE COURT, A/ Kevin : Hess, P. _-' Kathryn Nonas-Hunter, Esquire For the Plaintiff - '1ichael Quick Defendant :rlm Cop £S LaCt l� �9�iy /' 0.0 -0 RYAN HUNTER, Plaintiff V : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 13-6612 CIVIL MICHAEL QUICK, Defendant IN RE: MOTION FOR SANCTIONS ORDER OF COURT AND NOW, this 1st day of October, 2014, this matter having been called for hearing, and the court being satisfied that the defendant is in violation of earlier orders of this court, a contempt citation is issued. Hearing on the matter of adjudication is set for Thursday, October 30, 2014, at 11:30 a.m. The questions to be addressed at the adjudicatory hearing will involve attorney's fees, compliance with our prior orders of court, and any penalty for contempt, which may include a fine or incarceration. In the event the defendant fails to appear, a bench warrant will be issued for his arrest. By the Court, Kathryn Nonas-Hunter, Esquire For the Plaintiff Michael Quick 336 5th Street Apartment 2 New Cumberland, PA 17070 :bg 0.4 icL —4 rn —4 CA) CD r„) RYAN HUNTER, Plaintiff V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2013-6612 CIVIL MICHAEL QUICK, Defendant IN RE: CONTEMPT HEARING ORDER OF COURT AND NOW, this 30th day of October, 2014, this matter having been called for hearing, it is ordered and directed that the defendant respond to outstanding discovery within ten days as a condition of purge, and, in default thereof, to appear for sentence at the request of the plaintiff. Sentence to include a term of incarceration until such time as the defendant completes the required discovery. We award counsel fees in favor of the plaintiff in the amount of $250.00. ✓Kathryn Nonas-Hunter, Esquire For the Plaintiff Michael Quick 336 5th Street Apartment 2 .New Cumberland, PA 17070 :bg tri_;;;LEct 16/3/M By the Court, Kevin A Hess, P.J.