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HomeMy WebLinkAbout13-6783 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL Judicial District, County Of FROM }� MAGISTERIAL DISTRICT JUDGE JUDGMENT V COMMON PLEAS NoI3 — 6ji 7. 3 NOTICE OF APPEAL Notice is given that the appella has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District d t eda dinthec f b i" bwN�)ef NAM F A LLANT MAG.�ST. N0. �� OF MDJ ADDD F AP EL NT 1 1 � CITY S�E Z P C DE in D T OF JUDGMENT IN THE CASE OF (Plaintirt) - (Defeo nt) 1 � ' (' 1 - 3 I U \ �s 0 / ,J.�x DOCKET No. IGNATURE OF APPELLANT OR ATTORNEY OR fGENT MJ-bG3o3 - Cv_ 4 1 - 2,6)3 1AIM n4 This block will be signed ONLY when this notation is required under Pa. appellant w s lai an (see Pa. R.C.P.D.J. No. 1001(6) in action R.C.P.D.J. No 10086. This Notice of Appeal, when received by the Magisterial District Judge, will before a Magisterial District Judge, A COMPLAINT MUST BE FILED operate as a SUPERSEDEAS to the judgment for possession in this case. within twenty (20) days after filing the NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before Magisterial District Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary �Qn J I Enter rule upon l C v � appellee(s), to file a complaint in this appeal Name fappellee(s) (Common Pleas No. 13 — 6 ' l 0 6 within twenty (20) days after service of rule or suffer e ry of judgment of non pros. /e/M a1,1Aq[W"1f1_1A If ICA b6 yl ig t re of appellanT or attorney or agent RULE: To �r) G appellee(s) Name of appellee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailin Date: 1 20 3 Signature of Prothono ar or Deputy YOU MUST INCLUDE A COPY OF THE N0V#WAR II 04T/TRANSCRIPT FORM WITH T V NOTICE OF APPEAL. AM00 ONV1830WA3 4 Ods AOPC 312 -05 9Z .0 Wd S 1 AON E) 6Z m0!JA0-C1371J COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND x Case Mag. Dist. No: MDJ- 09 -3 -03 Eric Donley MDJ Name: Honorable Susan K. Day V.. Address: 229 Mill Street Nathan Strunk, Autumn Mason, Marie Elena P.O. Box 167 Gunter Mount Holly Springs, PA 17065 Telephone: 717- 486 -7672 File Copy Docket No: MJ- 09303 -CV- 0000148 -2013 Case Filed: 8129/2013 Disposition Summary Cross Complaint) Docket No Plaintiff Defendant Disposition Disposition Date MJ- 09303 -CV- 0000148 -2013 Eric Donley Nathan Strunk Judgment for Plaintiff 10/17/2013 MJ- 09303 -CV- 0000148 -2013 Eric Donley Autumn Mason Judgment for Plaintiff 10117/2013 MJ- 09303 -CV- 0000148 -2013 Eric Donley Marie Elena Gunter Judgment for Plaintiff 10/17/2013 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Autumn Mason $2,876.49 $0:00 $2,876.49 Eric Donley $0.00 $0.00 $0.00 Marie Elena Gunter $2,876.49 $0.00 $2,876.49 Nathan Strunk $2,876.49 $0.00 $2,876.49 Judgment finding (*Post Judgment) In the .matter of Eric Donley vs. Nathan Strunk; Autumn Mason; Marie Elena Gunter on MJ- 09303 -CV- 0000148 -2013, on 10/17/2013 the judgment was awarded as follows: . Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $2,725.9.9 $0.00 $2,725.99 Filing Fees $150.50 $0.00 $150.50 Grand Total: $2,876.49 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A .NOTICE OF APPEAL WITH: THE PROTHONOTARY /CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT As OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. Date Magisterial District Judge Susan K. Day MDJS 315 Page 1 of 3 Printed: 10/17/2013 10:49:43AM it e't r—i-IO! u E PRO HONOT',. . 3 NOV 22 PSI I: 53 ?i. MMBERLANCJ COUNTY PENNSYLVANIA 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 of the notice of appeal. Check applicable boxes.) COMMONWEALTH OF PENNSYLVANI COUNTY OF tulivriai1�V ; ss AFFIDAVIT: I hereby(swear)(affirm)that I served b" ❑ a copy of the Notice of Appeal, Common Pleas No. , upon the Magisterial District Judge designated therein obi (date of service) 1 -22 20 l , ❑ by personal service ;i4, by(certified)(registered)mail, sender's receipt attached hereto, and upon the appellee, (name) , on /I-27,, 20 13 Eby personal service❑ by(certified)(registered)mail, sender's receipt attached hereto. (SWO N (AFFIRMED)AND SUBSCRIBED BEFORE ME T`fF e DAY Mk 4 I r C JA /4 Sig atu 71 bef.re w'.■ affidavit was made Sgrature of affia r U.S. Postal ServicE,TM m CERTIFIED MAILTM RECEIPT u (Domestic Mail Only;No I'tsurance Coverage Provided) tv rru▪ For delivery information visit our website at www.usps coms Title of office t ,- . CI My commission expires on ,20 Postage $ .� Certified Fee M Postmark ��� a Return Receipt Fee Here 0▪ (Endorsement Required) Restricted Delivery Fee • O (Endorsement Required) r1 r-R Total Postage&Fees r- Sent I I ( Don l.0 O Street,Apt.No.; Lju 1 ,V) lo-1 -B id€€ Pd r- or PO Box No. l t City,State,ZIP , 1 b 3 PS Form 3800,August 2006 See Reverse for Instructions AOPC 312A-05 1 II U.S. Postal Service Ti,- - CERTIFIED MAILTM RECEIPT co (▪ Domestic Mail Only;No Insurance Coverage Provided) ru• For delivery information visit our website at www.usps.com© ..ioN gt's r, A A7't„ r f CARLISLE MPO ° 4 r is .,. ,,„ 6 w. CARLISLE, Pennsylvania `p 170139998 -I▪I Postage $ 4134870013 -0096 Certified Fee 11/22/2013 (800)275-8777 01:41:16 PM ° 0 Return Receipt Fee Postmark Here Sales Receipt ° (Endorsement Required) Product Sale Unit Final Restricted Delivery Fee Description Qty Price Price CI (Endorsement Required) rg r- (Forever) Total Postage&Fees 1 $0.58 $0.58 ,a Bank Swallow I `(/ PSA #10 m 1 Sent To '\l vi,n 16 Envelope ° Street,Apt.No.; (Forever) 1 $0.58 $0.58 N or PO Box No. G"�_aIll.,, 6 x!_ Bank Swallow City,State,ZIP+ PSA #10 t f Ill ' S O1/ I _ Envelope PS Form 3800,August 2006 Sue Reverse for Instructions MOUNT HOLLY SPRINGS PA 17065 $0.46 Zone-1 First-Class Mail Letter 0.60 oz. Scheduled elivery Day: Sat 11/23/13 Return Rc t (Green Card) $2.55 $0 Certif ed $3.10 Label #: 70131710000064602486 Customer Postage -$0.46 Subtotal : $5.65 Issue PVI: $5.65 CARLISLE PA 17013 Zone-0 $0.46 First-Class Mail Letter 0.60 oz. Scheduled Delivery Day: Sat 11/23/13 Return Rcpt (Green Card) $2.55 r 00 Certified $3.10 Label #: 70131710000064602493 Customer Postage -$0.46 Subtotal : $5.65 Issue PVI: $5.65 Total : $12.46 Paid by: Cash $13.00 Change Due: -$0.54 AR Alt's!!,Ys r,1 MM++.14,rsgt Am%m itet Itit.to%libelant mei W slum r of crur. tk 1 Christopher E. Rice, Esquire ' ' ' ' i r MARTSON LAW OFFICES 113 DEC i 4' r. I.D. No. 90916 Ten East High Street Carlisle, PA 17013 PENNSYLVANIA (717) 243-3341 Attorneys for Plaintiff ERIC DONLEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2013 - 6783 CIVIL TERM NATHAN STRUNK, AUTUMN MASON, : AND MARIE ELENA GUNTER, Defendants • NOTICE 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 defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 NOTICE REQUIRED UNDER THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1601 (AS AMENDED) AND THE PENNSYLVANIA UNFAIR TRADE PRACTICES ACT AND CONSUMER PROTECTION LAW, 73 PA. CON. STAT. ANN. §201, ET SEQ. ("THE ACTS") To the extent the Acts may apply, please be advised of the following: 1. The amount of the original debt is stated in the Complaint attached hereto. 2. The Plaintiff who is named in the attached Complaint is a Creditor to whom the debt is owed. The Creditor's law firm, Martson Deardorff Williams Otto Gilroy & Faller, is filing this Complaint on behalf of the Creditor. 3. The debt described in the Complaint attached hereto and evidenced by the copies of the note will be assumed to be valid by the Creditor's law firm, unless the Debtor(s), within thirty (30) days after receipt of this notice, disputes the validity of the debt or some portion thereof. 4. If the Debtor(s) notifies the Creditor's law firm within thirty (30) days of the receipt of this notice that the debt or any portion thereof is disputed, the Creditor's law firm will obtain verification of the debt and a copy of the verification will be mailed to the Debtor(s) by the Creditor's law firm. 5. If the Creditor who is named as Plaintiff in the attached Complaint is not the original Creditor, and if the Debtor(s) makes a request to the Creditor's law firm within thirty days from the receipt of this notice, the name and address of the original Creditor will be mailed to the Debtor(s) by the Creditor's law firm. 6. Requests can be made to: MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER Attn: Christopher E. Rice, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 * THIS DOCUMENT MAY BE CONSTRUED AS AN ATTEMPT TO COLLECT A DEBT FOR THE PLAINTIFF AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. F:\FILES\Clients\I 1381 Donley\11381.7\11381.7.Donley.Complaint wpd Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Aaron S. Haynes. Esquire I.D. No. 307746 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ERIC DONLEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2013 - 6783 CIVIL TERM NATHAN STRUNK, AUTUMN MASON, : AND MARIE ELENA GUNTER, • Defendants COMPLAINT 1. Plaintiff, Eric Donley, is an adult individual residing at 407 Wolf Bridge Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant,Nathan Strunk,is an adult individual with a last known address of 64 Old Mill Road, Dillsburg, York County, Pennsylvania 17019. 3. Defendant, Autumn Mason, is an adult individual with a last known address of 64 Old Mill Road, Dillsburg, York County, Pennsylvania 17019. 4. Defendant, Marie Elena Gunter, is an adult individual with a last known address of 64 Old Mill Road, Dillsburg, York County, Pennsylvania 17019. 5. On or about August 4, 2012, Plaintiff and Defendants entered into a written residential lease agreement("Lease")whereby Defendants agreed to rent the premises at 1 Chestnut Street, Mount Holly Springs, Cumberland County, Pensylvanial 7065 ("Premises"). A true and correct copy of the Lease is attached hereto as Exhibit "A" 4. The Lease ended on or about April 30, 2013, and Defendants moved from the premises on May 1, 2013. 5. After an inspection of the Premises, Plaintiff determined that Defendants caused damages in the amount of$3,938.49. See list of damages included in the Civil Complaint attached hereto as Exhibit "B". 6. Defendants have failed and refuse to pay the outstanding charges as stated above. 7. On or about January 30, 2012, Plaintiff filed a Civil Complaint with Magisterial District Judge Susan K. Day for judgment against the Defendants. A true and correct copy of the Civil Complaint is attached hereto as Exhibit `B". 8. On October 17, 2013, the Honorable Susan K. Day entered a Notice of Judgment in favor of Plaintiff, and against the Defendants. 9. On November 15, 2013, Defendants filed a Notice of Appeal From Magisterial District Judge Judgment. A true and correct copy of the Defendants' Notice of Appeal is attached hereto as Exhibit"C". 7. Pursuant to the Lease,Defendants are indebted to the Plaintiff for damages as stated above, plus costs of suit. 8. Defendant has breached the Lease for the reasons stated above. WHEREFORE, Plaintiff demands judgment in their favor and against Defendant in the amount of$3,938.49, plus costs of suit, interest, any additional damages discovered hereafter. MARTSON LAW OFFICES By eg/ S �� Christopher E. Rice, Esquire I. D. Number 90916 Aaron S. Haynes, Esquire I.D.Number 307746 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Date: /Z,(f3 _ /5 Attorneys for Plaintiff This is a debt collecting firm attempting to collect a debt for Eric Donley. Any information obtained will be used for that purpose. EXHIBIT "A" LF310PA O4 Pennsylvania RESIDENTIAL LEASE Apartment— Condominium --- House BY THIS AGREEMENT made and entered into on `P.' / ,20/2.. between -(2-1 f 0/4) herein referred to as Lessor, and Ayfni ,J 1,MulL,t;/ .41,crt,trti i j 41/1S0'4,. / LA herein referred to as Lessee. Lessor leases to Lessee the prel rises situated at j (/ c rp-t r �t. . in the City of /14.7714'0.7 .C,/ziAk,. , County of State of Pennsylvania, and more particularly described as follows: LH€- . .'` .r 1' . ,rte . l','f / ,'L'L, together with all appurtenances,for a term of f..);7- x 7- years, to commence on . s5 .—$f• t 20 '? , and to end on ?` I.7 7 at 14 o'clock . na. 0 1 1. Rent. Lessee agrees to pay, 'without demand,to Lessor as rent for the demised premises the sum of /[d Dollars i$ g, ie> e> ) per month in advance on the ,, :^ clay of each calendar month beginning 220 ) -. ,at '-/r 7 i t., S" r.<1 C ?rl'rs4.67 , Cr v of State of p:-A'i9'`<`t +r�,v,y, or at such other place as Lessor may designate.Uf'- execution ' "r ?,:2. Security Deposit. Cr of this lease, Lessee deposits with l essc. irii9c./14 0,1 Dollars (S tiki l ), receipt of which is acknowledged by Lessor,:sor, as security for the faithful performance by Lessee of the terms hereof, to be returned to Lessee, without interest, on the full and faithful performance by lute of the provisions hereof. 3. Quiet Enjoyment. Lessor covenants that on paying the rent and perform ng the cot-enants herein contained.Lessee shall peacefully and quietly have, hold,and enjoy the demised premises for the agreed term. 4. Use of Premises. The demised premises shall be used and occupied by Lessee exclusively as a private single family residence,and neither the premises nor any part thereof shall be used at any time during the term of this lease by Lessee for the purpose of carrying on any business.profession, or trade of any kind, or for any purpose other than as a private single family residence. Lessee shall comply with all the sanitary laws, ordinances,es, rules, and orders of appropriate governmental authorities affecting the cleanliness, occupancy. and preservation of the demised premises. and the sidewalks connected thereto.during the term of this lease. 5. Number of Occupants. Lessee agrees that the demised premises shall be occupied by no more than ^3 persons,consisting of 3 adults and t7 children under the age of tt years. «ithout the written consent of Lessor. 6. Condition of Premises. 1 essee stipulates that he has examined the demised premises. including the grounds and all buildings and improvements, and that they are, at the time of this lease, in good order. repair. and a safe, clean, and leaseable condition. 7. Assignment and Subletting. Without the prior written consent of Lessor,Lessee;ee shall not assign this lease,or sublet or 'rant any concession or license to use the premises or ;tn'y' part thereof. A consent by Lessor to one assignment, ent, subletting. concession, or license shall not be deemed to he a consent to any subsequent assignment, subletting. concession,or license.An assignment, subletting. concession. or license without the prior written consent.of Lessor,or an assigntuerit ca subletting by operation of law,shall be void and shall,at Lessor's option, terminate this lease. NOTICE:Contact your local county real estate hoard for additional forms that may be required to meet your specific needs. f. 1992-200! It cL F tit :.tnc P age i Rev.l'ill t :e «,n iuu..mr r ncler ug or legal advice or services. ,noduei is imet cd for informational u.„only a.�ci i=,not a;tbarute A tr 1 u pro duet d 1 rr, ud•.pit. St.!te laws vale.so consult an..aorney on .i.legal ma:et..This I odunn was not necessarily prepared by a I„trot,.taen ed i;practice tau in your a'ate. AQAB 8„Alterations and Improvements. 1._essec shall make no alterations tc. the buildings on the clen ised premises or construct any building or make other tinprovenients on the demised premises without the prior wrltiell consent of Lessor. All alterations, changes, mnd improvements built. constructed, or placed rra the demised premises by Lessee, Kith tile exception of fixtures removable without damage to the premises and movable personal property.shell.unless otherwise provided by written agreement between Lessor and t be demised Lessee, ?e li p.'c=°>zr:e of Lessor and rennin; on the ricniisc;d premises at the expiration or sooner termination of this lease. 9. Damage to Premises. if the demised premises, or arty part thereatf, shill be partially damaged by fire or other casualty not due to Lessee's negligence or willful act or that of his employee,family,agent.or visitor,the premises shall he promptly repaired by ilmssor and there shall he an ahmciitent of rent corresponding vyith the time during which, and the extent to which, the leased premises may have been untenantabh, but if the leased premises should be damaged other than by Lessee's negligence or willful act or that of his employee. family.e.agent,or visitor to the extent that Lessor shall decide not to rebuild or repair. the tern': of this lease shall end and the rent shall be prorated up to the time of the damage, 10. Dangerous Materials. Lessee shall not keep or have on the .raised premises any article pr Thing of a danger sus, inflammable, Of explosive character dint Might Unreasonably increase the;clanger of I its on the leased premiss or that might be Considered hazardous or extra hazardozit, by any responsible .insurance company. 11. Utilities. lessee shall he responsible for arranging for and pus ing for ail utility ser ices required on the premises, except that Y.,`J,Q: .7.1_ _ 56-iAl r_-r ^✓ rT> 3 > t' shall he provided by Lessor, 12.Right of Inspection. Lessor and his agents shall have the right at all reasonable onable times during the term of this lease and any renewal thereof to enter the demised premises for the purpose of inspecting the premises and all building and improvements thereon. 13. Maintenance and Repair. 1.ease will, at his sole expense, keep and maintain the leased pre ppis:es and appurtenances in good and sanitary condition and repair during the term of this lease and any renewal. thereof. In particular, shall keep the fixtures in the house or on or about die leased premises in good order and repair.keep the ISit'naae cleat;keep the electric bells in order:keep the walls free from dirt and debris;and,at his sole expense,shall make all required repairs to the plumbing, range. heating, apparatus. and electric and gas fixtures whenever damage thereto shall have resulted front Lessee's misuse, waste, or neglect or that of his employee. family, agent, or visitor. Major maintenance and repair of the leased premises, not due to Le s:ee s misuse, waste. or neglect or that of his employee.famil\ agent,of visitor. shall be the responsibility of Lessor or his a signs. Lessee agrees that no signs shall he placed or painting donee o,or about the leased premises by Lessee or at his direction without the prior written consent of Lessor. 14. Animals. Lessee shall keep no domestic or other animals on or about the leased premises without the written consent of Lessor, , ji i ) 15.Display of Signs. During the last 3cc,days of this lease.Lessor Or his agent shall have the privilege of displaying , the usual "For Sate, or -For Rent,'' or Vienne signs n1 the demised premises and of shoot-lug the property to prospective purchasers or lessees. 16.Subordination of Lease. This lease and Lessee's leasehold interest hereunder are and shall be subject,subordinate, and inferior to any liens or encumbrances now or hereafter placed on the demised premises by I-:essor,all advances made under any such liens or encumbrances,the interest payable on any such dens or encumbrances,and any and all renewals or extensions of sin 1 liens or encumbrances. 17.Holdover by Lessee.. Should Lessee remain in possession of the cleansed premises with the consent of Lessor after the nature! expiration of this lease. a new tnontll-to-month tenancy shall be created between Lessor and lessee which shall he t.b,cc tti all the terms and conditions hereof but,hal■ be terminated on 30 Puts;s' written notice roved by either Lessor or lessee on the other party. 18. Surrender of Premises. At the expiration of the lease term, Lessee shall quit and surrender the premises hetebv demised in as good state and condition as they were at the commencement of this lease,reasonable use and wear thereof and damages by the elements excepted 19.Default. If any default is ritade in the payment of rent.or any pert tt.efC 'f.at the mimes hereinhefot e specified,or if any default is made in the performance of or compliance with any other term err condiitioti hereof, the lease,at the option of Lessor. shall terminate and be forfeited, and Lessor may re-enter the premises and remove all persons therefrom. Lessee shall be given written notice of any default or breach,and termination and forfeiture of the lease shall not result if, within ,-- days of receipt of such notice,Lessee,has corrected the default or breach or has taken action reasonably likely to eRt171.such correction within a reasonable time. 20. Abandonment. If at any time during the terra of this lease Lessee abandons the demised premises or any part without being ,1 thereof.Lessor may, at his option, enter the demised premises by.any incurs nubs a ..ern, basie for any prosecution therefor. and without becoming liable to Lessee for damages or for any payment of any kind whatever, and may,at his discretion, as agent for Lessee. relet the demised premises or any part thereof, for the whole or any part al the then unexpired tenon, and may receive and collect all rent payable by virtue of such ;•electing, and. at Lessor's option, hold Lessee liable for any difference between the rent that would have been payable under this lease during the balance of the unexpired term, if this lease had continued in force.and the net rent for such period realized by Lessor by means of such reining. If Lessor's right of re-entry is exercised following abandonment of the premises by Lessee.then Lessor may consider any personal property belonging to Lessee and left on the premises to also have been abandoned,in which case Lessor may dispose of all such personal property in inns• manner r Lessor shall deem proper and is hereby relieved of all liability for doing so. 21. Binding Effect. The covenants and conditions herein contained shall apply to and bind the heirs, legal representatives, and assigns of she patties hereto.and all cotenants are to be construed as conditions of this lease. 22, Radon Gas Disclosure, As required by law, (Lessor) (Seller) makes the following disclosure: "Radon (;rats" is a naturally occurring radioactive ens that,when it has accumulated in a building in sufficient quantiiies,may 1?1Ses,nt health risks to persons who are exposed to it over time.Levels of radon that exceed federal and state guidelines have been found in buildings in Pennsylvania. Additional information regarding ration and radon testing may be obtained from your county public health unit. 23.Lead faint Disclosure "Every purchaser or lessee of any interest in residential real property on which a residential dwelling was built prior to 1978 is notified that such property may present exposure to lead from lead-based paint that may place young children at risk of developing lead poisoning. lead poisoning in young children may produce permanent neurological damage,including learning disabilities, reduced intelligence quotient behavioral problems and impaired memory.Lead poisoning also poses a particular risk to pregnant women.The seller or lessor of any interest in residential real estate is required to provide the buyer or lessee with any information on lead-based paint hazards from risk assessments or inspection in the seller or lessor's possession and notify the buyer or lessee of any known lead-based paint hazards.A risk assessment or inspection for possible least based taint hazards is recommended prior to purchase." 24.Other Terms: 1 t { } L'655 C _... 1r lea % .e. °L-a:^f' .7 �?_t:..d"r"•i_`.. J v., , r 4n 2 e ...ts+i' (it a'_s"v?:'ss'�a''i't•d""1. {.>.trs- +C.... 49+1.0"1,+111 a.__ir.rl^A..V's N.. ., IN WITNESS WJIER ,)i',the parties have executed this lease the y at d year fi•' • hose written.• Lessor f ; 'SFr r+ Lessor le:se k./ % r r 1 NO"IIt,L: Suite taw establishes rights and obligations for pang, to t,at ta;re'e. ,at r., his ter ernu, t>°° eclu.r,,d tall comply with the Truth in Renting Act or the applicable L.essor-Lessse Statute or code of your state. If you have a question about the interpretation or legality of a provision of this agreement. you may want to seek assistance from a lawyer or other qualified person. AQAB • EXHIBIT "B" COMMONWEALTH OF PENNSYLVANIA r, '�` Civil Complaint COUNTY OF CUMBERLAND ~ Mag. Dist. No: MDJ-09-3-03 PLAINIIFF. NAME and ADDRESS MDJ Name: Honorable Susan K. Day nj�yC �� Address: 229 Mill Street ("W.�-1,54_6 A / 7t'/.j P.O. Box 167 L. vs —J Mount Holly Springs, PA 17065 DEFENDANT NAME and ADDRESS —� rAi N�9A).57 0A,',Ilk rwr V.4 1_Aliz e ,u? ::4�✓:ti:{J Telephone: 717-486-7672 ky 49.1.6 ,'44 H...4... .t=6 AMOUNT DATE PAID '4.4-$:5,t r2.-(;- 'A / t FILING COSTS $ / / L Docket No: J POSTAGE $ / / Case Filed: SERVICE COSTS $ / / Social Security Numbers and financial information (e.g. PINs) should not be listed. If the identity of an account number CONSTABLE ED. $ / / must be established, list only the last four digits. 204 TOTAL $ / / Pa.Code§§213.1 -213.7. Pa.R.C.P.D.J. No. 206 sets forth those costs recoverable by the prevailing party. To The Defendant: The above named plaintiff(s)asks judgment against you for$, 3 e 3S'', 4/9 together with costs 1� upon the following claim (Civil fines must include citation of the statute or ordinance violated): t_i-t r c: •�'c' ^ 4- "f: I C A4 .(i 44 r f .S ra r'2'14,- - ,,,ti- f2'/ , I.7 C.�>.S ,f rz u,-4,4-:).4, ,,,::?..,;-/v7- .y .. C;.''. J ,u<. /3 0/41 L h'° -r7 -it CC' C C ,,":;7'!t L- ircc ( L c t=oy T,,,..09:4., Id .5: ,S- at, ra ,°-c);-",kc `lrt,ur� .96 9 ), i; t e.:74 r -eJ +.ii e..,c!.7c1 i f''''''' —k lot". aw lZ�3'it:t:C Sa■f2G.._`G"a3iDr t•c' 714.54 Ccr °2ti2S- CV )61,4/N-,;-/iv.,/,_ - y`_,,`rri��.tt a tv <f7•, r°.k:r" F i2:•v 7 d 5'CiY1 4.,,, ...1:b�a�JS- ..�' Jb Y" a,.S1'C'-f,L k i'i''iii4 air 4:tr.3exti -z d•..,i ` 3 £v .eJ S ''tr.",e.1 L tr,re 4,3,`i„,,e):.3c.0 r3-S°9 s Liz y :,G .vc 5 S IS, w ' I, r--r"-\C--- _De)?ILCU1 verify that the facts set forth in this complaint are true and correct to the best of my knowledge, information, and belief. This statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA. C.S. § 4904) related to unsworn falsification to authorities. l'--- ature f Plaintiff r Autho ed.Agent) The plaintiffs attorney shall file an entry of appearance with the magisterial district court pursuant to . C.P.M.D.J. 207.1 If you intend to enter a defense to this complaint,you should notify this office immediately at the above telephone number. You must appear at the hearing and present your defense. Unless you do,judgment may be entered against you by default. If you have a claim against the plaintiff which is within the magisterial district judge jurisdiction and which you intend to assert at the hearing,you must file it on a complaint for at this office at least five days before the date set for the hearing If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. _ MDJS 308A 1 Printed 01/3012012 2:24:37PM EXHIBIT "C" COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL Judicial District, County Of FROM &Vn rta MAGISTERIAL DISTRICT JUDGE JJUDDGMENT IVI�J�U[ COMMON PLEAS No./3 — ji (a 3 ewr NOTICE OF APPEAL -76/V Notice is given that the appella has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District d•- • t e d-.- din c- the ,.: -� -. b= t V ►i!. !L 11.f:.41 ' s P,r NAM4gF A LLANT r nit D3-01 01-3-03 ME V.• l/ aD0 E F AP EL d NT CITY S E P C D ad u Ind - E D°ivT OF JUDGMENT IN THE CASE OF(Plaintiff) • (Defeo.:of). -Y7. 13 arct I ) vs l�. .., , tal dil., DOCKET No .IGNATURE OF APPELLANT OR ATTORNEY•R•GENT • MJ�0303 Cv-0000 -16)3 This block will be signed ONLY when this notation is required under Pa. appellant w lai an (see Pa. R.C.P.D.J. No. 1001(6) in action R.C.P.D.J. No. 10086. This Notice of Appeal, when received by the Magisterial District Judge, will before a Magisterial District Judge, A COMPLAINT MUST BE FLED operate as a SUPERSEDEAS to the judgment for possession in this case. within twenty (20)days after filing the NOTICE of APPEAL Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT(see Pa.R.C.P.D.J. No. 1001(7) in action before Magisterial District Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary DQniN arc( . Enter rule upon appellee(s), to file a complaint in this appeal • Nametf appellee(s) (Common Pleas No. 13— <ri'3 V--.1 ))within twenty(20)days after service of rule or suffer) of judgment of non pros. I)6y I< •'fit re of appellan or attorney or agent RULE: To of C appellee(s) Name of appellee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty(20)days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time,a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailin•. Date:/1/rte 20 1 _! . � . • - Signature of Prothono ary or Deputy YOU MUST INCLUDE A COPY OF THE NOOIIMOVI L N$ JT/TRANSCRIPT FORM WITH T IS NOTICE OF APPEAL. AINfOU ONV1J38W110 410 3. sbpd1 /1t ' AOPC 312-05 8£ :£ Rd S I AON£10Z na C It/lON:1JO0l3 1 a(, A#.2e149,2‘/L VERIFICATION The foregoing Complaint is based upon information which has been gathered by our counsel in the preparation of the lawsuit. The language of the document is that of counsel and not our own. We have read the document and to the extent that it is based upon information which we have given to counsel,it is true and correct to the best of our knowledge,information and belief. To the extent that the content of the document is that of counsel, we have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa.C.S.Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. l Eric Donley F,VILEStClicnu\11381 Uu0k5+41381.7.11381.7.Donley.Complamt.w7x( SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff , Jody S Smith w i 1r ,1 ad Chief Deputy ' �� Richard W Stewart iti , ;£� Solicitor d X145 ' S I t� °` tr9t;` Eric Donley Case Number vs. Nathan Strunk(et al.) 2013-6783 SHERIFF'S RETURN OF SERVICE 12/19/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Nathan Strunk, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Complaint& Notice according to law. 12/19/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit:Autumn Mason, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Complaint& Notice according to law. 12/19/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Marie Elena Gunter, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Complaint& Notice according to law. 12/27/2013 09:22 AM -The requested Complaint& Notice served by the Sheriff of York County upon Autumn Mason, Friend of defendant, who accepted for Marie Elena Gunter, at 64 Old Mill Road, Dillsburg, PA 17019. Richard P. Keuerleber, Sheriff, Return of Service attached to and made part of the within record. 12/27/2013 09:22 AM-The requested Complaint& Notice served by the Sheriff of York County upon Autumn Mason, personally, at 64 Old Mill Road, Dillsburg, PA 17019. Richard P. Keuerleber, Sheriff, Return of Service attached to and made part of the within record. 12/27/2013 09:22 AM -The requested Complaint& Notice served by the Sheriff of York County upon Autumn Mason, girlfriend of defendant, who accepted for Nathan Strunk, at 64 Old Mill Road, Dillsburg, PA 17019. Richard P. Keuerleber, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $60.46 SO ANSWERS, January 16, 2014 RON R ANDERSON, SHERIFF u ayF>, �ntf, e >c` • SHERIFF'S OFFICE OF YORK COUNTY A Richard P Keuerleber OF'S op, PETER J. MANGAN, ES Sheriff 4 — e.tee" So/ici Reuben B Zeager Richard E Rice Chief Deputy, Operations C Chief Deputy, Administrat, ERIC DONLEY vs. Case Number NATHAN STRUNK(et al.) 2013-6783 SHERIFF'S RETURN OF SERVICE 12/27/2013 09:22 AM - DEPUTY MICHAEL DONOVAN, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED COMPLAINT& NOTICE BY HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE AUTUMN MASON, GIRLFRIEND, WHO ACCEPTED AS "ADULT PERSON IN CHARGE" FOR NATHAN STRUNK AT 64 OLD MILL ROAD, DILLSBURG, PA 17019. MICHAEL ID•NOVAN, DEPUTY 12/27/2013 09:22 AM - DEPUTY MICHAEL DONOVAN, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED COMPLAINT& NOTICE BY"PERSONALLY" HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT, TO WIT: AUTUMN MASON AT 64 OLD MILL ROAD, DILLSBURG, PA 17019. 6z _._ MICHAEL b0NOVAN, DEPUTY 12/27/2013 09:22 AM - DEPUTY MICHAEL DONOVAN, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED COMPLAINT& NOTICE BY HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE AUTUMN MASON, FRIEND, WHO ACCEPTED AS"ADULT PERSON IN CHARGE" FOR MARIE ELENA GUNTER AT 64 OLD MILL ROAD, DILLSBURG, PA 17019. MICHAEL I•NOVAN, DEPUTY SHERIFF COST: $64.43 SO ' ► - " -S, January 13, 2014 RICHARD P K i RLEBER, SHERIFF COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sheila E.Cook,Notary Public City of York,York County My Commission Expires Feb.1,2017 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES NOTARY Affirmed and subscribed to before me this ` / / 13TH day of JANUARY 2014 _ .ice ; , MY r F:\FILES\Clients\11381 Donley\11381.7\11381.7.10.default.wpd r it U TI 11 Ll fi r ‘ Christopher E. Rice, Esquire 23' FEB 14 pH 2: s. MARTSON LAW OFFICES CUMSzo D UUU I.D. No. 90916 PENNSYLVANIA Aaron S. Haynes. Esquire I.D. No. 307746 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ERIC DONLEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2013 - 6783 CIVIL TERM NATHAN STRUNK, AUTUMN MASON, : AND MARIE ELENA GUNTER, Defendants • PRAECIPE TO THE PROTHONOTARY: Please enter default judgment in the above-captioned action in favor of Plaintiff and against Defendants, Nathan Strunk, Autumn Mason, and Marie Elena Gunter, in the amount of$3,938.49 plus costs of suit,interest,any additional damages discovered hereafter,for failure to file an Answer to Plaintiffs Complaint. I do hereby certify that written notice of intention to file this Praecipe was mailed to Nathan Strunk,Autumn Mason, and Marie Elena Gunter, on January 21, 2014, which date is subsequent to the date default occurred and at least ten (10) days prior to the date of this Praecipe. MARTSON LAW OFFICES By: e---4-%4 1�-- Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 /6 a) pal,44 (717) 243-3341 Dated: �j _� �� Attorneys for Plaintiff a ,, d:1 99,r" Olt 3 0/6 3fr wrA F'.FILES\Clients\11381 Donley\11381.7\11381.7.IOdaynoticeswpd Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Aaron S. Haynes. Esquire I.D.No. 307746 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ERIC DONLEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2013 - 6783 CIVIL TERM NATHAN STRUNK, AUTUMN MASON, . AND MARIE ELENA GUNTER, • Defendants TO: NATHAN STRUNK DATE OF NOTICE: January 21, 2013 64 Old Miller Road Dillsburg, PA 17019 IMPORTANT NOTICE 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 MARTSON LAW OFFICES By �'t--- Christopher E. Rice, Esquire I.D. No. 90916 This is a debt collecting firm attempting to collect a debt for Eric Donley. Any information obtained will be used for that purpose. Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D.No. 90916 Aaron S. Haynes. Esquire I.D. No. 307746 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ERIC DONLEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. :No. 2013 - 6783 CIVIL TERM NATHAN STRUNK, AUTUMN MASON, . AND MARIE ELENA GUNTER, • Defendants TO: AUTUMN MASON DATE OF NOTICE: January 21,2013 64 Old Miller Road Dillsburg, PA 17019 IMPORTANT NOTICE 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 MARTSON LAW OFFICES By 4 �'--_ Christopher E. Rice, Esquire I.D.No.90916 This is a debt collecting firm attempting to collect a debt for Eric Donley. Any information obtained will be used for that purpose. Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Aaron S. Haynes. Esquire I.D. No. 307746 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ERIC DONLEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2013 - 6783 CIVIL TERM NATHAN STRUNK, AUTUMN MASON, : AND MARIE ELENA GUNTER, • Defendants TO: MARIE ELENA GUNTER DATE OF NOTICE: January 21,2013 64 Old Miller Road Dillsburg, PA 17019 IMPORTANT NOTICE 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717)249-3166 MARTSON LAW OFFICES By C IL Christopher E. Rice, Esquire I.D. No. 90916 This is a debt collecting firm attempting to collect a debt for Eric Donley. Any information obtained will be used for that purpose. Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Aaron S. Haynes. Esquire I.D. No. 307746 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ERIC DONLEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2013 - 6783 CIVIL TERM NATHAN STRUNK, AUTUMN MASON, : AND MARIE ELENA GUNTER, Defendants . COMMONWEALTH OF PENNSYLVANIA ) : SS COUNTY OF CUMBERLAND ) Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he is an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY&FALLER,attorneys for the Plaintiff in the above captioned matter and that pursuant to the provisions of the Pennsylvania Rules of Civil Procedure,a notice of intention to enter default judgment against Defendants Nathan Strunk, Autumn Mason, and Marie Elena Gunter, was given to them by mail on January 21, 2014. est.r.,,Z C le-- Christopher E. Rice, Esquire Sworn to and subscribed before me this /la day of February, 2014. 1 , /l Ofacel. Nt to i Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Mary M.Price,Notary Public Carlisle Boro,Cumberland County y15 My Commission Expires Aug. MEMBER,PENNSYLVANIA ASSOCIATION Of NOTARIES CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY& FALLER,hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Nathan Strunk 64 Old Miller Road Dillsburg, PA 17019 Autumn Mason 64 Old Miller Road Dillsburg, PA 17019 Marie Elena Gunter 64 Old Miller Road Dillsburg, PA 17019 MARTSON LAW OFFICES By M.ry�i . Price 10 E. t High Street Carlisle, PA 17013 Dated: 00 y/i This is a debt collecting firm attempting to collect a debt for Eric Donley. Any information obtained will be used for that purpose. Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Aaron S. Haynes. Esquire I.D. No. 307746 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ERIC DONLEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2013 - 6783 CIVIL TERM NATHAN STRUNK, AUTUMN MASON, : AND MARIE ELENA GUNTER, Defendants TO: NATHAN STRUNK NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the /y day of February,2014, the following Judgment was entered against you in the above-captioned action: in the amount of$3,938.49 plus costs of suit, interest, any additional damages discovered hereafter, for failure to file an Answer to Plaintiffs Complaint. Date: •/y-/�/ .� Prot tart' I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Nathan Strunk 64 Old Miller Road Dillsburg, PA 17019 Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Aaron S. Haynes. Esquire I.D. No. 307746 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ERIC DONLEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2013 - 6783 CIVIL TERM NATHAN STRUNK, AUTUMN MASON, : AND MARIE ELENA GUNTER, • Defendants TO: AUTUMN MASON NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the ill day of February,2014, the following Judgment was entered against you in the above-captioned action: in the amount of$3,938.49 plus costs of suit, interest, any additional damages discovered hereafter, for failure to file an Answer to Plaintiff s Complaint. Date: •I y'/� '� Prothonotary I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Autumn Mason 64 Old Miller Road Dillsburg, PA 17019 Christopher E. Rice, Esquire MARTSON LAW OFFICES I.D. No. 90916 Aaron S. Haynes. Esquire I.D. No. 307746 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ERIC DONLEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2013 - 6783 CIVIL TERM NATHAN STRUNK, AUTUMN MASON, : AND MARIE ELENA GUNTER, Defendants • TO: MARIE ELENA GUNTER NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the /y day of February,2014, the following Judgment was entered against you in the above-captioned action: in the amount of$3,938.49 plus costs of suit, interest, any additional damages discovered hereafter, for failure to file an Answer to Plaintiffs Complaint. Date: • /11/1/ w ' Proth I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Marie Elena Gunter 64 Old Miller Road Dillsburg, PA 17019