HomeMy WebLinkAbout14-0222 COMMONWEALTH OF PENNSYLVAN4A
COURT OF COMMON PLEAS NOTICE OF APPEAL
9th Judicial District, County Of Cumberland FROM
MAGISTERIAL DISTRICT JUDGE JUDGMENT
COMMON PLEAS No. /'/ - d_c -c-- „v../
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District
Judge on the date and in the case referenced below.
NAME OF APPELLANT MAG.DIST.NO. NAME OF MDJ
Lisa Haag MDJ 09-3-04 KATHRYN H. SILCOX
ADDRESS OF APPELLANT CITY STATE ZIP CODE
404 VENICE AVENUE CARLISLE PA 17015
DATE OF JUDGMENT IN THE CASE OF(Plaintiff) (Defendant)'
January 6, 2014 LEIBY'S M.H.C. Lisa Haag
DOCKET No. SIGNATURE OF APPELLANT OR ATTORNEY 0 AGENT
MJ-09304-LT-0000180-2013 ' a
This block will be signed ONLY when this notation is required under Pa. I _..ell-nt was CI nt ( ee a. R. P.D.J. No. 1001(6) in action
R.C.P.D.J. No. 1008B.
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
. 14,eiCCI ..glAjj,..
' (20)days after filing the NOTICE of APPEAL.
Lori 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
Enter rule upon LEIBY'S M.H.C. appellee(s),to file a complaint in this appeal
Name of appellee(s)
(Common Pleas No. )11 — )ac)_ /2,\/...,1 )within twenty(20)days after service of rule or suffer en ry If judgment of non pros.
i
j)t. Si ature o a.;ellant 0 -ttorney or agent
RULE: To LEIBY'S M.H.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) ►he date of service of this rule if service was by mail is the date of the maili
DatP:, 20� ') ^ i:' .!1"1_I;,.:1€'1 W -
- i 't a,.a a9 '''
�' +/,�///�� Signature of Prothonotary or Deputy
. i ��� Yii� 6.� ;''dT )j t.,
YOU MUST INCLUDE A COPY OF THE NOTIC OF,,JgDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
AOPC 312-05 tS Ill Notice of Appeal Page 1 of 2
COMMONWEALTH OF PENNSYLVANIA Notice Of Judgment/Transcript
COUNTY OF CUMBERLAND
r.�
Residential Lease
Mag. Dist. No: MDJ-09-3-04 Leiby'S M.H.C..
MDJ Name: Honorable Kathryn H. Silcox
V.
Address: 5275 East Trindle Road Lisa Haag .
Suite 110
Mechanicsburg, PA 17050
Telephone: 717-697-2201
Lisa Haag Docket No:. MJ-09304-LT-0000180-2013
404 Venice aye Case Filed: 12/27/2013
Carlisle, PA 17015
Disposition Details
Grant possession. Yes
Grant possession if money judgment is not satisfied by the time of eviction. No
Disposition Summary . cross
Docket No Plaintiff Defendant Disposition Disposition Date
MJ-09304LT-0000180-2013 Leiby'sM.H.C. Lisa Haag Judgment for Plaintiff 01/06/2014
Judgment Summary
Participant Joint/Several Liability Individual Liability Amount
Leiby's M.H.C. $0.00 $0.00 $0.00
Lisa Haag $0.00 $1,5x9.32 $1,589.32
Judgment Finding (*PostJudgment)
In the matter of Leiby's M.H.C.vs. Lisa Haag on MJ-09304-LT-0000180-2013, on 1/06/2014 the judgment.was awarded as follows:
The amount of rent per month,as established by the Magisterial District Judge,is$363.00
Judament Component Joint/Several Liability Individual Liali tv Deposit Applied Amount
Rent in Arrears $0.00 $1,454.65 $1,454.65
Filing Fees $0.00 $97.50 $97.50
Costs $0.00 $5.00
$5.00
Server Fees $0.00 $32.17 $32.17
Grand Total: $1,589.32
Portion of judgment for physical damages arising out of residential lease: $0.00
MDJS 315A
Pagel of 3 Printed:01/06/2014 1:07:53PM
Leiby's M.H.C. Docket No.: MJ-09304-LT-0000180-2013
V.
Lisa Haag
IN AN ACTION INVOLVING A RESIDENTIAL LEASE,ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION
WITHIN TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF
COURT OF THE COURT OF COMMON PLEAS,CIVIL DIVISION. AN APPEAL MUST BE FILED WITHIN THIRTY DAYS IN RESIDENTIAL LEASE
ACTIONS INVOLVING A VICTIM OF DOMESTIC VIOLENCE. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT,IF ANY.
IN ORDER TO OBTAIN A SUPERSEDEAS,THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER
OF THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED.HOWEVER,LOW-INCOME AND/OR
SECTION 8 TENANTS SHOULD REFER TO Pa.R.C.P.M.D.J.NO.1008 OR 1013 FOR DIFFERENT PROCEDURES REGARDING THIS DEPOSIT.
IF A PARTY WISHES ONLY TO APPEAL THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE,THE PARTY HAS
30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF
COURTS OF THE COURT OF COMMON PLEAS,CIVIL DIVISION.
THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THE 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 The Honorable Silcox
I certify that this is a true and correct copy of the record of the proceedings containing the judgment.
Date Magisterial District Ju
j
MDJS 315A Page 2 of 3 Printed:01/06/2014 1:07:53PM
Leiby's M.H.C. Docket No.: MJ-09304-LT-0000180-2013
V.
Lisa Haag
,Participant List
Plaintiff(s)
Leiby's M.H.C.
7075 Carlisle Pike
Carlisle, PA 17015
Defendant(s)
Lisa Haag
404 Venice ave= -
Carlisle, PA 17015
MDJS 315A Page 3 of 3 Printed:01/06/2014 1:07:53PM
i
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION — LAW
LEIBY'S M.H.C.,
Plaintiff )
V. ) No.
LISA HAAG, ) rnC -
Defendant ) -Z_r rl
CO -D
Petition for Waiver of Costs
1. I am the Defendant in the above matter and because of my financial condition,4am�W— able
to pay the fees and costs of prosecuting or defending this action or proceeding.
2. 1 am unable to obtain funds from anyone, including my family and associates, to pay the
costs of litigation. I represent that the information below relating to my ability to pay the fees and
costs is true and correct:
(A) NAME: Lisa Haag
ADDRESS: 404 Venice Avenue, Carlisle, Pa 17015
(B) EMPLOYMENT:
If you are presently employed, state:
EMPLOYER: Pheaa
ADDRESS: 1200 North 7Th Street, Harrisburg, PA 17102
SALARY OR WAGES PER MONTH: $ 1,473
TYPE OF WORK: CUSTOMER SERVICE REPRESENTATIVE 1
If you are presently unemployed, state:
DATE OF LAST EMPLOYMENT:
SALARY OR WAGES PER MONTH:
TYPE OF WORK:
(C) OTHER MONTHLY INCOME WITHIN THE LAST TWELVE (12) MONTHS:
BUSINESS OR SELF-EMPLOYMENT: $ 0
INTEREST OR DIVIDENDS: $ 0
PENSION OR ANNUITIES: $ 0
SOCIAL SECURITY OR S.S.I.: $ 0
SUPPORT: $ 0
UNEMPLOYMENT COMPENSATION: $ 0
WORKER'S COMPENSATION: $ 0
Petition for Waiver of Costs Page 2 of 4
WELFARE: $ 236 (Food stamps: ALL
YEAR)
OTHER(Please specify): $ 0
(D) OTHER MONTHLY CONTRIBUTIONS TO HOUSEHOLD SUPPORT:
SPOUSE'S NAME (if living together): (Not applicable)
If your spouse is employed, state:
EMPLOYER:
SALARY OR WAGES PER MONTH:
TYPE OF WORK:
CONTRIBUTIONS FROM CHILDREN: (None)
CONTRIBUTIONS FROM PARENTS: (None)
OTHER CONTRIBUTIONS: (None)
(E) PROPERTY OWNED:
CASH: $20
CHECKING ACCOUNT: (None)
SAVINGS ACCOUNT: $ 12
_. CERTIFICATES OF DEPOSIT, STOCKS, BONDS: (None)
REAL ESTATE/ HOME: PRESENT VALUE: $4,000 (5S7-
AMOUNT STILL OWED: $
MOTOR VEHICLE: (None)
OTHER: (None)
(F) DEBTS AND OBLIGATIONS PER MONTH:
MORTGAGE/RENT: $ 363 WATER/SEWER: $ 70
ELECTRIC: $ 225 TELEPHONE: $ 0
OIL/GAS/HEAT: $ 130 CABLE: $ 0
FOOD: $ 236 CLOTHING: $ 50
CHILD SUPPORT: $ 0 CHILD CARE: $ 0
TRANSPORTATION: $ 100 MEDICAL EXPENSES: $ 0
LOAN PAYMENTS: $ 270 CREDIT CARD PAYMENTS: $ 0
INSURANCE: $ 50 MISCELLANEOUS: $ 0
(G) PERSONS DEPENDENT UPON YOU FOR SUPPORT:
CHILDREN (STATE NAMES AND AGES):
Name Age
Hunter Patrick 5 years
Petition for Waiver of Costs Page 3 of 4
OTHERS (STATE NAME, AGE AND RELATIONSHIP):
Name Age Relationship
(None)
3. 1 understand that I have a continuing obligation to inform the court of any improvement in
my financial circumstances which would permit me to pay the cost incurred with this case.
4. 1 verify that the facts stated in the foregoing Petition are true and correct to the best of
my knowledge, information and belief. Petitioner understands that false statements therein are
subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities.
Date: 1�
L A AAG, Detendiant
Petition for Waiver of Costs Page 4 of 4
" 1
1
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION —LAW
LEIBY'S M.H.C., )
Plaintiff )
V. ) No.
LISA HAAG, )
Defendant )
ORDER OF COURT
AND NOW this
day of 40M
it is hereby ORDERED that LISA HAAG, the above-named Defendant, be GRANTED leave to
proceed in forma pauperis in the above action. At this time, Defendant is relieved from paying the
initial filing fees and costs only. Defendant shall promptly notify the Court of any material change in
income or financial condition during the pendency of this action.
BY THE COURT:
J.
K.
-1, E,
11)14M
C. i,
Petition for Waiver of Costs Page 1 of 4
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CU%f&E,-) Ail
LVANIA l" ,
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 PENNSYLVANIA
COUNTY OF / ,,M I,t i /u") ;ss
AFFIDAVIT: I hereby(swear)(affirm)that I served
,y_aa-2-
a copy of the Notice of Appeal, Common Pleas No. , upon the Magisterial District Judge designated therein on
(date of service)`)Ill , 20 1 4 , ❑ by personal service V by(certified)(registered)mail,
iisender's receipt attached hereto, and upon the appellee, (name)use, off"
31 120 'It_I by personal services by(certified)(registered)mail,
sender's receipt attached hereto.
(SWORN'(AFFIRMEDIAND SUBSCRIBED BEFORE ME
THIS ii l DAY OF,JiM ,201Y
L--lbk-IVAL) e,E,Signature of official before w ovit was made at I.,affia t
/V o-f-6u'q
nee 0,vaacid/ . 1
My commission expires on 4Lfi- 20 v ,
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Mena D.Howsarel,Notary PubMc
Silver Spring Twp.,Cumberland County
My Commission Expires Oct.28,2017
£'.M3R.PENNSYLVANIA ASSOQAT{051 OF NOTARIES
AOPC 312A-05
U.S. Postal Service,.,
CERTIFIED MAIL, RECEIPT
(Domestic Mail Only;No Insurance Coverage Provided)
mr-1 For delivery info•mation visit our website at www.usps.com
U)
Er P117.,t
Postage $ ,1
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11111M
Certified Fee 1M
Postmark —
Return Receipt Fee VI
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,Endorsement Required) Here
Restricted Delivery Fee 111
`E,clorsement Required)
.=" -.btal Postage&Fees $
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Se.rtt To
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ci Street,Apt No.; 4/ .......
Box No.
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PS Foi m 3800.August 2006 See Reverse for Instructions
U.S. Postal Service .
CERTIFIED MAIL, RECEIPT
(Domestic Mail Only;No Insurance Coverage Provided)
For delivery information visit oar website at www.usps.com.,
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C,It•
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1.11
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!Street,Apt No,,
or BO Box No.
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PS Form 3800.August 2006 See Reverse for instructions
•
i
LEIBY'S M.H.C., LLC IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA_-
- r.3
Plaintiff, ~-
V. No. 14-222 ' ' W
:r_
LISA HAAGQ -;
=C:)
Defendant.
PRAECIPE FOR ENTRY OF APPEARANCE
Please enter the appearance of Barbara A. Darkes, Jerome P. DeSanto, and McNees
Wallace &Nurick LLC on behalf of Plaintiff, Leiby's M.H.C., in the above-captioned matter.
McNEES WALLACE &NURICK LLC
By
Barbara A. Darkes
I.D.No. 77419
Jerome P. DeSanto
I.D. No. 314637
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
Attorneys for Plaintiff, Leiby's M.H.C.
Dated: February 6, 2014
CERTIFICATE OF SERVICE
AND NOW, on this 6th day of February, 2014, I hereby certify that I have served a true
and correct copy of the within document, via first class mail postage paid as follows:
Lisa Haag
404 Venice Avenue
Carlisle, PA 17015
�:Jerome P. DeSanto
LEIBY'S M.H.C., LLC IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
V. No. 14-222
LISA HAAG m _
Defendant. '
NOTICE
C-
You have been sued in court. If you wish to defend against the claims set forton tiw
following pages, you must take action within twenty (20) days after this complaint and notice aife
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 plaintiff. You may lose money or property or other rights important to
you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Telephone Number 717-249-3166
McNEES ALLACE &NURICK, LLC
Y
` Barbara A. Darkes
I.D. No. 77419
Jerome P. DeSanto
I.D. No. 314637
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
Dated: February 6, 2014 (717) 232-8000
LEIBY'S M.H.C., LLC IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
V. No. 14-222
LISA HAAG
Defendant.
COMPLAINT
This matter concerns a breached lease agreement. Plaintiff, Leiby's MHC, LLC
("Leiby"), submits this Complaint for three reasons: (1) to evict Defendant Lisa Haag ("Ms.
Haag") from its mobile home park; (2) to recover unpaid rent from Ms. Haag; and (3)to recover
its attorneys fees and court costs, which Leiby has (and will) incur for having to sue Ms. Haag
for unpaid rent and eviction. In support of this Complaint, Leiby avers as follows:
1. Leiby owns a manufactured housing community in Carlisle, Cumberland County,
Pennsylvania.
2. Ms. Haag is an adult individual currently residing in that community.
3. Since Ms. Haag became a community resident in June 2011, Leiby has
consistently struggled exacting rent payments from her.
Background
4. This action is not the first suit that Leiby has brought against Ms. Haag for
eviction and past-due rent.
5. Ms. Haag became a community resident of Leiby's manufactured housing
community on June 15, 2011.
6. On that date, she and an individual named Shawn Patrick("Mr. Patrick") signed a
written lease agreement with Leiby (the "Lease"). A true and correct copy of the Lease is
attached to this Complaint as Exhibit A.
7. Under the Lease, Ms. Haag and Mr. Patrick agreed to pay monthly rent to Leiby;
together, their rent obligations consisted of:
a. a base rent amount of$335;
b. utility costs, which included trash recovery at $10 per month, water use at
an amount per month determined by sub-metered usage, and sewer use at
an amount per month determined by sub-metered usage; and
C. an extra occupant fee at $7 per month for their son.
8. In exchange for Ms. Haag and Mr. Patrick's promise to pay monthly rent, Leiby
granted them possession of a lot in its manufactured housing community— specifically, lot 213 at
404 Venice Avenue, Carlisle, PA 17015 (the "Leased Space").
9. By granting possession to Ms. Haag and Mr. Patrick, Leiby gave them the right to
place a manufactured home in the Leased Space and to reside inside of it; the two placed a
manufactured home in the Leased Space after signing the Lease.
10. During the course of the Lease, Ms. Haag and Mr. Patrick routinely missed
paying their monthly rent obligations on time; back rent accrued to $3,562.32 on April 1, 2013.
A true and correct copy of Ms. Haag's rent and payment history is attached as Exhibit B.
11. Then, in April 2013, Leiby sent a Notice to Quit the Lease to Ms. Haag and Mr.
Patrick ("Notice 1"); Notice 1, attached as Exhibit C, warned both lessees that failure to pay rent
when due within six months of the Notice would result in Leiby commencing an eviction
proceeding. Nevertheless, the two continued missing their rent payments.
2
12. Near mid-May 2013, after failing to pay rent for several months, Ms. Haag and
Mr. Patrick owed Leiby an amount exceeding $3,800.
13. In response to their failure to pay, Leiby sued Ms. Haag and Mr. Patrick for
unpaid rent and possession in the Magisterial District Court of Cumberland County. On May 28,
2013, the judge in that court rendered judgment in Leiby's favor, holding Ms. Haag and Mr.
Patrick jointly and severally liable for $3,870.07 in rent due and for $167.67 in filing fees and
costs associated with the suit; that same judge also granted Leiby possession of the Leased
Space. A true and correct copy of the Notice of Judgment dated May 28, 2013 is attached as
Exhibit D.
14. On June 7, 2013, Ms. Haag appealed' that decision to the Court of Common Pleas
of Cumberland County. Leiby, then, under Pa. R. C. P. M. D. J. No. 1004, filed a complaint with
the Court in response to Ms. Haag's appeal ("Suit V).
15. After the complaint was filed, however, on October 2, 2013, Ms. Haag paid a
portion of her past-due rent and the costs and fees imposed on her by the Magisterial District
Judge's May 28, 2013 judgment(in total, she paid approximately $5,771.00). She then paid an
additional $181.50 on October 14, 2013. As such, Leiby stopped prosecuting Suit 1 against Ms.
Haag; it agreed to grant her continued possession of the Leased Space, but only if she abided by
the terms of the Lease and paid off, by the end of October 2013, the remaining $470.89 in rent,
fees, and costs still due and owing to Leiby.
16. Leiby memorialized these expectations in a letter dated October 17, 2013. As an
aside, the letter also mentions a new lease, removing Mr. Patrick as co-lessee (upon information
and belief, he moved out of the Leased Space in May 2013) and removing the extra occupant fee
By this time,upon information and belief,Mr. Patrick had stopped living in the Leased Space.
3
i
from Ms. Haag's payment obligations (without Mr. Patrick living in the Leased Space, the
Leased Space contained only two people—Ms. Haag and her son— so the Leased Space was no
longer subject to an extra occupant fee). Leiby drafted this new lease, but Ms. Haag never
signed it, even though Leiby asked that she do so. A true and correct copy of the October 17,
2013 letter is attached as Exhibit E.
Missed Payments Since Suit 1
17. Soon after Leiby granted Ms. Haag permission to remain on the Leased Space,
she breached the Lease (again) and the expectations described in the October 17, 2013 letter: she
failed to pay off the outstanding $470.89 due and owing to Leiby; and she continuously failed to
make her rent payments on time.
18. By November 12, 2013, her back payments due accrued to $770.27.
19. In response, Leiby sent a second Notice to Quit the Lease to Ms. Haag ("Notice
2"). Notice 2, attached as Exhibit F, warned Ms. Haag that failure to pay rent when due within
six months of the Notice would result in Leiby commencing an eviction proceeding.
Nevertheless, Ms. Haag continued missing her rent payments.
20. By December 27, 2013, Ms. Haag's back payments accrued to approximately
$1,091.65.
21. As such, on December 27, 2013, Leiby, again, sued Ms. Haag for unpaid rent and
possession in the Magisterial District Court of Cumberland County.
22. On January 6, 2014, the Magisterial District Judge rendered judgment in Leiby's
favor, holding Ms. Haag liable for $1,454.65 in rent due and $134.67 for filing costs and fees
associated with the suit; the same judge also granted Leiby possession of the Leased Space. A
4
true and correct copy of the court's Notice of Judgment is attached to this Complaint as Exhibit
G.
23. Ms. Haag appealed the judgment to this Court on January 8, 2014.
24. In response to her appeal, Leiby files its Complaint under Pa. R. C. P. M. D. J.
No. 1004.
25. Ms. Haag continues to occupy the manufactured home on the Leased Space, but
continues her failure to pay rent.
26. The amount owed to Leiby has increased since the Magisterial District Judge
granted judgment on January 6, 2014. As of this filing, the aggregate amount of past-due rent,
filing fees, and costs is $2,073.45.
COUNT
EVICTION
27. The averments of the preceding paragraphs are incorporated herein by reference.
28. Ms. Haag has repeatedly failed to make her monthly rent payments; as such, Ms.
Haag, for a second and subsequent time within six months, breached the Lease and violated the
rules of Leiby's manufactured housing community by repeatedly failing to pay monthly rent.
29. Following the November 12, 2013 Notice advising Ms. Haag that she was in
breach of the Lease and in violation of community rules, and that Leiby would pursue eviction if
she failed to timely pay rent, Ms. Haag, has again, and within six months of the Notice and her
initial breach, breached the Lease and violated community rules by failing to pay rent on time.
30. Leiby has complied with all of its Lease and legal obligations.
31. Under section 398.3 of the Manufactured Home Community Rights Act, Ms.
Haag may be evicted for (a) a second or subsequent violation Leiby's manufactured housing
rules and/or (b) not pay paying rent. See 68 P.S. § 398.3(a)(1)(2).
5
WHEREFORE, Plaintiff Leiby's MHC, LLC requests that the Court enter judgment
evicting Defendant Lisa Haag from the Leased Space and granting possession to Leiby; and that
the Court enter judgment in favor of Leiby and against Defendant Lisa Haag in the amount of
Leiby's costs, expenses, and reasonable attorneys fees, together with such further relief as the
Court deems just.
COUNT II
BREACH OF CONTRACT
32. The averments of the preceding paragraphs are incorporated herein by reference.
33. Ms. Haag has breached the lease agreement by repeatedly failing to pay monthly
rent.
34. Leiby has complied with all of its Lease and legal obligations.
35. Under section 250.301 of the Landlord Tenant Act, a landlord may recover rent
owed to it, plus interest, by bringing an action for breach of contract. See 68 P.S. § 250.301.
36. Since the Magisterial District Court's judgment granting Leiby damages for rent
due, Defendant Lisa Haag has remained in possession and continues to remain in possession of
the Leased Space by occupying that lot with a manufactured home.
WHEREFORE, Plaintiff Leiby's MHC, LLC requests that the Court enter judgment
holding Defendant Lisa Haag liable for rent and costs due to Leiby in the amount of$2,073.45
(which includes all rent amounts, filing fees, and costs outstanding as of this filing), interest that
has accrued on the Magisterial District Court's judgment of$1,589.32, ongoing monthly rental
charges until the home is removed from the Leased Space, and for the amount of Leiby's costs,
expenses, and reasonable attorney fees, together with such further relief as the Court deems just.
6
COUNT III
UNJUST ENRICHMENT
37. The preceding paragraphs are incorporated herein by reference.
38. Defendant Lisa Haag has benefited from remaining in possession of the Leased
Space.
39. Defendant Lisa Haag has been unjustly enriched by remaining in possession of
the Leased Space without paying rent to Leiby.
WHEREFORE, Plaintiff Leiby's MHC, LLC requests that the Court enter judgment
holding Defendant Lisa Haag liable for rent and costs due to Leiby in the amount of$2,073.45
(which includes all rent amounts, filing fees, and costs outstanding as of this filing), interest that
has accrued on the Magisterial District Court's judgment of$1,589.32, ongoing monthly rental
charges until the home is removed from the Leased Space, and for the amount of Leiby's costs,
expenses, and reasonable attorney fees, together with such further relief as the Court deems just.
COUNT IV
ATTORNEYS FEES AND OTHER COSTS AND EXPENSES
40. The preceding paragraphs are incorporated herein by reference.
41. Paragraph 18 of the Lease states: "Community Owner shall charge in accordance
with the law, any attorney's fees, courts, and other reasonable costs incurred by the Community
Owner as a result of upholding, enforcing, or obtaining compliance of this Rental/Lease
Agreement or the Community Standards as a result of a breach or default on behalf of the
Resident."
42. This Paragraph 18 entitles Leiby to any attorneys fees, court costs, and other
reasonable costs that Leiby has had to incur in suing Ms. Haag for past-due rent and eviction,
including, but not limited to: the May 28, 2013 action before the Magisterial District Court of
7
Cumberland County; the January 6, 2014 action before the Magisterial District Court of
Cumberland County; and the above captioned-action.
WHEREFORE, Plaintiff Leiby's MHC, LLC requests that the Court enter judgment
holding Defendant Lisa Haag liable for any attorneys fees, court costs, and other reasonable costs
that Leiby has had to incur in suing Ms. Haag for past-due rent and eviction, together with such
further relief as the Court deems just.
McNEES WALLACE &NURICK, LLC
B
�2
Barbara A. Darkes
I.D. No. 77419
Jerome P. DeSanto
I.D. No. 314637
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
Attorneys for Plaintiff, Leiby's Mobile Home
Community, LLC
Dated: February 6, 2014
8
VERIFICATION
Subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to
authorities. I hereby certify that I am the Property Manager ofLeiby's MI IC. LLC at 7075
Carlisle Pike, Carlisle, Pennsylvania 17015, and that I azn authorized to verify the foregoing
document on its behalf, and that the facts set forth in the foregoing document are true and correct
to the best of my knowledge or infonnation and belief.
.....__.........
_. _
Beth Chaves
Dated:
EXHIBIT
A
n
t LEIBYS
Manufactured Rome Community ;. .._.
7075 CARLISLE PIKE CARLISLE,PA 17015
717-697-1321
PENNSYLVANIA LOT RENTAL/LEASE AGREEMENT
This is a Rental Agreement made and entered into this / '- day of
by and between
LRIBYS MH , LLC, , ere i filer"Community Owner",and ,
tA 144,1 hereinafter "Resident",
in consi er i n of t e m tua covenants hereinafter expressed,and incompliance with the requirements of
"The Mobile Home Rights ct of 1976`' also known as "Act 261" governing the relationship between
Resident and Community Owner,the parties hereto agree as follows:
1. DESCRIPTION OF PROPERTY TO BE RENTEDA EASED:
Community Owner hereby rents unto Resident and Resident rents from Community Owner, Manufactured
Home Space; Lot#: and address °`, ks to
be used and occupied only for residential purposes.
The Resident rents a plot of ground within the community described as follows.
Approximate Length(These are only approximate and are not legally binding) ""
The eround from the inner edge of the front sidewalk or roadway to the lot line to the rear of the mobile
home.
Approximate Width(These are only approximate and are not legally binding): -,,i
2. TERM
This is a Month-to-Month Rental Agreement:
The term of the Rental/Lease Agreement shall commence the �day of 2() .
and continue in full force and effect for a period of one month and month-to-month thereafter starting on the
first day of the month and concluding on the last day of the month. However, either Community Owner or
Resident may terminate this Rental/Lease Agreement as of the end of the initial term or any extension
thereof by giving at least Thirty (30) days' prior written notice to the other. In the event Resident occupies
the aforesaid space prior to the beginning date, the rent for such prior occupancy shall be prorated and all
covenants!obligations shall be in effect during the prorated period. Occupancy is defined as the date this
Re t 1/Lease Agr ent is,
Resident's Si g g na re Date
r 4 o i r,—I , ,
CS' t, Signa rc Ua e
s . -
Residents Initials
3. RENTAL AMOUNT AND PAYMENT TERMS
Resident agrees to pay a monthly base lot rent tee of d -�> __ per month due can or before the first
day of each month without notice to the Community Owner. This amount is based on two oc-cupants per
home. Any more than two occupants per home will incur an additional charge per occupant. All rents and
rather payments will be made at the Community Office or a place designated by the Community Owner. All
rent will be made payable to L,eiby's MHC. When made, all payments will be applied to past due; amount,
first in the following manner: /sate, court, utility. and "other" roes first. COS payment second, and rent
payment last for that particular month which is most delinquent. If any portion of the base rent, COS,
Utilities. late/court fees, or"other" charges or assessments are not paid by the fifth(5`h)of the month, a late
[cc of Fifty (50.W) dollars will be charged for that month. Community Owner reserves the right to take
legal action against the Resident for non-payment of rent after the first (1") of the month should the rent~
not be paid AND the situation warrants this action. A Twenty Five (25) dollar fee will be charged on all
checks that are returned by a bank for any reason. Should a resident have two cheeks returned by a bank for
any reason during the period of the lease, Community Owner will require future payments made by or on
behalf of that Resident to he either certified check or money order only. All rents are to be paid by a check
or money order only. No cash will be accepted at the Community office. Rents will only be considered paid
when they are in the Community office.
Other monthly charges due on or before the First (I')of the month include but are not limited to:
t I'1LITIES:
All charges are based on a monthly charge unless otherwise noted. An administrative fee, mailing fee,
billing fee, meter reading fee,or similar fee may be charged and/or included with the utility charges/fees.
Water: Included in base rent
A flat fee of _per month
Resident billed directly by utility company
Sub-metered,usage billed to the Resident based on the amount of gallons used
Sewer: Included in base rent
flat fee of per month
Resident billed directly by utility company
Sub-metered, usage billed to the Resident based on the amount of gallons used
Trash: Included in base rent.
A flat fee of r=. a,_ per month
Resident billed directly by utility company./waste hauler
Taxes: Included in the base rent
_A flat fee of` _per month
Resident billed directly by the taxing authority unless otherwise noted
Yet Fee: A flat fee,of per month per pet
Ot.hcr: a
PENNSYLVANIA LEASE / LEIBYS
t
xesiuents inivats_.
Any charges billed to the Resident as described and permitted by this Rental/lx=w Agreement and or the
Community Standards, will be due when the next rent installment is due and will be considered as part of
the rent due.
Total monthly rents/eharges due and owing on or before the First(I')of the month for lot
# known as
and Rented by
is$ per month.
List other monthly charges to be billed to Resident based on usage:
Community Owner may at it's sole discretion adjust monthly rents and or charges upon a Thirty(30)day
written notice of such to the Resident.
4. SECURITY DEPOSIT
Upon execution of the Rental/Lease Agreement,Resident agrees to pay Community Owner the first month's
rent in advance in the amount as stated herein, and a security deposit in the amount of$ ; °E The
security deposit will not be returned to the Resident if the Resident does not give;Community Owner a
minimum of Thirty (30)days written notice of the Residents intentions to terminate the Lease Agreement.
Resident shall not use any part of the,security deposit as payment of rents or other charges until the
Rental/Lease Agreement has been terminated by evidence of the�Rcsidents absence from the Community
and/or removal of the home from the lot described.by the terms of this Renta tLease Agreement. The
security deposit may be applied by the Community Owner towards,any rent delinquency or other charges
which may have occurred at the termination of this Rental/Lease Agreement. It is the responsibility of the
Resident to provide the Community Owner with a forwarding address for the return of any monies which
might be owed.
Total amount of Security Deposit on file: $
5. MANUFACTURED HOME DESCRIPTION
Resident agrees to rent the lot on which to place his/her manufactured home of the following description on
the space agreed to above:
Make: Year _S.i7e
Color d _
Serial Number
Model
Legal owners name as it appears on the title
Finance Company(If any).. y ___.__.____ Contac<number
Residents Initials 4�1
t
6. USE OF RENTED SITEICOMMON AREAS
A Occupancy-The Resident shall occupy the demised premises only for the use of placing a manufactured home
for his/her own dwelling purposes. Occupancy will be limited to two(2) persons per bedroom.The manufactured home
may only be occupied by those individuals who appear on the rental application, the lease agreement, community
standards/rules,and have been approved to live in the community. The primary individual on the-title must reside in the
manufactured home.
B Resident information-The resident agrees to provide the Community Management with any updated.information
pertaining to al l occupants residing in the mobile home and other information,deemed necessary by Community Owner.
C Sublease/Subletting- The Resident shall not assign this Rental/Lease Agreement or sublet the premises or any
part thereof. The site shall be occupied by only those person(s) whose names appear on the Rental/Lease Agreement.
The Resident shall not put the manufactured home or the premises in the possession of another party while the home is on
the rented lot without the prior written approval of the Community Owner.Community Owner may at its sole discretion
rent homes within the Community that are Community owned.
D Resident shall not make any alterations, additions, or,improvements on any space or any manufactured home
located therm without first obtaining the prior written approval of the Community Owner pursuant to the procedures
more fully set forth in the Community Standards.
E All Residents, Guests, or invitees, shall act in accordance and compliance with all Federal, State, and Local
statutes, ordinances,rules and regulations,Community Standards, and laws.A violation of any of these aforementioned
will be deemed a violation of your RentallLease Agreement.
F All pets must be approved and registered with the Community Manger PRIOR.to the pet being allowed within the
Community.Resident agrees to comply with all pet stipulations and rules set forth by the Community Standards including
the completion and signing of a pet agreement.
G No Resident shall interfere with another residents desire to enjoy the Community in a lawful and respective
mariner. Loud and profane language will not be permitted in the Community. Stereos and televisions will be kept to a
level as not to disturb or be heard on another residential lot within the community. The playing of"Loud" musical
instruments such as drums are strictly prohibited. The Resident is responsible for all actions of their children, guests, or
invitees while in the Community.
7. VEHICLES
All vehicles within the community must be registered, currently licensed,have current valid inspection,operable, in
good repair,and properly insured. All vehicles and conduct pertaining with or to vehicles as outlined in section Eight(8)
of the Community Standards will be strictly enforced and Resident agrees to abide by all terms and conditions contained
therein.
8. SALE OR TRANSFER OF OWN'ERSMPMTLE
All Residents of the Community must be approved prior to the purchase of a home within the Community by the
Community Management. Residents are required to give a written Thirty (30) day notice of intent to sell the Residents
home. Residents and or prospective Residents agree(s) to all terms set forth in sections One(1), Two(2),Three(3), and
PENNSYLVANIA LEASE / LEIBYS 1-1HC , LLC1
c"' E
xesiaents initials
Four(4)of the Community Standards pertaining to the resale and transfer of ownership of a home.
9. HOME AND LOT MAINTENANCE
All residents must keep their lot and home in a well kept manor. The lot must be maintained in accordance with the
Community Standards so as to present a neat and attractive site. Failure of the tenant to do so may result in the
Community Owner performing such up keep at the Residents expense. All items not in use must be stored away. The
patio and decks are for l awn furniture,barbeque grills, and the like. This area is not to,be used as open storage.Homes
and any accessory buildings/structures are to be kept in a good condition. The f exterior of any structure needs
maintenance from time to time which is the sole responsibility of the Resident.Any Resident wishing to paint their home
or being required to by the Community Owner shall do so with an approved color.Failure to maintain the exterior of your
home is a breach of lease. No trash or rubbish will be permitted to accumulate around your home or on your lot-
Any plantings or digging of any kind must be doge after written consent of the Community Owner. Anyone who
foregoes this consent, will be held liable for any damage to underground utilities and holds the Community'Owner and
their agents harmless. If any Resident has a contractor working on their lot or home,said contractor must have liability
insurance coverage for such work_ Resident agrees to notify Community Owner of any defective conditions in the
Community immediately.
10. GENERAL
A) Resident agrees to dispose of all rubbish, garbage and other waste materials in a clean and sanitary manner.
Resident agrees to pay for telephone, electricity,takes, oil an&propane>-and garbagettrash collection charges due for
services to the premises during the term of this Rental/Lease.}'Agreement or any extension thereof. Resident agrees to be
responsible for the connection and maintenance of electric lines between the service pole and the manufactured home.
B)If the manufactured home located upon the lot is rented to the Resident,the Resident is responsible for keeping the
home and all of its parts including,but not limited to,plumbing fixtures,cooking„refrigeration equipment,and electrical
fixtures in a rented manufactured home unit in a clean and sanitary condition. The Resident is responsible for the
exercise of reasonable care in their proper use. Batteries for the smoke detectors in the rented homes must be serviced
regularly by the Resident.
C:)All Residents,guest.'s,invitee's,or family members must abide by all of the Community Standards concerning the
use, occupation, and maintenance of the premises, either incorporated by reference in this Rental/Lease Agreement,
referenced in the Community Standards, or brought to Resident's attention at the time of the execution of this
Rental/Lease Agreement.
D)The Resident hereby agrees that he/she will abide by AND sign the Community Standards as attached hereto,and
incorporated herein by reference, as well as any additional or amended Rules which may be changed,altered,or enacted
with proper notice as required by law. Thirty (-10) days' written notice of the change in the Rules will be given to the
Resident prior to the effective date of the revisions. The Resident understands that violations of these Rules/Community
Standards shall constitute a breach of this Rental Agreement and be grounds for termination of the Renfiai/Leaase
Agreement. — – –
E)The Resident shall not permit others in the manufactured home unit without his/her consent nor shall the.Resident
allow others to willfully or wantonly disturb the peaceful enjoyment of the premises of other Residents and neighbors.
F)Guests staying with the Resident for a period of over ten(10)days must apply and be registered with Community
Management, and the length of the stay must be approved. All guests must abide by Community Standards, and any
infraction of the Community Standards will be considered grounds to require the guest to immediately leave the
Community. The Resident is responsible for the actions and conduct of invited guests and occupants. Any breach of the
Residents Initials ]
Rental/l,ease Agreement or the Community Standards by invited guests or occupants shall be deemed to be a breach by
the Resident and may constitute grounds for an action for summary possession or eviction.
G) The Resident agrees that the Community Owner and the Community Owner's agents, employees, or other
representatives, shall have the right to enter into and upon the said premises consisting of the lot which is the subject of
this RentaMease Agreement, or any part thereof, at all reasonable hours, for the purpose of examining the same or
making such repairs or alterations therein as may be necessary for the safety and preservation thereof. This clause shall
not be deemed to be a covenant with the Community Owner nor be construed to create an obligation on the part of the
Community Owner to make such inspections or repairs. If the Resident is also renting.the manufactured home,then the
Resident authorizes Community Owner, its agents, employees or other representatives to enter into the home for the
purpose of maintenance or to show the home to a prospective purchaser or renter after giving notice as required by law.
N)Resident may not place any aboveground or underground storage tanks on the premises without the prior written
consent of the Community Owner. It shall be the Resident's sole responsibility to comply with all existing and future
statutes,rules, regulations,ordinances,and orders related to the storage tanks(including pipes and equipment connected
thereto)on the premises,and to keep and maintain the tanks in good condition and repair,such that they do,not leak or
present any harm or threat of harm whatsoever to the Premises; the public safety and welfare, or the environment.
Resident shall indemnify and hold harmless Community Owner,from aid against any and all expenses,liabilities,or costs
of any kind or nature, including attorney's fees,arising out of,caused by,or related'°in any way to Resident's installation,
ownership,operation, maintenance, or closure of the storage,tanks. Upon termination of this Rental/Lease Agreement,
Community Owner may at its sole discretion require Resident to remove the tanks and clean up and restore the Premises
back to the original conditions_ A violation of this SMdon shatl constitute a material breach of this RentalnLease
Agreement. In addition to any other remedies available,upon Resident's failure to comply with this Section or obtain the
Community Owner's approval to maintain the tanlcs`on the Premises,Community Owner may,but is not obligated to,(1)
order the Resident to remove or repair the tank and'restore the site,(2)without waiving its right to indemnification or to
pursue any remedies available,remove or repair the tank and restore the property itself at the Resident's expense,and/or
(3) terminate this Rental Agreement. 'Community Owner shall have the right to inspect the Premises to ensure
compliance with this Section.
11. INSTALLATION
All new homes to the community must be installed to meet all local,,state,and federal building codes that apply.A
building permit is required and a third party inspection must be performed as a condition of occupancy whether the local
building codes office requires such inspections or not. A copy of said inspection and building permit must be provided to
the Community Owner on demand. Any contractor working in the Community is required to have insurance coverage in
an amount that is commonly deemed as acceptable for the type of work being completed.
a) All homes must have an approved footer system to prevent frost heave and meet all building codes and be set up
by a licensed contractor.
b) All homes must be tied down in accordance with the manufactures requirements or the UCC code which ever is
more stringent.
c) All homes must be skirted with materials specifically manufactured for use as mobile home skirting only. All
materials must be approved by the Community Owner prior to the installation of such materials.
d) Utilities must be hooked up in a workmanship like manor as to be neat and pass all building codes pertaining to
such installation. The water line must have a shut off valve at the home, a back flow preventer valve installed, and a
heating tape.
e) Steps(Which are considered a part of the home structure)must be built to meet local codes and must have a four
(4) toot by four(4)foot landing. Any deck larger than this must have approval from the Community Owner prior to the
construction of said steps/deck- The granting of a permit by a local building inspector does not represent permission by
the Community Owner to construct a non-compliant structure.
f)No deck,patio,or carport may be enclosed by any materials as to provide another room to the structure_
g)No fences are allowed on a Residents lot unless it is placed there by the Community Owner.
h) Additional structures (Sheds, gazebos, carports, etc) shall be held in strict compliance with the Community
Kesidents Initials
Standards.
12. TERMINATION OF THE RENTAL AGREEMENT
This Rental/Lease Agreement shall be terminated by either party with a Thirty(30)day written notice from the
date of service and in accordance with all applicable law. Failure on the Residents behalf to give written notice, will
negate any monies held as a security deposit from being returned to the Resident.A violation of the Lease Agreement or
of the "Community Standards"will be grounds for the termination of the Rentaltt,ease:Agreement It is agreed to by the
Resident that the premises will be returned to the Community Owner in the same condition or better condition than when
received with the exception of reasonable and ordinarily accepted wear.
13. ABANDONMENT OF HOME BY THE RESIDENT
If any manufactured home is left abandoned in this Community,for a,period of thirty(30)days or mote,the Community
Management may enter the home, secure any loose or movable appliancesJurnishing, materials or supplies, and move
the home to a storage area or other location at the Resident's expense. The home will.be considered abandoned if no one
is living in the home, the rent is not paid in full,and if any of the following,water,sewer,electricity, phone,TV cable,
and mail delivery,have been disconnected or services terminated.. The Community Owner will have no responsibility for
safeguarding the manufactured home or its contents`regardless of whether the home has been moved or not.Any Resident
who abandons their mobile home on our property,will be subject to all legal remedies available to Community Owner for
the removal of said home, clean up}of the lot, and all rents stilt owed on the Leased property until a time that the lot is
made to a condition of being able to be leased again. All rents, fees,and charges will continue to accrue as long as the
home remains on the rented lot.
14. REMOVAL OF HOME AT RESIDENT'S DECISION.
A. The Resident is required to submit to the office in writing,Thirty(30)days'prior to any home being moved,a notice
that the manufactured home is to be moved from the Community.If resident fails to give Community Owner a thirty(30)
day written notice,said resident will be charged for an additional months rent.
B. The Resident must advise the office who will be moving the home from the Community, the exact date it will be
moved, and who will be preparing the home for removal (disconnecting the water, sewer and electrical lines). The
Community Manager must give the final approval that all lines have been properly disconnected before the home may be
pulled off of the lot.
C. The manufactured home shall not be demolished on the IoL
D. All provisions of the Community Standards will be strictly enforced in reference to the removal of a home from the
Community.
15. REMOVAL OF MANUFACTURED HOME BY COMMUNITY OWNER
Management shall have the right to require the removal of any manufactured home when the following exists:
A. Home has been left in disrepair by the Resident after written notice was given to repair. (This is primarily in regard
to exterior condition of home,shed,awnings,porches,skirting,etc.)
Residents Initials ST
s
B. The rented lot is in disrepair in so far as items are stored haphazardly around yard and/or on porches, etc., after
written notice has been given to clean up.
C. Hazardous conditions exist and have not been corrected after written notice has been given in regard to, but not
limited to:electrical,plumbing,and heating systems.
D. The manufactured home is vacant even if the lot rental is still being paid and if the owner of the manufactured home
is not making a sincere effort to sell the home. A sincere effort to sell home would be: having home listed with any
service by signing a written agreement; placing classified ads in local papers on a regular basis to "sell by owner",and
having a"For Sale"sign displayed in the window
E. The manufactured home has been abandoned as more fully set forth in Section 3 of the Community Standards and
section 13 of the lease,Abandonment of Home by the Resident.
F. Community Owner has been granted summary possession by a court of competent jurisdiction.
16. DISCLOSURE STATFWNTS
Resident hereby states that he/she has been advised of the following:
A. That the Resident is aware of the specific identification of the site being rented.
B. That the Resident is aware of and accepts the amount of rent due for each monthly installment.
C. That the Resident is aware of and accepts the amount of any late°fee, returned check fee, or other assessment or
charge that may be levied against the Resident contained within the Lease Agreement.
D. That the Resident understands each service,facility, and utility servicethat the Community Owner will provide, and
that the Resident has had clearly identified the availability, capacity and connection fees for all utility services at the
proposed site in order to assure the proper and adequate installation of utilities and of the manufactured home.
E. That the Resident has received a description of any termination or renewal options as set forth in this Rental/Lease
Agreement
F. Resident hereby states that he/she has received the following parts of this Rental/Lease Agreement and understands
said parts and that the listed parts are incorporated herein and become a part of the RentaVLease Agreement as is fully set
forth herein:
Part I A copy of this RentaVLease Agreement
Part 2 A copy of L,eiby's MHC Community Standards
Part 3 A copy of Act 261 known as The Mobile Home rights Act.
17. NON-WAIVER
The acceptance of rent by the Community Owner is not deemed as a waiver of any rights or remedies for a breach or
subsequent breach by the Resident of this Rental/Lease Agreement or the Community Standards.
18 LEGAL FEES,COURT FEES,AND/OR ATTORNEY FEES
Community Owner shall charge in accordance with the law,any attorney's fees,court costs,and other reasonable costs
incurred by the Community Owner as a result of upholding, enforcing, or obtaining compliance of this Rental/Lease
Agreement or the Community Standards as a result of breach or default on behalf of the Resident.
Kesidents initials
19. SURVIVORSHIP
This Lease Agreement is binding upon the successors,assigns, heirs,lien holders,agents,executors and administrators
of the Resident.
20 COMMUNUrY STANDARDS(RULES AND REGULATIONS)
The Community Standards(Also known as the Rules and Regulations)are a condition of this Rental/Lease Agreement
and to which all residents,guest's,invitee's,and others must comply with as a condition.of occupancy.A BREACH OF
THE COMMUNITY STANDARDS IS A BREACH OF THIS RENTAI/LEA—M AGREEMENT AND MAY
SUILIEC'T THE RESIDENT FOUND TO BE IN pEFAULT OF'THESE STANDARDS TO EVICTION BY ANY
MEANS ALI4QWED BY LAW.All residents are responsible for the actions of their children,guest's,and invitee's:By
the resident signing of this lease, said resident acknowledges receipt of Community Standards;as they are written on the
date of signing and to fully comply with these Community Standards or any amended Standard that the Community
Owner may implement at a future time.
21. AMENDMENTS,CHANGES.UPDATES
Community Owner may at its discretion change, update, and/or amend any section of the Rental/Lease Agreement or
Community Standards with a thirty(34)day written notice to the Resident as required by law.
22. REQUIRED RESIDENT INSURANCE
Community Owner does not carry insurance to protect the resident or their property against loss including but not
limited to fire,thef) vandalism,criminal acts, acts of God,or other causes. Each resident is required to carry insurance
against loss and liability_Resident must provide proof of such insurance as a condition of occupancy.
23. NOTICES
Any contractual obligations or special permission/exemption of use must be in a written form from the Community
Owner. Any deviation of the Community Standards granted by Community Owner or the agent thereof must be in
writing.
24. APPLICATION OF RESIDENCY
All persons seeking residency in the Community are required to complete an application for residency.Any prospective
Resident who falsifies any part of the application document will be denied residency from the Community and if such
falsifications are discovered after residency has been granted, residency status will be revoked and the Resident will be
evicted from the community. Any one residing in the community without being granted approval by the Community
Owner will be considered a trespasser and be dealt with as such.
25. RESIDENTS PERSONAL PROPERTY
Community Owner shall not be responsible for any personal property left in the community upon termination,
surrender, or abandonment of the premises. Furthermore, Community Owner shall not be liable for the storage or
disposition of any residents personal property.
sp , j
Residents Initials_
26. COMMUNITY OWNERS LIABILITY
Community Owner shall not be liable to any Resident,.Residents invitees,guests,family,or employees of the premises
for any injuries, deaths,or damage to life or property caused by defects,disrepair,or faulty construction of the premises
except where as provided by law. Community Owner shall be held harmless of any liability arising from death or
damages by such incidents but not limited to fires,floods, storms,falling trees or branches,vandalism,criminal activity,
explosion,rain,or other scenarios beyond the Community Owners control.
27. OFAC
Resident does hereby represent that neither Resident or any person who resides or is proposed to reside with the
Resident in the community is or will be a Prohibited Person, as that term hereinafter`dfiined.A"Prohibited,.Person" is
any entity, person or party: that is listed in the Annex to, or is otherwise subject to the provisions of;Executive Order
13224 issued on September 24, 2001 (EO13224); whose name appears on the United States Treasury Department's
Office of Foreign Assets Control (OFAC) most current list of"Specifically Designated National and Blocked Persons"
(Which list may be published from time to time in various mediums including.but not limited to,.the OFAC website,
http:www.treas.gov/ofac/ti lsdn.pdf) (the OFAC list); who commits, threatens to commit, or supports'"Terrorism," as
that term is defined in EO 13224;or who is otherwise affiliated with any entity or person listed above.
28. PARTIES BOUND
This Rental Agreement shall be binding upon.the parties hereto.
Signed with our hands and seals the day,month and year first above mentioned.
WITNESS
WITNESS RESIDENT
LEIBYS MHC,LLC DATE
LIST ALL OTHER OCCUPANTS TO RESIDE IN THE ROME
LEIB Y- S LLC
Rules and Regulations
COMMUNITY STANDARDS
LEIB Y'S MHC,9 LLC
70175 CARLISLE PIKE, CARLISLE,PA .1701 S
COMMUNITY STANDARDS
(RULES AND REGULATIONS)
The Community Management and the Community Owner
of this Community offer Equal Housing Opportunities. We
operate our Community in accordance with State and Federal
Fair Housing laws and will not discriminate against any person.
because of race, color, age, religion, sex, handicap, familial status
or national origin.
The Community Rules and Regulations also referred to as
Community Standards, are to insure the safety, health, and quiet
enjoyment of our Community for you and your guests while at
our Community. These Rules and Regulations also insure a well
maintained appearance and a high level of living standard. A
copy of these Standards will be posted in a central location within
the community or at the office and must be observed by all
Residents, family members, guests, and invitees. Residents and
their guests or visitors shall conduct themselves in accordance
with these Community Standards, These
rules/regulations/community standards may be amended
periodically by the Community Owner as the need arises. All
amendments will become effective thirty (30) days from date of
service unless otherwise specified.
. .
_
_
TABLE OF CONTENTS
� 4
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Request
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' Occupancy ^ .........__~'.-..�...�[3
24)...Liability "^a°"-`-''.'' ''-''^--''-'''''-'' '''' �[}
25)-.Insurance......-.-...-....-'..-~..........~'..'~--'`^..^'-^'''^^'.''^
li...Undere
NOTE-to the extent that state law differs wrcontradicts these Standards then
applicable state law shall apply.
Residents Initials
3 .
DEFINITIONS
"Act 261" is an act of law which governs the tenancy and responsibilities of the Resident and the
Community Owner
"Application"means the document by which all prospective residents must complete in order to be
accepted or rejected as a Resident of the Community.
"Community Standards"-meats to rules and regulation
"Community"means LEIBY'S MHC, LLC.
"Community Management"refers Owner's manager,assistant manager(or other employee or agent)of
the Community as identified to you from time to time.
"Community(honer"means the owner or operator of the Community.
"Guest(s)"means an individual who maintains a permanent legal residence at a locale other than the
Community and who pays one or more visits to a Tenant of the Community.
"Home Owner(s)"meads a person who owns a manufactured home by title and rents or leases a
residential lot within a manufactured home Community for residential use.
"Invitees(s)"means all non-residents present on the Community grounds at the invitation of a
Residents(s).
"Lease Agreement"means an agreement whether written or oral between the Community Owner or
Community Management that temporarily transfers possession of a mobile home space or lot or mobile
home and lot to an approver{Arty for a definite period of time.
"Notice"Pertains to any legal notification whether written or oral,having an influence or
consequence regarding the Lease Agreement or status thereof for any particular Resident.
"Resident(s)"means a person entitled under an executed Lease Agreement to the use and
occupancy of the residential lot to the exclusion of others.The term includes both'Tenants and Home
Owners.
"Tenant(s)"means a person entitled under a I:ease Agreement to occupy a manufactured home located
on.a residential lot in the Community and who does not own the manufactured home occupying the lot. The
tern applies only to persons who have been approved by Community Management pursuant to these Standards.
"Violation (s)" means an infringement of a rule, non-compliant.
"Primary Resident (s)" means person who applied as applicant or co-applicant
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l "SiDENCY
A. Any person applying for admittance as a Resident of Leiby's MHC,LLC,here after
know as"Community",must fill out an application for residency and be interviewed by Community
Management.All prospective residents must be approved by Community Management and must sign a Lease
Agreement, sign a copy of The Community Standards,pay the first months rent,and pay a security deposit
prior to taking possession of a manufactured home currently in the Community or moving a manufactured
home into the Community.No one other than those executing the Lease Agreement shall be allowed to reside
upon the lot set forth in the Lease Agreement without prior approval from the Community Owner and Community
Management.Any person(s)requesting to reside in a mobile home within the Community where as the home
owner/tenant has executed a lease agreement with the Community Owner, shall do so only upon completion of an
application and AFTER being granted approval by the Community Owner.The purchase of aResident's home by
one who has not applied for and has been granted approval for such and executed a Lease Agreement or obtained
written consent from Community Management shall not constitute permission or right for the purchaser(s)to
reside writhin the Community.An executed Lease Agreement and executed copy of these Standards,as well as a
completed and approved Application for Residency and credit and background check,must be received by
Community Management prior to the arrival of the Resident's manufactured home in the Community;transfer
of title when the manufactured home is already in the Community;or taking of possession of a manufactured
home on a residential lot by Tenant(s). Community Management reserves the right to refuse to accept further
rent and terminate the Lease Agreement of anyone who fails to comply with these requirements and refitse
rental to any applicant.
B. Only manufactured homes owned and occupied by persons who have applied for
residency in the Community and who have been approved as such by Conim pity Owner,are permitted in the
Community,although the Community Management may rent homes owned by the Community Owner or its
affiliated entities.As a condition to approval for residency in the Community,each Resident who is not a renter
of a Community owned manufactured home is required to show proof of ownership of his/her manufactured
home;such proof may be made by title or registration to the home.Each occupant of the home must be approved
for residency by the Community Owner.Prior to beginning occupancy in the manufactured home, each Resident
must sign a copy of these Standards and a Lease Agreement. Written approval of the Community
Management is required as to any change in the name or number of persons in the manufactured home.
C. Failure of applicant to provide documentation verifying the information of all Residents of
the home shall constitute a violation of these Community Rules, and the Resident and/or manufactured home
may be subject to eviction as per law.
2 REQUEST FOR OCCUPANCY PROCEEDURE:S
A. Prospective residents of the Community must be approved by Community Owner based
upon: (1)the completion of a site rental application provided for this purpose;(2)credit,background and
reference check,employment verification, and criminal history check; (3)an interview of all persons planning
to occupy the manufactured home;(4)a signed authorization form; and(5)a copy of a current photo
identification,a copy of the applicants social security card and a.form of employment/wage verification.
B. All applications will be reviewed and judged fairly in regards to the information provided
and further information that may be discovered during background investigation. Any written or oral approval
will not be unreasonably withheld;however,Community Management and Community Owner does reserve the
right to refuse admission to the Community to any person(s)deemed not suitable to Community Management or
Community Owner in its sole discretion.
PENNSYLVANIA . LEIBYS 1\111C . LLC
Residents Initials Ur
. Any misrepresentations,whether written or oral,made by a prospective resident in
information provided on the application,credit application,personal interview, or statements as to number,
age, or identity of persons residing in the home, or about pets,personal background,or past landlords,are
deemed material and fraudulent and.made to induce the Community Owner to admit the prospective resident.
Any such misrepresentation shall be deemed a conclusive breach of the Lease Agreement and shall void the
approval of the request for occupancy by all of those on that particular application.
D. Application and Documentation. The Community Owner is vested with the
authority to prescribe an application form such as may require specific personal, social,financial and other
data relating to the proposed purchaser, or as relates to the prospective resident,as may reasonably be
required by the Community Owner in order to enable the Community Owner to responsibly investigate the
proposed purchaser,or prospective resident within the time limits extended to the Community Owner for that
purpose as hereinafter set forth and which application shall be completed and submitted to the Community Owner
along with and as an integral part of the notice of intent to sell.An application fee shall be charged to all
prospective residents over the age of Eighteen(18)years of age..
E. Application of Residency denied by the Community Owner.In accordance with
applicable State and federal law,Community Owner may disapprove the prospective resident if the prospective
resident does not qualify to be a resident by giving notice to the prospective resident of the disapproval in writing.
If the Community Owner shall disapprove a proposed purchaser, such disapproval shall be grounds for
eviction in the event such proposed purchaser has taken possession of the respective lot.If the Community
Owner shall disapprove a
proposed purchaser,such disapproval shall be grounds to deny such proposed purchaser Community,
Management's consent to such sale providing the home is to remain within the community.In the event of
disapproval,the Community Owner may pursue all remedies available at law or in equity.
3. SALE, RESALE OR REMOVAL OF MANUFACTURED HOME.
A. All homes in the Community must be built in accordance with the Manufactured Home
Construction and Safety Act of 1974("the HUD code"). Homes built prior to 1976 which may not be in
accordance with the HUD code may be"grand fathered" in by written agreement with the Owner. Such
agreement may require that,once the home is sold or vacated by the Resident,such home may be required to be
removed from the Community.`this decision is at the sole discretion of the Community Management and will be
based on condition of the home on a case by case basis.
B. Providing notice to the Community Owner-A Resident intending to make a bona fide
sale of his/her manufactured home or any interest in said home,shall give to the Community Management notice
of such intentions thirty(30)days prior to the completion of any such transactions.Failure of Resident to give this
thirty(30)day notice of intent to sell will result in the forfeiture of part or all of any deposit monies held by the
Community Owner on behalf of said Resident. Resident that is intending to sell his/her horne shall together with
the name and address of any proposed purchaser,the purchase terms, such other information concerning the
proposed purchaser as the Community Owner may reasonably require and an executed copy of the proposed
contract to sell.Resident shall inform the proposed purchaser that prior to the completion of any agreement for the
purchase of said manufactured home,purchaser shall be directed to the Community Management office to obtain
an application for residency and to interview with the Community Manager at which time an exchange of
information, including the lot rental amount which will apply at the expiration of the seller's lease tern,or at the
time of sale,and shall advise the proposed purchaser that the Lease Agreement is not transferable.After proposed
purchaser has been granted written approval to purchase the home and at such a time that the Lease Agreement is
executed,proposed buyer/Resident shall provide as a condition of occupancy,a true copy of the legal registration
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showing title registe 'd m , naive of the purchaser and the name of the lien holder,if any,shall be provided to
Community Man' by the Resident along with proof of insurance on the manufactured home."This rule
does not in any way diminish or affect the obligation of'every seller of a manufactured home to seek and to
obtain written approval of the proposed purchaser by Community Management prior to the sale/purchase of
the home and prior to change in occupancy of the home.Furthermore,failure of the seller to properly notify
Community Owner may continue the lease and any obligations bound by the lease onto the seller of the
mobile home.
C. FAILURE TO OBTAIN APPROVAL OF COMMUNITY OWNER- ANY PERSON
WHO PURCHASES A MANUFACTURED HOME LOCATED WITHIN THE COMMUNITY BUT DOES
NOT,PRIOR TO PURCHASE OF THE HOME,APPLY FOR AND HAVE BEENT GRAN][ED
APPROVAL FROM THE COMMUNITY OWNER TO BECOME:A RESIDENT OF THE COMMUNITY
SHALL BE SUBJECT TO IMMEDIATE EVICTION AND WILL BE CONSIDERED TO BE
TRESPASSING IN THI COMMUNITY AND DEALT WITH BY APPLICABLE LAW.
D. Community Management shall have the right to inspect the exterior of the
manufactured home prior to approving a proposed purchaser as an acceptable Resident/Home Owner
in that manufactured home. Community Management MUST be given thirty(30)days notice of
intent to sell their manufactured home to the Community Manager prior to any transaction or the
acceptance of an application for Residency by a prospective buyer. Homes must meet all local
building code requirements, including electrical and plumbing,but not limited thereto. Community
Owner or Community Management makes no warranty as to the home meeting any or all local
building codes by granting approval of home in regards to the exterior appearance of the home.Prior
to the purchase,the seller and the proposed purchaser must make any repairs or changes to the home
as necessary to bring the home into compliance with Community standards as set forth in these
Standards. Community Management has the right to deny approval of the proposed purchaser for
residency if such work is not completed.
E. Home Owner may display one"For Sale"sign,no larger than 18 inches by 24.inches,
inside the manufactured home window or in an approved location by management.This sign may display only
the words,"For Sale"or the equivalent plus an address or telephone number of the Resident,agent or dealer
where further information may be obtained. Due to safety and security considerations,any home offered for
sale must be registered with the Community office before a sign is displayed.All outside realtors,brokers or
service companies working in the Community must show proof of appropriate liability insurance before
starting work. Those without such proof of insurance on file with Community Management will be stopped
from perfbnning work inside the Community until such proof of insurance is presented to the Community office.
F. The Community Management requires that any manufactured home not meeting the
Community's established standards, as required by these Standards, or any manufactured home which is
improperly maintained,be upgraded to improve the quality and appearance of the manufactured home. Failure to
meet the Community's requirements shall be a violation of these Standards and will be subject to eviction or
removal from the community.
G. If the Home Owner intends to move his or her manufactured home from the
Community,Home Owner must give written notice to Community Management of that intent at least thirty
(30)days prior to the moving date. Such move must be made between 8:00 a.m. and 5:00 p.m.Monday through
Friday so Community Management may have personnel present to observe the removal of:'said home and to
prepare the property in any manor the Community management deems necessary for the safe and proper
removal of the home from the premises. Only transporters of manufactured homes that have proper
insurance and are properly authorized by governing authorities, are permitted to move homes into or out of the
Residents Initials
Community. Such 'Pokers must provide Community Management with a security deposit of up to
$500.00 and a ce ' cate of general liability insurance in an amount of not less than five hundred thousand
dollars($500,000.00)to ensure against personal injury and damage to property. Written permission from the
Community Owner is required prior to any move of a manufactured home either into or out of the
Community. All current charges must be paid in full.at the Community office before the home is moved from
the Community. Prior to removal of the home from the community,a copy of the removal permit must be
provided to the Community owner.After removal,the lot must be clean and free of any materials or debris and
any damage such as ruts in the yard must be corrected prior the Residents refund of a security deposit.
Furthermore,if the lot is not left in a satisfactory condition community Management reserves the right to restore
the lot to its original condition at the Home Owners expense.
H. Community Management requires that each Resident comply with the requirements of all
governmental agencies including,but not limited to,HUD,the department of motor vehicles or transportation.
the State and the county in which the Community is located.
4. SETUP: NEW,.RESALES AND RENTALS.
A. The location and positioning of a non-Community owned home being placed on a lot will
be carried out under the direction of Community Management. Community Management's written approval of
the style and quality,size and type of all proposed additions or other improvements to Resident's home or lot
will be subject to Community Owner's prior written approval and will be based on factors such as the size,
location,and the proposed location of equipment,additions or other improvements in relationship to other lots
in the Community, Responsibility for compliance with applicable zoning or code provisions shall be that of
Residents)/owner and shall be a violation or the l..,ease. Only new homes(never previously occupied)and used
homes which have been approved in advance in writing by Community Management as acceptable for location
within the Community will be allowed in the Community.A plot plan showing the location of the home,
accessory buildings and any improvements existing and proposed to the home or lot shall be submitted to the
Community Owner. Written approval from the Community Owner is required prior to the commencement of
any work. All persons involved with the move in and set up of the home must have adequate general liability
and worker's compensation insurance. All liability associated with the move in shall be the responsibility of
Home Otivner.
B. New manufactured homes to the community must be placed in a uniform manner,
properly blocked,set and all utilities connected in accordance with the applicable UCC code,local,city or
county code and/or regulations and with Community Management's specifications.Manufactured homes must be
anchored immediately,as required by governmental regulations.
C. Horne Owner agrees that the following standards and requirements shall be met and
completed,if required by applicable ordinance,under a building permit issued by the city or county building
department or other applicable local agency and approved by Community Management:
I) All new manufactured homes entering the Community must have removable
hitches which shall be removed upon the completion of set up,and older manufactured homes moved into the
Community after the effective date of these Standards which do not have hitches which are designed to be
removed,shall nonetheless be removed.These hitches are to be stored and remain tinder the home in which
they were removed.
2) The manufactured home must be skirted on all sides with vinyl skirting
�I �
Residents InitialA�tik manufactured fp as mobile home skirting and in colprs pr styles approved by Community
Management.All skirting must be installed as per the manufactures instructions have sufficient ventilation
panels as to meet local codes pertaining to ventilation in crawl spaces. Skirting must be completed within 30
days of delivery of the home in the Community, and must be maintained regularly to insure a uniform
and attractive Community.
3) Entry steps and stoops that comply with local and UCC building code requirements
and are approved by Community Management must be installed,with appropriate skirting,at all entrances to
the manufactured home.All steps(both front and back door)must have an adequate handrail running the
entire length of the steps as per local and UCC codes.
4) No air conditioning unit shall be located in the front window of the manufactured
home or front wall of any manufactured home, or any wall facing a street. All window air conditioners
must be supported by a bracket system or by chains from the top of the unit to the top of the window.
No supports will be permitted that extend from the air conditioner to the ground.
5) Window coverings visible from the street shall be limited to blinds,shutters,
drapes,curtains or similar standard window treatments.Bed sheets,flags,mattresses,blankets or the like shall
not be used as a window covering or shade device, including the use of aluminum foil or cardboard.Any
window treatments deemed unsightly or in poor taste will be considered a breach of the community standards.
6) No fences are permitted except those installed by Community Owner or otherwise
expressly consented to in writing by the Community Owner.Fences remaining prior to the enactment of these
standards will be allowed to remain as long as they are kept in like new condition.Any change in ownership of
the home will negate this exemption and all fences on the lot will need to be removed prior to the approval of a
new Resident.
D. All of the materials utilized in connection with the erection and completion of the
manufactured home as contained within these Standards shall be of a quality,type,style,color and pattern
approved in advance in writing by Community Management.Community Management shall have approval
rights over the manner of installation or attachment of the home and of any accessory structures, and all
installation and construction shall be consistent and compatible with other homes in the Community.
Additions,porch enclosures,or alterations to the basic structure of the mobile home are prohibited.All
installations shall comply with federal,State and local laws,codes and regulation-,,and shall comply with all
standards referenced within these Standards and the Lease Agreement.
Residents Initials
5. LOT IMPROVEMENTS/MAINTENANCE BY RESIDENTS.
A. Improvements are encouraged; however, any construction of or addition to a
manufactured home,and its location, including but not limited to porches,skirting,steps,awnings,utility
buildings, air conditioners,concrete slabs, carports,stone or concrete walkways, and the like, will not be
permitted Curless the Resident obtains prior written approval from the Community Management and obtains the
necessary governmental approvals and permits when required. If electrical,mechanical or plumbing is
upgraded,whether or not to accommodate appliances or improvements of any type,such upgraded service shall
be at the sole expense of the Resident.Approval is necessary to protect the underground utilities,continuity of
Community appearance, and the safety of Community Residents.In addition to all other remedies available to
it,Community Management may require Resident to remove any unapproved construction or addition at the
expense of Resident.Resident shall consult the Conununity Management before doing any digging, as certain
utility and service connections are underground and Resident shall call for any required utility location. Cost of
repairs for damaged underground services will be assessed to the Resident who damages any underground
service. Each Resident is responsible for the submission of complete plans and/or permits for anticipated
alterations showing compliance with these Standards, county building and zoning codes,and other restrictions
of record.All improvements must be completed within 30 days.For additional information on these Standards,
please see"l,ot/Home Care"below.
B. Where the Community has provided a paved parking area on the lot,the Resident,at
Resident's expense, is responsible for maintaining this paved area,and if damaged by Resident or guest(s)
during the tenancy,the Resident must repair same. This obligation includes any oil spill or leak.
C. In the event the Horne Owner wishes to extend the paving available to his/her lot for use
of a vehicle,he/she may do so after obtaining written permission from Community Management,and at the sole
cost and expense of the Home Owner.All work must be performed to specifications approved by Community
Management in writing in advance and all work must be performed by a licensed contractor with liability
insurance. Proof of liability insurance from the contractor will need be submitted to the Community
Management prior to the commencement of any work.
D. Residents must secure their street address numbers on the front of the manufactured home,and
placed in an approved location. Numbers must meet all local codes.
E. No basketball hoops(either portable or stationary),weight benches,trampolines,mini
tramps,outdoor exercise equipment or other outdoor recreational equipment,major appliances or vehicles are
permitted on the residential lot. Swing sets may be permitted if prior written approval is received before
installation, installation is completed in a manner that is safe and does not disrupt the privacy of neighbors,the
swing set is well maintained, and the Resident does not allow use except under Resident's supervision.
Resident hereby indemnifies and holds harmless Community Owner, its affiliates and its and their officers,
directors, employees, assigns and agents with respect to any claims,damages, loss or cause of action arising
from the use of the same and agrees to have a home owners insurance policy which covers such swing sets.
All swing sets must be place to the rear of the lot.
F. No pools,are permitted except temporary"toddler"wading pools that are less than
6 feet in diameter and no more than 6 inches deep. All "toddler"pools must be emptied and stored away
in an acceptable location following each and every use,and may never be left unattended while containing any
i
Residents Initials
amount of water.All pools are to be placed on the patio or deck when available.No pools will be permitted to
remain on the grass overnight.All pools containing water,must have proper supervision at all times.
G. Any signs such as`No Trespassing"are prohibited on a Residents home or lot space.
Flags or banners at a Residents home or lot shall only be displayed for short periods of time with the Community
Managements approval.
H. Only umbrella-type clotheslines are permitted and must be placed to the rear of the lot.
Al l other types of clotheslines are prohibited and must be removed when the home is sold or home ownership
changes.All approved clothes line are the responsibility of the Resident and must be kept in good repair at all
times.No clothes lines or rope of any kind will be permitted to be attached to a tree or shrub.Clothes may not be
hung on porches,patio's,decks,tree's,awnings,or any other structure on the lot.
I. Awnings.Must be approved in writing prior to installation and meet all building codes.
Awnings are not permitted to be enclosed by any material other than a handrail or other restraining devise as
required by local building codes.
J. Utility/storage sheds must be constructed of wood,sturdy vinyl,or other finished siding
materials that have been APPROVED BY COMMUNITY MANAGEMENT PRIOR TO
INSTALLATION and must be anchored on a sturdy rot resistant platform.No sheds may be erected or placed
on the patio.No metal sheds will be allowed to be constructed or placed within the mobile home community.
Wherever required, a permit must be obtained from the local city or county building department and from
Community Management before installing the structure.The color of the shed must match,or keep in harmony
with the color of the mobile home. The location of the shed will be determined by the Community Management
and must be kept to the rear of the lot.The size of the shed must not be any more than one hundred(100)square
feet and no more than eight(8)feet high at the highest point on the roof. There is only one shed allowed per
residential mobile home lot No resident is permitted to have two or more sheds.If the prior community
rules allowed for a Resident to have two sheds,then that resident will be allowed to have the two sheds until a
time that the home is sold or the ownership of the home changes.As a condition of resale approval,any home
that has two sheds on the lot will be deemed in violation and will not receive resale approval.
G LOT/HOME CARE-Residents are required to maintain their manufactured home lots
and manufactured homes in a professional manor.
A. All Residents are required to maintain their manufactured home,yard, driveway,
flower beds,and all applicable structures in compliance with all. local and state codes. Each Resident shall
be responsible for the maintenance and cleanliness of his/her lot.Any Resident that creates a health risk due to
neglect and does not cure the violation within a reasonable set time frame will be subject to eviction.Bottles,trash,
cans,boxes,equipment,or debris of any matter shall not be stored anywhere outside or beneath the
manufactured home,deck,yard,conunon area, stoop or patio.In the event any governmental agency shall
impose a fine for failure to comply wTith any violation, Resident shall be responsible for the payment of the fine
or penalty,and,in the event Community Management or Community Owner shall be made to pay the fine or
penalty,Resident shall promptly reimburse Community Owner for any fine or penalty imposed.
B. All drainage ditches,swales and other apparatus designed to allow water to flow
freely through the community must be maintained by each individual Resident where such a drainage way
exists on the Residents lot.'Ibe dumping of leaves, grass clippings,and other debris into these drainage ways
is prohibited.
.�
Residents Initials
1 C. A Resident is prohibited from erecting,planting,building,or otherwise
obstructing access to their lot to allow unfettered access by Community Management,maintenance
personnel, emergency workers,service or delivery personnel.
D. Ponds or water gardens are strictly prohibited.
7. HOME MAINTENANCE-All manufactured homes, awnings, sheds, skirting,
porches,decks and any other accessories must be kept in good repair. Residents trust immediately repair any
water leaks in or from pipes or fixtures in1 on,or under the manufactured home.All broken windows,peeling
paint,dull exterior of a manufactured home,or dirt,grime or mildew must be corrected in a timely manner.
In the event that the Resident repaints the exterior of the manufactured home, the color MUST BE
APPROVED BY COMMUNITY MANAGEMENT PRIOR TO PAINTING THE HOME.All colors
must have been applied by the manufacture at the time the home was manufactured or be of a color that is
used in production currently. The exterior surfaces of the manufactured home shall be kept free of mildew or
discoloration. Peeling,fading,or damaged exterior surfaces must be restored to the original condition at the
time of the manufacture of the home.All exterior materials used in upgrading roust be approved in writing by
the Community Management prior to their use on the home.The materials used to repair the home must be
consistent with the types of materials used when the home was manufactured.Upon failure of Resident to take
appropriate corrective action after receipt of notice, Community Management may,but has no obligation to,
have the necessary work performed, and.shall have the right to charge the Resident for materials,equipment
and labor.'Ibis amount shall be collectable in the same manner as lot rental.Community Management reserves
the right to consider any violations of this provision as a breach of Community Standards and to act
accordingly.
A. Utilities-Water;The Resident is responsible for the water line from the top of the
strut off valve at the ground to the home.The Resident is REQUIRED to have a working heating tape and
proper insulation on the water line,meter,and all valves. (.including the valve in the ground)In the event that a
water leak is found in or under the home to a condition that there is evidence of a considerable amount of water
loss or damage being caused to the home,the Community Management shall at its discretion turn the water off
and post a notice of water shut off explaining the reason for the action..
B. Utilities-Sewer; The Resident is responsible for the sewer line from the point
where the main waste line enters the ground up to the home.Allowing water to run as a means to prevent frozen
water lines is prohibited. Severe damage to the home can result from this type of action should the sewer line
freeze solid.
C. Utilities-Electric;The Resident is responsible for electric wires from the point of
the main disconnect located directly under the meter base to the home including all lines or secondary
disconnects above or below round. The main breaker in the main disconnect box is the responsibility of the
Community Owner unless it is found to have been damaged by an electrical malfunction on behalf of the
Residents electrical system which includes but is not limited to wiring,appliances,inappropriate use, or an
improper electrical connection.Any electrical work that is being performed by the Resident or an agent thereof
must be completed in a manner that meets all building, fire,and electrical codes.Any work that involves the
main disconnect must be reported to the Community Management prior to any work commencing.
D. Utilities-Gas;The Resident is responsible from the point that the gas line leaves
the meter to the home whether the piping is underground or above ground.
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E. If a Residents manufactured home's facade ages or deteriorates, the Resident
or Owner of the manufactured home shall resurface,re-side,re-roof,re-paint, or replace if deemed necessary
or appropriate by Community Management or by local city or county housing,health or code enforcement
personnel. If the manufactured home is to be repainted,all colors applied must have been used in the original
manufacturing process or a color that is currently used by manufactures, THESE COLORS ARE
RE UIl2ED TO BE APPROVED BY COMMUNITY MANAGEMENT PRIOR TO 1'RE PAINTING
OF THE HOME.
F. Every Home Owner is required to maintain the skirting around the manufactured
home in a neat and proper condition. If the present skirting is destroyed by windstorm,an act of God,or any
other means,replacement skirting must be of the approved type that is specifically manufactured for use as
mobile home skirting.All skirting must be installed as per manufactures instructions and to all local codes.
All skirting must be of a color consistent with the color of the home.
G. In the event that a Home Owner's manufactured home be destroyed by fire,windstorm,
an act of God,or by any other means, Home Owner must,at his/her own expense: erect a suitable fence or
barrier around the site as a protection against trespass; and remove the salvage from the lot the earlier of 15
days from the date of such event or from the date of the mailing of written notice from Community(Nvner to
Home Owner requesting removal,unless a longer period for removal is provided by applicable ordinance or
law.Lot rent shall continue to accrue until all the debris has been removed,the lot cleaned up,and any
dumpsters or removal equipment is removed from the property.
1-1. It shall be the responsibility of each Resident to keep the lawn mowed,edged,raked,
and trimmed.Resident must mow,trim and edge along the side of the home,walkways,driveways and streets
before they become unsightly. Generally,this means mowing when lawn reaches approximately 4"in height.
The object is to keep Resident's lawn and the Community looking neat. Sod destroyed or damaged by neglect,
vehicular traffic or by any other means or for any other reason,must be repaired or replaced at Resident's
expense. If,in the opinion of Community Management,all or part of Resident's lawn needs to be re-sodded,
Resident will receive written notice from Community Management to complete this repair at Resident's
expense or face eviction. Each Resident is responsible for his/her respective plants and lawn. Plants,lawns and
the residential lot are to be kept free of, among other things,weeds,underbrush, debris and any other rubbish
and should not be permitted to become overgrown or unsightly.At its option,Community Management may
notify Resident of his/her failure to comply with this provision.Upon failure of Resident to take appropriate
corrective action within 3 days after receipt of notice,Community Management may,but has no obligation to,
have the necessary
work performed, and shall have the right to charge Resident for materials,labor and equipment,which may be
as much as$75.00 per hour with a minimum of 1 hour. This charge will be due and payable with the next
month's rent and if not paid,will be treated the same as delinquent rent.
I. The planting of trees, shrubbery, and flowers is encouraged; however,to
protect underground utilities, it is necessary for Resident(s)to receive prior written approval from
Community Management before planting.Nonetheless,with Management's prior written approval small plants
and shrubs planted by Resident may not be removed when vacating the lot unless prior written approval is granted
Sod must be replaced by Resident where plantings are removed. Existing trees or shrubs must not be damaged
or removed by Resident without prior written permission,of Community Management.Resident is responsible
for trimming and maintenance of all shrubs and bushes located on the residential lot. Community Management
will maintain trees, shrubs and any other horticultural amenities in Community common areas, as well as
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trim and/or remov ees that in its sole discretion are safety hazards located either in common areas or on
residential lots. Residents are required to maintain their residential lots including,but not limited to,yards,
shrubs and garden areas in a well-groomed manner at all times.If Community Management receives a written
request,the basis of which in Community Management's sole discretion is not safety related,to trim or remove
trees and/or shrubs located on a residential lot,then such service as consented to by Community Owner shall
be at the expense of the requesting Resident.
J. Snow Removal-It shall be the responsibility of the Resident to clear all snow and ice
from their parking space,driveway,walkways,patio,and steps in a timely manner. Shoveling or placing snow
onto the common drives or roadways of the communities is strictly prohibited and is a violation of the lease.
K. Residents who are going to be absent from the Community for more than one(1)month
must notify the Management office as to what arrangements have been made for the necessary grounds care
and to leave a contact name and number in case of an emergency at the mobile home. Community
Management reserves the right to do all necessary work at Resident's expense so that the lot will meet these
Standards.
L. Holiday decorations will only be permitted to be displayed for Thirty(30)days past
the date of the actual holiday.
8 VEHICLES.
A. All Community streets,roads,parking areas,or cart ways are private and not public
streets or thoroughfares. Community Management may at its discretion use vehicles in the community that
will not be bound by these rules and regulations in the course of normal community maintenance or
operation such as but not limited to tractors,backhoes, excavators,and golf carts.
B. If off street parking is provided at the Resident's lot,then said Resident must park his or
her vehicles on his or her own lot.The Resident is permitted a total of two (2)vehicles per lot,provided there is
adequate room.A Resident who is already occupying the two spaces designated for their particular rented
lot may not park a vehicle on a common parking space, a vacant lot, an overflow parking area, or a guest
parking area without prior written approval from the Community Management. Without prior written
consent of Community Management, no vehicle shall be parked in or on Community common areas,other
than those areas specifically designated for parking.No vehicle shall he narked in the grass at any time.All
vehicles must have liability insurance in the minimum amount required by State law,but at least$15,000. In
the event there is not sufficient space,it is the responsibility of the Resident to locate parking or storage outside
the Community and not on other Residents' lots. Unless expressly allowed by Resident's Lease Agreement,
parking on roadways within the Community or on ]awns,swales,green areas or vacant lots or on undeveloped
portions of the Community is strictly prohibited. Any vehicle that is parked in such a manner as to block or
impede an emergency vehicle will be subject to immediate to-wing without notice.Furthermore,blocking or
impeding an emergency vehicle constitutes a breach of community standards for which a violation notice will
be issued. Only vehicles licensed and used for daily personal transportation will be allowed to be stored in the
Community.All other vehicles must be removed from the Community.Community Management will ban
from the Community any vehicles that, in its sole judgment, interfere with the peace, privacy, and/or general
welfare of other Residents or with the appearance of the Community. Vehicles in violation.of these Standards
may be towed away without notice,or with such minimum notice as is required by applicable law,at the
registered owner's expense,payable to the towuig service and not to the Community Owner.Residents are
responsible for guests' vehicles complying with these standards.
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C. Any maintenance or repair of vehicles,boats or trailers is strictly prohibited anywhere on
a residential lot or common area within the Community. This includes but is not limited to the changing of
fluids such as motor oil, anti-freeze, or other vehicle related fluids. Vehicles without current licenses,
inspection stickers and tags,or which are inoperable or in a state of disrepair including, but not limited to,
those which are rusted, dented, or unpainted or which are missing external parts,are not to be stored on the lot
or in any other area within the Community. Washing of Resident's personal vehicles is permitted subject to
any rules or regulations promulgated by any local, State or federal agency, or the Community Management.
No vehicle may be on jacks, stands,blocks or ramps at any time other than for emergency tire changes lasting
no longer than 30 minutes. Due to the safety hazard it presents, any vehicle left on jacks,blocks or ramps is
subject to immediate towing without notice,or with such minimum notice as may be required by applicable law,
at the vehicle owner's expense.Any vehicle with a loud exhaust system that is considered a nuisance will not
be permitted within the community.
D. No truck larger than three-quarter(3/4)ton with pickup bed will be permitted in the
Community unless permission has been requested and granted by Community Owner.All commercial trucks,
boats,off-road vehicles,campers,motor homes,step vans,or other large vehicles are not permitted in the
Community unless stored in a designated area when and if such area is available and storage fees as
applicable are paid. Campers,motor homes,boats or delivery vehicles will be permitted reasonable tune for
loading and unloading.No person may remain overnight or otherwise reside in the Community in any camper,
motor home or similar vehicle.
E. Motorcycles and mopeds operated by a Resident will be permitted only as transportation
on Community streets via the shortest route in and out of the Community.No recreational or joyriding will be
permitted within the Community by Residents or guests.All motorcycles and mopeds must be properly
licensed, inspected,and have insurance. Any motorcycle deemed to disturb the peace and quiet enjoyment of
the Community will be banned from the Community and may lead to eviction of the resident from the
Community.
F. ATVs, mini-bikes, dirt bikes, motorized scooters, go-carts, or any recreational
motorized vehicles not properly licensed for legal street use on a public road are prohibited in the Community.
All permitted vehicles must have factory-type quiet: mufflers. No unlicensed non registered off-road vehicles
will be permitted within the Community.
G. Speed bumps,if installed,are installed as a safety measure to discourage speeding in the
Community.The Community Owner or Community Management is not responsible for any damage or
personal injury resulting from contact with a speed bump.
H. SPEEDING IN EXCESS OF POSTED LEMITS IS PROHIBITED. All autos,
motor-cycles,mopeds and any other vehicle must observe the posted speed limits or, if no sits are posted,
must observe a speed limit of 5 miles per hour and must obey all"stop signs"or other posted warnings.A
FULL STOP must be made at all stop signs.All of these Standards will be enforced as this is for the safety of
our Community Residents.Residents must inform all visiting guests/invitees about the speed limit and the
aforementioned rules.
L Skateboarding is prohibited on sidewalks, steps, and pool areas and is not to
interfere with traffic flow. Community Management reserves the right to post other areas deemed as
inappropriate for such activities.No skate board ramps will be permitted.
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J. Only individuals having a current and valid driver's license may operate a motor vehicle
in the Community.
9 PETS. DOGS ARE NOT PERMITTED IN THE COMMUNITY
A. All pets are permitted on.Iy with prior written permission of the Community Management,
and payment of the applicable pet fee,if any, and the completion a pet agreement.Residents are required to
formally apply to the Community Management for permission to bring a pet into the Community before the pet is
allowed to be brought into the Community. Community Management reserves the right to make decisions on pets
on a case by case basis.Community Management can at any time terminate approvals granted for pets based
upon incomplete or inaccurate information.Under no circumstance shall a Resident be allowed to feed a dog or
cat outside of the home. Placing food outside encourages stray animals to stay in the community and to
reproduce. Stray cats and dogs carry diseases and can cause damage to homes. FEEDING ANY CATS
OUTSIDE OF THE HOME IS A VIOLATION OF THE COMMUNITY STANDARDS.
B. Completion of the written application form by the Resident shall be required before
approval of any pet will be considered. All information required on the application shall be provided with
complete detail as requested. Such items requested shall include,but not be lirnited to,the name of the pet,the
breed,the adult size of the pet(height and weight),the pet license tag number and current vaccination status of
the pet,the veterinarian for such pet,the length of time that said pet has been with the Resident and any history
of the pet as it pertains to barking, attacking,growling,biting,other menacing behavior or law suits occasioned
by its behavior.The application shall be signed and dated by the Resident.Any false or incomplete information.
on the application, including that of the mix or breed of the pet,will be deemed absolute grounds for rejection
of the pet, and shall constitute a violation of the Standards if the pet is not immediately removed.
C. When a written application is submitted,the Resident shall bring it to Community
Management with proof that the pet has a valid and current pet license(if a license is required by law), and that
the pet has received all required vaccinations and inoculations.Resident shall also bring the pet to Community
Management for a visual assessment.Annually, Resident shall be required to provide to Community
Management proof of a current pet license and of vaccinations and/or inoculations as are required.This
documentation shall be copied and presented to the Community Management within 15 days of the renewal
date of any pet license and/or vaccination and inoculation requirement.
D. No pet with a history of biting or attacking any person shall be allowed or approved.Any
Resident or prospective resident who has previously°been sued because of damages caused by any pet for which
approval is being sought shall be denied permission for such pet to be brought into the Community.
(1) DOGS ARE NOT PERMITTED WITHIN THE COMMUNITY.
THIS INCLUDES GUES'T'S OR INVITEES. IF YOU ARE FOUND TO
BE INVIOLATION OF THIS STANDARD, EVICTION
PROCEEDINGS WILL COMMENCE AGAINST YOU.
(?) CATS
(a) Domesticated cats for which inununization and licensing in compliance with the
PENNSYLVANIA . LEIBYS
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local/state animal control ordinance(or other comparable municipal ordinance accepted by local animal control)
is current and is maintained current are permitted.Applicants far.residency in the Community and Residents in
the Community who wish to acquire a cat must provide evidence of'such immunization and licensing to
Community Management.
(b) Cats must be kept inside the manufactured home except when taken
outdoors on a leash for reasonable outdoor exercise periods.Any cat found unattended outside your
home will be dealt with as a stray animal.
(c) Cats shall not,under any circumstances,at any time be caged,fenced,tied or
otherwise left restrained but unattended outside the manufactured home of the cat's owner.No outside fences or
pet restraining perimeters,whether above or below ground,or other forms of restraint of any kind for the
retention of pets will be permitted on the lot.
(d) One(1)cat shall be permitted in any manufactured home.The only
exception to this rule is that a cat owner with 2 otherwise qualifying cats who is applying for residency in the
Community and who would otherwise qualify for residency,will be approved,provided said cat owner signs a
written statement stating that when either of the 2 cats dies, it will not be replaced.
(e) Community Management will investigate any and all written complaints
concerning cats from any neighboring Resident. When cat owners are determined by Community
Management to be out of compliance,the cat owner will be given written notice of such non-compliance,
which may lead to eviction for non-compliance under these Standards.
(f) Persistent howling which is audible outside the manufactured home by any
cat at any time of the day or night constitutes unacceptable cat behavior.
(3) BIRDS
(a) Pet birds whose singing or other noises are not audible outside the
Resident's manufactured home are permitted.However,should a pet bird become a noise nuisance,the bird's
owner is required to take corrective action.
(4) OTHER ANIMALS. No other agricultural,non-domesticated,or wild animals,
poisonous creatures or
exotic creatures such as pigs, iguanas,snakes,ferrets,etc., are permitted in the Community.
(a) Residents shall hereby be liable for and shall defend,indemnify and hold
harmless Community Owner,its affiliates and its and their officers,directors,employees,agents,and assigns from
all personal injury or property damage caused by pets. In.addition,Residents shall comply with all provisions of
any rules,regulations and ordinances of any governmental authority or agency and the laws of the State with
respect to dogs,cats and other pets. Pet owners must provide Community Management proof of insurance
coverage of all pets on their home owners policy.
(b) Without the prior written approval of Community Management,pets
belonging to daily visitors and/or overnight visitors of Residents must be boarded outside of the Community.
However,guests' seeing-eye dogs are permitted.
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J (c) Pets are specifically prohibited from Community or recreation buildings or
facilities including laundry rooms.
(d) FEEDING OF STRAY OR WILD ANIMALS IS PROHIBITED
AND IS A VIOLATION OF THE :LEASE.
(e) Any pet found running loose will be considered abandoned and may be
picked up and delivered to the local animal shelter. if the animal is wearing identifying tags,Community
Management may,but is not obligated to, first attempt to return the animal to its owner. In the event Cornmiuiity
Management picks up the animal,a special service fee will be charged to the Resident.
10. TRASH/GARBAGE.
A. All garbage must be wrapped and placed in a garbage container and securely closed at all
times. Until ready for pickup,containers are to be placed in an area not noticeable from the street.Yard trash
and cuttings must be put in plastic bags containing no trash.Limbs must be tied in bundles,none over 3 feet in
length.Cardboard boxes must be broken down flat.Any bulk items that the trash contractor will not take as routine
service must be disposed of immediately by the resident. Such disposal will be at the Residents expense.Trash
containers may not be placed at pickup locations any earlier than 6:00 p.m. the evening prior to pickup service,
and containers must be removed from pickup locations within 12 hours of pickup service.
B. Items such as,but not limited to,sanitary napkins, condoms,metal,rubber,clothes,
plastic,paper towels,fabric, grease, disposable diapers,tampons(including those labeled"flushable"),and the
like are not to be disposed of in manufactured home or Community toilets or drains. Expenses of purging
stoppages of sewer lines of such or similar foreign objects shall.be the burden of the Resident who occupies the
space from which the foreign object originated. All costs of collecting the expense of purging the lines,
including reasonable attorney's fee in the event said Resident fails to pay the expenses within 5 days after
written demand. shall also be the burden of the Resident.
C. The garbage company will pick up trash according to their own schedule and rules. All
rubbish and garbage must be securely bagged in plastic bags and put inside plastic containers lvith lids. Residents
are responsible for cleaning up any scattered or remaining residue resulting from collection. It is the Resident's
responsibility to remove any trash the garbage company will not handle. Residents shall not dispose of
hazardous waste in garbage containers or anywhere in the Community.
11. ANTE NN AS/SATELLITE DISHES.
A. In order to maintain an attractive Community,Residents are strongly encouraged to rely
on indoor broadcast antennas and cable broadcast or master centralized broadcast antennas, as opposed to
installing outdoor reception devices. If an outdoor reception device(satellite dish,antenna,or any other
device)is reasonably necessary to receive an acceptable signal of reasonable quality, it must not exceed one
meter(39") in diameter and must be installed in a manner that complies with all applicable codes,city and
State laws and regulations and manufacturer instructions. Outdoor reception devices must be installed on
Resident's home or on the ground of Resident's lot in a location which is not visible from the street and which is
reasonably acceptable to Community Management,or if such placement sufficiently impairs the quality of
reception,it must be installed on the home or lot in the most inconspicuous location possible and must be
attractively landscaped and shielded from view to the greatest extent feasible.
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B. No reception device may be placed so as to obstruct a driver's view of any street,
driveway,sidewalk or intersection,nor may it be installed on or encroach upon any common area or restricted
access to property located within the Community.Due to safety concerns posed by winds and the risk of falling
reception devices and masts,outdoor reception devices and masts may only be as high as required to receive
acceptable quality signals and no reception device and mast may be installed that would extend higher than 12
feet above a roofline.Additionally,outdoor reception devices shall not be installed nearer to a lot line than the
combined height of the mast and reception device. Outdoor reception devices must be painted an appropriate
color to match the surrounding environment. Resident is responsible for the maintenance of the outdoor
reception device and is liable for all injuries,losses or other damages to any person or property caused by the
installation,maintenance,or use of the reception device.
C. A policy of liability insurance covering such foregoing injury or damage must be
maintained by.Resident and proof of such insurance must be provided to Community Management Upon the
removal of the outdoor reception device or the termination of Resident's tenancy,Resident must restore the lot
and/or manufactured home to its original condition.If Resident violates any of these Standards,Community
.Management may bring an action before the FCC. or before any court of competent jurisdiction for declaratory
relief and Community Management may recover from Resident a fine,reasonable attorney fires,costs,and
expenses incurred in enforcing these Standards. The laws applicable to these Standards described above are
subject to interpretation and change.Therefore,Residents are advised that future changes in the law,court
decisions and rulings by the FCC may affect their rights and obligations regarding the installation of reception
devices.
D. Prior written permission from Community Management must be obtained before
installation of any kind of antenna(over-the-air antenna, .DBS satellite dish or multi-channel multipoint
antenna)to ensure that the device is located in conformance with the aesthetic standards of the Community.No
radio. CB or shortwave antennae is permitted at the manufactured home lot or on the manufactured home.
"Rabbit ears"are permitted inside the manufactured home,as well as any other inside receiving device;satellite
dishes are prohibited except those designed for direct broadcast satellite (DBS)services and which are one
meter(39")or less in diameter.
12. RESIDENT CONDUCT.
A. Noise or conduct that Conununity Management finds objectionable,that disturbs the
peaceful enjoyment of the Community by neighbors,or is deemed a nuisance to other Residents,that materially
interferes with Community Management's operation of the Community or that constitutes a breach of the peace
is prohibited.Loud noises,annoying parties,and abusive or profane language shall not be permitted at any time
in the Community. Yelling,screaming, other noise-making,or the use of profanity outside the manufactured
home or inside the manufactured home if audible outside the home,are not permitted in the Community.All
Residents and their family members, invitees and guests must conduct themselves in an orderly fashion and
must ensure that they behave in such a manner as not to annoy,disturb or interfere with other occupants of the
Community.Residents are requested to keep noise levels from whatever source to a minimum.Noise which can
be heard outside the residential lot from which it originates will be considered too loud. Written complaints
filed with Communivy Management by other Residents concerning noise or disturbances caused by another
Resident or such Resident's guests shall be considered as evidence of a violation of these Standards and may be
grounds for eviction. Verbal abuse of another resident or community management/maintenance will
constitute a violation of the lease and such action will be considered„grounds for eviction.
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B. Residents and those persons residing with Resident shall not allow anything to be done
on the residential lot or in the home,including the operation of any equipment or machinery that may result in
property damage to the home,residential lot or Community in which the home is located or that is disturbing to
other Residents.Residents and those persons residing with Residents shall not allow any activity that may
constitute or create a liability on the part of Community Owner or interfere with the quiet enjoyment of other
Residents.
C. Residents,Resident's family.members,guests and invitees are not permitted to play in the
streets or in the yards of other Residents,or to pass through other Residents'yards.Resident shall be held responsible
for the actions of both persons residing in his/her home and invitees who violate the provisions hereof or these
Standards,and for damages caused by such persons. Resident,Resident's family members,guests and invitees
are not permitted to play in lots other than Resident's lot.Resident,Resident's family members,guests and
invitees are not to climb the trees in the Community.No ball playing is allowed in the Community streets.
D. Alcoholic beverages are prohibited from being consumed in any common area or
recreational area of the Community. Smoking is not allowed in any Community structure.
E. Residents will be held responsible for their guests' conduct.Neither Residents nor their
guests may sleep in vehicles.
F. The outdoor burning of leaves, brush, wood, trash, etc. is strictly prohibited. 'This
includes but not limited to "Chimneys" or fire rings/pits. No open flames other than a grill intended
for cooking purposes only usinp_ charcoal or propane.
G. No firearms,other forms of weaponry,or mechanism capable of firing dangerous
projectiles,or firecrackers are to be discharged in the Community. Fireworks of any kind are
prohibited in the community.
13. GUEST'S. Guest's shall not stay in the Community more than 10 consecutive days or 30
days in any year without written permission from Community Management. Residents shall be solely
responsible for the conduct of their guests.All guests must comply with these Standards. Guests shall not be
permitted to reside or stay in the Community in the absence of the Resident. Seasonal occupants are requested to
notify Community Management of the period(s)during which the manufactured home is vacant.Without prior
written consent of Community Management guests will not be allowed to bring a dog or any other animal
into the Community with them at any time, even for a daily visit. Seeing-eye dogs are permitted for the sight
impaired.Any guest 18 years of age or older staying with a Resident in excess of 10 consecutive days shall
be considered an applicant for permanent residency in the Community, and shall be subject to the Standards
including,but not limited to,the obligation to make application for residency and to satisfy the requirements
of residency.If Community Management so requests,a guest must vacate the Community within 24 hours of
delivery to the Resident or the guest of a written demand to vacate.
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14. ILLEGAL DRUGS AND CRIMINAL ACTIVITY-
A. Any criminal activity in the Community is strictly prohibited and will not be
permitted. Any criminal activity constitutes a breach of this Lease Agreement.
B. Illegal drugs and drug activity are strictly prohibited and will not be permitted.
(1) Resident,members of Resident's household,Resident's guests or other persons
under Resident's control or on the lot with Resident's permission or consent, shall not engage in criminal
activity, including drug-related criminal activity,anywhere in the Community. "Drug-related activity"means
the illegal manufacture, sale,distribution,use, or possession with the intent to manufacture, sell, distribute,or
use a controlled substance,as such term is defined by applicable laws.
(2) Resident,members of Resident's household,Resident's guests or other persons
visiting the Resident or on the lot with Resident's pennission or consent, shall not engage in any act
intended to facilitate criminal activity,including drug-related activity,on or near the manufactured home,leased
lot,or otherwise.
(3) Resident,members of Resident's household,Resident's guests or other persons
visiting the Resident or on the lot with Resident's permission or consent,will not permit the manufactured home
to be used for,or facilitate criminal activity on or near the leased lot or otherwise,including drug-related activity,
regardless of whether the individual engaging in such activity is a member of the household or a guest.
(4) Resident, members of Resident's household, Resident's guests or other persons
visiting the Resident or on the lot with Resident's permission or consent, shall not engage in the unlawful
manufacturing, selling, using, storing, keeping or giving of a controlled substance (as such term is defined by
applicable laws), at any location,whether on or near the manufactured home, leased lot or otherwise.
(5) Resident,members of Resident's household,Resident's guests or other persons
under Resident's control or on the lot with Resident's permission or consent, shall not engage in any illegal
activity,including prostitution,criminal street gang activity,assault(including threatening or intimidating other
persons in the Community), battery,including but riot limited to the unlawful discharge of firearms or use of
fireworks on or near the leased lot or otherwise, or any breach of the Lease Agreement that jeopardizes the
health,safety,welfare or peaceful existence of the Community(hvner,Community Management, or other
Residents,or involving imminent or actual property damage.
VIOLATION OF THESE STANDARDS SHALL BE A VIOLATION OF THE LEASE
AGREEMENT AND SHALL CONSTITUTE CAUSE FOR TERMINATION OF TENANCY.
Unless otherwise provided by law,proof of violation shall;not require criminal conviction, but shall be
by a preponderance of the evidence.
15. COMMUNITY OWNER ACCESS TO MANUFACTURED HOME LOT. In an
emergency situation or by the request of the owner,the Community Management may enter a
manufactured home to prevent imminent danger to an occupant of the manufactured home or to the
manufactured home itself.Additionally,at all reasonable times and subject to any minimum notice
requirement of applicable law,the Community Management may enter onto the manufactured home lot for
purposes of repair and replacement of utilities and protection of the Community.
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16. SOLICITING OR PEDDLING. Soliciting or peddling is not permitted in the Community.
Vendors,peddlers and agents(including representatives of nonprofit organizations)are prohibited from
commercial solicitation of any nature in the Community. Vendors,peddlers and agents,after showing proof of
insurance to Community Management,may from time to time,and only upon prior written permission of
Community Management, be permitted to conduct business from prearranged facilities in the Community at
times and on dates specified by Community Management,but at no time will door-to-door solicitation be
permitted.
17. BUSINESS. No business or commercial enterprises shall be permitted to be operated
by any Resident, or any guest or invitee of any Resident, from or within the Community and no
advertising signs may be erected on the Resident's.lot or manufactured home.Babysitting for
compensation is a commercial enterprise and is prohibited within the Community except by written
consent of Community Management. Babysitting which is performed occasionally or sporadically and
which does not involve numerous additional vehicle trips within the Community is allowed;however,if
complaints about such babysitting activities are received by Community Management, it reserves the right,
in its sole and exclusive discretion,to prohibit future babysitting by the offending Resident(s).A"business"
also includes any commercial enterprise which: (i)is required to be licensed by local or State law; (ii)
requires traffic from outside the Community to enter for the purpose of dealing with said business; (iii)
uses any type of sign or advertising on the exterior of the manufactured home; (iv) includes door-to-door
canvassing of Community Residents; (v) interferes with the safe, pleasant, and enjoyable use of the
Community by any of its Residents; or(vi)involves the purchase of a manufactured home or of any
interest in a manufactured home for the purpose of resale, leasing, subleasing,renting or other business
use.
18. WEAPONS.The use,threatened use,or display of weapons within the Community by
Resident(s),members of Resident's family or guests or invitees is strictly prohibited including, but not limited
to, firearms,knives,paint ball guns, air rifles,bows and arrows,slingshots,cross bows,or any other type of
instrument to inflict bodily harm.Furthermore, anyone found to be in possession of a known illegal weapon
will be reported to the police department.
19. PATIOS. Only standard lawn or patio furniture will be permitted on patio including
gas,'barbeque grills. "I'hc patio and driveway are not to be used for storage of any items including,but not limited
to, interior furniture and any appliances, lawn equipment, exercise equipment and motor cycles or motor
vehicles.
20. RECREA`rioN/COMMON FACILITIES. The use of recreational facilities and/or other
amenities is a privilege and not a right.As such,their availability is not a bargai.ried for in consideration with
regard to entry into any lease with Community Owner. Such facilities may and will be closed from time to time
as necessary in Community Management's judgment for appropriate cleaning and/or repairs and no such
closures shall be grounds for abatement of rent. Rules posted in the common. and recreational areas will be
strictly enforced and Community Management shall have the right to bar usage of such facilities to any party
based upon such party's prior conduct. The recreational facilities are provided for use by Residents and their
guests on a"USE AT YOUR OWN RISK"basis. No drinking of alcoholic beverages is allowed in or around
the recreation areas or buildings within the Community. Any person caught damaging community property
will be reported to the police department and will be sent a violation notice.
A. LAUNDRY FACILITIES
(1) The laundry facilities are provided for the exclusive use of Residents of the
Residents Initials
Community. The h ar posted and the facilities may at the Community Managements discretion be
closed from time to time for cleaning or maintenance.
(2) Washers, dryers, and all other laundry facilities are to be cleaned by Resident,
inside and out,immediately after use. Clothes are to be removed from washers and dryers as soon the laundry
cycle is over. The laundry room and its equipment is to be left in a clean,neat and orderly condition. Any
laundry or articles of clothing remaining in the laundry room for more than 24 hour will have said items placed
in the trash.The laundry facilities are off lit-nits to anyone who is not directly doing laundry.
(3) Loitering in the laundry facilities is strictly prohibited.Children under the age of
eighteen (18)must be accompanied by an adult.
(4) Additional rules and regulations governing the use of the laundry and its
facilities are posted in the laundry area and are incorporated herein by reference.Community
Management may limit the use of these facilities by residents who do not abide by these rules.The
laundry facilities are provided as convenience to our residents and not as a consideration of rent.
21. CO.MPLATNTS AND CONCERNS, All complaints or concerns must be made in writing and
brought to the office in person.If Resident has any complaints,concerns,recommendations,etc.,please discuss
them with the Community Management.
22. REQUESTS FOR MAINTENANCE TO BE PERFORMED. All requests for Community
maintenance must: (1)be submitted to Community Management in writing at the Community office;(2)reflect
the date of submission;(3)state the nature and location of the maintenance activity requested;and(4)be signed
by the submitting Resident(s).Requests not submitted in conformance with this rule may not be acted upon by
Community Management,
23. USE AND OCCUPANCY. The residential lot shall be used solely for the purposes of placing a
manufactured home thereon for the residential use and occupancy of Resident.Without prior written consent of
the Community Owner,the lot may not be occupied by more than 2 persons per bedroom.
24. LIABILITY/DAMAGES,Community Owner shall not be liable for any loss of,. or damage
or injury to,the person or property of Resident,any member of Resident's household or any occupant,guest, or
invitee on the residential lot,caused by but not limited to: (a) any condition of the lot; (b) any act,fault,or
neglect of any Resident, a member of any Resident's household, or any occupant, guest or invitee of any
Resident or of any occupant of the Community, or of any trespasser;(e) fire,water,steam,rain,hail,wind,flood,
sewerage,odors, electrical current,insects,mold,mildew, fungus,or any act of God; or(d)theft or
embezzlement,unless any of the foregoing was caused by Community Owner's active or willful misconduct.
Resident does hereby indemn4 and hold harmless Community Owner,its affiliates and its and their officers,
directors,employees, assigns,and agents from any loss,cost, damage, or expense arising out of any claim or
cause of action asserted by any person because of any loss of,or damage or injury to,the person or property of
any person caused by any act,default,or neglect of any Resident,member of Resident's household,or occupant.
of the lot,or of any guest or invitee of any Resident or occupant of the lot.
25. INSURANCE. All Home Owners must have fire and liability insurance on their mobile
��
Residents Initials
home at all times'as n i ion of occupancy and provide proof of insurance to the Community Owner.
J'he Community Ov ner does not provide insurance for Home Owner's manufactured home located on the
residential lot or any of Resident's personal property. Resident is responsible for obtaining insurance,at
Resident's expense,to cover loss or damage to hisJher manufactured home and/or personal property_
26. APPLICABLE LAW.The Community Owner-Resident relationship created by the Lease
Agreement and the Standards that have been set forth shall be governed by all applicable federal law,the
law of the State of Pennsylvania, and any locally binding jurisdiction. It is the intent of Community Owner
and Resident to comply with applicable laws and that applicable federal,state,and local law shall override
any provision of these Standards that may be contrary to same.
27. SUBLEASING/SUBLETTING.No portion of the residential lot or manufactured home may be
subleased,rented or leased by Resident without the prior written consent of Owner,which consent may be
withheld, delayed or denied by Owner in its reasonable discretion. Without Community Owner's written
consent,any such act shall be void and shall constitute a default by Resident under the Lease Agreement.
Community Management may lease any manufactured home it owns and places on Community lots.Any
subleasing without Community Ovkmer's written consent shall be void,and shall constitute a default by Resident
under the Lease Agreement. Sales agreements,rent to own contracts,and owner financing plans where as the
title is not transferred to the buyer prior to the approved applicant signing the lease shall be considered subletting
and will be strictly prohibited. Neither residential lot leases nor manufactured home leases are transferable.Ifthe
home is subleased without written authorization of Community Owner,no such subleasing, occupancy or
collection of rents shall be deemed to be a waiver of this provision, or acceptance of the subtenant or occupant
as a tenant, or a release of the Resident(s) from further performance by Resident(s) of the provisions of the
Lease Agreement and these Standards.
28. ABOVE GROUND TANKS—Resident may not plate any above ground tanks on the premises
without prior written approval from the Community Owner.All tanks shall be placed to the rear of the home at
a designated area set:forth by the Community Owner.It shall be the Residents sole responsibility to comply
with all existing and future laws,local building/fire codes,rules,regulations, and ordinances related to storage
tanks, piping,equipment, installation, spill cleanup,removal, and disposal of said equipment as it pertains to the
Community. Furthermore, the Resident is solely responsible for the maintenance and repair of the tanks in such a
condition that the tanks do not leak or present a danger to the Community, Community Owner, other Residents,
or the environment. Residents shall indemnify and hold harmless the Community Owner from and against any
and all expenses, liabilities or costs of any kind or nature,including but not limited to attorneys fees arising out
of the installation, ownership, operation,maintenance, or closure of the storage tanks. In addition to any other
remedies available,upon Residents failure to comply with this section or obtain Community Owners written
approval, Community Owner may but is not obligated to (1) order the Resident to remove or repair the tank and
to restore the site to the original condition, (2)without waiving the Community Owners rights to indemnification
or to pursue any remedies available,remove or repair the tank and restore the site itself at the Residents expense,
and,'or(3)terminate the Residents tenancy according to law. Community Owner shall have the right to inspect
the premises to ensure compliance with this section.
29. UNDERGROUND STORAGE TANKS.Residents will no longer be permitted to utilize
underground storage tanks for storage of any petroleum products.Continued use of such tanks is a violation of
the Lease Agreement.
30. PRIVATE WATER TREATMENT FACILITIES.Residents in those communities that have
private water treatment facilities will no longer be permitted to use such water sources for non-essential
activities including,but not necessarily limited to,the washing of the following: trailers:' boats; lawn mowers;
recreational vehicles;or other similar equipment; driveways;out buildings; or other similar items.'Ihis
�I
Residents Initials f-'-�---'
prohibition will be sirilctly e f reed and violation of same will constitute a breach of the Rules and could result
in termination of appYicable leases and consequently termination of residency in the community.The Resident
shall be allowed to wash the mobile home once a year or as directed by Community Management.
31. LEASE AGREEMENT TERMS AND CONDITIONS.A written Lease Agreement will be
required of all new Residents prior to occupancy.Whether or not Resident chooses to execute a written Lease
Agreement,Resident is subject to the same terms and conditions as Residents who have executed Lease
Agreements.All of the terms and conditions of the Lease Agreement are specifically incorporated herein
by reference as Standards for Community Living governing the tenancy.Resident shall not assign the
Lease Agreement or any interest therein.In the case of automatically renewing lot leases that do not otherwise
provide that they are assumable,with the prior written consent of Community Owner,the purchaser is allowed
to assume only the remainder of the lot lease term in effect at the time of sale.
32. DEFAULT AND EVICTION.Any violation of these Standards for Community Living,the
Lease Agreement,State law,or applicable local ordinances shall,at Community Owner's option,shall be grounds
to terminate the Lease Agreement, and Resident, together with Home Owner's manufactured home, shall be
subject to eviction in accordance with the procedures prescribed by applicable law.
33. WAIVER. No waiver of any default by Resident shall be implied from any omission by
Community Owner to take any action with respect to the default if such default persists or is repeated. No
express waiver shall affect any default other than the default specified in the express waiver,and that only for
the time and to the extent stated in the express waiver. One or more waivers of any covenant, term, or
conditions of the Lease Agreement or these Standards by Community Owner shall not be construed as a waiver
of a subsequent breach of the same covenant,term,or condition.The consent of Community Owner to any act
by Resident requiring Community Owner's consent shall not be deemed to waive or render unnecessary
Community Owner's consent to any subsequent similar act by.Resident.The rights and remedies of Community
Owner contained herein are cumulative and shall be in addition to those prescribed by law.
34. SPECIAL EXCEPTIONS.Community Management reserves the exclusive,unrestricted.
right to grant special exceptions to these Standards when, in the exclusive opinion of Community
Management,special circumstances warrant the granting of special exceptions or written waiver of a particular
provision as it applies to a particular Resident or Residents,so long as such exception or waiver does not
interfere with the general welfare,health and safety of the other Residents of the Community.For example,
variances to these Standards may be granted by the Community Management due to space limitations,design
considerations,in cases where the intent of a Role or Regulation is met but not the specific requirement,or in
such other circurnstances where the exception will not disturb the quiet enjoyment of the Community by other
Residents, or when the basis for the variance is deemed sufficient in the discretion of Community
Management.
35, NON-ENGLISH STANDARDS.A copy of these Standards for CommuniN,Living is
available in Spanish.The Community Owner and each Resident receiving the Spanish version of these Standards
hereby acknowledge that the Spanish version is provided for.informational purposes only,may vary from the
English version,and that the English version of these Standards is the controlling version that governs the
relationship between Community Owner and Resident.
36. SURVIVAL.If any portion of these Standards is found to be void or unenforceable by a court of
competent jurisdiction,the balance of these Standards shall remain in hull force and effect, so long as the
general intent of the parties continues to be met.To the extent State or local law is inconsistent with any terms of
these Standards,such State or local law shall control the relationship between the parties hereto.
........ ..... --- 1
Residents Initials I
3'/. PRIMARY RESIDENT STATUS CHANGE. In the event that either the Applicant or
Co-applicant wants to be removed from the Lease and Community Standards,the Community Management
shall do so only if the remaining resident:
A. Applies to the Community as sole applicant and can meet all application requirements
B. Provides proof that the mobile home is owned solely by the remaining Resident. (Lien holders
excluded)
C. Provides proof of insurance on the mobile home.
D. Home passes a resale inspection.
38. OFAC REPRESENTATION. Resident hereby represents that neither Resident
nor any person who resides or is proposed to reside with Resident in the Community is or will be a
Prohibited Person,as that term is hereinafter defined.A"Prohibited Person" is any entity,person,or
party: (i) that is listed in the Annex to,or is otherwise subject to the provisions of,Executive Order 13224
issued on September 24,2001 ("E013224"); (ii)whose name.appears on the United States Treasury
Department's Office of Foreign Assets Control("OFAC")most current list of"Specifically Designated
National and Blocked Persons"(which list may be published from time to time in various mediums
including,but not limited to,the OFAC website,http:www.treas.gov/ofacltl lsdn.pdf)(the"OFAC List");(iii)
who commits,threatens to commit or,supports "terrorism," as that term is defined in EO 13224; or
(iv) who is otherwise affiliated with any entity or person listed above.
39. CIIANGES TO STANDARDS.Community Owner reserves the right to change any
of the wording,rules in whole or part, language, specifics, or terms of the Community Standards with a Thirty
(30)day written notice in accordance to the law.All changes become effective Thirty(30)days from Notice
d wr
ate whether acknowledged by the Resident or not.
Residents initials J
.J
'These Standards for Community Living(Rules and Regulations),dated
supersede all others.
Receipt Acknowledg
Resi en Ii . tore Resident Signature Date
Date n
IL
Name of others livi6j in the home (print) Age Relationship
Name of others living in the home (print) Age Rela ionship
fAAM��
Name of others living in the home (print) Age Relationship
Name of others living in the home (print) Age Relationship
Manufactured Home Community
Cornrnunity Management Date
i ��
Residents initials
NOTICE AND WAIVER
The accompanying contract, lease and/or informational material,together with the
Standards for Community Living,Rules or Addendums thereto(collectively,the
"Material(s)")is provided in English text("English Document")with a Spanish
"illustrative"version(the"Spanish Version").The undersigned Resident(s)/Prospective
Resident(s)(the"Undersigned")acknowledges and agrees:
1. The Spanish Version is provided for illustrative purposes only,that
the English Document is the controlling and governing language and any
inconsistencies between the two are resolved in favor of the English Document;
2. That the Spanish Version is not intended to be nor is it an exact
translation of the English Document,but is merely for illustrative purposes and
therefore Undersigned is advised to have the English Document reviewed by such
person(s)as Undersigned deems appropriate to ensure a full and complete
understanding of the controlling terms and conditions of any of the Material(s);
3. All notices,including any notices of breach,termination,rent increases,or
amendments are to be given in English,and Leiby's MHC,LLC and its affiliated entities
have no obligation to do so in Spanish;
4. That the enforcement of any contract or other form of agreement shall be
done in English only, and Undersigned does not assert,and hereby waives his/her/their
rights, if any.,to seek enforcement of the same in Spanish to the extent permitted by
applicable law,and Leiby's NMC,LLC and its affiliated entities are hereby relieved of any
duty or obligation to Undersigned regarding the same;and
5. Undersigned acknowledges that the execution of this Notice and Waiver is
an express condition of his/her/their right to execute any contract or other form of
agreement,is a bargained for and negotiated right,and shall be treated as part of any
contract and is hereby incorporated therein by reference.
IN WITNESS WHEREEOF,this Notice and Waiver is executed this day of
1 f0__
RESIDENT/PROSPECTIVE RESIDENT:
Name:
.Name:
PENNSYLVANIA . LEIBYS MHC , LLC
x ,
Residents initials
IMPORTANT NOTICE REQUIRED BYLAW
The rules set forth below (see Standards for Community Living, attached) govern
the terms of your lease or occupancy agreement with this mobile home park. The
law requires all of these rules to be fair and reasonable.
You may continue to stay in this park as long as you pay your rent and other
reasonable fees, service charges and assessments hereinafter set forth (or as
set forth in your lease agreement(s)) and abide by the rules of the park. Entrance
and exit fees may not be charged in excess of the actual cost to the mobile home
park owner or operator for the installation or removal fees of a mobile home in a
mobile home space.
You may be evicted for any of the following reasons:
1 . Nonpayment of rent.
2. A second or subsequent violation of the rules of the home park
occurring within a six-month period.
3. If there is a change in use of the park land or parts thereof.
4. Termination of the mobile home park.
You shall only be evicted in accordance with the following procedure:
1. A resident shall not be evicted by any self-help measure.
2. Prior to the commencement of any eviction proceeding, the mobile
home park owner shall notify you in writing of the particular breach or
violation of the lease or park rules by certified or registered mail.
(i) In the case of nonpayment of rent, the notice shall state that
an eviction proceeding may be commenced if the mobile home
resident does not pay the overdue rent within 20 days from the
date after April 1 and before September 1, and 30 days if given
on or after September 1 and before April 1 or an additional
nonpayment of rent occurring within six months of the giving of
the notice may result in eviction proceedings.
(ii)In the case of a breach of the lease or violation rules, other
than nonpayment of rent, the notice shall describe the particular
breach or violation. No eviction action shall be commenced
unless you have been notified as required by this section, and
upon a second or subsequent violation or breach occurring
within six months, the mobile home park owner may commence
eviction proceedings at any time within 60 days of the last
violation or breach.
Residents initials
You shall not be evicted when there is proof that the rules you are accused of
violating are not enforced with respect to the other mobile home residents on the
park premises.
In addition, no eviction proceeding for nonpayment of rent may be commenced
against you until you have received notice by certified or registered mail of the
nonpayment and have been given (the opportunity) to pay the overdue rent
Twenty (20) days from'the date of service if the notice is given on or after April 1st
and before September 15', and Thirty (30) days if notice is given on or after
September 1St and before April 1S`. However, only one notice of overdue rent is
required to be sent to you during any six (6) month period. If a second or
additional violation occurs within six (6) months from the date of the first notice
then eviction proceedings may commence immediately against you.
You are entitled to purchase goods or services from a seller of your choice and
the Community owner shall not restrict your right to do so.
If you desire to sell your mobile home, the mobile home Community Owner may
not prevent the sale of the mobile home and may not claim any fee in connection
therewith, unless there exists a separate written agreement. However, the
Community Owner may reserve the right to approve the purchaser as a resident
in the mobile home community. Enforcement of the Mobile Home Park Rights Act
is by the Attorney General of the Commonwealth of Pennsylvania or the District
Attorney of the county in which the mobile home Community is located. You may
also bring a private cause of action. If your rights are violated you may contact the
State bureau of Consumer Protection or your local District Attorney. 68 PA, S.
Section 398.4
EXHIBIT
6
Leclger Page 1 of 5
Date : 8/14/2013
Resident Ledger
Code Property Lease From 6/15/2011
Name Lisa Haag Unit Lease To 7/14/2011
Address 404 Venice Avenue Status Current Move In 6/15/2011
Rent 364 Move Out
City St. Zip Carlisle, PA 17015 Phone(0)- Phone(H)- (717) 691-1160
Date Description Charge Payment Balance Chg/Rec
6/7/2011 Application Fee 36.00 36.00 1,2„332fm%?
Ledger Page 2 of 5
10/1/2011 Trash Recovery (1012011) 6.00 364.00 1. C't>W=..__:,i
10/1/2011 Water 8/13-9/14/11 28.63 392.63 :1,::;__%`
10/1/2011 Sewer 8/13-9/14 29.43 422.06 t_;> '_
10/6/2011 Late Charge 50.00 472.06 _'<' ?`
11/1/2011 Extra Occupant Fees (11/2011) 7.00 479.06 „..a< ;?_F.
11/1/2011 Base Rent (11/2011) 345.00 824.06
11/1/2011 Trash Recovery (11/2011) 6.00 830.06 1s% ! :_
11/1/2011 Water 9/14-10/14/11 37.74 867.80
11/1/2011 Sewer 9/14-10/14/11 29.43 897'23
11/5/2011 chk# 1374 352.00 545.23
11/5/2011 chk# 1376 67.17 478.06
11/6/2011 Late Charge 50.00 528.06 ;,,;;?s` ' :`z
12/1/2011 Water 10/14-11/14/11 23.17 551.23 , :!
12/1/2011 Extra Occupant Fees (12/2011) 7.00 558 23 ;..
12/1/2011 Base Rent (12/2011) 345.00 903.23 '%,
12/1/2011 Trash Recovery (12/2011) 6.00 909.23 ?
12/1/2011 Sewer 10/14-11/14/11 29.43 938.66
12/5/2011 chk# 1386
352.00 586.66 9,5b "P
d-
12/5/2011
chk# 1387 52.60 534.06
12/6/2011 Late Charge 50.00 584.06 ,,.3. ,1......
1/1/2012 Water 11/14-12/13 27.42 611.48 L,s' 4
1/1/2012 Sewerll/14-12/13 29.43 640.91 1,��f?w!1_:,
1/1/2012 Extra Occupant Fees (01/2012) 7.00 647.91 1, f .?.!
1/1/2012 Base Rent (01/2012)
345.00 992.91 %:: ; '-'>>?
1/1/2012 Trash Recovery (01/2012) 6.00 998.91 '.�� ;C`e <:i.
1/4/2012 chk# 1395 352.00 646.91 ,6/'38
1/4/2012 chk# 1397 56.85 590.06 ",7?.`. '.
1/5/2012 chk# 1251 352.00 238.06 a7;.;%> ..
1/6/2012 Late Charge 50.00 288.06 1W>;t ---�;?
2/1/2012 Extra Occupant Fees (02/2012) 7.00 295.06 1,> �l.a:
2/1/2012 Base Rent (02/2012) 345.00 640.06
2/1/2012 Trash Recovery (02/2012) 6.00 646.06 11�i88 1
2/1/2012 Water 12/13-1/12 24.17 670.23 13�?t 7'1
2/1/2012 sewer 12/13-1/12 29.56 699.79 1 s?3,,:_ z:
2/5/2012 chk# 1265 352.00 347.79 `? ,53 1
2/5/2012 chk# 1266 53.73 294.06
2/8/2012 Late Charge 50.00 344.06 i:., £_?.-..ti..... .-
2/29/2012 Trash recovery adjustments 6/15/11-2/29/2012 (53.33) 290.73 1.4 110(2,')
3/1/2012 Water 1/12-2/13 34.49 325.22
3/1/2012 Extra Occupant Fees (03/2012) 7.00 332.22 1 '=
3/1/2012 Base Rent (03/2012) 335.00 667,22 _A,�_,':4C1?r
3/1/2012 Trash Recovery (03/2012) 10.00 677.22 L 1 R
3/5/2012 chk# 1110 352.00 325.22
3/5/2012 chk# 1109 64.05 261.17
3/14/2012 Sewer 1/12-2/13/12 29.56 290.73 3 f1
4/1/2012 Extra Occupant Fees (04/2012) 7.00 297.73 I,-='....'_�
4/1/2012 Base Rent (04/2012) 335.00 632.73 1
4/1/2012 Trash Recovery (04/2012)
https://www.yardiaspnc 8.com/36217carlyle/reports/Resident_Ledger.asp?hTent=44018&R... 8/14/2013
Ledger Page 3 of 5
chk# 1283 55.79 586.94
4/5/2012 chk# 1292 150.00 436.94 i_ i_' :=
4/6/2012 Late Charge
50.00 486.94
4/12/2012 Sewer 2/12-3/13/12 29.56 516.50 1 '2 .1'
26.23 542.73
4/23/2012 Water 2/13 to 3/13/12
5/1/2012 Extra Occupant Fees (05/2012) 7.00 549.73 1` `m`'?m'`
5/1/2012 Base Rent (05/2012) 335.00 884.73 A4'- : 47
5/1/2012 Trash Recovery (05/2012) 10.00 894.73 .`.
5/4/2012 chk# 0104 :CHECKscan Payment 66.80 827.93
5/4/2012 chk# 0105 :CHECKscan Payment 352.00 475.93 ` '-" "+11-
5/6/2012 Late Charge 50.00 525.93 >.?>
5/18/2012 Water: 3/13-4/13/12 37.241 563.17 L_,_<_ 6 >
5/18/2012 Sewer: 3/13 - 4/13/12 29.561 592.73 %:">::_:>.;}<::
16/1/2012 Extra Occupant Fees (06/2012) 7.00 599.73 -_%tt ?u
6/1/2012 Base Rent (06/2012) 335.00 934.73 Ll 'v
6/1/2012 Trash Recovery (06/2012) 10.00 944.73 ;_....r'3{?(€
6/5/2012 chk# 0102 :CHECKscan Payment Reversed by ctrl#1048242 352.00 592.73
6/8/2012 Returned check charge 25.00 617.73 :c ,�(l''e
6/8/2012 chk# 0102 NSF receipt Ctrl# 1042889 (352.00) 969.73 ' _« �_,�_.
6/10/2012 Late Fee due to NSF 50.001 1,019.73 .14-,0
6/11/2012 SW 04/13 to 05/12/2012 29.561 1,049.29 .1<<+,;C)0()5
1 6/13/2012 WB 04/13 to 05/12/2012 11.63 1,060.92 (,>:._..,?,..,:':.
6/19/2012 Sewer 05/12-06/12/12 29.56 1,090.481A0�s._._
6/19/2012 Water: 05/12-06/12/12 17.291 1,107.77 ti. �'s_I : :'.
7/1/2012 Extra Occupant Fees (07/2012) 7.001 1,114.77 1A
7/1/2012 Base Rent (07/2012) 335.00 1,449.77 1"t's :"
7/1/2012 Trash Recovery (07/2012) 10.00 1,459.77 1^<.'31 't3
7/1/2012 water 6/12-/7/12 26.24 1,486.01 1`".` :?'?%
7/1/2012 Sewer 06/12/2012-07/12/2012 38.39 1,524.40 :1_ 1L;^`:i
7/6/2012 chk# 1430 :CHECKscan Payment
352.00 1,172.40 ;i062'�7._:.
7/6/2012 chk# 1461 :CHECKscan Payment
45.00 1,127.40 1:.0 t .'.:-
8/1/2012 Extra Occupant Fees (08/2012) 7.001 1,134.40 1.57
8/1/2012 Base Rent (08/2012) 335.001 1,469.40 _`:Wi8;?23
8/1/2012 Trash Recovery (08/2012) 10.00 1,479.40 ;,E_. ,m1;.
8/5/2012 chk# 1477 :CHECKscan Payment 352.00 1,127.40 Q)l S-4
8/5/2012 chk# 1465 :CHECKscan Payment
64.63 1,062.77 ?:Ei 71_:;b'5
8/6/2012 Late Charge 50.00 1,112.77 i,.'.a::'_:; .5
8/12/2012 sewer 7/12 to 8/12 38.39 1,151.16 1. ?'.?�?s
8/20/2012 Water 07/12/12-08/12/2012 27.24 1,178.40 5 12 M-1QE
8/22/2012 Sewer 07/12/2012-08/12/2012 38.391 1,216.79 ;._`_.21 i_:a:;.
9/1/2012 Extra Occupant Fees (09/2012) 7.00 1,223.79
9/1/2012 Base Rent (09/2012) 347.00 1,570.79 :152140
9/1/2012 Trash Recovery (09/2012) 10.00 1,580.79
19/5/2012 chk# 1526 :CHECKscan Payment Reversed by ctrl#1085055 364.00 1,216.79
9/5/2012 chk# 1527 :CHECKscan Payment 65.63 1,151.16 1.08.1.0,18
9/10/2012 Returned check charge 25.001 1 1,176.16 3:?-<?Er
9/10/2012 Late Fee Due to NSF 50.00 1 1,226.16 1
364.00
9/10/2012 chk# 1526 NSF receipt Ctrl# 1081047 ( ) 1,590.16
https://wv,-"7.yardiaspnc8.com/36217carlyle/reports/Resident_Ledger.asp?hTent=44018&R... 8/14/2013
Ledger Page 4,of 4,o 5
Utilities-Swr billed separately 26.32 1,616.48
10/1/2012 sewer 8/12/12-9/12/12 38.391 1,654.87
10/1/2012 Extra Occupant Fees (10/2012) 7.00 1,661.87 _1.`5
10/1/2012 Base Rent (10/2012) 347.00 2,008.87 15,--5'7Q:`
10/1/2012 Trash Recovery (10/2012) 10.00 2,018.87
10/4/2012 chk# 20169151154 :CHECKscan Payment 182.00 1,836.87 <<!9 f6'1
10/4/2012 chk# 20169151165 :CHECKscan Payment 38.00 1,798.87 1i .:;E><:>
10/16/2012 Water - 9/12/12 - 10/12/12 26.32 1,825.19 1
10/16/2012 Sewer- 9/12/12 - 10/12/12 38.39 1,863.58 1 3:<<? t`i,
10/18/2012 chk# 40145844868164 :CHECKscan Payment 230.001 1,633.58 ;1.. ';;'c`i.2
11/1/2012 Extra Occupant Fees (11/2012) 7.00 1,640.58 t. t;'s<."�,t=
11/1/2012 Base Rent (11/2012) 347.00 1,987.58 y=` :_;
11/1/2012 Trash Recovery (11/2012) 10.00 1,997.58
11/5/2012 chk# 3128731 :CHECKscan Payment 62.00 1,935.58 1:_'[;_3_';.
11/5/2012 chk# 3128730 :CHECKscan Payment 37.00 1,898.58 a ' 9
12/1/2012 Extra Occupant Fees (12/2012) 7.00 1,905.58 ;t_`.;r< <_s <
12/1/2012 Base Rent (12/2012) 347.00 2,252.58 I5, ,;> , •,i.,:'
12/1/2012 Trash Recovery (12/2012) 10.00 2,262.58 1 1S
12/1/2012 sewer 10/12/12 to 11/12/12 38.39 2,300.97 3`_ ...-Wt WiW,
12/1/2012 water 10/12/12 to 11/12/12 30.91 2,331.88
12/27/2012 chk# 3128789 :CHECKscan Payment 200.00 2,131.88
1/1/2013 Extra Occupant Fees (01/2013) 7.00 2,138.88 "166
1/1/2013 Base Rent (01/2013) 347.00 2,485.88
1/1/2013 Trash Recovery (01/2013) 10.00 2,495.88
1/1/2013 Sewer- 11/12 to 12111 38.39 2,534.27
1/8/2013 Water - 11112 to 12/11 26.32 2,560.59
1/31/2013 Water bill for 12/11/12 to 01/11/13 29.99 2,590.58 101 ?u;
2/1/2013 Sewer 12/11/12 to 01/11/13 38.39 1 2,628.97 '162 m_
2/1/2013 Extra Occupant Fees (02/2013) 7.00 2,635.97
2/1/2013 Base Rent (02/2013) 347.00 2,982.97 16)ITI-3"
2/1/2013 Trash Recovery (02/2013) 10.00 2,992.97 1,;.;'.::__:CI
2/26/2013 Water bill 01/11/13 to 02/11/13 32.74 3,025.71 161'
Led_er Page 5 of 6
Late Charge 50.00 3,809.95 .'i, • i�
5/22/2013 sewer 4/10/13-5/11/13 38.39 3,848.34
5/22/2013 water 4/10/13-5/11/13 21.73 3,870.07 ;,h;:.:;Z.
3,877.07
6/1/2013 Extra Occupant Fees (0612013) 7.00 --
6/1/2013 Base Rent (06/2013) 347.001 4,224.07
6/1/2013 Trash Recovery (06/2013) 10.00 4,234.07 C
6/6/2013 Late Charge 50.00 4,284.07 "?
6/14/2013 sewer 5/11/13-6/12/13 38.39 4,322.46 %' '•-
6/14/2013 water 5/11/13-6/12/13 21.73 4'344,19
6/18/2013 Order of Possession Filing Fees 180.171 4,524.36
7/1/2013 Extra Occupant Fees (07/201.3) 7.00 4,531.36
7/1/2013 Base Rent (07/2013) 347.00 4,878.36 _
7/1/2013 Trash Recovery (07/2013) 10.00 4,888.36 z. ...
7/6/2013 Late Charge 50.00 4,938.36
7/17/2013 Sewer 6/12/13-7/12/13 38.39 4,976.75
12.55
7/17/2013 water 6/12/13-7/12/13
4,989.30
7.00
8/1/2013 Extra Occupant Fees (08/2013)
4,996.30
8/1/2013 Base Rent(08/2013) 347.00 5,343.30
8/1/2013 Trash Recovery (08/201.3) 10.00 5,353.30
8/6/20!3 Late Charge 50.00 5,403.30
8/1.6/2013 Sewer 7/;.2/13-8/12/13 38.39 5,441.69
8/1.6/201.3 Water 7/12/13-8/12/13 34.58 5,476.21
9/1/2013 Extra Occupant Fees (09/2013) 7.00 5,483.27
9/1/2013 Base Rent (09/2013) 353.00 5,836.27 3
9/1/2013 Trash Recovery (09/2013) 10.00 5,846.27
9/6/2013 Late Charge 50.00 5,896.27
9/18/2013 Sewer 8/12/13-9/12/13 38.39 5,934.66
9/18/2013 Water,8/12/13-9/12/13 23.56 5,958.22
9/23/2013 Court Fees - Possession Filing LT000076 39.67 5,997.89
10/1/2013 Extra Occupant Fees(10/2013) 7.00 6,004.89
10/1/2013 Base Rent: (10/2013) 353.00 6,357.89
10/1/2013 Trash Recovery (10/2013) 10.00 6,367.89 �'%_--.)
10/1/2013 Constable Fees - Lockout 97.50 6,465.39
10/2/2013 chk.0 3287884 :CHECKscan Payment 1,000.00 5,465.39
10/2/2013 chko 3287885 :CHECKscan Payment 500.00 4,965.39
4,271.00 694.39
10/2/2013 chk# 000085181 :CHECKscan Payment `'
Credit for Extra Occupant Fees - Shawn Patrickhas not lived in (42.00) 652.39
10/14/2013 '
Home since 5/6
10/14/2013 chk4F 3289202 :CHECKscan Payment 181.50 470.89
10/16/2013 Sewer 9/12/13-10/14/13 38.39 509.28
10/16/2013 water 9/12/13-10/14/13 29.99 539,27
11/1/2013 Base Rent (11/2013) 353.00 892.27
11/1/2013 Trash Recovery (11/2013) 10.00 902.27
11/5/2013 chk# 40147305575184 :CHECKscan Payment 182.00 720.27
11/6/2013 Late Charge 50.00 770.27 .:a,.'f?._'. f.__.
11/13/2013 chk-7 40147305575832 ;CHECKscan Payment 68.38 701.89
11/21/2013 sewer 10/14/13-11/14/13 38.39 1 740.28
11/21/2013 water l0/14/13-11,'14/13 31.83 772.11
https -«wAk.vardiaspncu.con-i/36'_'1 7carlyle:'reports,Resident_I,edger.asp?hTellt-=4401 S&R... 1!24/2014
Ledger Page 6 of 6
12/1/2013 Base Rent (12/2013) 35100 1,125.11 __
12/1/2013 Trash Recovery (12/2013) 10.00 1,135.11
12/6/2013 Late Charge 50.00 1,185.11
12/11/2013 r_hkr 40147844876982 :CHECKscan Payment 160.00 1,025.11
12/18/2013 SEWER 11/14/13-!2/13/13 38.39 1,063.50
12/18/2.01.3 WATER 1.1/14/13-1.2/13/13 28.15 1,091.65
1/1/2014 Base Rent(01/2014) 353.00 1,444.65
1/1/2014 Trash Recovery (01/2014) 10.00 1,454.65
1/6/2014 Late Charge 50.00 1,504.65 '-
1/6/2014 Court Fees - Landlord/Tenant Complaint Filed 134.671 1,639.32
lhttps:/iw%v .vardiaspne8.eo1nfi62 t 7carlyle/reportsiResident Ledger.asp?h'rent=44018&R... 1/24/2,014
EXHIBIT
C
Leiby's M11W
7073 Carlisle -Pike
Carlisle, PA 17013
(717) 697-1321
NOTICE
1' l
RESIDENT_�.. -so -H 0.G ��
ADDRESS `� o y V ►�� ✓
Dear
Pursuant to Pennsylvania Act No. 261 of'1976, and the notice provided to you as required
by that Act, please take notice that your monthly :-e.ntal payment of$ (Oq o ,
which was due on or before tln�_. _E 5+ 20 ( L-- , has not been received to
date. If this overdue rent, plus the $ _ late charge is not paid within thirty (30)days,
(by (L�A -�lr._ 20 1 ` ' ), we shall commence the eviction
proceedings an other remedies available to us b-, ;:,iw.
This will also serve to notify you that if you pi . the overdue rent within the thirty (30)
day period described above, but again fail to ma:.:c a rental payment when due within six
(6) months from the date of this notice, eviction 1 !oceedings may be commenced with no
further notice to you.
Signed,
Management
/ �Z/3
Date
My documents/Park Specific/forms/PA-NOT.doe 12100
EXHIBIT
D
COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript
COUNTY OF CUMBERLAND Residential Lease
Mag.Dist.No: MDJ-09-3-04 Leiby's M.H.C.
MDJ Name: Honorable Paula P.Correal V.
Address: 5275 East Trindle Road Lisa Haag, Shawn Patrick
M Suite 110
Mechanicsburg,PA 17050
!a Telephone: 717-697-2201
Lisa Haag Docket No: MJ-09304-1-T-9000076-2013
404 Venice Avenue Case Filed: 5/16/2013
Carlisle, PA 17015
Disposition Details
Grant possession. Yes
Grant possession if money judgment is not satisfied by the time of eviction. No
Disposition Summary
Docket No Plaint! Defendant Disposition Disposition Date
MJ-09304-LT-0000076-2013 Leiby's M.H.C. Lisa Haag Judgment for Plaintiff 05/28/2013
MJ-09304-LT-0000076-2013 Leiby's M.H.C. Shawn Patrick Judgment for Plaintiff 05/28/2013
Participant Joint/Several Liability Individual Liabilu Amount
Leiby's M.H.C. $0.00 $0.00 $0.00
Lisa Haag $4,033.74 $0.00 $4,033.74
Shawn Patrick $4,033.74 $0.00 $4,033.74
Judgment Detail ('Post Judgment)
In the matter of Leiby's M.H.C.vs. Lisa Haag;Shawn Patrick on 5/2812013 the judgment was awarded as follows:
The amount of rent per month,as established by the Magisterial District Judge,is$347.00
Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount
Rent in Arrears $3,870.07 $0.00 $3,870.07
Filing Fees $114.00 $0.00 $114.00
Costs $10.00 $0.00 $10.00
Server Fees $39.67 $0.00 $39.67
Grand Total: $4,033.74
Portion of judgment for physical damages arising out of residential lease: $0.00
MDJS 315A Page 1 of 3 Printed:05/28/2013 2:30:53PM
J
J
Leiby's M.H.C. Docket No.: MJ-09304-LT-0000076-2013
V.
Lisa Haag, Shawn Patrick
v a
IN AN ACTION INVOLVING A RESIDENTIAL LEASE,ANY PARTY HAS THE RIGHT TO'APPEAL FROM A JUDGMENT FOR POSSESSION
WITHIN TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT,BY.FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF
COURT-,OF;THE
COURT.OF COMMON PLEAS,CIVIL DIVISION. 'AN APPEAL•MUST BE FILED WITHIN THIRTY DAYS IN RESIDENTIAL LEASE
j ACTIONS.INVOLVING"A VICTIM OF DOMESTIC VIOLENCE. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT,IF ANY,
J IN ORDER TO OBTAIN A SUPERSEDEAS,THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER
OF THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE-THE APPEAL IS FILED.HOWEVER,LOW-INCOME AND/OR
:.,
SECTION II TENANTS SHOULD REFEkTO Pa.R.C.P.M.D.J.NO.1008 OR 1013 FOR DIFFERENT PROCEDURES REGARDING THIS DEPOSIT.
IF A PARTY WISHES ONLY TO APPEAL THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL.LEASE,THE PARTY—HAS
30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF
COURTS OF THE COURT OF COMMON PLEAS,CIVIL DIVISION.
THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF-THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THE 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.
ell-3
Date Senior Magisterial District Judge Paula P.Correal
certify that this is a true and correct copy of the record of the proceedings contain g the Iu gment.
Date Mabister4al District Judge
MDJS 315A Page 2 of 3 Printed:05/28/2013 2:30:53PM
Leiby's M.H.C. Docket No.: MJ-09304-LT-0000076-2013
V
Lisa Haag, Shawn Patrick
I
Participant List
Plaintiff(s)
Leiby's M.H.C.
7075 Carlisle Pike
Carlisle,PA 17015
Defendant(s)
Lisa Haag
404 Venice Avenue
Carlisle,PA`1701� ..�. --� �_ .r •- 7, .�..
Shawn Patrick
404 Venice Avenue
Carlisle,PA 17015
Authorized Agent-Plaintiff(s)
Beth Graves
cto l-eiby's M.H.C. ,
7075 Carlisle Pike
Carlisle,PA 170.15
MDJS 315A Page 3 of 3 Printed:05128/2013 2:30:53PM
EXHIBIT
E
MANUFACTURED HOME COMMUNITY
7075 Carlisle Pike, Carlisle PA 17015
PH(717)697.1321 FX(717)790-0690
Email:leibysmhp@aol.com
October 17, 2013
Lisa Haag
404 Venice Ave. Lot 213
Carlisle, PA 17015
Dear Resident:
We have received your letter and your payment of$181.50 on October 11, 2013. A new
lease has been created and the requested changes have been made to remove Shawn
Patrick from your lease (and remove the extra occupant fee since you first notified us on
May 6, 2013). Also since the title is now in your name and the home belongs to you, we
will remove your father Charles Haag as guarantor. This means that you are solely
responsible for lot rent.
We did agree for you to pay in two installments for October, 2013 but we will not
approve a payout agreement beyond October. You will need to get your finances in
order and pay your rent when due November 1, 2013.
Your current balance is $470.89 and includes the constable fee which is still your
responsibility. Paying$181.50 is not enough to lower your balance since there are also
utilities due. You will need to pay the total balance of$470.89 by the end of the month
to continue to be in good standing with us and prevent a refilling of Possession.
Please call the office to make an appointment to sign the new lease.
Sincerely,
Beth Graves
Leiby's MHC Manager
EXHIBIT
F
V
Leiby's MHP
7073 Carlisle Pike
Carlisle, PA 17013
(717) 647-1321
NOTICE
RESIDENT-
ADDRESS _G
Dear
Pursuant to Pennsylvania Act No. 261 of 1976, and the notice provided to you as required
by that Act,please take notice that your monthly rental payment of$ -7"-4 U-t t l
which was due on or before J , 20 /�3 , has not been received to
date. If this overdue rent, plus the $ _ late charge is not paid within thirty (30)days,
(by .0 .c e-4yj:> r" / Z. , 20 t D' we shall commence the eviction
proceedings and other remedies available to us by law.
This will also serve to notify you that if you pay the overdue rent within the thirty (30)
day period described above, but again fail to make a rental payment when due within six
(6) months from the date of this notice, eviction proceedings may be commenced with no
further notice to you.
t11 A ti-1,' ' It'2-1 l_
Signed, 4y
Management J 1 z
Date
Mydo"menrslPurkSpecrficF'ormVPA-NOT doe 12100
EXHIBIT
G
A y
C0 M MI0N'V'V=ALTH OF PENNSYLVANIA Notice of Judgment/Transcript
COUNTY OF CU BERLAND Residential Lease
Mag. Dist No MDJ-05-3-04 Leiby's M.H.C.
MD,j Name Honorable Kathryn H Silcox V
Address 5275 East Trindle Road Lisa Haag
Suite 110
Mechanicsburg, PA 17050
Telephone. 717-697-2201
Leiby's M H C Docket No MJ-09304-LT-0000180-2013
7075 Carlisle Pike Case Filed: 12/27/2013
Carlisle, PA 17015
Disposition Details
'an:oossessior, es
G ant possessor if money Judgment Is not sat sf"ed by the t>rne of eviction No
Disposition Summary ( Cross Complaint)
Docket Na PI in iff Defendan t Disposition Disposition Date
"a1 -09304-LT-0000180.2 13 ,.elby's M KC L sa Haag Judg?nent for Pialntiff v?-06?2 t4
Judgment Summary
Participant JointlSeveral Liability Individual Liability Amount
t.eibv's M,H C so or) $a CC $c o0
L sa Haag $0.00 st 589 32 51.53932
Judgment Finding i`PostJudgment)
in?he matter of Leiby's M H.0 vs Lisa I-iaaa on M.1-09304-'i T-0000180-2013,on 1/0612014 the judgment was awarded as fo lows.
amount of rent per month.as estab'ishec by the tAag steriai District.;ucge. s536300
Judgment Component Joint/Several Liability Individual Liability Deoosit Applied Am gun
Rent in Arrears so 3-C $1,454.65 51.454 655
F,iir.o Fees s0 OC $97 5C $9-1150
Costs $0.00 55 00 55.Ot?
Serve,--ees $0-00 $32 17 $32 17
Grand Total; $1,589.32
Portion of;udgmer for phys+Ca damages arss:ng out of res+der.t3al lease: S0,00
... _ _.__..... _ __+.....-...
NIMS 315.A gage 1 of 3 Pr.^ten:01106.2014 107 53P A
w
Leiby's M.H.0 Docket No.: MJ-09304-LT-0000180-2013
V
Lisa Haag
IN AN ACTION INVOLVING A RESIDENTIAL LEASE,ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION
WITHIN TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARYICLERK OF
COURT OF THE COURT OF COMMON PLEAS,CIVIL DIVISION. AN APPEAL MUST BE FILED WITHIN THIRTY DAYS IN RESIDENTIAL LEASE
ACTIONS INVOLVING A VICTIM OF DOMESTIC VIOLENCE. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT,IF ANY.
IN ORDER TO OBTAIN A SUPERSEDERS.THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARYICLERK OF COURTS THE LESSER
OF THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED,HOWEVER,LOW-INCOME AND/OR
SECTION 8 TENANTS SHOULD REFER TO Pa.R.C.P.M.D.J,NO.1008 OR 1013 FOR DIFFERENT PROCEDURES REGARDING THIS DEPOSIT.
IF A PARTY WISHES ONLY TO APPEAL THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE,THE PARTY HAS
30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARYICLERK OF
COURTS OF THE COURT OF COMMON PLEAS,CIVIL DIVISION,
THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH THE 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.
`3
9
Sate The Honorable Silcox
certify thatthis is a trace and correct copy of the record of tr?e proceedings containing the judgment.
Date Magisterial District Judge
__.._...._.__.............................__........
__...
MDJS 315A Page 2 of 3 Printed:01iG5120"4 107 5 3PM
CERTIFICATE OF SERVICE
AND NOW, on this 6th day of February, 2014, I hereby certify that I have served a true
and correct copy of the within document, via first class mail postage paid as follows:
Lisa Haag
404 Venice Avenue
Carlisle, PA 17015
Jerome P. DeSanto
LEIBY'S M.H.C., LLC : IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff :
C7 r
V. : No. 14-222 =�
rrix mrri. Fes;
2t c:
LISA HAAG, •
cn :'c'
Defendant.
PRAECIPE TO TERMINATE SUPERSEDEAS
PURSUANT TO Pa. R. C. P. M. D. J. 1008
TO THE PROTHONOTARY:
Please terminate the Supersedeas in the above-referenced matter. As an indigent tenant
under Pa.R.C.P.M.D.J.No. 1008(C)(3), Appellant/Defendant Lisa Haag was required to pay into
Court:
(a) a sum of money equal to one third (1/3) of her monthly rent at the time
of filing her appeal;
(b) an additional sum of two thirds (2/3) her monthly rent within 20 days
of filing her appeal; and
(c) additional deposits of one month's rent, in full, each 30 days after filing
her appeal.
Other than depositing $121.00 with the Court on January 15, 2014, Appellant/Defendant
Haag has not made the required payments. Leiby's MHC, LLC therefore requests that the
Supersedeas be terminated.
Respectfully Submitted,
McNEES WALLACE &NURICK, LLC
Barbara A. Darkes
I.D. No. 77419
Jerome P. DeSanto
I.D. No. 314637
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
Attorneys for Plaintiff, Leiby's Mobile Home
Dated: February 7, 2014 Community, LLC
2
TERMINATION OF SUPERSEDEAS
Upon confirmation of Appellant/Defendant Lisa Haag's failure to deposit the required
payments under Pa. R. C. P. M. D. J. No. 1008(C)(3), the Supersedeas is terminated.
Prothonotary
Deputy
Date: I l , 2014
CERTIFICATE OF SERVICE
AND NOW, on this 7th day of February, 2014, I hereby certify that I have served a true
and correct copy of the within document, via first class mail postage paid as follows:
Lisa Haag
404 Venice Avenue
Carlisle, PA 17015
Jerome P. DeSanto
LEIBY'S M.H.C., LLC : IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
LISA HAAG
Plaintiff,
Defendant.
: No. 14-222
cf.k
0 ,
7.7 Cr3,
CERTIFICATE OF SERVICE
I hereby certify, that on February 6, 2014, I served a true and correct copy of the
Complaint in this matter, via first class mail postage paid to the following:
Dated: April 4, 2014
Lisa Haag
404 Venice Avenue
Carlisle, PA 17015
LEIBY'S M.H.C., LLC
LISA HAAG
Plaintiff,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v. : No. 14 -222
Defendant. c->
s•?
Default Judgment. A true and correct copy of the aforesaid Notice is attached hereto as
Exhibit A.
McNEES WALLACE & NURICK, LLC
By
ai
Barba" Dar
I.D. No. 7419
Jerome P. DeSanto
I.D. No. 314637
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108 -1166
(717) 232 -8000
Attorneys for Plaintiff, Leiby's Mobile Home
Community, LLC
Dated: April 11, 2014
LEIBY'S M.H.C., LLC : IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
LISA HAAG
Plaintiff,
v. : No. 14 -222
Defendant.
NOTICE OF INTENTION TO FILE A PRAECIPE
FOR ENTRY OF DEFAULT JUDGMENT
TO: Lisa Haag
DATE: February 28, 2014
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION OR ENTER
A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN
WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS
SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT
A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE.
FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 249 -3166
Dated: February 28, 2014
McNEES WALLACE & NURICK LLC
Barbara A. Darkes
I.D. No. 77419
Jerome P. DeSanto
I.D. No. 314637
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108 -1166
(717) 232-8000
Attorneys for PlaintiffLeiby's Mobile Home
Community, LLC
2
CERTIFICATE OF SERVICE
AND NOW, on this 28th day of February, 2014, I hereby certify that I have served a true
and correct copy of the within document, via first class mail postage paid as follows:
Lisa Haag
404 Venice Avenue
Carlisle, PA 17015
Jerome P. DeSan to
CERTIFICATE OF SERVICE
AND NOW, on this 1 lth day of April, 2014, I hereby certify that I have served a true and
correct copy of the within document, via first class mail postage paid as follows:
Lisa Haag
404 Venice Avenue
Carlisle, PA 17015
LEIBY'S M.H.C., LLC : IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
LISA HAAG
Plaintiff,
vi. : No. 14 -222
Defendant.
RULE 236 NOTICE OF ENTRY OF JUDGMENT ON COUNT I — EVICTION
TO: LISA HAAG /
You are hereby notified that on a I y , 2014, Judgment in eviction was
entered against you and in favor of Plaintiff Leiby's M.H.C., LLC in the above - captioned case.
You are hereby evicted from lot 213 at 404 Venice Avenue, Carlisle, Pennsylvania 17015 and
possession of that lot now belongs to Plaintiff Leiby's M.H.C., LLC.
Date: /N //V
PROTHONOTARY
I hereby certify that the last known address of the Defendant is:
Lisa Haag
404 Venice Avenue
Carlisle, PA 17015
McNEES WALLACE & NURICK, LLC
By
1 / "or
ff_ _4grAL
Bar.ar . Darke
I.D. No. 7419
Jerome P. DeSanto
I.D. No. 314637
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108 -1166
(717) 232 -8000
Attorneys for Plaintiff, Leiby's Mobile Home
Community, LLC
Dated: April 11, 2014
LEIBY'S M.H.C., LLC
Plaintiff,
v. : No. 14 -222
LISA HAAG
2011-1 APR
2:
: IN THE C01EiR1CIf I�t
13 '' PLEAS
: CUMBERLAMMAN Y, "ENNSYLVANIA
Defendant.
PRAECIPE TO ENTER DEFAULT JUDGMENT ON
COUNTS II & III — BREACH OF CONTRACT & UNJUST ENRICHMENT
TO THE PROTHONOTARY:
Defendant Lisa Haag ( "Haag ") has failed to file an Answer to the Complaint of Plaintiff
Leiby's M.H.C., LLC ( "Leiby ") in the above- captioned matter within 20 days from the date of
service of said Complaint and within 10 days after notice of Plaintiff Leiby's intent to enter
default judgment.
Pursuant to Pa. R. Civ. P. 1037(b) please enter judgment in breach of contract and in
unjust enrichment, in favor of Plaintiff Leiby and against Defendant Haag for (a) the total
amount of $3,401.81, which includes all rent amounts, filing fees, and costs, due and owing to
Plaintiff Leiby from Defendant Haag as of April 1, 2014; (b) post judgment interest accruing at
the statutory rate of 6% per annum; and (c) rent that continues to accrue until Defendant Haag
vacates the Leased Space (lot 213 at 404 Venice Avenue Carlisle, Pennsylvania 17015).
I hereby certify that on February 28, 2014, Plaintiff Leiby, in accordance with Pa. R. Civ.
P. 237.1, mailed to Defendant Haag written Notice of Intent to File this Praecipe for Entry of
0M4 -9-pd
C'1- 3i:7L/
g#
o�u le
Default Judgment. A true and correct copy of the aforesaid Notice is attached hereto as
Exhibit A.
Dated: April 11, 2014
McNEES WALLACE & NURICK, LLC
Barbar. Dark
I.D. No. 419
Jerome P. DeSanto
I.D. No. 314637
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
Attorneys for Plaintiff Leiby's Mobile Home
Community, LLC
LEIBY'S M.H.C., LLC : IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
USA HAAG
Plaintiff,
: No. 14-222
Defendant.
NOTICE OF INTENTION TO FILE A PRAECIPE
FOR ENTRY OF DEFAULT JUDGMENT
TO: Lisa Haag
DATE: February 28, 2014
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION OR ENTER
A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN
WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS
SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT
A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 249 -3166
Dated: February 28, 2014
McNEES WALLACE & NURICK LLC
Barbara A. Darkes
I.D. No. 77419
Jerome P. DeSanto
I.D. No. 314637
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108 -1166
(717) 232 -8000
Attorneys for PlaintiffLeiby's Mobile Home
Community, LLC
2
CERTIFICATE OF SERVICE
AND NOW, on this 28th day of February, 2014, I hereby certify that I have served a true
and correct copy of the within document, via first class mail postage paid as follows:
Lisa Haag
404 Venice Avenue
Carlisle, PA 17015
Jerome P. DeSanto
CERTIFICATE OF SERVICE
AND NOW, on this 1 th day of April, 2014, I hereby certify that I have served a true and
correct copy of the within document, via first class mail postage paid as follows:
Lisa Haag
404 Venice Avenue
Carlisle, PA 17015
LEIBY'S M.H.C., LLC : IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
LISA HAAG
Plaintiff,
vi. : No. 14 -222
Defendant.
RULE 236 NOTICE OF ENTRY OF JUDGMENT
ON COUNT II & III — BREACH OF CONTRACT & UNJUST ENRICHMENT
TO: LISA HAAG
You are hereby notified that on (fir% C / `% , 2014, Judgment in breach of
contract and in unjust enrichment was entered against you and in favor of Plaintiff Leiby's
M.H.C., LLC in the above - captioned case. You are hereby liable to Plaintiff Leiby's M.H.C.,
LLC for (a) the amount of $3,041.81, which includes all rent amounts, filing fees, and costs, due
and owing to Plaintiff Leiby as of April 1, 2014; (b) post judgment interest accruing at the
statutory rate of 6% per annum; and (c) rent that continues to accrue until you vacate the Leased
Space (lot 213 at 404 Venice Avenue Carlisle, Pennsylvania 17015).
DATE: LI )1q)14/
PROTHONOTARY
I hereby certify that the last known address of the Defendant is:
Lisa Haag
404 Venice Avenue
Carlisle, PA 17015
if
/ : arbara Parkes V
I.D. No. ' ' 19
Jerome P. DeSanto
I.D. No. 314637
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108 -1166
(717) 232 -8000
Attorneys for Plaintiff, Leiby's Mobile Home
Community, LLC
Dated: April 11, 2014
LEIBY'S M.H.C., LLC
Plaintiff,
v. : No. 14 -222
LISA HAAG
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Defendant.
PRAECIPE TO ENTER DEFAULT JUDGMENT
ON COUNT IV — ATTORNEYS FEES AND OTHER COSTS AND EXPENSES
TO THE PROTHONOTARY:
Defendant Lisa Haag ( "Haag ") has failed to file an Answer to the Complaint of Plaintiff
Leiby's M.H.C., LLC ( "Leiby ") in the above - captioned matter within 20 days from the date of
service of said Complaint and within 10 days after notice of Plaintiff Leiby's intent to enter
default judgment.
Pursuant to Pa. R. Civ. P. 1037(b) please enter judgment in favor of Plaintiff Leiby and
against Defendant Haag, for payment of Plaintiff Leiby's attorneys' fees and other reasonable
costs, which Plaintiff Leiby incurred in pursuing the eviction of Defendant Haag and its breach
of contract claim. Under Pa. R. Civ. P. 1037(b)(1), Plaintiff Leiby respectfully requests that a
trial or arbitration be scheduled to determine the amount of attorneys' fees due and owing to
Plaintiff Leiby.
I hereby certify that on February 28, 2014, Plaintiff Leiby, in accordance with Pa. R. Civ.
P. 237.1, mailed to Defendant Haag written Notice of Intent to File this Praecipe for Entry of
Cov cI a4k
C� (�
02317100
P241 3bLiiictit
AQ
f.
Default Judgment. A true and correct copy of the aforesaid Notice is attached hereto as
Exhibit A.
Dated: April 11, 2014
McNEE WA L E & URICK, LLC
Barb A. Da
I.D. .77419
Jerome P. DeSanto
I.D. No. 314637
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
Attorneys for Plaintiff; Leiby's Mobile Home
Community, LLC
LEIBY'S M.H.C., LLC IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
LISA HAAG
Plaintiff,
v. : No. 14-222
Defendant.
NOTICE OF INTENTION TO FILE A PRAECIPE
FOR ENTRY OF DEFAULT JUDGMENT
TO: Lisa Haag
DATE: February 28, 2014
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION OR ENTER
A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN
WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS
SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT
A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 249 -3166
Dated: February 28, 2014'
McNEES WALLACE & NURICK LLC
Barbara A. Darkes
I.D. No. 77419
Jerome P. DeSanto
I.D. No. 314637
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108 -1166
(717) 232 -8000
Attorneys for Plaintiff Leiby's Mobile Home
Community, LLC
2
CERTIFICATE OF SERVICE
AND NOW, on this 28th day of February, 2014, I hereby certify that I have served a true
and correct copy of the within document, via first class mail postage paid as follows:
Lisa Haag
404 Venice Avenue
Carlisle, PA 17015
Jerome P. DeSanto
CERTIFICATE OF SERVICE
AND NOW, on this 11th day of April, 2014, I hereby certify that I have served a true and
correct copy of the within document, via first class mail postage paid as follows:
Lisa Haag
404 Venice Avenue
Carlisle, PA 17015
LEIBY'S M.H.C., LLC
vi.
LISA HAAG
Plaintiff',
Defendant.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: No. 14 -222
RULE 236 NOTICE OF ENTRY OF JUDGMENT
ON COUNT IV — ATTORNEYS FEES AND OTHER COSTS AND EXPENSES
1 /
TO: LISA HAAG
You are hereby notified that on
iq, 2014, Judgment for attorneys fees
and other costs and expenses was entered against you and in favor of Plaintiff Leiby's M.H.C.,
LLC in the above - captioned case. You are hereby liable to Plaintiff Leiby's M.H.C., LLC for all
attorneys' fees that Plaintiff Leiby incurred in pursuing its eviction action and breach of contract
action against you — an amount to be decided at trial or arbitration.
DATE: 1111
PROTHONOTARY
I hereby certify that the last known address of the Defendant is:
Lisa Haag
404 Venice Avenue
Carlisle, PA 17015
McNEE f ALL E & URICK, LLC
td
r —
Bar A. D es
I.D. 77419
Jerome P. DeSanto
I.D. No. 314637
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
Attorneys for Plaintiff Leiby's Mobile Home
Community, LLC
Dated: April 11, 2014
Barbara A. Darkes
I.D. No. 77419
Dana W. Chilson
Attorney I.D. No. 208718
Jerome P. DeSanto
I.D. No. 314637
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
r I .EL1-(: F iCE
OFTHE PROTHONOTARY
Y
2014 KAY 16 P1112: 30
CUMBERLAND COUNTY
PENNSYLVANIA
Attorneys for Plaintiff Leiby's M.H.C., LLC
LEIBY'S M.H.C., LLC
v.
LISA HAAG
Plaintiff,
Defendant.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: No. 14-222
PRAECIPE FOR A WRIT OF EXECUTION
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER AS FOLLOWS:
Writ of Execution For Money Judgment
(1) directed to the Sheriff of Cumberland County;
(2) against Lisa Haaq, 404 Venice Avenue, Lot 213, Carlisle, PA 17015,
Defendant;
(3) index this writ against Lisa Haaq, as Defendant;
(4) levy on all personal property, including but not limited to, the manufactured home
(VIN #1210242T), of Defendant found at Defendant's residence,
located at 404 Venice Avenue, Lot 213, Carlisle, PA 17015. A copy of the
Certificate and Attestation from the Commonwealth of Pennsylvania
Department of Transportation is attached hereto as Exhibit A;
(5) prepare a list of all the personal property found at Defendant's residence, located
at 404 Venice Avenue, Lot 213, Carlisle, PA 17015; and
(6) Amount Due $ 3,393.81
Attorneys° Fees $ 6,253.00
Cost Fees $ 469.77
Interest at 6% per annum from 4/14/14 $ 50.58
$ 10,167.16
g4t 30,0
3O5t733
McNEESALLACE & NURICK, LLC
By
Dated: May 16, 2014
Barbara A. Dares
I.D. No. 77419
Dana W. Chilson
I.D. No. 208718
Jerome P. DeSanto
I.D. No. 314637
100 Pine Street, P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
Counsel for Plaintiff Leiby's M.H. C., LLC
Exhibit A
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
SAFETY ADMINISTRATION
HARRISBURG, PA 17123
4/01/14
11:14
REFERENCE * 33617-0003
BARBARA A DARKES
100 PINE ST.
PO BOX 1166
HARRISBURG PA 17108-0000
CERTIFICATE & ATTESTATION
140910701000030 001
I hereby certify that Anita M. Wasko, Director of the Bureau of
Motor Vehicles of the Department of Transportation, is the legal custodian of
the Motor Vehicle Records of the Pennsylvania Department of Transportation.
IN TESTIMONY WHEREOF, I HAVE HEREUNTO SET. MY HAND AND SEAL OF THIS DEPARTMENT
ON THE ABOVE DATE IN ACCORDANCE WITH SECTION 6103 OF THE JUDICIAL CODE, TITLE
42, PA. Consolidated Statutes.
BARRY J. SCHOCH, P.E.
SECRETARY OF TRANSPORTATION
I hereby certify that the documents attached hereto are full, true and
correct photostatic, microfilm or printed copies of documents or electronically
stored information of which I have legal custody and that the copies conform to
the requirements of 6109 of the Judicial Code. Sales tax information is
redacted from applications for certificate of title in accordance with the Act
of April 9, 1929, P.L. 343, as amended, 72 P.S. Section 731.
TITLE: 36769985
VIN : 1210242T
CERTIFIED IN ACCORDANCE WITH SECTION 6103 OF THE JUDICIAL CODE, TITLE 42, PA.
Consolidated Statutes.
ANITA M. WASKO, DIRECTOR
BUREAU OF MOTOR VEHICLES
PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
VEHICLE RECORD ABSTRACT
4/01/14 11:14
PAGE 1
REFERENCE * 33617-0003
OWNER : LISA A HAAG
404 VENICE AVE
CARLISLE PA 17015
TITLE NUMBER
TAG NUMBER
VIN
MAKE
MODEL
RENEWAL WID
PREVIOUS TAG
LIENS
STOPS
: 36769985
: 1210242T
LAYTON
NO
: NO
TITLE BRAND INFORMATION
NO TITLE BRANDS EXIST FOR THIS TITLE
LIEN INFORMATION
NO LIENS EXIST FOR THIS TITLE
ADDRESS CORRESPONDENCE TO:
DEPARTMENT OF TRANSPORTATION
VEHICLE RECORD SERVICES
PO BOX 68691
HARRISBURG, PA 17106-8691
140910701000030 001
LESSEE : NONE
TITLE DATE : 11/30/84
REGISTRATION EXPIRY DATE:
BODY TYPE : MH
ODOMETER READING
*EXEMPT BY FED LAW
DUPLICATE TITLE COUNT 0.
VEHICLE YEAR : 1984
STOLEN DATE
INFORMATION:
IN STATE
OUT-OF-STATE
TDD IN STATE
TDD OUT-OF-STATE
(8:00 AM TO 5:00 PM)
1-800-932-4600
717-412-5300
1-800-228-0676
717-412-5380
WWW.DOT.STATE.PA.US
THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PA
DAVID D. BUELL, PROTHONOTARY
One Courthouse Square • Suite100 • Carlisle, PA • 17013
(717) 240-6195
www.ccpa.net
LEIBY'S M.H.C., LLC
Vs.
LISA HAAG
WRIT OF EXECUTION
(Pa R.C.P. 3252)
NO 14-222 Civil Term
CIVIL ACTION — LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs against LISA HAAG, 404 VENICE AVENUE, LOT 213,
CARLISLE, PA 17015 Defendant (s)
(1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein;
LEVY ON ALL PERSONAL PROPERTY, INCLUDING BUT NOT LIMITED TO, THE
MANUFACTURED HOME(VIN #1210.2qrr^), OF DEFENDANT FOUND AT DEFENDANT'S
RESIDENCE, LOCATED AT 404 VENICE AVENUE, LOT 213, CARLISLE, PA 17015. A COPY OF
THE CERTIFICATE AND ATTESTATION FROM THE COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION IS ATTACHED HERETO AS EXHIBIT A;.
(2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of
GARNISHEE(S), as garnishee, (Specifically describe property) and to notify the garnishee 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 (s) and from delivering any property of the defendant (s) or otherwise disposing thereof;
(c) the attachment shall not include
(i) the first $10,000 of each account of the defendant (s) 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 from execution, levy or attachment under Pennsylvania or federal law.
(ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed
$10,000.00 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 (s) 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
1
determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general
exemption provided in 42 Pa.C,S. § 8123.
(3) if property of the defendant (s) 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.
Amount Due $3,393.81 Plaintiff Paid
Interest AT 6% PER ANNUM FROM 4/14/14 - $50.58 Law Library $.50
Attorney's Comm. % $6,253.00 Due Prothonotary $2.25
Attorney Paid $'}$,d() Other Costs $469.77
Date: 5/16/14
gtAxi,L,
David D. Buell, Prothonotary
REQUESTING PARTY:
Name : Dana W. Chilson, Esq.
Address: McNees Wallace & Nurick, LLC
100 Pine Street, P.O. Box 1166
Harrisburg, PA 17108-1166
Attorney for: Plaintiff
Telephone: 717-232-8000
Supreme Court ID No. 208718
MAJOR EXEMPTIONS UNDER PENNSYLVANIA
AND FEDERAL LAW
1. $300 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
2
Barbara A. Darkes
I.D. No. 77419
Dana W. Chilson
Attorney I.D. No. 208718
Jerome P. DeSanto
I.D. No. 314637
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
;LED -Of I= ICS
tHE PROTHCHCTAF3'
2OI'4 MAY f6 PM I2:3
CUMBERLAND COUNTY
PENNSYLVANIA
Attorneys for Plaintiff Leiby's M.H.C., LLC
LEIBY'S M.H.C., LLC
v.
LISA HAAG
Plaintiff,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: No. 14-222
Defendant.
PRAECIPE FOR WRIT OF POSSESSION
To the Prothonotary of Cumberland County:
Please issue a writ of possession in the above -captioned matter upon the judgment
in eviction entered against Defendant Lisa Haag for the real property located at lot 213 at
404 Venice Avenue, Carlisle, Pennsylvania, 17015.
Dated: May 16, 2014
McNEES WALLACE & NURICK, LLC
By 9,01/40
Barbara A. Darkes
I.D. No. 77419
Dana W. Chilson
I.D. No. 208718
Jerome P. DeSanto
I.D. No. 314637
100 Pine Street, P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
Counsel for Plaintiff Leiby's M.H. C., LLC
a- g -,j j
L53
3)593,
i'7,2,As
loft
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
LEIBY'S M.H.C., LLC
VS.
LISA HAAG
No. 14-222 Civil Term
Costs
Attorney's $ 78.00
Plaintiff's $
Prothonotary $ 2.25 DUE CO
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sheriff of Cumberland County, Pennsylvania
(1) To satisfy the judgment for possession in the above matter you are directed to deliver
possession of the following described property to: (Plaintiff (s))
LEIBY'S M.H.C., LLC
being: (Premises as follows):
REAL PROPERTY LOCATED AT LOT 213 AT 404 VENICE AVENUE, CARLISLE, PA
17015
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any
property of the defendant (s) and sell his/her (or their) interest therein.
-Date 5/1'6/14...
(Seal)
David D. Buell, Prothonotary,
Common Pleas Court of Cumberland County2 PA
(7e-
2 of 2
No 14-222 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LEIBY'S M.H.C., LLC
LISA HAAG
Att' y
Plff (s)
Prothy
Sheriff
VS.
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
$ 78.00
$ 2.25
Plaintiff (s) attorney name and address:
DANA W, CHILSON, ESQ.
MCNEES WALLACE & NURICK LLC
100 PINE STREET, PO BOX 1166
HARRISBURG, PA 17108-1166
By virtue of this writ, on the
Attorney for Plaintiff (s)
Where papers may be served
day of , . I caused the within
named , to have possession of the premises described with the
appurtenances, and
Sworn and subscribed to before me this
Day of
So Answers,
Sheriff
By
Prothonotary Deputy
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson
Sheriff THE PRUTI104u f:�f
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
OFFICE cF Tf5" Sf RI
JUN --4 PM 3:
CUMBERLAND COUNTY
PENNSYLVANIA
Leiby's M.H.C.
vs. Case Number
Lisa Haag 2014-222
SHERIFF'S RETURN OF SERVICE
06/02/2014 04:31 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Writ of Possession
by "personally" handing a true and attested copy to a person representing themselves to be the Defendant,
to wit: Lisa Haag at 404 Venice Ave, Lot 213, Silver Spring Township, Carlisle, PA 17015, Cumberland
County.
(cE„,n--)
DAWN KELL, DEPUTY
SHERIFF COST: $30.25 SO ANSWERS,
June 04, 2014 RONNY R ANDERSON, SHERIFF
(c) CcuntySuite Sheriff, Teleosoft, !�o,
SHERIFF ' S SALE
By Virtue of a Writ of Execution
No. 2014-222
Issued out of the Court of Common Pleas of Cumberland County, Pennsylvania and to me directed, I will expose the
following described property at public sale at
404 Venice Ave, Lot 213, Silver Spring Township, Carlisle, PA 17015
on
THURSDAY, JUNE 19, 2014
AT 10:00 O'CLOCK A.M.
Prevailing Time,the following described property, to wit:
Two-tone blue mobile home with white trim—VIN 1210242T
FIREARMS:
Gamo—S/N 041051044706
Mossberg 22(with Simmons scope 3x9)—model 702—S/N EFK252788
Mossberg 243(with Weaver scope 3x9)—S/N BA169910
Ruger 280(with HC scope 3x9)—Model M77—S/N 77327923
=
2 Sofas Hca r
End table `E u•�
Sanyo television cD ^�
Sony DVD player
Book shelf with assorted PS3 games <
Coffee table " :
Book shelf with assorted DVD's
Entertainment stand
PlayStation 3 gaming system
Table with 3 chairs
General Electric refrigerator
General Electric gas stove
General Electric microwave
Miscellaneous pots/pans/utensils
Roper washer and dryer
Bed
Dresser
Nightstand
Floor lamp
Toshiba television
HP laptop
Chest
Recliner
Office chair
Vacuum
Computer desk
LG computer
Ladder
Toro leaf blower
Fishing rod
and all other personal property of defendant(s).
Any person claiming any interest in said personal property shall file the same prior to the sale, with the Sheriff's
Office. A schedule of distribution will be filed in the Sheriff's Office no later than five (5) days after the date of the
sale, and distribution made ten (10)days thereafter unless exceptions are filed with the Sheriffs Office prior thereto.
Seized and taken into execution to be sold as the property of LISA HAAG in suit of LEIBY'S
M.H.C. and to be sold by me.
Attorney for the Plaintiff:
Dana Chilson RONNY R ANDERSON, Sheriff
Harrisburg, PA CUMBERLAND COUNTY, Pennsylvania
i:j Ctlrrt,StIlt;Ztter;f` e,
f /
Ronny R. Anderson, Sheriff, who being duly sworn according to law, says that due and
legal notice having been given according to law, he sold the personal property of Lisa
Haag, of 404 Venice Avenue, Lot 213, Carlisle, PA 17015 for the sum of$1.00, to
Leiby's M.H.C. LLC, it being the highest bid and price quoted for the same. Date and
Time of sale, Thursday, June 19, 2014 at, 10:00 E.D.S.T., at, 404 Venice Avenue, Lot
213, Carlisle, Cumberland County Pennsylvania 17015.
Property taken by plaintiff:
Two-tone blue mobile home with white trim—VIN 1210242T
Brown sofa
Roper washer and dryer
Sanyo television
General Electric gas stove
So Answers, �� " , j
r Ronny R. Anderson, Sheriff Of-Lk
Sworn and Subscribed to before me this
ofx�4 2014A.D.
Notary Public
NOTARIAL-SEAL
4 CLAUDIA A.B I Ek,,NOTARY PUBIC
CLA . ,'Carlisle Sem Cumberla nil
�` �►Corn Ex il't§Apt**20;=7
�y.;1 cS 4,2017
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
OFFICE OF THE SHERIFF
FILED -OFFICE
CF THE PROTHONOTARY
2014 AUG -6 ! l l :22
CUMBERLAND COUNTY
• PENNSYLVANIA
Leiby's M.H.C.
vs.
Lisa Haag
Case Number
2014-222
SHERIFF'S RETURN OF SERVICE
06/02/2014 04:31 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Writ of
Possession by "personally" handing a true and attested copy to a person representing themselves to be
the Defendant, to wit: Lisa Haag at 404 Venice Ave, Lot 213, Silver Spring Township, Carlisle, PA 17015,
Cumberland County.
06/19/2014 By virtue of this writ, Sheriff Ronny R. Anderson caused the within named Plaintiff to have possession of
the premises described as 404 Venice Avenue, Lot 213, Carlisle, PA 17015.
SHERIFF COST: $75.28 SO ANSWERS,
August 05, 2014
(c) CountySuite Sheriff, Toleosoff. Inc.
A 30y9 /
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ►- IL ED -Or FI '{=
Sheriff ‘wtita, ar rrrraf+rt Ur THE PROTHONO #Ari`'
' alto
2014 AUG -6 All 10: 22
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
OFFICE OF THE SHERIFF
CUMBERLAND COUNTY
PENNSYLVANIA
Leiby's M.H.C.
vs. Case Number
Lisa Haag 2014-222
SHERIFF'S RETURN OF SERVICE
06/02/2014 04:31 PM - Dawn Kell, Deputy , being duly sworn according to law, states that on June 02, 2014 at 4:31
PM hours, served the requested Writ of Execution and Claim for Exemption Form by "personally" handing
a true and attested copy to a person representing themselves to be the Defendant, to wit: Lisa Haag at
404 Venice Ave, Lot 213, Silver Spring Township, Carlisle, PA 17015, informed Defendant of contents of
same and levied upon personal property as directed. Copy of levy mailed to attorney and letter mailed to
defendant on June 4, 2014.
06/06/2014 12:12 PM - Deputy Christopher Sharpe, being duly sworn according to law, states service was performed
by posting a true copy of the requested Sheriffs Sale Bill in the above titled action, upon the property
located at 404 Venice Ave, Lot 213, Silver Spring Township, Carlisle, PA 17015, Cumberland County.
06/19/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, says that due and legal notice having
been given according to law, he sold the personal property of Lisa Haag, of 404 Venice Avenue, Lot 213,
Carlisle, PA 17015 for the sum of $1.00, to Leiby's M.H.C. LLC, it being the highest bid and price quoted
for the same. Date and Time of sale, Thursday, June 19, 2014 at, 10:00 E.D.S.T., at, 404 Venice Avenue,
Lot 213, Carlisle, Cumberland County Pennsylvania 17015.
Property taken by plaintiff:
Two-tone blue mobile home with white trim — VIN 1210242T
Brown sofa
Roper washer and dryer
Sanyo television
General Electric gas stove
08/05/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is
returned STAYED, per request from plaintiffs attorney.
SHERIFF COST: $87.49 SO ANSWERS,
August 05, 2014
(c) CountySuite Sheriff, Teleosofi, Inc.
X'�
RONR ANDERSON, SHERIFF
S1) 11, �l•
Q711 6 3--
APX 3 09Y 4 4?
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
SAFETY ADMINISTRATION
HARRISBURG,.PA 17123
4/01/14
11:14
REFERENCE It 33617-0003
BARBARA A,DARKES
100 PINE ST.
PO BOX 1166
HARRISBURG PA 17108-0000
CERTIFICATE & ATTESTATION
140910701000030 001
I hereby certify that Anita M. Wasko, Director of the Bureau of
Motor Vehicles of the Department of Transportation, is the legal custodian of
the Motor Vehicle Records of the Pennsylvania Department of Transportation.
IN TESTIMONY WHEREOF, I HAVE HEREUNTO SET.MY HAND AND SEAL OF THIS DEPARTMENT
ON THE ABOVE DATE IN ACCORDANCE WITH SECTION 6103 OF THE JUDICIAL CODE, TITLE
42, PA. Consolidated Statutes.
44‘709.
BARRY J. SCHOCH, P.E.
SECRETARY OF TRANSPORTATION
I hereby certify that the documents attached hereto are full, true and
correct photostatic, microfilm or printed copies of documents or electronically
stored information of which I have legal custody and that the copies conform to
the requirements of 6109 of the Judicial Code. Sales tax information is
redacted from applications for certificate of title in accordance with the Act
of April 9, 1929, P.L. 343, as amended, 72 P.S. Section 731.
TITLE: 36769985
VIN : 1210242T
CERTIFIED IN ACCORDANCE WITH SECTION 6103 OF THE JUDICIAL CODE, TITLE 42, PA.
Consolidated Statutes.
.�Cc� �•�-plc ,
ANITA M. WASKO, DIRECTOR
BUREAU OF MOTOR VEHICLES
PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
VEHICLE RECORD ABSTRACT
4/01/14 11:14
PAGE ' 1
REFERENCE it 33617-0003
OWNER : LISA A HAAG
404 VENICE AVE
CARLISLE PA 17015
TITLE NUMBER : 36769985
TAG NUMBER
VIN : 1210242T
MAKE : LAYTON
MODEL
RENEWAL WID
PREVIOUS TAG
LIENS : NO
STOPS : NO
TITLE BRAND INFORMATION
NO TITLE BRANDS EXIST FOR THIS TITLE
'LIEN INFORMATION
NO LIENS EXIST FOR THIS TITLE
ADDRESS CORRESPONDENCE TO:
DEPARTMENT OF TRANSPORTATION
VEHICLE RECORD SERVICES
PO BOX 68691
HARRISBURG, PA 17106-8691
140910701000030 001
LESSEE : NONE
TITLE DATE
REGISTRATION EXPIRY DATE:
BODY TYPE
ODOMETER READING
*EXEMPT BY FED LAW
DUPLICATE TITLE COUNT 0
VEHICLE YEAR
STOLEN DATE
11/30/84
MH
INFORMATION:
IN STATE
OUT-OF-STATE
TDD IN STATE
TDD OUT-OF-STATE
: 1984
(8:00 AM TO 5:00 PM)
1-800-932-4600
717-412-5300
1-800-228-0676
717-412-5380
WWW.DOT.STATE.PA.US