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Home My WebLink About14-0866 COMMONWEALTH OF PENNSYLVANIA NOTICE OF APPEAL COURT OF COMMON Nvnbe.clarl� Ccx)'A FROM JUDICIAL DISTRICT DISTRICT JUSTICE JUDGMENT 0q COMMON PLEAS Ns - l U t NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas on appeal from the judgment rendered by the District Justice on the date and in the case mentioned below. bog OF ORUAW S* 00 " �' fyv! n Wdv-6 PLC l�� nno- SQ 1�� n � n CITY * A STA L 40q aim NTFE CASE OF ( )� � c r�rr�s TLJRE APPELL A f� T LT . ° vr>` /� • Bea �z This block will be signed ONLY when this notation is required under Pa. R.CP.JP. Nor If ant was CLAIMANT (see Pa. R.C.P.J.P. NO. 10088. This Notice of Appeal, when received by the District Justice, will operate as a 1001(6) in action before District Justice, he MAST SUPERSEDEAS to the judgment for possession in this case FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. S ignature of Prothonotary a Dr�outy 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.J.P. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee). PRAECIPEs To Prothonotary Enter rule upon Narne or apperlee(s) oppellee(s), to file a complaint in this appeal (Common Pleas No, ) within twenty (20) days after service of rule or suffer entry of judgment of non pros Sgrof " of XPOIN4 or Irs stew" or agent RULES To appeaee(s). A*m of ArieMeefsl (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 WILL BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of moiling Date. 20_ . sbreu,e of P►oehornrary or DRastb VINVAIASNN3 fi AMU LAN v'1838wno I 03J 101 A aNfl'rf� F AOPC 312 -90 COURT FILE TO BE FILED WITH PROTHONOTARY COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript COUNTY OF CUMBERLAND Residential Lease Mag. Dist. No: MDJ- 09 -3 -01 Quentin Holdings LLC, Lynne Seymour MDJ Name: Honorable H. Anthony Adams V. Address: 35 West Orange Street LarriSa Negley, Richard Estright Shippensburg, PA 17257 Telephone: 717- 532 -7676 Quentin Holdings LLC, Lynne Seymour Docket No: MJ- 09301 -LT- 0000007 -2014 2159 White Street Case Filed: 1/9/2014 Suite 3 -139 York, PA 17404 Disposition Details _ Disposition Summary (cc -Cross Complaint) Docket No Plaintiff Defendant Disposition Disposition Date MJ- 09301 -LT- 0000007 -2014 Quentin Holdings LLC, Lynne Larrisa Negley Judgment for Defendant 02/04/2014 Seymour MJ- 09301 -LT- 0000007 -2014 Quentin Holdings LLC, Lynne Richard Estright Judgment for Defendant 02/04/2014 Seymour 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. 914 Date Magisterial District Judge H. Anthony Adams I certify that this is a true and correct copy of the record of the proceedings containing the lu gment. Date Magisterial District Judge MDJS 315A Page 1 of 2 Printed: 02/04/2014 2:30:OOPM . .--1,- ,:ii,, 7,7,i, -lq FEB 5:0 „r, 10: Art (..„ c I JHBERL A A NO PENNSYL LtiLihT Y ANA C'k,),MrlArCi a bqiiq Y tco-iTco\k* Tizichoset .-5.)r,.cfni_ lq A • , I . , 1 tl •- • C- bi tick-Qi IL ( ( . 1 i - COMMONWEALTH OF PENNSYL . IA Kist\k- Cik krU esk,)VD\t C_ __., . Notarial Seal i Lorena M.Wiser,Notary Pub-c City of York,York County 0 t 14 MEMBER.Commission Expires Sept.20,2014 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES A ' U.S. Postal ServiceTM U.S. Postal Service. '0,- CERTIFIED MAIL. RECEIPT CO CERTIFIED MAIL. RECEIPT ru (Domestic Mall Only;No Insurance Coverage Provided) m (Doitiestic'Mall Only;No insurance Coverage Provided) N N For delivery information visit our unbolts at antocuspLoorft For delivery intornudion visit our wobsite at wuncuspe.conuo m m -u -a — ____ ______— ----r ru ru Postage S Postage 1$ o Certified Fee 1=1 Certified Feu, D D -I Postmark Postmark O Return Reciept Fee CI Return Reciept Fee (Endorsement Required) Here (Endorsement Required) Here 0 Restricted Delivery Fee ,__, Restricted Delivery Fee D (Endorsement Required) 1--, (Endorsement Required) Lri Ln o able H.Anthony Adams Total Postage&Fees $ Total Postage&Fees 1:r m m Shippensburg,gpe Street A1e7e2t 17257 o Sent To I=1 Sent To Hon o Larrisa Negley m N Richard Estright Street,Apt.No.; ' N Street,Apt.No.; 35 West pensb Orange or PO Box No. 17 Town Mills or PO Box No. ip City,State.ZIP+4 Shippensburg,PA 17257 City,State,ZIP+4 PS Form 3800,June 2002 See Reverse for Instructions PS Form 3800,June 2002 See Reverse for Instructions OE 2:- ' L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA QUENTIN HOLDINGS, LLC • NO \ y - W Vo Plaintiff Vs. • CIVIL ACTION-LAW • LARRISA NEGLEY and RICHARD ESTRIGHT, • Defendants • NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the foregoing pages,you must take action within twenty(20)days after this Complaint and Notice are served, by entering appearance personally or by attorney to the claims set forth against you. You are warned that if you fail to do so,the case may proceed without you and 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 in these papers by the Plaintiff You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service York County Bar Association 137 East Market Street York, PA 17401 (717) 854-8755 ,) f J --3 ` BLAKE 8 GROSS,L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York,PA 17401 Page 1 of 7 717-848-3078 g FAX 717-848-2777 AVISO USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion dentro veinte (20) dias a partir de la fecha en que recibio la demanda y el aviso. Usted debe presentar comparecencia escrita en person or por abogado y presentar en la Corte por escrito sus defensas o sus objeciones a leas demandas en su contra. Se le avisa que si no se defiende,el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso o notificacion por cualquier otra queja o compensacion reclamados por el demandante. USTED PUEDER PERDER DINERO, 0 PROPIEDADES U OTROS DERECHOS IMPORTANTES PARA USTED. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO, SI NO TIENE 0 NO PUEDE PAGAR UN ABOGADO, VAYA 0 LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Lawyer Referral Service York County Bar Association 137 East Market York, PA 17401 (717) 854-8755 BLAKE Et GROSS,L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York,PA 17401 Page 2 of 7 717-848-3078 g FAX 717-848-2777 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA QUENTIN HOLDINGS, LLC • • Plaintiff • Vs. CIVIL ACTION -LAW • • LARRISA NEGLEY and • RICHARD ESTRIGHT, • Defendants COMPLAINT q'� AND NOW, this the } day of February,2014, comes the Plaintiffs, by and through its attorney, Kurt A. Blake, Esquire of Blake & Gross, LLC, and in support of this complaint, aver as follows: 1. Plaintiff is Quentin Holdings, LLC, a duly formed and existing Pennsylvania Business Entity,with a mailing address of 2159 white Street, Suite 3-139, York, PA 17404 (Hereinafter "OWNER" or "LANDLORD"). 2. Defendants are an adult individuals with a last known address of 17 Town Mills, Shippensburg, PA 17257. 3. Plaintiff is the owner of real property known as Town Mills Mobile Home Park, which includes the Defendants' address of 17 Town Mills address, hereinafter referred to as "Real Property". 4. The Plaintiff and Defendant have a written lease agreement which BLAKE&GROSS,L.L.C. has been attached to this Complaint as Exhibit "A". ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York,PA 17401 Page 3 of 7 717-848-3078 g FAX 717-848-2777 • 5. Notice to Quit is waived per the terms of the lease. 6. The Prior Owner assigned to the Plaintiff the lease agreements. 7. The Defendant has defaulted under the terms and conditions of the lease and failed to comply with the lease terms and conditions, by failing to make payments as detailed: A. $400.00 October Rent B. 30.00 October Late fee C. $400.00 November Rent D. $30.00 November late fee E. $400.00 December Rent F. $30.00 December late G. $400.00 January Rent H. $30.00 January Late Fee I. $400.00 February Rent J. $30.00 February late Fee. 8. Plaintiff is entitled to reasonable legal fees and costs of$500.00 for any action before the Board of Arbitrators and an additional$800.00 for any proceedings beyond that proceeding. 9. Plaintiff incurred filing fees and is entitled to that amount. BLAKE Et GROSS,L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York,PA 17401 Page 4 of 7 717-848-3078 g FAX 717-848-2777 10. Plaintiff also will continue to be entitled to rents monthly of$400.00, late fees, etc during the pendency of appeal. 11. There is a security deposit of$250.00. 12. Final judgment may have credits for payments made to the Prothonotary, however late fees will continue to accrue given the arrears in payments. WHEREFORE, the Plaintiff respectfully requests judgment against the Defendant for a judgment for possession and money judgment of $2150.00, $500.00 for proceedings before the Board of Arbitrators or $1300.00 in legal fees if appealed, as well as costs. Resp ct Submitted: Bla • oss,LLC BY: Kurt A. ake, Esquire Atto e,SID No. 68791 29 E.- 'hiladelphia Street York, P 17401 (717) 8'8-3078 BLAKE Et GROSS,L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York,PA 17401 Page 5 of 7 717-848-3078 g FAX 717-848-2777 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA • QUENTIN HOLDINGS, LLC • NO 1 4 -Sc,-) Plaintiff • • Vs. • CIVIL ACTION -LAW • LARRISA NEGLEY and RICHARD ESTRIGHT, • Defendants • CERTIFICATE OF SERVICE I, the undersigned, do hereby state that a true and correct copy of the foregoing Complaint was served upon the following person(s) by United States Mails, postage prepaid and addressed as follows: Larrisa Negley Richard Estright 17 Town Mills Shippensburg, PA 17257 C r Dated: February 2014 BY: A. Blake BLAKE Ft GROSS,L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York,PA 17401 Page 6 of 7 717-848-3078 g FAX 717-848-2777 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA QUENTIN HOLDINGS,LLC • NO 1 (0(0 • Plaintiff Vs. CIVIL ACTION-LAW LARRISA NEGLEY and • RICHARD ESTRIGHT, Defendants VERIFICATION I,the undersigned, hereby verify that the statements in the foregoing Complaint are true and correct to the best of my understanding. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. Section 4904, relating to Unworn Falsifications to Authorities. Quentin Holdings,LLC DATE: BY: _ As2/< C : \ Users \ kblake \ Documents \ MyFiles \ Civil Forms\landlord tenantcomplaint.wpd BLAKE&GROSS,L.L.C. A1TORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York,PA 17401 Pa e 7 of 7 717.848.3078 g FAX 717-848-2777 /22/X' l0 ,Th rri LEASE AGREEMENT TOWN MILLS MOBILE HOME PARK LOT# �7 1. PARTIES. This Lease Agreement(the"Lease")is made this /s� day of rte/ / ,20 L3 by and between Town Mills MHP,("Landlord")and the following individuals(collective "Resident"): NAME DOB (a) 1i:titre 6 )-1,9 Mara, b) t.as c--S� k te, Oct ( 1∎ ( C`t R-9 (c) (d) 2. RENT: The rent of$ `7 l per month payable on the first day of each month,in advance,to the office of Town Mills MHP.Rent is to be paid as follows: Town Mills MHP,8775 Cloud/Leap Ct.,Suite P-31,Columbia,MD 21045. If paid before the fifth(5th)of each month the discounted rent due is$ / . Payments received will be applied first to your oldest outstanding invoices regardless of rent,water/sewer,or late fee designations.All payments will be posted as of the date of receipt. Note: Your account will be charged a Ten Dollar(510.00)fee for each certified letter sent to you. This Lease s be for he term of one month,starting on the first day of l..C. r. / ,20/,3,and ending on the last day of r'I / ,20/1 provided that a holding ovef by Resident may be construed by Landlord, or its option,as a renewal of this lease for another like term,subject to all the terms and conditions of this Lease. v0 3. SECURITY DEPOSIT: A security deposit of$ e2S-3• must be paid prior to sighing the Lease or occupancy of the lot. A Resident must provide the office, in writing, a thirty-day notice of termination and if Resident complies with the terms, agreements and conditions of this Lease, Landlord shall return this Security Deposit within 30 days after the end of the Lease, including any extension or renewal thereof. Landlord may refuse to return the Security Deposit if Resident has breached any term, agreement or condition of this Lease. Upon termination of this Lease, or surrender and acceptance by Landlord of the premises, Resident shall provide the Landlord with Resident's new address,in writing,so that Landlord may provide Resident with(1)a written list of any damages,and(2)payment of the difference between the Security Deposit and actual damages caused by Resident. Landlord shall have the right to use as much of the Security Deposit as is necessary to pay for damages resulting from Resident's occupancy of the premises. If such damage occurs prior to termination of this Lease. Resident shall replace the amount, if any,of the Security Deposit used by the Landlord to repair such damage. It is expressly understood by the parties that nothing in this paragraph shall preclude Landlord from refusing to return the Security Deposit to resident due to the nonpayment of rent or other breach of this Lease by Resident. If the Landlord sells the community. Landlord may transfer the Security Deposit to the new owners of the community for Resident's benefit. Landlord shall notify resident of any such sale and transfer,whereupon Landlord shall be released of all liability relating to the Security Deposit. 4. USE OF THE PREMISES: Resident shall have the right to place one (1) manufactured home as defined in the Mobile Home Park Rights Act_ as amended. 68 P.S. 398.1 et seq., (the "Home-) on the Premises, provided, however, that the Premises and the Home shall be used for residential purposes only. No one shall live on the Premises or the Home other than those named above unless prior written approval is given by the Landlord. 5. TRANSFER BY ASSIGNMENT. SUBLEASE,OR SALE: Resident shall not transfer possession of the Premises by sub- lease or assignment without Landlord's prior written consent. Resident shall have the right to sell the Home. provided. however. that Landlord reserves the right to approve the purchase of the Home. which approval shall not be unreasonably withheld. 6. ILLEGAL ACTIVITY BY RESIDENT: Resident shall occupy and use the Premises and the common areas of the manu- factured home community in which the Premises are located (the "Community") in compliance with all Federal,State and Local laws. ordinances and regulations now in force hereafter enacted and imposed. Violation of such laws, ordinances and regulations by Resident shall be a violation of this Lease. and shall permit Landlord to exercise any and all remedies provided by this Lease.including eviction. 7. LIABILITY OF RESIDENT: Each person listed in Paragraph I above and designated collectively as"Resident"shall be individually responsible for fully performing. all of Resident's obligations under this Lease. and each such person shall be liable for any breach of any such obligation. �1 Rt1 • 8. PROPERTY RULES: Resident shall conform to Landlord's Rules and Regulations governing the Community (the "Rules"),which are attached to this Lease and made a part thereof, and hereby accepted by Resident. The Rules are also posted in the Community. Landlord shall have the right during the term of this Lease to change or add to the Rules, provided,however,that the purpose of any change or addition shall be to preserve the Community and the quiet enjoyment of all the residents of the Community. No change or addition to the Rules shall become effective until Resident has been provided with a written copy of the change or added Rules by mail,posting,or delivery to the Premises. Resident agrees that a violation of the Rules shall be a violation of the Lease. Violations of the Rules shall permit Landlord to exercise any and all remedies provided by this Lease. 9. POSSESSION: Landlord shall not be liable to Resident for any failure to give Resident possession of the Premises ("Possession")at the start of this Lease, nor shall any such failure constitute a breach under this Lease. If Landlord cannot give Resident Possession within 30 days after the starting date of this Lease,Resident shall have the option to cancel this Lease. 10. RENT PAYMENT: Resident shall pay, without notice or demand by Landlord, all rent due and payable as set forth in Paragraph i above by check or money order at the rental office on or before the first(1a)day of every month.Time is of the essence. Acceptance by Landlord of a check for payment of rent is conditional and Rent shall not be deemed to be finally paid until payment of the check by the Resident's bank.No payment by Resident,or receipt by Landlord,or an amount less than the full amount of Rent,shall be deemed to be an accord and satisfaction,nor shall any statement on any check or letter accompanying any such partial payment be considered an accord and satisfaction. Landlord reserves the right to accept a partial payment of Rent without prejudicing Landlord's rights to recover the balance of the Rent due and owing,or to pursue Landlord's available remedies. Resident hereby waives any rights to set-off the Rent according to any other claim against Landlord.Make check or money order payable to: Town Mills MHP. 11. REASONS FOR EVICTION: The rules governing eviction of manufactured home community residents are set by statute and described in the`important Notice Required by Law"attached to this Lease. I2. DELIVERY AT EXPIRATION OF TERM: Resident shall remove the Home and deliver the Premises to Landlord at the end of the term of this Lease,leaving the Premises clean and in eood order,reasonable wear and tear accepted.Within thirty (30)days prior to moving the Home from the Premises, Resident shall obtain the necessary removal permit from the local tax office and provide a copy of this permit to Landlord. Immediately prior to delivery of the Premises to Landlord,Resident shall (I)jointly inspect the Premises with a person from the management staff; (2)indicate then-existing conditions; and (3)sign and date the duplicate form provided by Landlord. Resident agrees that any personal possessions remaining in the Premises after the Resident moves out shall be deemed abandoned by Resident and that Resident shall pay the cost of removing and disposing of such possession. 13. CARE OF THE PREMISES HOME (a) Sanitation. Resident shall keep the Premises and the Home clean. sanitary and safe, as by (1) removing from the Premises all rubbish_garbage and other organic or inflammable waste in a clean and sanitary manner; (2)complying with any established recycling procedures:and(3)keeping all plumbing fixtures in the Home clean and sanitary. (b) Vandalism. Resident shall not permit any other person to destroy, deface,damage, impair or remove any part of the structure of the Premises or its facilities,equipment or appurtenances. (c) Disorderly Conduct. Resident shall not use_ or allow to be used. the Premises or the Home for any disorderly or unlawful purpose. Resident shall not cause hurt_ inconvenience or discomfort to any employee of Landlord or any other resident of the Community. (d) Smoke Detector,Fire Extinguisher. Resident shall maintain a smoke detector in the Home and ensure that it is in proper operating condition at all times. Resident shall also maintain a fire extinguisher in the Home and ensure that it is in proper operating condition at all times. (e) Hazardous Use. Resident shall not keep on or about the Premises, the Home or the Community anything dangerous. flammable.explosive or which might increase the danger of fire or other hazard. (f) Maintenance of Premises. Resident shall keep and maintain the yard, sidewalk and driveway of the Premises clean and free from ice.snow. leaves and garbage.and otherwise in good and clean condition. Resident shall maintain the yard of the Premises(excluding shrubs,bushes.trees and flowers)cut and trimmed at all times to a height of three(3)inches:provided_ however.that in the event Resident fails to so maintain the yard_ Landlord shall have the right to do so and bill Resident for the cost.which bill shall be immediately payable upon demand. 14. INSURANCE: Resident shall maintain insurance on the Home_ which insurance shall cover(I)damage to the property of Resident or Resident's guests. and (2) injury to persons occurring on or about the Premises_ Resident, upon request by Landlord,shall provide Landlord with written evidence of such insurance,such as Certificate of Insurance. 15. DAMAGE/INJURY (a) The Premises. Damage to the Premises caused by Resident or Resident's guests shall be repaired by landlord,provided, however,that the costs of such repairs shall be billed to the Resident and shall be immediately payable on demand.Landlord shall not be liable for any injury to person or property due to damage to the Premises unless such injury arises from the gross negligence or intentional act of Landlord or Landlord's agents. (b) The Home. Landlord shall not be responsible for any damage to the Home or to any personal property therein,or any injury to person or property occurring within the Home, unless such damage or injury arises from the gross negligence or intentional act of Landlord or Landlord's agents. (c) Indemnification of Landlord by Resident. Resident shall be responsible for,and indemnify Landlord against, any and all liabilities, damages, claims and costs (including reasonable attorney fees) which may be imposed upon or incurred by Landlord in connection with loss or damage to property of injury to persons resulting from any act or omission by Resident or Resident's guests. 16. REPAIRS (a) Notice. Resident shall notify the on-site manager orally and rental office in writing of any problem affecting the Premises. Landlord shall not be liable for any injury of damage to the Premises unless such notice is provided. (b) Alterations. Resident shall not alter,repair or decorate the Premises,nor physically attach any personal property to the Premises, unless (I) Landlord's written permission is obtained, and (2) such written permission is attached to this Lease Agreement. 17. LANDLORD'S RIGHT OF ACCESS (a) Inspection/Maintenance. Landlord shall have the right to enter the Premises to inspect and maintain equipment, appliances, and safety conditions on or about the Premises. In addition, Landlord shall have the right to enter the Home (1)for purposes related to a sale of the Home or the Community, or (2) in the event of an emergency. as reasonably determined by Landlord. Landlord shall give advance notice of such entry to Resident whenever possible, provided, however,that no notice need be given in the event of an emergency. (b) Inability to Gain Access. Resident shall be liable for any damage caused by Landlord's inability to gain access to the Premises and the Home to effect repair or to remedy an emergency or similar situation,where such inability to gain access is caused by a violation of this Lease by Resident. (c) Interruptionilnconvenience_ Landlord shall not be liable for any temporary inconvenience or interruption of services due to repairs,improvements or for any reason beyond Landlord's control. Resident shall pay the full amount of rent when due despite any such inconvenience or interruption. 18. DESTRUCTION OF THE PREMISES (a) Total Destruction. In the event that the Premises are destroyed by fire or other casualty so that it is not habitable as a dwelling place, and (I) this destruction occurs through no fault or negligence of Resident. and(2)the Premises cannot be restored within ninety (90)days of the date of the total destruction_then this Lease shall terminate absolutely_ Upon such termination, Resident shall move out of the Premises immediately and deliver possession to Landlord. Upon such delivery by Resident all obligations under this Lease,including Tenant's obligation to pay rent,shall cease. 19. REMEDIES CUMULATIVE: Landlord's remedies under this Lease are not exclusive_and no termination of this Lease or taking or recovering of the Premises shall deprive Landlord of any other remedy or action for Rent or any other charge due at the time or which shall otherwise become due in the future. 20. EVICTION: Notice to quit — Resident hereby waives the Notice to Quit requirements of the Pennsylvania Landlord and Tenant Act of 1951. as amended, 68 P.S. 250.101 et seq._ and any other applicable law. This Lease shall itself constitute sufficient notice to quit the Premises without Landlord providing Resident any additional notice. • 21. STORAGE TANKS: Resident may not place or continue to permit in place from this date forward any aboveground or underground storage tanks on the Premises without the express prior written consent of Landlord. It shall be Resident's sole responsibility to comply with all existing and future federal, state, and local statutes, rules, regulations,ordinances,orders and guidance related to any storage tanks(including pipes and equipment connected thereto) on the Premises,and to keep and maintain such 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 Landlord from and against any and all expenses, liabilities, response costs, and costs of any kind or nature, including attorney's fees arising out of, caused by, or related in any way to Resident's tanks or Resident's violation of or failure to comply with any federal,state,or local law,statute, rule,regulation, ordinance,order,or guidance.Upon the termination of this Lease, Landlord may,at its sole discretion,require Resident to remove the tanks and clean up and restore the Premises to background conditions. Such removal shall be performed in accordance with and pursuant to any and all applicable federal,state,and local laws,statutes,regulations,rules,ordinances,guidance,and orders and shall be performed by persons authorized and certified to perform such removals under those laws and regulations. A violation of this paragraph shall constitute a material breach of the Lease.In addition to any other remedies available,upon Resident's failure to comply with this paragraph or obtain the Landlord's approval to maintain tanks on the Premises, Landlord may.but is not obligated to (I)order 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 tanks and restore the property itself at the Residents expense, and/or (3)terminate this Lease.Resident shall have the right to inspect the Premises to ensure compliance with this paragraph_ 22. SUBORDINATION: This Lease and Resident's rights are subject and subordinate to present and future mortgages on the Property_ Landlord shall have the right to execute any papers on Resident's behalf as Resident's attorney-in-fact for this purpose. In the event that Landlord mortgages the Community, Landlord shall obtain from the mortgage holder a non- disturbance agreement for the benefit of Resident, provided, however, that Resident shall not have been in default of any Resident's obligations under this Lease at any time during the Lease term,including any extensions or renewals thereof. 23_ GENDER, SEVERABILITY: Where the context of this Lease requires(1)words in the singular may be substituted for the plural and vice-versa,and(2)words in the masculine,feminine or neuter gender may be substituted for any other gender. If any term, covenant, condition, or provision of this Lease shall to any extent be deemed invalid or unenforceable, the remainder of the Lease shall not be affected thereby,and each term,covenant,condition,and provision of this Lease shall be valid and enforceable to the fullest extent permitted by law. 24. HEADINGS: The headings preceding the text of the paragraphs in this Lease are inserted for convenience of reference only and shall not constitute a part of this Lease,nor shall they affect its meaning,construction,or effect. 25. ENTIRE AGREEMENT. SUCCESSORS: This Lease contains the final and entire agreement between the parties hereto. and no party shall be bound by any term.condition or representation, oral or written,nor set forth or provided herein. The conditions,covenants,and rules contained in this Lease shall be legally enforced by the parties to this agreement.their heirs, executors, administrators, personal and legal representatives, successors and assigns_ and are binding upon all such parties. Nothing herein shall prevent modification of the terms of this Lease by mutual agreement though the execution of a written Addendum affixed to all copies of this Lease. In Witness Whereof,the parties hereto for good and valuable consideration, and intending to be legally bound,have entered into this Manufactured Home Site Lease Agreement on the date first set forth above. WITNESS/ATTEST D LANDLO cal ice-(i 0q er) By: By: WITNESS: RESIDENT: Resident(Seal) `/ - / l� � lam, 1�i � Resident("dal) Revised 1:99 4 ,,3 • c?52) ,A6--eC. %.,%1L1:71, . / c3--mss MOBILE HOME PARK SALES AGREEMENT MOBILE HOME: 1617 C is-k'C a,iA MAP # / 7 BUYER: (A2(.15. 14 114q le �tiC OGS' S LLER: L"c t�;IS macYcbj Ya 1. SALES PRICE AS IS, WHERE IS 70 tit' 2. BUYER AGREES TO PAY $ / DOWN AND THE BALANCE OF $ 6 ra AT $ `f PER MONTH. MOBILE HOME PAYMENT IS AS FOLLOWS: FIRST - r MONTHLY PAYMENT IS DUE ON THE FIRST DAY OF . �/ jj it 0613 PAYMENTS MADE AFTER THE FIFTH OF EACH MONTH A.RE SUBJECT TO A $25.00 LATE FEE. TIME IS OF THE ESSENCE. THE LATE CHARGE FEE SHALL NOT GIVE THE BUYER THE RIGHT TO FURTHER DELAY THE MONTHLY PAYMENT. 3. BUYER AGREES TO PAY ALL REAL ESTATE TAXES DUE AT TIME OF SALE AND PRESENT COPIES OF REAL ESTATE RECEIPTS TO SELLER UPON DEMAND UNTIL - BALANCE DUE IS PAID IN FULL. BUYER ALSO AGREES TO FORFEIT ALL CLAIMS, PRIOR PAYMENTS, AND RIGHTS TO THE MOBILE HOME IN THIS AGREEMENT IF EITHER LOT C` PAYMENT OR MOBILE HOME PAYMENT IS DELINQUENT. BUYER ALSO AGREES NOT TO MOVE THE ABOVE MOBILE HOME FROM THE PRESENT LOCATION UNTIL THE BALANCE DUE IS PAID IN FULL. 4. SELLER AGREES TO DELIVER CLEAR TITLE OR BILL OF SALE UPON FINAL MONTHLY PAYMENT OF THIS AGREEMENT. Ln 5. BUYER AGREES TO PURCHASE A FIRE AND DAMAGE INSURANCE POLICY WITH SELLER AS BENEFICIARY UNTIL FINAL PAYMENT IS MADE. BUYER SHALL PRESENT SELLER WITH PROOF OF ABOVE INSURANCE POLICY UPON DEMAND. 6. IN CASE OF A BREACH OF THE LEASE AGREEMENT BY THE BUYER, THE BUYER AGREES TO FORFEIT ALL CLAIMS, PRIOR PAYMENTS, AND RIGHTS TO THE MOBILE HOME IN THIS AGREEMENT. 7. LOT RENT IS SUBJECT TO CHANGE, 8. BY SIGNING THIS AGREEMENT THE SELLER AND THE BUYER AGREE TO ABIDE BY ALL OF ITS TERMS AND CONDITIONS. BUYER Vk1Y DALE ti-tv C SELLER: j S ffitd • ' C V2o.vC1-11 6YIQ- DA'Z'E Cin [ i , J-d& ASSIGNMENT OF LEASES AND NOW, this the 22" day of November 2013, for good, valid and acknowledged consideration,in hand paid,Lewis Mackay,trading and doing business as Town Mills Mobile Home as owner of Town Mills Mobile Home Park, located at 40 Middle Springs Road, Shippensburg,Franklin County,Commonwealth of Pennsylvania, IT IS HEREBY AGREED AS FOLLOWS: 1. The lease agreements are hereby assigned and set over and unto Quentin Holdings, LLC(hereinafter referred to a"New Owner" or "Purchaser"), being as follows: SEE ATTACHED EXHIBIT"A". 2. Security deposit(s) for the property have been transferred to the New Owner. 3. Owner states and affirms that there are no known city code violations. IN WITNESS WHEREOF,the parties hereto, set their hand and seal. I itness: OWNER: 1■111 By: ' g New Owner/Purchaser: ./� By: r1' ■ Information as of 11-16-13 Exhibit"A'; Owner Occupied (22) k t f r Back C �.r 02 d Aerie " " OT# f `yf e b 0& Te iaritI% '''51.k Rent e . , St'fait Pate Y,-7-'.44 1 Owner Vincent Starr $ - 5/26/2010 6 Owner Wayne McKee $ 605.42 Pre-2007 9 Owner Linda Bechtel $ - 8/1/2008 11 Owner Jennie Mohler $ - Pre-2007 12 Owner Jenny Shields $ 330.52 Pre-2007 13 Owner Saundra Durf $ - 11/7/2013 14 Owner Penny Beam $ - Pre-2007 15 Owner Kris Craig $ 773.44 Pre-2007 16 Owner Dale Galo $ - Pre-2007 18 Owner Joe Crist $ - Pre-2007 21 Owner Sharon Mowery $ - 4/1/1989 22 Owner Jennifer Stine $ - Pre-2007 25 Owner Vivian Vandiver $ - 10/1/2008 26 Owner Jenny Mohler $ - 4/1/2008 27 Owner Don Baer $ 533.00 Pre-2007 29 Owner Carol Moore Pre-2007 32 Owner James Bobbit $ - 3/1/2013 33 Owner Don Ice $ - 11/1/2008 34 Owner Joyce Shirley $ - 4/1/2008 38 Owner Pete Hall $ - 1/1/2010 39 Owner Megan Martin $ 1,455.95 8/2010 43 Owner Brandy Kennedy $ 1,157.03 _ Pre-2007 Rent-To-Own (13) � � � � � � fi� .ease y k �?�i 41 a t fat, h r �.� ro L ra, 11 �'",£¢ .� 'T 'a �, :s 9 e d w LOT# .,:'` . .pew y i, ` 'en4a a Balati.+�e : Sta Dated ,F 3 RTO John Mohler,Jr. $ 1,329.12 12/6/2011 4 RTO Linda Saar $ 6,184.40 4/1/2012 5 RTO Kaitlyn Carter $ 3,599.26 3/1/2013 10 RTO Kathy Schultz $ 3,600.00 10/25/2013 17 RTO Larissa Negley $ 6,561.91 4/1/2013 19 RTO Becky McHenry $ 5,631.22 3/1/2013 20 RTO Dave Greenwalt $ 1,819.14 5/1/2013 23 RTO Michelle Thomas $ 2,668.21 7/1/2013 24 RTO Richard Lawson $ 3,932.98 7/1/2012 28 RTO Mary Dingle $ 6,812.77 10/15/2011 31 RTO Matthew Pratt $ 8,013.33 11/3/2011 35 RTO Brandy Stouffer $ 16,106.73 11/1/2012 40 RTO Coty Mentzer $ 2,500.00 10/1/2010 Vacant(3) /► a} 4 ,c' s R' vt i '`i�� f 1T0 p . t` 4 Lease3i ' ,i LOT# ., Type " r Tenants °Balance. r . . 4 StartDate R 8 Vacant 36 Vacant 42 Vacant 4 r k ASSI Iv ENT 0 AGREEmE T `A AND T• • WN LEA E acknowledged consideration,the 22nd Town Mills ration,in hand day of November 2013 Middle Springs Home as owner ofid,Lewis Mackay,tradin for good, valid and T IT IS S rings Road, ome as ow To Mills Mobile g and Park, l HEREBY g,Franklin Co Horne th o e business as AGREED'q`gF'OLLOWS;. County,Commonwealth ofPe Gated at 40 Pennsylvania, 1' The lease agreements and the rent to and sea over and unto own agreements are hereby "New Owner„nd unto Holdings, LLC y signed "Purchaser"), being as follows: referred to a SEE ATTACHED EXHIBIT"A". 2. Own rty deposit(s) for the property have been transferred to the New 3' Owner states and affirms that there are no known city code violations. " l'.44 ESS HEREOF; the 'tness: P ties hereto,set their hand and seal. . OWNER: rriv 1Owner/Purchaser:New By. Information as of 11-16-13 Exhibit"A" Owner Occupied (22) Back.� . q s 1JIteL - At" ' k P 4i ��- `€' r'-y LUT# T A _W Ff ,Teliot a `u ., '1Zent to # ' .. ,a� 1 Owner Vincent Starr $ - 5/26/2010 6 Owner Wayne McKee $ 605.42 Pre-2007 9 Owner Linda Bechtel $ - 8/1/2008 11 Owner Jennie Mohler $ - Pre-2007 12 Owner Jenny Shields $ 330.52 Pre-2007 13 Owner Saundra Durf $ - 11/7/2013 14 Owner Penny Beam $ - Pre-2007 15 Owner Kris Craig $ 773.44 Pre-2007 16 Owner Dale Galo $ - Pre-2007 18 Owner Joe Crist $ - Pre-2007 21 Owner Sharon Mowery $ - 4/1/1989 22 Owner Jennifer Stine $ - Pre-2007 25 Owner Vivian Vandiver $ - 10/1/2008 26 Owner Jenny Mohler $ - 4/1/2008 27 Owner Don Baer $ 533.00 Pre-2007 29 Owner Carol Moore Pre-2007 32 Owner James Bobbit $ - 3/1/2013 33 Owner Don Ice $ - 11/1/2008 34 Owner Joyce Shirley $ - 4/1/2008 38 Owner Pete Hall $ - 1/1/2010 39 Owner Megan Martin $ 1,455.95 8/2010 43 Owner Brandy Kennedy $ 1,157.03 Pre-2007 Rent-To-Own (13) �' WW k s VtTO l ;ease y€ , ° $ �� FT it . r P 4,lancg • w w4 L�i 2...:.:z 3 RTO John Mohler,Jr. $ 1,329.12 12/6/2011 4 RTO Linda Saar $ 6,184.40 4/1/2012 5 RTO Kaitlyn Carter $ 3,599.26 3/1/2013 10 RTO Kathy Schultz $ 3,600.00 10/25/2013 17 RTO Larissa Negley $ 6,561.91 4/1/2013 19 RTO Becky McHenry $ 5,631.22 3/1/2013 20 RTO Dave Greenwalt $ 1,819.14 5/1/2013 23 RTO Michelle Thomas $ 2,668.21 7/1/2013 24 RTO Richard Lawson $ 3,932.98 7/1/2012 28 RTO Mary Dingle $ 6,812.77 10/15/2011 31 RTO Matthew Pratt $ 8,013.33 11/3/2011 35 RTO Brandy Stouffer $ 16,106.73 11/1/2012 40 RTO Coty Mentzer $ 2,500.00 10/1/2010 Vacant(3) Ut!VeovolkAteNr«';`",',V, kirN,IftwAttv*,-v4t, wittorov,. ''.,, ,#R,igwolp:‘ . ,.„_i,witl,,, , k LOT ,4% h '< y e °F a 'enant� c , 'a'Ba1ance, Al 4 Stag t3Date i 8 Vacant 36 Vacant 42 Vacant AMENDED AND RESTATED ASSIGNMENT OF RENT TO OWN AGREEMENT AND LEASES AND NOW this the 15 day of February 2014,for good, valid and acknowledged consideration, in hand paid, Lewis Mackay,trading and doing business as Town Mills Mobile Home as owner of Town Mills Mobile Home Park, located at 40 Middle Springs Road, Shippensburg,Cumberland County, Commonwealth of Pennsylvania. IT IS HEREBY AGREED AS FOLLOWS: 1. The lease agreements and the rent to own agreements are hereby assigned and set over and unto Quentin Holdings, LLC (hereinafter referred to as "New Owner"or"Purchaser"), being as follows: SEE ATTACHED EXHIBIT "A". 2. Security deposit(s)for the property have been transferred to the New Owner. 3. Owner states and affirms that there are no known city code violations. 4. Owner specifically assigns, grants and conveys to New Owner the right to collect any and all judgements,arrears, delinquencies,rents, fees, costs and charges that were accrued, incurred or due from any and all tenants, during the Owner's time period of ownership. IN WITNESS WHEREOF, the parties hereto, set their hand and seal. Witness: OWNER: la,• BY: NEW OWNER/PURCHASER: y��- By: /;nta/ i: /41,0/l. -- AMENDED AND RESTATED ASSIGNMENT OF LEASES AND NOW, this the j 5 day of February 2014,for good,valid and acknowledged consideration, in hand paid, Lewis Mackay,trading and doing business as Town Mills Mobile Home as owner of Town Mills Mobile Home Park, located at 40 Middle Springs Road, Shippensburg,Cumberland County, Commonwealth of Pennsylvania. IT IS HEREBY AGREED AS FOLLOWS: 1. The lease agreements are hereby assigned and set over and unto Quentin Holdings, LLC (hereinafter referred to as "New Owner" or "Purchaser"), being as follows: SEE ATTACHED EXHIBIT "A". 2: Security deposit(s)for the property have been transferred to the New Owner. 3. Owner states and affirms that there are no known city code violations. 4. Owner specifically assigns,grants and conveys to New Owner the right to collect any and all judgements, arrears, delinquencies,rents, fees, costs and charges that were accrued, incurred or due from any and all tenants, during the Owner's time period of ownership. IN WITNESS WHEREOF, the parties hereto, set their hand and seal. Witness: OWNER: By: �� <� mete ` NEW OWNER/PURCHASER: _ A 1. By: , L. afL44, y` Information as of 11-19-13 Exhibit"A" Owner Occupied(22) Back Lease LOT# Type Tenant Rent Start Date 1 Owner Vincent Starr $ - 5/26/2010 6 Owner Wayne McKee $ 605.42 Pre-2007 9 Owner Linda Bechtel $ - 8/1/2008 11 Owner Jennie Mohler $ - Pre-2007 12 Owner Jenny Shields $ 330.52 Pre-2007 13 Owner Saundra Durf $ - 11/7/2013 14 Owner Penny Beam $ - Pre-2007 15 Owner Kris Craig $ 773.44 Pre-2007 16 Owner Dale Galo $ - Pre-2007 18 Owner Joe Crist $ - Pre-2007 21 Owner Sharon Mowery $ - 4/1/1989 22 Owner Jennifer Stine $ - Pre-2007 25 Owner Vivian Vandiver $ - 10/1/2008 26 Owner Jenny Mohler $ - 4/1/2008 27 Owner Don Baer $ 533.00 Pre-2007 29 Owner Carol Moore Pre-2007 32 Owner James Bobbit $ - 3/1/2013 33 Owner Don Ice $ - 11/1/2008 34 Owner Joyce Shirley $ - 4/1/2008 38 Owner Pete Hall $ - 1/1/2010 39 Owner Megan Martin $ 1,455.95 8/2010 43 Owner Brandy Kennedy $ 1,157.03 Pre-2007 Rent-To-Own(14) RTO Lease LOT# Type Tenant Balance Start Date 3 RTO John Mohler,Jr. $ 1,329.12 12/6/2011 4 RTO Linda Saar $ 6,184.40 4/1/2012 5 RTO Kaitlyn Carter $ 3,599.26 3/1/2013 10 RTO Kathy Schultz $ 3,600.00 10/25/2013 17 RTO Larissa Negley $ 6,561.91 4/1/2013 19 RTO Becky McHenry $ 5,631.22 3/1/2013 20 RTO Dave Greenwalt $ 1,819.14 5/1/2013 23 RTO Michelle Thomas $ 2,668.21 7/1/2013 24 RTO Richard Lawson $ 3,932.98 7/1/2012 28 RTO Mary Dingle $ 6,812.77 10/15/2011 31 RTO Matthew Pratt $ 8,013.33 11/3/2011 35 RTO Brandy Stouffer $ 16,106.73 11/1/2012 36 RTO Nancy Welsh $ 13,856.00 11/19/2013 40 RTO Coty Mentzer $ 2,500.00 10/1/2010 Vacant(2) RTO Lease LOT# Type Tenant Balance Start Date 8 Vacant 42 Vacant F:\FILES \Clients \13994 Pro Bono \13994.60 Negley \13994.60.pral.wpd Revised: 3/14/14 3:11PM r_D-O ;' THE PROTIION George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FAIIIMAR 14 PM 3: 27 MARTSON LAW OFFICES I.D. 49813 CUMBERLAND COUNTY Y 10 East High Street PENNSYLVANIA Carlisle, PA 17013 (717) 243 -3341 Attorneys for Defendant QUENTIN HOLDINGS, LLC, : IN THE COURT OF COMMON PLEAS OF Plaintiff : COUNTY, PENNSYLVANIA v. : NO. 14 -866 : CIVIL ACTION - LAW LARRISA NEGLEY and RICHARD ESTRIGHT, Defendants : JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER on behalf of Defendant Larrisa Negley in the above matter. Defendant hereby demands a twelve juror jury trial in the above captioned action. Dated: 3/14/14 MARTSON LAW OFFICES By s'• George Faller, Jr., :quire I.D. No. 49813 Ten East High Street Carlisle, PA 17013 (717) 243 -3341 Attorneys for Defendant Larrisa Negley 4 CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Dated: 3/14/14 Quentin Holdings, LLC Attn: Lynn Seymour 2159 White Street, Suite 3 -139 York, PA 17404 MARTSON LAW OFFICES Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717) 243 -3341 .1rAFILES \Clients \ 13994 Pro Bono113994.60 Negley\13994.60.P01.wpd Revised: 3/17/14 3:24PM George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant cD CD QUENTIN HOLDINGS, LLC, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 14-866 : CIVIL ACTION - LAW LARRISA NEGLEY and RICHARD ESTRIGHT, Defendants : JURY TRIAL DEMANDED PRELIMINARY OBJECTIONS OF DEFENDANT LARRISA NEGLEY TO PLAINTIFF'S COMPLAINT 1. Plaintiff's Complaint was filed on or about February 20, 2014. 2. Plaintiff's Complaint alleges that the Defendant was a tenant in a mobile home park and the Plaintiff is the owner of the premises. 3. The Complaint in Paragraph 8 contains a claim for attorney's fees, however, there is no provision in the law under these circumstances which would allow attorney's fees to be recoverable. 4. Plaintiff's Complaint does not have a Verification signed by an appropriate representative of the Plaintiff. WHEREFORE, Defendant Larrisa Negley requests that the Court strike Paragraph 8 of Plaintiffs Complaint and require Plaintiff to file an appropriate Verification. MARTSON LA By Dated: 3/17/14 OFFICES George VFaIler, Jr., Esquire I.D. No. 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Larrisa Negley CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Preliminary Objections of Defendant Larrisa Negley to Plaintiff's Complaint was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Kurt A. Blake, Esquire BLAKE & GROSS, LLC 29 East Philadelphia Street York, PA 17401 MARTSON LAW OFFICES By.Jfl (4. Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: 3/17/14 BLAKE Et GROSS, L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York, PA 17401 717 - 848 -3078 FAX 717 - 848 -2777 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14 -866 Plaintiff v. CIVIL ACTION - LAW Larrisa Negley and i-, Richard Estright, -0- Defendants r" r i ' _ 1- ...<>. co CO Wit:: To: Larrisa Negley and Richard Estright Date: March 1-.6;g20 a c, f ` 17 Town Mills a Shippensburg, PA 17257 1,0 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO 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 IN THIS CASE. 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 RIGHT TO SUE THE DEFENDANT AND THEREBY LOSE 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE York County Bar Associ ion 137 East Market St York PA 17401 (717) 854 -875 A. Blake, Esquire I.D. N "o. 68791 29 East Philadelphia Street York, PA 17401 BLAKE & GROSS, L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York, PA 17401 717- 848 -3078 FAX 717 - 848 -2777 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14 -866 Plaintiff v. CIVIL ACTION - LAW Larrisa Negley and Richard Estright, Defendants To: Larrisa Negley and Richard Estright 17 Town Mills Shippensburg, PA 17257 Date: March 13th, 2014 AVISO IMPORTANTE Usted esta en rebeldia porque ha fallado en tomar la accion exiga de su parte en este caso. A menos de que usted actue dentro de diaz de la fecha de este aviso, se puede registrar una sentencia contra usted, sin el beneficio de una audencia y puede perder su propiedad o derechos importante. Usted debe llevar este aviso a un abogado ensequida. Si usted no tiene un abogado y no puede pagar por los servicios de an abogado, debe comunicarse con la siguiente oficina para averiguar donde puede obtener ayuda legal: LAWYER REFERRAL SERVICE York County Bar Association 137 East Market Street York PA 17401 (717) 854 -8755 Al I.D. By: frt A. Blake, Esquire No. 68791 29 ast Philadelphia Street Yo , PA 17401 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14 -866 Plaintiff v. CIVIL ACTION - LAW Larrisa Negley and Richard Estright, Defendants CERTIFICATE OF SERVICE I, the undersigned, do hereby certify that I have caused a true and correct copy of the foregoing to be served upon the Defendant, by placing such in the United States First Class & Certified Mail, in York, Pennsylvania, postage prepaid, and addressed as follows: Larrisa Negley and Richard Estright 17 Town Mills Shippensburg, PA 17257 March 13th, 2014 By: BLAKE & GROSS, L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York, PA 17401 717 - 848.3078 FAX 717 -848 -2777 t A. Blake, Esquire o. 68791 29 E. t Philadelphia Street York, '\,A 17401 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14-866 Plaintiff V. CIVIL ACTION - LAW Larrisa Negley and Richard Estright, r, Defendants '- � C.4 c J To: Richard Estright Date: June l It', 20IC- 17 Town Mills Shippensburg, PA 17257 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO 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 IN THIS CASE. 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 RIGHT TO SUE THE DEFENDANT AND THEREBY LOSE 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL S ICE York County Bar As o iation 137 East Market r et York PA 1740 (717) 854-87 BLAKE 8 GROSS,L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street y York,PA 17401 rt A. Blake, Esquire 717-848-3078 FAX 717-848-2777 D. NO. 68791 29 East Philadelphia Street York, PA 17401 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14-866 Plaintiff V. CIVIL ACTION -LAW Larrisa Negley and Richard Estright, Defendants To: Richard Estright Date: June 11'", 2014 17 Town Mills Shippensburg, PA 17257 AVISO IMPORTANTE Usted esta en rebeldia porque ha fallado en tomar la accion exiga de su parte en este caso. A menos de que usted actue dentro de diaz de la fecha de este aviso, se puede registrar una sentencia contra usted, sin el beneficio de una audencia y puede perder su propiedad o derechos importante. Usted debe Nevar este aviso a un abogado ensequida. Si usted no tiene un abogado y no puede pagar por los servicios de an abogado, debe comunicarse con la siguiente oficina para averiguar donde puede obtener ayuda legal: LAWYER REFERRAL SERVICE York County Bar Association 137 East Market Street York PA 17 (717) 854- 75 By- urt A. Blake,Esquire I.D. No. 68791 BLAKE&GROSS,L.L.C. ATTORNEYS AND 29 East Philadelphia Street COUNSELORS AT LAW York, PA 17401 29 East Philadelphia Street York,PA 17401 717-848-3078 FAX 717-848-2777 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14-866 Plaintiff V. CIVIL ACTION - LAW Larrisa Negley and Richard Estright, Defendants CERTIFICATE OF SERVICE 1, the undersigned, do hereby certify that I have caused a true and correct copy of the foregoing to be served upon the Defendant, by placing such in the United States First Class & Certified Mail, in York, Pennsylvania, postage prepaid, and addressed as follows: Richard Estright 17 Town Mills Shippensburg, PA 17257 June 1 I th, 2014 By: A. Blake, Esquire 1. . No. 68791 2 East Philadelphia Street York, PA 17401 BLAKE ft GROSS,L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York,PA 17401 717-848-3078 FAX 717-848-2777 BLAKE & GROSS, L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York, PA 17401 717-848-3078 FAX 717-848-2777 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14-866 Plaintiff v. CIVIL ACTION - LAW Larrisa Negley and Richard Estright, Fri co 2 rT1 f-- 1.r l ._.` Defendants 37-1 t r do -' „ PRAECIPE FOR DEFAULT JUDGEMF r>.a ca TO THE PROTHONOTARY: Please enter a judgement of default against the Defendant, Richard Estright ONLY in the amount of $2,150.00 plus costs and interest, plus possession of 17 Town Mills Shippensburg, PA 17257. , for the Defendants failure to file an Answer to the Complaint after timely and proper service of 10 day notice, copy attached here to Exhibit "A". tday of July, 2014 By: Kurt A. Blake, Esquire I.D. No. 68791 29 East Philadelphia Street York, Pennsylvania 17401 (717) 848-3078 (OA t)0!„1 "SOP -404\A VC.jk- 0D0410 p ,t)4 Woihn 0,08q8S j\j¼e MaJec( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14-866 Plaintiff v. CIVIL ACTION - LAW Larrisa Negley and Richard Estright, Defendants CERTIFICATE OF SERVICE AND NOW, this day of July, 2014, the undersigned does hereby certify that a true and correct copy of the Praecipe in the above matter was served upon the following persons by United States First Class Mail, Postage prepaid and addressed as follows: Richard Estright 17 Town Mills Shippensburg, PA 17257 ID day of July 2014 By: BLAKE & GROSS, L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York, PA 17401 717-848-3078 FAX 717-848-2777 Blake, Esquire o. 68791 2 East Philadelphia Street York, Pennsylvania 17401 (717) 848-3078 BLAKE & GROSS, L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York, PA 17401 717-848-3078 FAX 717-848-2777 David D. Buell Prothonotary RE: OFFICE OF THE PROTHONOTARY OF CUMBERLAND COUNTY Cumberland County Court House 1 Courthouse Square Suite 100 Carlisle, PA 17013 Richard Estright 17 Town Mills Shippensburg, PA 17257 Phone 717-240-6195 Date: July D, 2014 Quentin Holdings, LLC, Plaintiff VS: Richard Estright, Defendant Notice is given that a default judgement in the above captioned matter has been entered against you on July It , 2014 David D. Buell PROTHONOT ,RY OCUAND CO By Cleri or Deputy If you have any questions concerning the above please contact: Kurt . Blake, Esquire 29 East Philadelphia Street York! PA 17401 Phone (717) 848-3078 David D. Buell Prothonotary OFFICE OF THE PROTHONOTARY OF CUMBERLAND COUNTY Cumberland County Court House 1 Courthouse Square Suite 100 Carlisle, PA 17013 Phone 717-240-6195 IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA Plaintiff: Defendant: Judgement No: Quentin Holdings, LLC VS: Richard Estright 14-866 CERTIFICATE OF RESIDENCE PA R. P. 236 I, hereby certify that the precise address of: Plaintiff is: Quentin Holdings, LLC 2159 White Street Suite 3 Box 139 York PA 17404 and certify that the last known address of the within: Defendant is: BLAKE & GROSS, L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York, PA 17401 717-848-3078 FAX 717-848-2777 Richard Estright 17 Town Mills Shippensburg, P Kurt A. Blake, Esquire 29 East Philadelphia Street York, PA 17401 Phone (717) 848-3078 David D. Buell Prothonotary OFFICE OF THE PROTHONOTARY OF CUMBERLAND COUNTY Phone 717-240-6195 Cumberland County Court House 1 Courthouse Square Suite 100 Carlisle, PA 17013 Quentin Holdings, LLC, Plaintiff VS: Richard Estright, Defendant Docket NO. 14-866 Commonwealth of Pennsylvania Cumberland County Before me, The Prothonotary of Cumberland County, Pennsylvania, personally appeared Kurt A. Blake, Esquire attorney for Plaintiff, in the above entitled case, who being duly sworn or affirmed according to law deposes and says, that the Plaintiff above named is not in the military service of the United States of America, that he or she has personal knowledge that the Defendant, Richard Estright, residing at 17 Town Mills Shippensburg, PA 17257 and is a resident of Cumberland County County. Sworn and subscribed before me this day • f f:ly, 2014. Prothonotary BLAKE & GROSS, L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York, PA 17401 717-848-3078 FAX 717-848-2777 Ku . Blake, Esquire 29 r ast Philadelphia Street Yo , PA 17401 Phone (717) 848-3078 BLAKE & GROSS, L.L,C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York, PA 17401 717.848-3078 FAX 717-848.2777 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14-866 Plaintiff v. CIVIL ACTION - LAW -vim rnw Larrisa Negley and Richard Estright, Defendants n(---) To: Richard Estright 17 Town Mills Shippensburg, PA 17257 Date: June 11th, 2014 IMPORTANT NOTICE c J YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO 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 IN THIS CASE. 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 RIGHT TO SUE THE DEFENDANT AND THEREBY LOSE 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL S . • ICE York County Bar As • iation 137 East Markete York PA 1740 (717) 854-87 By: A. Blake, Esquire .D. No. 68791 29 East Philadelphia Street York, PA 17401 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14-866 Plaintiff v. CIVIL ACTION - LAW Larrisa Negley and Richard Estright, Defendants To: Richard Estright 17 Town Mills Shippensburg, PA 17257 Date: June 11th, 2014 AVISO IMPORTANTE Usted esta en rebeldia porque ha fallado en tomar la accion exiga de su parte en este caso. A menos de que usted actue dentro de diaz de la fecha de este aviso, se puede registrar una sentencia contra usted, sin el beneficio de una audencia y puede perder su propiedad o derechos importante. Usted debe llevar este aviso a un abogado ensequida. Si usted no tiene un abogado y no puede pagar por los servicios de an abogado, debe comunicarse con la siguiente oficina para averiguar donde puede obtener ayuda legal: LAWYER REFERRAL SERVICE York County Bar Association 137 East Market Street York PA 17 (717) 854 - By: BLAKE Et GROSS, L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York, PA 17401 717-848-3078 FAX 717-848-2777 Kurt A. Blake, Esquire I.D. No. 68791 29 East Philadelphia Street York, PA 17401 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14-866 Plaintiff v. CIVIL ACTION - LAW Larrisa Negley and Richard Estright, Defendants CERTIFICATE OF SERVICE I, the undersigned, do hereby certify that I have caused a true and correct copy of the foregoing to be served upon the Defendant, by placing such in the United States First Class & Certified Mail, in York, Pennsylvania, postage prepaid, and addressed as follows: Richard Estright 17 Town Mills Shippensburg, PA 17257 June 11th, 2014 By: BLAKE Et GROSS, L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York, PA 17401 717-848-3078 FAX 717-848-2777 A. Blake, Esquire I.No. 68791 2'' East Philadelphia Street York, PA 17401 BLAKE & GROSS, L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York, PA 17401 717-848-3078 FAX 717-848-2777 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14-866 Plaintiff v. CIVIL ACTION - LAW Larrisa Negley and Richard Estright, Defendants NOTICE OF FILING JUDGEMENT AGAINST RICHARD ESTRIGHT ONLY (X) Notice is hereby given that a judgement in the above -captioned matter has been entered against Richard Estright ONLY in the amount of $ 2,150.00 plus costs and interest and possession o4 17 Town Mills Shippensburg, PA 17257. (X) A copy of all documents filed with the Prothonotary in support f the within J gement are enclosed. Prothonotary Civil Division By: If you have any questions regarding this Notice, please contact the filing party: Kurt A. Blake, Esquire BLAKE & GROSS, LLC 29 East Philadelphia Street York, PA 17401 Phone: (717) 848-3078 (This Notice is given in accordance with PA R.C.P. 236) Notice sent to: Richard Estright 17 Town Mills Shippensburg, PA 17257 PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in triplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: (List the within matter for the next Argument court.) November 14th, 2014 CAPTION OF CASE (entire caption must be stated in full) Quentin Holdings, LLC VS. Larrisa Negley and Richard Estright -r, 1 rf. err; l i No.14-866 Z. Q -erm w-. ri cn 1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's demurrer to complaint, etc.): Preliminary Objections of Defendant Lrrisa Negley to Plaintiffs Complaint 2. Identify all counsel who will argue cases: (a) for plaintiffs:. Kurt A. Blake, Esquire 29 East Philadelphia Street York, PA 17401 (Name and Address) (b) for defendants: George B. Faller, Jr. 10 East High Street Carlisle, PA 17013 (Name and Address) Richard Estright (pro se) 3. I will notify all parties in writing within two days that this case has been listed for argument. 4. Argument Court Date: November 14th, 2014 Date: September 25th, 2014 Ku Signat r name e, Esquire ntin Holdings, LLC (Plaintiff) Att• ney for INSTRUCTIONS: 1. Original and two copies of all briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) before argument. 2. The moving party shall file and serve their brief 14 days prior to argument. 3. The responding party shall file their brief 7 days prior to argument. 4. If argument is continued new briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) after the case is relisted. -.y F: \FILES \ Clients\ 13994 \ 13994.60 Negley \ 13994.60.stipl.wpd Revised: 10/2/14 10:07AM George B. Faller, Jr., Esquire MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant FILE3-OFFICE "VHE PROMONOTAV, 2014 OCT 14 010: 15 CUMBERLAND COUNT'' PENNSYLVANIA QUENTIN HOLDINGS, LLC, Plaintiff V. LARRISA NEGLEY and RICHARD ES TRIGHT, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-866 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED STIPULATION OF COUNSEL 1. The parties by their respective attorneys hereby stipulate that Plaintiffs claim for attorneys' fees is hereby deleted and dismissed from Plaintiff's Complaint with prejudice. 2. This Stipulation is effective with no further action by the Court and Defendant Larrisa Negley will then file a Praecipe withdrawing her Preliminary Objections and file an Answer to the Complaint. MARTSON LAW OFFICES By George B. Falle I.D. No. 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 ., Esquire Attorneys for Defendant Larrisa Negley Dated: KAt3\ \Lk BLAKE OSS, L.L.C. u e, Esquire 29 East Philadelphia Street York, PA 17401 (717) 848-3078 By Attorneys for Plaintiff CERTIFICATE OF SERVICE I, Ami J. Thumma, an authorized agent for Martson Law Offices, hereby certify that a copy of the foregoing Stipulation of Counsel was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Kurt A. Blake, Esquire BLAKE & GROSS, LLC 29 East Philadelphia Street York, PA 17401 By rr) Ami- . Thu 10 East High treet Carlisle, PA 17013 (717) 243-3341 Dated: 101131 IC{ Vt-1' 0 Quentin Holdings, LLC 14-866 Plaintiff v. CIVIL ACTION - LAW Larrisa Negley and Richard Estright, Defendants PRAECIPE TO WITHDRAW TO THE PROTHONOTARY: Please withdraw the praecipe for listing case for argument only. Please also remove the case from the oral argument list currently scheduled for November 14', 2014. Dated : November 5th 2014 By: BLAKE & GROSS, L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York, PA 17401 717-848-3078 FAX 717-848-2777 Kurt A. Blake, Esquire I.D. 1 o. 68791 29 East Philadelphia Street York, Pennsylvania 17401 (717) 848-3078 Ext. 106 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14-866 Plaintiff v. CIVIL ACTION - LAW Larrisa Negley and Richard Estright, Defendants CERTIFICATE OF SERVICE I, the undersigned, do hereby certify that I have caused a true and correct copy of the foregoing to be served upon the Defendant, by placing such in the United States First Class Mail, in York, Pennsylvania, postage prepaid, and addressed as follows: Richard Estright 17 Town Mills Shippensburg, PA 17257 Larrisa Negley c/o George B. Faller, Jr. 10 East High Street Carlisle, PA 17013 November 5t'', 2014 By: BLAKE & GROSS, L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York, PA 17401 717-848-3078 FAX 717-848-2777 Ku A. Blake, Esquire I.D. No. 68791 29 East Philadelphia Street York, PA 17401 F:\FILES\Clients\13994Pro Bono \13994.60 Negley\13994.60.pet l .wpd George B. Faller, Jr., Esquire MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant iE F01 HOj: 20111tOV 19 AM 11:26 CUMBERLAND COUNTY PENNSYLVANIA QUENTIN HOLDINGS, LLC, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 14-866 : CIVIL ACTION - LAW LARRISA NEGLEY and RICHARD ESTRIGHT, Defendants : JURY TRIAL DEMANDED PETITION TO WITHDRAW AS COUNSEL FOR DEFENDANT LARRISA NEGLEY 1. On or about March 14, 2014, the undersigned agreed to represent Defendant Larrisa Negley through the Cumberland County Bar Association Pro Bono Program. 2. Counsel filed Preliminary Objections to Plaintiffs Complaint on behalf of Larrisa Negley on or about March 17, 2014. 3. On or about October 14, 2014, a Stipulation of Counsel was filed with the Court stipulating that Plaintiffs claim for attorneys' fees was deleted and dismissed and the Preliminary Objections were withdrawn. 4. Counsel has attempted to contact Defendant Larrisa Negley on several occasions with correspondence dated March 28, 2014, June 5, 2014, July 1, 2014, July 11, 2014, August 11, 2014, September 25, 2014, and October 15, 2014. 5. Counsel has advised Defendant Larrisa Negley that she needs to cooperate or he will be forced to with withdraw. 6. Larrisa Negley has failed to communicate, cooperate or respond to counsel and, therefore, counsel is requesting to withdraw as counsel on behalf of Defendant Larrisa Negley. 7. Counsel is sending a copy of this Petition to Defendant Larrisa Negley. 8. Plaintiff's counsel has concurred with the withdraw of counsel for Defendant Larrisa Negley. WHEREFORE, Counsel requests permission to withdraw. Dated: 11/19/14 MARTSON LAW OFFICES By George B. Faller, Jr., Esqui I.D. Number 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Larrisa Negley VERIFICATION George B. Faller, Jr., Esquire, of the firm of MARTSON LAW OFFICES, attorneys for Defendant Larrisa Negley in the within action, certifies that the statements made in the foregoing Petition to Withdraw as Counsel for Defendant Larrisa Negley are true and correct to the best of his knowledge, information and belief. He understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Georg". 1er, Jr., Esquire FAMES \Clients \13994Pro Bono \13994.60 Negley\13994.60.pet1.wpd CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent for Martson Law Offices, hereby certify that a copy of the foregoing Petition was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Kurt A. Blake, Esquire BLAKE & GROSS, LLC 29 East Philadelphia Street York, PA 17401 Ms. Larrisa S. Negley 17 Town Mill Mobile Home Park Shippensburg, PA 17257 MARTSON LAW OFFICES :7Y1(& Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: 11/19/14 George B. Faller, Jr., Esquire MARTS ON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant FILFJ3-OFL:rIC'E. THE P'il,071-10NOT4RY 2014 NOV 21 Ati 9:Q5 CUMBERLAND COUNTY PENNSYLVANIA QUENTIN HOLDINGS, LLC, Plaintiff V. LARRISA NEGLEY and RICHARD ESTRIGHT, Defendants : IN THE COURT OF COMMON PLEAS OF : COUNTY, PENNSYLVANIA : NO. 14-866 : CIVIL ACTION - LAW JURY TRIAL DEMANDED RULE TO SHOW CAUSE AND NOW, this/101y oWaYteork„ 2014, upon consideration of Petition to Withdraw as Counsel for Defendant Larrisa Negley, a Rule is hereby issued upon Defendant Larrisa Negley to show cause why Martson Law Offices should not be permitted to withdraw on behalf of Larrisa Negley. 2'0 J. cc: rge B. Faller, Jr., Esquire rt A. Blake, Esquire Ms. Larrisa Negley /72 -115.c -L a/ ilf F\FILES\Clients\13994Pro Bono\13994.60 Negley\13994.60.motI wpd Revised 12/19/14 220P George B. Faller, Jr., Esquire MARTSON LAW OFFICES I.D. 49813 1!1 f: i' 22 i j`1 2: v : 10 East High Street Carlisle, PA 17013 ''I' Etr'L- '' (717) 243-3341 r ENNSYE VAp `r Attorneys for Defendant QUENTIN HOLDINGS, LLC, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 14-866 : CIVIL ACTION - LAW LARRISA NEGLEY and RICHARD ESTRIGHT, • Defendants : JURY TRIAL DEMANDED MOTION OF GEORGE B. FALLER, JR., ESQUIRE TO MAKE RULE ABSOLUTE 1. On November 19,2014,the undersigned counsel for Defendant Larrisa Negley filed a Petition to Withdraw. 2. A Rule to Show Cause was issued by Judge Guido on November 20,2014. The Rule was sent to Larrisa Negley,but was returned by the post office indicating that the Defendant Larrisa Negley has vacated the premises and left no forwarding address. 3. Counsel's office has contacted the Cumberland County Bar Association Pro Bono Coordinator to see if Larrisa Negley has provided a better address or contact information,pursuant to their guidelines, and learned that she had not. 4. Larrisa Negley has not responded to the Rule issued on November 20, 2014. WHEREFORE, George B. Faller,Jr., Esquire,requests the Rule be made Absolute and that permission to withdraw as counsel be granted. MARTS()► , AW OFFIC_ By 11; / i� e George B. Viler, Jr., squire I.D. Number 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Date: 12/22/14 CERTIFICATE OF SERVICE I,Nichole L. Myers,an authorized agent for Martson Law Offices,hereby certify that a copy of the foregoing Motion was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Kurt A. Blake, Esquire BLAKE & GROSS, LLC 29 East Philadelphia Street York, PA 17401 Ms. Larrisa S. Negley 17 Town Mill Mobile Home Park Shippensburg, PA 17257 Ms. Larrisa S. Negley 1466 Wades Mobile Home Park Shippensburg, PA 17257 MARTSON LAW OFFICES By Siiit(64,71/1teg2" Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: 12/22/14 George B. Faller, Jr., Esquire MARTSON LAW OFFICES LD. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant •. Kik DEC 29 12 UMBckLAQ PENNSYLVANIA QUENTIN HOLDINGS, LLC, Plaintiff v. LARRISA NEGLEY and RICHARD ESTRIGHT, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-866 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED ORDER iles AND NOW, this 0' day of December, 2014, the Rule of November 20, 2014 is made Absolute. George B. Faller, Jr., Esquire is granted Leave of Court to withdraw as counsel. BLAKE & GROSS, L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York, PA 17401 717-848-3078 FAX 717-848-2777 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC . 14-866 Plaintiff v. CIVIL ACTION - LAW Larrisa Negley and Richard Estright, Defendants To: Larrisa S. Negley 17 Town Mill Mobile Horne Park Shippensburg, PA 17257 Larrisa S. Negley 1466 Wades Mobile Home Park Shippensburg, PA 17257 Date : December 29111, 2014 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO 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 IN THIS CASE. 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 RIGHT TO SUE THE DEFENDANT AND THEREBY LOSE 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER. LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE York County Bar '.s:ociation 137 East Mari treet York PA 1 (717) 854- u urt A. Blake, Esquire I.D. No. 68791 29 East Philadelphia Street York, PA 17401 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14-866 Plaintiff v.. CIVIL ACTION - LAW Larrisa Negley and Richard Estright, Defendants To: Larrisa S. Negley 17 Town Mill Mobile Horne Park Shippensburg, PA 17257 Larrisa S. Negley 1466 Wades Mobile Home Park Shippensburg, PA 17257 Date : December 29th, 2014 AVISO IMPORTANTE Usted esta en rebeldia porque ha fallado en tomar la accion exiga de su parte en este caso. A menos de que usted actue dentro de diaz de la fecha de este aviso, se puede registrar una sentencia contra usted, sin el beneficio de una audencia y puede perder su propiedad o derechos importante. Usted debe llevar este aviso a un abogado ensequida. Si usted no tiene un abogado y no puede pagar por los servicios de an abogado, debe comunicarse con la siguiente oficina para averiguar donde puede obtener ayuda legal: LAWYER REFERRAL SERVICE York County Bar Assoc -tion 137 East Market St York PA 17401 (717) 854-8755 By: BLAKE & GROSS, L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York, PA 17401 717-848-3078 FAX 717-848-2777 A. Blake, Esquire I.D. No. 68791 29 East Philadelphia Street York, PA 17401 fL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14-866 Plaintiff v. CIVIL ACTION - LAW Larrisa Negley and Richard Estright, Defendants CERTIFICATE OF SERVICE I, the undersigned, do hereby certify that I have caused a true and correct copy of the foregoing to be served upon the Defendant, by placing such in the United States First Class & Certified Mail, in York, Pennsylvania, postage prepaid, and addressed as follows: Larrisa S. Negley 17 Town Mill Mobile Home Park Shippensburg, PA 17257 Larrisa S. Negley 1466 Wades Mobile Home Park Shippensburg, PA 17257 December 29`1, 2014 By: BLAKE Et GROSS, L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York, PA 17401 717-848-3078 FAX 717-848-2777 t A. Blake, Esquire . No. 68791 9 East Philadelphia Street York, PA 17401 BLAKE & GROSS, L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York, PA 17401 717-848-3078 FAX 717-848-2777 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14-866 Plaintiff v CIVIL ACTION - LAW Larrisa Negley and Richard Estright, Defendants To: Larrisa S. Negley 17 Town Mill Mobile Home Park Shippensburg, PA 17257 Larrisa S. Negley 1466 Wades Mobile Home Park Shippensburg, PA 17257 Date : December 29th, 2014 AMENDED IMPORTANT NOTICE (-3 c: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO 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 IN THIS CASE. 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 RIGHT TO SUE THE DEFENDANT AND THEREBY LOSE 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle PA 17013 (717) 249-3166 By: ake, Esquire No. 68791 ' 29 East Philadelphia Street York, PA 17401 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14-866 Plaintiff v. CIVIL ACTION - LAW Larrisa Negley and Richard Estright, Defendants To: Larrisa S. Negley • 17 Town Mill Mobile Home Park Shippensburg, PA 17257 Larrisa S. Negley 1466 Wades Mobile Home Park Shippensburg, PA 17257 Date : December 29', 2014 AVISO IMPORTANTE Usted esta en rebeldia porque ha fallado en tomar la accion exiga de su parte en este caso. A menos de que usted actue dentro de diaz de la fecha de este aviso, se puede registrar una sentencia contra usted, sin el beneficio de una audencia y puede perder su propiedad o derechos importante. Usted debe llevar este aviso a un abogado ensequida. Si usted no tiene un abogado y no puede pagar por los servicios de an abogado, debe comunicarse con la siguiente oficina para averiguar donde puede obtener ayuda legal: LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle PA 17013 (717) 249-3] 66 By: BLAKE & GROSS, L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 Eost Pliftodelphia Street York, PA 17401 717-848-3078 FAX 717-848-1777 K A. lake, Esquire o. i:791 29 East Philadelphia Street York, PA 17401 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14-866 Plaintiff v. CIVIL ACTION - LAW Larrisa Negley and Richard Estright, Defendants CERTIFICATE OF SERVICE I, the undersigned, do hereby certify that I have caused a true and correct copy of the foregoing to be served upon the Defendant, by placing such in the United States First Class & Certified Mail, in York, Pennsylvania, postage prepaid, and addressed as follows: Larrisa S. Negley 17 Town Mill Mobile Horne Park Shippensburg, PA 17257 Larrisa S. Negley 1466 Wades Mobile Home Park Shippensburg, PA 17257 December 291h, 2014 BLAKE Et GROSS, L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York, PA 17401 717-848-3078 FAX 717-848-2777 B ur A. Blake, Esquire I.D. o. 68791 29 East Philadelphia Street York, PA 17401 F:\FILES\Clients\13994Pro Bono\ 13994.60 Negley\13994.60. pra2.wpd Revised: 1/8/15 2:31PM George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant � THE PRO 11-i �. tt�l s 2015 JAN 12 A11I10: 37 CUMBERLAND COUNT`( PENNSYLVANIA QUENTIN HOLDINGS, LLC, Plaintiff v. LARRISA NEGLEY and RICHARD ESTRIGHT, Defendants : IN THE COURT OF COMMON PLEAS OF : COUNTY, PENNSYLVANIA NO. 14-866 CIVIL ACTION - LAW : JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly withdraw the appearance of MARTSON LAW OFFICES on behalf of Defendant Larrisa Negley in the above matter. MARTSON LAW OFFICES George B. Faller, Jr., C v :wire I.D. No. 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Larrisa Negley Dated: 1/12/15 CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Kurt A. Blake, Esquire BLAKE & GROSS, LLC 29 East Philadelphia Street York, PA 17401 MARTSON LAW OFFICES By lthtk(- I`�� Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: 1/12/15 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14-866 Plaintiff .• CIVIL ACTION - LAW Larrisa Negley and . Richard Estright, • Defendants . PRAECIPE FOR DEFAULT JUDGEMENT TO THE PROTHONOTARY: Please enter a judgement of default against the Defendant, La- sa Negley in the amount of $2150.00plus costs and interest,plus possession of 17 Town Mills Shin.; sburg,PA 17257. , for the Defendants failure to file an Answer to the Complaint after timely and ,Lper service of 10 day notice, copy attached here to Exhibit"A". day of January, 2015 By: A firt . . Blake, Esquire I.II. N.. 68791 29 East Philadelphia Street York, Pennsylvania 17401 (717) 848-3078 BLAKE&GROSS,L.L.C. ATTORNEYS AND COUNSELORS AT LAW W , 29 East Philadelphia Street1\ p York,PA 17401 �� 1VA4 . 1:1 717-848-3078 FAX 717-848-2777 au M- 1\51L ----- __a .I elk ctom-' J``Nr-,..n . t, A A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC • 14-866 Plaintiff • CIVIL ACTION - LAW Larrisa Negley and • Richard Estright, • Defendants • CERTIFICATE OF SERVICE AND NOW, this l day of)anuary,2015, the undersigned does hereby certify that a true and correct copy of the Praecipe in the above matter was served upon the following persons by United States First Class Mail, Postage prepaid and addressed as follows: Larrisa S. Negley 17 Town Mills Shippensburg, PA 17257 Larrisa S. Negley 1466 Wades Mobile Home Park Shippensburg, PA 17257 day of January, 2015 By: Kurt A. Blake, Esquire I.D. No. 68791 29 East Philadelphia Street York, Pennsylvania 17401 (717) 848-3078 BLAKE&GROSS,L.L.C. ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York,PA 17401 717-848-3078 FAX 717-848-2777 OFFICE OF THE PROTHONOTARY OF CUMBERLAND COUNTY David D. Buell Phone 717-240-6195 Prothonotary Cumberland County Court House 1 Courthouse Square Suite 100 Carlisle, PA 17013 Larrisa S. Negley Date: January 1(0, 2015 17 Town Mills Shippensburg, PA 17257 Larrisa S. Negley 1466 Wades Mobile Home Park Shippensburg,PA 17257 RE: Quentin Holdings, LLC, Plaintiffs VS: Larrisa S. Negley, Defendant Notice is given that a default judgement in the above captioned matter has been entered against you on January 1(0, 2015 David D. Buell PROTHONOTARY OE CUMB RLAND i TY f • ‘ , \ ';,)) ( I By Cl; or Deputy If you have any questions concerning the abo - :,.e, please contact: Kur Blake, Esquire BLAKE Et GROSS,L.L.C. 29 ' ast Philadelphia Street ATTORNEYS AND York, PA 17401 COUNSELORS AT LAW 29 East Philadelphia Street Phone (717) 848-3078 York,PA 17401 717-848-3078 FAX 717-848-2777 OFFICE OF THE PROTHONOTARY OF CUMBERLAND COUNTY David D. Buell Phone 717-240-6195 Prothonotary Cumberland County Court House 1 Courthouse Square Suite 100 Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA Plaintiff: Quentin Holdings, LLC VS: Defendant: Larrisa S. Negley Judgement No: 14-866 CERTIFICATE OF RESIDENCE PA R. P. 236 I, hereby certify that the precise address of: Plaintiff is: Quentin Holdings, LLC 2159 White Street Suite 3 Box 139 York PA 17404 and certify that the last known address of the within: Defendant is: Larrisa S. Negley 17 Town Mills Shippensburg, PA 17257 Larrisa S. Negley l 1466 Wades Mobil: . e Park Shippensburg, PA BLAKE&GROSS,L.L.C. K • . Blake, Esquire ATTORNEYS AND 29 .st Philadelphia Street COUNSELORS AT LAW I� 29 East Philadelphia Street York, PA 17401 York,PA 17401 717-848-3078 Phone (717) 848-3078 FAX 717-848-2777 OFFICE OF THE PROTHONOTARY OF CUMBERLAND COUNTY David D. Buell Phone 717-240-6195 Prothonotary Cumberland County Court House 1 Courthouse Square Suite 100 Carlisle, PA 17013 Quentin Holdings, LLC, Plaintiffs VS: Larissa S. Negley, Defendant Docket NO. 14-866 Commonwealth of Pennsylvania Cumberland County Before me, The Prothonotary of Cumberland County, Pennsylvania, personally appeared Kurt A. Blake, Esquire attorney for Plaintiff, in the above entitled case, who being duly sworn or affirmed according to law deposes and says, that the Plaintiff above named is not in the military service of the United States of America, that he or she has personal knowledge that the Defendant, Larissa S. Negley, residing at 17 Town Mills Shippensburg, PA 17257 and/or 1466 Wades Mobile Home Park, Shippensburg, PA 17257 and is a resident of Cumberland County County. Sworn and subscribed before me this day of January, 2015. Prothonotary Ku f Blake, Esquire 29 •r: t Philadelphia Street BLAKE&GROSS,L.L.C. YO► , PA 17401 ATTORNEYS AND P one (717) 848-3078 COUNSELORS AT LAW 29 East Philadelphia Street York,PA 17401 717-848-3078 FAX 717-848-2777 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14-866 Plaintiff v. • CIVIL ACTION - LAW • Larrisa Negley and • Richard Estright, NOTICE OF FILING JUDGEMENT Defendants AGAINST RICHARD ESTRIGHT ONLY (X) Notice is hereby given that a judgement in the above-captioned matter has been entered against Larrisa S. Negley in the amount of$2,150.00 plus costs and interest and possession on 17 Town Mills Shippensburg, PA 17257. (X) A copy of all documents filed with the Prothonotary in support of the within J ,.,ement are enclosed. ...,.,v, w. Prothonotary Civil Division By: If you have any questions regarding this Notice, please contact the filing party: Kurt A. Blake, Esquire BLAKE & GROSS, LLC 29 East Philadelphia Street York, PA 17401 Phone: (717) 848-3078 (This Notice is given in accordance with PA R.C.P. 236) Notice sent to: Larrisa S. Negley 17 Town Mills Shippensburg, PA 17257 BLAKE @ GROSS,L.L.C. ATTORNEYS AND COUNSELORS AT LAW Larrisa S. Negley 29 East Philadelphia Street 1466 Wades Mobile Home Park York,PA 17401 717-848-3078 Shippensburg, PA 17257 FAX 717-848-2777 • • • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC 14-866 Plaintiff •• CIVIL ACTION - LAW Larrisa Negley and : Richard Estright, Defendants To: Larrisa S. Negley Date : December 291h, 2014 17 Town Mill Mobile Home Park Shippensburg, PA 17257 Larrisa S. Negley r— `. • IN) 1466 Wades Mobile Home Park r-- Shippensburg, PA 17257 c - AMENDED IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO 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 IN THIS CASE. 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 RIGHT TO SUE THE DEFENDANT AND THEREBY LOSE 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle PA 17013 (717) 249-3166 BLAKE&GROSS,L.L.C. ATTORNEYS AND COUNSELORS AT LAW By: , 29 East Philadelphia Street York,PA 77401A. i lake, Esquire 717-848-3078 FAX 717-848-2777 I.:. No. 68791 29 East Philadelphia Street ‘k. York, PA 17401 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC • 14-866 Plaintiff • v CIVIL ACTION - LAW Larrisa Negley and Richard Estright, • Defendants • To: Larrisa S. Negley Date : December 29th, 2014 17 Town Mill Mobile Home Park Shippensburg, PA 17257 Larrisa S. Negley 1466 Wades Mobile Home Park Shippensburg, PA 17257 AVISO IMPORTANTE Usted esta en rebeldia porque ha fallado en tomar la accion exiga de su parte en este caso. A menos de que usted actue dentro de diaz de la fecha de este aviso, se puede registrar una sentencia contra usted, sin el beneficio de una audencia y puede perder su propiedad o derechos importante. Usted debe llevar este aviso a un abogado ensequida. Si usted no tiene un abogado y no puede pagar por los servicios de an abogado, debe comunicarse con la siguiente oficina para averiguar donde puede obtener ayuda legal: LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle PA 17013 (717) 249-3166 By: 41 BLAKE Et GROSS,L.L.C. ATTORNEYS AND KA. 'i lake, Esquire COUNSELORS AT LAW 1.) 0. i:791 29 East Philadelphia Street York,PA 17401 29 East Philadelphia Street 717-848-3078 FAX 717-848-2777 York, PA 17401 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Quentin Holdings, LLC • 14-866 Plaintiff v CIVIL ACTION - LAW • Larrisa Negley and : Richard Estright, • Defendants • CERTIFICATE OF SERVICE I, the undersigned, do hereby certify that I have caused a true and correct copy of the foregoing to be served upon the Defendant, by placing such in the United States First Class & Certified Mail, in York, Pennsylvania, postage prepaid, and addressed as follows: Larrisa S. Negley 17 Town Mill Mobile Home Park Shippensburg, PA 17257 Larrisa S. Negley 1466 Wades Mobile Home Park Shippensburg, PA 17257 December 29'h, 2014 By: ur A. Blake, Esquire I.D. o. 68791 29 East Philadelphia Street BLAKE&GROSS,L.L.C. York, PA 17401 ATTORNEYS AND COUNSELORS AT LAW 29 East Philadelphia Street York,PA 17401 717-848-3078 FAX 717-848-2777