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Home My WebLink About14-1431 COMMONWEALTH OF PENNSYLVANIA 3 COURT OF COMMON PLEAS NOTICE OF APPEAL Judicial District, County Of FROM C tkAtE- .1--As kAb MAGISTERIAL DISTRICT JUDGE JUDGMENT J COMMON PLEAS No. l f it 3 1 C,dv:l/ 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 ANNE EDWARDS Al D3 - o9'- I -o3 Hoi . Rio-IARD s . oc4.QHE.R1 y ADDRESS OF APPELLANT CITY STATE ZIP CODE , o , o' to13 CAMP Wi(-L P. ■ 14-001 DATE OF JUDGMENT IN THE CASE OF(Plaintiff) (Defendant)' o2 / 24 2_o E1.1oL.A SENtoR ouS(14s, LP ,, AuNE EDwARDS DOCKET No. SIGNATURE Of APPELLANT OR ATTORNEY OR AGENT MS— 09103- LT- O0000 13-ZA 422r�� This block will be signed ONLY when this notation is required under Pa. If appellant was Claimant (see Pa. R.C.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 II (20)days after filing the NOTICE of APPEAL. _— Sgnature of Prc�honotary 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 ts.)0 LAN SEt∎110 - WO US f t6) LP appellee(s),to file a complaint in this appeal j LJ Name of appellee(s) 3 (Common /4/ / / / ) I G 1 ) Y( )days entry judgment P Common Pleas No. within twenty 20 da s after service of rule or suffer ent of'ud ment of non pros. Gia Signature of appellant or attorney or agent L? RULE: To E MO LA S& Jt o R us(IJ appellee(s) Name of appellee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty(20)days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time,a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was byVl_ maiis the�date offf the mailing. 3d Date:3JrO 20 I,'' 3 amrietcG , Or ' r're of Prothonotary or Deputy : add 0 YOU MUST INCLUDE A COPY OF THE NOT1CIEt-,f FflipD9ME-�TA�TRANSCRIPT FORM WITH THIS OTICE OF APPEAL. faS..66?aCl T}• AOPC 312-05 Pt.o. /98i413 V?rs3 / P3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND May. Dist. No: MDJ Name: Address: MDJ-001-03 Honorable Richar S. Dougherty 98 South Enola Drive, Suite 1 Enola.PA 17025 Telephone: 717-728-2805 Darrell Charles Dethlefs, Esq. Dethlefs Pykosh Law Group Llc 2132 Market St Camp Hill, PA 17011-4706 Notice of Judgment/Transcript Residential L ease EDOla Senior Housing, LP Anne Edwards v. Docket No MJ'09103-LT-0000013-2014 Case Filed: 2/14/2014 Disposition Details Grant possession. Yes Grant possession if mo»ey judgment,is not satisfied by the time of evicon., No ^' ��/� ` Disposition Summary Docket No �ain� Defendant Disposition Di��nDate MJ'09103-LT-0000013-2014 Enola Senior Housing, LP Anne Edwards Judgment for Plaintiff 02/27/2014 Judgment Summary Participant Joint/8ovara|Uabi|itv Individual Liability Amount Anne Edwards $0.00- $1.328.80 . *1.323.90 Enola Senior Housing, LP $0.00 $0.00 $0.00 Judgment Finding <1"os Jvugmem) In' the matter of Enola Senior Housing, LP vs. Anne Edwards on MJ-09103-LT-0000013-2014, on 2/37/20 14iho judgment was awarded as foliows: The amount of rent per month, as estabiished by the Magisteriaf Dfstrict Judge, is $210.08 Judgment Component Joint/Sovora|Liabi|dv Individual Liability Deposit Applied Amount Physical Damages to Property $Uzw' o*31.00 : — ---- — : *631.00 Filing Fees s0.00 $127.40 $127.40 Attorney Fees $0.00 $565.50 $565.50 Grand Total: `Portion v,imomom for physical damages arising out o/ residential lease: McoS31u* Page 1 of 3 Printed: 02/27/2014 10:12:38AM Enola Senior Housing, LP v. Anne Edwards 717b1XL1- Docket No: MJ- 09103 -LT- 0000013 -2014 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. FEB 2 7 2014 Date Magisterial District Judge Richard S. Dougherty I certify that this is a true and correct copy of the record of the proceedings containing the judgment. Date Magisterial District Judge MDJS 315A Page 2 of 3 Printed: 02/27/2014 10:12: 38AM Eno la Senior Housing, LP v. Anne Edwards Private(s) Plaintiff(s) Participant List Darrell Charles Dethlefs, Esq. Dethlefs Pykosh Law Group Llc 2132 Market St Camp Hill, PA 17011-4706 Tricia Dills Naylor, Esq. Baric Scherer Llc 19 W South-St Carlisle, PA 17013-3444 Eno le Senior Housing; LP do Redevelopment Authority of 114 N. Hanover Street Carlisle, PA 17013 Defendant(s) Anne Edwards 16 S. Eno la Drive #220 Eno la, PA 17025 )494t N/47Ar/14 Docket No.: MJ-09103-LT-0000013-2014 MDJS 315A Page 3 of 3 Printed: 02/27/2014 10:12:38AM IN THE COURT OF CO 01 01/1141/06 COUNTY, PENNSYLVANIA 1' Anift.,04,0514/41JS PAW 14)6, % PA-3- -0 1) 03,Lli DO OW 6,1c5c_Ps SENtoZ us NG) Plaintiff VS. poo4E E-DwAR-t) Defendant No PETITION TO PROCEED IN FORMA. PAUPERIS TO THE HONORABLE, THE JUDGES OF THE SAID COURT: The Petition of n L qfris respectfully represents: 1. I am the nt-4,n(k/it in the above matter and because of my financial condition arn unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation.. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct: cz rrl Cf) CT, (a) Name: EdWa(J-C Addrew Ctha,;( /9) 'FoA Po< Soc. Sec. No.: ig /013 (b) Employment—If you are presently employed, state Plif-t/ //2 Employer: Address: --- Salary or wages per month: Type of work --If you are presently unemployed, Date oflast employment: et 1(, 4 9 ( I ' Salary or wages per month: imp ) C Type of work: 41194; d�3� Q c L9-TN (c) Other incom within the past twelve months Business or profession: p p t Other self - employment: lJ n L Interest: -Np f & Dividends: QJ /1 Pension and annuities: jJ c i t T 36 Social security benefits: '444,, Oh4 t.r, Support payments: W0 n Disability payments: ft 11Z Workman's compensation: 0d f 0 Public assistance: / up cacti Other: r1)0 XXeR eel If (301• (d) • r • , trib on hou ehol Spouse's Name: �5 n� If your spouse is employed, Employer: I\ T V Salary or wages per month: Type of work: Contributions from child(ren): 11)6n & Contributions from parents: 1V 0 n L./ Other contributions: 0/ 0 p 1iv4 47-0118-0---093,))5-c � e V 7I To-AL og / /Pc/0 n7c- (e) 'ro li: Checking accoun Savings account: q3,51 Certificates of deposit: No 0 2 Real estate (including home): IV/d%) 02/ Motor vehicle: Make: fO,(10V0V Cost /61DD Amount owed: No 11 , Stocks; WO f1'. bonds: Jj It 1Q/ Other Q n Debts and obligations, 4764/5 /)/'/ Lv' mai Cep �egl: - fro44I1 f yPI rti ac y 13,-- � rAon 41 41 Mortgage :n L/ Rent: Hell (°'` /))(2efr Loans: 0 /0-- Other: /i €- Electric flid)i JJ Water r1/0 A /lion Wj 1:10/924.1, ;i1Cr .44 gob kg,4 airdta) in-014/7 /4 Telephone e, Cable p.411 Credit cards Alp Auto Insurance Gasoline 7J ' Y imil /!.q 01 Food t 000 4L -r &O - tva rtko n� -aO/ 0 o 136Jg NJ; ,aelt-frq ao• 42ecliew DAIT' 4- r ors r/d ove,r- Q -Coon 1 ��o©7 (g) Persons dependent upon you for §_u port Spouse's Name: -4/5U " Child(ren), if any: IM Ci-a f " Name(s) and age(s): ,4!4 pa �� N.: rf -01G3 -lam Other persons: Name: DIM f j Qi Relationship: ft/y 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. /1fuy'Ui 201 Date Petitioner dtgiakirid IN THE COURT OF COMMON PLEAS OF . 1:0UNTY, PENNSYLVANIA CIVIL ACTION—LAW API "lc& 3-16 II/ Poch+ Ivo; icap,? 001-5 airlepi;; Eoc ELI (oz Plaintiff • • • • • v. No. - Defendant : 3/) ORDER AND NOW, t day of,70-...-4', we , upon consideration of the Petition of tf„„e, to Proceed In Forma Pauperis, it is hereby ORDERED and DECREED that the Plaintiff'- /44r.(. 6 , may fikecthe lir/Laced in forma pauperis azedlaximetto the termination of proceedings without payment of filing fees or costs. By the Prothonotary: 71: -17 6, -a Lii N ci N ci N m ci C3 ci 1:3 C3 m ru m re , E3 Street, Apt. p....or PO Box N . ostal Service TM CERTIFIED MAIL, RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at www.usps.co P kertified F Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees Sent To 0000 3707 0749 S .1, iii RJ m ci U.S. Postal Service,. CERTIFIED MAILT-;"RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at www.usps.comu Postage 4/ 1C-edified Fe Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fe PS Form 3800. August 2006 See Reverse for Instructions PS Form 3800, August 2006 PROOF OF SERVICE OF NOTICE OF APP AL AND RULE Ti FIL COMPLAINT _ (This Proof Of service MUST BE FILED WITHIN TEN (10)DAYS AFTER filing of the notice of appeal. Check applicable boxes.) See Reverse for Instructions COMMONWEALTH OF PENNSYLVANI COUNTY OF ; SS AFFIDAVIT: I her at I served a copy of the Notice of Appeal, Common Pleas No. , upon the Magisterial Di trict Judge designated therein on (date of service)/5, 20// , 0 by personal service ifie ),(iregistered) mail, sender's receipt attached hereto, and upon the appellee, (name ) , on 20 by personal serviceD VEK-(C-e-r—stified (registered) mail, sender's receipt attached hereto. (SWOAI) (AFFIRMED1MD SUBTRIBED BEFORE ME THISr) DAY OF Lisn , 201 Signature of official before whom affidavit was made Dorr--rAct--e-e-r Title of official My commission expires onZ_, 201c) AOPC 312A - 05 Signature of affiant C.OMMONWEALTH OF PENNSYLVANIA Notarial Seal Elba Van Sant, Notary Public Lower Paxton Twp., Dauphin County My Oommission Expires Feb. 25, 2015 NEMER, PEWNSYLVAPflA ASSOcZA Ce? C) ENOLA SENIOR HOUSING, LP : c/o Redevelopment Authority of the : County of Cumberland 114 N. Hanover Street Carlisle, PA 17013 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO.2014 -1431 CIVIL TE ANNE EDWARDS EJECTMENT P.O. Box 1023 Camp Hill, PA 17001 CIVIL ACTION Defendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249 -3166 ENOLA SENIOR HOUSING, LP : c/o Redevelopment Authority of the : County of Cumberland 114 N. Hanover Street Carlisle, PA 17013 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2014 -1431 CIVIL TERM ANNE EDWARDS EJECTMENT P.O. Box 1023 Camp Hill, PA 17001 CIVIL ACTION Defendant COMPLAINT NOW, comes Plaintiff, Enola Senior Housing, LP, by and through its attorneys, BARIC SCHERER LLC, and files the within Complaint and, in support thereof, sets forth the following: 1. Plaintiff, Enola Senior Housing, LP, is Pennsylvania limited partnership, with an address of 114 North Hanover Street, Carlisle, Pennsylvania 17013. 2. Defendant, Anne Edwards, is an adult individual with a residence address of 16 S. Enola Drive, #220, Enola, Pennsylvania 17025. 3. Plaintiff is the owner of a certain residential real property known as 16 S. Enola Drive, #220, Carlisle, Pennsylvania 17013 ( "leased premises "). 4. On or about December 9, 2004, the parties entered into a Residential Dwelling Lease Agreement ( "Lease Agreement ") for the leased premises. A true and correct copy of the Lease Agreement is attached hereto as Exhibit "A" and is incorporated by reference. 5. The Defendant is identified as the Tenant and the Plaintiff is identified as Owner under the Lease Agreement. 6. After the initial one year lease term, the lease was renewed for additional one month terms. 7. The Lease Agreement set rent at $471.00 per month during the term of the lease. 8. Defendant's rent is subsidized through the Section 8 Housing Choice Voucher Program, and therefore Defendant's rental obligation is $216.000 per month. 9. Item 4, Paragraph A of the Lease Agreement provides, "Payment of the full amount of monthly rent and other charges when due is deemed to be a material term of this Lease." 10. Item 4, Paragraph D of Lease Agreement provides, the maintenance and repair charges "shall be due and payable the first day of the second month following the month in which the charges occurred." 11. Item 8 of the Lease Agreement provides, that the Tenant shall comply with the following: B. To conduct himself or herself and cause other persons who are on the Premises with Tenant's consent, to conduct themselves in a manner which will not disturb Tenant's neighbors' peaceful enjoyment of their accommodations. C. To refrain from, and to cause Tenant's household and guests to refrain from destroying, defacing, damaging or removing any part of the Premises or Project. 12. On or before July 8, 2013, Defendant dismantled the intercom /door control panel in the leased premises and disconnected the wires in the door control panel. 13. The damage caused by Defendant's actions resulted in the main doors of the apartment complex to remain unlocked and the building to be unsecure. 14. Plaintiff incurred charges in the amount of $631.00 to investigate the source of the main doors locking mechanism failure and repair of the intercom /door control panel of the leased premises. 15. On or about August 1, 2013, Plaintiff sent a request for payment and notice to Defendant of the charges incurred by Plaintiff. A true and correct copy of the letter and invoice are attached hereto as Exhibit `B" and are incorporated by reference. 16. Defendant has failed to pay for the charges. 17. On or about October 24, 2013, Plaintiff sent notice to Defendant that it was not renewing her lease and that she had the right to appeal. A true and correct copy of the letter is attached hereto as Exhibit "C" and is incorporated by reference. 18. Defendant requested an appeal and the appeal was heard by the independent hearing officer on December 27, 2013. 19. The decision not to renew Defendant's lease was upheld by the hearing officer. A true and correct copy of the hearing officer's decision is attached hereto as Exhibit "D" and is incorporated by reference. 20. On or about January 16, 2014, Plaintiff provided Defendant with a fifteen (15) day Notice To Quit. A true and correct copy of the Notice To Quit and Affidavit of Service is attached hereto as Exhibit "E" and incorporated herein by reference. 21. Defendant failed to vacate the leased premises within the allotted time period and continues to reside in the leased premises. 22. The Lease Agreement provides for the recovery by Plaintiff of all necessary legal fees to enforce the provisions of the lease agreement. 23. As of February 27, 2014, Defendant owed repair charges in the amount of $631.00 and attorney's fees and court costs of $692.90. 24. Rent has accrued for the months of February and March in the amount of $216.00 per month. 25. Additional attorney's fees have been incurred by Plaintiff in the amount of $382.66. COUNT I- EJECTMENT 26. Plaintiff incorporates by reference paragraphs one through twenty -five as though set forth at length. 27. On January 16, 2014, Defendant was served with Plaintiffs Notice to Quit. 28. Defendant refused to vacate premises after expiration of the applicable notice period. 29. Defendant breached her obligation to pay repair charges for the leased premises to Plaintiff. 30. Defendant breached her obligations to refrain from damaging or removing any part of the Premises. 31. Defendant breached her obligation not to disturb her neighbors' peaceful enjoyment. 32. Defendant breached her obligation to pay legal fees to Plaintiff. 33. The term of the Lease Agreement has expired. 34. By virtue of Defendant's breach of her obligations under the Lease Agreement and by virtue of the expiration of the lease term, Plaintiff is entitled to possession of the leased premises. WHEREFORE, Plaintiff requests judgment in ejectment to be entered in its favor and against Defendant and all others who may be residing in the premises together with costs and expenses of this action. COUNT II — BREACH OF CONTRACT FOR OTHER FEES AND CHARGES 35. Plaintiff incorporates by reference paragraphs one through thirty -four as though set forth at length. 36. As of February 27, 2014, Defendant owed repair charges in the amount of $631.00 and attorney's fees and court costs in the amount of 692.90. 37. Rent has accrued in the amount of $432.00. 38. Additional attorney's fees have been incurred by Plaintiff in the amount of $382.66. 39. By virtue of Defendant's failure to pay the debt owed to Plaintiff, Defendant has breached the terms of the Lease Agreement. WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the amount of $2,138.56, plus any additional charges for rent, other charges, legal fees and costs which may become due and payable after March 25, 2014. Respectfully submitted, BARIC SCHERER LLC Trici.. D. Naylor, E I.D. # 83760 19 West South Street Carlisle, Pennsylvania 17013 (717) 249 -6873 VERIFICATION The statements in the foregoing Complaint are based upon information which has been assembled by my attorney in this litigation. The language of the statements is not my own. I have read the statements; and to the extent that they are based upon information which I have given to my counsel, they are true and correct to the best of my .knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsifications to authorities. DATE: IV4 fq A t Andrew S. Haines, Manager of Pennsboro Housing, LLC, General Partner of Enola Senior Housing, LP CERTIFICATE OF SERVICE I hereby certify that on March31 , 2014, I, Tricia D. Naylor, Esquire, of Baric Scherer LLC, did serve a copy of the Complaint, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Anne Edwards P.O. Box 1023 Camp Hill, Pennsylvania 17001 RESIDENTIAL DWELLING LEASE ENOLA S ENIOR APARTMENTS THIS AGREEMENT, made this .641ty of December , 200 4, by and between Enola Senior Housing, L.P. (hereinafter referred to as "Owner"), and Anne Edwards (hereinafter referred to as "Tenant "). WITNESSETH: WHEREAS, Owner does hereby desire to lease to Tenant and Tenant does desire to lease from Owner, for its sole use and occupancy the premises, as hereinafter described, located at Enola Commons Senior Apartments (the "Project"), pursuant to the terms and conditions as hereinafter set forth; and WHEREAS, Owner has designated the Redevelopment Authority of the County of Cumberland as Owner's managing agent (the "Managing Agent "). NOW, THEREFORE, in consideration of the representations made to Owner by Tenant as to Tenant's household composition and income and in consideration of the rentals hereinafter reserved, intending to be legally bound, the parties do hereby agree as follows: 1. PREMISES. Owner does hereby lease to Tenant for the term as hereinafter set forth the premises known and described to as follows (hereinafter referred to as "Premises "): Dwelling Unit No. 220 at 16 South Enola Drive, Enola, PA 17025. MEMBERS OF HOUSEHOLD. The members of Tenant's household, having a right of occupancy, are as follows: Anne Edward /1" TERM OF LEASE. This Lease nd Tenant's right of occupancy hereunder shall commence as of December' 200 4 , and shall continue for one year, provided, however, that in the absence of a notice to terminate, this Lease will automatically be renewed for the successive term of one (1) calendar month (hereinafter referred to as the "Month- to-Month Lease "), upon payment each month by the Tenant of the rental in the amount and manner specified herein. In the event of any increase in the monthly rent amount payable under the Month -to -Month Lease, a thirty (30) day advance written notice shall be given by Landlord to Tenant. After the initial year of occupancy, either party may terminate this tease upon giving notice to the other party of lease termination, with said notice to be given not less than thirty (30) days prior to the last day of the month upon which the lease terminates. 4. PAYMENTS DUE UNDER THE LEASE; A. Rent. Rent for the period beginning December , 200 4 , and ending at midnight December 31 , 200 4 , shall be Zero Dollars ($0.00), payable not later than December 1. 2004. Thereafter, monthly rent in the amount of Four- Hundred - Seventy -One Dollars ($471.00) shall be due and owing on or before the first day of each month. Payment of the full amount of the monthly rent and other charges when due is deemed to be a material term of this Lease. A service charge Twenty -Five Dollars ($25.00) will be charged for all rent not paid by the fifth (5th) working day of the month. B. Storage Unit. A limited number of storage units are available for an additional fee. Rental of a storage unit is an option, not a requirement. Tenant chooses to rent a storage unit. Rent for the storage unit is Five Dollars ($5.00) per month and shall be due and owing on or before the first day of the month. In the event that the tenant chooses to no longer rent a storage unit, tenant shall provide notice to owner and remove any and all items in storage. Payment of the rent for the storage unit when due and tenant's responsibility to remove any and all items in storage upon conclusion of a storage rental term are deemed to be material terms of this Lease. Tenant chooses NOT to rent a storage unit. C. Utilities. Owner agrees to furnish and provide all utilities. Notwithstanding the foregoing, Tenant shall be responsible for telephone and TV cable. D. Maintenance and Repairs. A schedule of charges to Tenants for maintenance and repair beyond normal wear and tear shall be posted in the Management Office at Enola Commons Senior Apartments. Charges shall be due and payable the first day of the second month following the month in which the charges occurred. Security Deposit. Tenant agrees to pay Owner a security deposit of Four - Hundred -Seven -One Dollars ($471.00). The security deposit will be used by Owner at the termination of the Lease toward reimbursement of the cost of repairing any intentional or negligent damages to the dwelling unit caused by the Tenant, his family or guests, or any rent or other charges owed by Tenant. Tenant's security deposit is to be made upon lease signing. 2 5. ELIGIBILITY FOR OCCUPANCY. Tenant agrees to report any and all changes in family composition or income to Owner in writing within ten (10) calendar days of such change and to furnish accurate information to Owner annually at a time to be set by Owner as to family income, employment, and family composition. This information shall be used for the use of Owner in determining whether the Tenant remains income eligible to occupy the Premises. Tenant hereby authorizes Owner to verify all sources of income. OCCUPANCY. Tenant shall have the exclusive right to use and occupancy of the Premises. Guests or visitors of Tenant may be accommodated for the period as set forth in the Tenant's Handbook and House Rules. 7. OBLIGATIONS OF OWNER. Owner shall have the following obligations under this Lease Agreement: A. To maintain the Premises and the project in a decent, safe, and sanitary manner; To comply with all applicable building and housing codes materially affecting health and safety; C. To make the necessary repairs to the Premises; D. To keep the facilities and common areas not otherwise assigned to the Tenant, in a safe and clean condition; and To maintain in good and safe working order and condition all electrical, plumbing, sanitary, heating, cooling, ventilating, and other facilities and appliances, supplied or required to be supplied by Owner. OBLIGATIONS OF TENANT. Tenant shall comply with all of the Tenant obligations as set forth in Tenant's Handbook and House Rules, which are incorporated herein by reference thereto. Tenant's failure to comply with Tenant's Handbook and House Rules shall be deemed to be a material breach of this Lease Agreement. Notwithstanding the foregoing and in addition thereto, the Tenant shall comply with the following: A. Not to assign the Lease or sublease the Premises. B. To conduct himself or herself and cause other persons who are on the Premises with Tenant's consent, to conduct themselves in a manner which will not disturb Tenant's neighbors' peaceful enjoyment of their accommodations. C. To refrain from, and to cause Tenant's household and guests to refrain from destroying, defacing, damaging or removing any part of the Premises or Project. D. To keep the Premises and such other areas as may be assigned to Tenant for Tenant's exclusive use in a clean and safe condition. Tenant is also required to keep stove and refrigerator clean and free from grease. E. To refrain from, and to cause Tenant's household and guests to refrain from smoking cigarettes, cigars, or pipes inside any area of the building, including the tenant's apartment. To dispose of all ashes, garbage, rubbish and other waste from the Premises in a sanitary and safe manner. G. To comply with any and all federal, State, or local laws that impose obligations on the Tenant in connection with the occupancy or use of the Premises. To pay all necessary legal fees expended by Management for enforcement of the provisions of this Lease Agreement. Tenant, any member of the Tenant's household, a guest or another person under a Tenant's control, shall not commit any of the following types of criminal activity: 1. Any criminal activity that threatens the health or safety of, or the right to peaceful enjoyment of the Premises by, other residents (including property management staff); Any criminal activity that threatens the health or safety of, or the right to peaceful enjoyment of the residences by, persons residing in the immediate vicinity of the Premises; Any violent criminal activity on or near the Premises; or 4. Any drug- related criminal activity on or off the Premises. L Tenant, any member of the Tenant's household or guest or other person under the Tenant's control shall not abuse alcohol to the effect of which would threaten the health, safety or right to peaceful enjoyment of the Premises by other residents, J. A single violation of the provisions of Paragraphs 8H. and 81. shall be 4 deemed a serious violation and a material non - compliance with the Lease and good cause for termination of tenancy. Unless otherwise provided by law, proof of violation shall not require criminal convictions but shall be by preponderance of the evidence. It is agreed and understood that Owner has adopted a "one strike, you're out" or "zero tolerance" policy with respect to violations of Lease terms regarding criminal activity and abuse of alcohol that impacts upon the health, safety, or right to peaceful enjoyment of the project premises by other residents. 9. DEFECTS HAZARDOUS TO LIFE, HEALTH, OR SAFETY. In the event the Premises are damaged to the extent that the conditions are created which are hazardous to life, health or safety of the occupants: A. Tenant shall immediately notify Owner of the damage; B. Owner shall be responsible for repair of the unit within a reasonable time; provided, that if the damage was caused by Tenant, Tenant's household or guests, the reasonable cost of the repairs shall be charged to Tenant; and C. Owner shall offer standard alternative accommodations, if available, in circumstances where necessary repairs cannot be made within a reasonable time, except if repairs are required if the damage was caused by Tenant, Tenant's household or guests. 10. PRE - OCCUPANCY AND PRE- TERMINATION INSPECTIONS. A. Owner and Tenant or Tenant's representative shall inspect the Premises prior to commencement of occupancy by Tenant. Owner shall furnish Tenant with a written statement of the condition of the Premises, the dwelling unit and the equipment provided with the unit. A statement shall be signed by Owner and placed in Tenant's folder. B. At the time Tenant vacates the Premises, Owner shall inspect the unit and shall furnish Tenant with a statement of any charges to be made. Tenant shall be responsible to pay for reasonable charges (other than for wear and tear) for the repair of damages to the Premises, Project facilities or common areas caused by Tenant, Tenant's household or guests. Owner shall notify Tenant of the inspection and Tenant and/or Tenant's representative may join in such inspection unless Tenant vacates the Premises without prior notice of Management 11. ENTRY OF PREMISES DURING TENANCY. A. Owner shall, upon reasonable advance notification (7 days) to Tenant, be 5 permitted to enter the dwelling unit during reasonable hours for the purpose of performing routine inspections and maintenance, including extermination services, for making improvements or repairs, or to show the Premises for re- leasing. Owner may enter the Premises at any time without advance notification where there is reasonable cause to believe that an emergency exists. 12. PROCEDURES OF GIVING NOTICE. A. Notice to Tenant shall be in writing and delivered to Tenant or sent by prepaid first -class mail, properly addressed to Tenant. B. Notice to Owner shall be in writing and delivered to the Project Office or Management Central Office or sent by prepaid first -class mail, properly addressed to Owner. 13. PROCEDURES FOR TERMINATION OF LEASE. A. Owner may terminate or refuse to renew this Lease for violations of the terms of the Lease and /or the Tenant Handbook and House Rules. Owner shall give written notice of the proposed Termination of the Lease, which shall state the specific reasons for the termination, and shall inform Tenant of his or her right for a grievance hearing pursuant to the procedures outlined in the Tenant's Handbook and House Rules. Notice shall inform the Tenant of the right to request such a hearing within ten (10) working days of receiving the original notice of intent to terminate the Lease. Notwithstanding the foregoing, the Tenant shall have no right to request a hearing in cases involving a termination of tenancy for an activity including but not limited to criminal activity on or off the Premises by Tenant, any members of the Tenant's household or guests or other persons under the Tenant's control that threatens the health, safety or right of a peaceful enjoyment of the project premises by other Tenants or employees of Management. Upon expiration of the applicable notice period, as provided above, and upon Tenant's failure to request a hearing, then the Owner may give notice to vacate or quit which shall provide that: 1. In the case of failure of the Tenant to satisfy any rent reserved and due, the notice shall specify the Tenant shall remove within ten (10) days from the date of service of the notice; and 2. In case of breach of any of the conditions of the Lease, except for payment of rent, the notice shall specify that Tenant shall remove 6 within fifteen (15) days from the date of service thereof. 14. GRIEVANCE PROCEDURE; All disputes concerning the obligations of the Tenant or Management under this Lease shall be processed and resolved pursuant to the grievance procedure as outlined in the Tenant Handbook and House Rules. 15. WAIVER. By failure to exercise any available right or remedy as is provided herein, Owner shall not waive the right to do so at a later date for similar or other causes. 16. MODIFICATIONS. Any modifications to this Lease shall be accomplished by a written rider to the Lease executed by Owner and Tenant. 17. COMPLIANCE. This Lease agreement complies with all federal, state, and local laws. ATTACHMENT: TENANT HANDBOOK AND HOUSE RULES OF ENOLA COMMONS SENIOR APARTMENTS IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. WITNESS ENOLA SENIOR HOUSING, L.P. By: REDEVELOPMENT AUTHORITY OF THE COUNTY OF CUMBERLAND, MANAGING AGENT TENANT 7 Eno la Commons Senior Apartments 16 S. Eno la Dr., Eno la, PA 17025 P 71 7-732-281 1 F 717-732-2878 enolacommons@pa.net August 1, 2013 Anne Edwards 16 S. Eno la Drive, #220 Eno la, PA 17025 Dear Anne: Enclosed is an invoice for charges to repair the front entrance door. The cause of the door malfunction came from your disconnecting the wires in your door control panel, inside your apartment. Your tampering with the panel system caused a great inconvenience for residents and guests to get in the building over the July 4th weekend. Therefore, you will be held responsible for all charges incurred. Please make check payable to Eno la Commons Apartments. Payment is due in 30 days. Sincerely, Si1ith Resident Manger Enclosure Enola Senior Housing, Limited Partnership, Owner S&A Homes, General Partner Redevelopment Authority of Cumberland County, Managing Agent Enola Commons Senior Apartments Affordable, Independent Living for the Elderly 16 S. Enola Dr. Enola, PA 17025 Phone 717 - 732 -2811 Fax 717 - 732 -2878 Bill To: For: Anne Edwards 16 S. Enola Drive, #220 Enola, PA 17025 Repair to front entrance Door INVOICE INVOICE # 221 DATE: 8/1/13 DESCRIPTION AMOUNT Maintenance Staff Labor — 4 hrs. @ $30 /hr. $ 120.00 Hilton's Lock Service 360.00 Herschocks 151.00 (Balance due to Landlord) TOTAL $ 631.00 Make all checks payable to Enola Commons Apartments. Amounts are due upon receipt. Failure to pay in 30 days from date of invoice will result in all amounts owed being turned over to a credit bureau for collection. Failure to pay will reflect on your credit report. If you have any questions concerning this invoice, contact Judy Smith (717)732 -2811 THANK YOU! OPPORTUNITY Enola Commons Senior Apartments 16 S. Enola Dr., Enola, PA 17025 P 717-732-2811 F 717-732-2878 enolacommons@pa.net October 24, 2013 Anne Edwards 16 S. Enola Drive, #220 Enola, PA 17025 Dear Ms. Edwards: EXHIBIT 1 C This letter is to notify you of management's decision to terminate your lease and not renew your lease for another year. Your current lease expires on November 30, 2013. Our decision to not renew your lease is based on non-payment of charges billed to you on August 1, 2013, in the amount of $631 and your failure to enter into a repayment agreement. You have the right to request a grievance hearing to appeal this decision. We must receive your written request for an appeal by 8:00 a.m. on Monday, November 4, 2013 at the above address. You may fax your appeal letter to us at our fax number 732-2878; however, you must call and confirm that we have received your fax. If you do not request a hearing on this matter, or if after the review, the decision to terminate your lease remains the same, then you will be provided with an eviction notice from our attorney setting forth the date upon which you are to vacate your apartment. If you have any questions, please contact our office at 732-2811. Sincerely, C \\&44Af jg1y ith Resident Manager Cc: Tricia Naylor Atty. Bette Newcomer- CCHRA Kathy Laser - CCHRA cu1OtgherlC f C4 11 r, HOUSING AND reDEVELOPM ENT UTHORITIE Enola Senior Housing, Limited Partnership, Owner S&A Homes, General Partner Redevelopment Authority of Cumberland County, Managing Agent C U M u E R L A N D C O U N T Y HOUSING AND reDEVELOPMENT U T H O R I T I E December 27, 2013 Anne Edwards 16 S. Enola Drive Apartment 220 Enola, Pennsylvania 17025 Re: informal Hearing Dear Ms. Edwards: Daniel J. Ellis Hearing Officer On December 27, 2013, an informal hearing was held at your request to appeal the Enola Commons Senior Apartment's October 24, 2013 decision to terminate and not renew your lease. Attorney Darrell Dethlefs represented you at the hearing. The Enola Commons Senior Apartments is managed by the Cumberland County Housing and Redevelopment Authority (CCHRA). The CCHRA's decision was a result of an incident that occurred on or about July 5, 2013 where it was alleged you tampered with the intercom inside your apartment that disabled the front door locking mechanism to the apartment building. The cost to trace the source of the malfunction, repair your intercom, and enable the locking mechanism was $631.00. On August 31, 2013, the CCHRA notified you of your financial obligation to reimburse them for the $631.00 pursuant to your lease. The CCHRA's action is based on your failure to pay the $631.00. The Enola Senior Apartments Residential Dwelling Lease dated December 9, 2004, Paragraph 4 reads: PAYMENTS DUE UNDER THE LEASE D. Maintenance and Repairs. A schedule of charges to Tenants for maintenance and repair beyond normal wear and tear shall be posted in the Management Office at Enola Commons Senior Apartment's. Charges shall be due and payable the first day of the second month following the month in which the charges occurred. After all hearing testimony and documents submitted in this matter, it is my ruling to uphold the CCHRA's decision to terminate and not renew your lease. Ms. Judy Smith testified on behalf of the CCHRA /Enola Commons Senior Apartments. She proved beyond a reasonable certainty that you engaged in a material breach of your lease when you tampered with your intercom system that resulting in the locking mechanism to the front door being disabled, and are responsible for the money being sought in the amount of $631.00. The tampering was beyond normal wear and 1 tear. Witnesses John Hostler (CCHRA Maintenance) and Perry Yingling (Hflton's Lock and Security) also testified on behalf of the CCHRA/Eno|a Commons Senior Apartments. Thelr testimony was found to be credible and consistent with their written statements. Mr. Yingling traced the source of the issue to your apartment. Mr. Hostier testified that you admitted to disabling your intercom because you "Didn't want to be bothered by people buzzing you at the front entrance." Attorney Dethlefs testified that you had no intent to damage the intercom and or locking mechanism to the frorit door when you disabled your intercom. vou further -admitted to disabling your 1ntercom Attorney Dethlefs contested the amount of the damages the CCHRA was seeking from you. He specifically contested the $151.00 from Hershocks, Inc. However, additional documentation was obtained from Hershocks, Inc. that supports their invoice to the CCHRA/Enola Commons Senior Apartments in the amount of $151.00. This objection is overruled and the amount of your flnanclai responsibility as previously stated stands at $631.00. I also took into consideration your limited Income prior to making this ruling. The CCH Commons Senior Apartments offered to enter intoa repayment agreement with you. However, a repayment agreement was never pursued. Ms. Smith testified prior to the hearing that they have no desire to revisit this, negotiate a resolution, and requested that the hearing be held. Attorney Qetblefs spoke of between the Enoia Commons Senior Apartments and you. This was not the causation for them to terminate and not renew your lease. However, since Attorney Dethlefs and for the record, not Ms. Smith raised this issue, a review of your Tenant File reflects documented instances where you were the source of disturbances at this apartment building. The Residential Dwelling Lease, Paragraph 8, that you executed on December 9, 2004 further reads: OBLIGATIONS OF THE TENANT. Tenant shall comply with all the Tenant Ob as set forth in the Teriant's Handbook House Rules, which are incorporated herein by reference thereto. Tenant's failure to comply with Tenant's Handbook and House Rules shall be deemed a material breach of this Lease Agreement. Notwithstanding the foregoing and in addition thereto, the Tenant shail comply with the following: B. To conduct hlmself or herseif and cause other persons who are on the Premises with Tenant's consent, to conduct themselves in a manner which will not disturb Tenant's neighbors' peaceful e joyment of their accommodations. C. To refrain from, and to cause Tenant's household and guests to refrain from destroying, Defacing, damaging or removing any part of the Premises or Project. The tampering of your intercom that resulted in the front door locking mechanism resulted in an inconvenience to the other residents and further placed them in "Harm's Way" causing the building to be unsecure. Furthermore, you d |ress towards this hearing officer and witnesses, and repeated disruption of the hearing supports the allegations of the disturbanes that you have caused at the Enola Commons Senior Apartments. 2 I have notified the CCHRA/Enola Commons Senior Apartments of my ruling. Please contact Manager Judy Smith and or your attorney if you have any questions concerning my ruling. Sincerely, Daniet alb Daniel J. Ellis Administrative Hearing Officer 3 Enola Commons Senior Apartments 16 S. Enola Dr., Enola, PA 17025 P 717-732-2811 F 717-732-2878 enolacommons@pa.net Name of Landlord: Name of Tenants: Leased Premises: Date of NOTICE TO QUIT: To: Anne Edwards: NOTICE TO QUIT Enola Senior Housing, LP Anne Edwards 16 S. Enola Dr. #220 Enola, PA 17025 January 16, 2014 EXHIBIT You shall have 15 days from the date of your receipt of this letter to vacate the premises at 16 S. Enola Dr. #220, Enola, PA 17025. This eviction is based on your failure to vacate the premise by November 30, 2013 due to non-renewal of lease for violating the terms of your lease under Paragraph 4D, 8B and 8C. C414111414411 1J,COL1141'Y HOUSING AND: reDEVELOPMENT U T H O R [TIE Very truly yours, Judy mi Property Manager Enola Senior Housing, Limited Partnership, Owner S&A Homes, General Partner Redevelopment Authority of Cumberland County, Managing Agent Enola Commons Senior Apartments 16 S. Enola Dr., Enola, PA 17025 P 71 7-732-281 1 F 717-732-2878 enolacommons@pa.net AFFIDAVIT OF SERVICE I, the undersigned adult individual, having been duly sworn upon my oath state that I did serve a copy of the attached Notice To Quit upon Anne Edwards, the Tenant, by personally placing one copy of the Notice To Quit under the Tenant's door and posting one copy of the Notice To Quit on the Tenant's door at the Leased Premises, 16 S. Enola Drive #220, Enola, PA 17025 on , janacvy /Co , 2014 at 3:e5c5 p.m. Subscribed and sworn to before me the Undersigned Notary Public on day of 4LU y 20 Server Pit‘ co ONW OF PE VAN Notarial Seal Tricia D. Naylor, Notary Public Carlisle Bora, Cumberland County My Commission BmIres Oct. 2 2014 CUMUIRt AND COutITY HOUSING AND' reDEVELOPM ENT ,UTHOR Enola Senior Housing, Limited Partnership, Owner S&A Homes, General Partner Redevelopment Authority of Cumberland County, Managing Agent J , ' ,5-i ii p z , ,e4 ,/,--tie..../4e-/; .,77/-447,, SA', 79 / '?9 oca, e, a ,„.. -, J ,A)./ e-„ //4/ //x Aa;i7g/z4c) siz)z.e.-- „. , ,,,ia 1,--- O .. 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Bair, Housing Choice Voucher Director Cumberland County Housing Authority, 114 North Hanover Street, Carlisle, PA 1701 Dear Ms. Bair, The things you told me to mention to the hearing officer, Daniel J. Ellis, in the hearing today were heard there. My information was refused, with everyone else allowed to speak. As you may know, I am physically disabled, and this constant harassment including the buzzer on the night in question, prevents healing. It is important that my evidence, the public areas surveillance videos requested of manager Judy Smith on July 9, 2013 and denied by her, referenced in my appeal letter of November 4, 2013, and again requested in the telephone call to you before noon on evidence day, December 26, 2013, be allowed to exonerate me. They cover my apartment, front entry door, office, and maintenance areas. I told you this evidence was needed to proceed. You told me to tell this to the hearing officer, and also of the two police reports on residents th | ninQmme/onehitdnGnne>,mhichanea|soon surveillance video on July 18, and on August 14, 2013. Video also exists of residents refusing to let me and my wheelchair pass on the front porch. All this happened since July 5, 2013, and contribute to the lawlessness which surveillance cameras were installed to curtaii. It is also i about 4:00 am on J |y e front security door continued to operate correctly through Thursday and Friday morning. Only after I left my apartment Friday afternoon was there a problem of security door entry. Another resident confirmed this to me when i returned Friday evening and couldn't get in. The security door was not left unlocked — just the opposite. The door problem was identified July 9 as originating in the building's panel, and the problem was corrected there, without fixing anything in my apartment. I deny any responsibility for this main door problem. Indeed, john Hostler, maintenance, offered to leave my apartment wires disconnected, but f told him I was expecting a package. The wires were not touching anything when I left Friday afternoon. The only effect John's reconnecting my wires had was to again allow me to hear and buzz in visitors. My husband and I managed an oceanfront hotel, and I take pride in protecting Emda[ommons.Just before a superstorm asked Judy Smith to have porch furniture secured, as weather services advised. She told me no. When the exterior of my apartment was damaged in this storm, John Hostler saw me looking out the window. "It's your tricking fault," he said, even blaming me for acts of nature. Ms. Smith told me that if I looked her in the eye and told her I wasn't responsible, she would not pursue the matter. ididthis,apditintrue. Please rectify these injustices, and let me live in privacy and peace. Thank you. I promise to do my part, as always, and I am grateful. 1023, Camp Hill, 17001 `71' 649-1047 ,� x1 .� ��/�/� �7��/ )/p7 �i�,v�f^/ - —'~ ' / ~ ^� "�' c��~ �/�S��/ ~'.'/''' ��_-_�—___' _' /�l�y� " _" / _ _/ /�>v��c-`~�r7 _ 7 --' ' � �� / ^�''~"~-`~-" �.-.�" » /��'^�� '. .. /l '- �/my��. / = ' a- N r9 N Postage Certified Fee U.S. Postal Service TM CERTIFIED MAILTM RECEIPT (Domestic Mall Only; No Insurance Coverage Provided) For delivery information visit our web 1 0 ✓Retum Receipt Fee O (Endorsement Required) C3 Restricted Delivery (Endorsement Required) I ed) v) Total Postage & Fees ru ti m ra N Sent To Street, Apt. No.• or PO Box No ZIP PS Form 3800, August 2006 See Reverse for Instructions -,wr A evri- rX41 vta .rlyt/ 74. 6'd 0-N.V e J( CeA'114(2/6;11 r Ct j ous-byi Ain gos'l a Ps: / /?J 7 , 4,j2 r,4414/2/111.6 e d%'J f6i g �s a� /7)/ ,' ac 62v,* (Kw /74/ ) le at b,h si/7/0/) fax/ COMMONWEALTH OF PENNSYLVANIA Notarial Seal Elizabeth A. Kessler, Notary Public Lower Allen Twp., Cumberland County My Commission Expires June 7, 2015 ME BER, PENNSYL 141A jis TtON F NOTARIES CAMP HILL POST OFFICE CAMP HILL, Pennsylvania 170119998 4134870011 -0097 1/16/2014 (717)737 -1461 04:42: .1 b- T- Sales Receipt Sale Unit Qty Price 'oduct 'ascription RLISLE PA 17013 Zone -1 rst -Class Mail Letter .80 oz. xpected Delivery: Thu 04/17/14 .,aturn Rcpt (Green Card) .9 Certified :iPS Certified Mail #: .1132250000055718769 sue PVI: al: by: ige Due.: 'or tracking or inquiries go to com or call 1- 800 - 222 -1811. $1. = *- x xwx *t*xxwt *wwxaax *axx*x*xx*xxxaam IHTEN SOMEONE'S MAILBOX, Greeting • lable for purchase at select Post ces. tt x*wwxwtw *wtxxw* ****xxww *w***ww* t*t*ttt *wxxww** ***x**t * *xt *wt *x *wtt r stamps at usps.com /shop or cal 10- Stamp24. Go to usps.com /clickn: .'rint shipping labels with postage: !r information call 1- 800 - ASK -USP!' xt**** *xw**t * *xxwww*xxww**ttxx m ax* * ** *x * * *>t *w* ** *xwwawt **t*wtxtl your mail when and where you WE - a secure Post Office Box. Sign x online at usps.com /poboxes. wx1t *awxxx * *x **xxxwxwt*xtt *w ****I .'. *wx ** **x* ** * *w * *w** *xtww * *xt *Y.. #: 1000305530247 k: 08 11 sales final on stamps and pos. Refunds for guaranteed services f Thank you for your business '.* w ** ***xww ** *wx*x*axa** * *w **xxxxn t* twx *t * *w**w*xx*txxx *x *x****x* *x,. HELP US SERVE YOU BETTER to: https: / /postalexperience.com. TELL US ABOUT YOUR RECENT POSTAL EXPERIENCE YOUR OPINION COUNTS * wax xx* *wx * * * ** * *xx *xxx*** *t*tx **a*xx* Customer Copy lLE,O,O -FICE Of THE PROTHONOTARY 014 APR. 17 Pfl 2 1 CUMBERLAND COUNTY PENNSYLVANIA PRAECIPE FOR LISTING CASE FOR NON JURY TRIAL (Must be typewritten and submitted in triplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case for a TRIAL WITHOUT A JURY. CAPTION OF CASE lentire caption must be stated in fulli ENOLA SENIOR HOUSING, LP c/o Redevelopment Authority of the County of Cumberland 114 North Hanover Street Carlisle, PA 17013 (Plaintiff) vs. ANNE EDWARDS P.O. Box 1023 Camp Hill, PA 17001 (Defendant) vs. (check one) E] Civil Action — Law El Appeal from arbitration (other) No. 2014-1431 Indicate the attorney who will try case for the party who files this praecipe: Tricia D. Naylor, Esquire Civil Term co Indicate trial trial counsel for other parties if known: This case is ready for trial. Date: May 13, 2014 Signe Print Name: Attorney for: Plaintiff 9- 7,fd ex.4„.?„,, 1°# 3 0S-fe2.5 ENOLA SENIOR HOUSING, LP : IN THE COURT OF COMMON PLEAS C/O Redevelopment Authority of : CUMBERLAND COUNTY, PENNSYLVANIA County of Cumberland 114 North Hanover Street Carlisle, PA 17013 PLAINTIFF x'030 V. cnr— ANNE EDWARDS, DEFENDANT : 14-1431 CIVIL za -4 ORDER OF COURT AND NOW, this �,`''`•ay of May, 2014, the non jury trial in the above referenced case has been assigned to this Court. Prior to setting an actual trial date, IT IS HEREBY ORDERED AND DIRECTED that the parties in this case file a pre-trial memorandum with the Court on or before July 1, 2014, in the following format: I. A concise statement of factual issues to be decided at trial. II. A list of witnesses the party intends to call at trial along with a concise statement of their anticipated testimony. III. A list of all exhibits each party anticipates presenting at trial. IV. A statement of any legal issues each party anticipates being raised at trial along with copies of any cases which may be relevant to resolution of the stated issue. 4 411. case. V. An estimate of the anticipated time needed for the party to present its Upon receipt and review of these memorandums, the Court will set a trial date for this case. Tricia D. Naylor, Esquire Attorney for Plaintiff ne Edwards Defendant P. 0. Box 1023 Camp Hill, PA 17001 Court Administrator -5 bas ecr ;is Pla4LL S a.3/1 y By the Court, ENOLA SENIOR HOUSING, LP : IN THE COURT OF COMMON PLEAS C/O Redevelopment Authority of : CUMBERLAND COUNTY, PENNSYLVANIA County of Cumberland 114 North Hanover Street Carlisle, PA 17013 PLAINTIFF V. ANNE EDWARDS, DEFENDANT : 14-1431 CIVIL ORDER OF COURT AND NOW, this 2"d day of July, 2014, the non -jury trial in the above captioned case will be held on Friday, October 3, 2014, at 10:00 a.m. in Courtroom No. 2 of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, M. L. Ebert, Jr., ✓ Tricia D. Naylor, Esquire Attorney for Plaintiff c--) nne Edwards cc �rn Defendant cn P. O. Box 1023 -<>. Camp Hill, PA 17001 <ELJ ^ 4 pp t5 - z c Court Administrator M '`Ti as b Q - sx-C.7/h/ig.,--rn Cr) C) ENOLA SENIOR HOUSING, LP : IN THE COURT OF COMMON PLEAS C/O Redevelopment Authority of : CUMBERLAND COUNTY, PENNSYLVANIA County of Cumberland - Na 114 North Hanover Street -Q a ... Carlisle, PA 17013 z W 1,:== PLAINTIFF moi' r -• 1---- VV. . >,--) - 70. Si ANNE EDWARDS, :.) DEFENDANT : 14-1431 CIVIL r ORDER OF COURT AND NOW, this 9th day of July, 2014, due to a conflict with this Court's schedule, the non -jury trial in the above captioned case will be now be held on Friday, October 17, 2014, at 9:30 a.m. in Courtroom No. 2 of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, M. L. Ebert, Jr., Tricia D. Naylor, Esquire Attorney for Plaintiff Anne Edwards Defendant P. O. Box 1023 Camp Hill, PA 17001 /Doug Lovelace, Esquire Court Administrator 1)A S bas / /0//if CD: .a� l e/7/ c7;,, � /l�JQ'� .Q� - / ��©w f74 ,re, �4i�j/2 60/2?ge,12.0//Aom/ e_6y///f/e/, /e/.-) tt: 6axw-yot -2 real k/ id t 4)am 4 rec_6;S 4?7,acri_ ;_iolowy.X6p /2-e/ t‘o cow //0/ /19, 9J/ems 4,r*/ 7Ke_-Ce2iS'-e 7firori2 /9471 /755_,c,,, ael Ceinsi/v/is, /62 7i/psi Q4n kaki zf((Q %' /9ss cieow A 4 a4e,r, i y, ,s9 /4 7 - "e--cCe ee/d 1( 4ois Qw e- ,6 e/ ,S' e4'3‘ c16:jif fitc_4a& �� dualeg 6i efes _7- 4Riel ce, 7(4' ,fi'etwe irreetwcs2 tv-pree-s4 at/77-&,/yez- &.e de/72, fig-e/S,& /V Ar# Z 4/ 4-W/e-d a/70/ agf /re4fer/AiX e /17e_coic4.7. hve qA 6.e0/2 wed „ic Afe_ s o'eQf Q7. -6 _ -144/7-e-- gdoGfd/', /,i _77 TZC�1j ' �� 7 r': '9 / �`” 4,414 COMMONWEALTH F PENNSYLVANIA NOTARIAL SEAL Alexa A. Sheely, Notary Public Hampden Twp., Cumberland County My Commission Expires May 13, 2018 EMBER, PENNSYLY TION OF NO1RRIES "axcie, cis 74//7 ,z7/-,.; £ a7d79---2 ov pi(i7(,re,(3 iv 6-0,eia u7. 7)itc,?, -2 c-) ,---.) ,.., ,- --- -- , - (-7. ,---- / a 0, / V /A/A/ /h7 = r_ j27/ E e 2 i y.a---/ -.‹ --c, :=•.-- __;__ °?I(' -->'-Al'IP ---- , 3 e / 2 bil'1297, 7 / / 4i '-d-'3 1/ C,/ S's Ey 27 L,/' L/7' # a‘ (1Ph yo • /' , 4// 01 / -1, / / ys 1)47.3--d,./712p - r/ p-)''/4`/,( i F, , '(--/i/.50 ,./o 7 cls- r / i w ir e / # afr 4/ /o-, c./ - 7 P.:"Pc:2 1 <&. 44',, d / 1/7' 00 Yo/ , , ' / . '1‘,5 I tr.?,C77c --;7/CPY /1/ o?' / / Pf Zat/P rzazt I/ 2/1//v L-15 `-/ ?z a (1 -Pe N (7 e/i/ 7/ 12/'/`/Y(1/V j9 ' ' 4,-.I'/4, il / ir, / f , , 7k/51V7 f C/7 L/67/ .I7V o,/ //hal xsp/c2 (/al // po /7-7?)--esvpo,iz(,/, ,/,0. (,/,/ov /0 577/4-0 /2 -A., -u 7- g:p, 4,-/c_4/07 X X ft/y1 ,01.7 n --2 5,-.2 Sar") 3 vd / c imor(,brifropav -7,-i,o4iv v'Y //E/ 1/2/ /,//4P ENOLA SENIOR HOUSING, LP : IN THE COURT OF COMMON PLEAS 0/0 Redevelopment Authority of : CUMBERLAND COUNTY, PENNSYLVANIA County of Cumberland 114 North Hanover Street Carlisle, PA 17013 PLAINTIFF V. ANNE EDWARDS, DEFENDANT : 14-1431 CIVIL ORDER OF COURT AND NOW, this 7th day of October, 2014, upon consideration of the Defendant's Pro Se Motion for Continuance in which she states that she is disabled and is requesting reasonable accommodations; IT IS HEREBY ORDERED AND DIRECTED that the Court Administrator shall contact the Defendant to determine what the Defendant's disabilities are and what accommodation is required. Tricia D. Naylor, Esquire Attorney for Plaintiff r/1 Edwards, Pro Se Defendant P. 0. Box 1023 Camp Hill, PA 17001 Court Administrator ---V`\ yN\ e•opl'Es I ieVIV/V --/Y By the Court, bas ENOLA SENIOR HOUSING, LP : IN THE COURT OF COMMON PLEAS C/O Redevelopment Authority of : CUMBERLAND COUNTY, PENNSYLVANIA County of Cumberland 114 North Hanover Street Carlisle, PA 17013 PLAINTIFF f-ri CO c") V. ANNE EDWARDS, DEFENDANT : 14-1431 CIVIL ORDER OF COURT AND NOW, this 6th day of October, 2014, upon consideration of the Motion for Continuance filed by the Defendant, the non -jury trial in the above captioned case will be now be held on Thursday, November 20, 2014, at 8:30 a.m. in Courtroom No. 6 of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, Tricia D. Naylor, Esquire Attorney for Plaintiff ne Edwards, Pro Se Defendant P. 0. Box 1023 Camp Hill, PA 17001 Court Administrator ,P1111(4 bas Ne_04.1g;47. ea 'ES ao*Lc...L Return of Service: (Reverse side of Subpoena) On the A day of (4W.trig with the fore(name of person served) going subpoena by: (De8cribe method of service) ig de/1 11723i a EE r'N) 7),Afild I' 6 cl 07n 7 44 ei€,<, AR/ I verify that the statements in this return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to authorities. 12/ /Am .)2-1/ a 4- • cA,7i•Id-fla,fig k),74 Date: a • (signatufe) incd/ KLd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff e-ing C34Y,/i/7 , a/-3 .0f /'20-/Z) 71/.,n-24, Z--%,7611/(1:- 5X D ,,;2 3 (47/72/' /// /00/ Defendant )// /J7/ / / (Narne(s) of Witness(es)) Number CivilActioh: Appeal From MJ ( SUBPOENA TO ATTEND AND TESTIFY To L 1. You are ordered by the Court to come (:7//74: (.7 (Specify courtroom or other place) atZ , Pennsylvria, on e /_4,/ at „V 3 0 a o' clock, ) • 7e)/411 to Ce777-2 419077 • ., to test .on behalf • in the above case, and to ,temain until excused. d bring with you the following: 27.- ef / 5z,k --e:mn7-e7/7-e / s-s2/2/e),n. "7347/97/770;27,43-- 7.40/22 /7, /6: /-7 _? 2d/ 7 /74- c7// /-iw/;/7- 7 //w2e7e, gry 6,'•/711/g/i-vs- c/ >1 /2/7g7/ /1 /4 4PI_IP /,,2 /5-() / /764r/ 1.) 1•21/77 )'j/2 X721J7 C Vi I 11‘,1---/1(2d 77.7 fra 4// aqd o'kvi 1//d 62 -ridS ) 2,4/2 5,7,27.());9/-1r 60,7,9A7 If you fail to attend or to produce the documents or things required by this subpoena, you may be subject to the sanctions authorized by Rule 234.5 of the Pennsylvania Rules of Civil Procedure, including but not limited to costs, attorney fees and imprisonment. Requested by: / 0fboie__ 6,1.40: -tit-2777 a./4 e/1,9 )igilPef. 4 / 45/ (Attorney's name, address, telephone number and identification number) n'%442--- 11/7/1 /7 /Doi, -c3 BY THE COURT, '-`?-/rnd° /) %"/ 157 4W Date: By Seal of the Court (Name of Prothonotary) N. ENOLA SENIOR HOUSING, LP : IN THE COURT OF COMMON PLEAS C/O Redevelopment Authority of : CUMBERLAND COUNTY, PENNSYLVANIA County of Cumberland 114 North Hanover Street Carlisle, PA 17013 PLAINTIFF ,.T c X v. --<' CM _ ANNE EDWARDS, _nrs ',' DEFENDANT : 14-1431 CIVIL >c c). t -r ORDER OF COURT AND NOW, this 4th day of December, 2014, upon consideration Plaintiff's Complaint, Defendant's Answer and a hearing on the matter, IT IS HEREBY ORDERED AND DIRECTED that: 1. Judgment in the amount of $2,841.71 is entered against Defendant and in favor of Plaintiff for February 2014 rent, damages, costs and attorney fees through November 20, 2014. 2. Judgment in ejectment is entered against Defendant and in favor of Plaintiff and possession of the premises known as 16 South Enola Drive, #220, Enola, Pennsylvania 17025 is hereby granted to Plaintiff. 3. The Prothonotary is directed to distribute the monthly rental deposits paid by the Defendant to the Prothonotary in the amount of $1,776.00 for the months of March 2014 through November 2014 to the Plaintiff. By the Court, Tricia D. Naylor, Esquire Attorney for Plaintiff Anne Edwards, Pro Se Defendant P. O. Box 1023 Camp Hill, PA 17001 bas ENOLA SENIOR HOUSING, LP : c/o Redevelopment Authority of the : County of Cumberland 114 N. Hanover Street Carlisle, PA 17013 Plaintiff v. ANNE EDWARDS P.O. Box 1023 Camp Hill, PA 17001 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2014-1431 EJECTMENT CIVIL ACTION PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: CIVIL TERM r. Please enter judgment pursuant to the Order of Court issued by The Honorable M. L. Ebert, Jr., a copy of which is attached hereto as Exhibit "A" in favor of Plaintiff and against Defendant. 11 -1 I hereby certify that a copy of the Notice of Praecipe for Final Judgment has been mailed to each other party who has appeared in the action and the name and address of the proper person to receive this notice is: Anne Edwards P.O. Box 1023 Camp Hill, PA 17001 Date: December 22, 2014 $4,c6 Ip84 eAt c/t.7�9 3445- /v(o 1 1a Respectfully submitted, RIC SCHERER LLC Tri t is D. Nay I.D. No. 83760 Baric Scherer LLC 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff 4f6.so pi Atli C#-a178o pi&-sr9847 ENOLA SENIOR HOUSING, LP : IN THE COURT OF COMMON PLEAS C/O Redevelopment Authority of : CUMBERLAND COUNTY, PENNSYLVANIA County of Cumberland C -i F.._.a 114 North Hanover Street_,. Carlisle, PA 17013 rri �i:l`�l f'�'1 PLAINTIFF c� CF3 V. y � ANNE EDWARDS, > DEFENDANT . : 14-1431 CIVIL ORDER OF COURT AND NOW, this 4th day of December, 2014, upon consideration Plaintiff's Complaint, Defendant's Answer and a hearing on the matter, IT IS HEREBY ORDERED AND DIRECTED that: 1. Judgment in the amount of $2,841.71 is entered against Defendant and in favor of Plaintiff for February 2014 rent, damages, costs and attorney fees through November 20, 2014. 2. Judgment in ejectment is entered against Defendant and in favor of Plaintiff and possession of the premises known as 16 South Enola Drive, #220, Enola, Pennsylvania 17025 is hereby granted to Plaintiff. 3. The Prothonotary is directed to distribute the monthly rental deposits paid by the Defendant to the Prothonotary in the amount of $1,776.00 for the months of March 2014 through November 2014 to the Plaintiff. By the Court, Exhibit "A" rl -- �;�r: C7' Tricia D. Naylor, Esquire Attorney for Plaintiff Anne Edwards, Pro Se Defendant P. 0. Box 1023 Camp Hill, PA 17001 bas ENOLA SENIOR HOUSING, LP : c/o Redevelopment Authority of the : County of Cumberland 114 N. Hanover Street Carlisle, PA 17013 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2014-1431 CIVIL TERM ANNE EDWARDS EJECTMENT P.O. Box 1023 Camp Hill, PA 17001 CIVIL ACTION Defendant NOTICE OF PRAECIPE FOR FINAL JUDGMENT To: Anne Edwards P.O. Box 1023 Camp Hill, PA 17001 Notice is hereby given to you of entry of a judgment against you in the above matter, pursuant to the Order of Court issued by The Honorable M. L. Ebert, Jr., a copy of which is attached hereto as Exhibit "A." Prothonotary Date: 0,,te-cAvte-C�y ENOLA SENIOR HOUSING, LP : IN THE COURT OF COMMON PLEAS C/O Redevelopment Authority of : CUMBERLAND COUNTY, PENNSYLVANIA i ) F...,J County of Cumberland 114 North Hanover Street ' �' Carlisle, PA 17013 rrr ca rn c PLAINTIFF z c'' -< �> it ANNE EDWARDS, : E---) DEFENDANT : 14-1431 CIVIL • .-, V. ORDER OF COURT AND NOW, this 4th day of December, 2014, upon consideration Plaintiff's Complaint, Defendant's Answer and a hearing on the matter, IT IS HEREBY ORDERED AND DIRECTED that: 1. Judgment in the amount of $2,841.71 is entered against Defendant and in favor of Plaintiff for February 2014 rent, damages, costs and attorney fees through November 20, 2014. 2. Judgment in ejectment is entered against Defendant and in favor of Plaintiff. and possession of the premises known as 16 South Enola Drive, #220, Enola, Pennsylvania 17025 is hereby granted to Plaintiff. 3. The Prothonotary is directed to distribute the monthly rental deposits paid by the Defendant to the Prothonotary in the amount of $1,776.00 for the months of March 2014 through November 2014 to the Plaintiff. By the Court, Exhibit "A" Tricia D. Naylor, Esquire Attorney for Plaintiff Anne Edwards, Pro Se Defendant P. 0. Box 1023 Camp Hill, PA 17001 bas ENOLA SENIOR HOUSING, LP : c/o Redevelopment Authority of the : County of Cumberland 114 N. Hanover Street Carlisle, PA 17013 Plaintiff v. ANNE EDWARDS P.O. Box 1023 Camp Hill, PA 17001 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2014-1431 CIVIL TERM EJECTMENT CIVIL ACTION PRAECIPE FOR WRIT OF POSSESSION rn cc? r- C) 4.7 TO THE PROTHONOTARY: Please issue a Writ of Possession for the premises located at 16 South Enola Drive, # 220, Enola, Cumberland County, PA in the above -captioned matter. Respectfully submitted, RIC SCHERER LLC Date: December 23, 2014 428• Pad P6' ►6 - So / 14,--/ of °j Poo eS/o° �ssoe � Tris D. Naylo I.D. # 83760 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Plaintiff I of 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Enola Senior Housing, LP c/o Redevelopment` Authority of the County of Cumberland VS. Anne Edwards P. O. Box 1023 Camp Hill, PA 17001 No. 2014-1431 Civil Term Costs Attorney's $ $91.25 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)) Enola Senior Housing, LP c/o Redevelopment Authority of the County of Cumberland being: (Premises as follows): 16 South Enola Drive, #220, Enola, PA (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. D. vid D. Buell, Prot r. onotary, Common Pleas Cou of Cumberland County, PA Date 12/23/2014 (Seal) _. 2 of 2 No 2014-1431 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Enola Senior Housing, LP c/o Redevelopment Authority of the County of Cumberland VS. Anne Edwards P. 0. Box 1023 Camp Hill, PA 17001 WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 91.25 Plff (s) $ Prothy $ 2.25 Sheriff $ Plaintiff (s) attorney name and address: Tricia D. Naylor, Esq. 19 West South Street Carlisle, PA 17013 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the 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 ele.C4e/71" /64,.s-; ' q,,0/ /'.PSP v.e. fp eareV2,57/A/ ,77/0pu cc)/Z7Gdetc 7 9D// .)//k/ e/// /9t'c2e 6'//43-mdle/ /911E/ Ctiele/V 1/// 4 y4 �.� A,� fl 'lsn/ se/9/ kla&7(Id s��S/ 3 ?7°/ 4../ //wO7_3 ; /1/0 ,e_/ - , 7 . 1 .e/- ( 0 i e:, 0 /9 ; 4 ? v -i, / ��Jot' a, (//_) J ,2 047,/, ,i ci;„), ) 4,0,7,6,, A, ). / „,,,,, Eitt/,LL, ii -„,/f 2 57,,„„, r', rkr //q//j p.07 ' 9 ' 74‘,. civ/e vc i ,c /1/414qj hep is cws .7177 Q,s/7) ifiq/ Q, d d/ M' p /ie o/eoy 7 . c�cr fe of l.e �, rJ )_e, /v'7 07Ji/ ' - /yi9/74 P,/' ,2,~7.1' 4I Pe,77S dm A-267/7(2. 4 ZO/t( vd'.//7-4,a .2,0A1-7/ . �l e2 `57-12/WIS 617) ) 0a0 /4Z G% J/1G%'//', cZo /S 9/'e- i 7� *1)9/s o /.(%'c 0 �/- Vii° 720/) 76-'07)/72a e --7/i)6//,2 /4'Ces' eire- 714 9 dy,� 62,7 c3 /op7._. / - 2 9 0/i/ f i%/% /4 /7 x zeil z,04r-P/M t="1... Plitifiv*P! A . Af-gt- //PA d/I eil% '``.(/74/'7' 1 CUMBERLAND COUNTY HOUSING AND reDEVELOPMENT UTHORITIE December 1, 2014 To All Applicants and Tenants of Public Housing & Section 8 Rental Assistance (Voucher) foesw), �� Aca/72n7c/.1,4',72,,, The Cumberland County Housing Authority (CCHA) does not discriminate against applicants on the basis of their race, creed, color, religion, sex, national origin, marital or familial status, disability, age, receipt of public assistance or sexual preference. Under applicable law, the CCHA provides "reasonable accommodation" to applicants and tenants if they or any household member(s) have a disability and if the reasonable accommodation is necessary to provide an equal opportunity to use and enjoy the housing. A reasonable accommodation' is a change, exception, or adjustment the CCHA can make to its rules, policies, procedures, or services that will assist an otherwise eligible applicant or tenant with a disability to take advantage of the CCHA's programs, provided that the change does not pose an undue financial and administrative burden to the CCHA or require a fundamental change in its program. A reasonable accommodation may also include providing an appropriate auxiliary aid to an applicant with a disability where such assistance is necessary to enable effective communication with the applicant. Examples of reasonable accommodation may include the CCHA: �� • Installing flashing Tight smoke detectors in an apartment for a household with a hearing-impaired member; • Making a reader available to a vision -impaired applicant during an interview; Allowing an assistance animal; Making a sign language interpreter available to a hearing-impaired applicant during an interview; Extra assistance in finding a unit for Housing Choice Voucher holders or an extension of a voucher expiration date. 90 - An applicant household that has a member with a disability must still be able to meet essential obligations of tenancy—they must be able to pay rent, to care for their apartment, to report required information to the housing authority, to avoid disturbing their neighbors, etc. This requirement takes into consideration whether any requested reasonable accommodation would permit the applicant to be considered eligible for CCHA's housing or programs. If you or a member of your household have a disability and think you might need a reasonable accommodation, you may request it at any time in the application process or after admission. /(,,,/,e//4/—/23/ tea. -�z -.cZaN 1 A reasonable accommodation is different from a reasonable modification, which is a structural change made to existing premises, occupied or to be occupied by a person with a disability, in order to afford such person full enjoyment of the premises. However, like reasonable accommodations, there must be an identifiable relationship, or nexus, between the requested modification and the individual's disability. Housing providers that receive federal financial assistance are obligated to make and pay for structural changes to facilities, if needed as a reasonable accommodation for applicants and tenants with disabilities, unless doing so poses an undue financial and administrative burden under Section 504 of the Rehabilitation Act of 1973.29 U.S.C. § 794. better places, better lives 114 N. Hanover St. • Carlisle PA 17013-2445 • www.cchra.com CUMBERLAND COUNTY HOUSING AUTHORITY P 717-249-1315 or 1-866-683-5907 F 717-249-5988 07') You may obtain a Request for a Reasonable Accommodation form by calling or visiting one of the CCHA offices: Public Housing Applicants and Tenants may contact: Public Housing Office 60 W. Penn St. Carlisle, PA 17013 Phone: 717-245-0516 Section 8 Rental Assistance (Voucher) Applicants and Tenants may contact: Cumberland County Housing Authority 114 N. Hanover St. Carlisle, PA 17013 Phone: 717-249-11315 or 1-866-683-5907. If you have any questions or problems on reasonable accommodation or if you require help in filling out the form or need to submit your request in some other way, you should contact either office listed above. better places, better lives 114 N. Hanover St. • Carlisle PA 17013-2445 • www.cchra.com CUMBERLAND COUNTY HOUSING AUTHORITY P 717-249-1315 or 1-866-683-5907 F 717-249-5988 tt '/ 7,72 de. iC9-7/27/112/S .//) /p/d3/7 '917 67/ filOrtezi///2 95- &-oe/7 /7./Aem,kri "z. ‘y) , . Q /2 a C4 i/w/7s-cry/o/4/',, /7 .4fr/mqi1V-r cY171 (.14 /.; 77( 4 ikec_C 0 /7 Cowl tote& lgan L9N/ 01( ArNe• oefi, peta7) i//o /19th1QC/a k. &Lc' pPoGidop2, pil //Y,copoi a,) (7710 -/d /.4cZad, //7 , 2o / A M/// "9 /76a/ Orie f/g CUMBERLAND COUNTY HOUSING AND reDEVELOPMENT UT H OR IT | E ^~1 �. '� � dt.' eil% 4:2 /^_" �; �/ � ~ - " reg,e,Mf, December 112014 To All Applicants and Tenants of Public Housing & Section 8 Rental Assistance(Voucher) � °4' Cv��Y4'�y/� The Cumberland County Housing Authority (CCHA) does not discriminate against applicants on the basis of their race, creed, color, religion, sex, national origin, marital or familial status, disability, age, receipt of public assistance or sexual preference. Under applicable law, the CCHA provides "reasonable accommodation" to applicants and tenants if they or any household member(s) have a disability and if the reasonable accommodation is necessary to provide an equal opportunity to use and enjoythehousinQ. A reasonable nz ba change, exceptkxn or adjustment the CCHA can make to its rules, policies, procedures, or services that will assist an otherwise eliible applicant or tenant with a disability to take advantage of the CCHA's programs, provided that the change does not pose an undue financial and administrative burden to the CCHA or require a fundamental change in its program. A reasonable accommodation may also include providing an appropriate auxiliary aid to an applicant with a disability where such assistance is necessary to enable effective communication with the applicant. '~ Examples of reasonable accommodation may include the CCHA: - - Y/ w Installing flashing light smoke detectors in an apartment for a household with a hearing-impaired member; Making a reader available to a vision -impaired applicant during an interview Allowing an assistance animal; Making a sign language interpreter available to a hearing-impaired applicant during an interview; Extra assistance in finding a unit for Housing Choice Voucher holders or an extension of a voucher expiration date. An applicant household that has a member with a disability must still be able to meet essential obligations of tenancy—they must be able to pay rent, to care for their apartment, to report required information to the housing authority, to avoid disturbing their neighbors, etc. This requirement takes into consideration whether any requested reasonable accommodation would permit the applicant to be considered eligible for CCHA's housing or programs. If you or a member of your household have a disability and think you might need a reasonable accommodation, you may request it at any time in the application process or after admission. Cilf0~ 44/ ^4z / =Z0 1A reasonable accommodation is different from a reasonable modification, which is a structural change made to existing premises, occupied or to be occupied by a person with a disability, in order to afford such person full enjoyment of the premises. However, like reasonable accommodations, there must be an identifiable relationship, or nexus, between the requested modification and the individual's disability. Housing providers that receive federal financial assistance are obligated to make and pay for structural changes to facilities, if needed as a reasonable accommodation for applicants and tenants with disabilities, unless doing so poses an undue financial and administrative burden under Section 504 of the Rehabilitation Act of 1973. 29 U.S.C. 794. better places, better lives 1z4N.Hanover St. ^ Carlisle p^l7Uz3-2445^nww.ohra.cvm CUMBERLAND COUNTY HOUSING AUTHORITY P 717-249-1315 or 1-866-683-5907 F 717-249-5988 You may obtain a Request for a Reasonable Accommodation form by calling or visiting one of the CCHA offices: Public Housing Applicants and Tenants may contact: Public Housing Office 60 W. Penn St. Carlisle, PA 17013 Phone: 717-245'0516 Section 8 Rental Assistance (Voucher) Applicants and Tenants may contact: Cumberland County Housing Authority 114 N. Hanover St. Carlisle, PA 17013 Phone: 717-249-1315 or 1-866-683-5907. If you have any questions or problems on reasonable accommodation or if you require help in filling out the form or need to submit your request in some other way, you should contact either office listed above. better places, better lives ll4m.Hanover St. ^ Carlisle PAl7n13-2u45^wwwxzhrazom CUMBERLAND COUNTY HOUSING AUTHORITY P 717-249-1315 or 1-866-683-5907 F 717-249-5988 'uperior Court of Venngpfbania Joseph D. Seletyn, Esq. Prothonotary Jennifer Traxler, Esq. Deputy Prothonotary Buell, David D. Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Middle District December 31, 2014 RE: In Re: Anne. Edwards 2208 MDA 2014 Trial Court Docket No: 141431 Dear David D. Buell: Pennsylvania Judicial Center P.O. Box 62435 601 Commonwealth Avenue, Suite 1600 Harrisburg, PA 17106-2435 (717) 772-1294 www.pacourts.us/courts/superior-court Enclosed please find a copy of the docket for the above appeal that was recently filed in the Superior Court. Kindly review the information on this docket. Appellant's counsel is also being sent a Docketing Statement, pursuant to Pa.R.A.P. 3517, for completion and filing. Please note that Superior Court Dockets are available on the Internet at the Web site address printed at the top of this page. Thank you. Respectfully, Jennifer Traxler, Esq. Deputy Prothonotary /alv Enclosure 2:38 P.M. Appeal Docket Sheet Docket Number: 2208 MDA 2014 Page 1 of 2 December 31, 2014 In Re: Anne Edwards Initiating Document: Notice of Appeal Case Status: Active Case Processing Status: December 29, 2014 Journal Number: Case Category: Civil Superior Court of Pennsylvania Secure CAPTION CASE INFORMATION Awaiting Original Record Case Type(s): Civil Action Law CONSOLIDATED CASES RELATED CASES SCHEDULED EVENT Next Event Type: Receive Docketing Statement Next Event Due Date: January 14, 2015 Next Event Type: Original Record Received Next Event Due Date: February 27, 2015 COUNSEL INFORMATION Appellant Edwards, Anne Pro Se: Yes Appoint Counsel Status: Not Represented IFP Status: No Pro Se: Anne Edwards Address: Box 1023 Camp Hill, PA 17001 Receive Mail: Yes Receive EMail: No EMail Address: Fee Dt Fee Name 12/29/2014 Notice of Appeal FEE INFORMATION Fee Amt Receipt Dt 85.50 Receipt No Receipt Amt 0.00 AGENCY/TRIAL COURT INFORMATION Court Below: Cumberland County Court of Common Pleas County: Cumberland Division: Cumberland County Civil Division Order Appealed From: November 20, 2014 Judicial District: 09 Documents Received: December 31, 2014 Notice of Appeal Filed: December 29, 2014 Order Type: Order Entered OTN(s): Lower Ct Docket No(s):14-1431 Lower Ct Judge(s): Ebert, Merle L., Jr. Judge 2:38 P.M. 1 Appeal Docket Sheet Docket Number: 2208 MDA 2014 Page 2 of 2 December 31, 2014 Original Record Item Superior Court of Pennsylvania Secure ORIGINAL RECORD CONTENT Filed Date Content Description Date of Remand of Record: None Filed Date BRIEFING SCHEDULE None DOCKET ENTRY Docket Entry / Representing Participant Type Filed By December 29, 2014 Notice of Appeal Docketed Appellant Edwards, Anne December 31, 2014 Docketing Statement Exited (Civil) Superior Court of Pennsylvania ENOLA SENIOR HOUSING, LP : IN THE COURT OF COMMON PLEAS CIO Redevelopment Authority of : CUMBERLAND COUNTY, PENNSYLVANIA County of Cumberland 114 North Hanover Street Carlisle, PA 17013 PLAINTIFF V. ANNE EDWARDS, DEFENDANT : 14-1431 CIVIL CD IN RE: NOTICE OF APPEAL TO SUPERIOR COURT ORDER OF COURT AND NOW, this 9th day of January, 2015, the Court being in receipt of the Notice of Appeal in ,the above captioned matter, IT IS HEREBY ORDERED AND DIRECTED that: 1. Defendant file a concise statement of the errors complained of on appeal on or before January 30, 2015; 2. The Statement shall be filed of record; 3. The Statement shall be served on this Court pursuant to Pa.R.A.P., Rule 1925(b) (1); IT IS FURTHER ORDERED AND DIRECTED that any issue not properly included in the Statement shall be deemed waived. By the Court, Tricia D. Naylor, Esquire Attorney for Plaintiff _/‹-nne Edwards, Pro Se Defendant P. 0. Box 1023 Camp Hill, PA 17001 bas C cyr .E..s