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HomeMy WebLinkAbout14-4076COURT OF COMMON PLEAS Judicial District, County Of NOTICE OF APPEAL FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT COMMON PLEAS No. /9- 1/o76 a ji 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 Distric Judge on the date and in the case referenced below. NAME OF APPELLANT Ph vlSkel MAG. DIST. NO. 0-1 2 -01 - NAME OF MDJ s 5 cce re' cv 14 keg ADDRESS OF APPELLANT /6 /1/ 1.7 5 e- „gi- CITY STATE ZIP CODE c 45 DATE OF JUDGMENT G-76 -Zely N THE CASE OF (Plaintiff) ti.1-/7'c j'14 VS nda DOCKET No. -Pf 2o L '-L7-- 'eo 7/ This / This block will be signed ONLY when this notation is required u der •Pa. R.C.P.D.J. No. 1008B. This Notice of Appeal, when received by the Magisterial District Judge, will operate as a SUPERSEDEAS to the judgment for possession in this case. Signature of Prothonotary or Deputy SIGNATURE OF APPELLANT OR ATTORNEY OR AGENT If appellant was Clai ant (see Pa. R. C. P. D.J. No. 1001(6) in action before a Magisterial District Judge, A COMPLAINT MUST BE FILED within twenty (20) days after filing the NOTICE of APPEAL. 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 Distric Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon 6.4 (Common Pleas No. appellee(s), to file a complaint in this appeal Name of appellee(s) V 76 c ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. RULE: To (A.) m 64,..Avlq,v Name of appellee(s) , appellee(s) Signature of appellant or attorney or agent (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. Date: • , 20 V1NVA1ASNN3d AIN1103 ONV1D1391-1110 CS3 W I 1111' YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. CAW! CM(1, ]1-11 ,.!=1 74:4 Signature of Prothonotary or Deput AOPC 312-05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Mag. Dist. No: MDJ Name: Address: Telephone: MDJ-09-2-02 Honorable Jessica Brewbaker 18 North Hanover Street, Suite 106 Business Central Building Carlisle, PA 17013 717-240-6564 Paul Steel 161 N. East St. Apt #3 Carlisle, PA 17013 Disposition Details Grant possession. Grant possession if money judgment is not satisfied by the time of eviction. Disposition Summary (cc- Cross Complaint) Docket No MJ -09202 -LT -0000074-2014 Judgment Summary Participant - Paul Steel Walter Garman Plaintiff Wafter Garman Notice of Judgment/Transcript Residential Lease Walter Garman 3Rt.kars.jr (lc i2d. v. Paul Steel Co-/<s/e 17ar% Docket No: MJ -09202 -LT -0000074-2014 Case Filed: 6/2/2014 No Yes Defendant Disposition Paul Steel Judgment for Plaintiff Joint/Several Liability $0.00. $0.00 Individual Liability $1.,087.40 $0.00 Disposition Date 06/16/2014 Amount $1,087.40 $0.00 Judgment Finding (*Post Judgment) In the matter of Walter Garman vs. Paul Steel on MJ -09202 -LT -0000074-2014, on 6/16/2014 the judgment was awarded as follows: The amount of rent per month, as established by the •Magisterial District Judge, is $430.00 Judgment Component Filing Fees Rent in Arrears Joint/Several Liability $0.00 $0.00 Individual Liability $127.40 $960.00 Deposit Applied Grand Total: Portion of judgment for physical damages arising out of residential lease: Amount $127.40 $960.00 $1,087.40 $0.00 "� IN AN ACTION INVOLVING A RESIDENTIAL LEASE,NY P R Y 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 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. MDJS 315A Page 1 of 3 Printed: 06/16/2014 1:57:03PM IN THE COURT OF COMMON PLEAS 0401 hT e-kfie COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Lui Afr/T - 6-4/V Plaintiff vs. 4c,)\s Defendant No. /y-y67�� C) c _ rn PETITION TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: The Petition of � ( .S/�i7 respectfully represents: 1. I am the f' F 4f./ in the above matter and because of my financial condition am 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: II / (a) Name: Pc., Address: S S 14-- 4 P 3 Soc. Sec. No.: is- 202 (b) Employment --If you are presently employed, state � Employer: J �� 5111- f `g4''� 1 �,r y y 7� 4/ ‘err I's /( 4 /70 / 3 67 7/ i �/ Address. l / � 4 Salary or wages per month: t d V C 1-0 55 Type of work: 4 4 --If you are presently unemployed, state Date of last employment: Salary or wages per month: Type of work: (c) Other income within the past twelve months Business or profession: Other self-employment: Interest: Dividends: Pension and annuities: Social security benefits: Support payments: Disability payments: Workman's compensation: Public assistance: Other: (d) Other contributions to household support Spouse's Name: If your spouse is employed, state Employer: Salary or wages per month: Type of work: Contributions from child(ren): Contributions from parents: Other contributions: (e) Property owned Cash: Checking account: Savings account: Certificates of deposit: Real estate (including home Motor vehicle: Make: Cost: Stocks: Bonds: Other: (f) Debts and obligations Mortgage: Rent: Loans: Other: Electric Water Telephone Cable Credit cards Auto Insurance Gasoline Food ; Year: Amount owed: (g) Persons dependent upon you for support Spouse's Name: Child(ren), if any: Name(s) and age(s): Other persons: Name: Relationship: 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 unsworn falsification to authorities. Date IN THE COURT OF COMMON PLEAS OF bCr )4,,,c1 COUNTY, /1/ —1M76' chv:( Case Number:/y1J c992o2 - L ©evoo7Y Zo t PENNSYLVANIA wa=(4— ►�c Plaintiff vs Pic s+ee( Defendant t� 3 mca c.._ 2rT7 u,r — 1. I am the ,P `%/ 7 (Plaintiff/ Defendant) in the above matter and because of my financial condition am unable to pay the fees and cots :of n AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS prosecuting, defending, or appealing 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. (a) Name: Au I .Skt / Address: No NP iv/ • / ,vy ,!¢4ldc5s '5 J`vil o ff;`, Adele 4,?/11/ /C/ IVA�q 5? S-% Csd6J1e /70)3 Social Security Number: /5Y' 22 -71(C (b) If you are presently employed, state Employer: Address: Salary or wages per month: Type of work: If you are presently unemployed, state Date of last employment: - 7" Salary or wages per month: 6°0,4 v p /►, 19/1/A (vs 5 Type of work: L % e (e2. (c) Other income within the past twelve months Business or profession: Other self-employment: Interest: Dividends: Pension and annuities: Social Security benefits: Support payments: Disability payments: Unemployment compensation and supplemental benefits: Worker's compensation: Public Assistance: Other: (d) Other contributions to household support (Wife)(Husband) Name: If your (husband) (wife) is employed, state Employer: Other transportation expenses Car insurance Gas for car Child care Child support payments Medical bills Health insurance Fines or costs payments *2_5 per /2,20.4/7* Other Other Total Monthly Expenses $ g) Persons dependent upon me for support (Wife) (Husband) Name: Children, if any: Name Age Name Age Name Age Other persons: Name Relationship 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 Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. DATE Petitioner ACTION BY THE MAGESTERIAL JUDGE: Date: Magisterial District Judge COURTfF COMMON PLEAS Judicial District, County Of NOTICE OF APPEAL FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT COMMON PLEAS No. NOTICE OF APPEAL — 1/107 (iv, Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial Distric Judge on the date and in the case referenced below. NAME OF APPELLANT 4V/ Yke ADDRESS OF APPELLANT CITY I cir 45 /e NAME OF MDJ f-fw&keg STATE /01 7 ZIP CODE DATE OF JUDGMENT -!d5' N THE CASE OF (Plaintiff) u r'r o- rn44 K./ DOCKET No. j -of 2.92_ eate)&ao 7V- 2-.0/3/. vs ndanty GNAT RE OF APPELLANT OR ATTORNEY OR AGENT This block will be signed ONLY when this notation is required Older Pa. R.C.P.D.J. No. 10088. This Notice of Appeal, when received by the Magisterial District Judge, will operate as a SUPERSEDEAS to the judgment for possession in this case. Signature of Prothonotary or Deputy If appellant was Clai ant (see Pa. R.C.P.D.J. No. 1001(6) in action before a Magisterial District Judge, A COMPLAINT MUST BE FILED within twenty (20) days after filing the NOTICE of APPEAL. 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 Distric Judge, IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon (Common Pleas No, Name of appellee(s) appellee(s), to file a complaint in this appeal VO 76 c ov. f) within twenty (20) days after service of rule or suffer entry of judgment of non pros. RULE: To (A rrt.12 611* "44/ Name of appellee(s) , appellee(s) Signatureof appellant or attorney or agent (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. - - DatelAti, 20/V.7 V1N VA1 A SNN3d ONV1.1301411 11 Signature of Prothonotary or Deput C.C.; :6 WV flI lilf [Hai, YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-05 IN THE COURT OF COMMON PLEAS OF £,'i 4415 COUNTY, PENNSYLVANIA CIVIL ACTION --LAW w # /Tea- G-krfis Plaintiff : v. s/tel Defendant No. ORDER AND NOW, thisda 201 upon consideration of the Petition of y of � , � , P -e f Plaintiff to Proceed In Forma Pauperis, it is hereby ORDERED and DECREED that the Plaintiff, 641 1/14e-/ , may file the-/4`v6€,coi in forma pauperis oto the termination of proceedings without payment of filing fees or costs. - IV- l -/J cry ma<<s:41, 711?py -/12 ra cT s C._ CA �z. to _a ci r -R ,M U.S. Postal Service,. CERTIFIED MAIL, RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at www.usps.come Postage Certified Fee Return Receipt Fee ndorsement Required) iestricted Delivery Fee ndorsement Required) Total Postage & Fees Sent To A $0.49 $3.30 $(1,00 �1J.0!ry 0013 24 0 Street, Apt. No.; or PO Box No. City, State, ZIP+4 PS Form 3800, August 2006 See Reverse for Instructions FILED -O)'" iC OF THE PROTNONOTAR'S• 2014 JUL 24 PM.+:,: S CUIDERLAND COUNTY PENNSYLVANIA 1.:E OF APPEAL AND RULE TO FILE COMPLAINT is proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ,.,4er (4(V ; ss AFFIDAVIT: I hereby (swear) (affirm) that I served ❑ a copy of the Notice of Appeal, Common Pleas No. (date of service) , upon the Magisterial District Judge designated therein on 'personal service ❑ by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) , onr 2 1. 20 t ( ❑by personal serviceD by (certified) (registered) mail, '0.t M0) sender's receipt attached hereto. (SWORN)` (AFFIRMED)A D SUBSCRIBED BEFORE ME THIS c�/ �DAY OF k 20»f � Signatq( of official before whom affidavit was made ark Title of official My commission expires on Am 20 Prothonotary, Cumberland 'County, Carlisle, PA My Commission Expires the First Monday of Jan -22018 AOPC 312A - 05 Signature of affiant WALTER GARMAN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. PAUL STEEL, Defendant To the Prothonotary: : NO.2014 - 4076 CIVIL TERM PRAECIPE FOR JUDGMENT (NON PROS) Kindle enter a Judgment of Non Pros against the Plaintiff in the above -captioned matter, for failure to file a complaint within twenty (20) days of service of rule issued, pursuant to Pennsylvania Rules of Civil Procedure Rule 1004. Respectfully Submitted, aul S - el, Pro Se Defen. ant 50 W. Penn Street Carlisle, PA 17013 rU c G") C) r_,„) cr, -H r rn CD -71 1P (\MAL �lidi(Po� WALTER GARMAN, Plaintiff v. PAUL STEEL, Defendant TO: Mr. Walter Garman : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO.2014 - 4076 CIVIL TERM • IMPORTANT NOTICE DATE OF NOTICE: August 18, 2014 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone (717) 249-3166 Resp tfully Su fitted, Paul Steel, Pro Se Defendant 50 W. Penn Street Carlisle, PA 17013 WALTER GARMAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2014-4076 CIVIL TERM PAUL STEEL, Defendant NOTICE TO DEFEND 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, order and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 1-800-990-9108 Americans with Disabilities Act of 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. WALTER GARMAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2014-4076 CIVIL TERM PAUL STEEL, Defendant COMPLAINT AND NOW this 27th day of August 2014 comes the Plaintiff, Walter Garman by his attorneys, Irwin & McKnight, PC and makes the following Complaint against the Defendant, Paul Steel as follows: 1. The Plaintiff is Walter Garman, an adult individual who resides at 398 Kerrsville Road, Carlisle, PA 17015. 2. The Defendant is Paul Steel, an adult individual who rented apartment #3 situated at 161 North East Street, Carlisle, PA 17013. 3. The Defendant entered into a Lease Agreement marked as Exhibit "A" and made a part of this Complaint. 4. The Defendant failed to pay rent as required by his lease. 5. The Defendant failed to pay rent for the months of March, April, May and June for a total rent due and owing in the amount of $1,720.00. 6. The Plaintiff filed a landlord tenant action before District Magistrate Jessica Brewbaker and incurred costs in the amount of Two Hundred Fifty Two and 20/100 ($252.20) in costs. 7. The total amount owed the Plaintiff by the Defendant is as follows: Unpaid Rent: Court Costs: $1,720.00 $ 252.20 Total $1,972.20 8. The Defendant appealed the judgment to the Court of Common Pleas at 2014-4076. He sent a ten (10) day notice dated August 18, 2014. 9. The Plaintiff has filed this Complaint as required by the Rules of Civil Procedure. WHEREFORE, the Plaintiff, Walter Garman requests judgment in the amount of $1,972.20 be entered against the Defendant, Paul Steel with interest and costs as permitted by law. By: Date: August 27, 2014 Respectfully submitted, IRWIN & KNIGH , P.C. Marc . A. McK ght, I Esq. 60 West Pomfret .treet Carlisle, Pennsylv (717) 249-2353 Supreme Court I.D. No. 25476 Attorney for Defendant VERIFICATION The foregoing document is based upon information, which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. By: ice(/ WALTER GARMAN Date: August 27, 2014 Exhibit "A" LEASE AGREEMENT MADE THIS .2 S day of ,,?G 13 , by and between WALTER K GARMAN with an address of 398 Kerrsville Rd., Carlisle, Cumberland County, Pennsylvania, 17015 hereinafter named "LESSOR"; AND S �� , adult individuals, with an address of /4/ IV. F'.9s7` //Pr, Carlisle, Cumberland County, Pennsylvania, hereinafter named "LESSEES". WITNESSETH that said LESSOR, in consideration of the rents and covenants hereinafter mentioned, doth demise and lease unto LESSEES to be used as a single family dwelling the premises ,L17641 located at/2/A/ S%r . /9/f , Carlisle, County of Cumberland and Commonwealth of Pennsylvania. 1. TO HAVE AND TO HOLD unto the LESSEES, subject to the conditions of this Lease Agreement for a term of one (1) year beginning the 1st day of 4/0 and continuing for a period of one (1) year. 2. IN CONSIDERATION OF WHICH the LESSEES agree to pay the LESSOR for the use and occupancy of said premises, the sum of 1_1 Dollars per month payable as follows: 1 e a. The sum of 1 fl9, o Dollars per month to be received at the address designated by the LESSOR on or before the first day of each month. b. The LESSEES agree to pay a late charge of Fifty and no/100 ($50.00) Dollars each time the monthly payment is not received by 5:00 pm on the tenth (10th) day of the month regardless of the cause including any checks which have been dishonored. 1 c. The Lease is for 02— adults. Any other persons who reside at the property will cause the rent to rise by One Hundred and no/100 ($100.00) Dollars per month. 3. IN ADDITION the LESSEES will be required to pay the sum of 16,0 U Dollars to the LESSOR as a security deposit. The security deposit shall be returned to the LESSEE by the LESSOR within thirty (30) days of the termination of this Lease Agreement less deductions for all damage to the property beyond normal wear, less all cleaning expenses incurred by the LESSOR, and less all unpaid rent under the terms of this Lease Agreement. 4. The LESSOR will remove all snow from the entrance and side walk to the leased premises. 5. The LESSEES agree not to permit any activity on the premises that creates excessive noise at any time, especially during the hours of 10:00 p.m. to 7:00 a.m. Excessive noise is any sound heard outside the apartment. 6. The LESSEES shall pay for the electric utilities, gas, trash bags, telephone, and cable service. The LESSOR will pay for the monthly water, sewer expenses. 7. The LESSOR shall pay for all school, county, and township property taxes. The LESSES shall supply LESSOR with proof of insurance for tenant liability coverage with a minimum of $1,000.00 in medical coverage. 8. The LESSEE shall keep the property maintained in as good repair and clean condition as it is currently and at the expiration of this Lease Agreement, the property is to be surrendered in like repair and condition, natural wear and damages happening by fire, storm or other casualties are the only exceptions. 2 k. LESSEES' GUIDE: The LESSOR reserves the right at any time and from time to time to prescribe such additional rules and make such changes to the rules and regulations set forth and referred to above as LESSOR shall in its judgment determined to be necessary for the safety, care and cleanliness of the premises, for the preservation of good order or for the comfort or benefit of LESSEES and of the neighborhood generally. Any violation of such rules and regulations shall constitute a breach of this Lease Agreement. 23. NOTICE TO QUIT: THE LESSEES HEREBY WAIVE THE USUAL NOTICE TO QUIT or notice to re-enter the Lease Property and agree to surrender the property at the expiration of the term, or the termination of this Lease Agreement without any notice whatsoever. IN WITNESS WHEREOF, and having fully and completely read and agreed to the terms and provisions set forth above, including LESSEES' waiver of any usual notice to quit the premises, the parties have set their hands and seals the day and year first above written. IN THE PRESENCE OF: LESSOR: WALTER OR BEVERLY GARMAN WALTER GARMAN LESSEES: ok° 7 hxhibit "B" WALTER GARMAN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. PAUL STEEL, Defendant TO: Mr. Walter Garman : NO.2014 - 4076 CIVIL TERM • IMPORTANT NOTICE DATE OF NOTICE: August 18, 2014 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone (717) 249-3166 fully Su itted, Paul Steel, Pro Se Defendant 50 W. Penn Street Carlisle, PA 17013 WALTER GARMAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2014-4076 CIVIL TERM PAUL STEEL, Defendant CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached document was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Paul Steel 50 West Penn Street Carlisle, PA 17013 IRWIN & McKNIGHT, P.C. By: Marcus . c is ' , squire 60 West ' omfret eet Carlisle, PA 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Date: August 27, 2014 prOt\A61N •14:41/1 VS ck7S -ke LAJe2S it-16,er tPeN4 pi C( I