Loading...
HomeMy WebLinkAbout14-4157COMMbNWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS Judicial District, County Of 6A-410e-da,4 NOTICE OF APPEAL FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT COMMON PLEAS No. /1/— 14/7 ?sv� NOTICE OF APPEAL iettn 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 O PPELLANT MAG. DIST. NO. NAME OF MDJ ro -nay f r 2..A,f AMISS- oct - 3- 01 1-1-Dnor0.6 Le -4 A ni l o y m s STATE ZIP CODE ADDRESS SOF 4 G\ b r. S h'� � p-ert5 bt,t r qj CITtCL DATE OF JUDGMENT DOCKET No. IN THE CASE OF (Plaintiff) {/��/o , y ryy C Q �^ L KSI SATURE OFSAPPELLANT OR ATTORNEY OR AGENT pq 3 01-1-t - 0000112.-2_01Y (Defendant)' rarcLi F n tit). rre_il This block will be signed ONLY when this notation is required under 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 j,uclgment for possession in this case. Sign. re of -rothonotary or Deputy If appelant was Claimant (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 District 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. RULE: To h i2 ,Dc 'o,r*Y\eJcS LLC Name of appellee(s) /'/ 41/s7C►��L appellee(s), to file a complaint in this appeal within twenty (20) days after service of rule or suffer entry of judgment of non pros. Ivl D C( Pa,l +vi S LIC appellees) Name of a pellee(s) Signature of appellant or attorney or agent (1) Youare_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. (l; If y8u do not file a compiaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) -The date f service of this rule itid &&; S E4atj) is the date of the mailin',1i11103 ONVTd:3814110 -Ptaiae-- Date:7���`?9�E 30 :1 Hd! L 1 inr tl i YOU MUST INCLUDE A COPY OF THE NOTICE' OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. Signature of Prothonotary or Deputy AOPC 312-05 COMM NWEALTH OF PENNSYLVANIA CO' TY OF CUMBERLAND Mag. Dist. No: MDJ Name: Address: MDJ-09-3-01 Honorable H. Anthony Adams 35 West Orange Street Shippensburg, PA 17257 Telephone: 717-532-7676 Justin Hurrell 15 Apache Drive Shippensburg, PA 17257 Disposition Details Grant possession. Grant possession if money judgment is not satisfied by the time of eviction. Disposition Summary (cc- Cross Complaint) Docket No Plaintiff MJ -09301 -LT -0000112-2014 MJ -09301 -LT -0000112-2014 Judgment Summary Participant Joint/Several Liability Individual Liability Brandy Hurrell $1,080.60 $0.00 Justin Hurrell $1,080.60 $0.00 Velocity Partners, LLC $0.00 $0.00 Velocity Partners, LLC Velocity Partners, LLC Defendant Justin Hurrell Brandy Hurrell Notice of Judgment/Transcript Residential Lease Velocity Partners, LLC v. Justin Hurrell, Brandy Hurrell Judgment Finding (*Post Judgment) In the matter of Velocity Partners, LLC vs. Justin Hurrell; Brandy Hurrell on MJ -09301 was awarded as follows: The amount of rent per month, as established by the Magisterial District Judge, is $946.00 Judgment Component Joint/Several Liability Rent in Arrears $946.00 Costs $134.60 Individual Liability $0.00 $0.00 Docket No: MJ -09301 -LT -0000112-2014 Case Filed: 6/24/2014 Yes No Disposition Judgment for Plaintiff Judgment for Plaintiff Disposition Date 07/07/2014 07/07/2014 Amount $1,080.60 $1,080.60 $0.00 -LT-0000112-2014. on 7/07/2014 the judgment Deposit Applied Grand Total: Portion of judgment for physical damages arising out of residential lease: Amount $946.00 $134.60 $1,080.60 $0.00 IN THE COURT OF COMMON PLEAS OF 6„ �4 0(aCOUNTY, PENNSYLVANIA vs. Plaintiff Defendant CIVIL ACTION - LAW Vdo votx4m s diutc_c-r-s4J-1 . No.`l� 6v -c(4 I lL.S'H t 14ewe PETITION TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: r The Petition of PPd 4 Tul_S-k) srpecLfully represents: 1. I am the CV-trick/4in 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: (a) Name: &anat./ t '�t t Y�'! ,n 4 x i RA Address: t j Avadi_e- . h^ i.n.e 16b\mi9 Pa Soc. Sec. No.: gbh CC" cxya,g n y — (o - " c1 q ie 0 (b) Employment --If you are presently employed, state /u ,n Employer: Address: Lo,vnax,\(AQJ \JhAe_ ch tc r ch c\d . 6 hiiV -5 "b Po. (,,p $ ©a fyL-co-a I rn r Salary or wages per month: Type of work: fax frl --If you are presently unemployed, statt(tyNx.vicfq Date of last employment: Li' a619 Salary or wages per month: 51 CSO Type of work: C I A (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: ?U 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: 5 Checking account: ' 1 D Savings account: /J )4. Certificates of deposit: Kt kk Real estate (including home): t`f ao`i I Q (r:, 2. Motor vehicle: Make: Cost: Stocks: (�/.4- Bonds: Jl.(�� Other: (f) Debts and obligations p -- Mortgage: Rent: V305— Loans: a5— Loans: $ 1 b o Other: ; Year: q `J ; Amount owed: Electric 1 $ Water (-Ce/4 Q -r $ a p a Ck • Telephone Cable Credit cards Auto Insurance 1) ( t Gasoline ` S t) D Food 5 3 p (g) Persons dependent upon you for support Spouse's Name: /L- IA Child(ren), if any: 6^ ,i%-LAki., CD 11 Cla fIA-Urcol( Name(s) and age(s): I 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. `71 Date COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS County Of (Ler' tarot PLAINTIFF: NAME and ADDRESS �VLIoc tr'0.4pers L_ VS. DEFENDANT: NAME and ADDRESS r c 4QcQ 1 Sins -fin erre_( ( S til ff-e-nk3bAvc 1 72s L - Common Pleas Docket No. TENANT'S SUPERSEDEAS AFFIDAVIT (NON -SECTION 8) FILED PURSUANT TO Pa.R.C.P.M.D.J. No. 1008C(2) I, l'\00tACALA rel (print name and address here), have filed a notice of appeal from a magisterial district court judgment awarding to my landlord possession of real property that I occupy, and I do not have the financial ability to pay the lesser of three (3) times my monthly rent or the judgment for rent awarded by the magisterial district court. My total household income does not exceed the income limits set forth in the supplemental instructions for obtaining a stay pending appeal and I have completed an in forma pauperis (IFP) affidavit to verify this. Lb-aye/have not (cross out the one that does not apply) paid the rent this month. I verify that the statements made in this affidavit 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 falsification to authorities. D to IGN D to IGNA Jn' E OF TENANT AOPC 312-08 (B) SUPPLEMENTAL INSTRUCTIONS FOR OBTAINING A STAY OF EVICTION ****IMPORTANT****PLEASE READ THESE INSTRUCTIONS CAREFULLY! This document contains important information about your case. Failure to comply with any instructions provided in these materials may cause you to be evicted before your appeal or writ is heard. 1. FOR TENANTS — SUPERSEDEAS: If you are a tenant and you filed the notice of appeal or praecipe for writ of certiorari, you must pay money into an escrow account to remain in the property until your appeal or writ is decided. This is called a "supersedeas." The supersedeas will suspend the magisterial district court judgment and will prevent your eviction until your case is heard by a judge and a final decision is made on the appeal or writ. IF YOU FAIL TO PAY YOUR MONTHLY RENT INTO ESCROW IN FULL AND ON TIME, YOU COULD BE EVICTED BEFORE YOUR APPEAL OR WRIT IS HEARD, Begin by looking at the income limits attached to these instructions. If your income is below the income limits, complete a Tenant's Affidavit, pursuant to Pa.R.C.P.M.D.J. No. 1008(C)(2) or 1013(C)(2). These affidavits are available on the website of the Administrative Office of Pennsylvania Courts (www.aopc.org). Then follow the instructions for low-income tenants below. There are several different options available; pick the option (A, B, or C) that best describes your situation. If your income is higher than the income limits attached to these instructions, follow the instructions for D. 17 A. If you are a low-income tenant and there was a money judgment entered against you for non-payment of rent, and you HAVE NOT paid rent for the month in which the notice of appeal or praecipe for writ of certiorari is filed, you must: 1. File an in forma pauperis petition (a petition for low-income parties) pursuant to Pa.R.C.P. No. 240; 2. Pay one-third of your monthly rent into an escrow account with the prothonotary's office at the time the notice of appeal or praecipe for writ of certiorari ("praecipe") is filed; 3. Pay the remaining two-thirds (2/3) of your monthly rent into the escrow account within twenty (20) days of the date the notice of appeal or praecipe was filed; and 4. Pay your monthly rent on an ongoing basis into the escrow account in thirty (30) day intervals from the date the notice of appeal or praecipe was filed until the time of your trial. ou are a low-income tenant, and there was a money judgment against you for non-payment of rent, and you HAVE paid rent for the month in which the notice of appeal or praecipe for writ of certiorari ("praecipe") is filed, you do not have to pay rent at the time you file your notice of appeal or praecipe. You must 1. File an in forma pauperis petition (a petition for low-income parties), pursuant to Pa.R.C.P. No. 240; 2. Pay your monthly rent on an ongoing basis into an escrow account with the prothonotary in thirty (30) day intervals from the date the notice of appeal or praecipe was filed until the time of trial. It is important to count the thirty (30) days exactly 18 because the date of your payment will change depending on the number of days in a given month. C. If you are a low-income tenant, and no money judgment was entered against you for non-payment of rent, you do not have to pay rent at the time you file your notice of appeal or praecipe for writ of certiorari ("praecipe"). This option is to be used/fat the magisterial district court hearing, the judge determined that you owed "zero" or "nothing" in rent. You must: 1. File an in forma pauperis petition (a petition for low-income pa ies), pursuant to Pa.R.C.P. No. 240; 2. Pay your monthly rent on an ongoing basis into an escrow account with the prothonotary in thirty (30) day intervals from the date the notice of appeal or praecipe was filed until the time of your trial. It is important to count the thirty (30) days exactly because the date of your payment will change depending on the number of days in a given month. D. If your income is higher than the income limits on the attached chart, you must: 1. Pay the fee to file a notice of appeal or praecipe for writ of certiorari ("praecipe"); 2. Pay the lesser of three (3) months' rent or the amount of rent awarded to the landlord in magisterial district court into an escrow account with the prothonotary's office at the time the notice of appeal or praecipe is filed; and 3. Pay your monthly rent into the escrow account in thirty (30) day intervals from the date the notice of appeal or praecipe was filed until the time of trial. It is important to count the thirty (30) days exactly because the date on your payment will change depending on the number of days in a given month. C. 19 • INCOME LIMITS 2008 HHS Poverty Income Guidelines Expressed in Monthly Amounts Size of Family Unit Poverty Guideline Monthly Amount 1 $866.66 2 I 1,166.66 3 I 1,466.66 4 1,766.66 5 I 2,066.66 6 2,366.66 7 I 2,666.66 8 I 2,966.66 For each additional person, add 300.00 += !LED -OF FICE OF THE PRUTHONOTAR 29114 JUL 23 en2 CUMBERLAND COUNTY PENNSYLVANIA PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF tl� ; ss AFFIDAVIT: I hereby (swear) (affirm) that I served ❑ a copy of the Notice of Appeal, Common Pleas No.yi' 1, upon the Magisterial District Judge designated therein on (date of service:I'u 20 lu ❑ by personal service b (certifie (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) V on Par'f`n," Italy fid, 20 /14 by personal service® by sender's receipt attached hereto. (SWO N) (Q FFIRMED) AND SUBSC IBED BEFORE ME THISp3(d DAY OFJ-efl 20 l Sig Title of official om affidavit was ma N(31 -i7 My commission expires on , 20 Prothonotary, Cumberland County, Carlisle, PA My Commission Expires the First Monday of Jati528f8. AOPC 312A - 05 (registered) mail, Supreme Ca Court;! C��d :fi urb_. ennsylvania omrnon Pleas County For Prornon ofary Use Only Docket No: The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Cencement of Action: Petition Declaration of Taking Complaint 1 Writ of Summons l� Transfer from Another Jurisdiction Lead Plaintiff's Name: \felvcit, j Partners, L. -L. C Lead Defendant's Name: i.t_Sfirl N -u rre.l i canc! Brclr cit t-+urre_l 1 Are Dollar Amount Requested: I within arbitration limits moneydamages requested? Yes No g q (check one) l outside arbitration limits Is this a Class Action Suit? l Yes ►! No Is this an MDJAppeal?/ Yes lllii No Name of PlaintifflAppellant's Attorney: Cheek here if you have no attorney (are a Self -Represented [Pr o Se] Litigant) Place an "X" to he left sof the ONE case category that most: accurately describes your PRFNCARYC'AS.E If you are making: more than one type of claim, checkthe one that you consider most important. TORT (do not include Mass Tort) 0 Intentional 0 Malicious Prosecution 0 Motor Vehicle 0 Nuisance 0 Premises Liability 0 Product Liability (does not include' mass tort) 0 SlanderlLibel/Defamation O Other: MASS TORT O Asbestos E. Tobacco O ToxicTort -DES ▪ ToxicTort-Implant El Toxic Waste El Other: PROFESSIONAL LIABLITY O Dental O Legal O Medical O Other Professional: CONTRACT (do root arlude Judgments) 0 Buyer Plaintiff 0 Debt Collection: Credit Card 0 Debt Collection: Other 0 Emp loyment D ispute: Discrimination 0 Employment Dispute: Other O Other: REAL PROPERTY El Ejectment Eminent Domain/Condemnation O. Ground Rent Landlord/Tenant Dispute 0 Mortgage Foreclosure: Residential 0 Mortgage Foreclosure: Commercial 0 Partition O Quiet Title O Other: CIVIL APPEALS Administrative Agencies O Board of Assessment O Board of Elections O Dept. of Transportation O Statutory Appeal: Other O Zoning Board O Other: MISCELLANEOUS 0 Common Law/Statutory Arbitration 0 Declaratory Judgment Mandamus "'i Non -Domestic Relations Restraining Order 0 Quo Warranto Replevin 0 Other: Updated 1/172011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VELOCITY PARTNERS, LLC, Plaintiff v. JUSTIN HURRELL and BRANDY HURRELL Defendants NO.: 14-4157 rn o° 730 rn CIVIL ACTION- LAWnP-- �c ') -<> w _,, C) .< O -0 C ->_.r . z CDs. COMPLAINT AND NOW comes the Plaintiff, Velocity Partners, LLC, who files this action at law in Ejectment and Assumpsit and in support thereof, makes the following averments: 1. The Plaintiff, Velocity Partners, LLC (hereinafter "VP" or "Plaintiff') is a Pennsylvania limited liability company which has a principal mailing address of 418 Epic Drive, Chambersburg, Franklin County, Pennsylvania, 17201. 2. The Defendants, Justin Hurrell and Brandy Hurrell, husband and wife (hereinafter, collectively "Defendants") are sui juris individuals, residing at all times material hereto at 15 Apache Drive, Lot 6, Shippensburg, Cumberland County, Pennsylvania, 17257. 3. At all times material to Plaintiffs cause of action, the Plaintiff has been the legal owner of the land upon which the Defendants have placed their manufactured home. 1 4. On or about June 21, 2013, Defendants executed a Lease Agreement by the terms of which the Defendants leased from the Plaintiff a manufactured home lot located at 15 Apache Drive, Lot 6, Shippensburg, Cumberland County, Pennsylvania, 17257, for a month to month term beginning July 1, 2013 and ending on July 31, 2013, after which the lease extended monthly unless properly terminated upon proper notice by either party. A true and correct copy of the Lease Agreement is attached hereto, made a part hereof, and is marked as Plaintiffs Exhibit "P-1." 5. The monthly rent owed is $325.00 per month. 6. Defendants have failed to pay lot rent for two (2) months. 7. The Lease Agreement provides that if the lessee fails to perform its obligations thereunder, such failure to perform shall constitute a default, entitling the lessor to terminate the lease and, otherwise, to seek all remedies available by law. 8. Defendants have failed to abide by Park Rules and Regulations in maintaining the premises as they agreed to upon signing the Park Rules and Regulations. A true and correct copy of the Park Rules and Regulations is attached hereto, made a part hereof, and is marked as Plaintiffs Exhibit "P-2." Picture of the outside clutter is attached hereto, made a part hereof, and is marked as Plaintiffs Exhibit "P-3." 9. Defendants have failed to abide by the Park Rules and Regulations with regards to registering pets within the mobile home community. Defendants did not approach management or the ownership of the park to secure permission to bring a pet into the home. All residents in the park are required to provide management with a pet form for all pets in the home. The animals must also be licensed and vaccinated as per the Park Rules and Regulations. Animals are not permitted to be tethered outside according to Park Rules and Regulations. A picture of an outside tether is attached hereto, made a part hereof, and is marked as Plaintiffs Exhibit "P-4." 10. Defendants have had two (2) returned non -sufficient funds checks within the past four (4) months for lot rent. One of the checks remains outstanding and awaiting reimbursement at the filing of this document. Copies of the NSF checks are attached hereto, and made a part hereof, and are marked as Plaintiffs Exhibits "P-5" and "P-6" respectively. 2 11. Defendants are in possession of a non -approved breed of dog in their home. Management reserves the right to refuse any pet to reside in the park. Defendants refused to remove dog from home when requested to do so by park Management. Defendants continue to fail to register the dog with ownership or management and continue to refuse to remove the dog from the home or clean up the dog excrement outside. Pictures of unapproved dog are attached hereto, made a part hereof, and are marked as Plaintiffs Exhibits "P-7", "P-8", "P-9" and "P-10." 12. Defendants have been issued two (2) violation documents within a six (6) month period. This causes a breach in the Lease Agreement to abide by the Lease and the Park Rules and Regulations. Copies of the Violation Documents are attached hereto, made a part hereof, and are marked as Plaintiffs Exhibits "P-11" and "P-12." COUNT 1- EJECTMENT 13. Plaintiff incorporates paragraphs 1 through 12 of the Complaint as if more fully set forth herein. 14. Defendants have failed and refused and continue to fail and refuse to follow the constraints of the Lease Agreement and the Park Rules and Regulations for the past four months. 15. Defendants have failed and refused and continue to fail and refuse to pay lot rent as outlined in the Lease Agreement and the Park Rules and Regulations for the past four months. 16. Defendants, although requested to do so by the Plaintiff, have refused to surrender the premises located at 15 Apache Drive, Lot 6, Shippensburg, Cumberland County, Pennsylvania to the Plaintiff. WHEREFORE, the Plaintiff demands entry of judgment in favor of the Plaintiff and against the Defendants, Justin Hurrell and Brandy Hurrell, on the issue of possession of the premises known and numbered as 15 Apache Drive, Lot 6, Shippensburg, Cumberland County, Pennsylvania. 3 COUNT II- BREACH OF CONTRACT 17. Plaintiff incorporates Paragraphs 1 through 16 of the Complains as if more fully set forth herein. 18. During the pendency of this litigation, Defendants may cause physical damage to the Lot. Defendants may or may not pay Plaintiff the cost to repair such damage. 19. As of the date of this pleading, Plaintiff has not received the full rent and fees for the months of June and August. The payment for the month of June was returned unpaid by the Defendants' financial institution. Late fees have accrued as well as a returned check fee. June rent and late fees are now $1420.00 and August lot rent of $325.00 in addition. to current water and sewer fees of $185.00. The total amount owing is $1930.00. 20. In the event, Defendants fail to pay rent or physical damages to premises during the pendency of this litigation, Plaintiff seeks payment of rent and damages, if any, due and owing until the conclusion of this litigation. WHEREFORE, the Plaintiff demands entry of judgment in favor of the Plaintiff against the Defendants, Justin Hurrell and Brandy Hurrell, the sum of $1930.00. This should be in addition to additional late fees and damages to the real estate, if any, incurred and unpaid from the date of the filing of this Complaint to the conclusion of this litigation, together with any further costs of this suit. Respectfully submi Velocity Part - C By: 418 Epic Drive, Franklin County Chambersburg, PA 17201 (717) 709-7066 Dated: Aulut.St 13, 2014 COMMbNWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS Judicial District, County Of 6444444 NOTICE OF APPEAL FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT COMMON PLEAS No. NOTICE OF APPEAL - 4/07 LI Lotice Is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District fudge on the date and in the case referenced below. fAltia paw Our PI � Disfi. kQ ;;�+MOF MI r rL ( Le -Oct-z-01 l4DnorAblt 44. A(1 1oO4 Ams (wA VI tr. 6�'�� �Q.rts b.uct% crr � • V 1 Q •c-- sYnre — SATE OF err N THE CASE OF (Ptah. (Defenwer.Q' .. tt.. 114 J Q1 b" f_ l± _ . n ei ,s_LL1.1•4- br©.r �j r 146fl H [ii dl mt.f�i�tda. -Sit full OF MVELLANTWR ATTOftkEY dR AGM This bock wi be signed ONLY when this notation is required under Pe. R.C.P.D.J. No. 10088. This Notice of Appeal, when received by the Magisterial District Judge, will operate as a SUPERSEDEAS to the 4udgrnent for possession in this case. R C. P.D.J. No. 1 001(6) in action before e Magisterial District Judge, A COMPLAINT MUST BE FILED 00, Twenty (20) days alter fling the NOnCE of APPEAL^ PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (itis section of forrn to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No: 1001(? in action before Magisterial District Judge. IF NOT USED, detach frvm copy Voodoo of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon L[ac-+ger$j LLC +varve cct apossoorsi (Common Pleas No. . %/S9 t, ial ) within twenty (20) days after service of rola or suffer entry of)udgment of non pros. appellees), to file a complaint in this appeal RULE: To Sl."24};31.dragnature of appellant or attorney or agent 1 O C`of ri 5 J LL . appe (s) Nani (1) You -are. noticed that a ruts is hereby entered upon you to file a complaint In this appeal within twenty (20) days after the date of service of this r c3 upon you by perfortai service or by certified or registered mail. (2) If you do net file a cissr:platt within this time. a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) Ifni datesof alis rune ItiateXie-WaSfAtirieri is the date of the mai •- i'!nf_i ONV1 i3Fhfl3 30:! ;lc! Li fir' YOU MUST INCLUDE A COPY OF t iNarmor JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. COUNTY OF CUMBERLAND eg. a MDJ Name: Honorable H, Anthony Adams Address: 35 West Orange Street Shlppenaburg, PA 17257 Telephone: 717.832.7676 OUNT DATE PAID b '2' FILING COSTS POSTAGE SERVICE COSTS CONSTABLE ED. S TOTAL 9 / / Pa.R.C.P.D.J. No. 206 sets forth those costs recon LanaIorarl PlAIN'nFP: NAME and ADDRESS Ve.loa(ty PC -1H ne.rS, LLC - 1.41 apt .. Drive ejrnbe.rsb..t.ri p„ I17 .41 ENDANT; NAME end ADDRESS ..l.tJ sten Giro $rcw,d y 1.1 urret i 15 Ape -.arc vc. Shtpper sk, zri, PA 112.51 Docket No: a Case Piled 6,.4t4 �t y able by the prevailing party. J TO THE DEFENDANT: The above nerved plainkiff(s) asks judgment together with costs against you for the possession of real property and for: Lease is ® Residential O Damages for injury to the real property, to wit: Nonreaidentlai In the amountof: O Damages for the unjust detention of the reel property In the amount of s 2K Rent remaining due and unpaid on Ong date In the amount of $ 51.5. O And additional rent remaining due and unpaid on hearing date 8 0 Attorney fees In the amount of $ THE PLAINTIFF FURTHERALLEGES THAT: Total: $ 1, The location and the address, Reny, of the real property la: It A p4G. ,e< Drive. 2. The pleintiff Is the landlord of that property. 3. He leased or rented the property to you or to 4, 0 Notice to quit was given In accordance with law, or gg No notice is required under the terms of the lease, 8. © The term for which the property was leased or rented is fully ended, or t Ctrtid t 0 rd Gkoo S e. S 40 v\04" I.'olct ova ® A forfeiture hes resulted by reason of e breech of the conditions of the lease, to wit: 1 Q e: (� v+r,., r..t-4. 4 41 i.t the n r©, I��7 hom you claim. 0 Rent reserved and due hes, upon demand, remained unsatisfied. 8. You retain the real property and WOO to give up to Its possession. 1..1sca Mairtir 'Arlt- Meanc.t e truand correct to the beat of my knowledge, t or of the Crimes Code (18 PA. C.S. § 4904) relating to unsworn verify that the fads set torah In this complaint are tis made eubject to the Densities of Section 4904 *Aim lure of " The pleintiff'e money shell file an entry of appearanoe with the magisterial district court pursuant to P..R.C.P.M.D.J, 2C7,t IP YOU WV A ©lPEN$B to this complaint you may resent n at Ow hearing. !P YOU HAVE A CLAIM against the ow estop out at the ne:wor cy of ins promises, whir Is in tramegatons' distrfct)ddge Jurtaotetion end which you Intend to emit et the hearing, YOU MUST FILE it on the compisint tom et the office BEFORE THE TIME set tenths hrsr'rag. IF You 00 NOT APPEAR A7 THE HEARING, *Judgment for possession and ousts, and for damages and rent if deimsd, mei, nevertheless be entered satirist you. 4IuJament sasinit you for pceeeeteon may noun in your EVICTION from the porn iese. 11 you are disabled and require et reasonable accommodation to gain access to the Magisterial Dietrlct.Court end tie services, plisse contact the Msglsteelel Ctleeest Court at the above address or telephone number. We are unable to provtde transportation. MIXIS 310A Pintail: 01)/0 •v . ,a•4+ ++, ,turinn 11 LrL!I nGL11,1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Meg. Dist No M J-08.3.01 MDJ Name. Honorable H. Anthony Adams. Address: 35 Weal Orange Street Shippensburg, PA 17257 Tnrtfl: 717.532.767 Velocity Partners, LLC 418 Epic Drive Charnbe sburg, PA 17201 r. Recovery of Real Property Hearing Notice Velocity Partners, LLC v. Justin Murrell, Brandy Murrell pocket No: MJ-06301-L.T-0000112-2014 Ceae Filed: 8/24/2014 A Recovery of Reel Property Haut ng has been setteduled for the above captioned case to be he on Date: Monday, July 7, 2014 Time:1t1t3AM Place; Courtroom. MDJ-00.3-01 35 West Orange Street Shtppensburp, PA 17257 717.532.7676 Notice To Defendant A landlord/tenant complaint rtes been filed Against you for the recovery of poseeselon of rest property, and or money anti damages associated with the above captioned case If you have a defense to this oompisint, you may present It at the hearing If you kavas claim against the plaintiff arising out of the occupancy of the premises, wnloh Is within the jurisdiction of the magisterial district fudge and which you Intend to steed et the hearing, you must Re it on a complaint form at this OMNI WOOD the time set for the hearing if you do not appear at the hearing, a Judgment for possession and costa, and for damages end rent 1f claimed, may nevertheless be entered against you, A Judgment against you for possession may result in your evtotlon from the premises. June 24, 2014 Date Magi atetiai rli;#act Juogo H. Anthony Adams If you are disabled and require a reasonable ta000mmadetion to aain raoretis to the Maglstertal Dietrtot Court and its aervIces, please contact the Magisterial Disblot Court at the above address or telephone number. Wears unable to provide transportation. MDJ$ 306 1 Printed; 06/24/2014 t t20:2f1AM COMMONWEALTH OF PENNSYLVANIA COUNT( OF CUMBERLAND Mag. Dist. No: MDJ Name: Address: MDJ-09-3-01 Honorable H. Anthony Adams 35 West Orange Street Shippensburg, PA 17257 Telephone: 717-532-7676 Velocity Partners, LLC 418 Epic Drive Chambersburg, PA 17201 Disposition Details Grant possession. Grant possession if money judgment is not satisfied by the time of eviction. Disposition Summary Docket No MJ -09301 -LT -0000112-2014 MJ -09301 -LT -0000112-2014 Judgment Summary Participant Brandy Hurrell Justin Hurrell Velocity Partners, LLC (cc - Cross Complaint) Plaintiff Velocity Partners, LLC Velocity Partners, LLC Defendant Justin Hurrell Brandy Hurrell Joint/Several Liability $1,080.60 $1,080.60 $0.00 Notice of Judgment/Transcript Residential Lease Individual Liability $0.00 $0.00 $0.00 Velocity Partners, LLC v. Justin Hurrell, Brandy Hurrell Docket No: MJ -09301 -LT -0000112-2014 Case Filed: 6/24/2014 Yes No Disposition Judgment for Plaintiff Judgment for Plaintiff Disposition Date 07/07/2014 07/07/2014 Amount $1,080.60 $1,080.60 $0.00 Judgment Finding (*Post Judgment) In the matter of Velocity Partners, LLC vs. Justin Hurrell; Brandy Hurrell on MJ -09301 -LT -0000112-2014, on 7/07/2014 the judgment was awarded as follows: The amount of rent per month, as established by the Magisterial District Judge, is $946.00 Judgment Component Rent in Arrears Costs Joint/Several Liability individual Liability Deposit Applied $946.00 $0.00 $134.60 $0.00 Grand Total: Portion of judgment for physical damages arising out of residential lease: Amount $946.00 $134.60 $1,080.60 $0.00 MDJS 315A Page 1 of 3 Printed: 07/07/2014 11:43:23AM Velocity Partners, LLC v. Justin Hurrell, Brandy Hurrell Docket No.: MJ-09301-LT-Q0Q0.112-2014 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 PRQTHONOTARY1QLERA QF 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 1S 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. C.J`�x.-�a- Magisterial District Judge H. Anthony Adams 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 or 3 Printed: 07/07/2014 11:43:23AM Velocity Partners, LLC v. Justin Hurrell, Brandy Hurrell Plaintiff(s) Participant List Velocity Partners, LLC 418 Epic Drive Chambersburg, PA 17201 Defendant(s) Brandy Hurrell 15 Apache Drive Shippensburg, PA 17257 Justin Hurrell 15 Apache Drive Shippensburg, PA 17257 Docket No.: MJ -09301 -LT -0000112-2014 MIDJS 315A Page 3 of 3 Printed: 07/07/2014 11:43:23AM COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Mag. Dist, No: MDJ Name: Address: Telephone: MDJ-09-3-01 Honorable H. Anthony Adams 35 West Orange Street Shippensburg, PA 17257 717-532-7676 Velocity Partners, LLC 418 Epic Drive Chambersburg, PA 17201 Rent in Arrears Costs Total $946.00 $134.60 $1,080.60 Request for Order for Possession Velocity Partners, LLC v. Justin Hurrell, Brandy Hurrell Docket No: MJ -09301 -LT -0000112-2014 Case Filed: 6/24/2014 Time Filed: 3:03 pm Date Order Filed:07/18/2014 TO THE MAGISTERIAL DISTRICT JUDGE: The Ptaintiff(s) named below, having ob ocated at: 15 Apache Drive, Shippensburg PA Requests that you issue an ORDER FOR POSSESSION for such property. Pate: 4,-,ji i, Plaintiff Signature: Plaintiff: Velocity, Partners, LLC a nect a judgment for possessron of real property t (t_ MDJS 311A 1 Printed: 07/18/2014 3:04:38PM COMMONWEALTH. Of PENNSYLVANIA COUNTY OF CUMBERLAND Mag. Dist. No: MDJ Name: Address: MDJ-09-3-01 Honorable H. Anthony Adams 35 West Orange Street Shippensburg, PA 17257 Telephone: 717-532-7676 Velocity Partners, LLC 41.8. Epic Drive - Chambersburg, PA 17201 rder for Possession, Return and Notice Velocity Partners, LLC v, Justin HurreIt Brandy Hurrell Docket No: Case Filed: Time Filed: Date Order Filed: MJ -09301 -LT -0000112-2014 6/24/2014 03:05PM 07/18/2014 TO THE MAGISTERIAL DISTRICT JUDGE: The above named plaintiff, having obtained a judgment for possession of real property located at: 15 Apache Drive, Shippensburg P -A Requests that you issue an ORDER FOR POSSESSION for such property. Date: Plaintiff: Velocity Partners, LLC f To: Kevin W Preston ORDER FOR POSSESSION (Sheriff or Certified Constable) You are hereby directed to deliver actual possession to plaintiff, or his agent, of real property located at (Give location ancVor address): 15 Apache Drive, Shippensburg PA Notice Concerning Personal Property Left in Rental Property If you vacate the rental property and leave personal property behind in the rental property, you have ten days to contact your len1Q1:0, Ql2(21.1t. your intentions. concerning the, removal. atthat personal property. Your landlord is obligated to. retain your personal property for thirty days if you make such a request within ten days of vacating the rental property. If no such request is made within the ten-day period, your landlord may dispose of the personal property at the end of the ten-day period. Additionally. you may be held responsible for the costs of removal or storage of your personal property after the landlord has the right to dispose of such property. Section 505.1 of the Landlord and Tenant Act of 1951("Act"), Act of April 6, 1951, P.L. 69, as amended, 68 P.S. § 505.1. July 18, 2014 ( Date Magisterial District Judge H. Anthony Adams Received Date & Time Signature of Sheriff or Certified Constable MDJS 3118 Printed: 07/18/2014 3:05:34PM Date: Tenant (s): LEASE AGREEMENT Landlord: Velocity Partners, LLC, P.O. Box 1180, Chambersburg, Pa 17201 r� Lot Number: Address; 15^ l'� cps c,\r r , t•-; pan r- C l\ Use: Parking of Tenant's Mohd home for Residential Purposes Intending to be legally bound, Landlord hereby Leases to Tenant, and Tenant takes from Landlord, the premises, upon the terms and conditions hereinafter set forth as follows: 1. Terms: The term of this Lease is for a eriod of one (1) month, commencing on % \ 3 and expiring % t 3 ; provided, that a holding over by tenant may be constru by the Landlord, at Land ord's ption. As a renewal of this lease on a month-to- month basis, subject to all the terms and conditions of this lease, except that the T.,andlord reserves the right to increase the rent, upon 30 days advance notice thereof, Successive renewals shall occur on the same basis, absent prior notice by either party. Landlord shall not be liable for failure to give possession a the teased property to the Tenant upon the effective elate of this Lease. In such event, rental payments and other fees, charges or Assessments shall not commence until possession is given to, or is made available to the Tenant, and the term of this tease shall he extended accordingly. Tenant must give Landlord at least 30 days written notice prior to moving. It is the responsibility of Tenant to provide Landlord with all necessary completed state or local forms and receipts. 2._ Rent Tk ret shall. he $325.0Q per month, payable on or before the first day of each month, in advance, at the office of Landlord as set forth above. For any rental payment which is not made on or before the required date, Tenant shall pay Landlord a late fee of $15 for each day that such payment is late. 3. Occupants: Landlord and Tenant agree that the following persons and not others will reside at the premise: Name: Age: t 4. Security Deposit: NIA PI ga No: 14- 1-115-1 S. Utilities and Taxes: Tenant shall obtain, where necessary, and pay for all utilities. for_ the_ Premises including, without limitation, water and sewer service, electricity, gas, and trash removal. Water and sewer chargt:.s shall be billed by Landlord to Tenant as set forth in the Indian Springs Manor Rules and regulations. Tenant shall also pay all real estate taxes assessed and levied against the Premises and Tenant's personal property, and shall furnish landlord, when requested, with proof of payment of same. Failure to pay any such taxes, when due, shall be a violation of this Lease, and constitute a default hereunder. It is the intent of this Lease and the parties hereto that Tenant shall provide and pay for all services and expenses related to the use and occupancy of the Premises, except for the expenses and services specifically stated herein to be the responsibility of Landlord. 6. En: Tenant shall use the Premises only as specified above and for no rafter purpose. Tenant shall not do or keep anything in the Premises which is contrary to any law or government reuutation. 7. Assignmen1 and Subletting: Tenant shall not assign this Lease, or sublet the Premises, without the prior written consent (lithe Landlord. 8. Liabil ly of Landlord: Landlord does not warrant the condition, fitness or merchantability of the premises. Landlord shall not be liable for any injury to persons or property occurring upon the Premise. Tenant agrees to indemnify save Landlord harmless from and against any and all payments, expenses, costs, attorney fees and the like, arising our of any and all claims and liabilities for losses or damage to property or injuries to persons occasioned wholly or in part by or resulting from any act or omission by the Tenant or the Tenant's agents, guest, licensees, invitees, or for any cause or reason whatsoever arising out of or by reason of the occupancy by the Tenant of the Premises. All personal property of'Tenant on the Premises, including Tenant's mobile home, shall be and remain at Tenant's sole risk, and Landlord shall not be liable for any damage to, or loss of such personal property arising from any cause whatsoever. 9. Care of Premise: Tenant shall maintain the Premises in a. clean and sanitary condition. Tenant shall not make any alterations or additions to the Premises without the consent of Landlord. Upon termination of the Lease, Tenant shall remove the Mobile Home from the Premises and surrender the Premises to Landlord in as good condition as when received, ordinary wear and tear excepted. Any equipment, fixtures, goods or other property of Tenant not removed by Tenant upon any quitting, vacating or abandonment of the Premises by the Tenant, or upon Tenant's eviction, shall be considered as abandonment, and Landlord shall have the right, without any notice to the Tenant, to sell or otherwise dispose of the same at the expense of the Tenant and shall not be accountable to the Tenant for any part of the proceeds of such sale, if any. 10. Right of Entry: Landlord shall have the right to enter the Premises at any reasonable time to inspect and to enfisrce the provisions of the l..ease. 11, Utility Failure: Landlord shalt not be liable for any damage or injury which may be sustained by Tenant or any other person as a consequence oldie failure, breakage or obstruction �\i 1401 lt4- 4157 of the water, sewer, waste ar sail pipes, or the electrical, gas or oil system, or by reason of the elements, or resulting from the carelessness, negligence or improper conduct on the part of Landlord or any tenant, or any of Landlord's or any Tenant's agents, guests, licensees, invitees, assignees or successors, or attributable_ to. any interference with, interruption of or failure of any such which is beyond the control of the Landlord. 12. Rules and Resplations: Tenant shall conform to all rules and regulations made by Landlord for Indian Springs Manor Mobile home Park, which rules and regulations, as currently in effect, are attached hereto and incorporated herein by reference ("Rules and Regulations"). The Rules and Regulations are covenants and conditions a this Lease, the same as if rutty set forth herein. Landlord shall furnish Tenant with notice of all changes in the Rules and Regulations. Tenant acknowledges receipt of a copy of such Rules and Regulations concurrent with execution of this Lease. 13. Applicable 14w: Attached hereto and incorporated by reference herein,. is a copy of a notice required by Pennsylvania Act 261 of 1976 ("Act''). In the event of any conflict between the provisions of this Lease and the Act, the Act shall control. Tenant acknowledges receipt of a copy of the notice concurrent with the execution of this Lease. 14. Insurance: Tenant shall at all times during the term of this Lease maintain adequate homeowners insutrant e, including at least $25,000 of Comprehensive Personal Liability cov-erage, and shall furnish the Landlord or his designee with evidence thereof upon request. 15. Default: The failure of Tenant to perform or observe any of the terms, covenants or conditions of this Lease shall constitute default by Tenant hereunder, 1(i. Remedies: Ln addition to any other remedies provided by law in the event of default of Tenant, 1:.andlord may, without notice, upon default, terminate the Lease and enter upon and take possession ofthe Premises. "Tenant hereby waives any right to notice under the Landlord and Tenant Act of 1951, as amended. 17. Notices: Any notice or consent required hereunder shall be in writing and shall be deemed given when delivered or deposited in the Ihnited States Mail, postage prepaid, certified mail, return receipt requested, addressed to the party at the address stated at the heading of this Lease. 18. Performance of Tenant's Obligations: Landlord shall have the right, but shall have no obligation, to pay any amount which Tenant has covenanted to pay hereunder and which Tenant shall fail to pay when due, and to make any repairs to the Premises which Tenant is obligated to make but has failed to do after notice by Landlord. Tenant shall reimburse Landlord for the amount of any payment so made by Landlord and the cost of any repair performed by Landlord immediately upon notice by Landlord to Tenant ofthe amount thereof. 19. Non -Waiver: The various rights and remedies ofthe Landlord expressed herein arc cumulative. The failure of Landlord to insi&t in any instance upon strict performance of any covenant ofthe Lease, ar to exercise any right, but the sante shall continue in full three and effect unless a contrary intention is expressed in writing by Landlord. P► No. 14- 415-1 20. Joint and Several Liability: Timcore than one person executes this Lease as Tenant, the liability of each shall be joint and several, and, in such event, notice given by Landlord to any such person, or by any such person to Landlord, shall bind all such persons. 21. Entire Agreement: This Lease, together with the Rules and Regulations, sets forth all of the promises, agreements, conditions and understandings between the parties relative to the Premises and supersedes any prior agreement between the parties. No subsequent alteration, amendment, change or addition shall be binding unless reduced to writing and signed by all parties. 22. miscellaneous: Tenant agrees that he has read this Lease, understands its terms and the Rules and Regulations, and agrees to be bound thereby. 23. Confession of Judgment: Tenant hereby irrevocably authorizes and empowers any attorney of any court of record within the United States of appear for Tenant and, with or without declaration filed, confess judgment against Tenant and in favor of Landlord, for the specific amount of rent or additional charges due by reason of any default or breach of this Lease and for costs of suit and an attorney's commission of ten percent (10%) of the amount due. Tenant further authorizes and empowers any such attorney, either in addition to or without such judgment of the specific amount due under this Lease, to appear for Tenant and for any other person claiming under, by or through Tenant, and confess judgment forthwith against Tenant and such other persons and in favor of Landlord, in an amicable action of ejectment for the premises. The entry of judgments under the foregoing warrants shall not exhaust the warrants but successive judgments may he entered thereon from time to time as often as default occur, 24. Sale of Mobile Home in Park: Landlord, in Landlord's reasonable discretion, must preapprovc the sale of any mobile in Indian Springs Manor Mobile Home Park if the purchaser(s) of the mobile home intend to remain in residence on the Premises. Any such approved purchasers shall he required to execute a new Lease. 25. Sale of Mobile You Own: If your home was originally purchased from the park or its affiliates or individual members, your home can not he removed from the park. Your purchase prices was below market value in order to fill the vacant pad. If your home is removed from the park, you and the new owner will be liable for all costs associated with the installation of your home. $5,000 for a single wide and $10,000 for a double wide. IN WITNESS WHEREOF. this Lease Agreement is executed as of the day and year first above written. WITNESS/ATTEST: VELOCITY PARTNERS, LLC Pt bio 1�- 14157 Prtntud Nam: Printed Naine By: By: By: TENANT(S) tia.vre n Printed Niun4 Printed Num PrinIM Waite Pi 11-1- 415-1 INDIAN SPRINGS MANOR MOBILE HOME PARK RULES AND REGULATIONS 1.. INSTALLATION, REMQVAL Mobile homes may be moved in or out only during favorable weather periods as may be mutually agreed upon between Landlord and Tenant. Mobiles originally purchased from park are subject to a S5,000 fee for a singlewide and a $10,000 fee for a doublewide in order to be removed. 2, PETS See attached Pet Regulations 3. SKIR`IING Mobile homes must be properly skirted with commercially manufactured skirting before Tenant occupies home, no wood. Proof of skirting must be shown before moving home into the park, and skirting must be kept in good repair at all times 4. SLEDS, DECKS, AWNINGS, STEPS, ADDITIONS, FENCES, ETC. All outside construction, including location and design, must he pre -approved by Landlord, whether or not the type of construction is addressed below. All such COnstrue&ion mus4 be professionally built and kept in good condition at all times. A. SHEDS: One outside shed is permitted, provided enough space is available. Sheds must be built of T111 grooved siding with an asphalt shingle, barn type roof Minimum size 8' x 8' - maximum 12' x 12'. Sidewalis may be a maximum of 8' high; provided that the shed may not exceed the height of the mobile home. Sheds must be painted or stained to match home and may only be placed at an approved location. B. DECKS AND STEPS: All exit doors from the home must have steps constructed of pressure treated lumber. A minimum deck size of 4' x 4' is req.. iced at the front entrance of each mobile home. The maximum deck width is 12'. All steps must have hand railings. Decks may not be enclosed in any manner. C. AWNINGS AND OTHER ADDITIONS: No homebuilt awnings or additions are permitted. D. FENCES: Fences are not permitted. NC: ii -1-415-1 5. GUESTS Guests who remain at the premises for a consecutive period of two weeks or longer will be considered a permanent resident resulting in a violation of your lease. Tenants are responsible for any and all actions of their occupants or guest. All Tenants, occupants, and guests must abide by the rules and regulations of the park. 6. MOTOR VEHICLES Two motor vehicles are allowed per lot. Others must be parked as posted, and may not obstruct traffic. All motor vehicles inside the park must be licensed and bear a current inspection sticker. Only automobiles and'. { ton or less trucks are permitted on park property. Repairing or overhauling of motor vehicles on park property is not allowed. No 4 -wheelers or dirt bikes are permitted in the park. Riding of aforementioned vehicles is prohibited in the park. The speed limit in- the sthe park is 10 MILES PER HOUR. 7 DETERGENTS Only biodegradable detergents may be used in the park. 8. WATER, SEWER Tenants own and are responsible for the maintenance of all water and sewer lines from the ground connection into and including the home. Plumbing hook-ups to park specifications are the responsibility of the Tenant. Heat tapes must be installed by the Tenants to prevent water freezing. TENANTS MAY NOT ALLOW WATER TO RUN THROUGH PIPES TO AVOID FREEZING. Automatic sprinklers are not permitted. Wading pools, a maximum size of 4 feet in diameter and 12" deep are permitted, and Tenant assumes all responsibility and liability therefore. Tenants must contact management betare entering outside water box at any time. Any expenses incurred by the management due to negligence of the Tenants in connecting or disconnecting water or sewer will be the sate responsibility of the Tenant. Tenants shall he solely responsible to maintain tight drains to the sewer outlet. Leaking spigots must be repaired immediately. Any water leaks may result in a temporary shut of of water. Do not flush anything that is not soluble down your commode or any other drain. Such items should be wrapped in paper and deposited in the garbage tan. Tenants shall be solely liable and responsible for all cost involved in sewer stoppages due to their failure to comply with the above. There must be a back flow preventer installed on your water line. Garbage disposals are not allowed. 9. ELECTRIC Tenants arc responsible for the hook-up and maintenance of all electric lines from the meter pedestal to the horse. Paget P2.. No: t4-415- 10. UTILITY SERVICES Tenants are responsible for arranging with the local utility providers, servicing the park for connections of gas, electric, telephone and cable. CAUTION: DO NOT DIG MOLES OR DRIVE STAKES IN THE GROUND FOR ANY REASON WITHOUT APPROVAi, OF PARK MAINTENANCE. Underground utilities damaged by failure to comply will be repaired at Tenants' expense. 11. SEWER: W_4TE'.R METERS (where appcable) Tenants minimum sewer rate of $40.00 per month will be billed along with water on a quarterly basis. Tenants minimum quarterly water charge is $60.44 per quarter. Water usage over 8000 gallons per quarter will be billed quarterly by the Landlord at the following rates: At the end of the quarter, any water used from &000 gallon up to 20.000 gallons will cost thc tenant $9.04 per thousand, anything 20.000 gallons and over per quarter will be billed at $10.00 per thousand. Water meters will be read once each quarter. Failure to pay water and sewer charges becomes thc same as past due rent as is spelled out is the Tenant lease. Late fee for not paying water or sewer bill will be $3 for ever day unpaid. Any increases in the charges by the water company or sewer authority will be passed onto the Tenant with a 30 day notice. Please. be advised that the Landlord reserves the rig it to hill water & sewer separately and shall not be considered an increase in rent. 12. CLOTHES LINE, NO ANTENNAS One umbrella type clothes dryer is permitted. No antennas of any kind are allowed. Satellite dishes are permitted but must be of the smallest size available and must be attached to the home. No large satellite dishes are permitted. 13. PROPANE All homes installed will have a minimum of 100 ib. Propane cylinder placed at rear of home_ No small propane tanks from gas grills are permitted to be attached to the home for heating purposes or indoor cooking purposes. 14. GARBAGE COLLECTION Garbage collection is not provided by the Landlord. Elealth Department regulations require garbage cans to have fly -tight lids. Garbage containers are to be stored to the rear of your home, out of sight as much as possible, until it is time to put it nut for pick-up. All trash should be placed inside the toter. Any garbage not fitting inside toter should be placed behind the home and out of sight of public. Trash should be bagged and arranged in an orderly manner. All cardboard and lumber should be baled and placed at back of home. Twine or rope should be used to bundle cardboard to prevent it from blowing around the park. 15-1 Page 3 15. CHILDREN Parents are responsible for any and all actions and or damages caused by their children or any visiting children. Children are not permitted to play in the service buildings, service areas, or any neighboring Tenants lots without permission. No one is allowed on private park. property, constructions sites, or any park equipment. No children should he walking through the park after dark_ Any injury sustained by children who are wandering through the park without parental supervision will be the responsibility of the parent or guardian. CURFEW: Any Township ordinance or curfews also apply to residents/children/guests of the park. 16. FIREARMS The firing or displaying of any gun, firearm of any kind or description, live ammunition, or bow and arrow, etc. on park property is strictly prohibited. No BB guns or air rifles allowed. No discharging of firecrackers 17. NOISE 'Tenants will permit no noise or disturbance to interfere with the rights of other Tenants to quiet and peaceful enjoyment of their premises. No loud radios, TV's, stereos, or parties will be allowed at any time. This includes loud stereos in vehicles while on park property. ix., SELLING- HOKE IN PARK The park office must he notified 30 days in advance, in writing, of your intentions to sdl your mobile home to purchasers who will remain in residence within the park. See 1.ease Agreement, paragraph 24. For sale signs may only he displayed inside the mobile home. 19_ TAXES Residents must pay all real estate taxes assessed and levied against the mobile home, and, upon the request of The park owner, must furnish proof of payment. The mobile imine may not be removed from the park unless all rent, fees, charges or assessments are paid to the end of the term. The park owner may prevent the removal of the mobile home to enforce this rule. 'Tenants are advised that prior to removing a mobile home from the park, a removal permit must be obtained from the local tax collector. A copy of this permit must be given to the Landlord before moving the home. 1.10: -415-7 Pae 4 20. YARD MAINTENANCE Tenants must keep their lawns mowed and trimmed on a regular basis, so that the grass or other ground cover, EXCLUDING shrubs, bushes and flowers, shall not exceed 3 inches in height. Accumulations of mowed grass shall be raked and removed. In the event a Tenant does not mow, trim or rake their lawn, the I .andiord has the right to mow, trim or rake Tenants lawn, and the Tenant will he billed and responsible for payment. 21. ABANDONM.IfNT OP HOME For any mobile home which is left abandoned in the park for a period of 30 (thirty) days, or more. The Landlord has the right to enter the home, to secure- any ecureany loose or movable appliances, furnishings, materials or supplies, and move the home to a storage area or other location. The Landlord will have no responsibility for safeguarding the mobile home or its contents. 22. COMPLAINTS All complaints from Tenants shall be in writing, dated and signed. Initially, complaints should be directed to the park manager. The park manager will forward all complaints of a serious nature to the Landlord. Tenants should not come to the management with complaints after office hours unless an emergency exists. Z. LOT NUMBERS All mobile homes must have the lot numbers displayed on the front of the home. Numbers shall he no less than 3" in height. The numbers shall be of contrasting color to the house and be clearly visible from the road. 24. CARE AND APPEARANCE The only items that can be stored outside are lawn furniture and/or lawn related items. No more than 3 days supply of heat burning word may he stored at any one time in front of home and only in the winter months. All ocher rimes. wood must be placed as much out of sight as possible. Outside toys must be kept in an orderly fashion. 25, SATEMJTF. DISHES Per state & local governtnents 26. OCCU PA NCV Occupancy of one mobile home situated on one lot is limited to (i) one (1) adult individual, whether married or not, (ii) two (2) single adult individuals of either the same or opposite sex; or (iii) two (2) adult individuals who are P2 No: 14-4(51 Page. 5 married. In addition, any children of any of the foregoing may reside with their parents, however, said parent or parents shall be related to such child or children by blood, adoption, or legal guardianship. All adults occupying a mobile home must, as a condition of tenancy, sign the Lease Agreement and any and all additional required documents in order to perfect tenancy. There shall be no other form of Tenant occupancy which included more than two (2) adult individuals residing together as a "unit" in any one (1) mobile home situated on any one (1) leased mobile home lot. Any exceptions must he approved by the manager. SIGNATURE OF TENANT SIGNATURE OF TENANT! SIGNATURE OF LANDLORD, or Representative P2 DATE 601a1/43 DA r' Ido'_ I4-4(51 Cci. 29. 2(3 h 3I PM REMAX REALTY AGENCY O. 5 j9 E.. INDIAN SPRINGS MANOR MOBILE HOME PARK RULES AND REGULATIONS 1, INSTALLATION, REMOVAL Mobile homes may be moved in or out only during favorable weather periods as may be mutually agreed upon between Landlord and Tenant. Mobiles originally purchased from park are subject to a 55,000 fee for a singlewide and a S10,000 fee for a doublewide in order to be removed. 2. PETS Please see management before bringing a pet into the park. See attached Pet Regulations - NO Pitbulls, German Shepherds, Rottweilers, Doberman. Pinschers, Fila Brasilieros, Cane Corsos, Mastiffs, Cane Presario,, Dalmatians, Great Danes, and any and all mixes or delineations of these dogs are permitted in the park. NO constricting and/or poisonous snakes are permitted in the park, NO alligators or crocodiles are permitted in the park, 3. OUTSW1i CATS All outside cats will be humanely trapped and removed from park premises. Anyone feeding these animals is considered the owner of such animal and is, therefore, legally responsible for all damages by such animal. All issues of damages must be in written form to management and appropriate steps to rectify the situation will be taken. 4. SKIRTING • Mobile homes must be properly skirted with commercially manufactured skirting before Tenant occupies home, no wood. Proof of skirting rntust be shown before moving home into the park, and skirting must be kept in good repair at all times. All homes purchased from other sources and moved into the park are required to have skirting installed within 64 days of entering park promises. 5, SHEDS, DECKS, AWNINGS, STEPS, ADDITIONS, FENCES, ETC. All outside construction, including location and design, must be pre -approved by Landlord, whether or no the type of construction is addressed below. All. such construction must be. professionally built and kept in good condition at all times, A. SHEDS: One outside shed is permitted, provided enough space is available. Sheds must be built of T111 grooved siding with an asphalt shingle, barn type roof. Minimum size 8' x 8' - maximum 12' x 12'. Sidewalls may be a maximum of 8' high; provided that the shed may not exceed the height of the mobile home. Sheds must be painted or stained to match home and may only be placed at an approved locution. Page 1 INDIAN SPRINGS MANOR MOBILE HOME PARK RULES AND REGULATIONS INSTALLATION, REMOVAL Mobile homes may be moved in or out only during favorable weather periods as may be mutually agreed upon between Landlord and Tenant. Mobiles originally purchased from park are subject to a $5,000 fee for a singlewide and a $10,000 fee for a doublewide in order to be removed. 2. PETS Please see management before bringing a pet into the park. See attached Pet Regulations - NO Pitbulls, German Shepherds, Rottweilers, Doberman Pinschers, Fila Brasilieros, Cane Corsos, Mastiffs, Cane Presarios, Dalmatians, Sharpei, Chow Chows, Great Danes, and any and all mixes or delineations of these dogs are permitted in the park. NO constricting and/or poisonous snakes are permitted in the park. NO alligators or crocodiles are permitted in the park. 3. OUTSIDE CATS All outside cats will be humanely trapped and removed from park premises. Anyone feeding these animals is considered the owner of such animal and is, therefore, legally responsible for all damages by such animal. All issues of damages must be in written form to management and appropriate steps to rectify the situation will be taken. 4. SKIRTING Mobile homes must be properly skirted with commercially manufactured skirting before Tenant occupies home, no wood. Proof of skirting must be shown before moving home into the park, and skirting must be kept in good repair at all times. All homes purchased from other sources and moved into the park are required to have skirting installed within 60 days of entering park premises. Skirting not installed on homes after tenant has moved in will cause Tenant to incur a $10/day charge until skirting has been installed and approved by park management. 5. SHEDS, DECKS, AWNINGS, STEPS, ADDITIONS, FENCES, ETC. All outside construction, including location and design, must be pre -approved by Landlord, whether or not the type of construction is addressed below. All such construction must be professionally built and kept in good condition at all times. Page 1 Pz No'.1 -4i5-i A. SHEDS: One outside shed is permitted, provided enough space is available. Sheds must be built of T111 grooved siding with an asphalt shingle, barn type roof. Metal sheds are acceptable but must be pre -approved by park management. Minimum size 8' x 8' - maximum 12' x 12'. Sidewalls may be a maximum of 8' high; provided that the shed may not exceed the height of the mobile home. Sheds must be painted or stained to match home and may only be placed at an approved location. 13. DECKS AND STEPS: All exit doors from the home must have steps constructed of pressure treated lumber. A minimum deck size of 4' x 4' is required at the front entrance of each mobile home. The maximum deck width is 12'. All steps must have hand railings. Decks may not be enclosed in any manner. C. AWNINGS AND OTHER ADDITIONS: No homebuilt awnings or additions are permitted. D. FENCES: Fences are not permitted to encompass the entire lot, however, pet fences are permitted and must be approved by park management prior to installation. 6. GUESTS (INITIAL RULE #6 THAT YOU HAVE READ AND UNDERSTAND) Guests who remain at the premises for a consecutive period of one week or longer will be considered a permanent resident resulting in a violation of your lease. Tenants are responsible for any and all actions of their occupants or guest. All Tenants, occupants, and guests must abide by the rules and regulations of the park. Any person who has created or who creates a problem within park confines, is not permitted therein. The park is private property, as are the streets within, and therefore, the Landlord and management retain the right to have any person(s) removed from the premises without issuance of a violation document. Violation documents will be issued for any and all indiscretions by guest/visitors and given to park tenant. 2 violations within 6 months can lead to further actions from the Landlord. NO person/persons shall wander throughout the park for the sole purpose of inciting fear or for the purpose of endangering the sanctity of the other Tenants. No one should be peering into the homes of others. Respect your neighbors. Management will be addressing any reports of harassment with the Landlord and legal authorities. Page 2 Pz. i.10‘. W-14(57 7. MOTOR VEHICLES Three motor vehicles are allowed per lot. Others must be parked as posted, and may NOT obstruct traffic. All motor vehicles inside the park must be licensed and bear a current inspection sticker. Only automobiles and % ton or less trucks are permitted on park property. Repairing or overhauling of motor vehicles on park property is NOT allowed. NO 4 -wheelers or dirt bikes are permitted in the park. Riding of aforementioned vehicles is prohibited in the park. The speed limit in the park is 10 MILES PER HOUR. NO RV's are allowed within the park. NO visiting RV's are permitted. 8. DETERGENTS Only biodegradable detergents may be used in the park. 9. CLOTHES LINES One umbrella type clothes dryer is permitted. 10. PROPANE All homes installed will have a minimum of 100 lb. propane cylinder placed at rear of home. NO small propane tanks from gas grills are permitted to be attached to the home for heating purposes or indoor cooking purposes. 11. GARBAGE COLLECTION Garbage collection is not provided bv the Landlord. Health Department regulations require garbage cans to have fly -tight lids. Garbage containers are to be stored to the rear of your home, out of sight as much as possible, until it is time to put it out for pick-up. All trash should be placed inside the toter. Any garbage not fitting inside toter should be placed behind the home and out of sight of public. Trash should be bagged and arranged in an orderly manner. All cardboard and lumber should be baled and placed at back of home. Twine or rope should be used to bundle cardboard to prevent it from blowing around the park. NO COMPOST BINS. 12. SEWER & WATER METERS Tenants' minimum sewer rate of $40.00 per month will be billed along with water on a quarterly basis. Tenants' minimum quarterly water charge is $60.00 per quarter. Water usage per quarter will be billed quarterly by the Landlord at The following additional rates: at the end of the quarter, any water used from Mpkgallons up to 20,000 gallons will cost the Tenant $9.00 per thousand, anything $20,000 gallons and over per quarter will be billed at $10.00 per thousand. Water meters will be read once each quarter. Failure to pay water and sewer charges becomes the same as past due rent. Late fee for not paying water and/or sewer bill will be $3.00 for every day unpaid. Any increases in the charges by the water company or sewer authority will be passed onto the Tenant with a 30 day notice. Please be advised that the Landlord reserves the right to bill water and sewer separately and shall not be considered an increase in rent. Page 3 P2_ pc)%14-1-1151 13. CHILDREN Parents are responsible for any and all actions and or damages caused by their children or any visiting children. Children are not permitted to play in the service buildings, service areas, or any neighboring Tenants lots without permission. No one is allowed on private park property, constructions sites, or any park equipment. NO children should be walking through the park after dark. Any injury sustained by children who are wandering through the park without parental supervision will be the responsibility of the parent or guardian. NO children should be riding bicycles or any other type of riding toy on the lots of other tenants. Children are prohibited from removing anything from the property of another tenant without permission from the tenant. CURFEW: Any Township ordinance or curfews also apply to residents/children/guests of the park. **Definition of children — A child is known as a child until 18 years of age. At 18 year of age, a child is considered an adult. 14. FIREARMS The firing or displaying of any gun, firearm of any kind or description, live ammunition, or bow and arrow, etc. on park property is strictly prohibited. NO BB guns or air rifles allowed. NO discharging of firecrackers. 15. NOISE Tenants will permit NO noise or disturbance to interfere with the rights of other Tenants to quiet and peaceful enjoyment of their premises. NO loud radios, TV's, stereos, or parties will be allowed at any time. This includes loud stereos in vehicles while on park property. Quiet time shall begin at 8:OOPM and will end at 8:OOAM the following morning. 16. YARD MAINTENANCE Tenants must keep their lawns mowed and trimmed on a regular basis, so that the grass or other ground cover, EXCLUDING shrubs, bushes and flowers, shall not exceed 3 inches in height. Accumulations of mowed grass shall be raked and removed. In the event a Tenant does not mow, trim or rake their lawn, the Landlord has the right to mow, trim or rake Tenants lawn, and the Tenant will be billed and responsible for payment. NO mowing of another tenant's property shall occur without advance notice of such to park management. NO mowing after 8:OOPM or before 8:OOAM. Violations will result in documentation to Landlord. 17. SNOW AND ICE Each Tenant is responsible for removing snow and ice from walks around his or her home site and parking area. Snow may NOT be shoveled into the street. Page 4 Na. (14-L1(5-1 18. COMPLAINTS All complaints from Tenants shall be in writing, dated and signed. Initially, complaints should be directed to the park manager. The park manager will forward all complaints of a serious nature to the Landlord. Tenants should not come to the management with complaints after office hours unless an emergency exists. 19. LOT NUMBERS All mobile homes must have the lot numbers displayed on the front of the home. Numbers shall be no less than 3" in height. The numbers shall be of contrasting color to the house and be clearly visible from the road. 20. CARE AND APPEARANCE The only items that can be stored outside are lawn furniture and/or lawn related items. No more than 3 days supply of heat burning wood may be stored at any one time in front of home and only in the winter months. All other times, wood must be placed as much out of sight as possible. Outside toys must be kept in an orderly fashion. 21. SATELLITE DISHES, NO ANTENNAS NO antennas of any kind are allowed. Satellite dishes are permitted but must be of the smallest size available and must be attached to the home. NO large dishes are permitted. Small dishes are permitted and MUST be professionally installed by a reputable company. 22. BURN PITS Burn pits are permitted but MUST be a professionally manufactured burning receptacle which has a screen covering over the top. Tenants are NOT permitted to burn trash or rubbage of any sort in the pit. The burn pit is solely permitted to burn wood and all pits must be extinguished by 9PM. NO person shall have the right to have a party environment around the burn pit, which includes NO music, drinking in public or loud noise of any sort. Page 5 P2_ N6'.i'4-415-7 23. OCCUPANCY (INITIAL RULE #23 THAT YOU HAVE READ AND UNDERSTAND) Occupancy of one mobile home situated on one lot is limited to (i) one (1) adult individual, whether married or not, (ii) two (2) single adult individuals of either the same or opposite sex; or (iii) two (2) adult individuals who are married. In addition, any children (children are defined as a child until the age of 18 years old. At 18 years old, a child is considered an adult) of any of the foregoing may reside with their parents, however, said parent or parents shall be related to such child or children by blood, adoption, or legal guardianship. All adults occupying a mobile home must, as a condition of tenancy, sign the Lease Agreement and any and all additional required documents in order to perfect tenancy. There shall be no other form of Tenant occupancy which included more than two (2) adult individuals residing together as a "unit" in any one (1) mobile home situated on any one (1) leased mobile home lot. Any exceptions must be approved by the manager. All occupants of any dwelling must be listed on the lease. Anyone not on the lease must vacate the property. This is a safety issue. Management has the right to have any visitor removed from premises. All persons 18 years old and older within the home must have passed a background check and must be listed on the lease. All persons will be background checked before tenancy is granted. Any person or persons who have been removed from the park for any reason or who have caused issues in the park will not be permitted within or on park property. SIGNATURE OF TENANT DATE SIGNATURE OF TENANT DATE SIGNATURE OF LANDLORD, or Representative Page 6 Pa ‘. ILI- 4( 5 -1 AMENDMENT TO RULES AND REGULATIONS: All mobile home payments will be considered rent upon any default of lease and enforceable under Landlord Tenant disputes. AMENDMENT TO RULES AND REGULATIONS: Velocity Partners, LLC is NOT responsible for sinking mobile homes. AMENDMENT TO RULES AND REGULATIONS: Velocity Partners, LLC is NOT responsible for exterior maintenance or damage of a home due to natural or unnatural elements IE: failing trees or limbs, freezing, flooding, fires, tornados, wind. etc. AMENDMENT TO RULES AND REGULATIONS: The MHP may take self-help action to terminate water, sewer, gas, or electric services to any mobile home upon notice of a leak or hazardous situation. Upon termination of service from a leak, service will not be restored until proof leak has been repaired. Page 7 (Revised 7-9-2014) P2 - N v'. 11-i- y r s 1 PET REGULATIONS HAVING A PET IN THE PARK IS A PRIVILEGE THAT WILL BE REVOKED IF THE FOLLOWING REGULATIONS ARE NOT FOLLOWED. PETS THAT BECOME A NUISANCE TO OTHERS WILL NOT BE TOLERATED You MUST clean up any droppings that are left by your pet immediately after the droppings are let, not after they accumulate 2. Whenever your pet is outside of your home, it must be on a hand-held leash. Pets may not run free at any time. You must be physically outside supervising your pet whenever the pet is outside. Pets may not be tied or otherwise left outside of your home or anywhere else in the Park. 3. No outside pet houses are permitted 4. Pet fences are permitted but must be approved by management prior to installation. 5. Excessive barking outside or inside of your home that disturbs your neighbors will not be tolerated. 6. ALL PETS MUST BE REGISTERED WITH THE PARK OFFICE. The information necessary to register a pet is listed below. Anyone bringing an unacceptable dog breed into the park will be required to have said animal DNA tested to prove lineage. Owner of said animal will be responsible for DNA test costs. Dog will NOT be permitted within park confines until DNA test results proving dog is an acceptable breed are received by park management arid Velocity Partners, LLC. 7. ABSOLUTELY NO "visiting" pets are allowed at any time. 8. Any pet that is required to have a license must have such license and must wear its current license tag at all times. All dogs are required to be licensed with the courthouse. All information regarding licensing should be copied and a copy is to be registered with the park manager. 9. All pets are required to be current on rabies vaccinations. The park manager should be given copies of rabies vaccination paperwork. 10. Any pet which has displayed a propensity to attack either human beings or other animals without provocation, and any dog which has been determined to be a "dangerous dog" under the provisions of the "Dog Law" of Pennsylvania, 3 P.S. 4559-101, et seq., shall be considered an "aggressive animal" and shall not be permitted in the Park for any purpose at any time whatsoever. P 7\10 - 14(5.1 11. NO MORE THAN TWO DOGS PER RESIDENCE. Only one large dog permitted in addition to a small dog or two small dogs. TYPE OF PET: BREED SIZE: AGE WEIGHT HEIGHT TYPE OF PET: BREED SIZE: AGE WEIGHT HEIGHT By signing below, I hereby certify that all of the above information is true and correct to the best of my knowledge. TENANT: DATE: LANDLORD or Representative: DATE: (Revised 7-9-2014) NO i4- 41 5-1 P3 NN. tL+ yr5 r ti/2C14 000006501077034 Thi ii LIOAL COPY at you them& You On 01 urn. wily pod *oat ths original cheek. eitiNY P5 ra4 • fon rrl t -S4 ▪ re. en(11 pal PR t:1 rk 1-11 • rza a. C3 c:9 ocz, ru n.1 , , c;t:0 1607&15011 aat1116111.0511 BRANDY MURRELL is "0%04 R. SHIP"ENSOURc, PA 1Y357 4111111011.11Ve ' " 110$11401 ' 1006 gilt 0 /41 Ait $ 1p 011 41:03G076145046254468405e11006 1000,10032500#0 Nos, N.- 14t5"/ 1 6' A..V 17 V it LI!in/' I\L1L I nV LIVV 1 140, VELOCITY PARTNERS, LLC 418 EPIC DRIVE CHAMBERSBURG, PA 17201 July 21, 2014 Brandy Hurrell 15 Apache Drive Shippensburg, Pa 17257 RE. INSUFFICIENT FUNDS — ACCT #6239468405 - $565.00 Dear Brandy, Thank you for your payment on July 1, 2014 (check #1014 for the amount of $56500). Unfortunately, it was returned to us for insufficient funds, Please send us the full payment, plus $50.00 service fee for the returned check by July 31, 2014. If you have any questions, please contact Jill Mellott @ (717) 709-70661 Thank You Velocity Partners, LLC No t-1-4(5"7 Hug. 1, LV !4 0: 31AM ttt! I A KtAL ! Y AGtNI;Y ►� M&T Bank Understanding what's important' VELOCITY PARTNERS LLC 418 EPIC DR CHAMBERSEURG PA 1720 ? -2887 Dear Customer: No. Tit Pftt t'a Quicklime: Bealo (716) 626.19e0 Outside Of The Buffalo Area (800) 724-2440 AMOUNT OF CHECK(S) RETURNED S 565.00 NUMBER OF ITEMS DATE 07-11-14 Your account, number 9850361370, has been charged for the total value of the following items which were deposited and subsequently returned for the reasons indicated below. Fees ir.curred as a result of these transactions will be reflected in your monthly service charges, If you have any questions, please contact your relationship manager or call QuickLine at the phone number listed above. The items on the subsequent pages of this communication are legal copies of check(s) you deposited into your accoant that were returned to us unpaid. You may use these legal copies of the check(s) the lama way you would use the original check(s), If you wish to re -negotiate (e.g„ re -deposit or cash) these Items, please carefully separate them along the perforated llnes. DETAILED LISTING OF RETURNED DEPOSITED ITEMS •'i •i L' ?� z IIII nr. !��f;.:i.:.!!, •7 ..!• •x• • • ..:� • -:{..,7.7....1 :I 44 7 �t:.ili{ ii(i'S•"!�:Iri: A.rr„r.. ix . 1 , . •• x :�'•(.i y �'` .:' ,r.rr..,.,,. tyI?p!...w : ..... I:. .i»•,!L:. 74' I:;'n:•' Sf S• �' ,.,,; , ..I:' kl.%f :fI ���•':Iri ;,: ' x:ra•.,,; :. xa• r.,r:. ,. p•r •. nv.,-. I.Y.r n. u,.; •n•ua; „• ,•..71'I .r;:; Ly_y!;. r.n..,. .. 1 1 ... ..... yl r.:,ruc I:n:.:, i YV .'4 n „i.,..•„ .7,I I i , i : I:>!: ra .,,•,,: xu. liaa .:: ••.r.:•I.. I,' II,,..I ..q,. i;.::,.r.:.!.........'1.......9.;i,L,xay!nu:u.l:'Gu'vl!vu::,,,..... �1, :�aJY ., y ' ..11 r i �"i r �' ••x .,.� .0 i.y , •, •r�rii i';�•; s,x :r ti I . I it •yii. 1161�''I i r I. Illi ' "i�TT•T 7Jr' h1.7:L°'''l,:f 4rl .., nn r r•'. . �iaa ,:.•,,: ,�r .�, .p .ii,,.rn �:1:. 'Ii '.11.. :P:'... _. "}r �.• in.•,•, �,., r•!� ' I. , 070914 5563.00 NSF 0038001315 j 03607613 6239468405 2116739 PAGE 1/1 VR96EN03 Na`. (L -L4(5 Aug. n144, 8:33AM 07/11/2014 0000065C8160532 rti* * t.P.CAL COPY your Onerek `to:, *an Lao It the sere Way YO. WOW tr* arigftg theek. ral ru BRANDY HURRELL is ApAcHE OR. 0$ , sHireesuRc, PA 1P2iNr7 174 En3 1 1:2 cl I (Si Eci • ru ru cat i 60 ? 6 1 501: REMAX REALTv AGENCv .f; 25 F. 4 #1400...e•yoglillaiMashap/WOrdiheadwitu •• o • Es a leo WPM ---------,. 3.70i11-11110 • PAY tc the o de 1014 j $ 5405, " 6EA 15 cm PINNS'Ad afirodi.g, 6 2 3941410So '440360 7G 046 d 194684C S4.10 A e00000 SE, SOW NAol 1-4 (4- (5 1 hi /hu/ jJ >9hi= fO< sommimem44110 S'tE'[©QVE[IUIlDLU h1E2/TC/LO 9h0000220 P rlb i4 - -t51 Ps' Nci. i4 -'4t5 N� fL4L4(57 r to zJ ......-..... VELOCITY PARTNERS, LLC 418 EPIC DRIVE CHAMBERSBURG, PA 17201 Tenant name: Brund.y_ Hi-.rre-i Tenant address: 15 Apc_tri, Dr%ve , Sfn; ppensbu c., PA inQS1 You are receiving this notification because you have violated a park rule/regulation. The violation(s) is/are as follows: t • Pi+hc.et..tt puce - v‘totcifice or t cw ru tes card cats cis., t uSt be roved -Ero gra pore t► i d ; me:! }P'e4- . not- -Fe re L ittpc:1ric.Gf6Ce. 4� , pe -Fs tet-tr-excci OLLt5lac {-cam' of �.mc cz r1d Ur\ C ttcrdcci 4. ft-rr A \/nvd - hCrtar-ck such cts -Fish fietrrkS Oct,+ Si cl - c_ In (tc1 F -c to CO u l d hu r+ #-lntti-v‘cc ivc s, f v- os cr, (.0 1:) pr 2 Vii. t Cv \ ctrct The lease and park rules/regulations of this mobile home park constitute a contractual agreement between you and the landlord. Be aware that election proceedings can be forthcoming if you choose to not honor your part of the contract. Date: ..Mq/q, cath 4 Signature of park representative: Pow k NACiagfir tsars lvtt_tr etcrr SCotce- Lc) Mr. t t-trrctI or\ -rhuxScieny May (cvCiCc tt c'lv9 o± bttpct C_W\ CaC O\it d hye eC . 5.0i 4 CC'. ' i V carnCF s NittOrTici sl i t t Me_i tott Part files H KIO'. t 4- c4 t 5-i VELOCI1Y PARTNERS/ LLC 418 EPIC DRIVE CHAMBERS8URGi, PA 17201 Tenant name: 17^.rcand. 14 LI re -t t Tenant address: 115 Ape -A aVe. i7, s vc_. Stnopp sburr PA 11251 a_teNCI caif> Spv iB Nie cA- MOVN t e. H orv'e.. �'c tu- You are receiving this notification because you have violated a park rule/regulation. The violation(s) is/are as follows: C�LA 4 4 vac .cls:, vse-.c��rc. i Get i-cz.) +c: ( Vc: PLie 1py timed io be_ re iSe rrd i/�tit 1n (�c-av-�.. fi 6.a The lease and park rules/regulations of this mobile home park constitute a contractual agreement between you and the landlord. Be aware that ejection proceedings can be forthcoming if you choose to not honor your part of the contract. Date: Herm l ., aU1.4 Signature of park representative: &. k-i/A.Cl.t(,t,L Pot, Mc tr\e_.c f` e ' TcY\R Mc fc (-1 i l t Mel tc Gff'tc -Ft IeS D(2 ►�:rLL 4-(S7 VELOCITY PARTNERS, LLC, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. : NO. 14-4157 JUSTIN HURRELL and : CIVIL ACTION- LAW BRANDY HURRELL ,-' • 0-1 cn Defendant : Appeal from Magisterial District JudgeK?:,. : Landlord/Tenant Judgment •P' .74s <,77: DEFENDANT'S ANSWER TO THE PLAINTIFF'S COMPLAINT And now, comes the Defendant, by and through her attorney, Jaime M. Haley Esq., and MidPenn Legal Services and files this Answer to Plaintiff's Complaint as follows: 1. Admitted. 2. Admitted. 3. Defendant has no independent knowledge if the Plaintiff has been the legal owner of the land where Defendant resides. 4. Admitted. 5. Admitted. 6. Admitted in part and denied in Part. Defendant admits to falling behind on rental payments in June 2014. Defendant contacted the owner in an attempt to work out an acceptable payment arrangement to get current prior to the MDJ hearing. Defendant sent two rent checks to Plaintiff in July, and one of the two checks remains outstanding and awaiting reimbursement, however rent for July has been paid. Defendant's rental payments have been, and will continue to be paid in a timely fashion into the Prothonotary's escrow account. 7. Admitted. 8. Admitted in part and denied in part. Defendant admits to being notified regarding clutter only once. In May 2014, Defendant promptly complied with Plaintiff's request to remove items from the yard. 9. Admitted in part and denied in Part. Defendant admits to bringing a lab/ boxer dog into the home. Defendant's dog has been vaccinated, and Defendant is in the process of obtaining a license for the dog. Defendant approached the park management's secretary, Jill to secure permission to keep the dog in the home, and Jill gave Defendant permission. 10. Admitted 11. Admitted in part and denied in Part. Defendant's dog is a lab/ boxer mix, not a pit bull. Defendant approached the park management's secretary, Jill to secure permission to keep the dog in the home, and Jill gave Defendant peiisiission. Defendant cleans up the dog excrement outside, and Defendant accompanies the dog when the dog is outside. 12. Admitted in part and denied in Part. Defendant admits to being issued a violation notice in May 2014. Defendant denies receiving a violation notice in March 2014. COUNT I — IN EJECTMENT 13. No response required. 14. Denied. Defendants have made their best efforts to comply with the Lease Agreement and Park Rules. 15. Admitted in part and denied in Part. Defendant admits to falling behind on rental payments in June 2014. Defendant contacted the owner in an attempt to work out an acceptable payment arrangement to get current prior to the MDJ hearing. Defendant sent two rent checks to Plaintiff in July, and one of the two checks remains outstanding and awaiting reimbursement, however rent for July has been paid. Defendant's rental payments have been, and will continue to be paid in a timely fashion into the Prothonotary's escrow account. 16. Admitted. WHEREFORE, Defendant respectfully requests that this Honorable Court enter judgment in favor of Defendant and against Plaintiff. COUNT II — BREACH OF CONTRACT 17. No response required. 18. Denied. Defendant has not caused physical damage to the Lot. 19. Admitted in part and denied in Part. Defendant admits to falling behind on rental payments in June 2014. Defendant contacted the owner in an attempt to work out an acceptable payment arrangement to get current prior to the MDJ hearing. Defendant sent two rent checks to Plaintiff in July, and one of the two checks remains outstanding and awaiting reimbursement, however rent for July has been paid. Plaintiff's late fee of $15 per day is an unreasonable amount. 20. Denied. Defendant has not and will not cause physical damages to the premises. Defendant's rental payments have been, and will continue to be paid in a timely fashion into the Prothonotary's escrow account. WHEREFORE, Defendant Respectfully requests that this Honorable Court enter judgment in favor of Defendant and against Plaintiff Respectfully submitted, 01,64-4-ke gime M. Haley, Esquire MidPenn Legal Services 401 East Louther Street, Suite 103 Carlisle, PA 17013 (717) 243-9400 ext. 2513 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of perjury of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: Bra rre 1, Defendant VELOCITY PARTNERS, LLC, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-4157 • : CIVIL ACTION- LAW vs. JUSTIN HURRELL and BRANDY HURRELL Plaintiff Defendant : Appeal from Magisterial District Judge : Landlord/Tenant Judgment CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of the foregoing Defendant's Answer to Plaintiff's Complaint was served this day by U.S. First Class Mail, postage prepaid, upon the following: (c4 Velocity Partners, LLC 418 Epic Drive Chambersburg, PA 17201 aime M. Haley, Esquire Attorney for the Defendant MidPenn Legal Services 401 East Louther Street, Suite 103 Carlisle, PA 17013 (717) 243-9400 ext. 2513 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VELOCITY PARTNERS, LLC, Plaintiff NO.: 14-4157 V. JUSTIN HURRELL and BRANDY HURRELL Defendants CIVIL ACTION -LAW PETITION FOR THE RELEASE OF FUNDS FROM COURT ORDERED ESCROW Thomas Mongold, Partner of Velocity Partners, LLC, 418 Epic Drive, Chambersburg, PA, 17201, by and through himself and on behalf of the Indian Springs Manor Mobile Home Park of Shippensburg, PA 17257, petitions this Court for the entry of an Order approving the disbursement of $1,950 (one -thousand nine hundred and fifty dollars), payable to Velocity Partners, LLC from a court appointed escrow fund for Justin and Brandy Hurrell of 15 Apache Drive, Shippensburg, PA 17257. A request for ongoing release of escrowed funds as applicable until the resolution of the aforementioned Civil Action in Law is also requested. Respectfully submitted, Thomas Mongold, Velocity Partners, LLC 418 Epic Drive, Chambersburg, PA 17201 IN T11t COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Pcirtr‘cr5 Plaintiff NO. 14-1-115-1 CIVIL TERM VS (--) r--, = c=5 JuSi-in 1-i LAr rct I 44 rd -3- -- cf.? ....,,, BrzAry:lv H urreIi(— : 7- rn Defendants= — r_ cp. _ —< Xr.-- cri RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in the following form: > c = = c . ..._ — _ THE PE 1111.0N FOR APPOINTMENT OF ARBITRATORS --- TO THE HONORABLE, int JUDGES OF SAID COURT: 51-F1 Vet Oc2it.v Pcirtv-Ncrs, , counsel for the plaintift7defoadant in the above action (er--aettefts), respectfully represents that 1. The above -captioned action (or-aatiens) is (we) at issue. 2. The claim of plaintiff in the action is $ q t51c. The counterclaim of the defendant in the action is ror The following attorneys arc interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Lcc Srvcs,Jory\i e kcIty , esc€, WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respec *tted, nnovvv_As KAorN -0 Ic-1 ccit Pvt. ORDER OF COURT , LLC - AND NOW, , 20 , in consideration of the foregoing petition, Esq., and Esq., and Esq., are appointed arbitrators in the above captioned action actions) as prayed for. By the Court, KEVIN A. HESS, P.J. 64sk P tria 4 3 10'7