Loading...
The URL can be used to link to this page
Your browser does not support the video tag.
Home
My WebLink
About
14-5520
COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL Judicial District, County Of FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT YV1 p.. COMMON PLEAS No. NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District Judge on the date and in the case referenced below. NAME OF APPELLANT MAG.DIST.NO. NAME OF MDJ l (i �vq- - Y' I M tC,� r+l IPCODE D ESS OF APPELLANT CITY STATE Z 1 cO �Ili Me 0 t C3 M pI DATE OF JU GMENT IN THE CASE OF(Plaintiff) ., (Dere t)' q 20� ���1� ��5 t4t� DOCKET No. I SIGNATURE OF APPELLANT OR ATTORNEY Y'�)'3 - 0q30c-7, - I - (Do �2-26tll 2��l�41- f This block will be signed ONLY when this notation is required under Pa. If appella t was Claimant (see Pa. R.C.P.D.J. No. 1001(6 action R.C.P.D.J.No. 1008B. This Notice of Appeal, when received by the Magisterial District Judge, will before a Magisterial District Judge, A COMRL-AINTrMUST:.BE FILED operate as a SUPERSEDEAS to the judgment for possession in this case. within C twenty ` (20)days after filing the NOTICE of APPE M � signFlureofProthonotaryorDeputy (1) PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE -� ,c (This section of form to be used ONLY when appellant was DEFENDANT(see Pa.R.C.P.D.J. No, 1001(7) in actio-bWor Magisterial District Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. 1 _ PRAECIPE: To Prothonotary `7—r03 yy�0 �� e Hcr � krVI" Enter rule upon appellee(s),to file a complaint in this appeal Narne of appellee(s) (Common Pleas No.J ,. JS�� )within twenty(20)days after service of rule or suffer entry of judgment of non pros. (.� ;7,4r�, Lam/ Signature of appellant or attorney or agent 0 RULE: To #OrkU j 4I"� appellee(s) Name of appellee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty(20)days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. Date: 10/l/, N 1 N VAl)S N N 3 d Signature of Prothonotary or Deputy M.Nrjoo ti V��-30 VJ- �b��s•6 YOU MUST INCLUDE A COPY OF THE V T3CPIbF BgQQV ',,TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. I1S.�p pet• °Alain AOPC 312-05 �,�J , : -'j--C-1 �� 311/ COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript COUNTY OF CUMBERLAND Residential Lease Mag. Dist. No: MDJ-09-3-05 Trebor Mobile Home Park MDJ Name: Honorable Mark Martin V. Address: 507 North York Street Christopher Sanderson, Nicki Sheryl Mechanicsburg, PA 17055 Hockenberry Telephone: 717-766-4575 Nicki Sheryl Hockenberry Docket No: MJ-09305-LT-0000132-2014 967 W. Trindle Road Case Filed: 8/29/2014 Lot 13 Mechanicsburg, PA 17055 Disposition Details Grant possession. Yes Grant possession if money judgment is not satisfied by the time of eviction. No Disposition Summary (cc-cross complaint) Docket No Plaintiff Defendant Disposition Disposition Date MJ-09305-LT-0000132-2014 Trebor Mobile Home Park Christopher Sanderson Judgment for Plaintiff 09/08/2014 MJ-09305-LT-0000132-2014 Trebor Mobile Home Park Nicki Sheryl Hockenberry Judgment for Plaintiff 09/08/2014 ..... Judgment Summary. . .W. . ..... . ,.,.-.... _... .. ,. .,___... .._._. _M . .,___._. ......�..�_......._., ._.. ...... ... ..... Participant Joint/Several Liability Individual Liability Amount Christopher Sanderson $3,393.71 $0.00 $3,393.71 Nicki Sheryl Hockenberry $3,393.71 $0.00 $3,393.71 Trebor Mobile Home Park $0.00 $0.00 $0.00 Judgment Finding (*PostJudgment) In the matter of Trebor Mobile Home Park vs. Christopher Sanderson; Nicki Sheryl Hockenberry on MJ-09305-LT-0000132-2014, on 9/08/2014 the judgment was awarded as follows: The amount of rent per month,as established by the Magisterial District Judge, is$350.00 Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Rent in Arrears $3,230.97 $0.00 $3,230.97 Filing Fees $162.74 $0.00 $162.74 Grand Total: $3,393.71 Portion of judgment for physical damages arising out of residential lease: $0.00 MDJS 315A Page 1 of 3 Printed:09/09/2014 10:09:05AM Trebor Mobile Home Park V. Docket No.: MJ-09305-LT-0000132-2014 Christopher Sanderson, Nicki Sheryl Hockenberry IN AN ACTION INVOLVING A RESIDENTIAL LEASE,ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURT OF THE COURT OF COMMON PLEAS,CIVIL DIVISION. AN APPEAL MUST BE FILED WITHIN THIRTY DAYS IN RESIDENTIAL LEASE ACTIONS INVOLVING A VICTIM OF DOMESTIC VIOLENCE. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT,IF ANY. IN ORDER TO OBTAIN A SUPERSEDEAS,THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED.HOWEVER,LOW-INCOME AND/OR SECTION 8 TENANTS SHOULD REFER TO Pa.R.C.P.M.D.J.NO. 1008 OR 1013 FOR DIFFERENT PROCEDURES REGARDING THIS DEPOSIT. IF A PARTY WISHES ONLY TO APPEAL THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE,THE PARTY HAS 30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS OF THE COURT OF COMMON PLEAS,CIVIL DIVISION. THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THE NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. Date Magisterial District Judge Mark Martin > � certi y that t is is a true an correct copy o the record o the proceedings containing the judgment. Date Magisterial District Judge MDJS 315A Page 2 of 3 Printed:09/09/2014 10:09:05AM IHE ?Oh SEP 19 PH 1: 1 9 . 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 ; ss AFFIDAVIT: I hereby (swear) (affirm) that I served a copy of the Notice of Appeal, Common Pleas No. , upon the Magisteriai District Judge designated therein on 557a (date of service 20 A--/ L (by personal service 0 by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) , on q20 1 14 by personal serviceD by (certified) (registered) mail, PaY14 sender's receipt attached hereto. (SWOIM,)iNFFIRMEE).) A D SUWRIBED BEFORE ME THIS rf DAY OF.J - 20 ir Signature of offici horn affidavijiwYs made Signature 044- IP/O—gOkaiia-r Title Of o icial My commission expires on , 20 Prothonotary, Cumberland County, Carlisle, PA - My Commission Expires the First Monday of Jak2011. AOPC 312A 05 s E c T 0 N s E c T 0 N Supreme Cpurta iRenn.sylvania CourtofCommottlleas dui), Ci8j1,-COVO„:$1-1---et ..,•• , •r.:• County For Prothonotary Use Only: Docket No: /2/ 455 ti The information collected on this form is used solely „for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers CIS required by law or rules of court. Corfencement of Action: Complaint 0 Writ of Sununons 0 Petition 0 Transfer from Another Jurisdiction eclaratio.n of Taking /ptCs. Name: 1#77/1r. 2/1ile, Aefile- Lead Defant' UNamee•y_ .e.ethe./rez,--4 Are money damages requested? Yes 0 No iv' Dollar Amount Requested: ['within arbitration limits (check one) D outside arbitration limits Is this a Class Action Suit? 0 Yes re? IK -o Is this an MDJ Appeal? es 0 No Name of Plaintiff/Appellant's Attorney: j .3.0N /9/ '?// 0 Check here if you have no attorney (are a Self -Represented !Pro Sel Litigant) EJ Nature of the Case: Place an "X" fo the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) O Intentional O Malicious Prosecution 0 Motor Vehicle O Nuisance O Premises Liability O Product Liability (does not include mass tort) O Slander/Libel/ Defamation O Other: MASS TORT O Asbestos Ej Tobacco O Toxic Tort - DES 0 Toxic Tort - Implant O Toxic Waste 0 Other: PROFESSIONAL LIABLITY O Dental El Legal O Medical O Other Professional: CONTRACT (do not nclude Judgments) 0 Buyer Plaintiff O Debt Collection: Credit Card O Debt Collection: Other 0 Employment Dispute: Discrimination O Employment Dispute: Other O Other: REAL PROPERTY O Ejectment O Eminent Domain/Condemnation O Ground Rent O Landlord/Tenant Dispute • Mortgage Foreclosure: Residential O Mortgage Foreclosure: Commercial O Partition O Quiet Title O Other: CIVIL APPEALS Administrative Agencies 0 Board of Assessment 0 Board of Elections o Dept. of Transportation O Statutory Appeal: Other MISCELLANEOUS 0 Common Law/Statutory Arbitration o Declaratory Judgment 0 Mandamus 0 Non -Domestic Relations Restraining Order 0 Quo Warranto 0 Replevin 0 Other: Updated 1/1/2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY TREBOR MOBILE HOME PARK and ROBERT V. GOTHIER, Jr. PLAINITFFS, v. NICKI HOCKENBERRY, INDIVIDUALLY, and CHRIS SANDERSON, INDIVIDUALLY, and NICKI HOCKENBERRY AND CHRIS SANDERSON, JOINTLY AND SEVERALLY Jason A. Mitchell, Esquire Atty ID #85148 J.C. BAR Properties, Inc. 415 Fallowfield Rd., Suite 301 Camp Hill, PA 17011 (717)761-7801 CIVIL ACTION APPEAL FROM MAGISTERIAL APPEAL FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT CASE NO. 14-5520 COMPLAINT— BREACH OF LEASE EVICTION AND POSSESSION Attorney for Plaintiffs `y Jason A. Mitchell, Esquire Atty ID #85148 J.C. BAR Properties, Inc. 415 Fallowfield Rd., Suite 301 Camp Hill, PA 17011 (717)761-7801 Attorney for Plaintiffs TREBOR MOBILE HOME PARK and ROBERT V. GOTHIER, Jr. PLAINITFFS, v. NICKI HOCKENBERRY, INDIVIDUALLY, and CHRIS SANDERSON, INDIVIDUALLY, and NICKI HOCKENBERRY AND CHRIS SANDERSON, JOINTLY AND SEVERALLY DEFENDANTS. NOTICE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION APPEAL FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT COMMON PLEAS NO. 14-5520 You have been sued in Court. If you wish to defend against the claims set forth in this following pages, you must take action within twenty (20) days after this Petition 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 notice for any money claimed in the Petition or for any other claim of relief requested by the petitioner. You may lose money or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Reference Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 1-800-990-9108 717-249-3166 Jason A. Mitchell, Esquire Atty ID #85148 J.C. BAR Properties, Inc. 415 Fallowfield Rd., Suite 301 Camp Hill, PA 17011 (717)761-7801 Attorney for Petitioner TREBOR MOBILE HOME PARK and ROBERT V. GOTHIER, Jr. PLAINITFFS, v. NICKI HOCKENBERRY, INDIVIDUALLY, and CHRIS SANDERSON, INDIVIDUALLY, and NICKI HOCKENBERRY AND CHRIS SANDERSON, JOINTLY AND SEVERALLY DEFENDANTS. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION APPEAL FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT COMMON PLEAS NO. 14-5520 COMPLAINT AND NOW, comes Plaintiffs, Trebor Mobile Home Park and Robert V. Gothier, Jr. (hereinafter collectively "Plaintiff" or "Plaintiffs"), by and through counsel, Jason A. Mitchell, Esquire, and pursuant to the Manufactured Home Community Rights Act, Act 261 of 1976 as amended by Act 80 of 2010 (the "Act"), and files this Complaint, averring as follows: 1. Plaintiff, Robert V. Gothier, Jr. ("Gothier") is an adult individual with a principal place of business located at 415 Fallowfield Rd., Camp Hill, Cumberland County, Pennsylvania. 2. Defendants Nicki Hockenberry ("Hockenberry") and Christopher Sanderson ("Sanderson"; collectively, Hockenberry and Sanderson are "Defendants") reside at 967 West Trindle Road, Lot #13, Mechanicsburg, PA (the "Property") 3. Gothier owns the property located at 967 West Trindle Road, Mechanicsburg, PA, which is a mobile home park known as Trebor Mobile Home Park (the "MHP"). 4. Trebor Mobile Home Park ("Trebor") is a fictitious name owned by Gothier. 5. At all times material hereto, Gothier rented to tenants residential mobile home lots within Trebor. 6. On or about October 1, 2012, Defendant Sanderson signed a "Lease of Mobile Home Space" for Lot #13 in Trebor Mobile Home Park (the "Lease"). (A true and correct copy of the Lease is attached hereto and made a part hereof as Exhibit A.) 7. On or about January 23, 2014, Defendant Hockenberry was added to the Lease as a tenant. (See Exhibit A.) 8. The Lease required a rental payment of Three Hundred Fifty and 00/100 Dollars ($350.00) per month. (See paragraph 1(a) of the Lease.) 9. The Lease allowed for a late fee of Thirty -Five and 00/100 Dollars ($35.00) for each late rent payment. 10. As of July 25, 2014, Defendants were delinquent in their rental payments and late fees in the amount of Two Thousand Two Hundred Thirteen and 51/100 Dollars ($2,213.51). 11. Pursuant to the Act, on or about July 25, 2014, Helen Latchford, property manager for Trebor, send a certified letter to Defendants outlining their delinquency, demanding payment, and giving the required thirty (30) day notice before eviction proceedings have begun. (A true and correct copy of the July 25, 2014, letter from Helen Latchford to Defendants is attached hereto as Exhibit B.) 12. Subsequent to the July 25, 2014, letter, Defendants have made no rental or late fee payments, and as of the filing of this Complaint, Defendants are now Three Thousand Three Hundred Sixty -Eight and 51/100 Dollars ($3,368.51) delinquent in rent and late fees. 13. An eviction hearing was held on September 8, 2014, as the result of an eviction filing with the Magistrate Judge at MJ -09305 -LT -0000132-2014. 14. This action is Defendant Hockenberry's appeal from the decision of the Magistrate Judge. COUNT I TREBOR MOBILE HOME PARK and ROBERT V. GOTHIER, Jr. PLAINITFFS, v. NICKI HOCKENBERRY, INDIVIDUALLY BREACH OF LEASE 15. Plaintiff hereby incorporates paragraphs 1 through 14 of this Complaint as if fully alleged herein. 16. The Lease was a contractual relationship between Plaintiff and Defendant Hockenberry. 17. As a result of not paying rent as required pursuant to the Lease, Defendant Hockenberry has breached the Lease. 18. Defendant Hockenberry has not made any payments to Plaintiff, therefore, Defendant Hockenberry remains in arrears on her rent and is in default of the Lease. 19. As a result of Defendant Hockenberry's breach, Plaintiff has been damaged in the amount of Three Thousand Three Hundred Sixty -Eight and 51/100 Dollars ($3,368.51). WHEREFORE, Plaintiffs, Trebor Mobile Home Park and Robert V. Gothier, Jr., demand that judgment is entered in Plaintiffs' favor against Defendant Nicki Hockenberry in the amount of Three Thousand Three Hundred Sixty -Eight and 51/100 Dollars ($3,368.51). COUNT II TREBOR MOBILE HOME PARK and ROBERT V. GOTHIER, Jr. PLAINITFFS, v. NICKI HOCKENBERRY, INDIVIDUALLY EVICTION AND POSSESSION 20. Plaintiff hereby incorporates paragraphs 1 through 19 of this Complaint as if fully alleged herein. 21. The Act, at Section 3, provides that Plaintiff is entitled to an eviction in the case of nonpayment of rent so long as the owner of the mobile home park gives the tenant thirty -days (30) notice of an eviction proceeding. 22. Plaintiff gave Defendants notice of eviction proceedings on July 25, 2014, and a hearing was held September 8, 2014. 23. Plaintiff provided Defendant Hockenberry sufficient notice of an eviction hearing. 24. Defendant Hockenberry has not made any payments to Plaintiff, therefore, Defendant Hockenberry remains in arrears on her rent and is in default of the Lease. WHEREFORE, Plaintiffs, Trebor Mobile Home Park and Robert V. Gothier, Jr., demand that judgment is entered in Plaintiffs' favor against Defendant Nicki Hockenberry for immediate eviction and possession of the Property. COUNT III TREBOR MOBILE HOME PARK and ROBERT V. GOTHIER, Jr. PLAINITFFS, v. CHRISTOPHER SANDERSON, INDIVIDUALLY BREACH OF LEASE 25. Plaintiff hereby incorporates paragraphs 1 through 24 of this Complaint as if fully alleged herein. 26. The Lease was a contractual relationship between Plaintiff and Defendant Sanderson. 27. As a result of not paying rent as required pursuant to the Lease, Defendant Sanderson has breached the Lease. 28. Defendant Sanderson has not made any payments to Plaintiff, therefore, Defendant Sanderson remains in arrears on her rent and is in default of the Lease. 29. As a result of Defendant Sanderson's breach, Plaintiff has been damaged in the amount of Three Thousand Three Hundred Sixty -Eight and 51/100 Dollars ($3,368.51). WHEREFORE, Plaintiffs, Trebor Mobile Home Park and Robert V. Gothier, Jr., demand that judgment is entered in Plaintiffs' favor and against Defendant Christopher Hockenberry in the amount of Three Thousand Three Hundred Sixty -Eight and 51/100 Dollars ($3,368.51). COUNT IV TREBOR MOBILE HOME PARK and ROBERT V. GOTHIER, Jr. PLAINITFFS, v. CHRISTOPHER SANDERSON, INDIVIDUALLY EVICTION AND POSSESSION 30. Plaintiff hereby incorporates paragraphs 1 through 29 of this Complaint as if fully alleged herein. 31. The Act, at Section 3, provides that Plaintiff is entitled to an eviction in the case of nonpayment of rent so long as the owner of the mobile home park gives the tenant thirty -days (30) notice of an eviction proceeding. 32. Plaintiff gave Defendants notice of eviction proceedings on July 25, 2014, and a hearing was held September 8, 2014. 33. Plaintiff provided Defendant Sanderson sufficient notice of an eviction hearing. 34. Defendant Sanderson has not made any payments to Plaintiff, therefore, Defendant Sanderson remains in arrears on her rent and is in default of the Lease. WHEREFORE, Plaintiffs, Trebor Mobile Home Park and Robert V. Gothier, Jr., demand that judgment is entered in Plaintiffs' favor arid against Defendant Nicki Hockenberry for immediate eviction and possession of the Property. COUNT V TREBOR MOBILE HOME PARK and ROBERT V. GOTHIER, Jr. PLAINITFFS, v. NICKI HOCKENBERRY and CHRISTOPHER SANDERSON JOINT AND SEVERAL BREACH OF LEASE 35. Plaintiff hereby incorporates paragraphs 1 through 34 of this Complaint as if fully alleged herein. 36. Defendants Hockenberry and Sanderson are both signatories to the Lease. 37. Defendants Hockenberry and Sanderson are jointly and individually responsible for the rent payments pursuant to the Lease. 38. As a result of not paying rent as required pursuant to the Lease, Defendants Hockenberry and Sanderson have breached the Lease. 39. Defendants Hockenberry and Sanderson have not made any payments to Plaintiff, therefore, Defendants Hockenberry and Sanderson remain in arrears on her rent and is in default of the Lease. 40. As a result of Defendants Hockenberry and Sanderson's breach, Plaintiff has been damaged in the amount of Three Thousand Three Hundred Sixty -Eight and 51/100 Dollars ($3,368.51). WHEREFORE, Plaintiffs, Trebor Mobile Home Park and Robert V. Gothier, Jr., demand that judgment is entered in Plaintiffs' favor and against Defendants Nicki Hockenberry and Christopher Hockenberry jointly and severally in the amount of Three Thousand Three Hundred Sixty -Eight and 51/100 Dollars ($3,368.51). COUNT VI TREBOR MOBILE HOME PARK and ROBERT V. GOTHIER, Jr. PLAINITFFS, v. NICKI HOCKENBERRY and CHRISTOPHER SANDERSON JOINT AND SEVERAL EVICTION AND POSSESSION 41. Plaintiff hereby incorporates paragraphs 1 through 40 of this Complaint as if fully alleged herein. 42. Defendants Hockenberry and Sanderson are both signatories to the Lease. 43. Defendants Hockenberry and Sanderson are jointly and individually responsible for the rent payments pursuant to the Lease. 44. The Act, at Section 3, provides that Plaintiff is entitled to an eviction in the case of nonpayment of rent so long as the owner of the mobile home park gives the tenant thirty -days (30) notice of an eviction proceeding. 45. Plaintiff gave Defendants notice of eviction proceedings on July 25, 2014, and a hearing was held September 8, 2014. 46. Plaintiff provided Defendants Hockenberry and Sanderson sufficient notice of an eviction hearing. 47. Defendants Hockenberry and Sanderson have not made any payments to Plaintiff, therefore, Defendants Hockenberry and Sanderson remain in arrears on their rent and are in default of the Lease. WHEREFORE, Plaintiffs, Trebor Mobile Home Park and Robert V. Gothier, Jr., demand that judgment is entered in Plaintiffs' favor and against Defendants Nicki Hockenberry and Christopher Hockenberry jointly and severally in the amount of Three Thousand Three Hundred Sixty -Eight and 51/100 Dollars ($3,368.51). Date: 0a00,1,91- fa XII By: Jason i chell, Esquire AttOr y for Petitioner VERIFICATION I, Robert V. Gothier, Jr., do hereby verify and state that the facts above set forth are true and correct (or are true and correct to the best of my knowledge, information and belief) and that I expect to be able to prove the same at a hearing held in this matter. I understand that the statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 (relating to unsworn falsification to authorities). Date: By: Jason A. Mitchell, Esquire Atty ID #85148 J.C. BAR Properties, Inc. 3100 Market Street Camp Hill, PA 17011 (717)761-7801 Attorney for Plaintiffs TREBOR MOBILE HOME PARK and ROBERT V. GOTHIER, Jr. PLAINITFFS, v. NICKI HOCKENBERRY, INDIVIDUALLY, and CHRIS SANDERSON, INDIVIDUALLY, and NICKI HOCKENBERRY AND CHRIS SANDERSON, JOINTLY AND SEVERALLY DEFENDANTS. ORDER OF COURT AND NOW, this day of COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION APPEAL FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT COMMON PLEAS NO. 14-5520 20_, after reasonable notice and an opportunity for hearing having been provided to all interested parties, the Court hereby awards judgment as follows: (1) In favor of Plaintiffs and against Defendant Nicki Hockenberry, individually, in the amount of Three Thousand Three Hundred Sixty -Eight and 51/100 Dollars ($3,368.51). (2) In favor of Plaintiffs and against Defendant Nicki Hockenberry, individually, for immediate eviction from the Property and immediate possession of the Property by Plaintiffs. (3) In favor of Plaintiffs and against Defendant Christopher Sanderson, individually, in the amount of Three Thousand Three Hundred Sixty -Eight and 51/100 Dollars ($3,368.51). (4) In favor of Plaintiffs and against Defendant Christopher Sanderson, individually, for immediate eviction from the Property and immediate possession of the Property by Plaintiffs. (5) In favor of Plaintiffs and against Defendants Nicki Hockenberry and Christopher Sanderson, individually, jointly and severally, in the amount of Three Thousand Three Hundred Sixty -Eight and 51/100 Dollars ($3,368.51). (6) In favor of Plaintiffs and against Defendants Nicki Hockenberry and Christopher Sanderson, individually, jointly and severally, for immediate eviction from the Property and immediate possession of the Property by Plaintiffs. BY THE COURT: ,Judge 6z0164 r4 LEASE OF MOBILE HOME SPACE TREBOR MOBILE HOME PARK THIS INDENTURE, made this L day of October, 2012, BY AND BETWEEN Trebor Mobile Home Park, party of the first part, Lessor, and Christopher Sanderso y°^`�« //"°6''—~' WITNESSETH, that the said party of the first part, for and in consideration of the covenants and agreements hereinafter mentioned and kept and preformed by the said party of the second part, their executors and adminiotratoro, does hereby demise and |eame, to the said party of the second part. the premises in the Township of Monroe, County of Cumberland, and State of Pennoy\vania, known and described as lot or street number 13 in Tnebor, a mobile home park, to be occupied solely as a private dwelling place. TO HAVE AND TO HOLD the same for a tenancy from month-to-month commencing the day of October 2012, either party may terminate this lease by providing in writing to the other written nVUoe, which notice is delivered to the other party at least thirty (30) days prior to the end of the month at which termination is to take place. In all events, if notice of termination is provided by either Lessor or Lessee, Lessee shall remove his or her mobile home from the leased premises no later than the termination date. If such removal does not occur, Lessee hereby grants to Lessor the absolute right and power to remove said mobile home, and hereby releases Lessor from any and all c{mimm, damages or liability incident to said removal. 1. Lessee shall pay to the Lessor at the office of the latterrent as foliows: (a) Lessee shall pay to the Lessor upon execution of this document the sum of $350.00 representing rental from the first month of occupancy which begins on the first day of every month; Lessee shall also pay the Lessor of the sum of $0.00 which represents the proportionate amount of one month's rent if the lease is executed on a day other than the first of the month. Checks should be made payable to Trebor MPH, and mailed to c/o J.C. BAR Properties, Inc., 415 Fallowfield Road, Suite 301, Camp Hill, PA 17011 (b) $350.00 on the first day of this instrument thereafter in advance during the remainder of the lease. (c) $350.00 upon the signing of this instrument representing a security deposit. (d) Said rental shall be paid promptly on the 1st of each month, it being agreed by the parties hereto that the time of each and all payments is of the essence of this agreement. A late charge of $35.0O will be accessed if not received by the seventh day of the month. However, the imposition or payment of this late charge shall not be taken to prevent Lessor from terminating this lease or otherwise proceeding against Lessee on account of failure to pay the rent on the 1st of the month, and no waiver shall occur by accepting rent and late payment after the first of each month. (e) A $35.00 fee will be charged if a check is returned for non sufficient funds. 2. The leased space shall be used only for the parking of a mobile home. It is mutually understood for the purpose of this agreement that said mobile home is personal property and not reality. Wage 3. As additional rent hereunder, Lessee agrees to pay the following, which is due at the same time the basic rental is due as set forth in Paragraph above: (a) 01O.0Uper month per pet, which is maintained by Lessee for any part of the month; (b) $10.00 per month for each automobile or motor vehicle, including campers, trucks, trailers and othesimilar vehicles, in excess of two (2), which are owned, used or possessed by any occupant of the premises during part of each month. (c) All other costs and fess as provided in the Disclosure of Rent, Fees, Service Charge Assessments, and Utility Charges as defined in Exhibit B. attached to the Lease 4. Lessee shall not subiet the demised premises, or any part thereof,or assign this agreement, or any rights pursuant (0 the agreement. In the event a termination of this lease agreement occurs, the Lessee shall have absolutely no right whatsoever to sell or otherwise transfer his rights in the lot demised herein (0 any person, and shall have the obligation to remove his mobile home at this own expense by the termination date, unless express written approval is granted by Lessor pursuant to terms and conditions to be set fourth in such document. Lessee hereby signifies his understanding that the leasing of the space in the mobile home park from Leoaor, and his right to place a mobile home on said lot, does not give him any rights to retain said mobile home on the lot in the event of termination of this lease, excepting only in strict accordance with the earlier provisions of this paragraph. 5. Lessee shaH pay for afl gas, heat, light,ht, waterpower, telephone and any other public utility services that may be obtained or supplied to the demised premises, 6. No storage shall be allowed outside the mobile home unless the space is attractively enclosed inemanner specifically approved by the Lessor 7. Lessee agrees to maintain the demised premiseo, and all parts thereof, in good condition and repair. Treee, ahnubn, and flowers may be planted, posts may be inubo||ed, driveways and cabanas added, but only with the prior written consent of the Lessor. Lessee agrees to properly cultivated and care for the lawn, ahrubbery, tress and grounds. In addition, Lessee agrees to properly maintain in good condition and repair the mobile home and storage enc|omunnn, which might be places upon the premises. Lessee specifically authorizes Lessor to come upon the premises at all reasonable times for the purpose of inspecting the exterior of the mobile home and eno/osunon, and herewith agrees to comply with all directives of the Lessor with respect to maintenance and repair of said facilities. Lessee recognizes that failure to abide by these obligations with respect to maintenance and repair will be an additional basis upon which Lessor may terminate this lease. 8. Lessee agrees not to erect or disptay either on the lot or within the mobile home, any business sign unless written authority is previously obtained from Lessor. Q. Lessor expressly releases and quit claims to Lessee any and all rights, title and interest in or to the mobile home as realty which may, during the term of this leama, become attached to the real property. 10. Inasmuch as Lessor's mobile home park is maintained as a private enterprise, its streets and lanes are private and not public thoroughfares. Lessor maytherefore, at his discretion, and in the interest of safety and traffic control as well as for the well-being of tenants therein, restrict the delivery of certain products and services by designated suppliers. These controls may or may not include such goods and services as the furnishing of dairy 2|9ago products, fuel, bakery goods, laundry and dry cleaning. Where such limitations shall be posted in the office of the park and such posting made part of this lease. 11. It is expressly understood between the parties hereto that the posted Rules and Regulations are a part of this lease at the time of execution and attached as Exhibit A. Lessor may alter, add or amend said rules and regulations from time to time but said rules shall not take effect until a written notice to this effect has been given to the Lessee. Lessee acknowledges neceipt, at the time of execution hereof, of a copy of the applicable Rules and Regulations dated as of the date of this Lease acknowledges also that he/she had read and understands same, and agrees to abide by the terms and conditions thereof in the same manner as the written provisions of this lease. 12. The Lessee will in every respect comply with the ordinances of Monroe Tmvvnohip, with the rules and orders of the Board of Health thereof, with the orders and requirements of the police department, with the requirements of the Underwriters' Association so as not to cause any raise in the rate of insurance upon the building and contents thereof, and with the rules and orders of the fire department in respect to any matters coming with the jurisdiction. 13. At the termination of the |000e, by the lapse of time or otherwise, the party of the second part shall yield up immediate possession to the party of the first part and failing to do so shall pay as liquidated damages for the whole time such possession is withheld, in addition to all of the monies due pursuant to this |eaao, the sum of $10.00 per day, plus any and all mxpenmos, including attorney's fees and coats before a justice or the peace or court, incurred by Lessor because of such failure on the part of the Lessee. 14. Resident hereby waives the Notice to Quit otherwise required by the Pennsylvania Landlord and Tenant Acof 1951, as amended, 68 P.S. 250.101 et sea., and any other applicable law. This means that Landlord may demand that Resident vacate the Premises immediately without any prior notice when this Lease ends, or if Resident is in default of this Lease. Notwithstanding the foregoing, Landlord may not seek Resident's eviction based on defaults of this Lease without first giving Resident such default notices as are required by the Act. 15. The rules governing eviction of manufactured home community residents are set by statute and described in the "Important Notice Required By Law" attached to this Lease as Exhibit C. Resident may be evicted from the Premises for any of the foliowing reasons: (a) Nonpayment of Rent; (b) A second or subsequent violation of the Rules or this Lease occurring within a six- month period; (c) A change of use of the Community or parts thereofor (d) Termination of the Community. 16. References to the masculine shall include the feminine as well, and the singular shall include the plural if there are more than one party who executes this Lease. IT IS EXPRESSLY AGREED, between the parties hereto that if default be made in the payment of the rent herein agreed or any part thereofor in any of the covenants and agreement herein conbained, to be kept by the party of the second part, it shall be lawful for the party of the first part, or the legal representative of the said party, at any time thereafter, at the election of said first party of the legal representatives thereof, without notice, to declare said term ended, and to re-enter said demised premises, or any part thereof, either with or without process of Iaw,and the said party of the second part of any person or persons occupying the mobile home, to expel, remove and haul some mobile home from the premieeo, using such force as may be necessary _ _ so to do, ad the said premises again to repossess and enjoy, as before this demise, without prejudice to any remedies which might otherwise be used for arrears of rent or preceding breach of covenants said party of the second part hereby expressly waiving all right to any notice or demand under any statute of this utato, relating to forcible entry and detainer, and said party of the second part further covenants and agrees that said party of the first part, or the representatives or assigns of said party, shall have, at all times, the right to distrain for rent due, and shall have a valid and first lien upon all property of said party of the second part, whether exempt by law or not, as security for the payment of the rent herein reserved. IT IS FURTHER AGREED, by the parties hereto, that after the service of noUce, or the commencement of a suit, or after final judgment for possession of said premises, the first party may receive and collect any rent due, and the payment of said rent shall not waive or affect such noUce, said suit, or said judgment. The party of the second part further covenants and agrees to pay and discharge all reasonable coate, attorney's fees and expenses that shafl be made and incurred by the party of the first part in enforcing and covenants and agree that the covenants and agreements herein contained shall be binding upon, apply and inure to their respective heirs, executors, ad m inistrators and assigns. Witness the hands and seals of the parties hereto, the day and year first above written. W7ess: , TREBOR ILE HOME PARK Witness: 4|Pagc Gothier, Jr., LESSOR Exhibit A TREBOR MOBILE HOME PARK RULES and REGULATIONS PURPOSE: PARKING A MOBILE HOME FOR RESIDENTIAL USE ONLY BUSINESS HOURS: Business will be transacted at 3100 Market Street, Camp Hill, PA. The Office telephone number is 761-7801. In case of an emergency after hours, the telephone will be answered by our service. ADDITIONAL PERSON: Any pernnoinexce000fthrmewhowiUnocupyamobUehomoshaUborepodedinvvhUngtodhe Lessor, and the full name and relationship, if any, of said party or parties to the Lessee shall be disclosed. PETS: NO PETS shall be allowed to run loose on the premises, to be staked or tied outside. Animals being exercised on leash shall not be allowed on other tenant'pn*miaea. No pets shall be housed outside the mobile home. All waste products of pets must be picked up and properly disposed of by the Lessee. Also, there is a $10.00 charge per pet per month. REGISTRATIONS: Alt tenants must register at the officeand check out before moving. RENTS: PARKING: All checks are to be made payable to Trebor MHP. Alt checks are due AT OUR OFFICE by the 7th seventh ��F��035mW|baa��m���eof the month. $35.08 NSF Fee Parking spaces for two (2) cars (for Lessee and guests) in frorit of the lot will be provided at no charge. Lessees having more than two cars shall be charged $10.00 per morith per car. Vehicles must be legally registered and inspected; any vehicles that are not, must be removed. No repairing or overhauling of cars on premises shall be permitted. Washing of guests autos is absolutely prohibited. Vehicles with oil leaks shall be moved from the premises immediately. Noisy motorcyctes and vehicles shall be banned from the mobite home park. Any vehicte over one ton shall not be permitted in the park at any tinie, with the exception of moving vans and permitted local deliveries. No trail bikes, three wheelers, snowmobiles or other type of all terrain vehicles are permitted in the park at any time. SPEED LIMIT: A five (5) mile per hour speed limit and all STOP signs must be observed at all times. MAINTENANCE: Lawns must be kept mowe, trimmed and rake, if necessary, at alt times. The Lessoreserves the right to mow any lawn that is neglected. Such mowing shall be subject to a service charge. Shrubbery and plants permanently attached to the premises by tenants shall become the property of Lessor and cannot be removed after planting without the permission of management. It is required that painting shall be done by Lessee to steps, hitchesroofs, utility buildings and any other unpainted surfaces which appear to the Lessor to be unsightly. Steps shall be approved type, No cinder blocks shall be permitted Any electrical hook-ups in excess of 50 amps will be charged at cost. MAINTANCE DIFFICULTIES: SKIRTING: AWNINGS: UTILITY BUILDINGS: CLOTHESLINES: GARBAGE CANS: RESPONSIBILITIES: 2|Pugo When a maintenance problem is encountered, for instance a light out, leaky outside faucet, broken water or sewer pipe, pipe, tree Iimbs rubbing the traUer or lines, etc. CalI the office 717-761- 7801 and the orders for correction of maintenance difficulties are disbursed from the office only. Removal of mobile home hitches is mandatory.AH skirting shall be installed at the direction of the park owner. This will include the type, the color, the installer, the workmanship, etc. The park owner reserves the right to remove or have removed or reject any color or workmanship, which does not conform to specifications. Ariy coach without skirting at the end of thirty (30) days shall pay a fee of $10.00 per day until skirting is installed. See Lessor before purchasing or instaUation to avoid problems. Awnings, cabana rooms, carports, etc. must be discussed with the park owner to make sure construction rneets with park standards. Must be approved by park owner. All sheds (new or being replaced) must be wood. Will not be permitted outside on premises. Drying of clothes on premises will be permitted with an umbrella -type pole. Is prohibited on the lot. No garbage cans will be permitted outside the mobile home. ALL garbage must, WITHOUT FAIL, be placed in plastic bags and deposited in the central containers provided by the park owner. There are to be no grass, leaves or tree trimmings placed in the dumpsters unless they can be cut up in small pieces and placed in bags and then put in dumpsters. No household appliances are to be placed in the trash bultding. You may contact the office and we will make arrangements with you for their disposal free of charge. No bags, boxes, etc are to be left outside the dumpster. All trash MUST BE placed inside the dumpster. All glass, aluminum cans, bi-metal/metal cans and plastic containers are to be placed in plastic bags. Newspaper should be wrapped separately. Place all recyclables in yellow trash bins. Parents shall be held responsible1orMhe conduct of, and any damage caused by their children and guests. The Lessor reserves the right to take any corrective measures necessary in such instances. The Lessor is NOT RESPONSIBLE for any damage, injury or loss by accident, theft or fire to either the property or person of Lessor or guest, and Lessee will assume all risk in such matters. No peddling, soliciting or commercial enterprises are allowed on the park premises. No subletting is permitted. The Lessor reserves the right to remove with or without prior notice any property or person(s) who create a disturbance by drunkenness, fighting, immoral conduct or loud parties. Residents are expected to be considerate of their neighbors and keep all sounds (radios, TV, stereos, voices, etc.) at a moderate level. The Lessor shall evict anyone who becomes a nuisance immediately. The Lessor will be the sole judge of the need for such action. CHILDREN IN THE STREETS: OIL TANKS: REPORTING: No children should be allowed to play or participate in games on any of the streets or drives of the park. There is a Park Area on the side of the property where children may play. All persons shall be respectful of the rights and properties of each of the other Lessees, and shall not Trespass upon their premises or otherwise disturb their quiet possession thereof. Anyone selUng their mobile home must remove the underground oil tanks. These musbe replaced with an above ground tank, which must be approved by the park owner. All Lessees shall report to the office immediatey concerning changes in the number of their pets, occupants and vehicles so that proper rental can be calculated. These rules and regulations herein contained constitute a part of the lease and are hereby binding. Regulations of the Park have been established for your protection and to help make living here happy and pleasant for you and your neighbors. The management reserves the right to add or delete rules and regulations when necessary. Trebor Mobile Home Park c/o J.C. BAR Properties, Inc. 3100 Market Street Camp Hill, PA 17011 717-761-7801 ��_/���'� ���� (^��6�letw~ ^u/- �-/�� ��~� ^ Print Name Date Time N`[ls' /ym [ /2!/E Print Name I Date Time Signature Print Name Signature Print Name 3/page Date Time Date Time Exhibit B TREBOR MOBILE HOME, PARK DISCLOSURE OF RENT, FEES, SERVICE CHARGES, ASSESSMENTS, and UTILITY CHARGES MONTH-TO-MONTH LEASE I. RENT PER MONTH $350.00 2. FEES APPLICATION: $10.00 PER PERSON CREDIT CHECK: $30.00 PER PERSON CRIMINAL CHECK: $10.00 PER PERSON LAWN AND SHRUB CUTTING: Amount charged by the contractor hired. CLEAN-UP OF LAWN, LEAVES, DEBRIS: Amount charged by the contractor hired. RETURNED CHECK: $35.00 LATE FEE FOR RENT RECEIVED AFTER THE 7TH OF THE MONTH: $35.00 PET FEE: $10.00 PER MONTH PER PET VEHICLE FEE:TWO VEHICLES $0.00; THREE PLUS CARS $10.00 PER MONTH PER CAR COURT FILING FOR RENT/POLICY VIOLATIONS: COURT ASSESSED COSTS ABANDONED HOME (PA ACT 74) STORAGE FEE: $10.00 PER DIEM RENT 3. UTILITY CHARGES: WATER: INDIVIDUAL USAGE METERED AND BILLED DIRECTLY TO LESSEE SEWER: INDIVIDUAL USAGE METERED AND BILLED DIRECTLY TO LESSEE TRASH: INCLUDE WITH MONTHLY RENT ONE CONTAINER PER WEEK INTERNET SERVICE: NOT INCLUDED OR PROVIDED BY COMMUNITY CABLE SERVICE: NOT INCLUDED OR PROVIDED BY COMMUNITY ELECTRICITY: NOT INCLUDED OR PROVIDED BY COMMUNITY FUEL: NOT INCLUDED OR PROVIDED BY COMMUNITY RENT CHARGES FEES DISCLOSURE EXHIBIT C IMPORTANT NOTICE REQUIRED BY LAW The rules set forth below govern the terms of your lease or occupancy agreement with this manufactured home community. The law requires all of these rules to be fair and reasonable. As a lessee, you may continue to stay in this community as long as you pay your rent and other reasonable fees, service charges and assessments hereinafter set forth and abide by the rules of the community. Entrance and exit fees may not be charged. Installation and removal fees may not be charged in excess of the actual cost to the manufactured home community owner or operator for providing such service for the installation or removal of a manufactured home in a manufactured home space. As a lessee, you may be evicted for any of the following reasons: (1) Nonpayment of rent. (2) A second or subsequent violation of the rules of the manufactured home community occurring within a six-month period. (3) If there is a change in use of the community land or parts thereof. (4) Termination of the manufactured home community. As a lessee, you shall only be evicted in accordance with the following procedure: (1) A lessee shall not be evicted by any self-help measure. (2) Prior to the commencement of any eviction proceeding, the manufactured home community owner shall notify the lessee in writing of the particular breach or violation of the lease or community rules by certified or registered mail. (i) In the case of nonpayment of rent, the notice shall state that an eviction proceeding may be commenced if the manufactured home lessee does not pay the overdue rent within 20 days from the date of service if the notice is given on or after April 1 and before September 1, and 30 days if given on or after September 1 and before April 1 or an additional nonpayment of rent occurring within six months of the giving of the notice may result in immediate eviction proceedings. (ii) In the case of a breach of the lease or violation of the community rules, other than nonpayment of rent, the notice shall describe the particular breach or violation. No eviction action shall be commenced unless the lessee has been notified as required by this section, and upon a second or subsequent violation or breach occurring within PMHA Act 80 — Important Notice Required by Law dated 12-13-2010 Page 1 of 2 six months, the manufactured home community owner may commence eviction proceedings at any time within 60 days of the last violation or breach. As a lessee, you shall not be evicted when there is proof that the rules you as the lessee are accused of violating are not enforced with respect to the other manufactured home residents or nonresidents on the community premises. In addition, no eviction proceeding for nonpayment of rent may be commenced against you as the lessee until you have received notice by certified or registered mail of the nonpayment and have been given to pay the overdue rent 20 days from the date of service if the notice is given on or after April 1 and before September 1, and 30 days if given on or after September 1 and before April 1. However, only one notice of overdue rent is required to be sent to you as the lessee during any six-month period. If a second or additional violation occurs within six months from the date ofthe first notice then eviction proceedings may be immediately started against you. You are entitled to purchase goods or services from a seller of your choice and the community owner shall not restrict your right to do so. If you desire to sell your manufactured home, the manufactured home community owner may not prevent the sale and may not claim any fee in connection therewith, unless there exists a separate written fee agreement. However, the manufactured home community owner may reserve the right to approve the purchaser as a resident in the manufactured home community. Enforcement of the Manufactured Home Community Rights Act is by the Attorney General of the Commonwealth of Pennsylvania or the District Attorney of the county in which the manufactured home community is located. As a lessee, you may also bring a private cause of action. If your rights are violated you may contact the State Bureau of Consumer Protection or your local District Attorney." I hereby acknowledge receipt of this Important Notice. Print Name Date Time ick; k keib€t j cls©ji) 2- r. Si afore ,'% Print Name Date Time Signature Signature Print Name Print Name Date Time Date Time PMHA Act 80 — Important Notice Required by Law dated 12-13-2010 Page 2 of 2 TREBOR MOBILE HOME PARK ACKNOWLEDGEMENT OF RECEIPT I hereby acknowledge receipt of a copy of the Community Rules & Regulations and the Fees Disclosure sheet from the Landlord. Signature (7/72A-iwyr,e k)--e-/-)a z/,'13 Print Name Date Time Signature Signature Print Name Print Name PMHA Act 80 — Acknowledgement of Receipt dated 12-13-2010 Da e Date 12:/r Time Time Date Time July 25, 2014 Trebor Mobile Home Park Chris Sanderson NickiHockenberry z 967 West Trindle Road ,Lot # 13 Mechanicsburg, Pa. 17055 Dear Chris and Nicki : Certified Mail and US Mail 70132210000103080537 Your rent is behind again and your account is now past due $2,213.51. Attached is a copy of your outstanding balance statement. If you do not pay the outstanding balance within the next 30 days, eviction proceedings wil! commence. Act # 261 of the tegislature requires equal treatment to all tenants and it state" in case of non-payment of rent, the notice shall state that an eviction proceeding may be commenced if the mobile home reside t does not pay the overdue rent within 30 days. acchford Property Manager 4l5FxuoWr/sLnROAD, SUITE 3Ol.CxmrHILL, PAl7011 ~ OFFICE: 717-761-7801 * FAN: 7l7'76l'78]3 712-zA4 at 12:47:49.37 Page: 1 Trebor Mobile Home Park Customer Ledgers For the Period From Jan 1, 2014 to Jul 31, 2014 Filter Criteria includes: 1) IDs: 13 -Sanderson. Report order is by ID. Report is printed in Detail Format. Customer ID Date Trans No Type Debit Amt Credit AmBalance Customer 13 -Sanderson Sanderson, Chris 1/1/14 Balance Fwd 2,451.97 1/1/14 2O14Lot #131 SJ 350l0 2.801.97 1/21/14 1-2014 13 SJ 168.03 2.970.00 1/21/14 1-2014 LF SJ 35.00 3.085.90 1/21/14 EvicFoeo SJ 138.24 3,144.14 1/27/14 cash CRJ 300.00 2,844.14 2/1/14 2014Lot #132 SJ 350.00 3,194.14 2/4/14 cash CRJ 300.00 2.894.14 2/19/14 cash CRJ 380.00 2,594.14 2/24/14 cash CRJ 300.00 300.00 2,594.14 2/24/14 cash CRJ 300.00 2.294.14 2/24/14 2/24/14 LF SJ 35.00 2,329.14 2/24/14 2/24/14 13 SJ 70.27 2.309.41 2/27/14 cash CRJ 2.800.00 400.59 3/1/14 2O14Lot #133 SJ 350.00 '50.59 3/19/14 03-14 13 SJ 338.06 287.47 4/1/14 2O14Lot #134 SJ 350.00 637.47 4/24/14 04'14 )0t 13 SJ 316.14 953.61 5/1/14 2O14Lot #135 SJ 350.00 1.303.61 5/28/14 OB28/14lot 13 SJ 20025 1,503.86 6/1/14 2O14Lot #136 SJ 350.00 1,853.86 6/18/14 cash CRJ 200.00 1,653.86 7/1/14 2O14Lot #137 SJ 350.00 2.003.80 7/1/14 Spectrum 5/15- SJ 200.65 2,213.51 Report Total 4,261.54 4,500.00 2,213.51 Ronny R Anderson Sheriff Jody S Smith Chief Depu Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY �_/\ ��" THE p"OTH5� ., *< \`� xv��*` ^° °. /``^ . .� '� YO°�bwv, ,' ... v: 02 � AV COUNTY CUMBERLAND~.� :e�s���evys�p—^'oJ&N\� pF����°''`'`'' Trebor Mobile Home Park (et al.) vs. Nicki Hockenberry (et al.) Case Number 2014-5520 SHERIFF'S RETURN OF SERVICE 1013/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Christopher Sanderson, but was unable to locate the Defendant in his bailiwick. The Sheriff therefnsratumathewithinrequostadComp|oint&Nodmaaa"NcdFound^atQ87 W Trindle Road, Lot 13, Silver Spring Township, Mechanicsburg, PA 17050. Deputies were advised that the defendant is in Perry County Prison. 1013/2014 08:55 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing t - �-|ve be the Defendant, to wit: Nicki Hockenberry at 967 WTrindle Road, Lot 13, Silver Spring hanicsburg, PA 17050. SHN HA N, DEPUTY 1105/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Christopher Sanderson, buwas unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Perry, Pennsylvania to serve the within Complaint & Notice according to law. 1105/2014 08:12 AM - The requested Complaint & Notice served by the Sheriff of Perry County upon Christopher Sanderson, personally, at Perry County Prison, 300 Carlisle Street, New Bloomfield, PA 17068. Carl E. Nace, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $74.79 SO ANSWERS, November 05, 2014 RONNYRANDERSON, SHERIFF Trebor Mobile Home Park, Et al Versus Christopher Sanderson IN THE COURT OF COMMON PLEAS OF THE 41st JUDICIAL DISTRICT OF PENNSYLVANIA, PERRY COUNTY BRANCH No. 2014-5520 Cumberland County SHERIFF'S RETURN And now October 30 , 2014: Served the within name Christopher Sanderson the defendant(s) named herin, personally at his place of residence in Perry County Prison, New Bloomfield, PA Perry County, PA, on October 30, 2014 at 8:12 o'clock AM by handing to Christopher Sanderson, Defendant 1 true and attested copy(ies) of the within Complaint and made known to him the contents thereof Sworn and subscribed to before me this day of Odo&br-- -wool aAid, thenotafy_ COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL MARGARET F. FLICKINGER, Notary Public Bloomfield Boro, Perry County My Commission Expires February 16, 2016 So answers Deputy Sheriff of Perry County