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HomeMy WebLinkAbout14-7357 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL Judicial District, County Of FROM 6Jfti 4�fj n MAGISTERIAL DISTRICT JUDGE JUDGMENT \J COMMON PLEAS No.JAI„ 13�7 6,,t 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 e141 bi AJ ADDRESS OF APFE_LAN i CITY STAT- ZIP CODE G am GA�,���/,-� p�1C rn // �7ol, DATE Or JUDGMENT IN THE CASE OF('-1 t'- (Defendant' /ate. NyC 14 t e v5 DOCKET No. SIGNATURE OF APPELLANT OR ATTORNEY OR AGENT Nr- 45l 15 7-1(JOInO 0 <�L This block will be signed ONLY when this notation is required under Pa. If appellant was Claimfrit (see Pa. P.C.P.D.J. No. 1001(6) in action R.C.P.D.J. No. 10086. This Notice of Appeal, when received by the Magisterial District Judge, will before a Magisterial District Judge, A COMPLAINT MUST BE FILED operate as a SUPERSEDEAS to the judgment for possession in this case. within twenty (20)days after filing the NOTICE of APPEAL. Sionature o,Prothonotary or Deputy C"7 PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE rTirri Cif r•T -r. (This section of form to be used ONLY when appellant was DEFENDANT(see Pa.R.C.P.D.J. No. 1001(7) in action w° Mxteriah__07strict Judge. IF NOT USED, detach from copy of notice of appeal to be served.upon appellee. %i r PRAECIPE: To Prothonotary Enter rule upon (f appellee(s),to file a co;fi *=iht in.ths appe�a_l --.. Name of appellee(s) (Common Pleas No. i `}within twenty(20)days after service of r or suffer entry of judgment of non pros. Signature of appellant or attorney or agent RULE: To �fi3y s ���' ��C appellee(s) Name of appeliee(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: �a/�20� Signature or Prothonotanj or Depuhl YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-05 J. ro 3/1/ 9� COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript COUNTY OF CUMBERLAND Residential Lease *wo Mag. Dist. No: MDJ-09-3-04 Leiby's MHC LLC MDJ Name: Honorable Kathryn H.Silcox V. Address: 5275 East Trindle Road Barbara Vandersloot Suite 110 Mechanicsburg, PA 17050 Telephone: 717-697-2201 Barbara Vandersloot Docket No: MJ-09304-LT-0000165-2014 252 Deerfield Rd Case Filed: 12/4/2014 Camp Hill, PA 17011 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 Disnosition Date MJ-09304-LT-0000165-2014 Leiby's MHC LLC Barbara Vandersloot Judgment for Plaintiff 12/17/2014 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Barbara Vandersloot $0.00 $1,452.36 $1,452.36 Leiby's MHC LLC $0.00 $0.00 $0.00 Judgment Finding (*Post Judgment) In the matter of Leiby's MHC LLC vs. Barbara Vandersloot on MJ-09304-LT-0000165-2014, on 12/16/2014 the judgment was awarded as follows: The amount of rent per month,as established by the Magisterial District Judge,is$376.00 Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Filing Fees $0.00 $110.50 $110.50 Costs $0.00 $7.00 $7.00 Server Fees $0.00 $32.30 $32.30 Rent in Arrears $0.00 $1,302.56 $1,302.56 Grand Total: $1,452.35 Portion of judgment for physical damages arising out of residential lease: $0.00 MDJS 315A Page 1 of 3 Printed: 12/17/2014 9:32:13AM Leiby's MHC LLC Docket No.: MJ-09304-LT-0000165-2014 V. Barbara Vandersloot 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 The Honorable Silcox certify that t Is Is a true and correct copy of the record of the proceedings containing the judgment. Date Magisterial District Judge MDJS 315A Page 2 of 3 Printed:12/17/2014 9:32:13AM Leiby's MHC LLC Docket No.: MJ-09304-LT-0000165-2014 v. Barbara Vandersloot Participant List Plaintiff(s) Leiby's MHC LLC 7075 Carlisle Pike Carlisle, PA 17015 Defendant(s) Barbara Vandersloot - - 252-Deerfield Rd :. Camp Hill, PA 17011 _ Authorized Agent-Plaintiff(s) Beth Graves c/o Leiby's M.H.C. 7075 Carlisle Pike. Carlisle, PA 17015 MDJS 315A Page 3 of 3 Printed: 12/17/2014 9:32:13AM DEC 29 "2:35 PEi.i.',/t,:frf)Cati,' 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 esziOd,4 A Md ; SS AFFIDAVIT: I hereby (swear) (affirm) that I served /AA V57 l›K a copy of the Notice of Appeal, Common Pleas No. , upon the Magisterial District Judge designated therein on (date of service) 20 20 if 4 by personal servic by (certified) (registered) mail, AfP/c5 tic C- . sender's receipt attached hereto, and upon the appellee, (name) , on /I4! 210 Xby personal service0 sender's receipt attached hereto. (SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS FDEC-, 20 114 Signature of official befor w77oth affidavit was made a -T-4 r\q Title Of official My commission expires or - I'20 I COMMONWEALTH 101:1 NOTARIAL SEAL GINA KOLANKO, Notary Public Hampden Twp., Cumberland County My Commission EXpireS February 12,2018 AOPC 312A - 05 by (certified) (registered) mail, Signature o affiant Gic vri-74.5 e 1...11 vir... L/1,2 1 IN I¼ I UL)..7 ULM., [VI qv; COMMON PLEAS No./h/ 13.57 (1.246LL 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.PPELLANT nifzi 1//..-kaAs 4441 ADDRESS OF APPELLANT g 61 4,-)4 4.// ‚- MAG. 01ST. NO. I NAME Or MW 1/1-40:165.^ 3-• ©y I /-A,--015 _ /--#,eyw / 5', Cm..."..„2.y....."Aw &ct g4ii STATE ZIP CODE (Detend2T", vs / 4br6/41,-. Pr'i. o eT SIGNATuRE OF APPELLANT OR ATTORNEY OR AGENT DATE OF, JUDGMENT IN THE CASE OF (PiziAn /41/0 7/2 e), lz-/eyd in/VC 00CIT No. jor: al,Pg - 41-Pei°°0/ 6-- ,110/7 This block will be signed ONLY when this notation is required under Pa. R.C.P.D.J. No. 10086. This Notice of Appeal, when received by the Magisterial District Judge, will operate as a SUPERSEDEAS to the judgment for possession in this case. Signature or Ptallonetary or Deputy If appellant was Claim nt (see Pa. R.C.P.D.J. before a Magisterial District Judge, A COMPLAINT within r20)4ays after filing the NOTICE of APPEAL. /AA-) 1001(6) in action MUST BE FILED twenty r PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE rtj t=3 rn rrl n -his section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.O.J. No. 1001(7) in action rZre MagEsteriekqtrict (..17,17 • CD r -- Enter rule upon appellee(s), to file a cot in..this api:0—eacl (CommonPleas No. I ervice of or suffer entry of judgment of non pros. 10.11041 Air 00.1" Judge. IF NOT USED, detach from copy of notice of appeal to be served. upon appellee. PRAECIPE: To Prothonotary Name of appellee(s) /6°- 72s7 ) within twenty (20) days afters Signature of appellant or attorney or agent RULE: To AEldy , appellee(s) t45me of a- poetic -5(s) (3) The-crate5f service of this rule irsth-vica was by mail is the date of the mailing. Date: 10420/1- - , • ••••-' • • YOU MUST INCLUD:EA COPY OF -THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. (1) You are notified.th-at asule 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 y9rby -p-ersonal srvice or. by certified or registered S. • .TN. (2) If younao not.file complai-ntwithin.this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. C1,2.4;/eLM g e tU of Prothonotary or Deputy AOPC 312-05 ••Vhfs. so Palc-P- kJ] 3/1/906 LEIBY'S MHC, LLC, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. BARBARA L. VANDERSLOOT Defendant : NO. 14-7357 CIVIL NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint 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 Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 Telephone: 800-990-9108 f 1 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparencencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 Telephone: 800-990-9108 2 LEIBY'S MHC, LLC, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. Barbara Vandersloot, Defendant : NO. 14-7357 CIVIL COMPLAINT AND NOW, comes Plaintiff, Leiby's MHC, LLC, by and through its attorneys, Pecht & Associates, P.C., and avers the following: 1. Plaintiff is Leiby's MHC, LLC, ("Leiby's"), a Maryland limited liability company, which owns a manufactured housing community ("MHC") located at 7075 Carlisle Pike, Carlisle, Cumberland County, Pennsylvania. 2. Defendant Barbara Vandersloot is an adult individual who lives at 630 Grandview Avenue, Camp Hill, PA 17011 and/or 252 Deerfield Road, Camp Hill, 17011, and who is the leasee of Lot # 155, 246 Key West Boulevard, Leiby's MHC, Carlisle, Cumberland County, Pennsylvania. 3. Defendant Barbara Vandersloot is the registered owner of a mobile home that is located on Lot # 155. 4. Defendant Barbara Vandersloot signed an application to lease lot #155 for her daughter Raquel Dawson to live in. A copy of the application is attached as Exhibit "A" and is made a part of this Complaint. 5. Plaintiff obtained a judgment against Defendant on December 17, 2014, in Magisterial District Number MDJ-09-3-04 before the Honorable Kathryn H. Silcox for possession and for damages in the amount of $1,452.36. A copy of the Notice of Judgment is attached as Exhibit "B" and is made a part of this Complaint. 6. On or about December 23, 2014, Defendant Barbara Vandersloot filed a Notice of Appeal and a Praecipe to Enter Rule to file a Complaint and Rule to File on Plaintiff. 7. The initial terms of the lot lease required Defendant to pay $339 per month plus utilites. (See Exhibit A attached hereto). 8. Defendant leased Lot # 155 in the MHC beginning on or about July 1, 2010. 9. Defendant failed to pay utilities, late fees, and lot rent for Lot #155 in the amount of $363.00 per month for November and December of 2014. As of December 6, 2014 Defendant owed $1,452.36 in rent, utilities and late fees. 10. Defendant was provided Notice that her rent was late as required by Pennsylvania Act 261 of 1976 by Notice dated 10/9/14 (a copy of the Notice and proof of delivery are attached as Exhibit "C" and made a part of this Complaint). 11. When Defendant failed to pay rent for November, a second Notice was sent to her as required by Pennsylvania Act 261 of 1976 by Notice dated 11/4/14 (a copy of the Notice and proof of delivery are attached as Exhibit "D" and made a part of this Complaint). 12. Therefore, Defendant has breached her lot lease for failure to pay rent, utilities, late fees and penalties when due. 13. Further, Defendant is three months behind in their rent and is in arrears in payment of rent, utilities and late fees. As of December 31, 2014, Defendant owed rent, late charges, and utility charges in the total amount of $1,993.92. As of the date of the filing of this Complaint Defendant has also failed to pay lot rent for January of 2015. 14. When Defendant filed her appeal she was required by Pa.R.C.P.M.D.J. Rule 1008 to pay her rent into escrow in order to obtain, and maintain, a Supersedeas. 15. Defendant has failed to pay rent into escrow and, therefore, Plaintiff is entitled to immediate possession of the lot. 16. Plaintiff has complied with all prerequisites to filing suit against Defendant. 17. Therefore Plaintiff is entitled to possession and is entitled to the award of damages, including costs of the suit and reasonable attorney fees. 18. The total amount in controversy is less than Fifty Thousand Dollars ($50,000), exclusive of interest, costs, and attorney fees. WHEREFORE, Plaintiff requests possession of the premises known as Lot # 155 and requests that Barbara Vandersloot and all other persons who are living in the mobile home situate on Lot 155 be evicted from the lot, and further, that Barbara Vandersloot be 4 Ordered to pay rent in arrears plus, utilities, and late fees in such amount as is determined to be due at the time of the hearing in this matter. Dated: January 13, 2015 Respectfully Submitted, PECHT & ASSO ' S, P.C. By: 5 W-Pecht, Esquire PA ID No. 38904 ob Bleecher, Esquire PA ID No. 32594 650 North Twelfth Street, Suite 100 Lemoyne, PA 17043 (717) 691-9808 (717) 695-6550 Facsimile wpecht@pechtlaw.com Attorneys for Plaintiff VERIFICATION I, Beth Graves, hereby acknowledge that: 1. I am the Property Manager of Plaintiff, Leiby's MHC, LLC, and I am authorized to sign this Verification on behalf of Plaintiff; 2. The facts set forth in the foregoing document are true and correct to the best of my knowledge, information, and belief; and 3. I am aware that any false statements that may be made herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. LEIBY'S MHC, LLC Dated: %%4 -PS. By: 166''r Beth Graves, Property Manager EXHIBIT "A" 7 LEIBY'S MHC APPLICATION TO RENT For Office Use Only : LOT # /5:5 ADDRESS 04110 Key 4.1W V Resale 31'd Party OR Park Sale COS BOS Application Fee Monthly Rent $ 531 0 $ 36• p Per applicant 0 Lot Rental ❑Add'I Occupant,/ Roommate 0 Rental Unit APPLICANT INFORMATION I.AST NAME �� 9 4XS Ft . T NAME �a.f`1 MIDDLE. NAME 101. l V E,MPLOYFR::;:' C GI:NP:RATION I J. Cr, L IL etc.I GENI•'RAl'ION (Jr_ Si- L IL etc.) DATE OF BIRTH : •., ,,. • AGE SOCIAL SEC( IRUTNIIMBER EDUCATION - DRIVER'S LICENSE -NO. ISSUING SIATE AIISINESS W.EPNE(- SO Q U CJ EDUCATION - CURRENT Sit E \D Etiti ' �c'-�! � Fi_ t M (J� ,n ) ('t'RRE�1S�:E.T DRESS n B U_�J)• J[� CITY ,(^tirruo(77�— Lj �I ` 1� 1 COUNTY ,, IL4.4 ' STATE TELEPHONE NUMBERLB( ) (1 1 73 it v7 S / J 7 �ll:�(:OI ' How La J`N(�'r AT II'RT I ADDRESS'? -) ya NAME OF I. ANDLORD TFI F.PHONIi ( ) � .. MONTHLY,RENT OR MORT ' GE $ .. rxnA 8 a NAME. OF LANDLORD TELEPHONE ( ) '- j ou > (�jWCLr J MONTHLY RENT OR MORTGAGES " 'l.. ... PREVIOUS STREET ADDRESS PRF.V101 IS STREET_ADDRESS 6 l 3 1.4-; cjr— . . . . ...... HOW LONG 4j NW•HOW CITY COUNTYSTATE ' • ZIP CODE ZIP CODE. HOW TONG AT PREVIOUS ADDRESS? TELEPHONE NUMBER ( ) .N4:10. .... 00 DESCRIBE: NAME OF I ANDL.ORD TELEPHONE ( ) NAME OF I ANDI.ORD TELEPHONE ( ) MONTHLY RENT -Mt MORTGMiF °S'- " • • - 0 SPOUSE • 3;C0 -APPLICANT • ` • ` Cf -ROOMMATE - 0 OTHER I.AST'NAMEFIRST t` cvlj� ESA _.. j� MIDDLE NAME iv E,MPLOYFR::;:' C GI:NP:RATION I J. Cr, L IL etc.I DATE. OF milt r1 i / _ / J te RI ISINESS ADDRESS J?G l 4o/.142 � BUSINESS ADDR ( SO'!AI SR FCl/ITV NIIMBFR - AGE 4.3 AIISINESS W.EPNE(- SO Q U CJ EDUCATION - DRTVERSL(CLTISENO. LSSUING STATE- ....--- ) ('t'RRE�1S�:E.T DRESS n B U_�J)• J[� TYPE OF ROSINESS ('try 771A0 COUNTY 1 ITA t 1 TY C'OUF I It I ONI. A i.1' •SENT ADDRES,:4 II adet, l l TELEPHONE NUMBER ( )-7:13 4k- t. i 1_a 8 a NAME. OF LANDLORD TELEPHONE ( ) '- j ou > (�jWCLr J MONTHLY RENT OR MORTGAGES " 'l.. ... NAME & TITLE OF'SUPF.RVISOR PRF.V101 IS STREET_ADDRESS 6 l 3 1.4-; cjr— . . . . ...... HOW LONG 4j NW•HOW grk (Try \ ,� �b� �` I i�-� T COUNTY . .. .-. STATE ZIP CODE. HOW I.(ING AT PREVIOUS ADDRESS? I TELEPHONE NUMBER.( .N4:10. .... 00 DESCRIBE: NAME OF I ANDL.ORD TELEPHONE ( ) MONTHLY RENTOR MORTGAGE S .. _... _ ._... ._. .: OCCUPATION, 1F YOU ARE IN THE MILITARY PLEASE INCLUDE YOUR DUTY STATION UNDER: BUSINESS -ADDRESS) APPLICANT CO.- APPLICANT SPOUSE EMPLOYER• 41/01--- E,MPLOYFR::;:' C h`. RI ISINESS ADDRESS J?G l 4o/.142 � BUSINESS ADDR .. AIISINESS W.EPNE(- SO Q U CJ A[ISINF.SS TELEPHONE ( ) Tl'PF OF' )SMF . TYPE OF ROSINESS .. I(ril'1I(>N%h�.� POSITION..... NAMP. 8•' l.E. )F Si IPFR S( ` NAME & TITLE OF'SUPF.RVISOR HOW LONG 4j NW•HOW LONG? . MONTHLY GROSS INCOME S u1l101111-14MONT)II.V INCOMES , t [>ESCRIBE: ' MONTHLY GROSS INCOME. L. OTHER MONTHLY INCOME S. ... .N4:10. .... 00 DESCRIBE: )w.r `f DJ- . 4 t'. X e r\ ( r\) f' 01...A to: e . 1 ci n n tr. lrlrt) 1/ MILITARY W YOU ARE IN THE MILITARY-- IX) YOU HAVE PCS ORDERS TO A. . NEW COMMAND IN THIS AREA OTHER THAN LISTED UNDER OCCUPATION ABOVE? IF you ARF INAK MILITARY- - DO YOU HAVE PCS ORDERS TO A NEW COMMAND IN THIS AREAOTHER THAN LISTED UNDER OCCUPATION ABOVE? . - — IF SO - NEW DI ITY STATION IF SO -NEW DUTY.STATION . NAME OF BANK ADDRESS .. , : .. . . . - . ACCOUNT NUMBER CinicKING , ' • l-• -- 415))1 k.rd • • . : . .. ,... . . . ' SAN' I N( IS Ir. ARE YOI I THE REGISTERED OWNER OF THIS HOME? IF NOT, NAME. • ANI) ADDRESS LW REGISTERED OWNER: . NAME AND ADDRESS OF DEALER FROM WHOM HOME WAS PURCHASED: _ _:CHECKVIIICILOF THE F.OLLOWINGARE INCLA MED N THE 1101vIE WASHER DRYE ' RANGE • ".. NAME ADDRESS - . , .. ':- .. — AccouNT NO. MONTHLY PAYMENT NP43 '$ POLICY # . — • - • ' I IEN HOLDER • ACCOUNT - - - - - --- --: -- • • ARE YOI I THE REGISTERED OWNER OF THIS HOME? IF NOT, NAME. • ANI) ADDRESS LW REGISTERED OWNER: . NAME AND ADDRESS OF DEALER FROM WHOM HOME WAS PURCHASED: _ _:CHECKVIIICILOF THE F.OLLOWINGARE INCLA MED N THE 1101vIE WASHER DRYE ' RANGE REFRIGERATOR . !DISHWASHER • DISPOSAL__ _ . . . .. . . .. .... ,.. .. ....... . _ CURRENT NEEDED : 220 ....-----110 IF YOU-USE•GAS,WHATXYPE-?---- . $ .„, ii, •i .k.;:•`' • '''' ' $ TOTAL OF ALL PAYMENTS - . . . . . . .. $ MANUFACTURED HOME. INFO MATION - • NIANIIFACT"}" vilvb•111 fe-. .,..._. _. , • • 5171. • )( (V YEAR 4,1 / 7 moDEL4 fr,;,444. 44.1 ;.: . :..VINIIr.15..-r7 96 LINDEN( i INSTITI/1101: itj ' AMOUNT OF LOANS MONTHLY PAYMENTS: - :.' ' ' ' . INSURANCE t 'OM PAN Y F . POLICY # . — • - • ' I IEN HOLDER • ACCOUNT - - - - - --- --: -- • • ARE YOI I THE REGISTERED OWNER OF THIS HOME? IF NOT, NAME. • ANI) ADDRESS LW REGISTERED OWNER: . NAME AND ADDRESS OF DEALER FROM WHOM HOME WAS PURCHASED: _ _:CHECKVIIICILOF THE F.OLLOWINGARE INCLA MED N THE 1101vIE WASHER DRYE ' RANGE REFRIGERATOR . !DISHWASHER • DISPOSAL__ _ OTHER ' . . .. . . .. .... ,.. .. ....... . _ CURRENT NEEDED : 220 ....-----110 IF YOU-USE•GAS,WHATXYPE-?---- — • VEHICLES- ' • • • ' • (INCLUDE MOTOR HOMES, BOATS AND MOTORCYCLES) DESCRIPTION (IE AUTO, ETC.) YEAR, MAKE & MODEL . LICENSE # & STATE 170/rN " V/ 1031Z.A. A/mu:two_ - - : , Gluzsiiy-7. 1. _:. 1---11-1-7 5?' Be advised that EACH OF THE FOUR (4) questions below must be answered in order to consider your application for residency in the community (check yes or no for each): ' I. HAVE YOU EVER HAD A BANKRUPTCY, LEGAL JUDGME:N7 OR COLLECTION MADAGAINST YOU? NO 0 YES 2. HAVE YOU EVER BEEN CONVICTED OF A FELONY? NO a YES . (If YES4 please exihtin on the ine elow) - 3. ARE YOU CURRENTLY UNEMPLOYED? 4. HOW DID YOU HEAR ABOUT OUR COMMU RESIDENT INFORMATIjiT RESIDENTON LEA E ' - . • - ' RESIDENT ON LEASE NAME VN.04 _ — SOCIAL SECURITYNUMBER *- • • - " ' ' NAME • " SOCIAL SECURITY NUMBER RELATIONSHIP NAME SOCIAL SECtiRITY NUMBER • 'MALE/FEMALE HOME PHONE NAME WORK PHONE . HOME PHONE j•-: - ••; ••1.; •• -- • — * WORK PHONE NAME DATE OF BIRTH Q/7 )Sa-ciwcr.'(-7 ..,.- '..,- ,. . CHILDREN RESIDING IN TUE HOME NAME DATE OF BIRTH SOCIAL SECURITYNUMBER *- • • - " ' RELATIONSHIP NAME DATE OF BIRTH „ " ' soci4L,Aputury':Numatr;4:?",-.::',*: - . RELATIONSHIP NAME DATE OF BITh I . • • 'MALE/FEMALE . . SPAYED? NAME DATE : Coi With' - ‘ ' NAME DATE OF BIRTH -„„ 1: .7,1:1.--€.-.^, '..,- ,. . OTHERS RES ING THE 11614E' • NAME DATE OF BIRTH SOCIAL SECURITYNUMBER *- • • - " ' RELATIONSHIP NAME DATE OF BIRTH ' • " ' soci4L,Aputury':Numatr;4:?",-.::',*: - . RELATIONSHIP TOTAL NUMBER OF PERSONS RESIDING IN THE HOME Person(s) to contact in Case of Emergency: NAME ADDRESS gr)021 )a/ti0-461-\ C24) 7 , • • ••• • •• • .'en*E.. • • (t.-6 RELATIONSHIP • : . Please list any additional pets. NOTE: Farm and most exotic animals not allowed. Please cheql with management: I understand that all pets must be approved by management prior to moving into ' , ,„ anufactured Home Park and a pet agreement must be signed for all pets approved by management upon the signing of the lease. .Any.toisrepresentation on this form is cause for eviction from LEIBY'S MHC. Any of the following will also be cause for eviction or disposal of pets):.......... I. Distribution of litters within the park without prior approval from Management . . 2. Failure to keep pet(s) leashed at all times (day and night)., Leash not to excteclit) feet. - 3. Failure to keep arca clean. . 4. Barking dogs, howling cats, or loud noise.produced i* any other typoPet distuitinintiObors. 5. Failure to register existing pets and any pet sent'dafttIlildate.:-NOrier 2.5 IFS': - " ' ' ' DECLARATION OF DOMESTICATEaFET.S.":..:-: DOGS ' '.. BREED AGE COLOR . .... . . -WEIGHT. , • 'MALE/FEMALE . . SPAYED? CITY TAG # ' : , . . • ..::,' ) :, 1: .7,1:1.--€.-.^, ...-,,; .,. --.:.• :7!;:•:-..i.i: ATS BREED BREED AGE COLOR WEIGHT . . ;;MALE/F.EMA0;-,,,;,- H. SPAYED? CITY TACT # • - - Please list any additional pets. NOTE: Farm and most exotic animals not allowed. Please cheql with management: I understand that all pets must be approved by management prior to moving into ' , ,„ anufactured Home Park and a pet agreement must be signed for all pets approved by management upon the signing of the lease. .Any.toisrepresentation on this form is cause for eviction from LEIBY'S MHC. Any of the following will also be cause for eviction or disposal of pets):.......... I. Distribution of litters within the park without prior approval from Management . . 2. Failure to keep pet(s) leashed at all times (day and night)., Leash not to excteclit) feet. - 3. Failure to keep arca clean. . 4. Barking dogs, howling cats, or loud noise.produced i* any other typoPet distuitinintiObors. 5. Failure to register existing pets and any pet sent'dafttIlildate.:-NOrier 2.5 IFS': - " ' ' ' EXHIBIT "B" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Mag. Dist. No: MDJ-09-3-04 MDJ Name: Honorable Kathryn H. Silcox Address: 5275 East Trindle Road Suite 110 Mechanicsburg, PA 17050 Telephone: 717-697-2201 Beth Graves c/o Leiby's M.H.C. 7075 Carlisle Pike Carlisle, PA ,17015 f 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 -09304 -LT -0000165-2014 Leiby's MHC LLC Judgment Summary _ -- Participant Barbara Vandersloot Leiby's MHC LLC Notice of Judgment/Transcript Residential Lease Leiby's MHC LLC v. Barbara Vandersloot Docket No: MJ -09304 -LT -0000165-2014 Case Filed: 12/4/2014 Yes No Defendant Disposition Disposition Date Barbara Vandersloot Judgment for Plaintiff 12/17/2014 Joint/Several Liability $0.00 $0.00 Individual Liability $1,452.36 $0.00 Amount $1,452.36 $0.00 Judgment Finding (*Post Judgment) In the matter of Leiby's MHC LLC vs. Barbara Vandersloot on MJ -09304 -LT -0000165-2014, on 12/16/2014 the judgment was awarded as follows: The amount of rent per month, as established by the Magisterial District Judge, is $376.00 ,Iudoment Component Joint/Several Liability Individual Liability Deposit Applied . Amount ' Filing Fees Costs Server Fees Rent in Arrears $0.00 $110.50 $110.50 $0.00 $7.00 $7.00 $0.00 $32.30 $32.30 $0.00 $1,302.56 $1,302.56 Grand Total: $1;452.36 Portion of judgment for physical damages arising out of residential lease: $0.00 MDJS 315A Page 1 of 3 Printed: 12/17/2014 9:32:13AM Leiby's MHC LLC V. Barbara Vandersloot Docket No.: MJ -09304 -LT -0000165-2014 IN AN ACTION INVOLVING A RESIDENTIAL LEASE; ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR. POSSESSION •• WITHIN TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY 'FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF • COURT ORTHECOURTOPCOMMON PLEAS, CIVIL'DIVISION. AN APPEALMUST BE FILED WITHIN THIRTY DAYS IN RESIDENTIAL LEASE ACTIONS INVOLVING A VICTIM OF pOMESTIC.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.RENTOR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED. HOWEVER, LOW-INCOME AND/OR • SECTIONS 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 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 OTHERYiliag,c0M"PLIESANITH TH5„JUDGMENT. i. t," .. • . . /01 ) -7// Date The Honorable Silcox I certify that this is a true and correct copy of the record ofthe proceedings containing the judgmen I District J Date Magisteri • • MDJS 315A . Page 2 of 3 Printed: 12/17/2014 9:32:13AM Leiby's MHC LLC V. Barbara Vandersloot. Leiby's MHC LLC 7075 Carlisle Pike Carlisle, PA 17015 Defendants) Barbara Vandersloot 252 Deerfield_ Rd.. Camp Hill, PA 17011,' Authorized Agent - Plaintiff(s) Beth Graves Go Leiby's M.H.C. 7075 Carlisle Pike Carlisle, PA 17015 Participant List Docket No.: MJ -09304 -LT -0000165-2014 MDJS 315A Page 3 of 3 Printed: 12/17/2014 9:32:13AM MANUFACTURED HOME COMMUNITY 7075 Carlisle Pike, Carlisle PA 17015 PH (717) 697-1321 Ltax 1?\B„jet., RteAu-acbTal gJxa4 t55 ot 1,t). Pia to Pennsylvania Act No. 261 of 1976, : ce vided to you as required by that Act, please take notice dial your - • $ tat4 , s which on or beim CT 20 , has not been received to e---pstV0 jack_ . vaiCNtn the $5("(late charge is not paid within thirty (30) days, , 20 14- ), we shall- commence the eviction wadable to us by law. ill a1s-serve to notify you that if you pay the overdue rent within the thirty (30) V period described above, but again fail to make a rental payment when due within six (6) months from the date of this notice, eviction proceedings may be commenced with no further notice to you. Date 0 -5. 114, z3 Cokaay, 50•°° - k Ti 25 MANUFACTURED HOME COMMUNITY 7075 Carlisle Pike, Carlisle PA 17015 PH (717) 697-1321 NOTICE RESTINT Owcbco-ick zu)AliA ADD ALtbXq ba,41.1-00 Dear R3 \/(11) Re Qi CV- b'LLf2)5 CdP u, Pursuant to Pennsylvania Act No. 261 of 1976, and the notice provided to,xou as rawiAci by that Act, please take notice that your monthly -rental payment of $ which was due on Of before DOCIGirlih Jilt/ , 20 I , has not been received to date. If this overdue rent, plus the L50. late charge, is not paid within thirty (30) days, , (by , 20 t L\-.), we shall- commence the eviction proceedings and other rernecrms available to us by law. This will also serve to notify you that if you pay the overdue rent within the thirty (30) day period described above, hit again fail to make a rental payment when due within six (6) months from the date of this notice, eviction proceedings may be commenced with no further notice to you. Date IR- PA to!t 3.09 qi ituak_ 1,1). cLoapeents/Park Specific Fenes/PA-NOrdoc 12/00 7009 U.S. Postal Service, CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery intormslion visit our website lit www.tisps.com„, Postage. Owned Fee Return Receipt Fee (Endorsement Required) Restricted Denver), fee (Endansement Required) Total Postage & Reek Senulb or PO Box No. $ CIA s3.30 no .% P3 Fe; m 3F00 20r),.., So Nevei:A, For ins;,,,citen, CERTIFICATE OF SERVICE I, Rob Bleecher, Esquire, an attorney for Plaintiff, hereby certify that I have served the foregoing Complaint on this date, by depositing a true and correct copy of the same in the United States mail, first class postage prepaid, addressed as follows: Barbara L. Vandersloot 630 Grandview Avenue Camp Hill, PA 17011 Barbara L. Vandersloot 252 Deerfield Road Camp Hill, PA 17011 Dated: January 13, 2015 By: PECHT & ASSOCIATES, P.C. leecher, Esquire