HomeMy WebLinkAbout05-3241
ESTHER MAE BRANDT
Plaintiff
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
Vs.
VIRGINIA R. ADAMS
Defendant
CNIL TERM tJS. 3;).,,/ / ~
CNIL ACTION -REPLEVIN
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set
forth in the following pages, you must take action within twenty (20) days after this complaint
and notice are served, by entering a written appearance personally or by 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 MAYBE 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
(717) 249-3166
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
ESTHER MAE BRANDT
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYL VANIA
05- 3;2.1./ I
CWIL ACTION - REPLEVIN
c::wJ J~
Vs.
VIRGINIA R. ADAMS
Defendant
CWIL TERM
COMPLAINT
And Now, comes the Plaintiff, Esther Mae Brandt, by and through her attorneys MidPenn
Legal Services and Geoffrey M. Biringer, who sets forth as follows:
1. Plaintiff is Esther Mae Brandt, an individual who resides at 130 Cherry Street,
Carlisle, P A 17013.
2. Defendant is Virginia Adams, who resides at 917 W. Louther Street, Carlisle, PA
17013.
3. On December 1,2004 Plaintiff rented 432 Fairground A venue, Carlisle, P A 17013
from the Defendant.
4. On February 3, 2005, Defendant filed a Landlord/Tenant Complaint against Plaintiff
seeking possession plus rent remaining due (Complaint attached hereto as exhibit "A").
5. On February 18, 2005, Defendant obtained a judgment for possession and One
Thousand One Hundred dollars and fifteen cents ($1,100.15) against Plaintiff. (Judgment
attached as Exhibit "B").
6. On March 3, 2005, Defendant obtained an Order for Possession of the leased premises,
giving the Plaintiff until March 14, 2005 to vacate (Order attached hereto as Exhibit "C").
7. In accordance with said order, Plaintiff was evicted from the property on March 14,
2005, taking as much as she could fit into a car.
8. On March 14, Defendant changed the locks to the premises. Defendant allowed
Plaintiff into premises on March 19 to remove possessions, but at no time after.
9. Plaintiff alleges that at no time described herein, did Defendant obtain a levy on
Plaintiffs personal property, present her with a bill for storage, or give her any indication that it
was her intent to dispose of said personal property.
10. As a result of Defendant's unlawful taking or holding, Plaintiff is without and seeks
to obtain the following items of personal property, whose location or locations are unknown to
her:
Item Value
Clothes (Summer, Winter) $1,000
(Dresses, Skirts, Blouses, Jumpers, Pant suits, slacks, jeans, shorts, T-Shirts,
Underwear, bra's, slips, socks and footees, sport bra's, sweat pants, nylons, summer and winter
PI's, Robes, Jackets, Coats, Gloves, High Heels, Slippers, Boots, summer shoes)
Shoes $200
Coat Rack $10
Pictures, Mirrors $300
Rugs $100
Towels, bathroom items $200
Bedding, (Pillows, Blankets) $400
Sewing Basket (Longaberger) $100
Jewelry Boxes (2), Jewelry case, jewelry $500
Eight bags of dirty clothes, towels, bedding, blankets $150
Two suitcases (small and large) $100
Shelves (Ten Hanging) $150
Christmas Decorations $200
Dishes, glasses, pots and pans, silverware, knife set $400
Coffee Pot $60
Toaster Oven $100
Toaster $50
Microwave (new- still in box) microwave stand $100
George Foreman Grill $50
Can opener, other cooking utensils, food $300
Canned food, baking items, refrigerator and freezer items $150
Cleaning supplies $75
Sweeper (two) $200
Sofa, Lights $150
Computer and Computer Desk $300
Roll Top Desk $400
Coffee Table, Bookcase, Tall Cupboard $400
Recliner $200
Box, Spring mattress, Head and Foot Board $300
Dresser with large mirror $150
Dresser chest $100
Boxes of personal items $400
Books and magazines $250
Washer and Dryer $250
Two TV's (One 13") $150
(One 32") $150
Several Boyd's Bear $150
Wooden Bench $50
Two wooden stools $50
Step ladder $50
Wooden Desk Chair $100
Plant pots, hangers, hardware $100
DVD
VCR
VCR movies (30)
DVD movies (10)
Cassette tapes (60)
CD tapes (40)
Two radios wi CD and cassette
Two air conditioners
HoMedics Sole Therapy Foot Bath (new)
Linens and Towels
Several sheet sets (fitted, flat, pillow cases)
Towel sets - Bath towel, hand towel, wash cloths
Beach Towels - 2 Lion King - 4 Martha Stewart
Curtains, Curtain Rods, Blinds
Dishware
Plates, Saucers, Cups, Champaign glasses,
Crystal drinking glasses, Brandy glasses, Set of bowls
Cereal bowls, Glass pie pans, Casserole dishes,
Meatloaf pan, mugs, crystal bowl,
Salt and pepper shakers, sugar and milk container,
Canister set of four.
Desk and office and Computer Supplies
Paper, tablets, screen cleaner, pens and pencils,
Paper clips, desk trays (wooden), desk lamp,
Five telephones (1 cordless, 1 regular, 3 cell)
Bible, Religious material
$150
$150
$300
$150
$200
$150
$150
$100
$20
$400
$150
$1000
$500
priceless
$11,915 Total
11. Defendant's holding of Plaintiffs possessions is illegal, as Defendant obtained
Plaintiffs possessions without due process oflaw and, further, Defendant has no right, title or
interest in Plaintiffs possessions.
WHEREFORE, Plaintiff prays that this Court Order that Plaintiffs possessions be
returned to her from the Defendant or that, if unavailable, Plaintiff be awarded judgment in the
total amount of Eleven Thousand Nine Hundred Fifteen Dollars ($11,915), said amount being
within the amount subject to compulsory arbitration.
xi~/Jnr3:-t~~
Geoffrey M. Btringer, Esquire (/
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717)243-9400
Sup. Ct. LD. #18040
COMMONWEAL TH OF PENNSYLVANIA
COUNT.Y OF: CUMBERLAND
t
LANDLORD AND
TENANT COMPLAINT
Magosteflal District Numl:ler;
09-2-01
PLAINTIFF:
NAME and ADDRESS
District Justice Name: Hon.
I
VIRGINIA ADAMS
917 W. LOUTHER STREET
CARLISLE. PA 170J.4. .$3"(:;
717-2423-5399 ~ r
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PAULA P CORREAL
Add,,,,, 1 COURTHOUSE SQUARE
EAST WING - COURTHOUSE
CARLISLE, PA 17013
T,Io,ho"" (717)240-6564
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VS,
---1
DE~DANT: NAME <lOd ADDRESS
ESTER BRANDT
'(3L+ro"FAIRGROUND AVENUE
CARLISLE, PA 17013
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Docket No.:
Date Filed:
L T -69-05
2/3105
.
TO THE DEFENDANT: The above named plaintiff(s) asks AMOUNT DATE PAID
judgment together with costs against you for the
possession of real property for: Filing Costs $ I I
Lease is ~ Residential o Nonresidential. Service Costs $ / /
Total $ 94.08 02/03105
0 Damages for injury to the real property, to wit:
b in the amount of: $
Damages for the unjust detention of the real property in the amount of <
w
~ Rent remaining due and unpaid on filing date in the amount of $ 500.00
~ -
And additional rent remaining due and unpaid on hearing date $
Total: $
THE PLAINTIFF FURTHER ALLEGES THAT
1. The location and address. if any, 9f the real property is 440 FAIRGROUND AVE, CARLISLE, PA
2. The plaintiff is the landlord of that property.
3. He leased or rented the property to you or to under whom you claim.
4. ~ Notice to quit was given in accordance with law, or
0 No notice is required under the terms of the lease.
5. 0 The term for which the property was leased or rented is fully ended, or
~ A forfeiture has resulted by reason of a breach of the conditions of the lease, to wit:
FAILURE TO PAY RENT or,
~ Rent reserved and due has, upon demand, remained unsatisfied,
6. You retain the real property and refuse to give up its possession.
I,VIRGINIA ADAMS verify that the facts set forth in this complaint are true and
correct to the best of my knowledge, information and belief. This statement is made subject to the penalties of Section 4904
of the Crimes Code (1B PAc C.S. ) 4904) relating to unsworn falsification to auth'Ofll G I NAL ON FILE
(Signature of Plaintiff)
( )
(Plaintiffs Attorney) (Address) (Phone)
IF YOU HAVE A DEFENSE to this complaint you may present it at the hearing. IF YOU HAVE A CLAIM against the plaintiff arising out of the occupancy of
the premises. which is in the district justice Jurisdiction and which you intend to assert at the hearing. YOU MUST FILE it on a complaint form at this office
BEFORE THE TIME set for the hearing. IF YOU DO NOT APPEAR AT THE HEARING. a judgment for possession and costs, and for damages and rent if
claimed. may nevertheless be entered against you. A judgment against you for possession may result in your EVICTION from the premises. If you are
disabled and require assistance, please contact the Maaisterial District office at the address above.
AOPC 310A (12-1-98)
C>c AA:~
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUllBBlitLAlIID
09-2-01
NOTICE OF JUDGMENTrrRANSCRIPT
!'.LAINTIFF RESIDENTI~~E~o~~~s~
ADAIIS, VJ:B.GDlJ:A R I
917 w. LOU:L'.I1..151t ST
CAJlLXSLB, PA 17013
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VS.
Mag. Dis!. No.
MDJ Name: Hon.
Address:
PAULA P. COllll.lu.L
1 COURTHOUSB SQUAltB
CAJlLXSLB, PA
TolophooO' (717) 240-6564 17013-0000
DEFENDANT:
IjRARDT, BSTD
440. FArRGROUJID A'lI_u.15
CAJlLXSLB, PA 17013
L
NAME and ADDRESS
I
PAULA P. CORRJl!lU.
1 COURTHOUSB SQUAltB
CAJlLXSLB, PA 17013-0000
Docket No.: LT-0000069-05
Date Filed: 2/03/05
~
.
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLArJl'l'XFF
~ Judgment was entered for: (Name) ADAIIS. VJ:B.GXRrA R
o Judgment was entered against BJlAJIIDT, BSTD in a
~ LandlordfTenant action in the amount of $ 1.100.15 on 2/18/05 (Date of Judgment)
The amount of rent per month, as established by the Magisterial District Judge, is $ 500.00.
The total amount of the Security Deposit is $ .00
Total Amount Established b\l MDJ Less' Security Deposit ApQlied = Adjudicated Amount
Rent in Arrears $ 1,000.00 -$ .00 = $ 1,000.00
Physical Damages Leasehold Properly $ .00 $ .00 = $ .00
Damages/Unjust Detention $ 00 $ _ 00 = $ 00
Less Amt Due Defendant from Cross Complaint - $ _ 00
Interest (if provided by lease) $ 00
UT Judgment Amount $ 1,000 00
JudgmElnt Costs $ 100 _ 15
Attorney Fees $ 00
Total Judgment $ 1,100.15
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
DO Possession granted if money judgment is nO! sallSTleo oy time O! eViction.
Possession not granted. 0 Defendants are jointly and severally liable.
o Attachment Prohibited/
42 Pa.C.S. S 8127
o
[!J Possession granted.
This case dismissed without prejudice.
IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARlY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN
TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FlUNG A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS
OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. 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 ALED.
IF A PARlY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE PARlY 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 PARlY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT 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 MAYBE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT Of COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY ALE
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. . . ..
- .
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s containing
;> /' 3/'15
Date.
~~q?.T~ission expire Irst Monday of January, 2006 . Ex, ?? "
SEAL
.-;'
COMMONWEALTH OF PENNSYLVANIA
COUlllT-Y OF: ctJIlBJJlIT.:r,lIIJ)
'" ",'~1olo
ORDER FOR POSSESSION,
RETURN AND NOTICE -, .
09-2-01
PLAINTIFF:
'ADAMS, VIRCUlaA R
917 W. LOUTBBR ST
CARLISLB, PA 17013
L
N~E and ADDRESS
-,
Mag. Dis1. No.:
MDJ Name: Hon,
Address:
PAULA P. COll~BlI,L
1 COURTHOUSB SQUUB
CARLISLB, PA
..J
VS.
17013-0000
DEFENDANT:
fiJlUDT, BSTD
.A41l"PAIRGROUJIID A"_u.15
CARLISLE, PA 17013
L
NAME and ADDRESS
Telep""". (717) 240-6564
-,
BSTBR BJlUDT
440 PAIJWROUJIID A~_u.15
CARLISLB, PA 17013
Docket No.: LT-0000069-05
Date Filed: 2/03/05
..J
"*
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Judgment Amount $ 1,000.00
Costs in Original L T Proceeding $ 100.15
Costs in this Proceeding $ 88.58
Attorney Fees $ .00
Total $ 1,188.73
Time Filed:
Date Order Filed:
9:52AM
3/02/05
TO THE MAGISTERIAL DISTRICT JUDGE: The above named plaintiff, having obtained a judgment for possession
of real property located at: 440 FAIRGROUND AVENUE. CARLISLE. FA 17013
Address if any:
Requests that you issue an ORDER FOR POSSESSION for such property.
Date: 03-02-05 Plaintiff: (Sianature on File)
ORDER FOR POSSESSION
Date:
Received Date:
Time: tl: OOMl
Time: J3-
ified Constable)
. located at (Give location
To: JOB LBVDDA
You are hereby directed to deliver actual possession to
and/or address): ,.
D Defendant (Name):
D Adult person in charge ame :
Served with copy of ORDER FOR POSSESSION and served with NOTICE TO VACATE on (Date of service):
at (Location and Address):
XSince none of tlib~ found, served by posting a copy of the complaint conspicuously on the premises at
-(Oate): 3 D (Time): I. SJ,/J,."
D Order satisfied by payment of rent in arrears and costs D Premises vacated without forcible entry and ejectment
Amount Paid $
D. 'b . D Forcible entry and ejectment (Date):
Istn utlon (T' )
Ime:
To D Returned within five business days following delivery of
To possession to plaintiff or satisfaction by payment of rent
To In arrears and costs.
To Expenses and fees of sheriff or certified constable $
To
To
$
$
$
$
$
$
(Signature of Sheriff or Certified Constable)
(Print Name and Title)
NOTICE TO DEFENDANT TO V ACA TE
If you, and all the occupants of this .Qlopel\Y not authorized by the o'tn~r to be prpsent thereon, do no~cate this property within ten (10) days
after the (date 01 service) ~ f~ day of 1-' b.r<-.~ t::)j ,the law authorizes me to use, and I must
use, such force as may be necessary to enter upon this .e.ropprty, b~the ~aking in of any door or otherwise, and to eject you and aU unauthodz.ed
occupants. If necessary, eviction will commence on --:s / /1.11 a..s. after 12:01 AM.
At any time before actual delivery 01 the real property is m~de in execution 01 the Oreter for Possession, the defendant may, in a case for the ra.
covery of possession solely because of failure to pay rent, satisfy the Order for Possession by paying to the executing officer the rent actually in
arrears and the cost of the proceedings. .E ~ /( L-?
Complete if judgment of possession is based solely on failure to pay rent. Rent in Arrears $ Costs $
AOPC 311 B-05
The above-named Plaintiff, Esther Brandt, verifies that the statements made in
the above Complaint are true and correct. Plaintiff understands that false statements
herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn
falsification to authorities.
Date: b)~ 5
~ 1-YJ .8t1u.'VIcli
Esther Brandt
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ESTHER BRANDT,
Plaintiff
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
.:DOCKETNo. t1S' 3dtl/
euJ
VIRGINIA ADAMS
Defendant
:LANDLORD/TENANT
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow Esther Brandt, Plaintiff in the above, to proceed in forma pauperis.
I, Geoffrey M. Biringer, attorney for the party proceeding in forma pauperis,
certify that I believe the party is unable to pay the costs and that I am providing free legal
services to the party.
MIDPENN LEGAL SERVICES
By:
~.d~~4!' ~
. Geoffrey . Biriiger
8 Irvine Row
Carlisle, P A 17013
(717)243-9400
ID#18040
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SHERIFF'S RETURN - REGULAR
CASE NO: 2005-03241 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BRANDT ESTHER MAE
VS
ADAMS VIRGINIA R
CPL. TREVOR KENT
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - REPLEVIN
was served upon
ADAMS VIRGINIA R
the
DEFENDANT
at 1718:00 HOURS, on the 28th day of June
2005
at 917 W LOUTHER STREET
CARLISLE, PA 17013
by handing to
VIRGINIA R. ADAMS
a true and attested copy of COMPLAINT - REPLEVIN
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
3.70
.00
10.00
.00
31.70
So Answers:
?C---~':d'..e:~
7 7
R. Thomas Kline
00/00/0000
LS
Sworn and Subscribed to before
By:~1{r
Deputy Sheriff
00
me this p. - day of
(~ <>."" t' A. D
-'- Q;. )u ~ ~p,"-, ~
rothonotary ,
"
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 05-~1241 CIVIL
ESTHER MAE BRANDT
Plaintiff
VIRGINIA R. ADAMS
Defendant
: CIVIL ACTION - REPLEVIN
NOTICE TO PLEAD
TO: ESTHER MAE BRANDT
You are hereby notified to file a written response to the enclosed Answer and
New Matter within twenty (20) days from service hereof or a judgment may be entered
against you.
Respectfully Submitted
GREASON LAW OFFICE
"1/ d'lIOS
Date
//~yY..y\/~
C~reason, Esquire
P.O. Box 385
Carlisle, PA 17013
(717) 241-3030
Attorney for Defendant
"
II
I'
II
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 05-3241 CIVIL
ESTHER MAE BRANDT
Plaintiff
VIRGINIA R. ADAMS
Defendant
: CIVIL ACTION - REPLEVIN
ANSWER TO COMPLAINT AND NEW MATTER
AND NOW, comes the Defendant, Virginia R Adams, by and through her
attorney, Lisa M. Greason, Esquire and sets forth the following answers:
1. Defendant is without knowledge as to the truth of this averment.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7. Admitted in part, denied in part. Admitted that the Constable evicted Plaintiff
from the property on March 14, 2005. It is denied that Plaintiff took that much
with her. She took one bag, her purse, a dog and a cat when she left.
8. Admitted in part, denied in part. Defendant admits that she changed the locks.
The Constable was present when Defendant did this. Defendant further admits
that Plaintiff was allowed back on the premises on March 19 to remove
possessions. It is denied that Defendant denied or prevented Plaintiff from
reentry at any other time to remove her possessions.
9. Admitted in part, denied in part. Defendant admits that she did not obtain a levy
on Plaintiff's personal property. Defendant denies that she failed to give Plaintiff
any intent to dispose of her personal property. By way of further answer,
Defendant gave Plaintiff both verbal and written notice that she needed to
remove her remaining personal property or that it would be disposed of. The law
places no burden on the landlord to store tenant's belongings if they abandon
their personal property.
10. Denied. Strict proof of same is hereby demanded at trial. Values are completely
outrageous.
II
II
I[
11. Denied. Plaintiff abandoned her property. She had verbal and written notice
from the Defendant and the Court. Plaintiff was told on multiple occasions that
she needed to vacate and remove all of her personal belongings.
NEW MATTEH
12. Paragraphs 1-11 are hereby incorporated as if fully stated herein.
13. Plaintiff only paid the first month rent, therefore she knew or should have known
as early as January 1, 2005, that she would be removed from the property.
14. Defendant filed for judgment against the Plaintiff on February 3, 2005. At that
time, the plaintiff knew or should have known that she would be removed from
the property and should have made arrangements to remove her personal
property.
15. Plaintiff was present on the date of the hearing before Magisterial District Judge
Correal on February 18, 2005. At that hearing MDJ Correal told Plaintiff that this
was the third time in the past year that a lalndlord had to get a judgment against
her for non-payment of rent, that this behavior was becoming a habit and she
needed to change her behavior. During that hearing, Plaintiff stated to the MDJ
that she knew this was her fault.
16. Plaintiff failed to vacate the premises voluntarily. Defendant obtained an Order
for Possession on March 2, 2005. The Constable was unable to find Plaintiff on
that date so he posted a copy of the complaint on the premises on March 3,
2005. The Order for possession called for eviction on March 14, 2005. Said
Order was attached as Exhibit C on Plaintiff's Complaint and is incorporated
herein.
17.0n March 14,2005, the Constable and the Defendant arrived at the property to
physically remove the Plaintiff in accordance with the Order for Possession.
Defendant appeared to have not prepared ;anything for the eviction. She left with
one bag, her purse, a dog and a cat. All of Plaintiff's other possessions remained
on the property.
18. On March 16, 2005, Defendant sent an additional notice to Plaintiff that she had
10 more days to make arrangements to have her items removed from the
property or the Defendant would consider the property abandoned and remove it
herself.
19. Plaintiff made a request to the Defendant to have access to the property to
retrieve additional items. Defendant granted this request and on March 19,2005,
Plaintiff accessed the property and only retrieved her prescription drugs. Nothing
else was taken, nor were additional arrangElments made.
"
20. During the week of March 21, 2005, Defendant gave Plaintiff additional time to
retrieve her personal belongings. Plaintiff never showed to get her property.
21. Defendant, as a landlord, must mitigate her damages under the lease. Plaintiff
knew as early as January, 2005 that shls would not be able to stay in the
property. She made no arrangements to move any of her belongings from the
property despite repeated verbal and written warnings and Court Orders.
22. Effectively, Defendant considered that Plaintiff abandoned her property.
23. On March 31, 2005, Defendant took approximately 920 pounds of trash from the
property to the county landfill. The charge to Defendant for this was $32.07. The
receipt is attached as Exhibit A and is hereby incorporated herein.
24. On April 1, 2005, Defendant took Plaintiffs clothes and donated them to the
Salvation Army. The receipt for the clothing is attached as Exhibit B and is
hereby incorporated herein.
25. On May 3, 2005, Defendant took the remaining personal items of Plaintiff to a
local auction house. After the auctioneer took his commission, the Defendant
received a total of $83.00. The receipt for the auction is attached as Exhibit C
and is hereby incorporated herein.
26. On June 2, 2005, Defendant had to pay the water bill for the property that Plaintiff
failed to pay. The cost was $36.86. The receipt for the bill is attached as Exhibit
D and is hereby incorporated herein.
WHEREFORE, Defendant requests this Honorable Court to deny all claims by
the Plaintiff and to declare that Plaintiff abandoned her personal property. In the
alternative, Defendant prays this Court reduce any judgment for the Plaintiff by the
amount of judgment the Plaintiff owes to the Def'sndant along with charges Defendant
incurred to remove Plaintiffs property as well as Plaintiff's unpaid water bill.
Respectfully Submitted,
GREASON LAW OFFICE
7/;).9 (OS
Date
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~ P.O. Box 385
Carlisle, PA 17013
(717) 241-3030
ID #78269
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VERI FICA liON
Virginia R. Adams, states that she is the Defendent named in the foregoing instrument
and that she is acquainted with the facts set forth in thEl foregoing instrument; that the same
are true and correct to the best of her knowledge, information and belief; and that this
statement is made subject to the penalties of 18 Pa.C.SA ~ 4904 relating to unsworn
falsification to authorities.
Date:~
~~~lfd-
VL/ ,R. ADAMS
CUMBERLAND COUNTY LANDFI
620 Newville Rd, Newburg, PA 17240
(800) 531-4490
TICKET NUMBER: 77163755
Account Name: CASH
ACCOUNT #: 47119
Waste Tvpe
CD-7
Gross:
Tare:
NetWt:
Tons:
WEIGHMASTER
03/31/2005
Material Descriotion
6,280 Ibs
5,360 Ibs
g7n Ibs
0.46
~
C&D
1:25pm -1:47pm
[' WE, THE UNDERSIGNED, CERTIFY THAT THE
WASTE DeLIVERED FOR DISPOSAL 1$
NON,HAZAROOUS SOLID WASTE MATERIALS
CASH TICKET
TRUCK #: VIRGINIA RED PU N/A
Units
0.46
Manifest #1
Grid
Payment Type:
TOTAL DUE
TOTAL PAID
DRIVER SIGNATURE:
OriQin
CUMBERLAND COUNTY
1037
$32.07
$32.07
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THE SALVATION ARMY
RECEIPT FOR DONA TEl> GOOnS
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Description of Articles and its Condition:
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Valuation of gifts in kind is the privilege and responsibility of the donor. A Salvation
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Contributions are deductible for income tax purposes to the extent allowed by law,*
20 E. Pomfret Street, Carlisle PA 17013
Corps Address
"Note: Due to the record keeping and reporting requirements imposed by the IRS, The Salvation AmYj
requests that all donors who will require The Salvation Army to complete IRS Form 8283 (Non-Cash
Charitable Contribution) for a contribution of 55,000.00 or greater. to request that Form at the time of the
donation. The Salvation Army wili'not be able to execute such forms at allY time thereafter if the donated
item cannot be traced, The Salvation Army is required to repon such donlitions to the IRS.
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 05-3241 CIVIL
ESTHER MAE BRANDT
Plaintiff
VIRGINIA R. ADAMS
Defendant
: CIVIL ACTION - REPLEVIN
CERTIFICATE OF SERVICE
I hereby certify that I served a true and Gorrect copy of the Answer and New
Matter upon Geoffrey M. Biringer, Esquire, attorm~y for the Plaintiff, by depositing same
in the United States Mail, first class, postag,e pre-paid on the /1J} day of
aur; , 2005, from Carlisle, Pennsylvania, addressed as follows:
GREASON LAW OFFICE
Lisa M. Greason, Esquire
P.O. Box 385
Carlisle, PA 17013
(717) 241-3030
SupremEl Court # 78269
Attorney for Defendant
Date: r?/ liDS'
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ESTHER MAE BRANDT
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL V AN I A
v,
VIRGINIA R. ADAMS
Defendant
NO. 05-3241 CNIL
: CNIL ACTION - REPLEVIN
PLAINTIFF'S ANSWER TO DEFENDANT'S NEW MATTER
12. No response required.
13. Admitted that Plaintiff paid the first month's rent. It is denied that Plaintiff knew she
would be removed as Plaintiff gave Defendant a 60-day notice that she would be leaving.
(Notice attached as Exhibit "A").
14. Admitted that Defendant filed for judgment, but denied that she knew she would be
removed and would have to make arrangements for removing her possessions, as
Defendant led her to believe she would be able to remove herself and her belongings as
soon as she was able.
15. Admitted that Plaintiff was present, but the remainder of the paragraph is denied as it
relies on statements allegedly made by a third party not verified in Defendant's pleading.
16. Admitted that the Order for Possession was attached to Plaintiffs Complaint as
Exhibit "C," but the remainder of the Paragraph is denied as Plaintiff is without
information sufficient to form a belief as to the truth of the averment and proof thereof is
demanded at trial.
17. Denied. Almost all of Plaintiffs possessions were packed. She could take only that
which fit in her car, however.
18. Denied. Defendant is without information sufficient to form a belief as to the truth
of the averment, and proof thereof is demanded at trial.
19. Admitted that Plaintiff requested access, as she did on several occasions, but denied
that Plaintiff only retrieved prescription drugs. By way of further answer, Plaintiff again
filled her car with her possessions, and requested additional time and dates to be able to
retrieve other possessions.
20. Denied. Defendant did not give Plaintiff additional time, nor did she set dates when
Plaintiff could retrieve the rest of her property.
21.Denied. No answer required as paragraph states a conclusion oflaw. Further denied
that Plaintiff did not make arrangements to remove her property, and that Defendant gave
warnings to remove said property.
22. Denied. Plaintiff is without information sufficient to form a belief as to the truth of
the averment and proof thereof is demanded at trial.
23. Denied. Plaintiff is without information sufficient to form a belief as to the truth of
the averment, and proof thereof is demanded at trial.
24. Denied. Plaintiff is without information sufficient to form a belief as to the truth of
the averment, and proof thereof is demanded at trial.
25. Denied. Plaintiff is without information sufficient to form a belief as to the truth of
the averment, and proof thereof is demanded at trial.
26. Denied. Plaintiff is without information sufficient to form a belief as to the truth of
the averment, and proofthereof is demanded at trial.
WHEREFORE, Plaintiff requests that this Court dismiss Defendant's New Matter and
find for the Plaintiff on her original Complaint.
Date: 7~ 1--- tJ 5
Respectfully Submitted:
MIDPENN LEGAL SERVICES
By:~Jh.~
Geoffrey M. Biringer
8 Irvine Row
Carlisle, PA 17013
(717)243-9400
ID#18040
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VERIFICATION
The above-named Plaintiff, Esther Mae Brandt, verifies that the statements made
in the ab<lve Answer to New Matter are true and correct. The Plaintiff understands that
false statements herein are made subject to the penalties of 18 P A. C.S. ~4904, relating to
unsworn falsification to authorities.
Date: DAJcJi'.I./J ~'3 iAoo5
Ei-4c rmc.v&Ce/YtJ-I-
Esther Mae Brandt, Plaintiff
CERTIFICATE OF SERVICE
I, Geoffrey M. Biringer, being a member in good standing of the Bar of
Pennsylvania, hereby certify that I served a true and correct copy of the foregoing
document on this 9th day of August, 2005, by placing same in the United States mail, first
class, postage prepaid, addressed as follows:
Lisa M. Greason, Esquire
PO Box#385
Carlisle, P A 17013
BY:~ '/4 ,1.7..:...,
,/ Geoffrey M. Biringer :::::::.~
Attorney for the Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
Supreme Court ID#I8040
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CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05- 3Z ylCIVIL
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RULE 1312-1.
The Petition for Appointment of Arbitrators shall be substantially in the following form:
PETITION FOR APPOINTMENT OF ARBITRATORS
TO THE HONORABLE, TIlE JUDGES OF SAID COURT:
~1./...&-f1'~ /tz ,~ ' counsel for the plaintiff/defendant in the above action (or actions),
respectfully represents that:
1. The above-captioned action (or actions) is (are) at issue.
2. Theclaimoftheplaintiffintheactionis$ ~ 9/5"
The counterclaim of the defendant in the action is "" 0
Th~ !ollowing att~rneys are in~erested in the case(s) as c."unsel or are oth..erwi~e disqu
y:7~1'?7t /:iq,'r.2&~.,~4t..
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be
submitted.
. tied to sit as arbitrators:
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Respectfully submitted,
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ORDER OF COURT
AND NOW,
,19_, in consideration of the
foregoing petition,
Esq., and
actions) as prayed for.
Esq.,
,Esq., are appointed arbitrators in the above captioned action (or
By the Court,
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ESTHER MAE BRANDT
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL V AN I A
v.
VIRGINIA R. ADAMS
Defendant
: NO. 05-3241 CNIL
: CIVIL ACTION - REPLEVIN
PRAECIPE TO PROCEED IN FORMA PAUPERIS
Kindly allow Esther Mae Brandt to proceed in forma pauperis. I, Geoffrey M.
Biringer, attorney for the party proceeding in forma pauperis, certify that I believe the
party is unable to pay the costs and that I am providing free legal service to the party.
Date: _January 26,2006
MIDPENN LEGAL SERVICES
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By: ..~.-11 ,/.z(i:~
Geoffrey M. Bi 'nger "
8 Irvine Row
Carlisle, PA 17013
(717)243-9400
ID#18040
Attorney for the Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ESTHER MAE BRANDT,
Plaintiff
NO. 2005-3241
VS.
CIVIL ACTION -,LAW
VIRGINIA R. ADAMS,
Defendant
REPLEVIN
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance of E. RALPH GODFREY, Esquire of SALZMANN
HUGHES, P.c. as counsel of record for the Defendant in the above-referenced matter.
C~
. E. Ip , Esquire ______)
Attorney ID# 77052' ~
354 Alexander Spring Road
Suite I
Carlisle, PA 17013
717-249-6333
Attorney for Defendant
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 05,3241
ESTHER MAE BRANDT
Plaintiff
VIRGINIA R. ADAMS
Defendant
: CIVIL ACTION - REPLEVIN
PRAECIPE FOR WITHDRAWAL OF APPEARANCE
TO THE PROTHONOTARY OF SAID COURT:
Please withdrawal my appearance on behalf of the Defendant in the above-
captioned case.
GREASON LAW OFFICE
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Date
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'..... Li~a M. Greason, Esquir .
P.O. Box 385
Carlisle, PA 17013
(717) 241-3030
ID #78269
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CERTIFICATE OF SERVICE
I, E. Ralph Godfrey, Esquire, hereby certify that I served a copy of the foregoing Praecipe
to Withdraw and Praecipe to Enter Appearance upon all parties to this action, by mailing a copy
thereof on this 20th day of March, 2006, to:
Geoffrey M. Biringer, Esquire
401 East Louther Street
Suite 103
Carlisle, P A 17013
By
E. e)i SqUire~
Attorney I.D. No.
17 W. South Street
Carlisle, PA 17013
(717) 243-5100
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Civil Action - Law,
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Oath
We do sole y wear (or affinn) that we will support, obey and defend the Constitution of the United
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Award
We, the undersigned arbitrators, having been du1y appointed and sworn (or affirmed), make the
following award: (}{ote: If d ges for dela are awarded, ey shall be separately stated.)
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Notice of Entry of Award
Now, the :JIAA dayof ~ ,20 t>(,.. , at 3; 1:2 , P .M" the above award was P_1.-rJ
entered upon the docket and notice the eof given by mail to the parties or their attorneys. M-
be paid upon appeal: $ .2 tt 0, C/O
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