HomeMy WebLinkAbout06-1333COURT OF COMMON PLEAS
IA
Judicial District, County Of Cumberland
FROM 0309-OCi
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. 06-133J
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 District Justice on
the date and in the case referenced below.
09-1-03 Richard S. Doy
Hill
PA
unIt Ui JUUUMtNI IN THE CASE OF(Plelnfilr) (DelentleM)'
()2/28/2006 &mquiebanna Vial Apammzs Vs Ray S[ "Ski
LT-0000060-06
This block will be signed ONLY wh
R.C.P.D.J. No. 10088.
This Notice of Appeal, when received
SUPERSEDEAS to the judgment fc1A
under Pa. I If appellant was
17011
in action
District Justice, will operate as a before a District Justice, XCq*PLAINT MUST BE FILED within twenty
lion in this case.
I (20) days after riling the NOTICE of APPEAL.
17Z
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before District Justice. IF
NOT USED, detach from copy of notice of appeal to be served upon appellee.
PRAECIPE: To Prothonotary
Enter rule upon S'usnuieba®a Vier Apazbments appellee(s), to file a complaint in this appeal
Name or appellees) ?j?
(Common Pleas No. U(, __.) 3 3 `3 T) within twenty (20) days after service of?%r$(L? nlry o>pdgment of non pros.
RULE: To Susquehanna View Apartments , appellee(s)
Name of appellees)
NOTICE OF APPEAL
or
(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 MAYBE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of the mailing.
I
Date: '71,Lati.?.A c? . 20 s04 ) )-,1, .
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
AOPC 312-02
Signature of Pmfhonolary or Deputy
WHITE-COURT FILE TO BE FILED WITH PROTHONOTARY GREEN-COURT FILE YELLOV? - APPELLANT'S COPY
PINK -COPY TO BE SERVED ON APPELLEE GOLD-COPY TO BE SERVED ON DISTRICT JUSTICE
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 , upon the District Justice designated therein on
(date of service) , 20 , ? by personal service ? by (certified) (registered) mail,
sender's receipt attached hereto, and upon the appellee, (name) , on
20 ? by personal service ? by (certified) (registered) mail,
sender s receipt attached hereto
(SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS DAY OF 20_.
Signature ofefficial beforo whom affidavit was made,
Title of official
My commission expires on ............... ?G __._
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Srgrraturo of "Mart
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1.
?- COMMONWEALTH OF PENNSYLVANIA
'VUNIY I.
Mag. Dist No.'.
09-1-03
MDJ Name'. Ron.
RICHARD S. DOUGHERTY
Add,ess, 9 8 S ENOLA DR STE 1
ENOLA, PA
Telephone: (717) 728-2805 17025
NOTICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF: RESIDENTIAL LEASE
NAME and ADDRESS
rSUSQUEHANNA VIEW APTS ?
208 SENATE AVENUE
CAMP HILL, PA 17011
L _I
VS.
DEFENDANT: NAME and ADDRESS
rSHEPSKI, RAY
208 SENATE AVENUE APT/STE 818
CAMP HILL, PA 17011
KAY SHEPSKI L J
208 SENATE AVENUE APT/STS 818 Docket No.: LT-0000060-06
CAMP HILL, PA 17011 Date Filed: 2/14/06
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLAINTIFF
- ,% Judgment was entered for: (Name) SUSQUEHANNA VIEW APTS
Judgment was entered against SHEPSKI, KAY in a
® Landlord/Tenant action in the amount of $ 97.50 on 2/28/06 (Date of Judgment)
The amount of rent per month, as established by the Magisterial District Judge, is $ 185.00.
The total amount of the Security Deposit is $ 103.00
Total Amount Established by MDJ Less - Security Deposit Appplied =
Rent in Arrears $ 00-$ . D0 =
Physical Damages Leasehold Property $ -.90-$ .00 =
Damages/Unjust Detention $ o0 -$ .00 =
Less Amt Due Defendant from Cross Complaint -
Interest (if provided by lease)
LIT Judgment Amount
? Attachment Prohibited/
42 Pa.C.S. § 8127
? This case dismissed without prejudice.
® Possession granted.
? Possession granted if money judgment
? Possession not granted.
Judgment Costs
Attorney Fees
Total Judgment
Post Judgment Credits
Post Judgment Costs
Certified Judgment Total
$ Adjudicated Amount
$ .00
$ _00
$ .00
$ _oa
$ _00
$ 97.50
$ 0r
97.50
? Defendants are jointly and severally liable.
IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIV
TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING 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 PROTOONOTARY/CLERK OF COURTS THE LESSER OF
THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED.
IF A PARTY WISHES TO APPEAL ONLY 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 _j Magisterial District Judge
certl y that this is a true an orr t copy t rec the ro s contalning t e )u gment.
Date Magisterial District Judge
My commission expires first Monday of January, 2012 SEAL
AO C 315A 05
David J. Lanza
I.D. No. 55782 Attorney for Plaintiff
2157 Market Street
Camp Hill, Pennsylvania 17011
(717) 730-3775
SUSQUEHANNA VIEW LTD. PARTNERSHIP,
V.
CIVIL ACTION - LAW
KATHERINE SHEPSKI,
To the Defendant:
Plaintiff
Defendant
NO. 1333 Civil 2006
IN EJECTMENT
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 defense 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
David J. Lanza
I.D. No. 55782
2157 Market St.
Camp Hill, Pennsylvania 17011
(717) 730-3775
SUSQUEHANNA VIEW LTD. PARTNERSHIP,
Plaintiff
V.
KATHERINE SHEPSKI,
Defendant
COMPLAINT
NO. 1333 Civil 2006
CIVIL ACTION - LAW
Plaintiff is the owner of the real property situate at Unit 818, 208 Senate Avenue, Camp Hill, (East
Pennsboro) and maintains an address at 208 Senate Avenue, Camp Hill, PA 17011.
2. Defendant, Katherine Shepski, is an adult individual with an address at Unit 818, 208 Senate Avenue,
Camp Hill, (East Pennsboro) PA 17011
3. On or about September 15`h, 2004, Plaintiff and Defendant entered into a Lease Agreement for the real
estate situate at Unit 818, 208 Senate Avenue, Camp Hill, (East Pennsboro) PA 17011, a true and correct copy of which is
attached hereto as Exhibit "A".
4. The aforesaid Lease Agreement, at §11, requires Defendant to keep the premises clean and free from
debris and garbage.
5. Defendant is in breach of her obligations under the aforesaid Agreement in that she has failed to remove
debris and garbage from the premises.
6. Debris and garbage have accumulated in the aforesaid premises to such an extent that the premises are
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
unsanitary and constitute a hazard to neighboring properties.
7. Plaintiff has provided notice to Defendant to remove the debris and garbage from her residence, but
Defendant has failed to cure her lease breach.
8. Plaintiff has been forced to take additional steps to protect neighboring tenants, including arrangements
for additional extermination services.
9. Plaintiff is entitled to immediate possession of the premises at Unit 818.
10. Plaintiff has been forced to incur filing fees at the District Justice in the amount of $97.50 for the purpose
of enforcing the Lease and obtaining judgment against Defendant.
11. Pursuant to §8 of the aforesaid Lease, Plaintiff is entitled to recover attorney fees resulting from
Defendant's breach.
12. Plaintiff is expected to incur attorney fees in at least the amount of $2,000.00 to enforce the Lease
obligations.
13. Plaintiff has begun paying rent directly to the Prothonotary during the pendency of this case, to which
rent Plaintiff is entitled in the amount of $ 185.00 per month.
14. Plaintiff is expected to incur clean-up and repair costs for damage that may not be determined until after
Defendant vacates the premises.
15. Plaintiffs are entitled to judgmentin the amount of $ 2,282.50, set forth as follows:
Unpaid rent 185.00
Attorney fees 2,000.00
District Justice filing fees 97.50
Total 2,282.50
16. Defendant has refused to pay the aforesaid amounts and has refused to vacate the premises.
Wherefore, Plaintiffs demand judgment against Defendant in the amount of $2,282.50, plus costs, interest,
additional rent and additional clean-up costs as may be calculated at the time of trial.
By: Y.. i .
David J. Lanza
Attorney I.D. No. 55782
2157 Market Street
Camp Hill, PA 17011
Telephone (717) 730-3775
Attorney for Plaintiff
VERIFICATION
1, Lorraine Henkel, Manager, verify that the statements made in the foregoing Answers are true and correct to the
best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities.
Date: I /I 7106 Lorraine Henkel
CERTIFICATE OF SERVICE
AND NOW, this 19`" day of April 2006, the undersigned does hereby certify that he did this date serve
a copy of the foregoing Complaint upon the other parties of record by causing same to be deposited in the
United States Mail, first class postage prepaid, at Camp Hill, Pennsylvania, addressed as follows:
Stephen Hogg, Esquire
19 S. Hanover Street
Suite 101
Carlisle, PA 17013
By:
David J. Lanza
LEASE AGREEMENT
FOR SUBSIDIZED PROGRAMS
1. PARTIES AND DWELLING UNIT: The parties to this Agreement are NHPDIN Management, LLC, AGENT
FOR SUSQUEHANNA VIEW LTD. PARTNERSHIP , referred to as the Landlord, and
Katherine Shepski , referred to as the Tenant. The Landlord leases to the Tenant unit number 818 located at
208 Senate Ave, Camp Hill, PA. 17011 in the project known as Susquehanna View Apartments.
2. LENGTH OF TINIE (TERNI): The initial term of this Agreement shall begin on 11/01/04 and end on
11/30/04. After the initial term ends, the Agreement will continue for successive terms of one MONTH each
unless automatically terminated as permitted by Paragraph 24 of this Agreement.
3. RENT: The Tenant agrees to pay $N/A for the month ending on N/A . After that, Tenant agrees to pay a rent of
S Current Amount per month. This amount is due on the FIRST day of the month at THE, RENTAL OFFICE.
The Tenant understands that this monthly rent is less than the market (unsubsidized) rent due on this unit. This
lower rent is available either because the mortgage on this project is subsidized by the Department of Housing and
Urban Development (HUD) and/or because HUD makes monthly payments to the Landlord on behalf of the Tenant.
'I !)Q aiuuuul, i1 any, diaL I IUD wa6ca aeailaLlc muulhly uu Ldwlf uC the Tena,a i, called tl,u -1lii,;n[
Payment line of the Certification and Recertification of Tenant Eligibility Form, which is Attachment No.I to this
Agrcuuwa.
4. CHANGES IN THE TENAN'T'S SHARE OF THE RENT: The Tenant agrees that the amount of rent the
Tenant pays and/or the amount of assistance that IIUD pays on behalf of the Tenant may be changed during the
term of this Agreement if:
it. IIUD or the Contract Administrator (such a, it PLANIC Ilowing Agony) dctcrmincs, in accordancc rr ith
I IUD procedures, that an increase in rents is needed;
b. HUD or (lie Contract Administrator changes any allowanec for utilities or services considered in
computing the Tenant's share of the rent;
C. the income, the number of persons in the Tcnalnl's household or other Iactors considered in calculating the
Tenant's rent change and HUD procedures provide [fiat the Tenant's rent or assistance payment be adjusted
to reflect the change;
d. changes in the Tenant's rent or assistance payment are required by HUD's recertification or subsidy
termination procedures;
c. I IUD's procedures for computing the Tenant's assistance payment or rent change; or
f. the Tenant fails to provide information on his/her income, family composition or other factors as required
by the Landlord.
The Landlord agrees to implement changes in the Tenant's rent or tenant assistance payment only in accordance
with the time frames and administrative procedures set forth in HUD's handbooks, instructions and regulations
related to administration of multifamily subsidy programs. The Landlord agrees to give the Tenant at least 30 days
advance written notice of any increase in the Tenant's rent except as noted in Paragraphs 12, 16, or I8. The Notice
will state the new amount the Tenant is required to pay, the date the new amount is effective, and the reasons for the
change in rent. The Notice will also advise the Tenant that he/she may meet with the Landlord to discuss the rent
change.
5. CHARGES FOR LATE PAYMENTS AND RETURNED CHECKS: If the Tenant does not pay the full
amount of the rent shown in Paragraph 3 by the end of the 5th day of the month, the Landlord will charge a fee of
$5.00 on the 6th day of the month. Thereafter, the Landlord will charge a fee of $1..00 for each additional day the
rent remains unpaid during the month it is due. The Landlord may not terminate this Agreement for failure to pay
RG V IS ION 06/2004
Glderly Section 9
Tate charges, but nwy terminate this Agreement for nun-paynwnt of rent, as explained in Paragraph 24. The
Landlord may collect a fee of $10.00 which is an amount equal to the bank charge for returned checks the first
time or any additional time a check is not honored for payment (bounces). Also, late fees will accrue until the check
is rcplaccd in Cult, either by cectitiad ehcck or money order. Parsonal chsc" will no longer bo accaptcd uilcc a
resident's check is returned for non-sufficient funds. The charges discussed in this paragraph are in addition to the
regular monthly rent payable by the Tenant. Late fees will be assessed accordingly in cases of returned checks.
6. CONDITION OF DWELLING UNIT: By signing this Agreement, the Tenant acknowledges that the unit is safe,
clean and in good condition. The Tenant agrees that all appliances and equipment in the unit are in good working
order, except as described on the Unit inspection Reoort, which is Attachment No. 2 to this Agreement.
The Tenant also agrees that the Landlord has made no promises to decorate, alter, repair or improve the unit, except
as listed on the Unit Insnection Report.
7. CHARGES FOR UTILITIES AND SERVICES: The following charts describe how the cost of utilities and
services related to occupancy of the unit will be paid. The Tenant agrees that these charts accurately describe the
utilities and services paid by the Landlord and those paid by the Tenant.
a. The Tenant must pay for the utilities in column (1). Payments should be made directly to the appropriate
utility company. The items in column (2) are included in the Tenant's rent.
(1) (2)
Put "X" Put "X"
By Any By Anv
Type of Utility Utility
Tenant Included
Pays In Tenant
Directly Rent
_ Beat X
ghiS & X
Electric X
Cooking X
_ writer X
Other (Specify)
b. The'fcnant agrees to pay the Landlord the amount shown in column (3) on the dale the rent is due. "fhc Landlord
certifies that HUD has authorized him/her to collect the type of charges shown in column (3) and that the amounts
shown in column (3) do not exceed the amounts authorized by HUD.
(3)
Show S Amount
Tenant Pays to
Landlord in
Addition to
Rent
Parking $ N/A
Other (Specify)
$ N/A
$ N/A
8. COURT FILING, ATTORNEY, AND SHERIFF FEES: Payments of these fees will be accepted from tenants
who wish to avoid or settle an eviction suit. These fees cannot exceed the actual costs incurred by the Landlord.
9. SECURITY DEPOSITS: The Tenant has deposited $103.00 with the Landlord. The Landlord will hold this
Security Deposit, in the financial institution known as Wachovia Bank for the period the Tenant occupies the unit.
After the Tenant has moved from the unit, the Landlord will determine whether the Tenant is eligible fora refund of
any or all of the Security Deposit. The amount of the refund will be determined in accordance with the following
conditions and procedures.
1213 V IS ION 06/2003
Glderly Section 8
The Tenant will be eligible for a refund of the Security Deposit only if the Tenant provided the Landlord
with the 30-day written Notice of Intent to Move required by Paragraph 24, unless the Tenant was unable
to give the notice for reasons beyond his,M.cr control;
1. Death of Tenant. (Death Certificate required)
2. In the event the Tenant is transferred to such a distance that maintaining a residence in the leased
unit would constitute a serious hardship by reason of military orders or action of his/her
employer as substantiated by written proof.
3. The Tenant is unable to maintain his/her residency due to a disability, which necessitates being
placed in a care-providing facility, such as nursing home, or other similar facility. (Written
verification will be required)
b. After the Tenant has moved from the unit, the Landlord will inspect the unit and complete another Unit
Inspection Report. The Landlord will permit, and encourages, the Tenant to participate in the inspection,
if the Tenant so requests.
The Landlord will refund to the Tenant the amount of the Security Deposit, less any amount needed to pay
the cost of.
(1) unpaid rent;
(2) damages that are not due to normal wear and tear and are not fisted on the Unit Inspection
Report completed at move-in;
(3) charges for late payment of rent, legal fees and returned checks, as described in Paragraph 5 and
Paragraph 8; and
(4) charges for unretumed keys, as described in Paragraph 10.
'[he Landlord agrees to refund the security deposit, less any costs as defined hereinabove, within 30
days alter file Tenant has permanently moVed out of file unit, returned possession of the unit to the
f atidlord, and given InAler new address t01110 Landlord. The L ndlurd will also give the'renant a written
list of chniges that were subtracted from the deposit. If the Tenant disagrees with the Landlord concerning
the .unuunts deducted and asks to meet with file Landlord, file Landlord agrees to meet with the Tenant
and inlbmrally discuss the disputed charges.
d. Interest on Tenant's security deposit will be computed utilising file passbook rate of the banking
institution defined hereinabove. Interest will accrue beginning on the 25" month of the lease but will not
be payable until the 36°i month of the lease and each annual anniversary of the lease thereafter. Annual
security deposit interest payments are subject to a one (1%) percent administrative fee.
C. If the unit is rented by more than one person, the Tenants agree that they will work out the details or
dividing any refund among themselves. The Landlord will pay the refund, jointly, to any Tenants
identified in Paragraph I of this Agreement.
The Tenant understands that all outstanding rent and damages are due prior to move-out. The Landlord
will not count the Security Deposit towards the last month's rent or towards repair charges owed by the
Tenant in accordance with Paragraph 12. In the case of a unit transfer within the project, the security
deposit will be refunded, less any charges, and a new deposit will be collected, based on the new rental
amount and/or housing programs, if applicable.
10. KEYS AND LOCKS: The Tenant agrees not to install additional or different locks or gates on any doors or
windows of the unit without the written permission of the Landlord. If the Landlord approves the Tenant's request
to install such locks, the Tenant agrees to provide the Landlord with a key for each lock. When this Agreement
ends, the Tenant agrees to return all keys to the dwelling unit to the Landlord. The Landlord may charge the Tenant
$ 5.00 for each key the Landlord provided which is not returned.
R P. V IS ION 06/2004
Glderly Section 8
it. MAINTENANCE:
The Landlord agrees to:
(1) regularly clean all common areas of the project;
(2) maintain the common areas and facilities in a safe condition;
(3) arrange for collection and removal of trash and garbage;
(4) maintain all equipment and appliances in safe and working order;
(5) make necessary repairs with reasonable promptness;
(6) maintain exterior lighting in good working order;
(7) provide extermination services, as necessary; and
(S) maintain grounds and shrubs.
The Tenant agrees to:
(1) keep the unit clean;
(2) use all appliances, fixtures and equipment in a safe manner and only for the purposes for which
they are intended;
(3) not litter the grounds or common areas of project;
(4) not destroy, deface, damage or remove any port of tlro unit, common areas, or project grounds;
(5) give the Landlord prompt notice of any defects in the plumbing, fixtures, appliances, heating and
cooling equipment or any other part Of the unit or related I:icilitics; and
(6) remove garbage and other waste from the unit in clean and safe manner and dispose of in
designated containers and/or areas. Tenant agrees to handle all trash and recyclable materials in
accordance with Landlord's regulations and State Law.
12. DAMAGES: Whenever damage is caused by carelessness, misuse, or neglect on the part of the Tcnant, 111.5 her
family or visitors, the Tenant agrees to pay:
a. the cost of all repairs and do so within 30 days after receipt of the Landlord's demand for the repair
charges; and
b. rent for the period the unit is damaged whether or not the unit is habitable. The Tenant understands that
IIUD wilt not make assistance payments for any period in which the unit is not habitable. For any such
period, the Tenant agrees to pay the HUD-approved market rent rather than the Tenant rent shown in
Paragraph 3 of this Agreement.
13. RESTRICTIONS ON ALTERATIONS: No alteration, addition, or improvements shall be made in or to the
premises without the prior consent of the Landlord in writing. The Landlord agrees to provide reasonable
accommodation to an otherwise eligible tenant's disability, including making changes to rules, policies, or
procedures, and making and paying for structural alterations to a unit or common areas. The Landlord is
not required to provide accommodations that constitute a fundamental alteration to the Landlord's program
or which would pose a substantial financial and administrative hardship. See the regulations at 24 CFR Part
8. In addition, if a requested structural modification does pose a substantial financial and administrative
REVISION 06/2004
I.ldcrly Section 9
hardship, the Landlord must then allow' the tenant to make and pay for the modification in accordance with
the Fair Housing Act.
14. GENERAL RESTRICTIONS: The Tenant must live in the unit and the unit must be the Tenant's only place of
residence. The Tenant shall use the premises only as a private dwelling for himself or herself and the individuals
listed on the Certification and Recertification of Tenant Elieibility. The Tenant agrees to permit other individuals to
reside in the unit only after obtaining the prior written approval of the Landlord. The Tenant agrees not to:
a. sublet or assign the unit, or any part of the unit;
b. use the unit for unlawful purposes;
C. engage in or permit unlawful activities in the unit, in the common areas or on the project grounds;
d. have pets or animals of any kind in the unit without the prior written permission of the Landlord, but the
Landlord will allow the tenant to keep an animal needed as a reasonable accommodation to the
tenant's disability, and will allow animals to accompany visitors with disabilities who need such
animals as an accommodation to their disabilities;
C. create or permit any disturbing noises in or about Tenant's dwelling unit by himself, his family, or guests;
nor shall he, his family, or his guests intertbre with or materially diminish the rights, comforts, or
convenience of other Tenants or surrounding neighbors. Neither the Tenant, his family, nor his guests
shall engage in any activity that would constitute an offense against persons, public order, or public health
or decency, or that imolvcs fraud, deception, firearms, or other weapons.
f. refuse the extermination services for rodent or insect infestation. Management will consider an exception
for verified medical reasons.
g, fitil to immediately notify the Landlord in the event that Tenant is unable to maintain sufficient heal (for
which the Tcmou pays) to the premises. Tenant shall pay for any damages to the unit resulting front the
Tenant's negligent or intentional failure to maintain sufficient heat or to notify the Landlord of the hick of
sufficient heat.
15. RULES: 'Tire Tenant agrees to obey the House Rules, which are Attachment No. 3 to this Agreement. The Tenant
agrees to obey additional rules established after the eflcctive date of this Agreement if
the rules are reasonably related to the safcty, care and cleanliness of the building and the safety, comfort
and com'eniencc of the Tenants; and
b. the fcnanl receives written notice of the proposed rule at least 30 days before the rule is enforced.
16. REGULARLY SCHEDULED RECERTIFICATIONS: Once each year around the first day of December,
the Landlord will request the Tenant to report the income and composition of the Tenant's household and to supply
any other information required by HUD for the purposes of determining the Tenant's rent and assistance payment, if
any. The Tenant agrees to provide accurate statements of this information and to do so by the date specified in the
Landlord's request. The Landlord will verify the information supplied by the Tenant and use the verified
information to recompute the amount of the Tenant's rent and assistance payment, if any.
a. If the Tenant does not submit the required recertification information by the date specified in the
Landlord's request, the Landlord may impose the following penalties. The Landlord may implement these
penalties only in accordance with the administrative procedures and time frames specified in HUD's
regulations, handbooks and instructions related to the administration of multifamily subsidy programs.
Require the Tenant to pay the higher, HUD-approved market rent for the unit
REVISION 06/2004
Elderly Section 8
(2) Implement any increase in rent resulting from the recertification processing without providing the
30-day notice otherwise required by Paragraph 4 of this Agreement.
b. The Tenant may request to meet with the Landlord to discuss any change in rent or assistance payment
resulting from the recertification processing. If the Tenant requests such a meeting, the Landlord agrees to
meet with the Tenant and discuss how the Tenant's rent and assistance payment, if any, were computed.
17. REPORTING CHANGES BETWEEN REGULARLY SCHEDULED RECERTIFICATIONS:
a. If any of the following changes occur, the Tenant agrees to advise the Landlord immediately.
(1) Any household member moves out of the unit.
(2) Any adult member of the household who was reported as unemployed on the most recent
certification or recertification obtains employment.
(3) The household's income cumulatively increases by $200 or more a month.
The Tenant may report any decrease in income or any change in other factors considered in calculating the
Tenant's rent. Unless the Landlord has confirmation that the decrease in income or change in other factors
will last less than one month, the Landlord will verify the information and make the appropriate rent
reduction. However, if the Tenant's income will be partially or fully restored within two months, the
Landlord may delay the certification process until the new income is known, but the rent reduction will be
retroactive and the Landlord may not evict the Tenant for nonpayment of rent due during the period of the
reported decrease and the completion of the certification process.
The Tenant has thirty days after receiving written notice of any rent clue for the above described time
period to pay or the Landlord can evict for nonpayment of rent.
C. If the Tenant does not advise the Landlord of these interim changes., the Landlord may increase the
'tenant's rent to the I IUD-approved market rent. The Landlord may do so only in accordance with the time
Games and administrative procedures set forth in I IUD's regulations, handbooks and instructions on the
administration of multifamily subsidy programs.
d. the Tenant may request to meet with the Landlord to discuss how any change in income or other factors
affected his/her rent or assistance payment, if any. If the Tenant requests such a meeting, the Landlord
agrees to meet with the Tenant and explain how the Tenant's rent or assistance payment, if any, was
computed.
18. REMOVAL OF SUBSIDY )Section 8, RAP, Rent Supplement Only):
a. The Tenant understands that assistance made available on his/her behalf may be terminated if events in
either item 1 or 2 below occur. Termination of assistance means that the Landlord may make the
assistance available to another Tenant and the Tenant's rent will be recomputed. In addition, if the Tenant's
assistance is terminated because of criterion (1) below, the Tenant will be required to pay the HUD-
approved market rent for the unit.
(1) The Tenant does not provide the Landlord with the information or reports required by paragraph
16 or t7 within 10 calendar days after receipt of the Landlord's notice of intent to terminate the
Tenant's assistance payment.
(2) The amount the Tenant would be required to pay towards rent and utilities under HUD rules and
regulations equals the Family Gross Rent shown on Attachment 1.
b. The Landlord agrees to give the Tenant written notice of the proposed temmination. The notice will advise
the Tenant that, during the ten calendar days following the date of the notice, he/she may request to meet
with the Landlord to discuss the proposed termination of assistance. If the Tenant requests a discussion of
the proposed termination, the Landlord agrees to meet with the Tenant.
REVISION 06/2004
Elderly Section 8
The -Icnant may accept the changed terms and conditions by signing the new Agreement or the amendment to the
existing Agreement and returning it to the Landlord. The Tenant may reject the changed terms and conditions by
giving the Landlord written notice that he/she intends to terminate the tenancy. The Tenant must give such notice at
least 3U days before the proposed change will go into effect. If the Tenant does not accept the amended Agreement,
the Landlord may require the Tenant to move from the project, as provided in Paragraph 24.
24. TERMINATION OF TENANCY:
a. To terminate this Agreement, the Tenant must give the Landlord 30-days written notice before moving
from the unit. If the Tenant does not give the full 30-day notice, the Tenant shall be liable for rent up to
the end of the 30 days for which notice was required or to the date the unit is re-rented, whichever date
comes first.
b. Any termination of this Agreement by the Landlord must be carried out in accordance with HUD regulations,
State and local law, and the terms of this Agreement.
C. The Landlord may terminate this Agreement for the following reasons:
(1) the Tenant's material noncompliance with the terms of this Agreement;
(2) the Tenant's material failure to carryout obligations under any State Landlord and Tenant Act;
(3) drug related criminal activity engaged in on or near the premises, by any tenant, household
member, or guest, and any such activity engaged in on the premises by any other person
under the tenant's control;
(4) determination made by the Landlord that a household member is illegally using a drug;
(5) determination made b), the Landlord that it pattern of illegal use of a drug interferes with
the health, safety, or right to peaceful enjoyment of the premises by other residents;
(6) criminal activity by a tenant, any member of the tenant's household, a guest or another
person under the tenant's control:
a. that threatens the health, safety, or right to peaceful enjoyment of the premises by
other residents (including property management staff residing on the premises); or
b. that threatens the health, safely, or right to peaceful enjoyment of their residences by
persons residing in the immediate vicinity of the premises;
(7) if the tenant is fleeing to avoid prosecution, or custody or confinement after conviction, for
a crime, or attempt to commit a crime, that is a felony under the laws of the place front
which the individual flees, or that in the case of the state of New Jersey, is a high
misdemeanor;
(3) if the tenant is violating a condition of probation or parole under Federal or State law;
(9) determination made by the Landlord that a household member's abuse or pattern of abuse
of alcohol threatens the health, safety, or right to peaceful enjoyment of the premises by
other residents;
(10) If the Landlord determines that the tenant, any member of the tenant's household, a guest
or another person under the tenant's control has engaged in the criminal activity,
regardless of whether the tenant, any member of the tenant's household, a guest or another
person under the tenant's control has been arrested or convicted for such activity.
REVISION 06/2004
Elderly Section 8
BURGLARY: Should your apartment be burglarized and all your possessions stolen- the Landlord, Managing
Agent and Owners have no responsibility.
WATER DAMAGE: If a water line broke in your building, ruining your apartment and possessions- the property's
insurance would cover the damages to the building but not your possessions.
FIRE: In the instance of a fire- the Landlord, Managing Agent and Owners maintain insurance coverage for the
building, but not your personal possessions.
With this information in mind, the Landlord strongly recommends that the Tenant purchase a Renter's Insurance
Policy to provide personal coverage for your possessions and property.
28. TENANT'S RIGHTS TO ORGANIZE: Landlord agrees to allow tenant and tenant organizers to conduct on
the property the activities related to the establishment or operation of a tenant organization set out in
compliance with HUD requirements.
29. TENANT INCO:NIE VERIFICATION: The Tenant must promptly provide the Landlord with any letter or
other notice by HUD to a member of the family that provides information concerning the amount or
verification of family income in accordance with HUD requirements.
30. The Lease Agreement will terminate automatically, if the Section 8 Housing Assistance contract terminates
for any reason.
31. DRUG-FREE HOUSING PROVISION: -the Landlord, Managing Agent and Owners of this apartment
community are committed to Drug-Free Housing. All Tenants arc required to abide by the following provisions.
Violations of these provisions will be considered as cause for termination of tenancy:
I. -tenant, any member of tenant's household, or a guest or other person under the Tenant's control shall not
engage in criminal activity, including drug-related criminal activity, on or near project premises.
"Drug-related criminal activity" means the illegal manufacture, sale, distribution, use or possession with
intent to manufacture, sell, distribute, or use, of a controlled substance (as defined in Section 102 of the
Controlled Substance Act (21 U.S.C. 802)).
2. Tenant, any member of the Tenant's household, or a guest or other per50n under the'fcnant's control shall
not engage in any act intended to facilitate criminal activity, including drug-related criminal activity, on or
near project premises.
3. Tenant or members of the household will not permit the dwelling unit to be used for, or to facilitate
criminal activity, including drug-related criminal activity, regardless of whether the individual engaging in
such activity is a member of the household or a guest.
4. Tenant or member of the household will not engage in the mmnufacturc., sale, or distribution of illegal
drugs in any location, whether on or near project premises or otherwise.
5. Tenant, any member of the Tenant's household, or a guest or other person under the Tenant's control shall
not engage in acts of violence or threats of violence including, but not limited to, the unlawful discharge
of firearms, on or near project premises.
6. VIOLATION OF THE ABOVE PROVISIONS SHALL BE A MATERIAL VIOLATION OF THE
LEASE AGREEMENT AND GOOD CAUSE FOR TERIMINATION OF TENANCY. A single
violation of any of these provisions shall be deemed a serious violation and a material noncompliance with
the Lease Agreement. It is understood and agreed that a single violation shall be good cause for
termination of the Lease Agreement. Unless otherwise provided by law, proof of the violation shall not
require criminal conviction, but shall be by a preponderance of the evidence.
32. CONTENTS OF THIS AGREEMENT: This Agreement and its Attachments make up the entire agreement
between the Tenant and the Landlord regarding the unit. If any Court declares a particular provision of this
Agreement to be invalid or illegal, all other terms of this Agreement will remain in effect and both the Landlord and
the Tenant will continue to be bound by them.
REVISION 06/2004
Elderly Section e
10
35. SIGNATURES:
TENANT ??-- _
BY:? m _ I
1. Date
2.
3.
Date
Date
LANDLORD: SUSOUEIIANNA VIEW LTD. PARTNERStilP
N_HPMN(Managgeement, LLC. AGENT
BY:?--?
Lorraine ffeukel j
Date
COMMUNITY MANAGER 11
(I'itIC/1'usition)
REVISION 06/2004
Elderly Section 8
12
'
,?, ?
A
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
SUSQUEHANNA VIEW LTD. : CIVIL ACTION LAW
PARTNERSHIP,
Plaintiff NO.: 1333-06
V.
KATHERINE SHEPSKI, : JURY TRIAL DEMANDED
Defendant
DEFENDANT'S ANSWER
1. Defendant has no knowledge of the truth of this allegation and
proof thereof is demanded at trial.
2. Admitted.
3. Admitted.
4. It is admitted that under the lease agreement at §11 the
tenant(Defendant) agreed to keep the unit clean and remove
garbage from the unit. In all other respects this allegation is
denied.
5. It is denied that Defendant is in breach of her obligations under
the aforesaid lease agreement.
It is denied that debris and garbage have accumulated in the
aforesaid premises such that the premises are unsanitary and
constitute a hazard.
LAW OFF M OF
STEPHEN J. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
7. It is admitted that Plaintiff has given written notice to Defendant to
clean her residence. It is specifically denied that any
accumulation of debris or garbage is a lease breach.
8. Defendant has no knowledge as to the truth of this allegation and
proof thereof is demanded at trial. Defendant denies that any
additional extermination services to neighboring tenants have
been required because of any action or omission on her part.
9. It is denied that Plaintiff is entitled to immediate possession of the
premises. It is specifically denied that Defendant has breached
the lease in any way that would entitle Plaintiff to immediate
possession.
10. Defendant has no knowledge of the truth of this allegation and
proof thereof is demanded at trial.
11. It is specifically denied that Defendant has breached the lease in
any manner sufficient to entitle Plaintiff to recover attorney fees.
12. See answer to Paragraph 11.
13. Admitted.
14. It is specifically denied that the Defendant has caused the need
for any clean-up or repairs costs which Plaintiff is entitled to
recoup from Defendant.
15. It is admitted that Plaintiff is entitled to rent of $185.00 per month.
It is denied that Plaintiff is entitled to any filing fees or attorney
fees for pursuing this action against Defendant.
16.Admitted.
Wherefore, Defendant requests judgment in her favor and
against Plaintiff. 11
Stephen J. Ho quire
Attorney for D f dant
19 S. Hanover Street, Ste. 101
Carlisle, PA 17013
(717) 245-2698
Date: 0
LAW OFFICES OF
STEPHEN J. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
VERIFICATION
LAW OFFICES OF
STEPHEN J. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
I verify that the statements made in this Answer to the Court of
Common Pleas of Cumberland County, Pennsylvania, are true and
correct. I understand that false statements herein are made subject to
the penalties of 18 Pa. Section 4904, relating to unsworn falsifications
to authorities.
Date:
THERINE SHEPS b
0
cn "" .n a,
o
s ?
JORDAN D. CUNNINGHAM, ESQUIRE
CUNNINGHAM & CHERNICOFF, P.C.
2320 NORTH SECOND STREET
HARRisBURG, PA 17110
TELEPHONE: (717) 238-6570
FACSIMILE (717) 238-4809
EMAIL: JCUNNINGHAM ,CCLAWPC.COM
SUSQUEHANNA VIEW LTD.
PARTNERSHIP,
Plaintiff
V.
KATHERINE SHEPSKI,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1333 CIVIL 2006
CIVIL ACTION - LAW
IN EJECTMENT
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Enter my appearance on behalf of Plaintiff, Susquehanna View LTD. Partnership, in the
above captioned matter.
Respectfully submitted,
COFF, P.C.
Dated: .3 I 07 By:
,.*Tord Cunningham, Esquire
PA .D. No. 23144
2320 North Second Street
Harrisburg, PA 17110
Telephone: (717) 238-6570
F:\Home\AHEWITT\DOCS\Q-S\SUSQUEHANNA VIEW APARTMENTS\SHEPSKI\ENTRY OF APPEARANCE.wpd
! - '1
CERTIFICATE OF SERVICE
I do hereby state that on the QO'day of March, 2007, I served a true and correct copy of
the foregoing in the above captioned matter, by placing the same in the United States mail, first-
class, postage prepaid, in Harrisburg, Pennsylvania, addressed to:
Stephen Hogg, Esquire
19 South Hanover Street
Suite 101
Carlisle, PA 17013
Angel L. H Witt, Legal Assistant
t
CP
c?
a %
JORDAN D. CUNNINGHAM, ESQUIRE
CUNNINGHAM& CHERNICOFF, P.C.
2320 NORTH SECOND STREET
HARRISBURG, PA 171 10
TELEPHONE: (717) 238-6570
FACSIMILE (717) 238-4809
EMAIL: JCUNNINGHAMaCCLAWPC.COM
SUSQUEHANNA VIEW LTD. IN THE COURT OF COMMON PLEAS
PARTNERSHIP, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
: NO. 1333 CIVIL 2006
V. .
CIVIL ACTION - LAW
KATHERINE SHEPSKI,
Defendant IN EJECTMENT
PRAECIPE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Strike off the Appeal filed in this matter as a result of Defendant, Katherine Shepski's,
failure to complete the Proof of Service in compliance with Pa. R.C.P. 1005(B). Also strike off
the Supersedeas as the result of the underlying appeal having been stricken.
Respectfully submitted,
, P.C.
Dated: 3 1,?107-
/-7
an D unningham, Esquire
PA I.D. No. 23144
2320 North 2nd Street
Harrisburg, PA 17110
Telephone: (717) 238-6570
Attorneys for Plaintiffs
F:\Home\AHEWITT\DOCS\Q-S\SUSQUEHANNA VIEW APARTMENTS\SHEPSKI\PRAECIPE TO STRIKE TERMINATE.wpd
N
CERTIFICATE OF SERVICE
I do hereby state that on the day of March, 2007, I served a true and correct copy of
the foregoing in the above captioned matter, by placing the same in the United States mail, first-
class, postage prepaid, in Harrisburg, Pennsylvania, addressed to:
Stephen Hogg, Esquire
19 South Hanover Street
Suite 101
Carlisle, PA 17013
tkf??
eArVela'L. Hewitt, Legal Assistant
March 9, 2007, Appeal Stricken according the above Praecipe.
(itiz.
Curtis R. Lon onotary
c?
co
JORDAN D. CUNNINGHAM, ESQUIRE
I.D. #23144
CUNNINGHAM & CHERNICOFF, P.C.
2320 North Second Street
P. O. Box 60457
Harrisburg, PA 17106-0457
(717) 238-6570
SUSQUEHANNA VIEW LTD.
PARTNERSHIP,
Plaintiff
V.
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 1333 CIVIL 2006
KATHERINE SHEPSKI,
Defendant CIVIL ACTION - LAW
MOTION TO RELEASE RENT ESCROW
1. The Plaintiff, Susquehanna View Ltd. Partnership, is a Pennsylvania limited
partnership which is registered with the Department of State and has a principal office located at
208 Senate Avenue, Camp Hill, Cumberland County, Pennsylvania.
2. The Defendant, Katherine Shepski, is an adult individual who resides at Unit 818,
208 Senate Avenue, Camp Hill, Cumberland County, Pennsylvania.
3. On March 9, 2006, Defendant filed a Notice of Appeal and a supersedeas was
issued.
4. Defendant has paid her rent since March 9, 2006 to the Prothonotary of
Cumberland County.
1
5. Defendant, in her pleadings, has not raised an issue regarding Plaintiff's failure to
meet its obligation to provide a safe, clean and habitable premises to the Defendant.
6. On or about April 30, 2007, pursuant to an Order for Possession, the Defendant
removed herself and her possessions from the apartment she occupied and Plaintiff accepted
possession of the apartment unit.
WHEREFORE, Plaintiff, in accordance with Pa. R.C.P.D.J. No. 1008B, respectfully
requests that this Honorable Court direct the Prothonotary to distribute to the Plaintiff all the rent
deposits made by Defendant with the Prothonotary's Rent Escrow Account.
CUNNINGHAM & CHERNICOFF, P.C.
Esquire
2320 North Second Street
P.O. Box 60457
Harrisburg, PA 17106-0457
Telephone: (717) 238-6570
Attorneys for Plaintiff
F:\Home\AHEWITT\DOCS\Q-S\SUSQUEHANNA VIEW APARTMENTS\SHEPSKI\MOTRENTR.wpd/file no. 403905
Respectfully submitted,
CERTIFICATE OF SERVICE
I do hereby state that on the C 9-N of June, 2007, I served a true and correct copy of
the foregoing in the above captioned matter, by placing the same in the United States mail, first-
class, postage prepaid, in Harrisburg, Pennsylvania, addressed to:
Stephen Hogg, Esquire
19 South Hanover Street
Suite 101
Carlisle, PA 17013
gela L. Hewitt, gal Assistant
C?
is q
I
rtY N
l.
N ?
?
JORDAN D. CUNNINGHAM, ESQUIRE
I.D. #23144
CUNNINGHAM & CHERNICOFF, P.C.
2320 North Second Street
P. O. Box 60457
Harrisburg, PA 17106-0457
(717) 238-6570
SUSQUEHANNA VIEW LTD.
PARTNERSHIP,
Plaintiff .
V.
KATHERINE SHEPSKI,
Defendant .
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 1333 CIVIL 2006
CIVIL ACTION - LAW
AMENDED
MOTION TO RELEASE RENT ESCROW
1. The Plaintiff, Susquehanna View Ltd. Partnership, is a Pennsylvania limited
partnership which is registered with the Department of State and has a principal office located at
208 Senate Avenue, Camp Hill, Cumberland County, Pennsylvania.
2. The Defendant, Katherine Shepski, is an adult individual who resides at Unit 818,
208 Senate Avenue, Camp Hill, Cumberland County, Pennsylvania.
3. On March 9, 2006, Defendant filed a Notice of Appeal and a supersedeas was
issued.
1
4. Defendant has paid her rent since March 9, 2006 to the Prothonotary of
Cumberland County.
5. Defendant, in her pleadings, has not raised an issue regarding Plaintiff s failure to
meet its obligation to provide a safe, clean and habitable premises to the Defendant.
6. On or about April 30, 2007, pursuant to an Order for Possession, the Defendant
removed herself and her possessions from the apartment she occupied and Plaintiff accepted
possession of the apartment unit.
7. This Honorable Court has not ruled upon the issue contained in this Motion in this
matter or any other related matter.
8. Defendant's counsel, Stephen Hogg, Esquire, concurs in this Motion.
WHEREFORE, Plaintiff, in accordance with Pa. R.C.P.D.J. No. 1008B, respectfully
requests that this Honorable Court direct the Prothonotary to distribute to the Plaintiff all the rent
deposits made by Defendant with the Prothonotary's Rent Escrow Account.
Respectful ll,sffimitted
CHERNICOFF, P.C.
Dated: July 1, 2007 By: J1.Z &I
rd . Cunningham, Esquire
I.D. No. 23144
2320 North Second Street
P.O. Box 60457
Harrisburg, PA 17106-0457
Telephone: (717) 238-6570
Attorneys for Plaintiff
F:\Home\AHEWITT\DOCS\Q-S\SUSQUEHANNA VIEW APARTMENTS\SHEPSKI\AMENDED MOTION RETURN RENT
ESCROW.wpd/file no. 403905
2
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--?AG?
CERTIFICATE OF SERVICE
I do hereby state that on the ?day of July, 2007, I served a true and correct copy of the
foregoing in the above captioned matter, by placing the same in the United States mail, first-
class, postage prepaid, in Harrisburg, Pennsylvania, addressed to:
Stephen Hogg, Esquire
19 South Hanover Street
Suite 101
Carlisle, PA 17013
Ange a L. Hewitt, Legal Assistant
4rw? QTY
f
c !
?r
_ --, f b i
JORDAN D. CUNNINGHAM CUNNINGHAM & CHERNICOFF, P.C.
ROBERT E. CHERNICOFF
MARC W. W TZIG ATTORNEYS AT LAW
BRUCE J. WARSHAWSKY P.O. BOX 60457
KELLY M. KNIGHT HARRISBURG, PENNSYLVANIA 17106-0457
TRACY L. UPDIKE
TELEPHONE (717) 238-6570
FAX (717) 238-4809
July 5, 2007
Office of the Prothonotary
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
Re: Susquehanna View LTD. Partnership v. Katherine Shepski
Cumberland County Court of Common Pleas
Docket No. 1333-CV-2006
Our File No. 404607
Dear Sir or Madam:
HERSHEY TELEPHONE
(717) 534-2833
IRS NO. 23-2274135
Street Address:
2320 N. 2nd Street
Harrisburg, PA 17110
Pursuant to the directive of Melissa H. Calvanelli, Assistant Court Administrator,
enclosed for filing is the original and three (3) copies of the Amended Motion to Release Rent
Escrow. Please return a time stamped copy of the Amended Motion to my attention in the
enclosed pre-addressed postage paid envelope. Thank you for your attention to this matter.
If you have any questions, please do not hesitate to contact me.
JDC/alh
enclosures
OFF, P.C.
cc: Melissa H. Calvanelli, Assistant Court Administrator
Susquehanna View
Stephen Hogg, Esquire
F:\Home\AHEWITT\DOCS\Q-S\SUSQUEHANNA VIEW APARTMENTS\SHEPSKI\L070507 prothonotary. wpd
JUN 2 6 2007, Y
SUSQUEHANNA VIEW LTD.
PARTNERSHIP, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY,
PENNSYLVANIA
V. NO. 1333 CIVIL 2006
KATHERINE SHEPSKI,
Defendant CIVIL ACTION - LAW
ORDER
AND NOW, this day of taly , 200 , upon review of the
annexed Application and upon motion of Jordan D. Cunningham, Esquire, it is hereby
ORDERED that the Prothonotary of Cumberland County, Pennsylvania, pursuant to
Pa.R.C.P.D.J. No. 1008, distribute to the Plaintiff any and all amounts being held in the
Prothonotary's rent escrow account in the above docketed case.
I B HE COURT:
3
J.
c: i'syt??'? t : { -1,4
[I 'ritf'XrV
: 1 -' 0 ! `":f P l00Z
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JUN 2 6 2007?Y
SUSQUEHANNA VIEW LTD.
PARTNERSHIP,
Plaintiff
V.
KATHERINE SHEPSKI,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 1333 CIVIL 2006
CIVIL ACTION - LAW
ORDER
AND NOW, this day of V , 204,upon review of the
annexed Application and upon motion of Jordan D. Cunningham, Esquire, it is hereby
ORDERED that the Prothonotary of Cumberland County, Pennsylvania, pursuant to
Pa.R.C.P.D.J. No. 1008, distribute to the Plaintiff any and all amounts being held in the
Prothonotary's rent escrow account in the above docketed case.
B WCOURT:
J.
'1*11NXR woul *9 +V biwc
AIN #110 ofaw cow at t Pr.
1.7
PAY TOTHE
ORWR OF Kristen Leach. Site Manacfw, Susquehanna View ApartMts $ " 837.50
Ct1MOULAN11 CO. Q r? s
PIlO,Tlli"*TARYQ3 l do s5ofits"
DOLLARS 8
AM. -K
06-1333 "Release Rent" Susquehanna vs Shgmki
11'00 i?30n'..+:03 i3 150361: 108
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14242709112007 Cumberland County Prothonotary 's Office Page 1
PYS405 Manual Release Check Regi ster 9/11/2007
Escrow Tran Date
Distribution Case No Accounting Amount Date Release
---------------------------------------------------
3767 SUSQUEHANNA VIEW LIMITED Check Date: -----------
09/11/2007 ------------------
Check No.: 1730
RENT 2006- 01333 PYMT/CHECK 97.50 3/09/2006
RENT 2006- 01333 PYMT/CASH 370.00 5/04/2006
RENT 2006- 01333 PYMT/CHECK 185.00 6/08/2006
RENT 2006- 01333 PYMT/CHECK 185.00 7/06/2006
- Payee total:
--------------------------------
-
- 837.50
-----------
------------------
------------- -
-
-
Grand total: 837.50