HomeMy WebLinkAbout02-1401WEST SHORE EVANGELICAL
FREE CHURCH,
Plaintiff
DON WRIGHT AND JEAN WRIGHT,
husband and wife,
354 Stumpstown Road
Mechanicsburg, PA 17055
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN EJECTMENT
To the Prothonotary:
Please issue a Writ of Summons against the Defendants in the above-captioned
action. Kindly return the Writ to our office for service upon the Defendants' attorney,
who has agreed to accept service.
Respectfully Submitted,
WIX, WENGER & WEIDNER
David R. Getz, I.D.# 34838 ~
508 North Second Street
Post Office Box 845
Harrisburg, PA 17108-0845
(717) 234-4182
Date:
f:~rg\9230 - West Shore Evangelical Free Chumh\10286 - Real Estate - Monroe Township Property~Documents\Praecipe for Writ
of Summons.doc
Commonwealth of Pennsylvania
County of Cumberland
WEST SHORE EVANGELICAL FREE C~URCH
Plaintiff
DON WRIGHT AND JEAN WRIGHT
Husband and Wife,
354 STUMPSTOWN ROAD
MECHANICSBURG, PA 17055
Defendants
Court of Conmuon Pleas
No. 2Q02-14Q1 Civil
In Civil Law
To Don and Jean Wright H/W
You are hereby notified that
.__W_e_s__t__S_h_9_r_e' Evan~e_lical Free Church
the Plaintiff h~s commenced an action in
against you which you are required to defend or a default judgment ma), be entered against you.
(SEAL)
Date March 22, 2002 19 ....
WEST SHORE EVANGELICAL
FREE CHURCH,
Plaintiff
DON WRIGHT AND JEAN WRIGHT,
husband and wife,
354 Stumpstown Road
Mechanicsburg, PA 17055
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002-1401
CIVIL ACTION - LAW
IN EJECTMENT
~TIPULATI~I~ JUf~(~MI=NT
It is hereby stipulated and agreed by and between the undersigned that the
following is true and that judgment should be entered against the Defendants as
follows:
1. Plaintiff, West Shore Evangelical Free Chumh, is the owner of real estate
located at 354 Stumpstown Road, Mechanicsburg, Pennsylvania 17055 (the
"Property). The Church acquired the Property by deed dated January 24, 2002 and
recorded in Cumberland County Recorder of Deeds Office in Deed Book , Page
2. Defendants are tenants on the property pursuant to an unrecorded lease
between tenants and the prior owner of the Property, Marie K. McAndrew
("McAndrew"). Tenants are in default of the lease.
3. As part of the acquisition of the Property, McAndrew assigned the lease
and assigned all her rights and obligations under the lease to Plaintiff.
4. Among the defaults are unpaid rent owed to McAndrew and properly
assigned to Plaintiff of $3,400.00.
5. Additionally, Defendants are in default to Plaintiff for rent for February and
March in the amount of $850.00 per month for a total of $1,700.00.
6. Defendants also agree that they will owe Plaintiff monthly rent of $850.00
for the month of April 2002. Thus, Defendants owe the Plaintiff the total amount of rent
of $5,950.00.
7. Defendants hereby stipulate to a judgment in favor of Plaintiff in the
amount of $5,950.00. Defendants further hereby instruct their attorney, Richard S.
Friedman, Esquire, of the law firm of Friedman & King, P.C., to pay said amount to the
Plaintiff from the proceeds of any recovery made by Attorney Friedman on behalf of
Defendants or either of them.
8. Defendants agree that if they do not vacate the Property as agreed
herein, rent shall continue at the rate of $850.00 per month and Defendants instruct
their attorney to pay such rent to Plaintiff in addition to the sum set forth in Paragraph 7
hereof.
9. Defendants shall vacate the Property before April 30, 2002. Defendants
stipulate and agree that Plaintiff is entitled to a writ of possession for the Property on or
after April 30, 2002 without filing any additional pleadings and agree that Plaintiff shall
be entitled to a writ of possession upon presentation of this Stipulation to the
Prothonotary and/or the Sheriff of Cumberland County.
10. Defendants waive any and all rights they may have to a hearing, trial,
appeal, or any other proceedings under this litigation.
11. The parties have consulted with their respective counsel prior to entering
into this Stipulation.
12. Plaintiff shall file this Stipulation with the Prothonotary.
13. Upon filing of this Stipulation, the Prothonotary is authorized and directed
by the parties to enter judgment in favor of Plaintiff and against Defendants for
possession of the Property and the amount of $5,950.00, plus costs and interest.
IN WITNESS WHEREOF, AND INTENDING TO BE LEGALLY BOUND
HEREBY, the parties hereto have executed this Stipulated Judgment as of the 25th day
of March, 2002,
ATTEST:
(~a~e,) Secretary
(SEAL)
WEST SHORE EVANGELICAL
FREE CHURCH
BY~Pre~~
Wright
F:~drg\9230 - West Shore Evangelical Free Church\10286 - Reel Estate - Monroe Township Propert~uments~Stipulation.doc
c,j iD ~
ct) (-)
WEST SHORE EVANGELICAL
FREE CHURCH,
Plaintiff
DON WRIGHT AND JEAN WRIGHT,
husband and wife,
Defendants
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO· 2002-1401
: CIVIL ACTION - LAW
: IN EJECTMENT
To the Prothonotary:
Please mark the judgment satisfied with prejudice in the above-captioned case.
Date:
Respectfully Submitted,
WIX, WENGER & WEIDNER
By:
David R. Getz, I.D.# 34838
508 North Second Street
Post Office Box 845
Harrisburg, PA 17108-0845
(717) 234-4182
F:~drg~9230 - West Shore Evangelical Free Church\10286 - Real Estate - Monroe Township Property~Documents~Praecipe to
Satisfy Judgment.doc 5/20/02