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HomeMy WebLinkAbout06-2531 """ . COMMONWEAlTH OF PENNSYLVANIA COURT OF COMMON PLEAS .~'" Judicial District. County Of NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. I">l..- :J~I ~ NOTICE OF APPEAL Notice is given that the appeilant has fiied 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. CITY s ?Uc€)/ MAG. DIST. NO. - 3- 0<'; ZIP CODE /7 O-S:'G LC DOCKET No. This block will be signed ONLY when this notation is required under Pa. 1001(6) in action R.C.P.D.J. No. 1008B. This Notice of Appeal, when received by the District Justice, will operate as a before a District Justice, A COMPLAINT MUST BE FILED within twenty SUPERSEDEAS to the judgment for possession in this case. e.. (20) days aftar filing the NOTICE of APPEAL PRAECiPE TO ENTER RULE TO FilE COMPLAiNT AND RULE TO FilE (This section of form to be used ONL Y when appellant was DEFENDANT (sea Pa.R.C.P.D.J. No. 1001(7) in action before District Justica. IF NOT USED, detach from copy of nolice of appeal to be seNed upon appellee. PRAECIPE: To Prothonotary Enter ruie upon I) tlJu VI -I- '1AJJU E'ft! I6-~'Tftta,'w,....,J 1\ appeilee(s). to file a complaint in this appeal Name of appel/ee(s) (Common Pleas No. DIn-.::J S'3 J rJ. ;u;L ) within twenty (20) days after service 0 ~8uI) RULE: To flNJUl>n ..,.. 'llftJr/EEte ..T6A1',Ih('lwvl1 appeilee(s) Name of appellee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date ot service ot this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. Date: fYI:J.'I _~ ,20{){,.., '- ~~, /) P ~bL 7Jl& Signature f onot8ry or D P YOU MUST iNCLUDE A COPY OF THE NOTiCE OF JUDGMENTfTRANSCRiPT FORM WiTH THiS NOTICE OF APPEAL. AOPC 312-02 WHITE - COURT FILE TO BE FILED WITH PROTHONOTARY GREEN - COURT FILE YELLOW - APPELLANT'S COPY PINK - COPY TO BE SERVED ON APPELLEE GOLD - COPY TO BE SERVED ON DISTRICT JUSTICE '" i PROOF OF SERVtCE OF NOTICE OF APPEAL AND RULE TO FtLE COMPLAINT (This proof of service MUST BE FILED WITHIN, TEN (10) DAYS AFTER fifing of the notice of appeal. Check applicable boxes.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ; ss AFFIDAVIT: I hereby (swear) (affirm) that I served o a copy of the Notice of Appeal, Common Pleas , upon the District Justice designated therein on (date of service) ,20 0 by personal service 0 by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) , on , 20 0 by personal service 0 by (certified) (registered) mail, sender's receipt attached hereto, (SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF , 20~, Signature of affiant Signature of official before whom affidavit was made Title of official My commiSSion expires on ,20_, y 'bs g ...., ~ "-iQ. h c::> c::> ?:::J s: "'" ~~ :It ~" fi=- "- - ~ - -< ~~ ~ ~ C , 9 ~ ~e.;. en 0 r-::r~ - ~ '<-- ,.. ~ B ~o :It g~ o.,.J :E>2 'R :S P- ~ ~ FE! en 'II-- ~ ~ CJ-) f' i 09-3-04 NOTICE OF JUDGMENTrrRANSCRIPT PLAINTIFF RESIDENTI~~E~o~~~S~ fl;GATPUll.IWALA, ABJOM&: TAHVBER 1115 CARRINGTON CbUll.T,E MBCHARICSBUll.G, PA .17050 L '"1 ~OMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBElU.AI1D Mag. Dist. No.: MDJ Name: Hon. nOMAS A. PLACET Add,." 104 S SPORTING BILL RD MBCBAHJ:CSBUll.G, PA VS. ' ..J " ~ DEFENDANT: .\' NAME and ADDRESS 'cOLWELL, LISA A 1286'IIDJITBR'S RIDGE DRIVE MBCBARICSBUll.G, PA 17050 '"1 Telephooe (717) 761-8230 17050 LISA A. COLWELL 1286 IlUlftBR'S R:IDGB DRIVE ~CBAHJ:CSBUll.G, PA 17050 L Docket No.: LT-0000213 -06 Date Filed: 4/13/06 ..J . THIS IS TO NOTIFY YOU THAT: Judgment: POR PLA:IRTIPP !iJ Judgment was entered for: (Name) IGAi'PUll.IWALA, ABJOM' &: TAHVBBR liJ Judgment was entered against COLWELL, LISA A X Landlordrrenant action in the amount of $ 1.410. SOon 4/25/06 (Date of Judgment) The amount of rent per month, as established by the Magisterial District Judge, is $ .765.00. The total amount of the Security Deposit is $ . 750~ 00 , Total Amount Establi.Shed by MDJ Less' Security Deposit ApQlied_ = Adjudicated Amount Rent In Arrears . . $ 1,~50.00 -$ .' .VO - $. . 1,150.00 Physical Damages Leasehoid Property $ . .00, $ . .00 = $ .. .00 Damages/Unjust Detention $ 00 $ _ 00 = $ 00 Less Amt Due Defendant from Cross Complaint - $ _ 00 Interest (if provided by lease) $ 1!;~ 00 UT Judgment Amount $ L 303 _ 00 Judgment Costs $ 107. 5Q Attorney Fees $ 00 . Total Judgment $ 1,410.50 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ y Ime 0 eVlc Ion. o Defendants are jointly and severally liable. in a o o o Attachment Prohibited/ .42 Pa.C.S. 98127 This case dismissed without prejudice. Possession granted. [!] o Possession granted if money judgment is no sa IS Ie Possession not granted. IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF 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 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 JUDGMENTITRANSCRIPT FORM WITH THE NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDUR.E 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,MAV BE ISSUED BY THE MAGISTERIAL DISTRICT JUDd!;. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANVONE INTERESTED_~ THE JUDGMENT MA V FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTDR PA VS IN FULL, SElTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. c} -' .-- , Magisterial District Judge IRg$contalnlng t e JU gment. , Magisterial District Judge , , Mv commission expires first Monday of January~2GIO, AO~C 315A-OS SEAL . ~ .;.""~~f,i.' ':,l"-i'::.l",~~'r;,:;-,;'''-~'-'----::. .~ ""i . . CJ IT" IT" IT" <:(J <:(J .:r rn .lI CJ CJ CJ CJ IT" rn CJ U.S. Postal Service", CERTIFIED MAIL" RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) Certified Fee 0 f',,) C = ""'0 Return Receipt Fee $1.85 = (Endorsement Required) s: ~ ." "Vcc ::u: :i! Restricted DeHvery Fee lO.oo mf" :ta (Endorsement ReqUired) ~ti~ -< m:n -chi Total Postage & Fees l4.64 S9)~ N :.05:' rp- ~'~ '< _. ~r~" -0 L-" ....,.... 0(") )>0 -"'- C 6m Z ~ =2 .::- N -< 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.) COMMONWEAL'91 OF PI]NNSY. LVA~I'i COUNTY OF (~, f4 lil/2e.r IfIIr ~ ; ss AFFIDAVIT: I hereby (swear) (affirm) that I served ca/ a copy of the Notice of Appeal, Common Plea~ d~ 3/ ,upon the District Justice designated therein on (date of service) mil' " ,20 0(P . 0 by personal service ~ertifie,d) (registered) mail, sender's receipt attactmd hereto, and upon the appellee, (name) , --. - 1'.' Cr.' on ()? If!o. ? ,20 0<0 0 by personal service y (certified) registered) mail, , ~;fZS~:~:~:Dh::O~~E , L.,. / /'/5!: pl 4d j " '.. f..~...,1 .20f4tz-. ~~~ . . ':.:_' t.--'.... Signature of affiant ~-- .lI CJ CerlIlIed Fee CJ CJ Return ~ Fee $1.85 (Endo18lllll8lll RecjulnId) /It LI ~ CJ RestrtcI8d Oe!!very Fee lO.OO IT" (Endor8ement Required) rn CJ 1btaI Poelage & FMs l4.64 LrI :1of//31/3 CJ CJ I"- ....~ ~ .,,~ r.._",.,. --<', .....,..-c.~ ."~"'1J""" ""'................, ,,_._-,~~-.._" ~ COMMONWEALTH OF. PENNSYLVANIA COURT OF COMMON PLEAS Judicial District, County Of NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT CO_ON PLEAS No. ~_ ;;;;~~I ~\ 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 elate and in the case referenced below, MAG. DlST. NO. (J - 3,- 0,/ CITY s ZIP CODE .,~~..." ~ This block will be sjgriJMt~LY, " '~tion is required under Pa. (see Pa, R.C.P.D.J. No, 1001(6) in action R.C.P.D,J. No, 1008&:'":", './ '.~ '~j ;~':' This Notice of Apptil1,.~crecei~ by th4t~JP(;()J.ustice, will operate as a before a District Justice, A COMPLAINT MUST BE FILED within twenty SUPERSEDEAS~"t~judgroent(Of~'. ~ Ha case. 1. . 1::"', . ..'... .,'. -'" , (20) days after filing the NOTICE of APPEAL. : .~. j ". t . ~ } ~ ..., \ ,;I..", ,.'... ,I";.. ..' ... " :_ ,,':" ',,-- h " -" ':2~~.~jl&ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be'iiStd Oivt...y.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 t4 flJU'VI -J.. /A)/() rf~ J6A-7fflC2IW I't-J i\ appellee(s), to.flIea complain~ in thiS1i~ Name of appellee(s) (Common Pleas No, DiD-:J $'3 I (l iui L ) within twenty (2~) days after service .1l:U1e or suffeF.entry ofjudgmem of non p~, ~8l.nJ M'-'" ....~...;d ~6+>< q~ '. . .' , ~,,'1"^"\ .",'7 / . ."1'~"~ . 1,. .... Qfa,P,.trantor"jiiXiieyor.", RULE: To fJ NJu W\ ~4~i~, ..J6.A1' j)I.l1iW(f4,:,...'. _..'tel , ,~.., :,\~~'J~' ,.'" .. of .. "Ie(s}."" . , '.,' } '\ . ., ".,~.' , (1) You are n~~~at a rule is hereby ~met!d upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon YqlfiQ)l.pel'Sonal service or by Ctlfti5!ld or registered mail. r' :..:'''','.~ ,~ (2) If you do not file a com~l~tWithin this tifr\e;;~ JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. ft ...... ., . . " '. ."...:...it~'. e , (3) The date'9,fsetce ofthi~_~le'ifservice was1>y :ail is the date ofthemailing./Jnl-J11.tJ~ Date:fYlat...s"'.,,~'~~Db' '-- 1/-4~, /J - S~n:Uf8I'~::ortttIV '\ I,~">"':'~'\"'~:~~ YOU MUST INCLUDE A COpy OF THE NOTICE OF JUDGMENTrrRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-02 WHITE - COURT FILE TO BE FILED WITH PROTHONOTARY GREEN - COURT FILE YELLOW - APPELLANT'S COPY PINK - COpy TO BE SERVED ON APPELLEE GOLD. COPY TO BE SERVED ON DISTRICT JUSTICE ANJUM & TANVEER IGATPUNIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-2531 CIVIL TERM LISA A. COLWELL, DEFENDANT IN LANDLORD/TENANT PRAECIPE To the Prothonotary: Please terminate the supersedeas ln the wi thin action for failure of the appellant to pay the required deposit at the time of filing the Notice of Appeal. District Justice Rule 1008-B provides that the appellant at the time of filing the appeal, is required to deposit with the Prothomntary a sum of money equal to the lesser of three (3) month's rent or the rent actually in arrears on the ~ of filing of the appeal. The Appellant's monthly rent, as determined by the District Justice was $765.00. Three (3) month's rent would be $2,295.00. The District Justice found that the Appellant owed rent of $1,150.00 at the time of the hearing, April 25, 2006. As of May 5, 2006, when the Notice of Appeal was filed, Appellant owed additional rent of $765.00 for the month of May. Therefore, to obtain a supersedeas, Appellant was obligated to deposit $1,825.00 with the Prothonotary at the time of filing her Notice of Appeal. Appellant only deposited t /,(110. ~O ~:b. ~ Thomas D. Gould Attorney for Plaintiffs I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 '-\~ f F' C/~ (0).f ~~ r-.. .~ () c s: "'0 t-'- Cll( .t.~...'- zic (,0 ,; ~C' .3> ," ~~~" :Z ~ 1'-3 t::::) <=:) 0'" :E 3> -< ~ ~:n :o.fTi .UD OT _Iel -:T': ~.F. (5:0 70 ,srn ~ -< -.I J> :x \.D .. w -.,J ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-2531 CIVIL TERM LISA A. COLWELL, DEFENDANT IN LANDLORD/TENANT CERTIFICATE OF SERVICE AND NOW, this /'~ day of May, 2006, I, Thomas D. Gould, Esquire, Attorney for Plaintiffs, Anjum & Tanveer Igatpuniwala, hereby certify that I have this day sent a copy of Plaintiff's Complaint by depositing a copy of it in the United States mail, postage prepaid, addressed to: LISA A. COLWELL 1286 HUNTER'S RIDGE ROAD MECHANICSBURG, PA 17050 DATED MtJAj , " J..'d' -:1Tu.m44 0. ~ Thomas D. Gould, Esquire ID # 36508 2 E. Main Street Shiremanstown, PA 17011 (717) 731-1461 0 ......., 0 = c = -n ;Z:'- C1"' :JI: --I )~~ :C." -{ rnp :f~ c-J \.0 '~:-:;() __'~M" -"'-, -? '~~~,\ -::iolo- ~ 's,n :::=t ~ ._~. -.l :Q ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-2531 CIVIL TERM LISA A. COLWELL, DEFENDANT IN LANDLORD/TENANT 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 judgement 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 loose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE OF THE Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 THOMAS D. GOULD ID # 36508 2 EAST MAIN STREET SHIREMANSTOWN, PA 17011 (717) 731-1461 ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-2531 CIVIL TERM LISA A. COLWELL, DEFENDANT IN LANDLORD/TENANT COMPLAINT AND NOW, comes the Plaintiffs, Anjum & Tanveer Igatpuriwala, by and through their attorney, Thomas D. Gould, and files this complaint alleging: 1. The Plaintiffs reside at 1115 Carrington Court East, Mechanicsburg, Pennsylvania 17050. 2. The Defendant, Lisa A. Colwell, currently resides at 1286 Hunter's Ridge Drive, Mechanicsburg, Pennsylvania 17050. 3. The Plaintiffs are the fee simple owners of 1286 Hunter's Ridge Drive, Mechanicsburg, Pennsylvania. 4. On July 9, 2004 Plaintiffs and Defendant executed a Residential Lease for the premises at 1286 Hunter's Drive, Mechanicsburg, Pennsylvania. A copy of the Lease is attached as exhibit A. 5. The one year lease began on July 17, 2004 and terminated on July 17, 2005. .-"'IU n.-..1J,1I 1\t.:~l11L'nllul Ll';:),se RESIDENTIAL LEASE Apartment. .. Condominium.. House BY'JHISAGREEMENTmadeandentercdintoon ::r0\.::J('\~ :l-<Joy . %' between AY\J~;"" 0.",<\. TaY\veev- "'I 5 ool-PU-rlNo.l..o-. ,herein referred to as Lessor, W() /-J'Sc<- . A. C <> \ w<a..LL ". ,herem referred to as Lessee, Lessor leases 10 Lessee the premises situated at ~\ '2.'~b H \.mi~I/'" Rld.~ e. OR " ,inlheCityof Mec..\..-.c;",:,sb"v'i fAtioS'o,Countyof C" ,,,,\.,~....\.,,,,,,,,,,,, ' State Df 'Pc "'r. '6:1 \1,0('1') I' C""- , ancrmore particularly described as follows: II ' together with all appurtenances, for a term of 0 N ~ yeary, to commence on :::r0\~ I "t C'" "'.:20 Nt ,).I) ,and 10 end on.:rv~y ,"t~ ,,.W' ~Ol)5', at o'clock . m, "" c...,e. 1. HCIII, Lessee agrees to pay, without deman,l!. to Lessor as rent for lhe demiseA premises the sum ~ 00 'beveV\.. hu....d.....c\ an<!-\7'*'t-'1 01"\\""$ plv.$ ~IS- ;;,....;..pe.t per "t.io'iiars'o; , ($ <'1-S Q'x,," ) per month in advance on t!re 5+~ day of each calendar month beginning ~~ AUQ.J1o-L ';.2.004 ' W ,at . . -.J. City of , Slate of , or at such other place as Lessor may designate. 2. Sccurity Deposit. On e~cu[jon of this lease, Lessee deposits with Lessor o c s.cve~~u",J"..J ~~~ do\\o..tS c"l"Il'1 Dollars ($'TSD "... ), receipt of whIch is acknowletlge.v by Lessor, as security for the faithful pcrf()rman~e hy Lessee of the terms hereof, to be returned to Lessee, without interest, on the full and faiUlful perfmmance by 111m of tlle provisions hereof. ....... 3. Quict Enjoymcnt. Lessor covenants Ihat on paying the rent and performing lhe covenanlS herein contained, Lessee shall peacefully and quietly have, liold, and enjoy the demised premises for the'!lgreed term, . 4, Usc of Prcmises. The demised premises shall be used and Occupied by Lessee exclusively as il priville sing!.: family resit!.:nce, and neither the premises nor any part thereof shall be used at imy time during Ihe tcrm of this lease by Lessee for the purpose of carrying on any business, profession, or trade of any kind, or for .Iny purpose other than as a private single family residence. Lessee shall comply with all the sanitary lulYs, ordinanccs, rules, and orders of appropriate govcrnmcntal authorities affecting the cleanliness, oeeupilllcy, and jireservalien of lhe demised premises, and the sidewalks connected thereto, during the term of this lease, ", 5. NUlllhcr nf Occupants. Lessee agrees that the demised premises shall be Occupied by no marC than .;L {, -TwO:) persons, consisting of O\"\e., adults and one.. childr&R-under the age of years, without Ihe written consent of Lessor. . 6. Condition of Premiscs. Lessee stipulates that he has examined the der.ni$ed premises, including lhe grounds and all buildings and improvements, and U)at they are, at the time of this lease, in good ordcr, repair, and a safe, clean, and tenantable condition. ' 7. Assignment und Subletting. Without the prior wrillen consent of Lessor, Lessee shall not assign this lease, or sublet or graut any conCession or licence to use (he premises 01' any part thereof. A conSent by Lessor to one assignment, sublelling, concession, or license shall not be deemed to be a consent la any subsequent assignment, sublwing, concession, or license. An assignment, subletting, concession, or liccnse without the prior wrillen consent of Lessor, or an assignment or subletting by operation of law, shall be void ami Shall, at Lessor's option, tcrminate this lease, 8. Alterations and Improvements. Lessee shall make no alterations -to the buildings on the demised premises or construct any building or make other improvements on Ule demised premises without the plior writtcn consent of Lessor. All alterations, chunges, and improvements built, constructed, or placed on tlie dcmised premises by Lessee, with the ex~eption of fixtures removable WiUlOlIl damage to the premises and movublc personal property, shall, unless otherwise provided by written agreement between Lessor and L~ssee, be thc property of Lessor and remain on the demised premises at the expiration or Sooner termination of this lease. 9. Dalllage to Prcmises, If the demised premises, or any part thereof, shall be partially damaged by fire or oUler casualty not due to Lessee's negligence or willful act or that of his employee, family, agent, or visitor, the premises shall be promptly repaired by Lessor and there shall be an abatement of rent corresponding with the time during which, and the extent to which, the leased premises may have been L1nlcnanlilule; but, if the leased premises should be damaged other than by Lessee's negligence or willful act or tliat of liis employee, family, agent, or visitor to the extent that Lessor shall decide not to rebuild or repair, 11.1~ term of lliis lease shall end and the renl shall be prorated Lip to the time of the damage. " 111,I!lllll~l~l, EXHIBIT A 10. Dangerolls Materials. Lessee shall not keep or have on the leased premises nny nrticle or tiling of a dangerous, inflammable, or explosive character that might unreasonably increase the dallger of fil e on the leased premises or that might be considered hazardous or extra hazardous by any respousible insurance company. 11. Utilities. Lessee shall,be responsible for arranging for and paying for all utility services required on the premises. except Ilwt S:~II" G'\. -n4 -tt,..,'f'C\<; L... shal! be provided by Lessor. 12. Maintenance and Repair. Lessee will, anlis sole expense, keep and Itlpjntain the lensetl premises and appurtenances in good and sal1.itary condition and repair during the term of this lease and any renewal thereof. In particular, Lessee shall kecp the fixtures in the house or on or about the leased premises in good order and repair; keep the furnace clean; keep the electric bells in order; keep the walks free from dilt and debris; and, at his sole expense, shall make all required repairs to the plumbing. range, healing, appalalu,s, and electric and gas fixtures whcnevcr damage thereto shall have resulted from Lessee's misuse, wasle, or neglect or that of his employee. family. agent. or visitor. Major maintenance and repair of the Ien.sed premises. not due to Lessee's misuse, waste, or neglect or that of his employee, family, agent, or \'isiIOl, i shall be the responsibility of Lessor or his assigns. Lessee agrees that no signs shall be placed or painting done on or about the leased premises by Lessee or at his direction without the prior wriLlen consent or Lessor. 13. Animals. Lessee shall keep no domestic or other animals on or about the leased premises without the wrillcn consent of Lessor. 14. Hight of Inspection. Lessor and his agents shall have the right at all reasonable times during the term of this lease and any renewal thereof to enter the demised premises for the pUljlose o[ inspecting the premises and all building and improvements thereon. 15. Display of Signs, During the last Lt5' days of this lease" Lessor or his agent shall have the privilege of displaying the usual "For Sale" or "For Rent" or "Vacancy" signs on tile demisc.u premises and of showing the property to prospective purchasers or tenants, 16. Subordination of Lease. This lease and Lessee's leasehold interest hereunder mc and shall be subject, subordinate, and inferior to any liens or encumbranccs now or hereafter placed on the demised premises by Lessor, all advances made under any such liens or encumbrances, the, intercst payable 011 any slIch liens or cncumbrances, and any and all renewals or extensions of such liens or encumbrances, 17. Holdover by Lessee. Should Lessee remain in possession of the dcmised premisc., with the consent of Lessor afler the na(~ral expiration of this.lease, a new 1l10mlHO-monLh tenancy shall be creatc.u beLween LessPi' and Lessce which shall be suhject to all the terms and conditions hereof but shall be terminatcd on~ ~~<"'" days' wriLlcn notice served by eWler Lessor 01 Lessce on the other party, ", 18. Surrender o[ Premises. At the expiration of the lease tenll, Lessee shall quit and sUlrender the premises hereby demised in as good stale and condition as they were at the commencement of this Jense, rcasonable use and wear thereof and damages by the elements e.xcepted, 19. Default. If any default is made in the payment o[ rent, or any part thereof, at the times hereinbefore spccified, or jf any dcfault is made in the performance of or compliance with any oIlier lerrn or condition hcreof, the lease, at the. option of Lessor, shall terminate and be forfeited. and Lessor may re.-enler the prenfises and remove all persons thercfrom. Lessee shall be given written notice of ally de[ault or brcach. and termination and forfeiture o[ the lease shall not result if, within' days of receipt of snch nOlice., Lessee has corrected ule default or breach or has t.1ken action reasonably likely to effect such correclion within a reasonable time. 20. Abandonment. If at any Lime during the tenn of this lease Lessee abandons the demised premises or any part thereof, Lessor may, at his option, enter the demised plemises hy any means wilhout being liable for any prosecution therc[or, and without becoming liable to Lessc.e [or damages or for any payment of any kind whatcver, and may, at his discreLion. as agent for Lessec, relet the demised plemises, or any pan thereof, for UIC whole or any part of the Ihen unexpired term, anti may receive and collect all rent payable by virtue of such relelling, and, at Lessor's option, hold Lessee Iiahle [or any difference between the rent that would have been payable under this lease during the balance of the unexpired term, if this Ica,<e had continued in force, and the net rent for such period realized by Lessor by means of sudl reletting. If Lessor's right of re-entry is exercised [ollowing abandonment of the premises hy Lessee. Ulen Lessor mny consicter any personal property belonging to Lessee and le[t on the prcmises to also have been abandoned, in which C:1.<C Lessor may dispose of all such personal property in any manner Lessor shall deem proper and is herehy relieved of all liability for doing so, 21. llinding Effect. The covenants and conditions here.in contained shall apply to and bind the., heirs, legal representatives. and assigns of the parties hereto, and all covenants arc to be construed as conditions of this lease, ~J";'" ~ 9<>-..+~' ~ -..J ...L Lesso" ~.--, \ q \ I, ,/1 () '1 ' 22. Oth.er Tenn-s:l''''e. lrS~f'e ""; II L~ ~d:t.'o"\ ,t<> """""~\::l'~J ~~ --Tt,t hy........s "~fI,,...;. \eCVl~ . c.",,',,'V\~ ....,~~ (X~\ ~t_ -l't."""s 'tr L~",d\'i;o.,t \a.\c\ ~"'....;...... Lv-:. '~e. c""d.~",I",\v.", ~SS. <:(''''+:'.,...1 .- '~,):,le'-')"'e-ll o..",c\ '?'~~o-t.. '-\:1...<: -I:t.,,,,s. ~ c."O'\d-~",,^, \<>...00\ .10""'" Lv' -\-~... J I '\ ..1 ,,'t,S v..rt.~\\ ~ " ,p.'O"Ol.e.~"c) oJ.......... \'0 .\\.....v:l \~r.v:>e. (V\~\C-..B o~ w-R,J.... ,^~e..\oe.......... ,0""." ci..rR t~ .-\,^-,- \e",l;~E: \...l"t 't\,.ol1 ~ I '\ ~ , IN WITNESS WHEHEOF, the parties have e.xccuted this leasc!lt ~~toT , , ll1e day alld year first !lbove wrillcll. ,/'} \,./;;I'~,' '-,L/ /~~ftL' - - //- 1--",.-/' ~~v Dated: July 09, 2004 Addendum to Residenfi~J ~ . The Lessor is not responsible for the Lessee's personal belongings on the premises. It is advisable ror the lessee to have Renter's Insurance. . The Lessee will get the carpets professionally shampooed on vacating the premises. . The Lessor expects monthly Rent by the 5th day of every month. A $10 per day charge will be applied to the Rent amount ror the number or days late. . Received Security deposit or 750.00 (Seven hundred fifty dollars). . The Lessee will be charged $15 per month per pet in addition to the rent or ($750.00). /, 7/ry 1"(llll\ :\'310 H€~!d';lltiul Lease RESIDENTIA L LEASE, Apnrtmeni - Condominium - House . ,-r- +J..- ') 005 BY THIS AGREEMENT made and entered mto on () VI') e. J 2 -:- ,.r- , ..w-- between '111\~':"" C\ \'141" Ylvee r . :I:jcd1f",ti t>lo..Lo.. " here!n referred to as Lessor, allJ l"S';t.A, Co\w<:.L.L . ,'., herem referred to as Lessee, Lessor IeJses to Lessee the premises situated at \-:1.86 !+L:>'1'KV 5 R.'c\JQ 'J)y,.,-t., 5'l . ,in the City of i"1ec:-h-,,., I'c.sb~<~ fA 1'7~ ,County of C V>'Y' b ('''/CVy,,::( , State of P{..Yl n5'j 1\/",1'\,'", , and"rriore particularly described as follows: ~, lOgether Wilh all appurtenances, for a term of k Dne :Jv~ 16:- cxOJ5 ,,J'9 , and to end on ::r, 'j 182..-. ;LbO 6 o'clock , m. yeaI;i, tD commence on , ,r9' , at 1. RCllt. l.,essee agrces to pay without de'f~and, to Lessor as rent for tJle demjsed premises Ule ~l1m ofH-.. (; .( - 00 Se:vt'" nun drt'c{ <'(Y1q +fr1 dv\i"",.> ?\vs ~'S toY' OYlt, fet {e .r56!r'ilrs =-~;f;~S ($ ':f5 D :;:;- ) per monulin advance on the day of each calendar month beginning -to. --1 ' 19 ,at City of , State of , or at such other place as Lessor may designate, 2, Security Deposit. On execution of this lease, Lessee deposits with Lessor .. -:~ Dollars ($ ), rcceipt of which is acknowledged by Lessor, as security for the faithfnl pcrf'Jrl1lHnCe hy Lessee of the terms hereof, to be returned to Lessee, withont interest, on the full f.IJ1d faithful pafui'lnanee hy him of Ule provisions hereof. 3. Quiet ElIjoymclIt. Lessor covenants that on paying the rent and performing the covenants herclfl cllntaincd, Lessee s),all peacefnlly and quietly have, hold, and enjoy the demised premises for th"el1grccd Icrm. 4. (1St of Prcmists. The demised premises shall be used and occupied by Lessee exclusively as ,I private single family residence, and neither the premises nor any part thereof shall be used at any lime during Ibe IeI'm of this lease by Lessee for the purpose of carrying on any business, profession, or trade of any kind, or lor any pllqlose other than as a private single family residence. Lessee shall comply wilh all the sanitary la\Vs, ordinances, rules, and orders of appropriate governmental authorities affecting the cleanlincss, occllpancy, and preselvation of the delnisel1 premises, and the sidewalks conneqed thereto, dllring the term of Ibis lease, '" . 5. N~_I..nlJcr.. of Occupants. ~essee ~grecs that the demised premises shall be occupied by no ClIore Ihlln d.. (tv.JCo) persons, consisting of Ot1e..adulrp and 0>1 e.. children under the age of years, Wilhout the written consent of Lessor. ' 6. Condition of Premiscs. Lessee stipulates that he has examined the demised premises, in,lllding the grounds and all bllildings and improvements, and Ulal they are"atthe time of this lease, in good Imler, repair, und a safe. clean, and tcnanwble condition. 7. Assignment and SufJlctting. Without the prior written consent of Lessor, Lessee shall not assign this lease, or sublct or grant any concession 01 licence to use the premises or any part thereof, A conscnt by Lessor 10 one assignment, SUbletting, concession, or license shall not be deemed to be a consent to ilny subseqllcnt assignment, sublelting, concession, or license. An assignmcnt, subletting, concession, or liccnsc wilhollt Ihe prior written consent of Lessor, or an assignment or subletting by operation of law, shall be void and shall, at Lessor's option, tcrminate this lease. 8, Alterations and Improvemcnts. Lessee shall make no alterations to the buildings on the dclllised premiSeS or conSIIIIct any building or make other improvements on the demised premises without the prior writtcn cunsent of Lessor. All alterations, changes, and improvements built, constructed, or placed on ti,e demiscd premises by Lessee, with thc exception of fixtures removable WiUIOllt damage to the premises and movable personal property, shall, unless oUlerwisc provided by written agreement between Lessor and Lessee, be the propeny of Lessor ancl remain on Ute demised premises at the expiration or Sooner tenninalion of this lease. 9. Damage to Prcmises. If the demised premises, or any part thereof, shall be partially dnmaged by fire or olller casualty not due to Lessee's negligence or willful act or that of his employee, family, agent. or ViSitor, the prenllSes shall be promptly repaIred by Lessor and there shall be an abatement of rent corresponding wilh the time dllrin~ which, and the extent to which, the leased premises may have been untcnallt<lblc; bUI, If the leased prCllllseS should be damaged other than by Lessee's negligence or willful act or Ihal of hi" employee, family, agent, or visitor to the extent that Lessor shall decide not to rebuild or repair, the IeI'm of I!',IS lease shall end and the rent shall be prorated up to the time of the damage. 111111I111111I1111 I 1/ 11I1I1111 o )3926 2(04) 0 EXHIBIT B 10. Dangerous Materials. Lessee shall not keep or have on the leased premise,s any anicle or thing of a (hUlgerous, inDammable, or explosive character UlUtmight unreasonably increase Ule danger of fire on the leased premises or that might be considered hazardous or extra hazan10us by any responsible insurance company, II. Utililies, Lessee shall be responsible for arranging for and paying for all utility servic~s required on UIe premises, except Uml Se.. u..'> <-,- co". ,.,c\ --n\> "~$l-- . shall be provided by Lessor. 12. Maintenance and Repair. Lessee wiIl, at'h'is sole expense, keep and maintnin the leasnl premises and appunenanees in good and sanitary conditioll and repair duridg'l1Je term of this lease and any renewal thereof. In panicular, L-essee shall keep the fixtures in the house or on or about the leased premises in good order and repair; keep Ule furnace clean; keep the electric bells ill order; keep Ule walks frce from dirt and debris; and, at his sole expense, shall make all required repairs to the plumbing, range, heating, apparatus, and electric and gas fixtures whenever damage Ulereto shall have resulted from Lessee's misuse, waste, or neglect or that of his employee, family, agent, or visitor. Major maintenance and repair of the lensCll prcmises, not due to Lessee's misuse, waste, or neglect or that of his employee, family, agent, or visitor, shall be the responsibility of Lessor or his assigns. ' . Lessee agrees that no signs shall be placed or painting done on or about the leased premises by Lessee or at his direction without the prior wrillen consent of Lessor, 13. Animals, Lessee shall keep no domeslic or other animals on or about the leased premises wiUlOutthe wrillen consent of Lessor. 14, Hight of Inspection. Lessor and his agents shall have tbe right at all reasonable times during the term of this lease and any renewal thereof to enter the demised premises for the puqlose of inspccting the prcmiscs and all building and improvements thereon. IS, Display of Signs. During the last if 5 days of this lease. Lessor or his agent slwll have the prIvilege of displaying the usual "For Sale" or "For Rent" or "Vacancy" signs on the demised prcmises and 'lf showing the property to prospective purchasers or tenanLS. -.... :'.~ 16. Subordination of Lease. This lease and Lessee's leasehold inle,rest IJereundcr are and shall be subject, subordinate, and inferior to any liens or eucumbrauces now or hereafter placed on the delllised prcmises by Lessor, all advances made under any such liens or c.ncumbrances, the intere,\t pn)'able un any SlIch licns or encumbrances, and any and all rcnewals or extensions of such liens or encumbrances. 17. Holdover by Lessee, Should Lessee remain in possession of the demised premiscs with thc consent of Lessor after Ule natpral expiration or Ulis lease, a new month-to-month tenancy shall be Cleated betwccn Lessor and Lessee which shall be subject 10 all the terms and conditions hereof but shall be tcrminated on days' writlennotice served by either Lessor or Lessee on the other party. ", 18, Surrender of Premises, At the expiration of tlie lease term, Lessee shall quit and surrender thc prcmises hereby demised in as good state and condition as the)' werc at Ule cOll1mencement of this lease, reasonable use and wear Ulereof and damages by Ule elements excepted. 19, Default. If any default is made in the payment of rent, or any part thereof, at the times hereinbefore spccified, or if any default is made in the performance of or compliance with any other tcrm 01 condition hereof, the lease, at Ule option of Lessor, shalllerminale and be fnrfeiled, and Lessor IIlny rc.-enlel' the prentises and remove all persons thercfrom. Lessee shall be given written noLiee of any defaull or brcach, and teimination and forfeiture of the lease shall not result if, within days of receipt of silch notice, Lessee has corrected Ule default or breach or has mken action reasonably Iike.ly to effect such correct ion within a reasonablc time. 20. Abandonment. If at any time during the term of this lease Lessee abandons tbe demised premises or any partlhereof, Lessor may, at his option, enter the demised premises by 8ny means without bcing Iiablc for any prosecution therefor, and without beconting liable to Lcssee for damages or for an; p,lymenl of any kind whatevcr, and may, at his discretion, as agent for Lessee, relet the demised pt'emises, or any palltherear. for Ule whole or any part of the Ulen unexpired term, nnd may receivc and collect all rent payable by virtue of such relelling, and, at Lessor's option, hold Lc.ssee lIahle for any difference between llie rcnt that woult! have been payable under this lease during Ule bal<mce of thc unexpired term, if this lease had continucd in force, and the net rent for such period realized by Lessor b)' means of such relc.lling. If Lessor', right of re-entry is exercised following abandonment of Ule premises hy Lessee, U,en Lessor ma)' consider any personal properly belonging to Lessec and left on the premises 10 also have been abandoncd, in which el.Sc Lcssor may dispose of all sucb personal property in any manncr Lessor sball uecm ploper alld is hercby relieved of all liability for doing so. 21. Binding Effect. The covenants and conditions here,in contained sball apply to and hind IIfC, heirs, legal representatives, and assigns of the parties hereto, and all covenants are to be construcd a" conditions of Ulis lease. . ' . . J.... . " .,- . l.. V l' . "'" L't:iA. ft.,.e \-e. vv J 22. pther Terms: 11, e h-e5s",e (.0;/\ l"'\.. uclclq",,^ ,II) LDm,( ::1'1 . ",<2. 6P. tHIS \-e::de u"""'pl1 "",Ctt-\, "'-,l~ -t"'-e. -fe~W'\5->- c.""''1Jcr'O~\J lct.ltJ J.~'-'JiA-llA, ~ \ 1 " / "" ,j co' " Jd....,\.dj -f '''''5''' +/d,te v""'-S (A, 4 do.....""- lJ^ tkt. c..0~\6'-ur""''l\'(''0'"\.'''- r]~s,::), JU\ ~ " I . ~ I'> (, . I I P J )+~ .h-{ 'eJ)'~" AJJc'^c\c;-.....-t"'tlA.;'J (&-..?e.. c(,)f,e.~ of G.'t.-.'~"'- v..t:l0 ~e,^ i"'Vl Co. , \0 -tK. l..-rS'50i ' ) ::J IN WITNESS WIIEHEOF, the parties have executed tltis lease at , the day ant! year first above written. . 0 ' ,,^"e?~ (lAd{ ~0s f\ Lessor Date: 6-12-05 ADDENDUM TO RESIDENTIAL LEASE . The Lessor is not responsible for the Lessee's personal belongings on the premises. It is advisable for the lessee to have Renter's insurance. . The Lessee will get the carpet professionally shampooed and cleaned on vacating the premises. . The Lessor expects monthly Rent by the 5th day of every month. A $10 per day charge will be applied to the Rent amount for the number of days late. . The Lessee will be charged $15 per month for one pet in addition to the rent of $750.00 per month. /'J -' j ./ / ,r " ",i./'" /)/; /J.It '~~ V /1 /" (U ~0s- " .- -::-.- . . .' . ..... RULES AND REGULATIONS OF TIMBER CHASE II, A TOWNHOME CONDOMINIUM GENERAL 1. Timber Chase II. Condominium Association (IlAssociationll.), acting through its Executive Board, has adopted the following Rules and Regulations (-Regulations -). These Regulations may be amended from time to time by resolution of the Executive Board. 2. Wherever in these Regulations reference is made to .Unit OWners, If such term shall apply to the owner of any'Unit, to his family, tenants whether or not in residence, servants, employees, . agents, Visi tors and to any guests, invitees or licensees of such Unit OWner, his family or tenant of such Unit OWner. Wherever in these Regulations reference is made to the . Associati.on, such reference shall include the Association and any Managing Agent when, a Managing Agent is acting on behalf. of' .the .Association. . 3 . The Unit OWners shall conply with all the Re9u1.ations hereinafter set forth governing the buildings, public areas, "drives, recreational areas, grounds, parking areas and any other ~ppurtenances . 4 . The Association reserves .the right to alter, amend~ . modify, repeal or revoke these Regulations and any consent ,or approval given hereunder at any time by resolution of the Executive Board. RESTRICTIONS ON USE 5. No part of the Condominium shall be used by or through a Unit Owner for any purpose exc~pt housing and the cOtmnOn . purposes for which the Condominium was designed, except for such accessory uses as may be authorized by the Executive Board .pursuant to Article VIII of the Declaration. Each Unit shall be used as a reside~ce for a single family, its servants and gUests. 6. There shall be no obstrUction of the Common Elements. Nothing shall be stored or placed on the Common Elements without the prior consent of the Executive Board except as provided herein or as expressly provided in the Declaration or Bylaws. EXHIBIT C 4. ;.... Limifed Common Elements, except in such areas as may' be specifically designated for such use by the Executive Board. Patios and decks shall not be used unreasonably as storage areas. No patio 'or deck shall be altered. iIi any way except with the . written permission of .the Executive Board, and any alteration shall be done in accordance with the Declaration. 17. Water beds shall be permitted; but ALL water damage to the Common Elements, Limited Common Elements .or other Unit Owner's Units, and the expenses incurred to. correct the damage shall be paid for by the Unit Owner of the Unit in which the . water bed was located when the water damage occurred. r PET RULES 18. No animals, except small, orderly dogs, cats and birds, shall be kept in any Unit or on the Common Elements, not to exceed one (1) per Unit, without first obtaining the prior written consent of the Executive Board, subject to compliance with the Declaration, Bylaws and these Regulations. Nothing contained herein shall prohibit a visually iupaired owner oZ". occupant from keeping a seeing-eye dog in his or her Unit. : Moreover, any person who at the time of purchase of a Unit owns two (2) .'small house pets shall be permitted to keep hoth pets in the Unit. When one of the pets dies or for any other reason is no longer kept in the Unit, that pet may not be replaced and the Unit Owner will thereafter be subject to the one (1) pet 'rule. 19. A pet may be maintained in a Unit so long as it is not a nuisance. Actions which will constitute a nuisance include but ,are not limited to abnormal or unreasonable . crying, barking, scratching or unhygenic offensiveness. 20. All pets must be licensed and inoculated as required by law and registered with the Association office. 21. Pet owners are fully responsible for personal injuries and/or property damage caused by their pets. 22. Pets shall not be walked upon the Common Elements, .ex~ept for such areas as the Executive Board shall designate from time to time for that purpose. No Unit Owner shall be entitled to keep any-domes"tic animal life on any portion of the . Common Elements,including Limited.Common Elements appurtenant to a Unit. No Unit Owner may erect any'fencing, gates, animal enclosures, animal stakes or animal runs or use any Limited - 4 - .\ .., To, 01-07-2006 Lisa Colwell 1286 Hunter's Ridge Dr Mechanicsburg, P A 17050. Re: Your Letter Dated January 5th 2006 (Late Payment of Rent). I am sorry to hear that you are still having financial problems and are once again unable to pay the rent on time. I would like to point out that the $10.00 per day late fee is what you have agreed to as part of our lease agreement. To help you out I am going to make an exception this month (January 2006) and forego the late charges as long as you pay the rent for January on the 13th of January 2006 as stated in your above referenced letter to me. This is not the first time that you have been late, We have been having this issue with late payments of Rent for the last several months. Next month onwards we will have to revert back to the lease agreement of rent due on the 5th day of every month, failing to pay the rent by this due date will result in a $10 late charge fee per day as stated in our lease agreement. If this is unacceptable then you are free to go ahead and find other suitable accommodations, Thank You, Anjum Igatpuriwala i\ ~ ~~ c--~~cv'\\~Y\ vu~ (Landlord) 717-732-8156 EXHIBIT D To: DATE: April 1 st 2006. lISA. A. COLWELL 1286 HUNTERS RIDGE DRIVE MECHANICSBURG, PA 17050 YOU ARE HEREBY NOTIFIED TO VACATE THE PREMISES DESCRIBED IN THE ADDRESS ABOVE WITHIN 10 DAYS OF THE DATE OF THE DELIVERY OF THIS NOTICE TO YOU. YOUR LEASE WAS TERMINATED WHEN YOU FAILED TO PAY LAST MONTHS RENT WHEN OUE. IF YOU FAil TO VACATE WITHIN THIS PERIOD, COURT PROCEEDINGS WILL BE TAKEN IMMEDIATELY TO EVICT YOU FROM THE PREMISES. FOLLOWING ARE THE GROUNDS FOR YOUR evICTION: · NON-PAYMENT OF RENT · UNAUTHORIZED OCCUPANTS. (LEASE STATES 1 AOUL T & 1 CHILD). YOU HAVE AN EXTRA PERSON LIVING AT THE ABOVE ADDRESS. · PET VIOLATION (YOU HAVE 2 PETS INSTEAD OF 1 AS STATED IN THE LEASE AGREEMENT & AS PER CONDOMINIUM ASSOCIATION GUIDELINES) · DAMAGE TO PROPERTY. (BIG HOLE IN LIVING ROOM WALL SINCE DECEMBER 2005 AND HAS NOT BEEN FIXED. LANDLORD. Av~r~ ~\4-f--~~~ 'S,- ~\ ~a( WITNESS COMMONWEAlTH OF PENNSYLVANIA NOTARIAL SEAl Jennifer l. Oi Sylvester, ~ary Public Derry TCMltlhip, Dauphin County i My Commission E s Feb. 2~,-?Q09 A~ 11M Bwom to before me this J~o~ ~ 9'MIJ)~ 'Lt", EXHIBIT E ...~) c::> -.:.::...:;j c~~... o -n -f :r:.." rl1~ :~~ to (' .~ -, :3: :;:.-"" ~-~ \..0 -'\:1 ;.:...; ;.;;- ~j -J~ ~ -.....,..~ --'-~,~ f'J C' , ANJUM & TANVEER IGATPUNIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO. 06-2531 CIVIL TERM LISA A, COLWELL, DEFENDANT IN LANDLORD/TENANT CERTIFICATE OF SERVICE ye. AND NOW, this LZ-- day of May, 2006, I, Thomas D. Gould, Esquire, Attorney for Plaintiffs, Anjum & Tanveer Igatpuniwala, hereby certify that I have this day sent a copy of Plaintiff's Praecipe by depositing a copy of it in the United States mail, postage prepaid, addressed to: LISA A, COLWELL 1286 HUNTER'S RIDGE ROAD MECHANICSBURG, PA 17050 DATED M4Af 17f 2..~', ~_l>. ~ Thomas D, Gould, Esquire ID if 36508 2 E. Main Street Shiremanstown, PA 17011 (717) 731-1461 o c ~,:: -0\)':' fJ)l:.\. -",;.;.:;. ({~;c 'P" .;:,~:. 'Z -0 -- ~ ~ '% 'P'" -<: - Ct:J ..", - ...-.'" Q. ~e .."l"'Q ~p9 "2.0. :x;.::;~ c:~o L-fn 0. ::4 5S ::<. l':'? N Ct:J ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-2531 CIVIL TERM LISA A. COLWELL, DEFENDANT IN LANDLORD/TENANT APPLICATION FOR RELEASE OF ESCROW RENT PAYMENTS AND NOW, comes the plaintiffs, by and through their attorney Thomas D. Gould, pursuant to District Justice Rule 1008-B, and files this application to obtain escrowed rent payments based on the following: 1. The plaintiffs are the owner of the premises located at 1286 Hunter's Ridge Drive, Mechanicsburg, Pennsylvania. 2. Defendant is the tenant of the premises at 1286 Hunter's Ridge Drive, Mechanicsburg, Pennsylvania. 3. Magisterial District Judice Placey issued a Judgment on April 25, 2006, which determined that the monthly rent was $765.00 and awarded plaintiffs $1,410.00, plus possession. 4. Defendant filed a timely Notice of Appeal. 5. Defendant, pursuant to District Justice Rule 1008-B, has made a deposit of past due rent and costs upon filing the Notice of Appeal. 6. In addition, defendant has made rent payments to the Prothonotary $765.00 for the months of May and June 2006. ... ..'" 7 . Defendant continues to have actual possession of the premises. 8. Plaintiffs have not received any rent from defendant during the appeal process, the months of May and June 2006, a total of $1,530.00. 9. Pursuant to District Justice Rule 1008-B, defendant, to preserve a superseades, is required to deposit the monthly rent payments with the Prothonotary each month during the pendency of the appeal. 10. Plaintiffs have filed a timely Complaint seeking damages and possession of the premises. Wherefore, it is requested that this Honorable Court direct the Prothonotary to release $1,530.00 from the defendant's escrowed funds and authorize the continued release of defendant's monthly rent payments. Respectfully submitted, DATE J"tUL 12, 200" ~~~ Thomas D. Gould, Esquire ID # 36508 2 E. Main Street Shiremanstown, PA 17011 (717) 731-1461 . ~ ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-2531 CIVIL TERM LISA A. COLWELL, DEFENDANT IN LANDLORD/TENANT CERTIFICATE OF SERVICE AND NOW, this ____ day of June, 2006, I, Thomas D. Gould, Esquire, Attorney for Plaintiffs, Anjum & Tanveer Igatpuniwala, hereby certify that I have this day sent a copy of Plaintiff's Application For Release of Escrow Rent Payments by depositing a copy of it in the United States mail, postage prepaid, addressed to: LISA A. COLWELL 1286 HUNTER'S RIDGE ROAD MECHANICSBURG, PA 17050 DATED 'J";.", /2..1 2"" ~]). ~ Thomas D. Gould, Esquire ID # 36508 2 E. Main Street Shiremanstown, PA 17011 (717) 731-1461 (') c "> c;;> C.:;;> "~;J", a (A! o .1 '-f III mt~ , J, (t-l 'w . . ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-2531 CIVIL TERM LISA A, COLWELL, DEFENDANT IN LANDLORD/TENANT IMPORTANT NOTICE TO: LISA A. COLWELL DATE OF NOTICE: June 10, 2006 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGEMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 --n;:,.".." SI>. h...u-V Thomas D. Gould, Esquire 2 East Main Street Shiremanstown, PA 17011 "'" -r..-:::J c,~;~ "''' c:) 'Tl (,.j) """:} (.,) -_..: '/ '" , ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO. 06-2531 CIVIL TERM LISA A. COLWELL, DEFENDANT IN LANDLORD/TENANT CERTIFICATE OF SERVICE lIC. AND NOW, this ~ day of June, 2006, I, Thomas D. Gould, Esquire, Attorney for Plaintiffs, Anjum & Tanveer Igatpuniwala, hereby certify that I have this day sent a copy of Plaintiff's Important Notice (10-day default) by depositing a copy of it in the United States mail, postage prepaid, addressed to: LISA A. COLWELL 1286 HUNTER'S RIDGE ROAD MECHANICSBURG, PA 17050 DATED J",,~ IIJ, 2oo{, --rIz-,_ ~ hww Thomas D. Gould, Esquire ID # 36508 2 E. Main Street Shiremanstown, PA 17011 (717) 731-1461 {~ c; .., (~,::) i::1 c.~ - W <;f. ~-e] fn 'F: ~\:j'2? ~~.;~ rj~:t, ".3-9\ (:-5," .- ~ -n. ::... - (".) -' , ANJUM and TANVEER IGATPURIW ALA, Plaintiffs v. LISA A. COLWELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 06-2531 CIVIL TERM ORDER OF COURT AND NOW, this 19th day of June, 2006, upon consideration of Plaintiffs' Application for Release of Escrow Rent Payments, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 5 days of service. .Ahomas D. Gould, Esq. 2 E . Main Street Shiremanstown, P A 170 II Attorney for Plaintiffs vCisa A. Colwell ~ 1286 Hunter's Ridge Road Mechanicsburg, P A 17050 Defendant, pro Se :rc BY THE COURT, w ,,(J ,ry OU -<:'/<n;] I 0 : II H'} I ?, Hnl~ 9UaZ , ~', "i\", "e,l, j "Hi .'n AQ}lv! ,~,'i t_,.",~"'~ -.-,:J _llo,.i 3~):!YJ-c:nl:l ,. . ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-2531 CIVIL TERM LISA COLWELL, DEFENDANT IN LANDLORD/TENANT MOTION TO MAKE RULE ABSOLUTE comes the plaintiffs, by and through their attorney D. Gould, and files this motion to make absolute this Hono Court's Rule Returnable based on the following: The plaintiffs filed an Application For The Release of Escr Payments on June 12, 2006, 2. On June 19, 2006 this Honorable Court issued an Order of Cour to show cause why the relief should not be granted. 3. The rule was returnable within 5 days of service, 4. The Order was served on the defendant on June 21, 2006, 4. Defendant has not filed a response, Wherefore, it is requested that this Honorable Court issue an r directing the Prothonotary to release $1,530.00 from the def escrow funds and authorize the continued release of monthly rent payments, def Respectfully submitted, DAT ~~ Af: :J,..fJ" t: ~~~~ Thomas D, Gould, Esquire ID # 36i508 2 E. Ma;in Street Shiremanstown, PA 17011 (717) 731-1461 (~'< (:;;,., c) ''1'1 ::;1 hr'j r'~) CO i' ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-2531 CIVIL TERM LISA A, COLWELL, DEFENDANT IN LANDLORD/TENANT PRAECIPE TO THE PROTHONOTARY: Please enter judgment against the defendant in the amount of $3,772,50, plus statutory interest, The defendant has failed to plead to the complaint filed on May 19, 2006 in the above referenced matter. I certify that, pursuant to Rule 237.1 (a) (2), the written notice designated by Rule 237.4 was mailed on June 10, 2006 to the defendant at the address listed on their district justice appeal. .['l~(..l.....n.... .L.....1'-..........<::.. t.L<::. [.....ud.s d<:..t-'..:-.....:.tea :Sy Gi@fGuJu.l!~ .~ ,t-'lctlllL":"[[v. D"'-r.o.nrL::ln+- i@ te S0 ~i~.-eFl oJ?eEiit. Lon. .L,,-1<:"316<.:'~ r"nr1~ ~n ri'"'r90it a~aiFJ.at tlx18 j"ggm~l:~rt;: 1'1' Respectfully, ~.b.~ Thomas D. Gould Attorney for Plaintiffs ID # 36508 2 E. Main Street Shiremanstown, PA 17011 (717) 731-1461 R;)~{~ " ~ ~~J ~ ~ ~<X;\ ~ ~ ~ \ ~ \ ~ - .... r< p'..<') c;.;;,) r':-:) eJ'" r'",) G,) ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-2531 CIVIL TERM LISA A. COLWELL, DEFENDANT IN LANDLORD/TENANT ORDER OF COURT AND NOW this sth day of , 2006, Applicants' (Plaintiffs') application for release of defendants' escrow rents of $1,530.00 i.s granted. The Prothonotary is directed to pay $1,530.00 from the defendant's escrow funds to plaintiffs. The Prothonotary, until further notice, is to pay future rent payments from the defendant directly to the plaintiff. BY THE COURT, J. Thomas D. Gould, Esquire 2 East main Street Shiremanstown, PA 17011 Attorney for Plaintiffs Lisa A. Colwell 1286 Hunter's Ridge Road Mechanicsburg, PA 17050 Defendant, pro Se ~ -;2:53 / \ c) .:; ! ! ,e':'> ~"~ ,;;;- \' \ -' -,...>) ~- v ..,P ,-") c.~..') c-, CARS"" au, ~OEUl~OO.~' ..0..00" OEl-W>'-iO co\'\POPoA-rlON ~o ~~ ~.:a-<;.> o,,1YI ,~:l.~ -t,.o ~(\l ~f 'i~ 0, o~ ...:) tr''''' \J.I .:. M.J =i-. - .. o U.l ... ...... ... en o U.l tr' - .. ... o I):l ... ... ~ -70 t ~ v'" I.' (') c: ~ at fII ~ "" ~i t>("l "= ..(. '-' Ql oJ o g- """'" tI)~ o o C) ...... (/) ~ '< ~a m"" "jli o ... o o .- .- )> '" <Jl 8fl$1V g 0 is ~c: ~ nC ~i~~~ ~n\i~> '} g"\~ ~gg 0 ~~!i g '6 ~%~ c .. <II 1ft o ~ m ~ ()\ ~ ~ ~ * ~ '" 8> =~-:;':'-' \ ' \ ~ al t.:l N . RECEIPT FOR TRANSFER -------------------- -------------------- Cumberland County Prothonotary's Office Carlisle, Pa 17013 IGATPURIWALA ANJUM 1115 CARRIGNTON COURT E MECHANICSBURG, PA 17050 Case Number 2006-02531 Remarks PER ORDER OF COURT DATED 07-05-06 RKS Receipt Date Receipt Time Receipt No. 07/07/2006 14:42:03 180037 Transaction ---------------------- Distribution Of Adjustment ---------------------______ RENT RENT RENT RENT Payee PROTHONOTARY ESCROW PROTHONOTARY ESCROW PROTHONOTARY ESCROW IGATPURIWALA ANJUM & TANVEER This Adj 1,485.50- 1,485.50 1,530.00- 1,530,00 14433807072006 PYS405 Cumberland County Prothonotary's Office Manual Release Check Reglster Distribution Case No Accounting 3894 RENT IGATPURIWALA ANJUM & TANVEER Check Date: 2006- 02531 TRNS ESC IN Payee total: Grand total: Escrow Amount 07/07/2006 1530.00 1530.00 1,530.00 Tran Date Check No, : 7/07/2006 Paqe 1 7/07/2006 Date Release 1632 RECEIPT FOR TRANSFER =============~====== Cumberland County Prothonotary's Office Carlisle, Pa 17013 IGATPURIWALA ANJUM 1115 CARRIGNTON COURT E MECHANICSBURG, PA 17050 Case Number 2006-02531 Remarks PER ORDER OF COURT DATED 07-05-06 RKS Receipt Date Receipt Time Receipt No. 07/07/2006 14:42:03 180037 Transaction ---------------------- Distribution Of Adjustment --------------------------- RENT RENT RENT RENT Payee PROTHONOTARY ESCROW PROTHONOTARY ESCROW PROTHONOTARY ESCROW IGATPURIWALA ANJUM & TANVEER This Adj 1,485,50- 1,485,50 1,530.00- 1,530,00 ~. , .-r- ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS v. LISA A. COLWELL, DEFENDANT PC'Ei\!(:'.]. IU~I I) 9 <'.'.'.'6 . \ 1_ 'oJ. _ ,_ ... t '. 1'.."t :J ,'.'~" IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2531 CIVIL TERM IN LANDLORD/TENANT ORDER OF COURT AND NOW this --S-tL- day of J., I r--' 2006, Applicants' (Plaintiffs') application for release of defendants' escrow rents of $1,530.00 is granted. The Prothonotary is directed to pay $1,530.00 from the defendant's escrow funds to plaintiffs. The Prothonotary, until further notice, is to pay future rent payments from the defendant directly to the plaintiff. ~homas D. Gould, Esquire 2 East main Street Shiremanstown, PA 17011 Attorney for Plaintiffs ~isa A. Colwell ~ 1286 Hunter's Ridge Road Mechanicsburg, PA 17050 Defendant, pro Se BY THE COURT, J. "'1, .., " S2 : 1/ ~111 S - SQUZ Ai:f/.LC!;\.iC, 3CJL.l/1~). .~i'.il O::lij ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-2531 CIVIL TERM LISA A. COLWELL, DEFENDANT IN LANDLORD/TENANT APPLICATION FOR RELEASE OF ESCROW FUNDS AND NOW, comes the plaintiffs, by and through their attorney Thomas D. Gould, and files this application to obtain escrow funds based on the following: 1. The plaintiffs are the owner of the premises located at 1286 Hunter's Ridge Drive, Mechanicsburg, Pennsylvania. 2. Defendant was the tenant of the premises at 1286 Hunter's Ridge Drive, Mechanicsburg, Pennsylvania. 3. Magisterial District Judice Placey issued a Judgment on April 25, 2006, against the defendant. 4. Defendant filed a Notice of Appeal and paid a total of $3,015.50 into escrow at the Prothonotary. 5. Plaintiffs filed their complaint on May 19, 2006. 6. Defendant did not file any defenses or objections to the claims. 7. Plaintiffs served defendant with a 10-day notice on June 10, 2006. . .. 8. Defendant did not respond to the 10-day notice. 9. On June 28, 2006 plaintiffs filed a Praecipe entering a default judgment against defendant in the amount of $3,772.50. A copy of the Praecipe is attached as exhibit A. 10. Pursuant to this Honorable Court's July 5, 2006 Order the Prothonotary paid $ 1,530.00 from the defendant's escrow account to plaintiffs for escrow rent for May and June. A copy of the Court Order is attached as exhibit B. 11. The defendant's $1,530.00 escrow post appeal rent payments are credited against plaintiff's $3,772.50 judgment, leaving a judgment balance of $2,242.50. 12. The Prothonotary has $ 1,485.00 remaining in defendant's escrow account. WHEREFORE, it is requested that this honorable court direct the Prothonotary to pay the remaining balance in defendant's escrow account ($1,485.50) to the plaintiffs and that those payments be credited against the judgment leaving a judgment balance of $757.00. Respectfully submitted, DATE j ~ La', ').0 0 , -JL~i>. ~ Thomas D. Gould, Esquire 10 # 36508 2 E. Main Street Shiremanstown, PA 17011 (717) 731-1461 , ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-2531 CIVIL TERM LISA A. COLWELL, DEFENDANT IN LANDLORD /TENANT C t--_~ c...." :=,1 -:".:," , li-:--:".:: CO"" PRAECIPE TO THE PROTHONOTARY: Please enter judgment against the defendant in the amount of $3,772.50, plus statutory interest. The defendant has failed to plead to the complaint filed on May 19, 2006 in the above referenced matter. I certify that, pursuant to Rule 237.1(a) (2), the written notice designated by Rule 237.4 was mailed on June 10, 2006 to the defendant at the address listed on their district justice appeal. PlcJGC rolg~~~ tho fund3 dC~V0~LcJ b~ d~fcnd3Qi to ~laLltiff'" npfpnrl;:mt i c: rr> 'h~ gi HO" r'r~di t for PJlc.:H:od fll"r1<;: on depo:Jit ugain:Jt the j'lQ']mpnt Tb' Respectfully, ~j).~ Thomas D. Gould Attorney for Plaintiffs ID # 36508 2 E. Main Street Shiremanstown, PA 17011 (717) 731-1461 EXHIBIT A " ~ ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO_ 06-2531 CIVIL TERM LISA A. COLWELL, DEFENDANT IN LANDLORD/TENANT ORDER OF COURT AND NOW this sth day of , 2006, Applicants' (Plaintiffs') application for release defendants' escrow rents of $1,530.00 is granted. The Prothonotary lS directed to pay $1,530.00 from the defendant's escrow funds to plaintiffs. The Prothonotary, until further notice, is to pay future rent payments from the defendant directly to the plaintiff. BY THE COURT, J' . Thomas D. Gould, Esquire 2 East main Street Shiremanstown, PA 17011 Attorney for Plaintiffs Lisa A. Colwell 1286 Hunter's Ridge Road Mechanicsburg, PA 17050 Defendant, pro Se EXHIBIT B , -, I :~=, ~,~-:) ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO, 06-2531 CIVIL TERM LISA A. COLWELL, DEFENDANT IN LANDLORD/TENANT CERTIFICATE OF SERVICE AND NOW, this I~~ day of July, 2006, I, Thomas D. Gould, Esquire, Attorney for Plaintiffs, Anjum & Tanveer Igatpuniwala, hereby certify that I have this day sent a copy of Plaintiff's Application For Release of Escrow Funds by depositing a copy of it in the United States mail, postage prepaid, addressed to: LISA A, COLWELL 1286 HUNTER'S RIDGE ROAD MECHANICSBURG, PA 17050 DATED ~4 I ,( 2.~(), ~gl.~ Thomas D, Gould, Esquire ID # 36508 2 E. Main Street Shiremanstown, PA 17011 (717) 731-1461 ::i~ ,-.-1 VJ c~ " . . ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS v. LISA A. COLWELL, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2531 CIVIL TERM IN LANDLORD/TENANT ORDER OF COURT AND NOW this ,tl L ~ day of -2u , , 2006, upon review of Petitioner/Plaintiff's Application For release of Escrow Funds, a Rule issued upon Respondent/Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within ~OMAS D. GOULD, ESQUIRE 2 EAST MAIN STREET SHIREMANSTOWN, PA 17011 ~SA A. COLWELL ~ 1286 HUNTER'S RIDGE ROAD MECHANICSBURG, PA 17050 b days of service. BY THE COURT \)\0 ~ <\'~ \) f ;-' : r I .~' I t~; "'" "--" ..i ,~, .. ," . : ''''')'''1 'v J' .. ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-2531 CIVIL TERM LISA A. COLWELL, DEFENDANT IN LANDLORD/TENANT MOTION TO MAKE RULE ABSOLUTE AND NOW, comes the plaintiffs, by and through their attorney Thomas D. Gould, and files this motion to make absolute this Honorable Court's Rule Returnable based on the following: 1. The plaintiffs filed an Application For Release of Escrow Funds on July 19, 2006. 2. On July 25, 2006 this Honorable Court issued an Order of Court to show cause why the relief should not be granted. 3. The rule was returnable within 5 days of service. 4. The Order was served on the defendant on July 27, 2006. 4. Defendant has not filed a response. Wherefore, it is requested that this Honorable Court issue an order directing the Prothonotary to release the remaining balance, $1,485.00, from the defendant's escrow funds to the plaintiffs and that those funds be credited against the plaintiff's judgment. Respectfully submitted, DATE iI~....i- 101 ,,-'f} , ~IIW D. L1~ Thomas D. Gould, Esquire ID # 36508 2 E. Main Street Shiremanstown, PA 17011 (717) 731-1461 . JUL 2 02006rn ~ ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-2531 CIVIL TERM LISA A. COLWELL, DEFENDANT IN LANDLORD/TENANT ORDER OF COURT AND NOW this l11h day of , 2006, upon reVlew of petitioner/Plaintiff1s Application release of Escrow Funds, a Rule issued upon Respondent/Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within ~ days of serVlce. BY THE COURT d, THOMAS D. GOULD, ESQUIRE 2 EAST MAIN STREET SHIREMANSTOWN, PA 17011 LISA A. COLWELL 1286 HUNTER'S RIDGE ROAD MECHANICSBURG, PA 17050 ., . .;~ .-'" ."""Jl, L~'__I"~ . ~ J g ,....., ~ c:::;t c:::;t 3: CJ"'O :JlIlo :r!:1) -0 frJ c:: ~!r G"') mFT; z~: ~~ (J) _ ~.' c ~el K ;po :I:,i i0 ::E ~~ 0 c: '!? ~ ~ w ~ ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 06-2531 CrvIL TERM LISA A. COLWELL, DEFENDANT IN LANDLORD/TENANT CERTIFICATE OF SERVICE f1. AND NOW, this ~ day of August, 2006, I, Thomas D, Gould, Esquire, Attorney for Plaintiffs, Anjum & Tanveer Igatpuniwala, hereby certify that I have this day sent a copy of Plaintiff's Motion to Make Rule Absolute by depositing a copy of it in the United States mail, postage prepaid, addressed to: LISA A. COLWELL 1286 HUNTER'S RIDGE ROAD MECHANICSBURG, PA 17050 DATED A"1uJrl/J( '2..6d~ ~_1).~ Thomas D. Gould, Esquire ID # 36508 2 E, Main Street Shiremanstown, PA 17011 (717) 731-1461 ~\\ ~~, iL,Ci ZC ~\.-; re ~ ~ ~ ~ e;; - o ~ ,.p .' ..., - ~ ~~ ~~ "" -<, ...,.. -n ~w. ~ ~ ( ...'" RECEIVED AUG 1 1 2006 /Iv ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CtlMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-2531 CIVIL TERM LISA A. COLWELL, DEFENDANT IN LANDLORD/TENANT ORDER OF COURT AND NOW, this ~ day of ~ '"0 , 2006, the Plaintiffs' Application For Release of Escrow Funds is granted. The Prothonotary is directed to pay $1,485.00 from the Defendant's escrow account to Plaintiffs. The $1,485.00 paid is to be credited against the plaintiff's judgment against the defendant. By the Court THOMAS D. GOULD, ESQUIRE 2 EAST MAIN STREET SHIREMANSTOWN, PA 17011 g-{~-()~ ~ ~ ~ LISA A. COLWELL 1286 HUNTER'S RIDGE ROAD MECHANICSBURG, PA 17050 .. , , \fINlfi\1)"8NN3d AlNnCy, ryrVlli3\]V'Jn:) 2 I : II WV 91 5nV 9UOZ AtN.lOI'iOHlOOd 3Hl :10 381:lj0-{]3lI:! ocC,,-~3{ ~ J~ o~ o I I & '8 [l] 8 .\!l [~ .~ <(~ U CUMBERLAND COUNTY OFFICE OF THE PROTHONOTARY ESCROW ACCOUNT CUMBERLAND COUNTY COURT HOUSE CARUSLE, PA 17013 PAY TOTHE ORDER OF Anjum & 'I'Ufi'l.~r Igatpuri~".:lla CUM8ERLa,.&o CO. I 1185dol'~I:O,.ts PROTHONOTARY J~ w~ ~ ~ 0RRsr0wN PANK 06-2531 Igatpuriwala vs Colwell II' 0 0 ~ b ... b II' I: 0 3 ~ 3 ~ SO 3 b I: ~ 0 8 16. DOLLARS 1"-0.) = = en o Cj --l I <Jl o -n ~...., f'n F" --r-:rri ~tio ~~ ~:~~;-: ~~f~ s;! :D -< v ~~ (...) (2 ~." c:.: ;+.:t~.- . l"-':> c..? c.."""'.::l C' o c--) --''i I Vi -0 C->>) I' .. '.. RECEIVED AUG 1 1 2006 Ay ANJUM & TANVEER IGATPURIWALA, PLAINTIFFS IN THE COURT OF COMMON PLEAS CtJMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-2531 CIVIL TERM LISA A. COLWELL, DEFENDANT IN LANDLORD/TENANT ORDER OF COURT AND NOW, this ~ day of ~ "~ , 2006, the Plaintiffs' Application For Release of Escrow Funds is ~anted. The Prothonotary is directed to pay $1,485.00 from the Defendant's escrow account to Plaintiffs. The $1,485.00 paid is to be credited against the plaintiff's judgment against the defendant. By the Court THOMAS D. GOULD, ESQUIRE 2 EAST MAIN STREET SHIREMANSTOWN, PA 17011 g-{(p-Of; ~ ~ ~ LISA A. COLWELL 1286 HUNTER'S RIDGE ROAD MECHANICSBURG, PA 17050 10140710052006 PYS405 Distribution Cumberland County Prothonotary's Office Manual Release Check Reglster Escrow Amount Case No Accounting Tran Date Page 1 10/05/2006 Date Release RENT 3894 IGATPURIWALA ANJUM & TANVEER Check Date: 10/05/2006 Check No.: 1649 2006- 02531 TRNS ESC IN Payee total: 1485.50 1485.50 Grand total: 1,485.50 7/07/2006