HomeMy WebLinkAbout02-2294
RICHARD H. SWARTZ and
JOHN D. B1TNER, JR.,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V AN1A
v.
~,~
: NO.2002- :,l:;l.q<f
HARRY RINEHART and JOANN
RINEHART,
Defendants
C1VIL ACT10N - LAW
NOT1CE
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 a court your
defenses or objections to the claims set forth against you. You are warned that if you fail to do
so the case may proceed without you and a judgment may be entered against you by the Court
without further notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER 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
(717) 249-3166
SNELBAKER, BRENNEMAN & SPARE, P. C.
rtf11t~
By:
Attorneys for Plaintiff
LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
"'--_._~"------.
RICHARD H. SWARTZ and
JOHN D. BITNER, JR.,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V AN1A
v.
NO. 2002- .;l;l. "71.{
HARRY RINEHART and JOANN
RINEHART,
Defendants
CIVIL ACTION - LA W
COMPLAINT
Plaintiff Richard H. Swartz and John D. Bitner, Jr., by their attorneys Snelbaker,
Brenneman & Spare, P. C. file this Complaint against the Defendants and in support thereof state
the following:
I. Plaintiff Richard H. Swartz is an adult individual residing at 1832 Sterretts Gap
Avenue, Carlisle, Pennsylvania.
2. Plaintiff John D. Bitner, Jr. is an adult individual residing at 21 Ridgeway Drive,
Carlisle, Pennsylvania.
3. Defendants Harry Rinehart and Joann Rinehart, husband and wife, are adult
individuals residing at 3 Timber Lane, Mount Holly Springs, Pennsylvania.
4. Plaintiffs are the owners of a certain parcel of land in the Borough of Mount Holly
Springs commonly known as 421 N. Baltimore Avenue, Mount Holly Springs, which parcel is
improved with a commercial restaurant structure (hereinafter the "Premises").
5. On or about August 1, 2000 Plaintiffs and Defendants entered into a written
Commercial Lease whereby Defendants agreed to lease the Premises from Plaintiffs in
LAW OFFICES
SNEL.BAKER.
BRENNEMAN
& SPARE
accordance with the terms and provisions therein. A true and correct copy of the parties'
Commercial Lease (the "Lease") is attached hereto and incorporated by reference as "Exhibit A".
6. 1n or about July 200 I, Plaintiffs and Defendants agreed to extend the Lease for an
additional term of one year by initialing changes to the Lease noting it extension for another
year.
7. Pursuant to the terms of the Lease specifically Paragraph 2 thereof, Defendants were
to pay monthly rent in the amount of $1 ,000.00 to Plaintiffs on or before the first day of each
month.
8. Pursuant to the terms of the Lease, specifically Paragraph 3 thereof, Defendants were
responsible for maintaining the Premises in good condition, including any equipment on the
Premises, and were further responsible for all repairs requires.
9. Pursuant to the terms of the Lease, specifically Paragraph 7 thereof, Defendants were
solely liable for utility charges, including sewer and water utility charges.
10. Pursuant to the terms of the Lease, specifically Paragraph 15 and 16, Defendants
were responsible for paying real estate taxes assessed on the Premises during the Lease term.
II. Defendants occupied the Premises from August I, 2000 to March 1, 2002, at which
time the restaurant was vacated by Defendants.
12. Defendants materially breached the parties' Lease in following particulars:
a. By failing to pay rent for the months of November and December, 2001
and April 2002;
b. By failing to pay water and sewer charges assessed against the Premises
during the period of Defendant's occupancy and/or term of the Lease;
LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
c.
By failing to party in full real estate taxes assessed against the Premises
during the period of Defendants' occupancy and/or term of the Lease; and
-2-
d. By failing to maintain and repair the Premises.
13. As a direct, factual and proximate result of the material breaches by Defendants of
their obligations under the Lease, Plaintiffs have sustained the following losses and damages and
are owed the following amounts by Defendants:
a. Rent for the months of November and December 2001
and April 2002 and the balance of the lease term
(less $1,000 security deposit applied) together with
late fees in accordance with Lease Paragraph 1:
$5,670.00
b. Balance owed on 2001 real estate taxes and 2002 taxes:
2,489.87
c. Unpaid water and sewer charges:
348.00
d. Costs ofrepair for roof:
2,000.00
e. Plaintiffs attorney's fees incurred to the filing of this
Complaint pursuant to Paragraph 18 of the Lease:
250.00
14. Defendants have failed and refused to pay the amounts set forth in Paragraph 13, a.,
b. and c. after demand to do so.
15. All conditions precedent necessary for Plaintiffs to bring this action have taken place.
WHEREFORE, Plaintiffs demand judgment of Defendants, jointly and severally, in the
amount of$10,757.87, together with any additional attorney's fees incurred in this action, interest
and costs of this action.
The amount claimed by Plaintiffs herein does not exceed the jurisdictional amount for
LAW OFFICES
SNELBAKER.
BRENNEMAN
8c SPARE
-3-
LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
mandatory arbitration in Cumberland County.
SNELBAKER, BRENNEMAN & SPARE, P. C.
Date: May 3, 2002
BY:_~
Keith O. Brenneman, Esquire
44 W. Main Street
Mechanicsburg, P A 17055
(717) 697-8528
Attorneys for Plaintiffs
Richard H. Swartz and John D. Bitner, Jr.
-4-
L.AW OFFICES
SNEL.BAKER.
BRENNEMAN
& SPARE
VER1FICA TlON
I verify that the statements made in the foregoing Complaint are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4909 relating to unsworn falsification to authorities.
Date: M~ 3, ;)CO~
LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
VER1FICA nON
I verify that the statements made in the foregoing Complaint are true and correct. 1
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4909 relating to unsworn falsification to authorities.
Date: May 3. 2002
&-dE~~
~, ,,~
01
ff.:3 ~ ~ jt(q';/.JlL
___ /70 ;;;:r
tjy(P - '--If; 7'>
COMMERCIAL LEASE
Form A140 Commercial Lease
This lease is made between Richard Swartz ''''3).
$"r~......c.rr.s (,~J> t1v/;:
, herein calfed Lessor.
arxI Jolm Bitner
Harry and Joann Rinehart
. herein called Lessee.
C.~/I~~
P~/?#/3
Lessee hereby offcrs La lease from Lessor lhe premises situated in Lhe City of Mt .Holly sprin~S' 1.4
,Countyof Cumberland ,Slaleof PA ,described.. Ii' 0
421 North Baltimore street . upon the following TERMS and CONDITIONS: .' \l:9 1/ 'l
1. Term and Rent. Lessor demises the above premises for ~ le!", of . one. yearsr R/I~ 'tAr.:
commencing August 1, 2000 ... and termmaung on August 31 . 2001 r""- T .II
orsoonerasprovidedhereinallheannualrcnlalof 71.,'.. t-J.I'e Is ~'';'~dlll!!.:; ';"...J.14 "TA er e.J."'-
Dollars ($ 1,000.00 ) . payable in equal installments in advance on the fllSt
day of each month for that month's rental, during the lerm of this lease. All rental payments shall be made to If)l"
Lessor, at die address specified above. 'f: or ~
If not paid on due date there will be a '/0.00 .p",,,, D4.Y J..l4f'e Ft:!.<::-
r. lIse.- Lessee sJlaU-use and occupy the premiseS for Restaurant or any otJ{er use 0 ()
bv law . The premises shall be used for no other purpose. !:eSsor represents that the .J. f. II, r-
ptemlses may lawfully be used for such purpose. r ~. C1i'
3. Care and Maintenance of Premises.
Lessee shall, at his own expense and at all times. mainlain the
premises in good and safe condition, including plate glass, electrical wiring, plumbing and he-aling
installations and any oilier system or equipment upon the prelDises and shall surrender the same, at
termination hcreof...in as good condilion as received. normal wear and tear excepted. Lessee shall be
responsible for all repairs required, .
~
~ Lessee shall also maintain in good condition such portions adjacent to the
premises. such as sidewalks, driveways, lawns and shrubbery, which would otherwise be required 10 be
maintained by Lessor.
4. Alterations. Lessee may without first oblaining the wriucn consent of Lessor. make any
alterations, additions, or improvements, in, to or about the premises.
5 . Ordinances and Statutes. Lessee shall compJy with all Slatutes, ordinances and requirements of
all municipal, slale and federal authorities now in foree, or which may hereafter be in foree. pertaining to the
premises, occasioned by or affecting the use thereof by Lessee.
6. Assignment and Subletting. Lessee shall not assign this lease or sublet any portion of the
premises without prior wriuen consent of the Lessor, which shall not be unreasonably withheld. Any such
assignment or subletting without consent shall be void and, at the option of the Lessor, may terminate this
lease.
7. Utilities. All applications and connections for necessary utility services on the demised premises
shall be made in the name of Lessee only, and Lessee shall be solely liable for utility charges as they become
due, including those Cor sewer, water, gas, elccUicity, .and telephone ~ices.
8 . Entry and Inspection. Lessee shall permit Lessor or Lessor's agents to enter upon the premises at
reasonable times and upon reasonable notice, for the purpose oC inspecting the same, and will pennit Lessor at
any time within sixty (60) days prior to the expiration of this lease, to place upon the premises any usual "To
Let" or "For Lease" signs, and permit persons desiring to lease the same to inspect the premises thereafter.
9 . Possession. If Lessor is unable to deliver possession of the premises at the commencement hereof,
Lessor shall not be liabJe for any damage caused thereby, nor shall this lease be void or voidable. but Lessee
shall not be liabJe for any rent until possession is delivered. Lessee may terminate this lease if possession is
not delivered within fifteen days of Ihe commencement of the term hereof.
10. Indemnification of Lessor. Lessor shall not be liable Cor any damage or injury to Lessee, or any
other person, or to any property, occurring on the demised premises or any part thereof. and Lessee agrees to
hold Lessor harmless from any claims for damages, no matter how caused.
11. Insurance. Lessee, at his expense, shall maintain plate glass and public liability insurance including
bodily injury and property damage insuring Lessee and Lessor with minimum covemge as follows:
Lessee shall provide Lessor with a Certificate of Insurance showing Lessor as additional insured. The
Certificate shall provide for a len-day written notice to Lessor in the event of cancellation or material change'
of coverage. To the maximum extent permitted by insurance policies which may be owned by Lessor or
Lessee. Lessee and Lessor, for the benefit of eacb other, waive any and all rights of subrogation which might
otherwise exisL
Iesseehls tIE sole O!tim to pm:f-ese tile p:q:erty at aq( tme dJi::lrq 1:12 r..... _
fir a pm:f-ese p::\a! of $175,000.00, eitla: I:ri sb:alglt sale, cr _ A".,=..L. _
Jy....,..L>mld <DEist of Qa!r's firfn:::irq fir $20,000.00 cb.n at ~ ~ with P'Y off
.millUlr amaiilim at 15 ~~~:: 71.
'"'
IE:ElE
12. Eminent Domain. If the premises or any part thereof or any estate therein, or any other part of tho
building materially affecting Lessee's use of the premises, shall be laken by eminent domain, lhis lease shall
tenninatc all the date when title vests pursLWnl (Q such taking. 111e rent, and any addilional rent. shall be
apportioned as of 11m tcnnination date. and any rent paid for any period beyond lhat date shall be repaid (Q
Lessee, Lessee shall not be entilled to any parl of the award for such taking or any payment in lieu thereof,
but Lessee may file a claim for any taking of fixlures and improvements owned by Lessee, and for moving
ex pcnscs.
Destruction ur Premises. In the event of a partial destruction of the premises during the
hereof, r cause, Lessor shall forthwith repair the smoe, provided that such repairs can be within
sixty (60) days isting govemmenlallaws and regulations, but such partial ction shall not
terminate this lease. except see shall be entiLled to a proportionate redu' rent while such repairs
are being made, based upon the exten ich the making of such . II interfere with the business of
Lessee on lhe premises. If such repairs cann ade wi' d sixly (60) days. Lessor, at his option,
may make the same within a reasonable time, this 'nuing in effect wilh the rent proportionaLCly
abated as aforesaid. and in the event that L I not elect such repairs which cannot be made
within sixty (60) days, this lease tenninated at the option of el . In the event that the
building in which the demi emiscs may be situated is destroyed to an exlcnt 0 n than one-third of
the replacement c. ercof. Lessor may elect 10 terminate this lease whether the demise lises be
injured or total destruction of the building in which the premises may be situated shall terminat
I . ..
14, Lessor's Remedies on Default. If Lessee defaults in the payment of rent, or any additional rent,
or defaults in the perfonnancc of any of the other covenants or conditions hereof, Lessor may give Lessee
notice of such default and if Lessee does not cure any such default within FIFrEEN days. after the
giving of such notice (or if such other default is of such nature that it cannot'be completely cured within such
period, if Lessee does not commence such curing within. such THIRTY days and thereafter proceed
with reasonable diligence and in good faith to cure such default), then Lessor may terminate this lease on not
less than TEN days' notice to Lessee. On the date specified in such notice the term of this lease
shall terminate. and Lessee shall then quit and surrender the premises to Lessor, but Lessee shall remain liable
as hereinafter provided. If this lease shall have been so tenninated by Lessor, Lessor may at any time
thereafter resume possession of the premises by any lawful means and remove Lessee or other occupants arid
their effects. No failure to enforce any term shall be deemed a wai)'er.
iMe~d~~o~ ~l: deposit with Lessor all the signing of this lease the sum of
$2,000.00 plus tax prorated both school and PI'Op<!!rty Dollars
($ ) as security for the perfonnance of Lesscc's obJigations under this lease. including
without limitation the surrender of possession Of the premises 10 Lessor as herein provided, If Lessor applies
any part of Ule deposit to cure any dcfaulL of Lessee, Lessee shall on demand deposit with Lessor the amount
so applied so that Lessor shall have the full dePOSil on hand at all times during the term of this lease,
16. Tax Increase. In the event there is any increase during any year of the term of this lease in the City,
CounlY or Slate real eSlale taxes over and above the amount of such taxes assessed for the lax year during
which Lbe tem1 of this lease commences, whether because of increased rate or valuation, Lessee shall pay to
Lessor upon presentation of paid tax bills an amount equal to 100 % of the increase in taxes upon the
land and building in which the leased premises are situated. In the event that such taxes are assessed for a tax
year extending beyond the tenn of the lease, the obligation of Lessee shall be proportionate to the ponion of
the lease term included in such year.
17. Common Area Expenses. In the event the demised premises are situated in a shopping eenler or
in a commercial building in which there are common areas, Lessee agrees to pay his pro-rata share of
maintenance, taxes. and insurance for the common area.
18. Attorlley's Fees. In case suit should be brought for recovery of the premises, or for any sum due
hereunder, or because of any act which may arise out of the possession of the premises, by either party, the
prevailing parlY shall be entitled to all costs incurred in connection with such aClion, including a reasonable
anomey's fee.
19. Notices, Any notice which either party mayor is required to give, shall be given by mailing the
same, poSlage prepaid. to Lessee at the premises, or Lessor at the address shown below, or at such other
places as may be designated by the parties from time 10 time.
20. Heirs, Assigns, Successors. This lease is binding upon and inures to the benefit of the heirs,
assigns and successors in interest to the parties.
21. Option to Renew. Provided thal Lessee is not in default in the perfonnance of this lease. Lessee
shall have the option to renew the lease for an additional term of 'lWELVE months commencing at the
expiration of Lhe initial lease term. All of the terms and conditions of the l~shall apply during the renewal
term except Lhat the monthly rcntshall be the sum of$ 1 ,QOO.OO ;HtI~ . The option shall be
exercised by wriuen notice given 10 Lessor not less than THIRTY days prior (0 the expiration of the
initial lease term. If notice is not given in the manner provided herein within the time specified, this option
shall expire.
22. Subordination. This lease is and shall be subordinated to all existing and future liens and
encumbrances against the propeny. '
2 J. Entire Agreement. The foregoing constitutes the entire agreement between the parties and may be
modifJCd only by a writing signed by both parties. The following Exhibits. if any. bavt' been DUde a part of
."thi.$ lcase before I,he. p8f1i~. excc~tion hereof:
Signed Lhis 1 st 2000,
I' ~.,~
')
By
Lesso,
c. E.Z Legal Forms
. ,
(") 0 0
'tl c N ""
-oft: .,..
~ ~ ~ qJh- ::;".
~ L-:-j, -<
~ 0~~" I
Ir1 '.0
t r::.: ~-,~
C> ~{~ T"-'"
- ---.
cs- ~ 9?
)..> c z.
~ l)l ~ ....J
r-::-, .
~ fJ- \9
~
~
SHERIFF'S RETURN - REGULAR
~(SE NO: 2002-02294 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SWARTZ RICHARD H
VS
RINEHART HARRY ET AL
CPL. MICHAEL BARRICK
Cumberland county,pennsylvania, who being duly sworn according to law,
, Sheriff or Deputy Sheriff of
says, the within COMPLAINT & NOTICE
was served upon
the
RINEHART HARRY
DEFENDANT
, at 1311:00 HOURS, on the ~ day of May
at 3 TIMBER LANE
,~
MT HOLLY SPRINGS, PA 17065
by handing to
HARRY RINEHART
together with
a true and attested copy of COMPLAINT & NOTICE
and at the same time directing ~ attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
.r-~~"~~
R. Thomas Kline
18.00
4.83
.00
10.00
.00
32.83
Sworn and Subscribed to before By:
me this 3,...,A day of
(}w _ J.oo. ;; / A. D .
'().tL () ~_J#,.,,~
rothonotary
SHERIFF'S RETURN - REGULAR
CASE NO: 2002-02294 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SWARTZ RICHARD H
VS
RINEHART HARRY ET AL
CPL. MICHAEL BARRICK
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
RINEHART JOANN
the
DEFENDANT
, at 1311:00 HOURS, on the 13th day of May
at 3 TIMBER LANE
2002
MT HOLLY SPRINGS, PA 17065
by handing to
HARRY RINEHART
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
.00
.00
10.00
.00
16.00
r-~~
R. Thomas Kline
05/14/2002
SNELBAKER BRENNEMAN SPARE
Sworn and Subscribed to before By:
me this 6.1-d day of
q,'Q ~~. AD
__ a ~tt.,. ~
P ~onotary ,
LAW OFFICES
SNELBAKER.
BRENNEMAN
8: SPARE
.
R1CHARD H. SWARTZ and
JOHN D. BITNER, JR.,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2002-2294 Civil Term
HARRY RINEHART and JOANN
RINEHART,
C1VIL ACT10N - LAW
Defendants
PRAECIPE FOR JUDGMENT UPON DEFAULT
PURSUANT TO Pa.R.C.P. 1037(b)
TO THE PROTHONOTARY:
Please enter judgment against Defendants Harry Rinehart and Joann Rinehart and in
favor of Plaintiffs Richard H. Swartz and John D. Bitner, Jr. in the amount of$10,757.87,
together with interest, attorney's fees and costs of this action due to Defendants' failure to file
within the required time a pleading to the Complaint in this action. A certified copy of the
Complaint containing a Notice to Defend was served upon each Defendant on May 13,2002.
I hereby certify that written notice of intention to file this Praecipe was mailed to the
Defendants (the parties against whom judgment is to be entered) for failure to plead to the
Complaint and at least ten days prior to the date of the filing of this Praecipe. A copy of the
written notice mailed to the Defendants on June 11, 2002 is attached hereto and incorporated by
reference herein as "Exhibit A".
SNELBAKER, BRENNEMAN & SPARE, P. C.
Date: June 25, 2002
By:_i~/~
Keith O. Brenneman, Esquire
44 W. Main Street
Mechanicsburg, P A 17055
(717) 697-8528
Attorneys for Plaintiffs
Richard H. Swartz and John D. Bitner, Jr.
LAW OFFICES
SNELBAKER.
BRENNEMAN
8: SPARE
CERTIFICATE OF SERVICE
1, KElTH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date,
caused a true and correct copy of the foregoing Praecipe to be served upon the person and in the
manner indicated below:
FIRST CLASS MAIL. POSTAGE PREPAID. ADDRESSED AS FOLLOWS:
Harry Rinehart
Joann Rinehart
3 Timber Lane
Mount Holly Springs, P A 17065
Vlff1~
Keith O. Brenneman, Esquire
SNELBAKER, BRENNEMAN & SPARE, P. C.
44 W. Main Street
P. O. Box 318
Mechanicsburg, P A 17055
(717) 697-8528
Attorneys for Plaintiffs
Date: June 25, 2002
RICHARD H. SWARTZ and
JOHN D. BITNER, JR.,
Plaintiffs
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL V AN1A
v.
: NO. 2002-2294 Civil Term
HARRY RINEHART and JOANN
RINEHART,
Defendants
: CIVIL ACTION - LAW
TO: Harry Rinehart
Joann Rinehart
3 Timber Lane
Mount Holly Springs, P A 17065
Date of Notice: June 11,2002
IMPORT ANT NOTICE
YOU ARE IN DEF AUL T 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 DAYS FROM THE DATE OF THIS NOT1CE, A
JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE
THIS NOTICE TO A LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND
OUT WHERE YOU CAN GET LEGAL HELP:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
SNELBAKER, BRENNEMAN & SPARE, P. C.
tJ~
LAW OFFICES
SNELBAKER.
BRENNEMAN
8: SPARE
By:
Keith O. Brenneman, Esquire
44 W. Main Street
Mecharilcsburg,PA 17055
(717) 697-8528
Attorneys for Plaintiffs
Richard H. Swartz and John D. Bitner, Jr.
EXHIBIT A
LAW OFPlCES
SNELElAKER.
BRENNEMAN
Be SPARE
CERTIFICATE OF SERVICE
I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date,
caused a true and correct copy of the foregoing Important Notice to be served upon the person
and in the manner indicated below:
FIRST CLASS MAIL. POSTAGE PREPAID. ADDRESSED AS FOLLOWS:
Harry Rinehart
Joann Rinehart
3 Timber Lane
Mount Holly Springs, P A 17065
Date: June 11,2002
-{~~
Keith O. Brenneman, Esquire
SNELBAKER, BRENNEMAN & SPARE, P. C.
44 W. Main Street
P. O. Box 318
Mechanicsburg, P A 17055
(717) 697-8528
Attorneys for Plaintiffs
..
() r=-,
C {''';
~ ~ -r J~:: c
~ ,.g" ,'::---=:
_..;>[i "-
'""__ _i.
2'r: t'", ".,
(;) '.
'\. ~ -<;, (<
~ 1:: Li
5f;": .,., ,
~ Z() ~-.- - .,."
J-';
i:Y _j;: C:; ~-,;;'.( j
. c: w i~_~:; rn
~ ~ 2: ~-~
~ :< f_- :0
.J:-
~ -<
~
LAW OFFICES
SNELBAKER &
BRENNEMAN, P.C.
RICHARD H. SWARTZ and
JOHN D. BITNER, JR.,
Plaintiffs
v.
HARRY RINEHART and JOANN
RINEHART,
Defendants
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2002-2294 CIVIL TERM
CIVIL ACTION - LAW
PRAECIPE
Please mark the judgment entered in the above-captioned matter satisfied upon your
docket and indices.
Date: March 3, 2006
SNELBAKER & BRENNEMAN, P. C.
By:l~
Keith O. Brenneman, Esquire
44 W. Main Street
Mechanicsburg, PA 17055
(717) 697-8528
Attorneys for Plaintiffs
,--