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Home My WebLink About94-01142 -Y l.. S c d G: ~' ~~ L Q) C ~ j j COMMONWIALTH 0' PINNSYLYANIA COUll 0' COMMON PUAS NOTICE OF APPEAL FROM JUOICIAL 015711(7 DISTRICT JUSTICE JUDGMENT J I 'I I ,I I COMMON PLlAS No. /I Lf,1 Civl I J 99 'I NOTICE OF APPEAL Notic. i. given thot tho appellant ho. filed in tho obov. Court of Common PI.o. on appeal from tho judgment rendered by tho Di.trict Ju.tic. on tho dolo and in tho co... mentioned bolo-.< I ~ y- .... , 2.5' r"oy"+t<VI(....:J 'i)v-. _UANT ,;}.. - . q L\- L I~ fI... \-\ . N ~ A I .'" Cadi~k... " LQ\.ACJ<. ~ r- no"~ zr CODE ~ CV 19. ('lOOn, ") ';) -cr3 LT 19 Thi. black will be signed ONLY when this notation i. requir.d under Po. R.cP JP. No. looBB. Thi. Notic. of Appeal. when received by tho Di.trict Ju.tic.. will operat. o. 0 SUPERSEDEAS 10 tho judgment fa< po......", in this co... /II. Y A N Signature 01 ProthonolNy Of Deputy If appel/ant was CLAIMANT (see Pa. R.c.P.J.P. No. 1001 (6) In acllon before Disfrlcf Justice, he MUST FILE A COMPLAINT within fwenty (20) days after filing his NOTICE of APPEAL. (This section 0/ form to be used ONLY when appel/ant was DEFENDANT (sco Pa, R.c.P .J,P, No, IF NOT USED, detach from cq>y 0/ no/ice 0/ appeal to be served upon appel/co), PRAECIPE, To Prothonotary Enter rul. upon L I '::l lit t--\,. LCA.. \.A.F_ \c:... YVt. V- PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE 100 1 (7) in action be/ore District Justice, . oppelloo(.), to fil. 0 complaint in this oppool RULE, To '.., _ ^ J 0( ~ ex ~.homey ex agonI _J 'VOr<t:-hUUA.-<.J Ur c:..cO''"/iS J.e.. ?A- /"2013 Vf{!;/c/jl'f L'. ,cranca.~ (1) YOtJ ore notified thot 0 rule is hereby entered upon you to file 0 complaint in this appeal within twenty (20) day. after lho dot. of ""vice of thi. rule upon YOtJ by personal .ervice or by certified or regi.tered moiL L lS f't" /I 'I~ M, LCu..u:.. K.. n-t..,f,oPPellee(.}, Naroo 0/ _51 (2) If you do not file.o complaint within this time, 0 JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU, (3) Tho dote of service of this rule if .ervice was by moil i. tho dote of moiling. Date:JY\0.rr,h q 199i -9 11 {/ ;~ 711, (t?/1~~ 0/ ex /)(JIuty AOf'CJI2.84 PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (ThiS proor 01 service MUST BE FILED WITHIN TEN (10) DA YS AFTER /lUng the notice a/appeal, Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ; II AFFIDAVIT: I hereby swear or affirm thai I served o a copy of Ihe Notice 01 Appeal, Common Pleas No, ' upon the Dlslrlct Justice deslgnafed therein on (date 0/ service) , 19_, 0 by personal service 0 by (certified) (registered) mail, sender's receipt allached hereto, and upon the appeflee, (nama) , on ,19 n by personal service 0 by (certilied) (registered) mail, sender's receipt allached hereto. o and further thaI I served the Rule to File a Complaint accompanying the abovc Notice of Appcal upon Ihe appellae(s) to whom Ihe Rule was cd dressed on . 19_ 0 by personal scrvice 0 by (certified) (registered) mail. scnder's reccipt ettached hcrcto. SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF ,19_ Slgnarufe 0' olllcrat befole wf!om .",dal/lt was m.de T.tle 0' olllClal My commission expiros on 19_. ( \ \ ~' ..r::.\ ~ ll, "\ :)~ r:; -r'r. "I ~l:, Ell: -t:. I::> lr\ :J- .,::) ." ::' ''''-:.") " o c sw " '" -,~ .- .....:; ; :~ -t ~ ?. : d}t/ 5' - '1Sto'f ~~ ~;o.,.. . 4- 1\: l:) ~ iN ........') v.. ""<;) t:", ,1 Signature of aWant j;!= "" r.o to.> .... .... .:.: ~ r.o .c. - NOTICE OF APPEAL COMMONWIAL7H D. PINNSnVANIA '" COUIT O. COMMON PLlAS fROM JUOIClAL DiStRICT DISTRICT JUSTICE JUDGMENT COMMONPLlASNo. II L/J (IYI/ '999 NOTICE OF APPEAL Notic. i. given thot the appellant ho. filed in the above COUft of Common PI.a. an opp.al from the judgm.nt rendOf.d by lhe Di.trict Ju.tic. on the date and in the cose mentioned below. ~ 'Voo.r-H l)1( ~ APPfllAN " . Cor'l"<....O""-\.... YSVLVI A //01 " c'\ -. \.,. N' l)..- L\~fl..1-\ . N HE A 1'Llort'''J Ci::'l..-(l'j/~ . L.,C~I..Ac....k \"'It. f ~ I I=-v V'\ r:f- - '" LT 19 !iilNA,---ifiif,/ ~ :"" 01, tIS AJlOflNEv 01 ACINI CV 19 (1nO(-), ')) .q3 ~~ Thi. block will b. signed ONLY when this notation i. r.quir.d undOf Po. R.C.P J.P. No. If appellant was CLAIMANT (see Pa, R,CP,JP, No, 10088. Thi. Notic. of App.al. when rec.i",d by the Ci.lrict Ju.tic., will operate a. a 1001 (6) in action before Districf Justice, he MUST SUPERSEDEAS to the judgment for po....~on in this ca... FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. Sign.1/uro 01 ProlhonoUIlY ex Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This see/ion 01 loon to be used ONLY when appellant was DEFENDANT t see Pa. HC.P.J.P, No. IF NOT USED. detach lrom copy 01 notice 01 appeal to be selVed upon appellee), PRAECIPEI To Prothonotary 1-1'::.1\ l'--\, 100 1 (7) in action belore District Justice, RULEI To -1 _ ^ I ~IJIO oJ.11lJ)CIIanI br ~ .,''''"'''' ex agenl ,<J IvorV-h(~u. r..J Ur- Ger ~ II S I-e, P If I 7 0 / 3 VtC--!r.{!II+ I.', Francol'l (1) You ore notiflOd thot a rul. i. hereby entered upon you to file a complaint in this appeol within twenty (20) doy. aftOf the date of service of lhi. rule upon you by personal 'Ofvice or by cOftifoed 0< regi.tered maiL ~~ LIS l'\ c Ill!;}. M, Lo..L.\.c.. K.. r\.e.. r, app.lle.(.). NIwoo oJ 1JWCIIc<j., t'.., . LeA. '-A..c.... \'- Ylot.. V- , . a~~I;e(.). to 'file-a (ompIointin thi. appeal N.WlO 01 iJWCIu>fsJ : .. '. ~ , .:...:::... c...., . . _\,JU() 1,;.1- 0' "~Jwithintwenty(20)daysafters" eofruleorsufferentryoF.judgmentofnonpros. - , C IVI I J19Lj . Enter rule upon (Common Plea. No. (2) If you do not file a complaint within this time. 0 JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU, (3) The date of service of this rule if 'Ofvic. wo. by mail i. the date of mailing. Date:J'{\n.vrh 9 199J.. . .. !J1. (tJ. QA.J.. -0/JO" . /)~o/~'ex"-ry ~_. AOPCJ1;l.84 COURT FILE -- ... PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (ThIS proof of somco MUST BE FILED WITHIN TEN (10) DA YS AFTER fJling 1/10 nol/co of <1PflOal. Chock applicable bou.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cu.....'ilEtJ.."-"'i:> :n AFFIDAVIT: I hereby swear or aflirm Ihallserved ~COPY ollhe NOIJCe 01 Appeal, Common Pleas No J1.'-I2, ~vt:L- 1'i'l4, upon Ihe Dlslricl Justice designaled Iherein on Ida!o of somco) MAl.C4-l 'i! , 19.sL, ~ by pe~alsorYlce 0 by (ccrlitJod) (reglslered) mall. sender'. receipl alloched herelo, 'q~u~n Ihe appellee, (name) A I-AUe.I<I.1E:R.. ,on MAIZal ~ , 19 by personal service !&by (cerlilied) (registered) mail, sender's receipt all ached herelO. o and furl her Ihall served the Rule 10 File a Complamlaccompanymg Ihe above Nollce 01 Appeal upon Ihe appellee(.)10 whom lI,e Rule was addressed on , 19_ 0 b,Y personal service 0 by (carlified) (regislered) m.ul. sender's receipt attached hereto . SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS I~':) __DAY OF3 , lfl:f- " 1 _l-'nu/A. j) S/gnoll,,'!) 0: '~!I'[ldl ",Ie'" w".::m d"ld.ttll ,"",IS My comml:;"~ILi 110 "_I'"" " I' (;.;11.1."'''''" .,pJ~'" e ~rlw\CU'J:ft i94 c:.l\l,:t,. "'ooile; NC'I. 2lI. I .,\1 comln'S;\an TIlle 0(,,11-"<1: -::>' en - " N '" ('-..J L~ ." -. ~:. :oJ c. III N .. '" !;: "" '" I '" J, Z o i lo. < .... '" ~ .... > >- ~ ~ i ~ I:: 1~"'91:')C) o ~~CJ~t'l '" I' t" ~ .... "tl..?~l:~ is 0 .9 .t! ;1 r.~ "l .~. i" I 1":' Z III I.~ to. . ,-I t::" .... ~ ~ Pl ';1.:i ,oj ~ ! I ~ 1i ~i ~ r.:l i llc ~ ::a .... '" o lJl [:; lo. o >- c. o u < '" .... '" .... [:; ~ Ii j ~ .. ;L 1 V ~ ,J :; ...., ~..:::. ~ 1 I,' ~ .: ~ Fi~; ~ j I ... 1 \I :3 ~ a. Ii l ~ l 'V ~ j ~ j ~ i~ 3 ,~ 1 ~ .J t- .& .~' I J (:S.:r-" 1 j .! . -, ' ~l ,,:, ".' ,;., 't rl t I~. \ I ~ ~. r; :;: :ft'[, ;) 'To ,l~ I z I'~ :;1 -=: \.(. \ ~ ~ 1,,\ ~ , -.' '::' \:-- .'- - - ... I ~ a ~ ~ o ~ ~ l:l :) 5 ;:: z u m a i Ii n i ~ & r j " - .) .:J ,) ,-' '/- . - ::. . r- . ,~ ':::.:. . ~ !o ! a.; ~ 'iij h~!.! It ~ &! ~ ..... ;iA.t~ \~ I ; ~ :(<J,s~~ i ~ ~ ~ i ~ ~ ~,. ~ := <l: ~ l:l .~~~~~ ~ !l! -..l ... "" ::l -$ b ~H I i' J I 1 . II> , II::! .1:\ ift g .1Il j!.ll ~ ''-, .5 :: 0 r ':Ii ~., u . ';,; i ~l · ~ ~ l~ ~'(~ :1\ ~ ~l .' ~ ~ 1 'l~ ~ ~ f '01.2, ~,:"i'~ :II al ~ . co . j@~j@ . .'. ~~ \~\._' - '- '. , Z 719 95? b41 'A- Receipt for oX: Certified Mail -.: No Inlurance Coverage Provided ~.&-::a 00 not use for International Mall ISoe Reverse) MI..JCKAJC2 GAp'ia> SP'K..1 0.1_\ r.. ftetlllCted D.I......,y r.. it Rel\,lfn RK'tCll 5howll'lg .... 10 Wt>om & o.'e DeI......ed ~ Aellnn RKelpl SfIOw"'Q 10 Whom, ~ o.lf. end Add."..... Add,u, C o ~ E & le eo ,f: ~ . 'j ).. " .' ., " \'-- '-- .....~ ~ '~ ~ ~.., '.'<c'_.;'",,", I el.o wl.h to ,r~'V(;h'~/;~:I' :~~Wlng. .'Nlc.. .tfO~. .n.xtr~~t.1 :: ~ :::~:::.:':s~~:;~' "II Conlult Itml.te, for f..:"< ~. I ::: :~::: N;::er .. ,.:)! o Regl.ter.d 0 Inlurod?".;,,;~ : ~~;~~.dM'1I ~ ~~~rn RIC~IPt't~H.f: 7, ~"~o~'lIv~ry9 ~I p\}fl 8. :~tl~s:r:~s~~drol' 10nlv II roqu:llod,~l , ":",::;i ..u.o.OPO:'___"4 DOMESTIC RETURN RECEIPT'l "-;."," ';,', k I" ,-l!I" ;....,: f. jt ,...:.--.," .,I. ER: "'Compllt. h.m. 1 Ind/o, 2 tor addUIon.I"rvtce,. !Ii . COtnPltlllttml 3. end oC. I b. r= _' Print your MrM 1IMI1dd,... on the flVlr" olthlt 'ann 10 lh1t w, cln I "turn tN. card 10 you. ~'. Att.ch .tN. lorm to the front of the mtllP'fc.. Of on the blc" I' lpaC' . doe. not .,.mI. J' !~ writ. "A.lum A.e.lpt RlQUflttd,i on the mIIIpItc. below the .tUdtnumber .. j The R,turn Recelpt w1l1lhow to whom the .tUde WI' dtlivtfld ,net the dill Ii ..........., 1 .3. Anlcl. Addr....d to: i ~ ~ , D.cember 1991 ,1f I:rs IT /...~ uc#f.JE/l- O{ ~ES GA? ia> CA~L.e: It1\. l?ot3 ','t1 Y". )1 , f. ~';r ~ ~~ ',." . ~' ~", "1 ,. !: I . , - \. --~ \.- ., . V:r.ert3eJ;ft. L Fi~ ao Nol2.THltLEW "D~ CAaU'SLE , ~ (lOt'3-9C:sr/- ! 1 I I i I I .1 ! J /, r ; I I f I :1 'i .' j .N 1 "..I t, ' ., . POSTAL SERVICE I II II I . Offlclll BUlln.n PENALlY FOR PRIVATE USl: TO AVOID PAYMENT Of' POSTAGE. $300 g Print your nama, addrass and ZIP Code hare . . VICTORIA L. FRANCART RESPONDENT \ \ " .... V.S. LISA M. LACUI(NERR PETITIONEF< STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND COMMON PLEA>> 1142 CIVIL 1994 ANSWWER TO PLAINTIFF COMPLAINT~ DATED MARCH 29,1994. LETTER RECIEVED MAY 25,1994, DATED MAY 18,1994, PER CARA A. BOYANOWSI(I, ESQUIRE, LAW OFFICES RON TURD. AS PER OUR CONVERSATION ON MAY 25,1994 I HAVE UNTIL JUNE 5,1994 TO REPSOND TO THIS COMPLAINT. I, VICTORIA L. FRANCART, BEING DULY SWORN, DEPOSE AND SAY; 1. LISA 1'1. LAUCI(NER, WAS DOING CHILDCARE IN HER HOME LOCATED AT 51 CRANES GAP ROAD, CARLISLE, PA 17013-9654 HIRED NOVEMBER 16, 1993. FIRST DATE OF DAYCARE NOVEMBER 18,1993. 2. CHILDREN IN DAYCARE, JACQUELINE, AGE 6, ABIGAIL, AGE 4, LIZA, AGE 2. THE NUMBER OF HOURS IN QUESTION IS 38 HOURS. WHICH I HAVE NEVER QUESTIONED. 3. I DID EXPLAIN TO LISA, HOW THE TRANSITIONAL DAY-CARE PROGRAM WORKED. THE ONLY PROBLEM WAS THAT LISA DID NOT WANT THE CHECI(S, TO BE ISSUED IN HER NAME DUE TO THE FACT THAT SHE WAS RECIEVING A.F.D.C. AND MEDICAL ASSISTANCE, AT THE TIME AND WAS WORRIED ABOUT LOSING HER BENEFITS. SO FOR APPORXIMATELY 2 WEEKS I WAITED FOR HER ANSWER. IN THE MEANTIME SHE WAS WATCHING MY CHILDREN AT A RATE PREVIOUSLY AGREED UPON. THAT RATE loJAS 100.00 PER WEEK BASED ON A 40-HOUR WEEK, AND THAT WEf,ENDS WERE TO BE SEPERATE IN THE RATE OF 40.00 PER NIGHT. I, AS STATED TO LISA THAT ONCE THE TRANSITIONAL DAY- CARE DID IN FACT START THAT SHE COULD CHARGE MORE IF SHE WANTED TO. THAT SHE COULD CALL CARLISLE DAYCARE CENTER TO CHECK THERE RATES, AND TO CHARGE ACCORDINGLY, 4. I HAVE IN MY POSSESSION THE PAPERS FOR THAT PROGRAM THAT I WILL PROVIDE, IF NEED BE AND loJILL GO BACK TO MY CASE- WORI<ER IF NEED BE. 5. LISA, ONLY WATCHED MY CHILDREN FOR A TOTAL OF 38-HOURS STARTING NOVEMBER 18,1993 - ENDING DECEMBER 12,1993 IN THOSE 4.5 WEEKS. YES THERE WERE TIMES WHEN I WOULD BE RUNNING LATE AND I WOULD CALL HER TO VERIFY THAT THE CHILDREN WERE FJI~E AND IF THEY \~ER[ (-lI_LOl>JED TO STAY LONGER. THERE WAS ONE TIME: THIH ~n{';NDS OUT II~ MY MIND THAT WE I~ENT TO PICI:: UP THE CHIL.DREN, AND SIIE ~JAS SLEEPING AND DID NOT AI~SWER THE DOOR OR THE PHONE. THERE WERE TIi~ES THAT MY HUSBAND AND I WOULD GO OUT TO NIGHTCLUBS, AND I WOULD CALL TO CIiECI( ON THE KIDS BUT, THAT I~AS PAID SEPERATELY IN THE AMOUNT IJF 40,00 IN CASH, THERE WAS A TIJTAL OF 3 NIGHTS, TOTALLY 120.00 6. AS SHE STATED THIH I ALWAYS HAD MOI~EY FOR ALCOHOL, WHICH I DO NOT THIN!, IT IS ANY OF HER BUSINESS THERE- FORE, SHE I~AE, GETTING PArD FOR HER SERVICES ON A NIGHTLY RATE. SHE HAD I~GREED TO WAIT FOR THE PAPERS FROM THE TRANS- DAYCARE PROGRAM. 7. I, DID IN DEED FIRE HER FOR NUMEROUS REASONS, ONE IN PARTICULAR, WAS DATED DECEMBER 9,1993 WHERE SHE ONLY HAD MY YOUNGEST CHILD SHE PICKED HER UP AT 5:30 p.m. AND WAS TOLD THAT SHE HAD NOT EATEN DINNER AND WAS GIVEN 5.00 TO BUY HER SOMETHING AT THE MALL WHERE THEY WOULD BE GOING. WHEN I PICKED LIZA UP AT 8;15 P.M. SHE HAD NOT EATEN. 8. FEB.3,1994 PAULA CORREAL HEARD THE CASE, AND RULED THAT I SHOULD PAY 226.50 FOR CHILDCARE SERVICES, WHICH I FEEL IS OUT OF THE QUESTION. I DONT FEEL THAT I SHOULD PAY 5.00 PER HOUR. WHEN THERE WAS TIMES SHE ONLY HAD ONE CHILD. IF THAT IS THE CASE THEN I SHOULD oun MY JOB AND START CHILDCARE IN MY HOME TAX-FREE. PRIOR TO THIS HEARING SHE I~AS OFFERED 100.00 SHE STATED THAT SHE WOULD GET MORE BY GOING TO COURT. 9, MARCH 10,1994 THE LAST DATED TO FILE THE APPEAL I CALLED "L1SA AND SPOKE WITH HER AND INFORMED HER THAT I DID GET AIJRT AT WORK AND HAD BEEN OFF l~oRK SINCE FEB. 13,1994 'TO PRESENT TIME AND ASKED HER TO ACCEPT PAYMENTS OF 100.00 EVERY TWO WEEt,S, DUE TO THE FACT THAT CaMP. CHECKS WOULD BE COMING. SHE TURNED THAT DOWN WITH NO QUESTIONS, t~EN AGAIN IN APRIL SHE SAID NO AGAIN, I AM AWARE OF THE f~CT THAT I CAN FILE WITH THE FAIR CREDIT AGENCY TO SAY J'" MADE A ATTEMPT, TO PAY THIS DEDT. L ISA I~AS ALSO AWARE ~ THE'FACT THAT MY HUSBAND, WAS NOT EMPLOYED, AND FILED FOR UMEMPLoYMENT AND HAD TO GO THRUOGH THE APPEALS PROCESS AT THIS SAME TIME 10. I DO NOT FEEL AS IF I SHOULD BE RESPONSIBLE FOR HER COST INVOLDED IN THIS MATTER AND I PRAY TO THE COURTS THAT THEY SEE I HAVE MADE EVERY ATTEMPT TO SOLVE THIS MATTER. LISA HAS NOT SUFFERED ANY FINANCIAL HARDSHIP OVER THIS MATTER, SHE IS TO THIS DATE STILL WATCHING CHILDERN AND SHE HAS A STEADY INCOME COMING IN MONTHLY FROM HER BOY~RIEND/AND A. F, C. ~,~J; fa;:- a;. I know). DATED:~~~_~L22!~__ -~t~~~~~L~#~~~iART~------ ENCLOSURE; cc CAR A A. BOYANOWSn LISA LAUCKNER PROTHONOTARY . , . ~ ... C) >-,... ~- ._ ..r. {oJ 1,', :.;)~~ ~:':-":;';~ ",,-o(..,.c:; _~ ~"1: '; :~] , , ~ r I I I e; - ....., (i~ '.~l~~ j"':-;.a..:;4.< .to.g Q z ~ ,- . .. , ' VictDria L. Frankhart, RespDndent, CbmrrYJ/V PlttL I IIL/J C./vd /CfJ1 LISA M. LAUCKNER, PetitiDner, and STATE OF PENNSYLVANIA CDunty of Cumberland ~~\ V\ ':t C.C\'l'.O u \ '-' I, Lisa Lauckner, being duly sWDrn, depDse and say: I was dDing childcare in my hDme iDcated at 51 Cranes Gap Road Carllsle, Pa. 17013 when the raspDndant callad me snd arranged a time tD meet with me fDr pDssible childcare. I then met with har and she hire me tD care fDr her three children namely, Jacqueline,age 6 Abigail, age 4 and Liza, ege:a. At that same time she did in fact tell me that sha ...., - wDuld'be recieving "TransitiDnal Osy-care Assistance" which is B~prDgram funded thrDugh Cumberland CDunty Assistance Office. She stated that I wDuld racieve papers in 7 tD 10 days. I nevar tD date recieved any papars. I cDntacted the aasistance Dffice tD have them~infDrm me Df exactly hDW this prDgram wDrks. They to . did in fact tell me that the prDvider did not have tD wait fDr her mD~ies, the monies wDuld be paid by tha Respondent and they ~uld;'reimburse her. He did assure me that I shDuid nDt wait. I was tD be paid up front and that they had nD programs where the provider had to wait to be paid. From that conversetion, I became akeptical. I had cared fDr her chiidren fDr numerDUS hours, whiie she was suppDse to be working yet she'd call to check on the children from a bsr. I had had the children 38 hours in which I never racieved pay fDr. She was very unreliabie abDut picking up the children. She would call and ask me to keep them for a l~nger period of time. When I would call her and ask for my monies she would always make excuses, yet she always had monay for alcohol. She then told me that she decided not to use me anymore. When in fact she was sUPPDsad to give me a two week notice to quit. On January 20, 1994 I then filed a compiaint feeling I geve her adequate time to pay. District Paula Correal heard the caae and awarded me a judgement of $190.00 and $36.50 for CDurt CDStS amking a total of $226.50. This hearing took placa Dn February 3, 1994. On March 9th, 1994, the Respondent filed an appeal, which brought me to the present. My services were rendered and yet I hava still recieved no monies to date. I feel that I em entitled to payment and that any further costs be the respondents responsibility. This was my Dnly means of incDme and has caused a financial hardship for me. DATED: ~. a;J- 9-1 ~ '1;J.a'f IJi. f( ) BB M. uc ner ~ "1::' "'- ... o -:r ~t:: ~z W~;:).. 2:1:c..~ t&.OU... ...'2:0> r:>t-z-' ~, <:?..r~ :~ _IV" ;'... (~;I! _: ."w::: c"'''-' ~'.::r.01. ~=> 0'" ~ co: ~ ..--_.:.::r,:~" /...... ' . ','" r", rC~'l~~r ~(): 1:-J';::"", C\'-<~. ,,~((''';;'':L o;;'!::-~I::p:'r I)]~ "'~"-~.l'r';~ : ~"~~3 01 r"-i"T r,rl~ i.",.I-.C~--U; ;:.';.~r.Lrt F'. CCf:.j;;'E(L 16 1..1. HlEi.l ~-'T. ,;N) FLCCf-: r1'J.m)Iril !"'N RJtI,DIrJi CrH. ] ~LE FII ~';"'3::: 1 . l?Ol::J i))").:' '" r"l ~nrtE: f'Am [,y J"p',JL i'1,IH:lO: F'~\m Bf D-ECl. !-,~'IJ{'~, r1':CElF'r l'~J: O'EO:' 1\ 'XI5:31 r :> L IS\ M. IJ-'l-'J'l-ER 51 IT,;':'''ES (?t'=F' CI"F'Lt SU:.. Fi\ 17,) 13 A'1J..r-./T R:CE[I,8): ~tNT oOfA.IED: CO.LATEr"'L PFFUED: C1-'l'N:t:: 36.~.o ~.::() . (ill) .00 <t " .'") F'I:Wi'1~Nr t€SCR1H1CN r:r.LA' J.:E Fl.]J) N'IT oOfFUED CU'f1':NT fJI.'L . ) :'UDJCI~L CUftJTEH ff,OJECr FOOTAr:E a:tN:t.a.B:L'n~ F IUN] FEES F1L!rJ3 FE-:::S mST.. 1!f.~7 O:H'....Cn5T 21-Cr{ 1.~~O 5.00 5.(.) 7.::(1 17.~(1 l.eXl-- 5.(~)- 5.((t-- 7. e-O- l'I. 5/)- .((. .(lr.) ..0,) .00 .00 . . " Terri';., 2<:,.::.(1 36.~(1- .00 .~ . "S:;vn FT01 LAI.OJ\ET<. LI~,::' M .:.,) . ,J I . ..J . ...i . I- . , ~ ..) . ...i . j . II ..) . J . -...I . - ~.:bIr.~:>~ .. 'COMMONWEALTH OF PENNSYLVANIA ~ .... . COUNTY OF: CUMBERLAND 09-2-01 CIVIL ACTION PLAINTIFF HEARING NOTICE r; NAME and AOORESS LAUCKNER, LISA M 51 CRANES GAP CARLISLE, PA 17013 L -, Mag Ottl.. No : OJ NarM Uon PAULA P. CORREAL Add.... 16 W. HIGH ST. 2ND FLOOR MERIDIAN BANK BUILDING CARLISLE, PA ,_ (717) 243-0292 17013-0000 .J DEFENDANT: r;; NAME and ADDAE8S FRANCART, VICTORIA 25 NORTHVIEW DRIVE CARLISLE, PA 17013 L VS. -, .J LISA M. LAUCKNER 51 CRANES GAP CARLISLE, PA 17013 Docket No,: CV-0000722-93 Date Flied: 12/20/93 A civil complaint has been lIIed against you In the above captioned case. A hearing has been set In this matter for: Date: 1 20 94 3:45 PM Place: Time: 16 W. HIGH ST. 2ND FLOOR MERIDIAN BANK BUILDING CARLISLE PA 17013-0000 NOTICE TO DEFENDANT If you Intend to enter 8 defense to this complaint, you should so notify this olllce Immediately at the above phone number. You must appear at the hearing and preasnt your defense. UNLESS YOU 00, JUDGMENT WILL BE ENTERED AGAINST YOU BY DEFAULT. If you hav.e a claim against the plaintiff which Is within district justice jurisdiction and which you Intend to assert at the hearing, you must file It on a complaint form at this office at least five (5) days before the date set for the hearing. II you have a claim against the plalntlll which Is not within district justice jurisdiction, you may request Information from this olllce as to the procedures you may follow. DATE PRINTED: 12/20/93 AOPC 308B,92 ".'. NORTH MIDDLETON TOWNSHIP CARUSLE BOROUGH PAULA P. CORREAL DISTRICT JUSTICE 09'2,01 16 W, HIGH STREET MERIDIAN BANK BLD. 2ND FLOOR CARLISLE, PA 170:jy13 -......:<ti ..: February 8, 1994 ,,--_/ t'J)o- County 01 CUmberland OIllc8 (717) 243-0292 RESERVED JUDGMENT DETERMINATION Plaintiff. Lisa Lauckner Defendant: Victoria Francart Complaint No. CV-722-93 Date of Hearing. 2-3-94 I hereby render judgment to the plaintiff in the amount of $190.00, together with court costs of $36.50, total judgment $226.50. ("Comment: the above amount reflects thirty eight hours of bebysitting at the rate of $5.00. The plaintiff failed by a preponderence of the evidence to justify charging a higher rate than previously discussed. I also believe that the $5.00 charge is reasonable. Plaintiff also failed to produce specific evidence which would substantiate her request for additional hours and child care costs. ALL PARTIES ARE NOTIFIED THAT TilEY HAVE TIIIRTY DAYS FROM THE ABOVE DATE IUTII IIlIICH TO AFrE.\L TillS JUDGl-lEl;T TO TIlE OFI:"ICE Or' TIlE PROTHOllOTARY, COURT OF COMMON PLEAS, CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 Paula P. District " ( ",~\..L"'" Correal Justice ALL ABOUT ME MY NAME IS /, i :zA t-tfrJr7 ' ~tYJ. n ;::ranr./l.e:r- MY BIRTHDAY IS /1J~tJ/~ CJ/ I (AM) c1\M NOf)>POTTY-TRAINEO. MY MOOMY'S NAME IS -1I'l~/)q MY OADOY'S NAME IS sr€:p{)4D ~ ~/lI??7I~ 1Zl~- OUR ADDRESS IS ,4-'1 !i)()r4J1I///J/-l) Dr - (lCI.J1--ksA-f , PA 17~/3 I OUR TELEPHONE NUMBER IS (117) d'-ltJ -/19;2 I DADDY'S EMPLOYED BY Vlf/J f ' I../:J-. MOMMY'S EMPLOYED BY /:y/-v-J /}.~k;rl If //., /-' S7dJ ~ If . I TAKE NAPS LIKE THIS ( ) MORNINGS t><J AFTERNOONS ) NONE FOODS I REALLY LIKE - FOODS I DON'T LIKE ARE ...---... I REALLY ENJOY DOING THESE THINGS ~;~~ ,f/J~~~~/i A' DOC""' 5 .,A' '"-;(;: r~:;;t; - /l7p ,:/. DOCTOR'S NUMBER IS /~ V) J HAVE THESE ALLERGIES - MY HOSPITAL IS ;J.eALl/~ JJl~d. /-/ SIGNATURE ~~~~.,nt"//~ATE U lUNA TURE II^ II' ----.- If ------- AlJU liL_t!lf1.3 / --- .,., .. . SOME FACTS AND SOME SUGGESTIONS EACH CHILD WILL HAVE A FOLDER WHERE WE KEEP IMPORTANT THINGS LIKE THESE PAPERS AND OTHER THINGS THAT HAPPEN WHILE TilEY ARE HERE WITH US. KIDS DO SOME REAL NEAT THINGS WHILE YOUR AWAY AT Jo hi. ,/WORK AND WE NOTE THEM ALSO. WE SOMETIMES TAKE PICTURS OF THE -J-" hIDS AND THEY WILL BE IN YOUR CHILD'S FILE. YOU WILL ALSO GET r:rWll~, M:lnt'l v:% TO ENJOY. ~"Vl'l' '0 YOU THE FOR MAY WANT TO LEAVE A COUPLE OF THEIR FAVORITE TOYS HERE FOR FIRST FEW DAYS SO THAT THEY FEEL MORE SECURE. SAME GOES THEIR FAVORITE BLANKET. FOR THOSE OF YOU THAT USE DIAPERS, YOU MAY WANT TO LEAVE A BOX HERE SO THAT YOU DON"T HAVE TO BRING THEM EVERY DAY. I CAN TEI.L YOU WHEN YOU ARE GETTING LOW SO THAT YOU CAN BRING MORE BEFORE HE/SHE RUNS OUT. THEY WILL BE LABLED AND ONLY YOUR CHILD WIU_ USE HIS/HER OWN DIAPERS. THEY CHILDREN WILL HAVE SPECIAL THINGS TO DO. SPECIAL EVENTS, SUCH AS THEY WILL SEE THE CLOWNS ANO SANTA AND ECT. EACIl CIIILO WILL BRING HOME CRAFTS THAT THEY MAKE FROM TIME TO TIME. ALTIlOUGII THIS IS NOT A DAYCARE TYPE HOME BUT WE RATHER THINK IT'S JUST A PRIVATE HOME WHERE WE CARE FOR CHILDREN BECAUSE WE LOVE THEM AND NOT FOR THE REASONS OF A BUSINESS LIKE FACIL lTY. YOUR CIIILO WILL BE TREATED WITH LOTS OF LOVE ANO UNDERSTANDING HERE. TIlEY WILL BE FED HOME-COOKED MEALS THAT ARE NUTRICIONAL MEALS, NO CHILD WILL BE PHYSICALLY DISCIPLINED NOR WILL THEY SPOKE TO IN A LOUD VOICE. WE BELIEVE IN LOVING DICIPLINE. WE MAY TAKE THE11I FAVORITE TOY AWAY FOR AWHILE OR WE MAY MAKE THEM SIT AND TAKE SOME TIME OUT. WE MAY JUST EXPLAIN THINGS TO THEM. EACH CHILD IS THE!fl OWN LITTLE SELF AND NEED TO BE TREATED AS SUCH. WHAT WORKS WITH SOME DOESN'T ALWAYS WORK WITH OTHERS. ------ NO MEDICATION CAN BE GIVEN UNLESS A NOTE FOR PERMISSION IS GIVEN WITH DOSAGES AND TIMES AND IT HAS TO BE IN THE ORIGINAL CON- TAINERS THAT IT CAME IN. I'M SORRY BUT THEREARE NO EXCEPTIONS. THIS IS FOR OUR SAFETY AND YOURS. ------- WE WILL EXPECT PAYMENTS AT THE END OF ~UOWEEK UNLESS OHlER ARRANGEMENTS ARE MADE. WE CANNOT ACCEPT CHECKS AND WILL NO! EXTEND CREDIT LONGER THAN TWO WEEKS FOR THOSE OF YOU wlm GET PAID SEMI MONTHLY. -- p>"~~\....J.. 'WE WOULD LIKE A TWO WEEK NOTICE THAT YOU PLAN TO TERMINATE YOU!'l \ ~~ CHILD CARE PLACEMENT SO THAT WE CAN OFFER IT TO SDME~~_~~~~~ UNDER NO CIRCUMSTANCES WILL WE PERMIT YOUR CHILD TO LEAVE THIS HOUSE WITH ANYONE BUT THE PARENTS DR LEGAL GUARDIANS UNLESS A FORM IS SIGNED BY YOU IN MY PRESENCE. THIS IS FOR YOUR_ PROTECTION AND THEY WILL NEED TO SHOW SOME 1.0. WITH THE EVENTS THAT HAPPEN IN OUR WORLD TODAY , THIS SCARES ME AND THAT IS WilY I ~ ~ :.11 STRICT ABOUT THIS. I DON'T WANT YOU TO HAVE TO WORRY ABOUT YDU~ CHII n WHILE IT'S IN MY CARE. ***IF IT POSSIBLE WE WOULD LIKE A BY THE WEEK. WE CAN PLAN WHEN TO ~ EXPECT OF YOUR SCHEDULE YOUR CHILD. !-L;P fOl/IJL SIGNATURE DATE _Noll.:._Lu, N2.3 SIGNATURE DATE ** If you use this your chltdcare for a tax deduction, check the box below so that you can be sure that you get a reciept end we too can keep a record for you su that you witl automatically racleve a summary of payments. I DO PLAN TO USE CHILOCAAE MONIES ON MY TAXES. I DO NOT PLAN TO USE CHILOCARE AS A DEDUCTION ON MY TAXES. .. ALL ABOUT ME MY NAME IS ~I H(l('i.e. /...~nn r:VCH'IeC(r-l- MY BIRTHDAY IS ,::; ~ ,Q J -f3C/ I 6)CAM NOT) POTTY-.TRAINE? MY MOOMY'S NAME IS V/C-r/)RI f} MY DADDY'S NAME IS ,STE.pnAO - ~r--omp_ MoF-'-- OUR ADORESS IS 45'" /V()/cJ-hVI4>t'J /)1<. - (l/l1J Lwlo _ PA / 7o/~ I OUR TELEPHONE NUMBER IS C 717) d'-f() - (Jq,;U DADDY'S EMPLOYEO BY ~ /( , 11...$-. MOMMY'S EMPLOYEO BY S.J70~ 'tD /'dh ;',,+ - II 7~/-:57aJ II I TAKE NAPS LIKE THIS C ) MORNINGS C}<) AFTERNOONS ( ) NON~ FOOOS I REALLY LIKE 'lJn.;j FOOOS I DON'T LIKE ARE Y4n 'f I REALLY ENJOY OOING THESE THINGS ~~ i 1\ ~ h..P /1 rI ~- , , Lb.Ln-h J/{} (!~C1-1/~ I ..' J MY OOCTOR'S NAME IS fL"~'1,l.lY- L/7fe,0J!~;'ntJ ~('~--- OOCTOR'S NUMBER IS ~-~_~~ I IiAVE THESE ALLERGIES 'BCD J-:IH'/~'3,-()) -- MY HOSPITAL IS .i./p,'t.J..I. (Jy C//}p~~_______ / {/ -'7 SIGNATURE 4-v~ /1('A/r:Y~ OATE .tUz~/~ L'Z?c? 1l10NATtlRE Il^ II ------.-----.-- .~ , SOME FACTS AND SOME SUGGESTIONS EACH CHILD WILL HAVE A FOLDER WHERE WE KEEP IMPORTANT TllINGS LIKE THESE PAPERS AND OTHER THINGS THAT UAPPEN WUILE TIlEY ARE ~,b( HERE WITH US. KIDS 00 SOME REAL NEAT TUINGS WHILE YOUR AWAY AT " 10J 1V ,..wORK AND WE NOTE THEM ALSO. WE SOMETIMES TAKE PICTURS OF HtE I~uen ~KIDS AND THEY WILL BE IN YOUR CHILD'S FILE. YOU WILL ALSO GET COPJEU 9' DV-l::' TO EN.JOY. YOU MAY WANT TO LEAVE A COUPLE OF THEIR FAVORITE TOYS HERE FOR THE FIRST FEW DAYS SO THAT THEY FEEL MORE SECURE. SAME GOES FOR THEIR FAVORITE BLANKET. FOR THOSE OF YOU THAT USE DIAPERS, YOU MAY WANT TO LEAVE A BOX HERE SO THAT YOU DDN"T HAVE TO BRING THEM EVERY DAY. I CAN TELL YOU WHEN YOU ARE GETTING LOW SO THAT YOU CAN BRING MORE BEFORE HE/SHE RUNS OUT. THEY WILL BE LABLED ANO ONLY YOUR CHILD WILI_ USE HIS/HER OWN DIAPERS. THEY CHILDREN WILL HAVE SPECIAL THINGS TO 00. SPECIAL EVENTS, SUCH AS THEY WILL SEE THE CLOWNS AND SANTA ANO ECT. EACH CllILD WILL BRING HOME CRAFTS THAT THEY MAKE FROM TIME TO TIME. ALTHOUGH THIS IS NOT A DAYCARE TYPE HOME BUT WE RATHER THINK IT'S .JUST A PRIVATE HOME WHERE WE CARE FOR CHILOREN BECAUSE WE LOVE TltEM AND NOT FOR THE REASONS OF A BUSINESS LIKE FACILITY. YOUR ~IILO WILL BE TREATED WITH LOTS OF LOVE AND UNDERSTANDING HERE. TIlEY WILL BE FED HOME-COOKED MEALS THAT ARE NUTRICIONAL MEALS. NO CHILO WILL BE PHYSICALLY OISCIPLINED NOR WILL THEY SPOKE TO IN A LOUD VOICE. WE BELIEVE IN LOVING OICIPLINE. WE MAY TAKE TIlE 111 FAVORITE TOY AWAY FOR AWHILE DR WE MAY MAKE THEM SIT AND TAKE SOME TIME OUT. WE MAY .JUST EXPLAIN THINGS TO THEM. EACH CHILD IS THEIR OWN LITTLE SELF AND NEED TO BE TREATED AS SUCH. WHAT WORKS WITtI --- SOME DOESN'T ALWAYS WORK WITH OTHERS. NO MEDICATION CAN BE GIVEN UNLESS A NOTE FOR PERMISSION IS GIVEN WITH OOSAGES AND TIMES ANO IT HAS TO BE IN THE ORIGINAL CON- TAINERS THAT IT CAME IN. I'M SORRY BUT THEREARE NO EXCEPTIONS. THIS IS FOR OUR SAFETY ANO YOURS. -- WE WILL EXPECT PAYMENTS AT THE END OF ""f?P~EEK UNLESS OlliER ARRANGEMENTS ARE MADE. WE CANNOT ACCEPT CHECKS AND WILL NOT EXTEND CREDIT LONGER THAN TWO WEEKS FOR THOSE OF YOU WHO GET PAID SEMI MONTHLY. _. WE WOULD LIKE A TWO WEEK NOTICE THAT YOU PLAN TO TERMINATE YOUR CHILD CARE PLACEMENT SO THAT WE CAN OFFER IT TO SOMEONE ELSE. , , .' ... . . UNDER ND CIRCUMSTANCES WILL WE PERMIT YDUR CHILD TO LEAVE THIS HOUSE WITH ANYONE BUT THE PARENTS OR LEGAL GUARDIANS UNLESS A FORM IS SIGNED BY YOU IN MY PRESENCE. THIS IS FOR YOUR PROTECTION AND THEY WILL NEED TO SHOW SOME 1.0. WITH THE EVENTS THAT HAPPEN IN OUR WORLD TODAY. THIS SCARES ME AND THAT IS WHY I~!1 lill STRICT ABOUT THIS. I DON'T WANT YOU TO HAVE TO WORRY ABOUT YO~~ r.HTI n WHTI~ IT'S IN MY CARE. ***IF IT POSSIBLE WE WOULD LIKE A .dC~ OF YOUR SCHEDULE ':1 BY THE WEEK. WE CAN PLAN WHEN TO EXPECT YOUR CHILD. -tAJ~10~/;1;O ~. SIGNATURE?~ 7U-l't/Y/1.9L-' DATE Ab0-.!{P/J:L9$:-. SIGNATURE OATE ** If you use thLs your chLtdcsre for s tax deductLon, check the box beLow so that you can be sure that you get a reciept and we too can keep a record ror yuu ao that you witt autometLcally recLeve a summary of paymsnts. I 00 PLAN TO USE CHILDCARE MONIES ON MY TAXES. I DO NOT PLAN TO USE CHILDCARE AS A DEDUCTION ON MY TAXES. ,"",""-- --'''-; , . _I . Y(_' {UI)l'/) j c I I; /17 // v (/", ., <, . ~ (~_I i ( '1 //, . ~' ( [~~ l- jll'~ t. ~ /';n , ItJlII(1 ~-: 'leI'" ('S.r1. 9~{JCi , ~ClI)e.~)I VI{ 1-', ~('//(. {~5 "'f I 'uble. a lid t !1.U..:i.ILLirf-/Ir; a'Jd (101; irf! {t!..m!DrIObl-L {ul)~()j) {'-fat/uHf I(/i(' (Ihlct lUlU; J)t{(1. l..fl){. y~ucl'lcI{J5 J/{Jt /)jlfO./6 OI;(/!JljOr"J5 /C,-U;,L (l)iI /c!(lf//' ) ISO,..- C/(;1/5 nrIJ,j)//s Ut!;) HILL (I heirllt'IL I-v I)Lrtp H/lf 0) ( Lfar/i- d'l n..s I hi (11701(' Or ,f)'N; t>) I [)ru~ 1 11:( r ",-r:l( (({ C PS {(Y'(./'e / n r l~ liLt ,p d pel ! 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" Q .J\o-u.c. \"-L~'~""" --fv....~ CVv1}- ~~~?-<J ~~ ;:: ~-X-~w.,t.-+ ~ -'h"~r A<rn. ~. ~ '-.-lo-u.t..q c..rl.,-~L~ ~1 r} -6'-!-..Q ~ . ~~.,Wcr(.J!J /h.C"-LL hD-1r,,~t u"'''''t ''-6 -~ , In:J-eltbi- . ~ :;..- a WO-l.~ .~lVvJ ~ ~ bC\.~f: .. OvV\.-\j; ~)~" cJ~~ .t.0 \-"0 M -to~ ~ .0... ~~'- -~~ ~) hv~ (;'vve>1 _~ . .-H~ (j.~L...~....... o..-<J A o~ . .. ,~_._<- ....--,'- ~ '.'l!<:' a.;; :g. -::r ... .... ~r.: lUJ-:;e UC"):-J.' ~:C<J;; '....~U.t C.),_a> . ":'t~-' t'clB:.:s~. -J o;:Z:: -UJlA.I::':: .... "t:t:"IUJ t-~c.. .....:::J... OU R3 .~_. ~