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Home My WebLink About02-3005 -----..I U.:J4!!::"':fIJ:I. CUMBERLAND COUNTY ADULT PROBATION VS. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA CIVIL ACTION - LAW Joshua M Ramsay 60 E Louther St Apt 2 Carlisle, PA 17013 NO. ().2.. 3()7),,' CIVIL TERM Defendant RE: NO. 02-40 CRIMINAL TERM PRAECIPE TO ENTER JTmGMENT TO THE PROTHONOTARY: Enter judgment in favor of plaintiff, Cumberland County Adult Probation, and against Defendant in the amount of $ 1,281.00 pursuant to 42 Pa, C.S,A. Section 9728 as set forth in the attached statement of certified case costs and fines. Dennis E. Lebo, Clerk of Court Date: June 24, 2002 't\~ L Jf-dr..- ENTRY OF .rrmGMENT AND NOW, this .2 </ ~ day of (2,... , .:2 f)[) ~ judgment is entered in favor of the Plaintiff and against the Defendant the amount set forth above. Curtis R. Long, Prothonotary Attachment cc: Defendant Probation Clerk of Court elf'"' 0. J]/U;Ph, I A..&"" -'t- . 095047052902 - CCS746 ******************** *STATEMtNT OF COSTS* ******************** Page 36 5129/2002 Case No. 2002-00040 To: Dennis E. Lebo Cumberland County - Clerk of Courts 1 Courthouse Square Carlisle, Pa 17013 RAMSAY JOSHUA MICHAEL 60 E LOUTHER ST APT. 2 CARLISLE, PA 17013 Totals 200.00 200.00 04/09/02 ST - O.S.F. 75.00 75.00 Totals 75.00 75.00 04/09/02 CO - O.S.F. 75.00 75.00 Totals 75.00 75.00 04/09/02 COURT COSTS 8.00 8.00 Totals 8.00 8.00 04/09/02 AUTOMATION FEE 5.00 5.00 Totals 5.00 5.00 OS/22/02 LOCAL-DUI 150.00 150.00 Totals 150.00 150.00 OS/22/02 DUI PRISON MNT 75.00 75.00 Totals 75.00 75.00 OS/22/02 DUI DRUG/ACHOL. 75.00 75.00 Totals 75.00 75.00 OS/22/02 EMS 10.00 10.00 Totals 10.00 10.00 OS/22/02 CAT FUND 50.00 50.00 Totals 50.00 50.00 OS/22/02 ADMIN. FEE 40.00 40.00 Totals 40.00 40.00 OS/22/02 CCP FEE 90.00 90.00 Totals 90.00 90.00 095047052902 - CCS746 ******************** *STATEMENT OF COSTS* ******************** Page 37 5729/2002 Case No. 2002-00040 To: Dennis E. Lebo Cumberland County - Clerk of Courts 1 Courthouse Square Carlisle, Pa I7013 RAMSAY JOSHUA MICHAEL 60 E LOUTHER ST APT. 2 CARLISLE, PA 17013 Case Totals 1281. 00 .00 1281. 00 You are liable for the above costs ---------------------------------------------------------------------- Pursuant to Title 42 of Judiciary and Judicial procedure, 42 PA CSA 9728, the Prothonotary is authorized to confess jUdgment on all unpaid costs and issue an execution and place same in tfie fiands of the Sheriff for the collection. We trust you will give the above account your prompt attention. A TRUE COPY FROM RECORD . '~"Jn Testlmony whereof, I here unto set my hand . andlhe~saldCourtatCarlisle, PA, ~1daYOf ,2002-- k of the Cou umberland COUIIIf j '(in","",", ':~',~' ',I ;1 "llyn A -, - f t I~ lr I i o )r . :",T~ .~.~,1 j !/;v!u , t (") 0 e- N 0 ~ , -n "'0 OJ ,- q;!n: 'u.. .c- "T' Z :ri ~ t;f;' N ...= r$:~r .~ - <~~~ ,_u ~ -' i. j; :::>- ...( J ... :zC :J\: .~~-i :tJ -0 ..... )>c 'f? ;:;::?f: ;<. :z ~) ~ =< N ~~ en :0 -< ,$ CUMBERLAND COUNTY ADULT PROBATION IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Plaintiff VS. CIVIL ACTION - LAW NO. OJ.. 3{)t},' CIVIL TERM Joshua M Ramsay 60 E Louther St Apt 2 Carlisle, PA 17013 Defendant RE: NO. 02-40 CRIMINAL TERM PRAECIPE TO ENTER nIDGMENT TO THE PROTHONOTARY: Enter judgment in favor of plaintiff, Cumberland County Adult Probation, and against Defendant in the amount of $ 1,281.00 pursuant to 42 Pa. C.S.A. Section 9728 as set forth in the attached statement of certified case costs and fines. Dennis E. Lebo, Clerk of Court ~~L;f~ Date: June 24, 2002 ENTRY OF JUDGMENT AND NOW, this ,1" ~ day of (tf ,.. , .:l fJV ~ judgment is entered in favor of the Plaintiff and against the Defendant the amount set forth above, Curtis R. Long, Prothonotary QJNfL 0. /vrJ/P".- ~- I I Attachment cc: Defendant Probation Clerk of Court 'n,\ . ':j4 'i(~HU.. f t i~ ij;? i~ ~ r ,".. . t (") C) ~; (...,) 0 '"0 fh , -q 1:p11' '= ~, i- f 7i'-': ,"..- C!) '~t.. "-, .,' ,~ r~" ~:- ,.,.-,-_i ~I-'; ;z,. .. ZC :x "- J>Q :' '-- 'f? ~T" ~~ Cr :3 '" c> , en -< ROY A. LINDSTROM and KIMBERLY J. LINDSTROM, Plaintiffs, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-3005 CIVIL TERM vs. ROBERT MARROQUIN, Defendant. 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 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 SHU~~WER GET LEGAL HELP. & LINDSAY 26 W. High Street Carlisle, P A CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ATrORNEYS-ATeLAW - ROY A. LINDSTROM and KIMBERLY J. LINDSTROM, Plaintiffs, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3005 CIVIL TERM vs. ROBERT MARROQUIN, Defendant. COMPLAINT AND NOW come ROY A. LINDSTROM and KIMBERLY J. LINDSTROM, Plaintiffs, through their attorneys, SAlOIS, SHUFF, FLOWER & LINDSAY, and state as follows: 1. Plaintiffs are ROY A LINDSTROM and KIMBERLY J. LINDSTROM, husband and wife, adult individuals, residing at 1172 Newville Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is ROBERT MARROQUIN, an adult individual, residing at 1985 First Street West, No. 2000, Randolph Air Force Base, Texas 78150-4312. 3. On April 28, 2000, Plaintiffs and Defendant entered into a Lease, whereby Defendant leased a property located at 1183 Newville Road, Carlisle, Cumberland County, Pennsylvania, for a period beginning June 1, 2000, and ending May 31,2001. Said Lease is attached hereto as Exhibit "A". 4. In said Lease, Defendant agreed to the following clauses pertinent SAlOIS SHUFF, FLOWER to this Complaint: & LINDSAY ATIORNEYS.AT.LAW 26 W. High Street Carlisle, P A A. 'Tenant agrees not to alter or make additions to the premises, its painting or its fixtures and appliances without written permission." (Paragraph 4) 2 SAlOIS SHUFF, FLOWER & LINDSAY ATrOKNEYS.AT.UW 26 W. High Street Carlisle, PA B. "Tenant agrees to be responsible for any damages to the wall, carpets and any other surfaces." (Paragraph 4) C. "...if any damages have been found, tenant agrees to immediately pay for costs of repairs, cleaning, or repainting and repairing." (Paragraph 4) D. '7enant shall use plumbing and electrical installations only for their intended uses, and shall be fully responsible for maintenance of the same..." (Paragraph 5) E. '7enant shall agree to keep the premises in a clean and sanitary condition, and remove all garbage which may accumulate on the same during said term or any renewal thereof, and failing therein to pay to the Lessor double the costs of removing the same to be recovered, the same rent and in arrears." (Paragraph 6) '7enant shall place all trash and rubbish inside refuse containers supplied by the Tenant." (Paragraph 7) F. '7enant agrees that in the event it is necessary to go to Court to evict said Tenant, Tenant shall pay Lessor $250.00 for attorneys fees..." (Paragraph 15) G. '7enant shall surrender the premises to Lessor in compliance with the following conditions: (a) No damages to the premise, or appliances, beyond fair wear and tear. Dirt is not fair wear and tear. 3 SAlOIS SHUFF, FLOWER & LINDSAY AlTORNEVS-AT-UW 26 W. High Street Carlisle, PA (b) The entire premises, including range, bathrooms, closets, cabinets, and wall to wall carpeting must be cleaned. (c) No stickers, scratches or holes on walls... Tenants must remove all personal property not belonging to Lessor from the premises. Any property not removed shall be considered abandoned..." (Paragraph 18) 5. Defendant vacated the aforesaid premises on June 25, 2001, leaving the premises in a significantly damaged condition in breach of the terms of the Lease as set forth in more detail below. Within thirty days after surrender of the premises, Plaintiffs provided Tenant with a written list of damages, which exceeded the amount of $925.00 held as security deposit, in accordance with the provisions of 68 P.S. 9250.512. 6. The damages and other sums due under the aforesaid Lease are as follows: A. The sum of $320.00 due for trash removal (twice the actual cost of $160.00) as per item 6 of the Lease for removal of mattress, screen door, furniture, broken glass, and other miscellaneous refuse. B. Defendant broke a door and did not repair it properly, and the door frame support was pulled lose. The damage was $79.00 for the door and $115.00 for installation. c. Defendant discarded the heavy black porcelain drip pans from Plaintiff's brand new stove. The cost for new drip pans from manufacturer was $33.15. 4 SAlOIS SHUFF, FLOWER & LINDSAY ATI'ORNEYS'AT'LAW 26 W. High Street Carlisie. P A D. Replacement of floor tiles missing in laundry room and installation of floor covering to replace floor covering excessively worn in kitchen and laundry room, $2,615.00. E. Defendant nailed large nails and staples in wood trim. Estimate for removal of nails and staples from first and second floor windows, puttying holes, spot priming and applying coat of green paint to windows and door frames for damages of $600.00. F. Repair of damage to walls, plastic bead strip and woodwork from gauging, nicking and nails, as well as covering mismatched paint, primarily in three bedrooms and hallway for damages of $575.00. G. Repainting walls and ceilings in hallways and staircases constituting forty hours work, plus painting and supplies, $943.44. H. Four hours work plus supplies to repair kitchen counter, $80.00. I. Repair work and electrical work from laundry room fire $137.50. J. Eight hours work to wash and clean out 35 window storms and vacuum screens and sills and re-hang window in master bedroom, at $15.00 per hour, for damages of $120.00. K. Two hours to clean out, vacuum and wash all radiators, $30.00. L. Repair screen in living room by Carlisle Glass, $13.25. 5 SAIDIS SHUFF, FLOWER & LINDSAY A1TORNEYS'AT'LAW 26 W, High Street Carlisle, P A " M. Repair and replace screening on shed door and re-hang, $35.00. N, Damage requiring repainting of front staircase, which is badly scarred and marred, painting floor, replacing batteries in smoke detectors, replacing all outlet covers in the dining room to replace missing original metal wall outlet plates, replacing and reinstalling dented radiators, replacing broken trap in bathroom sink, repairing damage from phone line which had been installed and cut off with wire left hanging, cost of supplies, touch up paint and dents in refrigerator, removing and touching up nails in doors and cupboard, filling hole in garage vinyl siding, for a total cost of $285.00. o . Attomeys fees of $250.00 as per paragraph 15 of the Lease. 7. Defendant has refused to reimburse Plaintiffs for the aforesaid damages. WHEREFORE, Plaintiffs demand judgment against Defendant in the amount of $5,981.34, attorneys fees in the amount of $250.00 as per paragraph 15 of the Lease, costs, and interest at the legal rate of 6% from June 25, 2001, a total amount requiring submission to a Board of Arbitration for determination. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for the Plaintiff ames D. Flow r, r. I.D. #27742 26 West High Street Carlisle, PA 17013 (717) 243-6222 6 SAIDIS SHUFF, FLOWER & LINDSAY ATIOINEYS.AT.UW 26 W, High Street Carlisle, P A ~ VERIFICATION I hereby verify that the statements made in the within instrument are true and correct to the best of my knowledge, information and belief, I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: '"""\ \ 'l\ \ D "L- \ \ 7 '. (") r,; -.. qjH,: Tt~~'.: -l.. ,L;:( . :;:;:~ __I -, "':::) 1\.) n 0,'1 ,- ....,,) f',) -Q r:-:; :>~~';9 ~ (-:) , -+1 ,:,;) ;.:....~ I 11 ~.~:; t...O ~'1 -_J .'.'... <:7, =< 095047052902 . ~ CCS746 ******************** *STATEMENT OF COSTS* ******************** Page 37 5729/2002 Case No. 2002-00040 To: Dennis E. Lebo Cumberland County - Clerk of Courts 1 Courthouse Square Carlisle, pa 17013 RAMSAY JOSHUA MICHAEL 60 E LOUTHER ST APT. 2 CARLISLE, PA 17013 Case Totals 1281. 00 .00 1281.00 You are liable for the above costs ---------------------------------------------------------------------- Pursuant to Title 42 of Judicia~ and Judicial procedure, 42 PA CSA 9728, the Prothonotary is authorized to confess iudgment on all unpaid costs and issue an execution and place same in tlie fiands of the Sheriff for the collection. We trust you will give the above account your prompt attention. CUMBERLAND COUNTY ADULT PROBATION IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA Plaintiff VS, Joshua Michael Ramsay 735 W, Poplar Street York, PA 17404 CNIL ACTION - LAW NO. CNIL TERM / 2002-3005 Defendant! Address RE: NO, CR-40-2002 CRIMINAL TERM PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please mark satisfied the judgment, in favor of plaintiff Cumberland County Adult Probation and against the above-named defendant, previously entered pursuant to 42 Pa, C.S,A. Section 9728, Also, please prepare a Certificate of Satisfaction, ~frv-.C-~ Dennis E, Lebo, Clerk of Court Date: May 30, 2006 cc: Defendant Probation Clerk of Court 0 ,..., c = 0 = ;,c''''' 0-' -n ''0 (~'::, 3 ~-n i:~J , :J:>o ,,0 -< r11- >". ~r;; c. " w , 0 :DO r:' ;'..) 1.. ~ ,,,.,,1 e) -0 ~f~ ~~,.. :.:z.: '-" ...,,> C:. -"7 w ~ .'-\ U1 ?D N -<