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HomeMy WebLinkAbout94-02747 ~ 4 ~ . "J -...: ~ .\ ~ ~ ~ '= \1 , \J ~~ ~ ~ "- ~ " ro , ~ -g:, . \-i,j '" -",", ,,", -,' ~ \J-.;,J '.......... \ .. r -~--: \~ ~J ... (\-...!.C-j '::I - ., ., 'J ~i ~ ~I P i. · ~ ~~ ~ ~ t:S Ul +' ~I~~ ~~ .... .... '... +' .~ ~ '" I II) . .... ~ 8 ~ ~ 8 . ~~ ~~ . ...:I ~ :.:J ~ :><: , . 7' , .\.. ""'I (C'- ""'" 'C\ I" ..). r~ ;j \S- '-0 ~ . .J ) -.. ..I ,;. ~ ~Q:; ~r- ':0~ ...... -s.. ~ ..S\ d - _J '~ ij .c. .--- ~.... CJ t"...., '-..: \ 8.... J- ""....---- ") '" <:,J -:j- <) ~ . -..... I ~ ~ ~ ~ ~ ~~~s~ ilIW;2;ij-< \l - 0, 1l ~ ~ It iil .. ~ iI ::J i>- ::i 0 z ~ 0..... .>l .: ~ ;i.;J ~ ~ o i: 0 ~ ::i :z: ~ o ~ ~ I .a . . ~, - , I . . . . . OOOII4-00030IMay 4. 1994/JLH/AAKlMH/34973 JAMES 1WIGG tla STOUGH'S MOBILE HOME PARK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA NO. 14- ,;).74 7 {l~LJ Plaintiff vs. CIVIL ACTION - LAW KIMBERLY L. SOULE, CONFESSION OF JUDGMENT Defendant CONFESSION OF JUDGMENT Pursuant to the authority contained in the Warrant of Attorney, a copy of which is attached to the Complaint ~ filed in this action, I appear for the . Il!fud:IJt aD a::nfiss julJTmt in fcMr of tre Plaintiff aD a;Jrlmt: tre refa'd:nt, 1<lnl:e::ly L. S:1ll.e. as fbl..laoB: Unpaid Rent Late Fees Attorney's Collection Fee TOTAL $2,075.00 250.00 348.75 $2,673.75 JOHNSON, DUFFIE, STEWART & WEIDNER Date: \ - / 7 - <J 'I By~ '1. tJ;:; Jos ph L. Hitchings Attorney 1.0. No, 65551 30 I Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Plaintiff ..l.5-11-'i4 ,\; pI 'kl.lt~,...u:~...~,..,,,h.,, o.;,f(. IU'lk, ~tu. A'l'IJ, 'It Jo,..p;' Mc""'J' ' G6, OOOI14-00030/May 4. t994/JLH/AAK/MHI34973 , . '. JAMES 1WIGG lIa STOUGH'S MOBILE HOME PARK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. Plaintiff vs. CIVIL ACTION - LAW CONFESS[ON OF JUDGMENT KIMBERLY L. SOULE, Defendant COMPLAINT PURSUANT TO Po.R.C.P.P. 295Hbl FOR CONFESSION OF JUDGMENT FOR MONEY DAMAGES AND NOW, comes the Plaintiff by and througb their undersigned attorneys, Johnson, Duffie, Stewart & Weidner and in support of their Complaint for Confession of Judgment for Money Damages avers as follows: 1. The Plaintiff, James Twigg, is the owner of Stough's Mobile Home Park, an entity doing business in the Commonwealth of Pennsylvania having an office or principal place of business at 64-A Detroit A venue, Mechanicsburg, Cumberland County, Pennsylvania [7055. 2, The Defendant, Kimberly L, Soule, is an adult individual currently residing at 5246 Meadowbrook Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. On or about May 4, 1992, Plaintiff leased the premises at 93 Princess Boulevard, Mechanicsburg, Cumberland County, Pennsylvania, to the Defendant under a mobil home site lease agreement, a true and correct copy of which is attached hereto, incorporated herein by reference and marked as Exhibit" A." 4. Jerry Simpson is the manager of Stough's Mobile Home Park and an authorized agent for the Plaintiff. 5. Said lease agreement has not been assigned by the Plaintiff, The lease agreement requires the Defendant to pay unto Plaintiff a monthly rental of $215 ,00, which was increased to $235,()() effective January [, [994, payable in advance on the first day of each month. I OOOII4-000301May 4, 1994IJLH/MKlMHI34973 6. The Stough's Mobile Home Park rules and regulations provided to the Defendant by the Plaintiff and made pan of the lease agreement by Paragraph 20, provides that any rents not received by the fifth day of each month will receive a late charge of $25.00 per month. A true and correct copy of the applicable sections of the park rules and regulations are attached hereto, incorporated herein by reference and marked as Exhibit "B." 7. As a result of the Defendant's failure to make the monthly rental payments, there is due and owing to the Plaintiff from the Defendant the sum of $2,325.00 for back rent and late fees under the terms of the lease agreement. A true and correct copy of the breakdown of the rent delinquency Is attached hereto. incorporated herein by refertnce, and marked as Exhibit "C." 8. Despite repeated demands, the Defendant has failed to pay in full the back rent owing or to pay any pan thereof as required under the terms of the lease agreement. 9. Under the terms of lease agreement, specifically paragraph 17, the Defendant is obligated to pay to the Plaintiff the expenses of collection, including attorney's fees of 15% of the amount duly owing. 10. There is justly due and owing to the Plaintiff from the Defendant on account of the aforesaid breach of the lease agreement, the sum of $2,673.75, calculated as follows: Unpaid Rent Late Fees Attorney's Collection Fee TOTAL $2,075.00 250.00 348.75 $2,673.75 11. As a result of the Defendant's default under the lease agreement, the Plaintiff Is exercising his right under the lease agreement to confess judgment against the Defendant. OOOI14-000301MlY 4, 1994/JLH/AAKlMHI34973 WHEREFORE, the Plaintiff demands judgment against the Defendant in the total amount of $2,673.75, as authorized in the warrant of attorney in the Lease Agreement. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER By: Jos h L. Hitchings I.D. No, 65551 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 Attorneys for Plaintiff OOOII4-00030/May 4, 1994/JLH/AAKlMH/34913 VERIFICATION I, Jerry Simpson, Manager of Slough's Mobile Home Park, verify that I am authorized to make the statements herein and that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. A4904 relating to unsworn falsification to authorities. Impson Dated:~ -,. ~'.'l'.""'~'''ll '."':n",'Q W', ~<..nlo @ . . .. exhibit A _._" -- S'roUGH'S MJBILE IOIE PARI< , . '. . c/o REGEN::Y IICMES, INC. 7099 CARLISLE PIKE CARLISLE, PENNSYLV1INIJ\ 17013 wr NUMBER 'i 3 Pn lilt" e ~:, ::;. LFJ\SE J\GREEMENl' Ml\DE THIS DAY CF 1Ylt1 'f 11 -l h , 19 .,.2 , by and between smlGH'S LESSOR and E(1I'r ~'mdU tl~d<~AII ("S~ulf> { MJBILE HCME PARI<, LESSEE. WHEREAS, lessor owns and operates a Il'Obile hare park in which lessee desires to occupy a ndJile hare site. tOi THIS J\GREEMENl' WIWESSEmI, that the parties hereto, for and in consideration of the mutual covenants <Xlntained herein, and intending to be legally bound hereby, agree as follows: 00 1. '!he rent shall be $ ~I S"" -- day of each Il'Onth. . per Il'Onth, payable'oo the first day of 191'1-, P his option, 2. 'lhis lease shall be for a term of one Il'Onth, ~ing on the first , 19~, and terminate on the last day of Afti, _ , at a lding over by the tenant may be <Xlnstrued bY e lessor, at as a renewal of this lease for another like term and condition of this lease. 3. Occupants. Tenant and Landlord agree the following persons and no other will occupy the leased premises. NI\ME ?"l2fc ~iIh kl'M6-e..h/ ,so1J L e AGE '2'1 72. 4. All new tenants after June 1, 1986 shall, upon execution of this lease, deposit with Landlord as security for the perfomance of all the terms, covenants and <Xlnditions of this lease, a sun in the arrount of one nonth's rent, to be retained by the Landlord until the end of the original term and any extended tems of this lease. Upon termination of this lease, by default or othendse, the security deposit shall be returned to tenant, less any charge for damage to the leased premises, rent arrearages, or charges treated as rent arrearages. Tenant agrees to leave a forwarding address with the Landlord upon vacation of the leased premises to facilitate the return of the security deposit as above set forth. 5. ':the lessee agrees to and shall save, hold and keep harmless and indamify the lessor fran and for any and all payrrents, expenses, <Xlsts, attorneys fees and fran and for any and all claims and liabilities for losses or damage to property or injuries to persons occasioned wholly or in part by or resulting fran any act or anissions by the lessee or the Lessee's guests, licensees, invitees, or for any cause or reason whatsoever arising out of or by reason of the occupancy by the lessee. 6. If the demised premises shall be taken under eminent danain or c:ondennation proceedings, or if the lessor conveys the said premises to any governmental authorities seeking to take the sa.id p1"emises, or if tl1ero is a change in use of the park land, or parts thereof, or termination of the park, then this lease. at the option of the lessor, shall terminate and the term hereof sha1l end as such date as the lessor shall fix by notice. lessee shall have no claim or interest in the CCJTqJensation received by lessor for such taking. 7. If the lessee shall fail to CCJTply with any <Xlndi tions and <Xlvenants hereof, the lessor may perform such conditions and <Xlvenants, at the <Xlst and expense of the lessee, and the said cost and expenses shall be added to the next installment of rent and shall be payable as such. . . '. . B. The lessee agrees that the lessor and the lessor's agents, E!lTt>loyees or other representatives, shall have the right to enter into and upon the said premises consisting of the lot which is the subject of this Lease, or any part thereof, at all reasonable hours, for the purpose of exmnining the sarre or making such repair or alterations therein as may be necessary for the safety and preservation thereof. This clause shall not be deenEd to be a covenant by the Lessor nor be construed to create an obligation on the part of the lessor to make such inspection or repairs. 9. All goods and personal property of any kind in or upon the leased premises shall be the sole responsibility of the lessee, and in no event shall Lessor be liable for any loss or damage to said goods or property for any reason whatsoever. 10. The Lessee shall take good care of the premises and shall maintain the premises in good condition, and upon vacating the premises, either at the expiration of the tenn or for other reasons, shall deliver the rented premises in good order and condition, wear and tear fran a reasonable use thereof, and damage by the elerrents not resulting fran the neglect or fault of the lessee excepted. The lessee shall neither encunber nor obstruct the sidewalks, driveways or yards, but shall keep and maintain the same in aclean condition, free fran debris, trash, refuse, snow and ice. lessee further agrees to maintain the premises so that grass or other grolUld cover, excluding shrubs, trees and flCMers, shall not be permitted to exceed three inches in heigh~. . . . . \ 11. The lessee may not sublet the premises or any portion or part thereof. The lessee may sell the nobile hate belonging to the lessee, but, following the sale, if the rrobile hare is to remain in the park with a new owner, written approval of the new lessee is required, and this approvall1UlSt be obtained prior to sale. 12. lessor shall not be liable for failure to give possession of the leased premises to the lessee upon the effective date of this lease. In such event, rental payment and other fees, charges or assessments shall not commence lUltil possession is given to, or is made available to the lessee, and the term of the lease shall be extended accordingly. 13. Any equiprent, fixtures, goods or other property of the lessee not raroved by the lessee upon quitting, vacating or abandorurent of the premises by the lessee, or upon the lessee's eviction, shall be considered as abandoned and the lessor shall have the right, without notice to the lessee, to sell or otherwise dispose of the sarre at the expense of the lessee and shall not be accolUltable to the lessee for any part of the proceeds of the sale, if any. 14. The lessor shall not be liable for any damage or injury which may be sustained by the lessee or any other persons, as a consequence of the failure, breakage. leakage or obstruction of the water, sewer, waste, or soil pipes, or the electrical, gas or oil systE!l1; or by reason of the elE!ITEnts; or resulting fran the carelessness, negligence or inproper conduct on the part of any other lessee or the lessor or the lessor's or this or any other lessee's agents, guests, licensees, invitees, sublessees, assignees or successors; or attributable to any interference with, interruption of or failure, beyond the control of the lessor, of any services to be furnished or supplied by the lessor. 15. The various rights and rerredies of the lessor expressed herein are cumulative, and the failure of the lessor to enforce any such right or renEdy at any time against the lessee shall nol: consl:itute a waiver thereof. 16. lessee shall pay all county, municipal and school district real estate taxes assessed and levied against his hate and personal property, and shall furnish lessor, when requested, with proof of payrrent of sarre. Failure to pay such taxes, when due shall be a violation of the lease, rules, or regulations, if any, and constitute default thereunder . 17. The lessee hereby confesses judgnent in favor of the said lessor for the whole curolUll: of the rent al: any tine remaining lUlpaid, and any other charges incurred hereunder, whether the sarro shall have been due or not, waiving stay of execution. inquisition and all 'li4ID.J.5!.WS now in force or which may hereafter be passed, and au zes e ad g 0 ~S\) per cent attorney's commission for collection; and further does hereby, upon the breach of any of the conditions of this lease, including non- payrrent of rent or violation of rules and regulations, if any, authorize any attorney of any court of record to appear for him and enter an amicable action of ejecboont and confess a judgnent of ejectJrent therein for the premises herein described and does authorize the imrediate issuing of a writ of possession and execution for cost without asking leave of the court. A photocopy of this lease may be used for confession of judgnent for lUlpaid rent, or for confession of judgrrent in ejectrrent. Such rerredies shall be cumulative, and not alternative, and may be re-exercised as necessary. '. '. '. J.8. The Lessee shall conform to all rules and regulations made by the lessor for the use and governnent and managerrent of this rrobile hare park to protect the entire pranises of the Lessor and to further the general ccrnfort and welfare of 011 of the occupants, which rules and regulations, and any changes thereto hereafter adopted, are attached hereto and incorporated herein or reference, and made a part hereof, and are covenants and conditions of this Lease, the sarre as if fully set forth herein. Lessee shall furnish Lessee with notice of all changes in said rules and regulations. Lessee acJcrn.1ledges receipt of a copy of such regulations concurrent with execution of this Lease. 19. If proceedings shall be CCI'lIOOIlced by Landlord to recover possession under the J\cts of Assenbly, either at the end of the term or sooner tenninations of this lease, or for nonpayrrent of rent, or any other reason, tenant specifically waives the right to fifteen or thirty days' notice required by the 1Ict of 1\ssembly of l\pril 28, 1983, P.L 202, and agrees that five days' notice shall be sufficient in either or any such case. 20. The Lease, and the aforesaid rules and regulations, constitute the entire agreatent be~ the parties and sarre is not subject to any orall1Ddification. Further, this agreenent shall be legally binding upon the parties hereto, and their respective heirs, successors and assigns. If any information provided by the Lessee, whether by way of background, financial or otherwise, which has induced the Lessor to enter into this tease, is found by the Lessor to be false, the Lease shall, at the option of the Lessor and upon notice to the Lessee, be null and void and the Lessee shall be consi~red a trespasser. ..', 21. Lessor may fran tine to tine m:xlify, change or revoke rules for the M:lbile HaTe Park and upon notice to the tenant, these rules shall be incorporated herein with the sarre force and effect as though they were in force at the t:iJre this Lease was executed. 22. Lessee agrees that he has read this Lease Jlgreerrent, understands its terms and the rules and regulations of the M:lbile HaTe Park and agrees to be bound thereby. TIlE TENANT MUST GIVE ]>{X LEI\ST 30 DAYS NOl'ICE IN WRIT:rn3 PRIOR 'ro MJIlING. IT IS TIlE RESPOOSIBILI'lY OF TIlE TENANT 'ro PROVIDE MI\Nl\GEMEN1' WITH ALL NEX::ESSARY t'CM'LEl'ED STATE OR LOCAL 00VE:m0I1ENl' E'OIMl. IN wrrnESS WHEREOF, the parties hereto have hereunder set their hands and seals the day and year first above written. Witness BY: >J~ Q~JfT o w~ . . '. '. '. DISCLOSURE FOR roNFESSIONS OF JUDGIENl' I JIM (m; ARE) SIGlIOO, 'lUIS DAY OF "".:!'i 4 -t h , 19t12. , A LEASE FOR A /oDBILE HCl>IE SITE Kr wr NO. ~ AT S'roUGHS IDBILE HQoIE PARK FOR AN INITIAL TERM OF eM: M:Nl'II, AND M:Nl'H 'IO KNl'J1 'l'IIEREAPl'ER, WHICH WIIL OBLIGATE ME (US) TO A M:Nl'HLY RENrAL OBUGATIQl OF $ '? \ 5 0 0 EAOl, PAYABIE :m l\IJVAN:E. IN~TIALS:_Y) " A REPRESENl'ATIVE OF S'roUGHS IDBIIE H<J.IE PARK HAS EXPIAINED TO ME (US) THAT THE LEASE CDNl'AINS IDmIOO THAT WJUID PERMIT '!lIE LANDIDRD TO Em'ER JUJXM:N1' AGAINST ME (US) Kr,THE CXXlRl'KXJSE FOR (1) THE ENl'IRE UNPAID BALl\NCE OF THE RENl'AL OBLIGATIOOS OF THE LEASE IN THE E.VENl' THAT I (WE) ARE IN DEFAULT IN 'mE PAYMENl' OF ANY INS'l'ALlMEm'S OF RENT OR ANY 0l'IIER SlMS DUE THE I/lNDIDRD UNDER rilE LEASE THAT ~ UNPAID, AND/OR (2) IM1EDIATE REPOSSESSIoo OF THE /oDBIIE H<J.IE SITE PREMISES, IN THE EVEN!' THAT I (WE) BREAK OR E.VADE ANY OF 'mE COVEW\NTS OR COODITIOOS OF '!lIE LEASE, WITH<l1r TAB RIGHT 'IO jlAVE PREJUDGlENl' NOl'ICE AND HEARIOO, WITIlOl1r THE RIGHT'IO HAVE THE BURDEN OF ~ 00 THE OONERS. AND WITIlaJr TIlE RIGm' 'IO AVOID 'mE EXPalSE OF OP~ OR STRIK:IOO A ~ JUDGIENl', AND THAT THE JUI:lGIENl' MAY BE oo~ AND Em'ORCED Bl{ ANY LEXiAL MEANS. INITIALS: J~ ~. IN SIGNING TIlE LEASE, I 11M (WE ARE) KNCMINGLY, UNDERSTANDINGLY AND VOUMl'ARILY WAIVING MY (OOR) RIG/ITS TO RESIST THE ENl'RY OF JUJXM:N1' AGAINST ME (US) Kr '!lIE COORI'HOUSE, AND 11M (ARE) CONSENl'ING TO THE CXJNFESSIGlS OF JUDGlENl'. INITIALS:/ -U- /.:(' (I'IE) CERl'IFY THAT MY (OUR) ANNUAL INC:XH: E:l1rF.P.r1,S (IS LESS '!l1l\N) $10,000.00, TlIAT TIlE BLANKS IN TIllS DISCLOSURE WERE FILLED IN WHE2l I (WE) INITIAUD AND SIGNED IT, AlID THAT I (WE) ROCEIVED A OOPY Kr THE TIME OF SIGlING. LESSEE(S) : ()~-l .JJ~- ~g~, %(/ WI'lllESS "-_ (SEAL) @ SEAL) WE HAVE RECEIVED A OOPY OF RULES AND REXiULATIGlS OF S'roUGHS PARK lNCWDING A COPY OF PA. tcr NO. 261 RELATING TO THE REASalS GlE MAY BE (J. (J~/----- 'y-) r / h- ..:-4Yj 1fi1NES5 (J "", u- WI'lNESS ~ (SEAL) (SEAL) ;"r. . -. . : - . - : ': -; "i:" :(.: " ,- . I . . "...' , . . S':':l..Gi :. ?:l.IU:S All!) PJD.:L?I!I Cl-lS SEl:.":la; 11 ~ :A. AppHc:.aUcn tel' f.II1da.'\C')' - All proposed t.!l.'l.lI.-:~ lll::l: ~~ea 6.'\ Applic:.a::.ion ~:: Ru:.dL-..:-/, L-,4 ::.\0. &~~CAt.:.C~, ~: =.e ~r~ t::r~c= ;Q t.~ &rrlvZll of tr.e tenAnt'. m:lbUe nat.. /oIInAqtmIn1: re.M:\IU the ri9ht: tol al IletUM aatu.ttanCll Ind ret\n1 any lldvance doeposits a:ld ~~ 1:0 l::yoM IotlCIM :n::c:.lll hare is nor. lI.:ltler-~le i1l '\Pr>"A-lU1C8 W c:cncU.~CZ'l. bl Poatua. to accepr. UtY t\n:1ln renr. fran anycns WhO does not. ma.i.r:t:a.i1l his :c:c:.:"o :l;r:IS ~. A :a.a.r., "~6t~ri o:n.ii.t.l.al. LB. i'nor to e:'Itrt to the llCblle hare pult. a cndit c:neclc ...'ill be ::-ollda of all prespee-.J.v. t.e:'..a.'\tI :,:, &t~ f:...~..a.-'::iA.l. reBjXxl.u.::lU~, lC. A charactar retennoe lIWt l:llt p:ov1de4 by all teMnt.S an:S A lArJ..sf~ repon lIUIt be ~ before ac::eptal'.c:e W1l1 1:1I C]t'L'\w. 1.0. A lecuri'.:'/ cSeposit on all rrIN t.eMn:.l after June 1. 1.985 W111 be payable in tile CTDIrl t ot l:IrW 1\'CI11:l1'. ren 1:. Such aec\:r 1 ~ depoei l: will be refl.ln4aQ 1e \lj;lCI"I II'D\1ina' your hala 0\:; of Sto'~. ~~ce to IlCY8 cue 1lU8; be q1'.I'e1\ t:) t.'1e narA9ll>,.."r. at: leu; 'n'.u-:y (lOI dar- 111 Idvanoe. Nouce 1IUlIt: be in writin;. ].E. Rant.S ue due CXl or betfo" tile first day of e.!Idl Il'Cr1th. Any rtln~ rot received ~ fit th day of uc::h rrcntJ'l will .nlOBi YIt . ate c:harqe of 'I'en ($10. 00) Col1an ~ will be im:ruaed at: the rllte ot $1.00 Q'le COUllI' per day until rent is pa1.d 111 ~u.ll. J'. nw nlr.ter of pe.I:IlWliIl\t ~t5 i:'1 you: hare, inelud.irq c:h.11dnn, &r.a.l.l be lir.lit to 1'0'.: (4) pc' .1ni~ lIIX)ile hcmI IInd Fiw (S) per double-'Wi.de lI'Cbile hare. en. fsnill' , cnJ.y, Ih&U be pemi1:ted to o::cupy A ....v-,n. hare. Q.leStlI...no visit fc · puled of rl~ (lS) c:llIy1I or l.cInge.r IlUlU: reqist:e.r with ~;, and t.'1a re:' will be 1.ncreued 17f riw 1$5.00) Collan per c;uut per lICIllt.'1. la. ~r. ~I the riqht to refuse admittance to anyoner Also to decli."lIl to al~ any apace to be ~1ed 17f, and to &cOI!pt 5rtf further rent fran, any parsa not delitwd. ~;:uer.oes w right to I5ecido and det.e=:'.i.ne which teMl1U or prollp....J..... t:ANnu ere ~le and to eject any c:bjecticna.b1e per5a".ll 'at'IO c:.aua.. . dilturtlanoe or createS . nuisance. Manaqelrent sh.all be 101e judge of wh i. c:b jec:t.i.ctl&b 1. and ""'.at o:nsti 1:Ul:aI a dJ..sturl:ll.nc.. lJl. ~ltJ.nu of illY fam11y will be di.KuNed privately 'a'itJ'l the par-.J.cular flr.lily 1l1VlJ1Yw:l. L, C4.IIU W\"oaA 1XIl'(:l1ain~ tcntinue aner me fsnily has been properly /1Ot.lt~, to.... ~t w:.~ qive te:'llntl!'lOl:.ioe to vaca.te t.;..e pa..'it. - 1 - LAUREL HILLS NORTH TEL No.717-732-8955 May 5.94 15:03 No.OOG P.02 . ". Stough's Mobile Home Park 64 A Detruit Avenue Mechanlcsburs. PA 170" 5/5194 KimbIrIy Soule Erik Smith 93 Prill\:Cll Blvd. 1993 Rento-d: Auj. 535.00 rent, 525.00 lato SCIpI. $225.00'" $151110 Oct. $225,00 rem, S2~ latt Nov, 122'.00 rent, $2'.00 late 000. s:m.oo I'IIIlt 125.00 late 1994 Rent Owed: January 5235.00 rent, $25.00 lato February 5235.00 I'tIIlt. 525.00 Jilt Mardi $235.00 rtnt, $25.00 lat, April $235.00 rent, 125.00 late May $235.00 rom. $25.00 late