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