HomeMy WebLinkAbout94-06933
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HARRIET E. WHITE AND
DALE WHITE,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
94 - 6933
CIVIL TERM
KIP ROUT SONG AND
KAREN ROUTSONG,
Defendants
:
JURY TRIAL DEMANDED
COMPlAINT
NOW COMES, Plaintiffs, Harriet E. White and Dale White, by and
through their attorney, John L. Perry, Esquire, and state the
following:
1. Plaintiffs, Harriet E. White and Dale White, are adult
individuals residing at 580 North Middleton Road, Carlisle, PA
17013.
2. Defendants, Kip Routsong and Karen Routsong, are adult
individuals residing at 64 Faith circle, Carlisle, PA 17013.
3. On or about March 7, 1993, Defendants agreed to rent,
from Plaintiff 0, a mobile home located on Lot 112, 548 North
Middleton Road, carlisle, PA, for the sum of four hundred dollars
($400.00) per month plus a security deposit of four hundred
dollars.
4. This rental agreement was subject to written rules and
regulations provided to Defendants by Plaintiffs and attached
herein as Plaintiff's Exhibit "A".
5. On or about March 12, 1993, Defendants paid to plaintiffs
the sum of four hundred dollars ($400.00) as a security deposit, as
well as the sum of three hundred twenty two dollars and seventy
five cents ($322.75) as pro-rated rent for the period of March 7
through March 31, 1993.
6. On July 7, 1994, plaintiffs served Defendants with
written notice to vacate the premises within thirty d~ys because of
violations of the written rules and regulations pertaining to this
rental. A copy of this notice is attached as plaintiff's Exhibit
"Bit.
7. Defendants did vacate the premises on August 14, 1994.
8. Defendants have failed to pay rent to plaintiffs for the
fourteen days from July 7, 1994 until August 14, 1994.
9. Defendants have failed to refill the oil tank as required
by paragraph sixteen (16) of the rules and regulations governing
this rental.
10. Defendants have failed to pay their share of the water
bill as required by paragraph eight (8) of the rules and
regulations governing this rental.
11. Because of Defendants failure to properly maintain and
care for the premises as required by paragraph 1, 2 and 10 of the
rules and regulations governing this rental, Plaintiffs have
incurred significant expense for cleaning, hauling, repairs and
replacement of items damaged by Defendants, as follows:
a)
b)
c)
d)
e)
f)
g)
h)
i)
j)
k)
1)
m)
Drywall, paneling and other materials
Shower rod. . . .
Carpet. . . . . .
Screen. . . . . .
Toilet seat . . . . . .
storm window and frame.
Bathtub faucet. . . . .
Refrigerator. . . . . . .
Labor, general cleaning-5 hours. . . . . .
Labor to hang drywall and paneling-2 hours.
Labor to lay carpet . .... . . . . .
Labor and supplies to repair and paint walls
in master bedroom
Hauling of trash.
$ 30.35
$ 8.26
$203.18
$ 18.66
$ 9.52
$ 84.80
$ 28.57
$150.00
$ 50.00
$ 50.00
$ 80.00
$193.76
$ 50.00
$957.10
TOTAL . . . . . .
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Qne Year Rerital ^~eement Which ~
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Convert !2. ~Ionth 12. Month teaee Aftllr
One Year
Rul9lfirn[1nr~ulatione
The following rules and regulatione referred to in the above
~~oe~Ant ar, ~eq~i~A4 to br qb~~rved b~ thA Tenant as W~tl as
~':-'lnltIntJQf.~ Qt. hie' family, gueets, servants 'oremployees -shall
~e 'birldingWupon the tenant ~~d are expressly made a part of this
Agreement. Violation of any rule or regulation shall have the
same torce and eftect as the violation of any term or condition
ot the Agreement and shall oauseJlegal1 action to be taken tor
eviction trom the leased premises. Dale R. White Sr. reserves
the right to change and add or subract additional rules and
regulations from time to time as management may See necessary..
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1. Grounds
Do not throw garbage around or have uneightly artioles laying
around outside on lot. It is the tenants responsiblity to have
garbage hauled out, no garbage is allowed to pill up at ~ny time.
No veohicles waShed or j~ked vechicles allowed on t~e property.
2. Care ot Premises
'~Tenantagrees to maintain premises in good condition at all times.
No nails will be put in the walls for any reason.
~.. MaintentenancA of Utilities
. Tenant:s responsibility to supply' all their Utilities.
No rags, sweepings, matchee, ashes, sanitary napkins, tampsxs,
. diaper linere,or any other improper articles shall be thrown into
-""the. plumbin~xture8"nor-harm:tul dolean1ng-mater1111s be used.
The cost. of any damages resulting to the plumbing shall be borne
by the tenant."
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4. Laundry
Tenant may use landlord"s Clothes llne ~f tney wish to do so.
No Washer' allowed "Il l'\!l.lu.le hO/l'lB.
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!). Park1ng
Park~ng for two vehioles only.
6. Tenant will be liable for any persons visiting mobile home
on lot P.-l-. 584 N. Middleton Road, CarliSle, Pa. 1701'.
'1.00 Charge shall be paid for each person staying o;er,night.
hours: (10 P.M. to 7 A.M.)
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7. Lot rent is to be paid in cash or Certified Check Only,
no personal checks accepted.
Tenant must give a '0 day notice (written) before moving.
Plaintif's EXHIBIT "A"
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Plantif's EXHIBIT "0"
HARRIET E. WHITE AND
DALE WHITE,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
.
.
94 - 6933
CIVIL TERM
KIP ROUT SONG AND
KAREN ROUTSONG,
Defendants
JURY TRIAL DEMANDED
AJIEIIDBD COIIPlA[H'l'
NOW COMES, plaintiffs, Harriet E. White and Dale White, by and
through their attorney, John L. Perry, Esquire, and state the
following:
1. plaintiffs, Harriet E. white and Dale White, are adult
individuals residing at 580 North Middleton Road, Carlisle, PA
17013.
2. Defendants, Kip Routsong and Karen Routsong, are adult
individuals residing at 64 Faith Circle, carlisle, PA 17013.
3. On or about March 7, 1993, Defendants agreed to rent,
from plaintiffs, a mobile home located on Lot #2, 548 North
Middleton Road, Carlisle, PA, for the sum of four hundred dollars
($400.00) per month plus a security deposit of four hundred
dollars.
4. This rental agreement was subject to written rules and
regulations provided to Defendants by plaintiffs and attached
herein as plaintiff's Exhibit "A".
5. On or about March 12, 1993, Defendants paid to Plaintiffs
the sum of four hundred dollars ($400.00) as a security deposit, as
well as the sum of three hundred twenty two dollars and seventy
five cents ($322.75) as pro-rated rent for the period of March 7
through March 31, 1993.
6. On July 7, 1994, plaintiffs served Defendants with
written notice to vacate the premises within thirty days because of
violations of the written rules and regulations pertaining to this
rental. A copy of this notice is attached as Plaintiff's Exhibit
"B",
7. Defendants did vacate the premises on August 7, 1994.
8. Defendants have failed to pay rent to Plaintiffs for the
fourteen days from August 1, 1994 until August 7, 1994.
9. Defendants have failed to refill the oil tank as required
by paragraph sixteen (16) of the rules and regulations governing
this rental.
10. Detendants have failed to pay their share of the water
bill as required by paragraph eight (8) of the rules and
regulations governing this rental.
11. Because of Defendants failure to properly maintain and
care for the premises as required by paragraph 1, 2 and 10 of the
rules and regulations governing this rental, Plaintiffs have
incurred significant expense for cleaning, hauling, repairs and
replacement of items damaged by Defendants, as follows:
a)
b)
c)
d)
e)
f)
g)
h)
i)
j)
k)
1)
m)
Drywall, paneling and other materials
Shower rod. . . .
carpet. . . . . .
Screen. . . . . . . .
Toilet seat . . . . . .
Storm window and frame.
Bathtub faucet. . . . .
Refrigerator. . . . . . .
Labor, general c1eaning-5 hours. . . . . .
Labor to hang drywall and paneling-2 hours.
Labor to lay carpet .
Labor and supplies to repair and paint walls
in master bedroom
Hauling of trash.
$ 30.35
$ 8.26
$203.18
$ 18.66
$ 9.52
$ 84.80
$ 28.57
$150.00
$ 50.00
$ 50.00
$ 80.00
$193.76
$ 50.00
$957.10
. . . . . . . . .
TOTAL . . . . . .
~ ~ Rental A~reement WhicU ~
Convert 12 Month ~ Month Leaae Att~r
One Year
Rule n e ulatio B
~he toll owing rules and regulationa referred to in the above
~oe~ftnt ar~ ~eq~i~ft4 t9 b~ qb~~r!ed by ~ft ~enant as ~etl as
. "!ftWlntlllrl! Qto hill' family, guesta, aervanta .or 'employees 'llhall
be 'bind1ng~upon the tenant ~~d are expresSly made a part of this
Agreement. Violation ot any rule or regulat10n ahall have the
same toroe and etteot aa the v101ation ot any term or oondition
ot the Agreement and shall oauseilsgalJaotion to be taken tor
eviotion trom the leaaed premiaes. Dale R. White Sr. reserve a
the right to ohange and add or aubraot additional rulea and
reoulat10ns trom time to time as management may see neoeooary..
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1. Gllounda
Do not throw garbage around or have unaightly artiolea laying
around outoide on lot. It i8 the tenanto responoib11ty to have
garbage hauled out, nO garbage ia allowed to pill up at hny time.
~o veohioleo waahed or junked veohiol~a allowed on t~e property.
2. Care.2! Premises
'~~enant agrees to maintain premiaes in good oondit10n at all times.
~o na11. w111 be put 1n the walle tor any reaaon.
,
~., Maintentenance of Utilitiea
,~enant:s responoibility to oupply'sll their Ut11it1eo.
, No rags, sweep1ngs, matchea, aahea, sanitary napkins, tampaxs,
~ diaper IinerR,or any other improper articles ahall be thrown into
ne-:~lumMn~xturell~ nor-ilarm:tul--cleanillg""lDaterilils be used.
~he 09st. ot any damages rasult1ng to the plumb1ng shall be borne
by the tenant." "
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4. Laundry
~enant may UOd land!ord"o Clothes llne ~t they wish to do BO.
o ~o Wa.sh\l~\ aJ.J.owed "n. l'I~_~ue hQOllB.
~. Park1ng
par~'~~r two veh101eo only.
6. ~enant will be liable tor any persona vio1t1ng mob11e home
on lot,#-l.... 584 N. M1ddleton Road, Carlisle, Pa. 1701'.
'1.00 Charge shall be pa1d tor aach person stay1ng 0;er,n1gbt.
hours: (10 P.M. to 7 A.M.)
7. Lot rent 18 to be paid in cash or Certit1ed Check Only,
,no personal oheoks accepted.
Tenant must g1ve a '0 day not1ce (written) before mov1ng.
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Plaintif's EXHIBIT "A"
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Water r,harp;e
Pay 1/3 ot water bill electrio or 1/2 it other space is ~ocoup1ed
Curfew (10 P.M. To 7 A.M.) No noise ot any kin~.
9.
10.
Sumcer must mcw grass, can't be higher than 4 inohes.
Winter must help to clear driveway ot snow with other tenant
in other space.
Will pay late oh~rges ot #1.00 a day with a minimum ot &5.00
regardless it it is only ono da;; late with rent. (Period
rent runs from last day ot the month at 12 p.m. Atter that
you will be Charged for being late.) Rent du. 1st ot eaoh
month. 1400.00 Security Deposit ot one month rent 8400.00.
'0 day notice will be ~iven it mobile home rent will be raised.
You will be, gi'ren a'letter to mcve if you oause any trouble
or loud noise or parties or you brea~an1 ot the rules and
regulations, '0 day notice.
No Pets.
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Must have renters Fire Insurande on personal property and
provide a ccpy of pOlicy to landlord.
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275 gallone at tenants
Tenant must till oil tank before moving
expense.
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On this the +-:-- day 0 ~', 199',
-aoKnow-red'g'eil receipt 6'rrU s's a e'
the undersigned
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Further agreed,that the landlord may discontinue' this'
agreement by gi~ing to the tenant the '0 day notice.
tenant agrees to abide by all rules and regulations, t
the landlord ncw stipulates or may stipula~e
In witness Whereot, The respective .parties hereto, intend to
be legally boun~. have Ret their hands and seals the date and
year_first above written.
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P1antif's EXHIBIT "An (2of2)
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Plantif I s EXIlIDI'l' "D"
21. Admitted in part, denied in part. Plaintiffs
specifically deny that the Defendants vacated the rental premises
on August 5, 1994. By way of further answer, defendants vacated
the rental property on August 7, 1994.
(a) Plaintiffs deny that Defendants owe Plaintiffs rent from
August 1 to August 5, 1994 in the amount of $64.52. By
way of further answer, Defendants owe Plaintiffs rent
from August 1 to August 7, 1994 in the amount of $90.32.
(b) Admitted.
(c) Admitted.
(d) Admitted.
By way of further answer, Defendants owe Plaintiffs for
replacement of carpeting, repair of walls and various
other items enumerated in the Notice provided to the
Defendants on August 22, 1994, which total $942.19.
22. Denied. Plaintiffs specifically deny that the
Defendants, on August 10, 1994 or at any other time, provided
Plaintiffs with a forwarding address in writing. By way of further
answer, Defendants did inform Plaintiffs, verbally, that they were
moving to Shippensburg, however, Defendants refused to provide a
specific address.
23. Denied. Plai~tiffs specifically deny that they owe or
have failed to remit any balance owed to Defendants. By way of
further answer, pursuant to the Notice dated August 22, 1994,
Defendants owe Plaintiffs for damages significantly in excess of
any security deposit.
24. This is a conclusion of law which requires no responsive
pleading. To the extent that a response is required, Plaintiffs
specifically deny any obligation to Defendants in that the
underlying facts, supported by Defendants own Exhibit "A", failed
to support this conclusion.
WHEREFORE, Plaintiffs request that Judgement be entered in
their favor and against Defendants in the amount of $542.19,
together with such other relief as this Court may deem appropriate.
COUH'l' II
25. This averment requires no responsive pleading.
26. Admitted.
27. Denied. Plaintiffs specifically deny that they entered
the mobile home rented by Defendants on numerous occasions between
March of 1993 and August of 1994. By way of further answer,
Plaintiffs did enter the mobile home rented by Defendants when they
were present for legitimate reasons with De~endants knowledge and
consent. Plaintiffs did enter on one occasion when the Defendants
were not present to remove a window air conditioner belonging to
the plaintiffs.
28. Plaintiffs specifically deny that they ever, on any
occasion, permitted or encouraged their dogs to defecate on the
mobile home lot rented by Defendants. Plaintiffs further deny that
Defendants made repeated requests that they keep their dogs off of
the mobile home lot rented by the Defendants. By way of further
answer, Plaintiffs at all times made reasonable attempts to keep
their dogs on that portion of Plaintiffs property not rented by the
Defendants.
29. Plaintiffs answer to paragraph 28 of Defendants'
Counterclaim is incorporated herein by reference. By way of
further answer, after reasonable investigation, Plaintiffs are
unable to form an opinion as to the truth of this averment and
therefore strict proof thereof is demanded at trial.
30. Denied. Plaintiffs specifically deny that their dogs
often growled at Defendants children or that their dogs in any way
frightened them to the extent that the children were unwilling to
play in the lot rented by Defendants.
31. Admitted in part, denied in part. Plaintiffs admit that
sometime in April of 1994, they moved a quantity of gravel onto a
portion of the lot rented by Defendants. Plaintiffs specifically
deny that this action in any way rendered the lot rented by
Defendants unsafe or unsuitable for their use. By way of further
answer, Plaintiffs did spread out this gravel using a plow. This
gravel was spread on a portion of the lot upon which no grass or
other ground cover was growing.
32. This is a conclusion of law to which no responsive
pleading is required. To the extent that an answer may be
l:'equired, Plaintiffs specifically deny the averments of this
paragraph.
33. Denied. Plaintiffs specifically deny that any actions on
their part reduced the use, enjoyment and value of the rental
premises, constituted invasion of privacy or produced stress,
aggravation, annoyance or inconvenience to Defendants.
34. This is an averment which requires no responsive
pleading.
WHEREFORE, Plaintiffs request that Judgement be entered in
their favor and against Defendants in the amount of $542.19
together with such other relief as this Court may deem appropriate.
COUJft' J:II
35. This is a conclusion of law which requires no responsive
pleading. To the extent that a reply may be required, Plaintiffs
hereby incorporate by reference their answers to Count 2 of
Defendants' Counterclaim.
WHEREFORE, plaintiffs request that Judgement be entered in
their favor and against Defendants in the amount of $542.19 as well
as such other relief as this Court may deem appropriate.
Respectfully submitted,
n L. Perry
torney for PIa
South Hanover
suite 207
Carlisle, PA 17103-3321
(717) 243-1477
HARRIET E. WHITE AND
DALE WHITE,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V.
KIP ROUTSONO AND KAREN
ROUTSONO,
Defendants
NO. 94-6933 CIVIL TERM
ANSWER TO AMENDED COMPLAINT
COME NOW the defendants, Kip Routsong and Karen Routsong, by
counsel, Philip C. Briganti, Esquire, Legal Services, Inc., and
in response to Plaintiffs' Amended Complaint, state as follows:
1. Admitted.
2. Admitted.
3. Admitted in part and denied in part. Defendants deny
that the mobile home they agreed to rent from Plaintiffs was
located on Lot 2, 548 North Middleton Road, Carlisle,
Pennsylvania. Rather, Defendants aver that the mobile home waa
located at Lot 2, 584 North Middleton Road, Carlisle,
Pennsylvania. Otherwise, Defendants admit the averments set
forth in Paragraph 3 of Plaintiffs' Complaint.
4. Admitted.
5. Admitted.
6. Admitted in part and denied in part. Defendants admit
that they received said written notice, but deny that they
violated the rules and regulations as set forth therein.
7. Denied. Defendants deny that they vacated the premises
on August 7, 1994. Rather, they aver that they vacated the
premises on August 5, 1994, and attempted to return their keys to
Plaintiff on that date. However, because Plaintiffs were not at
home, Defendants were unable to return the keys until Auguat 7,
1994.
8. Denied. Defendants deny that they have failed to pay
rent to Plaintiffs for the fourteen days from August 1, 1994
until August 7, 1994. There are not fourteen days between those
two dates. Moreover, Defendants deny that they owe Plaintiffs
rent for that entire period of time.
9. Admitted.
10. Denied. Defendants deny that they have failed to pay
their share of the water bill as required by Paragraph 8 of the
rules and regulations. By way of further answer, Defendants aver
that Plaintiffs never provided them with a copy of this bill.
11. Admitted in part and denied in part. Defendants admit
that they unintentionally damaged the paneling and shower rod.
However, Defendants deny that they failed to properly maintain
and care for the premises as required by Paragraphs 1, 2 and 10
of the rules and regulations governing this rental. Moreover,
they deny that Plaintiffs have incurred the expenses for
cleaning, hauling, repairs and replacement of the items set forth
in Paragraph 11 of Plaintiff's Complaint, except for the paneling
and shower rod. Defendants specifically deny that they caused or
are responsible for the remaining damages and amounts described
by Plaintiffs. Defendants deny that Plaintiffs' expenses total
$957.10.
12. Admitted in part and denied in part. Defendants deny
that they owe the amounts set forth in Paragraph 12 of
Plaintiffs' Complaint, except the fuel oil expense of $184.20.
Defendants also deny that Plaintiffs are entitled to retain their
entire security deposit of $400.00, to offset the amounts
Plaintiffs claim is owed by Defendants. Defendants repeat and
incorporate by reference their averments set forth in Paragraphs
1 through 11 herein.
~MATTER
13. Pursuant to 68 P.S. ~250.512(a), "Every landlord shall
within thirty days of termination of a lease or upon surrender
and acceptance of the leasehold premises, whichever first occurs,
provide a tenant with a written list of any damages to the
leasehold premises for which the landlord claims the tenant is
liable."
14. Moreover, 68 P.S. ~250.512(b) sets forth that "[A)ny
landlord who fails to provide a written list within thirty days,
as required [by 68 P.S. ~250.512(a)), shall forfeit all rights to
withhold any portion of sums held in escrow, including any unpaid
interest thereon, or to bring suit against the tenant for
damages to the leasehold premises."
15. On or about August 22, 1994, after Defendants had vacated
the rental premises, Plaintiffs provided Defendants with a
written "List of Repairs and Cleaning", a copy of which is
attached hereto as Defendants' Exhibit "A".
16. This list faiis to specify the following alleged
expenses of cleaning, hauling, repairs and replacement of items
for which Plaintiffs seek damages against Defendants: toilet seat
($9.52); storm window and frame ($84.80); bathtub faucet
($28.57); refrigerator ($150.00); labor, general cleaning - 5
hours ($50.00); and hauling of trash ($50.00).
17. Plaintiffs provided Defendants with no other written
list which included these alleged damages to the leasehold
premises within thirty (30) days after Defendants surrendered the
premises and the premises was accepted by Plaintiffs.
18. Accordingly, Plaintiffs cannot bring suit against
Defendants for the alleged damages described above in Paragraph
16, and cannot withhold these sums from Defendants' security
deposit.
WHEREFORE, Defendants request that the relief requested by
Plaintiffs be denied, and that judgment be entered in favor of
Defendants.
COUNTERCLAIM
Count I - Failure to Return Security Deposit
19. On or about March 7, 1993, Defendants agreed to rent
from Plaintiffs a mobile home located at Lot 2, 584 North
Middleton Road, Carlisle, Pennsylvania for the sum of $400.00 per
month plus a security deposit of $400.00.
20. On or about March 12, 1993, Defendants paid to
Plaintiffs a security deposit in the amount of $400.00.
21. After Plaintiffs served Defendants with an eviction
notice, Defendants vacated the rental premises on August 5, 1994,
owing to Plaintiffs the following amounts:
a. Rent from August 1 to August 5, 1994 . $ 64.52
b. Kerosene to fill fuel tank . . . . $ 184.20
c. Wooden strips and or.e sheet of paneling $ 25.82
d. Shower rod . . . . . . . . . . . . . . $ 8.26
Total: $ 282.80
22. On or about August 10, 1994, Defendants provided
Plaintiffs with a forwarding address, in writing, to which
Plaintiffs were requested to send Defendants' security deposit.
23. Plaintiffs owe and have failed to remit to Defendants
the balance of Defendants' security deposit, in the amount of
$117.20.
24. Pursuant to 68 P.S. ~250.512(c), as a consequence of
Plaintiffs' failure to pay to Defendants the difference between
Defendants' security deposit and the actual damages to the
leasehold premises within thirty days after Defendants
surrendered possession of the premises to Plaintiffs, Plaintiffs
owe Defendants double the amount wrongfully withheld, a total of
$234.40.
WHEREFORE, Defendants request that Judgment be entered in
their favor and against Plaintiffs in the amount of $234.40,
together with costs of suit.
Count II - Trespass
25. Defendants repeat and incorporate by reference the
averments set forth in Court I of their Counterclaim.
26. As a consequence of the parties' rental agreement,
Defendants had the right to exclusive possession of the mobile
home and the lot on which it was situated.
27. On numerous occasions between March 1993 and August
1994, Plaintiffs intentionally entored the mobile home which
Defendunts rented from Plaintiffs, without reasonable cause, and
without Defendants' knowledge or consent.
28. On numerous occasions between March 1993 and August
1994, Plaintiffs intentionally permitted and/or encouraged their
dogs to defecate on the mobile home lot Defendants rented from
Plaintiffs, despite Defendunts repeated requests that Plaintiffs
keep their dogs off of the lot.
29. As the consequence of Plaintiffs' failure to keep their
dogs off of the rented lot, Defendants and their children often
stepped in dog feces.
30. Moreover, Plaintiffs' dogs often growled at Defendants'
children. frightening them to the extent that the children were
unwilling to play in their own yard.
31. In or about June 1994, Plaintiffs intentionally had
large quantities of gravel and dirt moved from their lot onto
Defendants' lot, almost completely covering Defendants' back
yard, and rendering much of their lot unsafe and/or unsuitab'e
for the use of Defendants and their children.
32. Plaintiffs' actions of intentionally entering
Defendants' dwelling, permIttIng and/or encouraging their dogs to
HARRIET E. WHITE and
DALE WHITE,
Plaintiffs
VS
KIP ROUT SONG and
KAREN ROUTSONG,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94-6933 CIVIL TERM
JURY TRIAL DEMANDED
,...-11'1'1011 POll APPO~~....oIl or ARBl'IIll\tm1S
TO THE HONORABLE, THE JUDGES OF SAID COURT:
John L. Perry, Esquire, counsel for the Plaintiff in the above
captioned action, respectfully represents that:
1. The above-captioned action is at issue.
2. The claim of the Plaintiff in the action is:
Approximately $ 542.19
The counterclaim of the Defendant in the action is :
$ 4,234.40
The following attorneys are interested in the case and are
therefore disqualified to sit as arbitrators:
Philip C. Briganti, John L. Perry
WHEREFORE, your Petitioner prays your Honorable Court to
appoint three (3) arbitrators to whom the case shall be submitted.
,
on as
BY lH~ COURT ~.~.. j.~
l (1..<-'-'/ ( '.
I.., .-.. .J.
-
'" 01 'INNIYLVANIA
COUIII 01 C_N ,lIAI
NOTICE OF APPEAL
C
fROM
JUOtCIAL DIIIOICT
DISTRICT JUSTICE JUDGMENT
C_MONmAIN.. 9L/--6933 ~ ~
NOTICE OF APPEAL
Nolle. i. giwn that tho appollant he" filed in the above COutt of Common Plea. an appeal from the judgment ronderod by the Di.trict Mtle. an tho
date and In tho COM montionod bolo.<
Kip Routsong and Karen Routsong
Paula P. Correal
A
64 Faith Circle
Carlisle
PA
17013
(~J
~ Kip Routsong aad Karen Routsong
NA . A
Legal Services, nc.
CV 19. 94 CV-0000429-94 8 Irvine Row
IT 1\1 s 7013
ThlI block wiQ bo signed ONLY when this nota~an i. required under Po. RCPJP. No. It appellant was CLAIMA (see Pa. ,P.J.P. No.
10088.
ThlI Notice of Appeal. when received by the Di.triel A"tico. will oporoto a. 0 to01(6) In action belore District Justice, he MUST
SUPERSEDEAS to tho Judgment for pououian in Ihi. co'o. FILE A COMPLAINT within twenty (20) days stier
filing his NOTICE ot APPEAL.
11-17-94
A (Plttnd,
Harriet E. \~hite
Signaturo 01 ProthonolillY or Deputy
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(ThIs section of 101m to be used ONLY when appellant was DEFENDANT (see Pa. HCP,J.P. No. t001(7) In action belore District Justice.
IF NOT USED. detach lrom cqJY 01 notice 01 appeal to be served upon appellee).
PRAECIPE. To Prolhonotary
Entot ruIo upon Harriet E. White . oppeI1oe(.). to file 0 complaint In thi. appeal
Nwno 01 _""".}
(Common Plocn No. QIf-C/133 CWil/~ _.l within twenty (20) day. after~_' of rule or~'Uffot ontr of judgmont of non proo.
, ______ _____ ~r
aweIOnt 01 his attomey 01 ~
RULE. '0 Harriet E. White
" . oppolleo(.~
Nwno oI....,eIlIeI.)
(I) You en no~fiod thot 0 ruIo b hereby entered upan you to file 0 complaint in Ih;. oppoal wilhin twenly (20) day. after tho dole of
IOfVice of this rule upon you by pononoI.orvleo or by c""ilied or rogi.torod moil
(2) If you do not file a complaint within this timo, 0 JUDGMENT OF NON PROS WIll Ilf ENTERED AGAINST YOU.
(3) The date of lOfVic. of thi. rule if ..,vico was by moil ;. the dole of moiling.
Dato:A. B' ,19j}{.. ~(L W~~orOoJxdY
,d'C3Il-64
COURT FILE TO BE FILED WITH PROTHONOTARY
Motor vehicle: Make Dod~e Year 1984
Cost ~~.000.0~ Amount owed $2.000.00
N/A
N/A
Stocksj bonds:
Other:
(f) Debts and obligations
Mortgage:
Rent: $450.00
Loans: AutomobiLe $200.00: Personal loan $75.00
Monthly Expenses:Groceries not covered bY food stamps
$80.00: Gas for car $80.00: Insurance for car $35.00:
Telephone $40.00: Electric $110.00: TV Cable $30.00:
Trash removal $18.00: Water $60.00: Misc. $50.00
(g) Persons depandent upon you for support
(Wife) (Husband) Name:
Children, if any:
Name: Christopher Thomas Age: 8 Yrs.
Joshua Routson~ 5 Yrs.
4. We understand that we have a continuing obligation to
inform the court of improvement in our financial circumstances
which would permit us to pay the costs incurred herein.
5. We verify that the statements made in this affidavit are
true and correct. We understand that false statements herein are
N/A
P 011 1108 1411
~ Receipt for
Certified Mall
.. No Insurance Coverage Provided
;;:;u 00 not UI. lor Internallon.1 Mall
(S08 Raverse.
',"II"HARRIET ~; WHITE
StlM' 'nd.f'4S1.
5t1u N HIDDLETON RD
P Ul1 '108 143
~. Receipt for
Certified Mall
'. No Inlurlnce Coverage Provided
.:t::I:U'~':n' Do not UI. for Intornatlonlll Mall
ISee Rever,.)
""",, PAULA P CORREAL
,,",' "'1 "'COURTHOUSE SQ ANNEX
PO_. 51... .nd liP Cod.
CARLISLE l'A
PoII.g.
I' (). SIll. .nu III' (lid,
CARLISLE PA
17013
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