HomeMy WebLinkAbout02-3989COMMONWEALTH Of PENNSYLVANIA
~COURT OF COAIMON PLEAS
JUDICIAL DISTRICT
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
NOTICE OF APPEAL ~'- ~ I~ 0 '~
Notice is given that the appellant has filed in the above Court of Common Picas an appeal from the judgment rendered by the District Justice on the
date and in the case mentioned below.
Theresa A. Martin
299 Greason Road
~enberger
zfc~
a Carlisle PA 17013
Is ~Theresa A. Martin
CV ~gal Services
LT LT-109-02 [~ .... /_ _' / -~'~ ~'~ Irvine Row
~nl£1p C. BrLganti Carlisle PA 17013
This block will be signed ONLY when this notation is required under Po~ ~
1008& If appellant was A - --C.P.J.P. ~o.
This Notice of 1001(6) in action before District Justice, he MUST
Appeal, when received by the District Justice, will operote as a
SUPERSEDEAS to the judgment for possessi~
~/~ FILE A COMPLAINT within twenty (20) days after
Signature of Prothonotary-~r-~3epu~¥ filing his NOTICE of APPEAL.
PRAEClPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appel/ant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before District Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee),
PRAECIPE: To Prothonotary
En~r rule upon
(Common Pleas ~
RULE: To
O & O Rentals
O & O Rentals
) within twenty (20) days a~ or
, oppeIlee(s).
Name of appellee(s) , appellee(s), to file a complaint in this appeal
suffer en.~ of judgment of non pros.
{I) You am notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of
service of this rule upon you by persoual service or by certified or registered moil
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by moil is the date of mailing.
AOPC312-e0 COURT FILE TO BE FILED WITH PROTHONOTARY
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULETO FILE COMPLAINT
(This proof of service P,,¢UST BE FILED WIT~-¢IN TEi'V (10) DAYS AFTER fiiirtg the notice of ~ppeal, Check app lcable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ; SS
AFFIDAVIT: I hereby swear or affirm that I served upon tl~e District Justice designated therein on
a coov of, the Notice o'~ Appea Common Peas No
~ (dat~ serv ce ,
' . 7 ~ ' on
~eceipt attached hereto and upon the appel,ee
- ~ by personal service ~ by (certmed) (registered) malt, senaers rece~p~ attacneu nu~u~u.
~ ~3-'7~{~i-'[ ~ 'erE~¢~-~ie to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to whom
the Rule was addressed on
mail sender's receipt attached hereto.
SWORN (AFFIRMED} AND SUBSCRIBED BEFORE ME
T {IS DAY,
CO~',"ffVlONWEALTH OF PENNSYLVANIA
C__OUNTY OF:
Mag. Oisl. No.:
09-3-02
DJ N&me: Hon.
H~.~.EN B. SHULENBERGE]~
~'~ P.O. ~OX 155
~ ~ 27 W. BI~ SPRIN~ A~UE
~ILLE, PA
T.,ep~n.: (717) 776-3187 172~1
THERESA L. MAETIN
299 GREASON P~D APT.#
CAELISLE, PA 17013
2
NOTICE OF JUDGMENT/TRANSCRIPT
PLA NT FE: RESIDENTIAL LEASE
NAME and ADDRESS
o
1300 RIT~TER HIGHWAY
CA~LISLE, PA 17013
DEFENDANT: VS.
NAME and ADDRESS
F"MAETIN, THEP~ESA L ~
299 GREASON P~D APT.# 2
CAELISLE, PA 17013
~Docket No.: I ~
8/08/02
lDateFiled: LT-0000109-02
in a
(Date of Judgment)
.0il.
The total amount of the Security Deposit is $__ ,00
I~ ~~,ablished by DJ. O~ess~Security Deposit A.p~l~d =$ Adjudicated AmouE
I ~R,ent.ii%A_rrears ........ $.
I ~~s ~e~a_?.ehold Property _ ·
.... .oo -$ .oo --
- .on-Si .oo = $ .oo
'essAmtDueDe'endan, fromCressComp,a,nt _$
interest (if provided by lease) $ 0n
THIS IS TO NOTIFY YOU THAT:
Ju~.gment ;, FO~. PT~AT~-~I F~'
-- ~] Judgment was entered for: (Name) O & O RENTALS
Judgment was entered against MARTIN THERESA L
Landlord/Tenant action in the amount of $ 8~.95 ~n-- 8 ~5___.~_/_~__~.
The amount of rent per month, as established by the District Justice, is $
UT Judgment Amount $ . no
Judgment Costs $ 86.9,fi
Attorney Fees $ .0 O
Total Judgment $., 86.95
Post Judgment Credits $
Post Judgment Costs $
~'~ Attachment Prohib ted/
Victim of Abuse (Act 5, 1996)
J--'~ This case dismissed without prejudice.
~ 'Possession granted.
E~ ' Certified Judgment Total $_,
Possession granted if money judg'ment L~ 'not satistied Dy time or eviction.
Possession not granted. [] Defendants are jointly and severally liable.
[] Levy is stayed for days or [] generally stayed.
~ Objection to Levy h--~s been filed and hearing will be held:
IN AN ACTION INVOLVING A RESIDENTIAL LEASE ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN
TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOT CE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS
OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT, IF ANY. IN
ORDER TO OBTAIN A SUPERSEDEAS, THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF
THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED.
IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLV NG A RESIDENTIAL LEASE, THE PARTY HAS
30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL wITH,THE PROTHONOTARY/CLERK OF
COURTS OF TIlE COURT OF COMMON PLEAS, CIVIL DIVISION. ·
THE PA~._Ty FIMNC~N APPEAL MU~T. INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCi~i~3~ FORM
(~" t .~;~5 '~' ~-/1~* ..,~ _ . WITH THE NOTICE OF APPEAL.
IjI' - '.---' c,,'L~aie . ~ ~ . ~ /. ~.__ ~, :
~,Y,:~,O,~?SSiOn expires first Monday of January, 2006.
SEAL
J
THERESA A. MARTIN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
O & O RENTALS,
Defendant
NO. 02- 3e~"fl CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow the defendant, Theresa A. Martin, to proceed in forma pauperis.
I, Philip C. Briganti, Esquire, attorney for the party proceeding in forma I/auperis,
certify that I believe the party is unable to pay the costs and that I am providing free legal
services to the party.
Date:
Attorney for Defendant
MIDPENN LEGAL SERVICES
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
THERESA A. MARTIN,
Plaintiff
O & O RENTALS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
:
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 02- .~?o~7 CIVIL TERM
_AFFIDAVIT
1. I, Theresa A. Martin, am the defendant in the above-captioned action, which is an
appeal from a judgment rendered by Distr/ct Justice Shulenberger on August 15, 2002, awarding
Plaintiff possession of the residence in which I reside.
2. My rent for this residence, located at 299 Greason Road, Carlisle, PA 17013, is
$26.00 per month. The rent, which is subsidized by HUD, is due on or before the 3rd day of each
month.
3. My rent payments are now current, and my next rent payment will be due on or before
September 3, 2002.
4. I verify that the statements made in this Affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to
unsworn falsification to authorities.
Date:
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check appficable boxes)
SWORN (AFFIRMED AND SUBSCRIBED BEFORE ME
THIS .............. DAY OF ...........................
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF......C.~.~.h~ ,,/~:.._,~_ ; SS
AFFIDAVIT: I hereby swear or affirm that I served
~ opy of the Not ce of Appeal, Common Pleas No 0,2-~ q~ ~'.'.v,/ 1,",'"- u on the D str ct Justice de i '
.......... . P s gnated there~n on
(c~ate o,~serwce)_F:_~/~ ~__~ [] by personal se_rvice IE~b-~/(certified)~mai, sender's
receipt attached hereto, and upon the appellee, (name) _~._.~ E2 ~,~¢'¢,/~ - '
mail, sender's receipt atta('h;~"~e~¢ [] y p ' ~ y (certified)~
f / Siqn~mre of afli~-
My commission exp res on ................
I verify
correct.
to the penalties
falsification to
that ~he statements made in this Affidavit are true and
I ~nerstand that false statements herein are made subject
of 18 P.S. Section 4904, relating to unsworn
authorities.
Philip~. Brigan~i
Postage
Certified Fee
Retur~ Receipt Fee
(En¢orsement Required)
Restricted Delivery Fee
(Encorsement Required)
4
/,
O & O RENTALS
Plaintiff
THERESA L. MARTIN
Defendant
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
: CIVIL ACTION - LAW
: CIVIL TERM 02-3989
NOTICE
YOU HAVE BEEN SUED IN COURT. W YOU WISH TO DEFEND
TAKE
AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST
ACTION WITHIN TWENTY (20) DAYS AFTER THE COMPLAINT AND NOTICE ARE
TO THE CLAIMS SET FORTH AGAINST YOV. xwv ~ MAY BE
TO DO SO, THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT
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 PLAINTWF. 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 GET LEGAL HELP.
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A
DEBT· THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT
THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY
INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT
PURPOSE. IF YOU HAVE pREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT
BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT
ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY.
CUMBERLAND COUNTY
BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
0 & 0 RENTALS
Plaintiff
V+
THERESA L. MARTIN
Defendant
: IN THE COURT OF COMMON PI.EAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
:
: CIVIL ACTION - LAW
:
: CIVIL TERM 02-3989
COMPLAINT
AND NOW, comes Plaintiff, O & O Rentals, by its attorneys, Duncan & Hartman &
Douglas, P.C. and makes the following Complaint:
1. Plaintiffis O & O Rentals, whose address is 1300 Kitner Highway, Carlisle,
Cumberland County, Pennsylvania, 17013.
2. Defendant is Theresa L. Martin, an adult individual, whose address is 299 Greason
Road, Apt. # 2, Carlisle, Cumberland County, pennsylvania, 17013.
3. The Plalntiffis the owner of a rental property located at 299 (3reason Road, Apt. # 2,
Carlisle, Cumberland County, pennsylvania..
4. The Plaintiff and Defendant entered into a lease agreement on March 3, 2000, for a
one year lease term with a monthly rental payment of $500.00 being due and owing on the first
day of each month. A copy of the lease agreement is hereto attached as "Exhibit A".
5. The Defendant is in default in her rental payments in the emoum of $1,044.00 plus
costs in the amount of $96.30 for a total demand of $1,140.30.
6. The Plaintiff further demands the eviction of the Defendant from the said rental
property and possession of the property returned to the Plaintiff.
WHEREFORE, Plaintiff request this Honorable Court to enter judgment in his favor
and against Defendant in the amount of One Thousand One Hundred Forty ($1,140.30) Dollars,
and possession of the property located at 299 Greason Road, Apt. # 2, Carlisle, Cumberland
County, Pennsylvania, plus all cost of this suit.
Duncan & Hartman & Douglas, P.C.
George F., Douglas, Ili, Esquire
1 Irvine Row
Carlisle, PA 17013
(717) 249-7780
ID # 61886
VERIFICATION
· · · ' to do so, state that the facts set
I, Owen Meals, make this verification being authonzed
forth in the foregoing Complaint are true and correct to the best of my knowledge. I understand
that false statemems herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unswom falsification to authorities.
THIS AGREEMENT OF LEASE, made this 3rd day of March, 2000
by and between O & O Rentals
hereinafter oiled the Lessor, and Theresa Martin
hereinafter called the LESSEE (whether singular or FtuPal), W1TNESSETH:
IN CONSIDERATION of the rents, covenants and agreements herein contained, the
LESSOR does hereby lease and demise unto the LESSEE
Apt. 2, 299 Grensun Rd., Carlisle, PA 17013
TO HAVE AND HOLD unto the Lessee, subject to the terms and conditions of this
Agreement, for a term of 12 months, commencing on April 1, 2000
and ending on the 31st day of March. 2001
IN CONSIDERATION of which, the LESSEE agrees to gay the Lessor as mm for the
use of the said demised pmnnses, the sum of. $6,000.00 to be paid as follows twelve
monthly installments of $ 500.00 per month to be paid on or before the lust ( 1 ~t) day of
each month.
AS FURTHER CONSIDERATION for the use and occugancy of the ~aid demised
premises, the parries hereto agree to faith~lly keep and be bound by thc follovang
covenants, conditions and agreements:
~ ~ ~ $500 00 dollars, therecetptofwhichlsher0~yackn eag oy
~,~ ~SD.oo '9/"~J/'~°a° 1 ........ . . - ow, en
,25~, O0 ~a~'~e retain said security deposit in a segregated account which the Lessor may apply only to
remedy a default of the Lessee in the faithful performance.o[ the texms, c~nditions and
covenants which the Lessee has undertaken, including but not hunted to default m payment of
rent and clamage to the demised premises. The Lessee shall not he entitled to apply the
security deposit as the last months rent. Within thirty (30) days following the surrender of the
premises by the Lessee and thc acceptance thereof by the lessor shall return to thc Lessee all
of the security not required to remedy defaults of the Lessee.
2. The demised la'emises are to be kept and maintained in as good repair and condition as at the
beginning of occupancy by the Lessee, and at the expimion of this Agreement, er any
renewal thereof as heminat~ provided, the demised premises shall be surrendered in like
repair and condition, normal wear and tear and damages happening by fire, storm and other
casualties only expuCted. The Lesme shall not make any alterations, additions or
improvements to the demised premises without the Lessor's written consent endorsed hereon,
and all alterations, additionS, or improvements made by either of the parties hereto to the
put in at the Lessee's
demised premises, except movable and detachable personal prope~ upon and be
expense, shall be and remain the prope~ of the Lessor and shall remain
surrendered with the demised premises, as pan thereof, at the termination of the Agreement.
The Lessor shall pay/provide: real estate t~xes, property insurance. The Lessor is not responsive for
the Lessees propafty stored in the basement area damaged by high nsmg water levels caused by an act
of God. The Lessee shall pay all other utilities and se~ices, including but not limited to: trash.
electric, telephone, cable, sidewalk snow remOval, and cleaning of sidewalks, renters insurance, and
shall kecp the demised premises in a clean and sanita~ condition, shall be responsible for the removal
of all garbage and trash from the premiSes.
Each of the parties hereto agrees to insure the demised premises and its contents to protect thc
respective interest of each in the dminsed premises and the contents thereof. The Lessec agrees to be
responsible for and to assume all liability for and any damage to the demised premises by wind or
precipitation caused by leaving windows open, by overflow of water or stoppage of water pipes, by
breaking of glass or damage to screens, and/or deterioration of lawns or landscaping due to Lessee's
abuse or neglect.
The Lessee shall do nothing upon the demised premises contrary to the conditions of the policies of
insurance upon the improvements herein demised wherchY thc hazard may be increased or thc
insurance invalidated-
. - . sublet, nor shall the Lessee remove
Neither the whole nor any pomon of the demised prenuses shall be thereof, without ~xinen
or attempt to remove from the demised during the term hereof, or any renewal .
consent of the Lessor; and no unlawful business shall at any time be carried on upon the denosed
premises.
The Lessee shall not keep any dog, cat or other ammal or pet unless ~t has been agreed to m ~aatmg bt
the Lessor, nor shall the les,ncc play musical iustmments, radio, tapes, records er television before 8:00
o'clock A.M. or aider 10:00 o'clock P.M. loud enough to disaub neighbors, nor violate any municipal
ordinances or State laws of whatever nature, nor drive any tacks, nails or screws into any walls or other
woodwork.
The Lessee shall make and pay for all minor repairs to the premises up to and including the suni of
.... All other repa~ shall be made and paid for by the Lessor except for such repairs as are
necessitated by reason of the Lessee's negligence or the noghgence of any member of their family,
household pets, animals, invitens or guests.
9. Prior to midnight on the final day of the term hereof, or any reaewal thereof, Lessee shall remove all
garbage and trash, clean the premises and return all keys to the Lessor. Tenant will be subject to trash
disposal costs in the event that trash is leiS.
reserves the tight to enter upon the demised premiSes at reasonable times for the
10. The Lessor expressly repairs, or to show the same to prospective purchase~ or
purpose of making necessary inspection,_ dis-alav "FOR RENT" or "FOR SALE" signs thereon.
lessees, or to a loan or insurance agent, ana may *~ ~
11. The removal of any goods from the demised premises, whether by day or by night, without
consent of the Lessor, shall be deemed a clandestine and fraudulent act and such goods shall remain
liable to distress for a period of thlity (30) days after such removal whether they may be found.
· ' and to act on behaff of
12. The Lessor designates O & O Rentals as agent to receive all rents and noUC~Sa,yable on or before the
the Lessor in any, other matter pursuant to this agreem-ent. Rent shall be
first (1~) day of each mouth. Residents ecenpYing any portion of a month shall constitute a full
month's rental. There will be a penalty of $5.00 per day for late rent payments beginmng me
day of the mouth. There is a $20.00 cha~e for returned checks.
shall default in the payment of rem or any part thereof after the same becomes due. or if
refills or
13. If the Lessce
the Lessee shall breach or evade or attempt to break or to evade any of the covenants,
the entire rent reserves for the full term of this lease remaining unpaid
conditions of the Agreement, at once and may forthwith be collected by dist~SS or otherwise; and at
shall become due and payable forfeit and mmal the unexpired portion of this lease and enter upon and
the same time the Lessor may . and without giving any notice whatsoever.
repossess the said premises with or without process of law
.... :-~ .... the demised premises after the termination of
14. - - - - forfeiture andannolment of the ~ rights and ander
Any property not owned by toe Lessor ano
this agreement or any renewal toereoI or upon
-J ~'---re the ,~-~mises by the Lessor and stored at the Lessees expense.
this ag~emenC may be removeo au
15. Acceptance by the Lessor of any of the said rent at any time after the same shall become due, afl.er
default had been made in the payment thereoL or any failure to enforce any of the rights hereto
reserved to the Lessor, or any of the penalfies~ forfeiture or conditions herein contained, shall not in
any way be considered a waiver of the fight to enforce the same at any time without any notice
whatsoever, and any attempt to collect the rent by one proceeding, but all of the rights of tine Lessor,
and all foffeittues, penalties and conditions, may be enforced together or successively at the option of
the Lessor.
16. It is further agreed by and between the parties hereto that if the Lessee shall becom, e insolvent, make
an assigament for the benefit of creditors, eormmt any act of bankruptcy be filed against the Lessee, all
the rent reserved for the full term of this agreement shall become due and collectable immediately by
distress or otherwise.
The Prethonota~ or any aaomey of any court of record of pennsylvania is hereby authorized to appear
17. . ' of the Lessor for the ~vhole an~oant of
for and to confess a judgement against the Lessee and m favor
said rent as hereionbeve set forth.
18. The Lessee hereby waives the usual notice to quit, and agrees to surrender the demised premises at the
expiration of said renu, or at the end of any renewal thereof, or the termination of this agreement
without any notice whatsoever. Upon any proceeding instituted for the recove~ of said rent, either by
· appraisement, stay and exemption laws. the
distress or otherwise, the Lessee vauveS the benefit of ~lor insolvency laws now in force or hereafter
right of inquisition on real estate, and all bankrulacy
UPastxs ned'n the breach of any of the covenants, terms or conditions of this agreement or upon its temanatlon
as aforesaid, is hereby authorized
19. by forfeiture, default or expiration, the Prothonotary or any a~omey,. . the Lessee and in
..... -._., .,.~,-,ise~ and to direct the immediate issuing of a
to appear for and to confess judggment in an amicable action of e~eetton against
favor of the Lessor for the pnssosmon
Writ of Possossion to include a clause for costs and rent due, waiving all irregularities, without notice
and without asking leave of Court.
20. If the Lessee shall continue in po-~e~ian of the demised p~atises after the expiration of the
sl~:ified in this agreement with the consent of the Lessor, it shall be deemed a renewal of
for a like
terms until an Agreement
this agreement nl~on the same covenants, terms and conditions as herein contained
term and shall so continue to he renewed for sueeessive like term~ unless or
is terminated by either party giving to the other not less than 60 days written notice for removal
prior to the expiration of the then current term: provided, however, that if the Lessor shall have
given a 60 day written nntiee prmr to the exp~ra~On of any term o~ mtenttan to change the terms
and conditions of this Agreement, including rental terms, and the Lessee shall hold over after
and conditions, including
such notice, the Lessee shall he considered a Lessee under the terms herein and until this
rental terms, mentioned in such notice for a further term as p. rovided
Agreement is terminated by notice, or otherwise, as provided here~n.
21. All notices, demands and requests and requests which may or are required to be given by either party
to the other shall be in writing, and either dehvered pemonally to the other or sent by registered or
certified mail to the address of the resPect~ve parties or at such other place as either party may
hereafter notify, the other.
22. The terms and conditions of this agteemcot shall in no way be changed or altered except by writing
signed by the panics hereto. Further, the covcnani~ and agreements herein contained shall apply and
insure to the benefit of thc parties hereto, their respective betts, executors and admimstmtors
DP~TE
LESSEE
DATE
LESSEE
LESSOR/_Owen E. Meals
0 & 0 R~NTALS,
Plaintiff
THERESA A. MARTIN,
Defendant
: 'IN THE COURT OF COMMON PLEAS' OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 02-3989 CIVIL TERM
:
~ W
STI___PUL_ATIO_N FOR RELEASE OF ESCRO FUNDS_
COME NOW the plaintiff, O & O Rentals, by counsel, George F. Douglas, III, Esquire,
and the defendant, by counsel, Philip C. Briganti, Esquire, and hereby stipulate to the entry of an
Order directing the Prothonotary to release to O & O Rentals all rent money held in escrow in the
above-referenced matter.
Date:
DUNCAN, HARTMAN & DOUGLAS, P.C.
1 Irvine Row
Carlisle, PA 17013
(717) 249-7780
COUNSEL FOR PLAINTIFF
Philip C. B&anf /
MIDPENN LEGAL SERVICES
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
COUNSEL FOR DEFENDANT
O & O RENTALS,
Plaintiff
THERESA A. MARTIN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 02-3989 CIVIL TERM
:
ORDER
AND NOW, upon consideration of the parties' Stipulation for Release of Escrow Funds,
it is hereby ORDERED that the Prothonotary shall release to.the plaintiff, O & O Rentals, all
rnt n 'lnt [~ ~rt.~ ]o~a.~e[~3~. ~C~:e----
e mo ey paiu ' o escrow in this matter. The check shall be made payable to George F.
Douglas, III, Attorney for O & O Rentals, and mailed to the following address: George F.
Douglas, III, Esq., I Irvine Row, Carlisle, PA 17013.
BY THE COURT,
~eorge F. Douglas, III, Esq.
Counsel for Plaintiff
o4fhilip C. Briganti, Esq.
Counsel for Defendant
Oq-oq-
· 0 & 0 RENTALS,
Plaintiff
THERESA A. MARTIN,
Defendant
7
: ~ THE COURT OF COMMON PLEAS' OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 02-3989 CIVIL TERM
STIPULATION FOR RELEASE OF ESCROW FUNDS
COME NOW the plaintiff, O & O Rentals, by counsel, George F. Douglas, III, Esquire,
and the defendant, by counsel, Philip C. Briganti, Esquire, and hereby stipulate to the entry of an
Order directing the Prothonotary to release to O & O Rentals all rent money held in escrow in the
above-referenced matter.
Date:
ugias, III
DUNCAN, HARTMAN & DOUGLAS, P.C.
1 Irvine Row
Carlisle, PA 17013
(717) 249-7780
COUNSEL FOR PLAINTIFF
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
COUNSEL FOR DEFENDANT
0
10350509092003 Cumberland County Prothonotary's Office Pa~e 1
PYS405 Manual Re±ease Check Register 9/09/2003
Escrow Tran Date
Distribution Case No Accounting Amount Date Release
.......................................3850 DOUGLAS GEORGE F III
RENT 2002- 03989 PYMT
RENT 2002- 03989 PYMT
RENT 2002- 03989 PYMT
RENT 2002- 03989 PYMT
RENT 2002- 03989 PYMT
RENT 2002- 03989 PYMT
RENT 2002- 03989 PYMT
RENT 2002- 03989 PYMT
RENT 2002- 03989 PYMT
RENT 2002- 03989 PYMT
RENT 2002- 03989 PYMT
/CASH 26
~CASH 26
CASH 26
CASH 26
CASH 26
CASH 26
CASH 26
CASH 26
CASH 26
CASH 26
CASH 26
0o
00
00 10
00 12
00
oo
O0
O0 5
00 61
00 7
27Z2002
20~2002
31~2002
02~2002
02Z2003
03~2003
04~2003
04~2003
01~2003
02~2003
01/2003
Payee total: 286.00
Grand total:
286.00
O & O RENTALS,
Plaintiff
THERESA A. MART1N,
Defendant
: 1N THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 02-3989 CIVIL TERM
PRAECIPE TO DISCONTINUE CASE
To the Prothonotary:
Kindly mark the above-captioned case as settled and discontinued, with prejudice.
Date:
George F. Douglas, III
DUNCAN, HARTMAN & DOUGLAS
1 Irvine Row
Carlisle, PA 17013
(717) 249-7780
COUNSEL FOR PLAINTIFF
Pfiilip C.~figanii
MIDPENN LEGAL SERVICES
8 Irvine Row
Carlisle, PA 17013.
(717) 243-9400
COUNSEL FOR DEFENDANT