HomeMy WebLinkAbout95-05223
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IOUAKER REALTY,
la partnership,
, Plaintiff
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!JEFF WALK.
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Defendant
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)
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IN THE COURT OF COKHON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95- Y.J.t.3 CIVIL TERM
VB.
NOTICE
:TO DEFENDANT NAMED HEREIN:
\1
, YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET PORTH IN
ITHE FOLLOWING PAGES. YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS APTER THIS COMPLAINT
'AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND
,FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
:AGAINST YOU. YOU ARB WARNED THAT IF YOU FAIL TO DO SO. THE CASE HAY PROCEED WITHOUT
r:YOu. AND A JUDGMENT HAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR
ANY HONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE
PLAINTIFF. YOU HAY LOSE HONEY 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
i,CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO PIND OUT WHERE YOU
CAN GET LEGAL HELP.
COURT ADMINISTRATOR
FOURTH FLOOR, CUMBERLAND COUNTY COURT HOUSE
CARLISLE. PENNSYLVANIA 17013
TELEPHONE: (717) 240-6200
1
QUAKER REALTY,
a partnership,
Plaintiff
)
)
)
)
)
)
)
)
IN THE COURT OP COMMON
PLBAS OP CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95- j- oJ.:J.;3 CIVIL TIlRH
vs.
JBPP WALK,
Defendant
cotlPLAINT
AND NOW c~es the above-named Plaintiff, by its attorney, Samuel L. Andes, and
files the following Complaint in this matter:
1. The Plaintiff is Quaker Realty, a general partnership organized under the laws
of the C~nwealth of Pennsylvania, consisting of Samuel L. Andes and James C. Byerly,
co-partners, and maintaining offices at 535 North 13th Street in LelOyne, Cumberland
County, Pennsylvania.
3. The Defendant is Jeff Walk, an adult individual who resides at 333 Pourth
';Street, West Pairview, CuMberland County, Pennsylvania.
3. Plaintiff OYDS a townhouse apartment at 130 High Street in Bnola, East
i
i Pennsboro TOYDship, CuRberland County, Pennsylvania, and has owned that property at all
times relevant to this suit.
4. At s~e time, believed by the Plaintiff to be in 1993, Defendant sub-let the
, property owned by Plaintiff from a prior tenant and entered into possession of the said
townhouse. Defendant continued to occupy said townhouse until the end of Septeaber,
1994. Defendant occupied the townhouse as a ~nth-to-.onth tenant and there was no
written lease between the parties.
3
5. Defendant did not pay the rent due for the month of September, 1994. in the
I allKlunt of $475.00.
6. Defendant first notified Plaintiff that he would vacate the premises on 15
September 1994 and vacated the premises by the end of September. Because Defendant's
"notice of termination was not effective until the end of the month following the date
, it was given, Defendant is liable to Plaintiff for rent for the full month of October,
'1994, in the alOunt of $475.00.
7. During his occupancy of the premises, Defendant did extensive damage to the
'townhouse, all of which is described in an estimate for the repair of that damage which
is attached hereto and marked as Exhibit A.
8. The reasonable cost of repairing the damage to Plaintiff's townhouse done by
,Defendant is $2,271.94. Attached hereto and marked as Exhibit A is an estimate
detailing the work to be done to repair and restore the townhouse and the reasonable
cost of that work.
9. Defendant, by his conduct. bas injured Plaintiff in the amount of $3.221.94.
10. Despite demands by Plaintiff, Defendant has failed and refused to pay the sums
he owes to Plaintiff.
VHBIBPOlB, Plaintiff demands judgment against Defendant in the amount of
$3.221.94, plus interest fr~ and after 31 October 1994.
By , \~ f)['J)~
~~~\Jl
Attorney for Plaintiff
Supreme Court ID 17225
3
Oct, 12,,1994
Jeff Walk
130 High Street
Enola, PA. 17025
!'I i s c_~i.-,~_~~r_L"-"_Le.p_aJL~-,,--"-d...!_e_n-,,y_a..t) _o_'~_s__d_u ..coo _t _0_ ...t_o.!_'!.L_ ,,-b_u_s_e_,_"-"-d..~1...<:..o:..t.. .
I.Remove damaged shower door and clean fiberglass tub/shower unit that
appeared to have never been cleaned.
Material Cost $10.00
Labor Cost $95.00
2.C\ean and disinfect bathroom flooring and commode, again that appeared
to have never been cleaned.
Material Cost $5.00
Labor Cost $50.00
3.1nstall new door casing around the perimeter of the front door the
was removed.
Material Cost $10.00
Labor Cost $20.00
4.1nstatl new front door entry Jock, existing one was falling off and
be n t .
Material Cost $15.00
Labor Cost $10.00
5.1nstall new lag bolts in metal hand rail at the bottom of the steps,
bolts were missing and railing was loose.
Material Cost $1.00
Labor Cost $5.00
6.Remove existing kitchen range hood and replace the same. Old one
had all the paint stripped from it.
Material Cost $39.00
Labor Cost $30.00
7.Clean refrigerator and fill dent and scratches on the side and touch
up with white enamel touch up paint.
Material Cost $10.00
Labor Cost $35.00
8.1nstall 5 new light
removE'd.
bulb. in kitchen light, existing bulbs WE're
Material Cost $6.00
Labor Cost $5.00
9.Repair existing range. Iostalling nE'W dLp pans to rE'place existing
011E' that WE're nE'ver clE'anE'd. Il1stall new small burner E'1E'mE'nts and
one over bakp ~Iemcnt.
Material Cost $55.00
Labor rost $50,00
10.Install I1CW door bcll .-h'me to replal'<' the old nile thet the COVE'r
was brnk('n.
Material rnst $15.00
labor rnst $15.00
Page 2
II.Patch kitchen and dining rnnm vinyl flooring that was tnrn.
Material Cost $5.00
Labor Cnst $70.00
12.1nstall new kitchen sink faucet set to replace the existing one
that the faucet spout was loose and leaking.
Material Cost $25.00
Labor Cost $30.00
13.Clean upstairs carpeting and stairs to remove large stains.
Cost $95.00
14.Replace living room carpeting that was unabled to be cleaned and
also carpet was ripped.
Material Cost $225.00
Labor Cost $59.00
15.Repair numerous holes and scratches in walls and ceiling throughout
the townhouse.
Material Cost $5.00
Laboo Cost $25.00
16.1nstall new shower rod th replace shower door that was removed.
Material Cost $5.00
Labor Cost $7.00
17.1nstalt 2 new commode scats to replace existing non cleanabte ones.
Material Cost $12.00
Labor Cost $15.00
18.Install new patio door lock to replace existing one that was pryed
open and broken.
Material Cost $12.00
Labor Cost $15.00
19.Replace existing bathroom door that the hinges were ripped off.
Material Cnst $65.00
Labor Cost $50.00
20.Stain and varnish the oewly installed door.
Material Cost $10.00
Labor Cost $50.00
21.Reflnish ends of kitchen base cabinets aod sinkbase doors dur to
abuse and neglect.
Material Cost $10.00
Labor Cost $60.00
22.Replace broken frnnt entry door raised square molding, that was
cracked and brnken.
Matl'rial Cnst $20,00
Labor Cnsl $35.00
Page 3
23.Clean dowo all the walls, ceil iOB and trim work from dirt, dust
and spider webs.
Material Cost $15.00
Labor Cost $200.00
24.Remove existing funnitur(' left in townhouse and in and around
dumpster.
Cost $95.00
25.Repair existing bathroom scre('o and install new
Material Cost $25.00
Labor Cost $20.00
iving room screen.
26.Repair varmous nicks and scratches in fiberglass tub/shower unit
with gel coat repair kit.
Material Cost $15.00
Labor Cost $40.00
Tot a 1 Job cost.............................................. $ 1,796.00
15% Overhead................................................$ 269.40
Sub Total.................................................. .$2,065.40
10% Prof it. ..... ..... ............ ...... ........ .. ..... ...... $ 206.54
Tot a I job Cost.............................................. $2.27 1.94
Total job cost ihcludes all labor and material.
Total job Cost $2,271.94
Ron-=~
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----.-------
7 Campbel I Place
Camp Hill, Pa. 17011
Phone: 763- 7025
'.~HEH I!. F' ._' HETUi-,N
r~tiT F~ J'_:!HI
CASE NO: 1995-05223 r
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
Q1J.AKER R_EA!:.U.._...___ __________
VS.
\'I.A!o-.Ii_..1EL .___ ____,____ .___.__.._
R. Tho,:".iJS K1.lne .______.
::....~i":'rt;!. "'~I': ;;"~lLq d'11', :.2W':'rn d..,::'cc'rdlnl]
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named defi?odant_. t 'J W 1.. t.: __.W_~l-.t: ,~;~fL..__._
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QUAKER REALTY,
a partnership,
Plaintiff
)
)
)
)
)
)
)
)
IN THE COURT OF COKHON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95- 5.1.:1) CIVIL TERM
vs.
JEPP WALK,
Defendant
NOTICE
TO DEPENDANT NAMED HEREIN:
YOU HAVE BEEN SUED IN COURT. IP YOU WISH TO DEFEND AGAINST THE CLAIMS SET PORTH IN
THE POLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COHPLAINT
AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND
PILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO, THE CASE HAY PROCBED WITHOUT
YOU, AND A JUDGHENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE POR
ANY HONEY CLAIMED IN THE COHPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTBD BY THE
PLAINTIPF. YOU HAY LOSB 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 OPFICE SET FORTH BELOW TO PIND OUT WHERE YOU
CAN GET LEGAL HELP.
COURT ADHINISTRATOR
POURTH PLOOR, CUHBERLAND COUNTY COURT HOUSE
CARLISLE. PENNSYLVANIA 11013
TELEPHONE: (111) 240-6200
TRU::: COpy FP.O~.1 REC')RD
!:"'; ;t;'.~i.r~a~~.' '.\'''~n':..f. I ~"";~e ur.;) :~~,~ f,;y 'j ~q,j
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Plolhonolaly
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QUAKER REALTY,
a partnership,
Plaintiff
I
I
I
)
)
I
I
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IN THB COURT OF COHKON
PLEAS OF CUHBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs.
NO. 9~-
CIVIL TERH
JEFF WALK,
Defendant
~PLAI~
AND NOW c~es the above-named Plaintiff, by its attorney, Samuel L. Andes, and
files the following Complaint in this matter:
1. The Plaintiff is Quaker Realty, a general partnership organized under the laws
of the COIaonwealth of Pennsylvania, consisting of Samuel L. Andes and James C. Byerly,
co-partners, and maintaining offices at 51~ North 11th Street in Lemoyne, Cuaberland
County, Pennsylvania.
Z. The Defendant is Jeff Walk, an adult individual who resides at 3Z2 Fourth
Street, West Fairview, Cumberland County, Pennsylvania.
3. Plaintiff owns a townhouse apartment at 130 High Street in Enola, East
Pennsboro Township, Cumberland County, Pennsylvania, and has owned that property at all
times relevant to this suit.
4. At s~e time, believed by the Plaintiff to be in 1991, Defendant sub-let the
property owned by Plaintiff fr~ a prior tenant and entered into possession of the said
townhouse. Defendant continued to occupy said townhouse until the end of Septelber,
1994. Defendant occupied the townhouse as a month-to-month tenant and there was no
written lease between the parties.
Ii
Ii
Ii
il
II
1
COHHONWBALTH OF PBNNSYLVANIA )
( 99.:
COUNTY OF CUHBBRLAND )
SAMUBL L. ANDBS. being duly sworn according to law, deposes and says that he is a
co-partner of Quaker Realty, the Plaintiff herein, and that the facts set forth in the
foregoing CQlplaint are true and correct to the best of his knowledge, infonlation, and
belief.
~LL.:~
9worn to and subscribed
before .e this :l'lA day
of Sep~ . 1995.
I fr1AA ~
Nota y Public
NollIiIl Seal
Lym l'Irder. Nd1rt:
=~~~~~
4
Oct, 12,1994
Jeff Walk
130 High Street
Enola, PA. 17025
Misc. interior repairs and renovations due to total abuse and neglect.
I.Remove damaged shower door and clean fiberglass tub/shower unit that
appeared to have never been cleaned.
Material Cost $10.00
Labor Cost $95.00
2.Clean and disinfect bathroom flooring and commode, again that appeared
tn have never been cleaned.
Material Cost $5.00
Labor Cost $50.00
3.Install new door casing around the perimeter of the front door the
was removed.
Material Cost $10.00
Labor Cost $20.00
4.Install new front door entry tock, existing one was falling off and
bent.
Material Cost $15.00
Labor Cost $10.00
5.Install new lag bolts in metal hand rail at the bottom of the steps,
bolts were missing and railing was loose.
Material Cost $1.00
Labor Cost $5.00
6.Remove existing kitchen range hood and replace the same. Old one
had all the paint stripped from it.
Material Cost $39.00
Labor Cost $30.00
7.Clean refrigerator and fill dent and scratches on the side and touch
up with white enamel touch up paint.
Material Cost $10.00
Labor Cost $35.00
a.lnstall 5 new tight bulbs in kitchen light, existing bulbs were
removed.
Material Cost $6.00
Labor Cost $5.00
9.Repair existing range. Instalting new d~ip pans to replace existing
one that were never cleaned. Inslatl new small burner elements and
one over bake element.
Materiat Cost $55.00
Labor Cost $50.00
10.lnstall new door belt chime to replace the old one thet the cover
was broken.
Material Cost $15.00
Labor Cost $15.00
Page 2
II.Patch kitchen and dining room vinyl flooring that was torn.
Material Cost $5.00
Labor Cost $10.00
12.1nstall new kitchen sink faucet set to replace the existing one
that the faucet spout was loose and leaking.
Material Cost $25.00
Labor Cost $30.00
13.Clean upstairs carpeting and stairs to remove large stains.
Cost $95.00
14.Replace living room carpeting that was unabled to be,cleaned and
also carpet was ripped.
Material Cost $225.00
Labor Cost $59.00
15.Repair numerous hotes and scratches in walls and ceiling throughout
the townhouse.
Materiat Cost $5.00
Laboo Cost $25.00
16.1nstalt new shower rod th replace shower door that was removed.
Material Cost $5.00
Labor Cost $1.00
11.1nstall 2 new commode seats to reptace existing non cleanable ones.
Material Cost $12.00
Labor Cost $15.00
18.1nstatl new patio door lock to replace existing one that was pryed
open and broken.
Material Cost $12.00
Labor Cost $15.00
19.Replace existing bathroom door that the hinges were ripped off.
Material Cost $65.00
Labor Cost $50.00
20.Stain and varnish the newly instatted door.
Material Cost $10.00
Labor Cost $50.00
21.Refinish ends of kitchen base cabinets and sinkbase doors dur to
abuse and neglect.
Material Cost $10.00
Labor Cost $60.00
22.Replace broken front entry door raised square molding, that was
cracked and brnken.
Material Cost $20.00
Labor Cost $35.00
Page 3
23.Clean down all the walls, ceilin8 and trim work frrm dirt, dust
and spider webs.
Material Cost $15.00
Labor Cost $200.00
24.Remove existing fueniture left in townhouse and in and around
dumpster.
Cost $95.00
25.Repair existing bathroom screeo and install new living room screen.
Material Cost $25.00
Labor Cost $20.00
26.Repair varmous nicks and scratches in fiberglass tub/shower unit
with gel coat repair kit.
Material Cost $15.00
Labor Cost $40.00
Total Job cost............................................. .$1,796.00
15% Overhead................................................$ 269.40
Sub Tot a 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $ 2,065.40
10% Profit..................................................$ 206.54
Total job Cost............................................. .$2,271.94
Total job cost ihcludes all labor and material.
Total job Cost $2,271.94
\
Ron Moroz
7 Campbell PLace
Camp Hill, Pa. 170 II
Phone:763-7025
Defendant
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
QUAKER REALTY, a partnership,
Plaintiff
vs
JEFF WALK,
NO. 95-5223 CIVIL TERM
PRAECIPE
TO THE PROTHONOTARY:
Please reinstate the Complaint in the above matter.
'--~
Samuel LAndes
Attorney for Plaintiff
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CASE no: t'3\Yj-l~e1::.~:1 !--'
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAflr
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