HomeMy WebLinkAbout00-00880
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ED COOMBS, t/d/b/a ED COOMBS,
GENERAL CONTRACTOR!
CONSTRUCTION MANAGER,
Claimant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
v.
MECHANICS' LIEN
HENRY W. STRONG, II,
NO. .;(CXXJ - ;>16
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Owner
TO: Henry W. Strong, II
AAMCO
6411 Carlisle Pike5135 Jonestown Road
Harrisburg, P A 17112
NOTICE OF FILING OF MECHANICS' LIEN CLAIM
You are notified that a mechanics' lien claim in the amount of$19,993.00 has been filed
on behalf of Ed Coombs, t/d/b/a Ed Coombs, General Contractor/Construction Manager, against
the property and improvements located at 6411 Carlisle Pike, Mechanicsburg, Silver Spring
Township, Cumberland C~, Pennsylvania, of which you are the owner or reputed owner.
The claim was filed on J., ~ 4 , 2000, in the Court of Common Pleas of
Cumberland County, No. ;Jo~ _ l?D Term. A copy of the claim is attached.
KEEFER WOOD ALLEN & RAHAL, LLP
By: ~cR~.--
Stephen . Grose
Attorney J.D. #31006
210 Walnut Street
P.O. Box 11963
Harrisburg, PA 17108-1963
(717) 255-8052
Dated: February 1, 2000
Attorneys for Claimant
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ED COOMBS, t/d/b/a ED COOMBS,
GENERAL CONTRACTOR!
CONSTRUCTION MANAGER,
Claimant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
v.
MECHANICS' LIEN
HENRY W. STRONG, II,
()OO
NO. ;;2000 - 4 d
fYllu I~
Owner
TO: Henry W. Strong, II
AAMCO
6411 Carlisle Pike5135 Jonestown Road
Harrisburg, P A 17112
MECHANICS' LIEN CLAIM
Claimant, Ed Coombs, t/d/b/a Ed Coombs, General Contractor/Construction Manager
("Claimant"), through the undersigned counsel, Keefer Wood Allen & Rahal, LLP, files this
claim against the improvements and property located at 6411 Carlisle Pike, Mechanicsburg,
Cumberland County, Pennsylvania, known as AAMCO and owned by H.W. Strong and/or
Strong Services, Inc. ("Owner"), for the payment of a debt due to Claimant as a general
contractor for materials and labor furnished by Claimant in the course of the Owner's selective
demolition, construction and renovation ofthe structure located thereon. In support ofthe claim,
the Claimant aver as follows:
1. The Owner ofthe property is Henry W. Strong, II, with a business address of
6411 Carlisle Pike, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. The improvements and the property that are subject to this claim are located at
6411 Carlisle Pike, Mechanicsburg, Silver Spring Township, Cumberland County, Pennsylvania.
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A building is located thereon (hereinafter referred to as the "Building") from which the Owner
operates a business known as AAMCO.
3. Pursuant to a contract dated September 1999 (the "Contract"), the Claimant
provided materials and labor to the Owner that were used in and about the construction and
renovation of the Building, in return for which the Owner agreed to pay the Claimant $42,700.00
in four (4) draws. A true and correct copy of the Contract is attached hereto as Exhibit "A" and
is incorporated here by reference.
4. In addition, to providing the labor and materials necessary to perform the work
called for under the Contract, Claimant also performed work requested by the Owner, but not in
the specification sheet or on the proposal in the amount of $7,293.00. A true and correct copy of
the listing of this additional change order work and the expense incurred for each, providing a
breakdown oflabor and material, is attached hereto as Exhibit "B" and is incorporated here by
reference.
S. The materials and service for which the debt is due consisted of construction and
renovation materials, including, but not limited to, soil, stone, concrete, brick, metal fabrications,
lumber, drywall and other items, all as specifically set forth on Exhibits "A" and "B" attached
hereto.
6. Claimant has received payment in the amount of $30,000.00 and the remaining
unpaid balance is $19,993.00 ($12,700.00 original contract balance and $7,293.00 in change
order work).
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7. Claimant substantially completed the construction and renovations at the
Building on December 15, 1999, when the occupancy permit was issued, which is less than four
(4) months before the filing ofthis claim.
WHEREFORE, Claimant requests that this claim be entered against the Owner, Henry
W. Strong, II, on the property located at 6411 Carlisle Pike, Mechanicsburg, Pennsylvania.
KEEFER WOOD ALLEN & RAHAL, LLP
By: ~ ~~-.~_
StepKen L. rose
Attorney I.D. #31 006
21 0 Walnut Street
P.O. Box 11963
Harrisburg, PA 17108-1963
(717) 255-8052
Dated: February !L, 2000
Attorneys for Claimant
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VERIFICATION
I, Ed Coombs, t/d/b/a Ed Coombs, General Contractor/Construction Manager, affirms as
follows:
I. I am Claimant herein;
2. The information stated in the Notice of Piling of Mechanics' Lien Claim and
Mechanics' Lien Claim are true and correct to the best of my knowledge, information, and belief;
and
3. I am aware that false statements herein are made subject to the penalties of 18
Pa.C.S. Sec. 4904, relating to unsworn falsification to authorities.
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Date: r;:l{. f - t70 , 2000
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Ed Coombs
General Contractor/Construction Manager
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ED COOMBS, t/dIb/a ED COOMBS,
GENERAL CONTRACTOR!
CONSTRUCTION MANAGER,
Claimant
v.
HENRY W. STRONG, II,
Owner
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IN THE COURT OF COMMON PLEAS
CUMBERL^"~ COUNTY, PENNSYLVANIA
MECHANICS' LIEN
NO. 2000-880
PRAECIPE TO DISCONTINUE
TO THE PROTHONOTARY:
Please mark the above-captioned matter settled and discontinued with prejudice.
Dated: May (}.(p, 2000
Respectfully submitted,
KEEFER WOOD ALLEN & RAHAL, LLP
By St~se,~e ~ .
Attorney J.D. #31 006
21 0 Walnut Street
P.O. Box 11963
Harrisburg, PA i7108-1963
(717) 255-8052
Attorney for Claimant
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-00880 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COOMBS ED ET AL
VS
STRONG HENRY W II
BRIAN BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County, pensylvania, who being duly sworn according to law,
says, the within MECHANICS LIEN CLAIM
was served upon
STRONG HENRY W II
the
OWNER
, at 0010:50 HOURS, on the 29th day of February, 2000
at 6411 CARLISLE PIKE
MECHANICSBURG, PA 17055
by handing to
HENRY W. STRONG, II
a true and attested copy of MECHANICS LIEN CLAIM
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
6.82
.00
10.00
.00
34.82
so;;~~
R. Thomas Kline
Sworn and subscribed to before
03/01/2000
KEEEER, WOOD, ALLKE '~
By: ~f(
Deputy Sheriff
me this )3~ day of
!VI" , ,L ;1.lJ1J1.) A. D .
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Prothonotary }
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