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HomeMy WebLinkAbout00-00880 ,.' 1'",,' --. . '-? "C' ',"~ ',,0 " '-'- --~ .'-- ~, ,'~" '~;" ,', , -- p , ~ . 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 fYlj.Jj~ 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 ",' """,.J.lIC""h'''' , ".h',ii,', ".' "" ",,;,~ ,,' , . " " """""'"'~''''' "0<",~~ """"",.",,' - \ ~0;--;,: C!:C" "":::....' Cr: ~:;[:-::. ;?~~ i:' ;"-~:':!- , )>~ ~-:.---, --, -< (') ("-' ~. '~',- ~"'~, " 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. , "~,oc,'",,,~', '", " ,,' , ."'" ;;__~ '",'0 . -" ',;' ",*,''', ",.,,',-,',,',-' 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). ,"'- '--'-"",,, .~,~. "." _, ~,- _ .. , ,'i:,:>'-~i~,'., ~ . ;:"",:,,;c:,:.'- ','-.c''',__ ,__',', '~', ..___,', "~--;"~,'''~-"'2:-''''2'';'--' ,--.~j '; 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 'L"_" ,- .-' ~-; 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. ? Date: r;:l{. f - t70 , 2000 ~. .,...., . -".;jf;~/'-. t/ Ed Coombs General Contractor/Construction Manager - ;.-~, ~ ...Q ~ o ~ ~ -:-0 ~ g ~f: ~ "tg ~ t~' ;c f..i,:'C'- .....:,-_.'" 2~r-- :::) j", [> ""- ,--~ 5>~~ ':::j -<, (") c: ~) "'."C; ~ f'" t ,~ 'C,") 'n ....J (., __1,,_, 2: if) c,",.; "" ,'~" ,~.' ~:-'d..--L...:.c ",' ';, .. ED COOMBS, t/dIb/a ED COOMBS, GENERAL CONTRACTOR! CONSTRUCTION MANAGER, Claimant v. HENRY W. STRONG, II, Owner , ,', '~ ' "_;<';"",~' '>"~j "'_,^"'-- "0 ~ ", >"'"il '" .1 >,:,_'.':;;)~ .-.,,<c "0 , ,",',--. ""_"0<, - . 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 ,,' '" ..,"""" 'hC I, ""<,i,;.',,,;'. :i;. '"".," "c" /i'i'S", '"'''' '.""",,,.':,,, 'i'; i,,; " . . .- "'h','"" f"","",.. " , ""k '1';" ~, C> 0 0 "Tt ::g .,-, riliU;; ~, ~:D -<",^, "'''- z~ (..:> -.:~tB z.' Go?'"Z: C> "''''~ '::::" . ~.o .." <H ';'~B is ::x t5.1~ 'ff '~ "'i - ~ . ,- ~~. ~'"", 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 . G..."" () ~~ ~ Prothonotary } ...".