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HomeMy WebLinkAbout00-03547 "" -.- """",,"-~-~~-- 'rbt. , .... . ~ " ~ .. JACK BROWN WHOLESALE SUPPLY, INC., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA Claimant v. NO. ;)000 - 35'-11 /!II Lf) SHERRY L. HUGHES, a married woman, Owner CIVIL ACTION - LAW MECHllNICS' LIEN CLAIM 1. The Claimant, is Jack Brown Wholesale Supply, Inc. ("Jack BrownU), a Pennsylvania corporation with offices located at 2969 North 7th Street, Harrisburg, Dauphin County, Pennsylvania, who files this Mechanics Lien Claim as a contractor/materialman. 2. The Owner of the property subject to the mechanic's lien is Sherry L. Hughes, a married woman, with an address at 232 West Lisburn Road, Upper Allen Township, Cumberland County, Pennsylvania. 3. Claimant and the Owner, and her husband, entered into a contract with the Claimant to furnish windows to be installed in the Owner's personal residence on the Owner's property at an agreed upon sum of $54,088.51. 4. The windows were delivered by the Claimant to the Owner's property on February 14, 2000. ~o "",,"" ,',..MJ,,- ~ '" 5. The windows were furnished with the knowledge and consent, and at the request of the Owner. 6. The amount unpaid and owing by the Owner to the Claimant is $10,000.00. 7. The improvements and property claimed to be subject to the mechanics' lien is all that certain tract of land situate in Upper Allen Township, Cumberland County, on which a personal residence is being constructed on a 14.85 acre tract of ground being known as Lot No. 3 of the Pennsylvania Supply Company Bowmansdale Quarry Final Subdivision Plan, dated September 9, 1996, last revised April 18, 1997, recorded April 30, 1997, in the Office of the Recorder of Deeds of Cumberland County in Plan Book 75, Page 94, being conveyed to the Owner by deed dated May 19, 1997, and recorded May 21, 1997, in Record Book 157, Page 1098. A true and correct of the legal description is attached hereto and marked as Exhibit "An. squire 1 North Second Street 17110 Attorney for Claimant J .. - . ALL THAT CERTAIN tract or lot of real estate situate in Upper Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a concrete monument located on the northern dedicated right-of-way line of West Lisburn Road, also formerly known as LR 2004, in Upper Allen Township, Cumberland County, Commonwealth of Pennsylvania: said point being the soutl~eastern c.o~n~r of LO;,2 of the recorded "Pennsylvania Supply Company Bowmansdale Quarry Fmal Sub.dl.v~slOn Plan, thence the following two (2) courses and distances along Lot 2 of said recorded subd.lVISlO~ plan: (I) North 70 degrees 54 minutes 35 seconds West a distance of 763.09 feet to an \fan pm; (2) North 19 degrees 45 minutes 00 seconds West a distance 0033.09 feet to a concrete monument at a corner of Lot 4 on said recorded subdivision plan: thence the following two (2) courses and distances aJongLot 4: (I) North 58 degrees 47 minutes 42 seconds East a distance of535.77 feet to an iron pin; (2) North 74 degrees 03 minutes 36 seconds East a distance of 253.87 feet to a concrete monument on the western dedicated right of way line of Bumble Bee Hollow Road; thence southwardly along the western dedicated right of way line of said Bumble Bee Hollow Road the following five (5) courses and distances: (I) South 34 degrees 31 minutes ]8 seconds East a distance of56.95 feet to a point; (2) a curve to the right having a chord bearing 0 south 3 I degrees 15 minutes 56 seconds East, a chord distance of223.78 feet a radius of 1,970.00 feet and an arc length of223.91 feet to a point; (3) South 67 degrees 22 minutes 45 seconds East a distance of 109.00 feet to a point; (4) a curve to the left having a chord bearing of South 36 degrees 06 minutes 10 seconds East. a chord of92.92 feet, a radius of330.00 feet and an afG length of93.23 feet to a point; (5) South 44 degrees 11 minutes 45 seconds East a distance of445.74 feet to a concrete monument at the northwestern intersection of the dedicated right of way lines of said Bumble Bee Hollow Road and said West Lisburn Road; thence along the northern dedicated right of way line of said West Lisburn Road the following four (4) courses and distances: (I) a curve to the left having a chord bearing of South 69 degrees 45 minutes 25 seconds West. a chord distance of24.58 feet, a radius of 880,00 feet and an arc length of 24.58 feet to a point; (3) South 67 degrees 22 minutes 45 seconds West a distance of 109,0 I feet to a point; (4) a curve to the right having a chord bearing of South 69 degrees 0 I minutes 41 seconds West, a chord distance of 113.38 feet, a radius of 1,970.00 feet and an arc length 113.40 feet to a concrete monument, the point ofBEGfNNfNG. CONTAINING 646.664 square feet or 14,85 acres. BEING Lot No.3, pennsylvania Supply Company Bowmansdale Quarry Final Subdivision Plan, dated September 9,1996, last revised April 18, 1997. recorded April 30, 1997, in the Omce of the Recorder of Deeds of Cumberland County in Plan Book 74, Page 94. EXHIBIT "An ~ ; , " , . VERIFICATION I hereby affirm that the following facts are correct: I am the CORP. CREDIT MANAGER of Jack Brown Wholesale Supply, Inc., Claimant in the foregoing action. The attached Mechanic's Lien Claim is based upon information which has been furnished to counsel and information which has been gathered by counsel in the preparation of this document. The language of the Mechanic's Lien Claim is that of counsel and not mine. I have read the Mechanic's Lien Claim and to the extent that the same is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the Mechanic's Lien Claim is that of counsel, I have relied upon counsel in making this Verification. I hereby acknowledge that the averments of fact set forth in the aforesaid Mechanic's Lien Claim are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. JACK BROWN WHOLE SUPPLY, INC. /:2- L.~g) Name: C JIM KING Title: CORP. CREDIT MANAGER ." ~. ...:i_ ,,~ 0;: = ~ i _" "L ~ ' JACK BROWN WHOLESALE SUPPLY, INC., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA Plaintiff CIVIL ACTION - LAW v. SHERRY L. HUGHES NO. 2000-3547 MI...\) Defendant PRAECIPE TO THE PROTHONOTARY: Please mark the above-captioned matter settled, discontinued and ended with prejudice. Date: 7-10 -t;PO ;j;. M. Socha, Esquire 2201 North Second Street Harrisburg, PA 17110 (717) 233-4141 Attorney for Defendant :.;.;- UIJ_Illil:iJ~>="' 1ilII~~t"""""'"'- d~llil:l""JIUUI'I""""";'~"-~~';"JiIfl~ ---,'",.-,' ,,--.!.., . . . () 0 0 c: 0 -n ? '-- -"> ~~~~'. -om c:: ~m r- ...~ :sts zs; 0 (j') .c: C),L, =<::"c:. ~,,-' C:;:C " -,--"r. :J;() :'3;: ~;~~ ~O t;1 )7c ::::::, :z - )0> ~ :D OJ ..<. CASE NO: 2000-03547 P SHERIFF'S RETURN - REGULAR \~, '<" COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BROWN JACK WHOLESALE SUPPLY IN VS HUGHES SHERRY L WILLIAM DIEHL , Sheriff or Deputy Sheriff of says, the within MECHANICS LIEN CLAIM was served upon 'I :1 , , I i , , ~I , I i ,! !i i! i 'I !I I 'i, I , I , Ii Cumberland County, Pensyl vania , who being duly sworn according to law, HUGHES SHERRY L the OWNER , 2000 , at 0019:55 HOURS, on the 12th day of July at 232 W LISBURN RD MECHANICSBURG, PA 17055 MARK HUGHES (HUSBAND) by handing to 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 Sworn and Subscribed to before tt,., me this /9 - day of C). ; ",2.o-vV A . D . ' iQ /) ""l. ' 'ti'" LL //I1,lJtJ'-1~ r thonotary So ;;~~t R. Thomas Kline 07/13/2000 FRANCIS M. SOCHA I j) DP~' By: