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Home My WebLink About97-01814 . JOHN FLOOD 294 West Chester Pike Edqmont, PA 19028 Phone: (610) 459-4814 Pro Se . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY, PENNA. . . . DOCKET NO : 97- J8N . . . . . : . . . . . . CIVIL ACTION MECHANICS' LIEN CLAIM JOHN FLOOD 294 West Chester Pike Edqmont, PA 19028 Claimant -vs- DEER RUN APPALACHIAN CAMPGROUND, L.L.C. 121 South Broad Street suite 1600 Philadelphia, PA 19107 owners KOTICR OF MBCRANIC'S LIEN TO : DEER RUN APPALACHIAN CAMPGROUND, L.L.C.: 121 South Broad Street suite 1600 Philadelphia, PA 19107 Please be advised that a mechanincs' lien claim was rilod in the Court of Common Pleas of Cumberland County on the ,,/~ , 1997, at Docket Number q7 - (J' / l.-( day or A d/ . true and correct copy of the mechanics' lien claim is attached herto for your convenience. By: //.)~, John Fl06d Plaint~fr, Pro Se /) ( .' [' / JOHN FLOOD 294 West Chester Pike Edqmont, PA 19028 Phone: (610) 459-4814 Pro Se . IN THE COURT OF COMMON PLEAS . . OF CUMBERLAND COUNTY, PENNA. . . . DOCKET NO : 97- J~/'-f . . . . . . . . CIVIL ACTION . MECHANICS' LIEN CLAIM . JOHN FLOOD 294 West Chester Pike Edqmont, PA 19028 Claimant -vs- DEER RUN APPALACHIAN CAMPGROUND, L.L.C. 121 South Broad Street Suite 1600 Philadelphia, PA 19107 Owners MECHANICS' LIEN CLAIM JOHN FLOOD, files this Mechanic Lien Claim against DEER RUN APPALACHIAN CAMPGROUND, L.L.C., Owners, and against the building hereinafter described and the curtilage appurtenant thereto for the payment of a debt due JOHN FLOOD, as contractor. The following is a statement of the claim of JOHN FLOOD: 1. The name of the claimant is John Flood, whose business address is 294 West Chester Pike, Edqmont, PA 19028. Claimant is a plumbing contractor. 2. The name and address of the Owner at the time of the furnishing of the labor and materials and at the time of the attaching of the lien therefor is DEER RUN APPALACHIAN CAMPGROUND, L.L.C., with a principal place of business at 121 South Broad Street, , Suite 1600, Philadelphia, PA 19107. . . 3. The Claimant contracted with DEER APPALACHIAN RUN CAMPGROUND, L.L.C., pursuant to a written contract to supply labor and materials to alter and repair the plumbing to the bathhouses located upon the premises of Deer Run Appalachian Campground, L.L.C. A copy of the contract is attached hereto as Exhibit "A". 4. The nature and character of the labor and materials r I I f furnished pursuant to the oral contract included locating the coin-operated shower valves; installation of four new shower stalls and valves; installation of five water closets; install hot water heater; repairs and alterations water lines; installation of new water lines; installation of hot water lines and gas lines; " installation of exhaust pipes for water heaters; installation of new water holding tanks and well tank; repairs to faucets and water supplies at campsites and snack bar. 5. Claimant commenced delivering the labor and materials on or about April 1, 1996, and completed the project on March 31, 1997. 6. The total balance due for labor and materials is Five Thousand Ten Dollars and Forty Three Cents ($5,010.43). A copy is the final bill is attached hereto as Exhibit "B". 7. The labor and materials were continuously furnished in and about the bath houses and snack bar situated on the premises located in South Middletown Township, Cumberland County, more particularly described in the deed dated Hay 17, 1996, by and \\..: I /I". PROPOSAL lC~k~~ ,. Proposal No. She at No. Date '1-/- r, 6 Work To ae Performad At Street /1,_ City.. Date of Plans Architect H' . ___. _ wal::~~e to furnish the ma,.ials and perform the labor necemry for the completion of ~ ~~p"~/ ~'f~~,J-(h I(~~~J-~~.I{~ ,J--~~~/~~~~~, R~~~~~~,I!~I J~~~~/~~d~ ~~lfd~, ~/~I-~~ ~~A~~~/~~~~ '~~~;;r;:-~~/ I{~~&. ., ~~!~.7.~~~,~~~". "->Om and specifications submitted for above work and completed in J substantia workmanlike an fo the sum of h3rrn?'~~~0<4- . II I. with payments to be made as follows: ). . P'/!_ / ..L ~ . ~ aMA:( ~ t:JI4... ~. /U'" . ~ ~ /. d' ~ . /.f'4.~~ ~o~-1s-:()'*-~r ~ Anv~n~~~~R~~-r-'- ~ oKtra costl, will be eXKUted onlv upon written order., and will bKOmo In extra charge over and above tha estimate. All agreement. contingent upon strikes, eccident. or delays beyond Per ____" our control. Owner to carry fir.. tornado and other necessary insurance upon abovll work. Workmen's Compensation and Public LiabililY Insurance on above work to be laken out bV Note - This proposal may be withdrawn by us if not accepted within"] Z> days ACCEPTANCE OF PROPOSAL The above prices, specifications and conditions arc satisfactory and arc hereby accepted. ~u are authorized to do the work 8S specified. Payment will be made ilS outlined auove. 'I_I'" 7 ~ ~:-" . . Signature~ d ~,-!. ~U'o/.P?t'!~IMa-'d 4._~ Date c.(,!, /{? Signatur.l~ 1M]' ~;I/ l'A/._ !Y~,(... ;=r,/2. b of"..-t /4,.; TOI"'I "ORM NO. nlo . . . John Flood PUMP .. WELL SERVICES 2114 W. Ch.ller Pike PLUMBING" HEATING 458.-4814 Edgemonl, PA 19028 RESIDENTIAL.COMM EnC:AL.IN OUSTRI,. L -? .. ~ I -- tf 7 I " f9 t)~~kr 1/117' ~*~ M~P~~ @ rt-et. "u~'-~. .~t7.d'~ P+~- /J p 1/7 iA vf ~. ~ _!- ~ 6}Vt X. & (": (>r -;. J f(.,l... c:-:-- . ".,-,~A~ ~ . i l r' I I I i 1 I . I ; , i I. I ' i I I I I : ,. Lj.- ~ - '1 7 7~vf~~~ IVb-/~Lt,f(".A' tI ? q./'J "'-"_ .) (...-/. v v L( r; do f)~ 'i r ~--1-- tQ ~610.~J " / .... ~/,o^- ~;7'7'~?"~ II _'j /'. --1-/-,,(. . ~() fl' . .......... '-'1 " .... " v-. ~'.B r .. . . -..-----.,.......-....,.-----.".. ALL ehat traoe ot real o.eaeo with inprovanant., .ie~aeo in So~eh Middloton ~ownlhip, cu~orland co~ney, pannlylvania, bo~ndad and de.oribad a. tollow.' 1...."'" IIO...l.1 ADJOINING und. ot Ja"u A. Killor, hereinattar raterred to e. ~ract 110. 2 end 3. land ot eha south Hounealn Land cOllpany. and other I , oonteinin9 1 aoru. sora or 10'" eho ..id land beln9 tha .aaa which Charla. W. oeeo and Ballio ,.. otto, hi. wiCe, by their dud deted thO 4th daY ot Juno, 1901. lold and convoyad to Janel A. Killlr in ta.. :I)lA"'" 110, l' BEClI!llItNG at a point, the oornor of land. tomerlY ownad bY I.T. Mabol and land. tor"arlY owned by C.W. All 1 I thanco south 49 daqraa. za.t 68 parcha. ehrOuqh a tract of which this tract: vas or1ginallY a part, to a postl thence by lands fOr1J,erly ot c, W. l\hl and D. V. 1J1l, south 40 de9reell West 68 percheS to A post; thence bY Tract No.3, hereinafter described, North 49 de9rees West 11.5 perches to A post, thence by lands formerly of C.W. 1J1l, North 49 de9rees East 23 perch.. to the place of B!GINNtNG. CONTAINING 10 acres, more or less, 'J'RAC'l' NO. 11 BEG1.NNING at A point, the corner ot Tract No.2, hereinbetore de.cribed; thence by land fo~erlY ot C.W. !hl, south 49 degrees west 21',5 perches to II post; thence by lands torllllrly at c.w. !hl and O.V. /\hl, south 49 degrees East 14 perches to a post I thence by the 8a~e, North 40 degrees Bast 21.5 perches to a pOlt; thence by 'trllct No.2 hareinbefore describad, North 49 d89reell wast 11.5 perches to a post, thB place at BEGINNING. CONTAINING 12 acres, more or les8. BEING the same premises that LAverne B, Hoyer, ~y Deed dated March 30, 1.9B8, and recorded in the OUiCB of the RecoJ:der of Deedl in and for cuoberland county, pennsylvania, in Deed BooK G, volume 33, pa9G 273, granted and convayad unto Laverne S. Moyar and L. Edward Moyer, II, Grantor herein, as tenants in common and not al joint tGnllnts with right of survivorshiP, Lavorne B. Moyer departed this life on August 19, 1992, veltinq title to his tenan~ in COIMIOn interest in thB ~8tate ot taverne B. Moyer, deceue.'!.:-_---,---. I I ! t~c It VRRIFICATION The undersigned does hereby verify that the facts set forth in this pleading are true and correct to the best of my information, knowledge, and belief. I understand that false statements made herein are subject to the provisions and penalties set forth in 18 Par C.S. 4904 relating to unsworn falsifications to authorities. (j-)- (j-) date ! ,~/, / ( j. /,' i\// --..;/' p-ohn Flood ft .f ," .', - . 4 r7= (0 ., h 7--P n ,() n ", b :i ,: -J " 0_ :;~- -J ~ ."'ni "J '~l;rJ Y rr': ::;J 7~i I -!z ;S tJi -'l ~, U c;> '._J (0 .p -<, .~ 9 ,- j ::.. -3 ]::> .~: . ~ 8 ."'" '~lE) 3 ~ .~ ~ ' S Ii. (fl f4' t (2 or1l 0 "!: ~~( :~. ~ 3 ~ ~ , r 1; R -: (::I '< .., n ,., ~ -~ li" tI> ~ R 0 }J1 0 0 Il- i'l 0 - 0 ..t:. 0 u..o (L C ,::> '-' '. --J ',1 , :-.,. cJ " ;:'1 '.' " 'r- ,. ;-,") 11" :;J ,. - .1,('.... I . : -.-,~ '-'1 ; :",:J ,l> '. :2 "1111 ! :') .i~ .r."" -, \ .. OJ 11'1 I I ' 1/: ! , , i I Ii I I , , I I i i I, , I f , I DEER RUN APPALACHIAN CAMPGROUND, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Owner NO. 97-1814 v. FILED: April 8, 1997 JOHN FLOOD, Contractor: RELEASE OF MECHANICS' LIEN WHEREAS, John Flood performed services on real estate situate at 111 Sheet Iron Roof Road, South Middleton Township, Cumberland county, Pennsylvania, and filed a Mechanic's Lien against said real estate on April 8, 1997 in the amount of Five Thousand Ten Dollars and Forty-Three Cents ($5,010.43); and WHEREAS, Deer Run Appalachian Campground, LLC, owner of said real estate wishes to satisfy the Mechanic's Lien filed against said real estate by John Flood. NOW, THEREFORE, this ! I day of December 1997, the undersigned hereby agrees as follows: On April 8, 1997, the undersigned filed for record in the Office of Recorder of Deeds in and for Cumberland County, Pennsylvania, a notice of lien, which was recorded in Book If/~,MLO Page TI... - The notice of lien gave notice of the intention of the undersigned to claim a lien on the real property of Deer Run Appalachian Campground, LLC for labor performed by the undersigned. The real property is located at 111 Sheet Iron Roof Road, south Middleton Township, Cumberland County, Pennsylvania, and is more particularly described as follows: ALL that tract of real estate with improvements, situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: TRACT NO. 1: ADJOINING lands of James A. Miller, hereinafter referred to as tract No.2 and 3, land of the South Mountain Land Company, and others, containing 7 acres, more or less; the said land being the same which Charles W. otto and Sallie A. otto, his wife, by their deed dated the 4th day of June, 1907, sold and conveyed to James A. Miller in fee. TRACT NO.2: BEGINNING at a point, the corner of lands formerly owned by Z.T. Meixel and land formerly owned by C.W. Ahl; thence South 49 degrees East 68 perches through a tract of which this tract was originally a part, to a post; thence by lands formerly of C.W. Ahl and D.V. Ahl, South 40 degrees West 68 perches to a post; thence by Tract No.3, hereinafter described, North 49 degrees West 71.5 perches to a post; thence by lands formerly of C.W. Ahl, North 49 degrees East 68 perches to the Place of BEGINNING. CONTAINING 10 acres, more or less. TRACT NO.3: BEGINNING at a point, the corner of Tract No.2, hereinbefore described; thence by land formerly of C.W. Ahl, South 49 degrees West 27.5 perches to a post; thence by lands formerly of C.W. Ahl and D.V. Ahl, South 49 degrees East 74 perches to a post; thence by the same, North 40 degrees East 27.5 perches to a post; thence by Tract No. 2 hereinbefore described, North 49 degrees West 71.5 perches to a post, the Place of BEGINNING. CONTAINING 12 acres, more or less. BEING the same premises that Laverne E. Moyer, by Deed dated March 30, 1988, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book "G", Volume 33, Page 273, granted and conveyed unto Laverne E. Moyer and L. Edward Moyer, II, Grantor herein, as tenants in common and not just as joint tenants with right of survivorship. Laverne E. Moyer departed this life on August 19,1992, vesting title to his tenant in common interest in the Estate of Laverne E. Moyer, deceased. On December 16, 1997, the owner of the real property fully satisfied the indebtedness mentioned in the notice of lien by paying to the undersigned the sum of Five Thousand Ten Dollars and Forty-Three Cents ($5,010.43). In consideration of such payment, the undersigned releases any and all rights the undersigned may have acquired in or to the mentioned property by reason of the notice of lien. Dated: I /- /~ -9 7 , 1997 (2) I, Ii. I: I I I I I ! \ I It I t' I I I . t R ""<l 0 \0 C lXI 0 ~ .,.," ..., '" C ~?!Z: r'l :-;J ft:. ::;j .1. ." I Il--~ .'"\ ",,'''' "In ~ :',' V . '-) ,';0 ~..I: ' , )J \l> '".:( ::=.. ''-'0 ~ .' n,. r.;::' 1-:~i' ~ ( J-J (l' 0 () lO -j. ("> P=- .. \'5111 C. ..... ;;:;! :! :::> ...J :.0 -<; r f (/I