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HomeMy WebLinkAbout01-4588SUSQUEHANNA OIL CO. P. O. BOX 700 DILLSBURG, PA 17019 Claimant V. KINNEY ASSOCIATES, THOMAS M. KINNEY, SR. and PAULA KINNEY 16 WEST MAIN STREET MECHANICSBURG, PA 17055 and 211 BEAVER DRIVE MECHANICSBURG, PA 17055 Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 0/- L/5-~ MECHANICS' LIEN CLAIM FOR PROPERTY % LOCATED AT 7 W.'-~T ;~i;~ STR,-,-~,, BOI~U~C~, I "/.~,,4 ~t _OF MECHANICSBURG, CUMBERLAND COUNTY, PENNSYLVANIA To: KINNEY ASSOCIATES, THOMAS M. KINNEY, SR. and PAULA KINNEY 1. The name of the party claimant is SUSQUEHANNA OIL CO., ("Claimant") with a mailing address of P.O. Box 700, Dillsburg, Pennsylvania 17019. The Claimant files its Mechanics' Lien Claim as a contractor. 2. The names and addresses of the owners of the property subject to the Lien are KINNEY ASSOCIATES, THOMAS M. KINNEY, SR. and PAULA KINNEY, of 16 West Main Street, Mechanicsburg, Pennsylvania 17055 and 211 Beaver Drive, Mechanicsburg, Pennsylvania 17055. 3. On or about 19 March 2001, Claimant entered into an oral contract with Defendants when Defendants placed a service call and requested Claimant to furnish labor and materials for the repair of a cast iron boiler situated in the commercial building on the land hereinafter described. 4. The Claimant's work was completed on 2 April 2001. 5. The Claimant contracted with the Defendants. 6. The labor and materials were furnished with the request, knowledge and consent of the Defendants. 7. The amount due and owing to Claimant for the materials and labor is Three Thousand Three Hundred Six Dollars ($3,300). 8. The real estate and improvements subject to this Mechanics' Lien consists of all that properly known as~t, Borough of Mechanicsburg, Cumberland County, Pennsylvania, and all improvements at this location. The said real estate is also known as Cumberland County Tax Map Parcel No. I {~'~'~-D ~'~'-00~' Respectfully submitted, MILLER & ASSOCIATES, PC Dated: 1 August 2001 By: · Miller, Jr., Esquire Anthony E. Marrone, Esquire 1822 Market Street Camp Hill, PA 17011 I.D. Nos. 07220 and 48182 (717) 737-9211 Attorneys for Claimant VERIFICATION The undersigned, ANTHONY E. MARRONE, hereby verifies and states that: 1. He is attorney for Claimant herein; and 2. He is authorized to make this Verification; and 3. He makes this verification because the Defendant's verification cannot be obtained within the time allowed for filing the Mechanic's Lien; and 4. The Facts set forth in the foregoing Mechanic's Lien are true and correct to the best of his knowledge, or information and belief based upon the information contained in his file and provided by Claimant; and 5. He is aware that false statements herein are made subject to the penalties of 18 Pa. C.S. {}4904, relating to unsworn falsification to authorities. Dated: August 1,2001 -3- SHERIFF'S RETURN - REGULAR CASE NO: 2001-04588 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SUSQUEHANNA OIL CO VS KINNEY ASSOCIATES ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within MECHANICS LIEN CLAIM was served upon KINNEY ASSOCIATES the OWNER , at 0017:25 HOURS, on the at 211 BEAVER DRIVE 3rd day of August , 2001 MECHANICSBURG, PA 17055 PAULA KINNEY (CO-OWNER) by handing to a true and attested copy of MECHANICS LIEN CLAIM together with and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: Docketing 18.00 Service 7.80 Affidavit .00 Surcharge 10.00 .00 35.80 Sworn and Subscribed to before me this ~ day of A.D. Pr6t~onotary So Answers: R. Thomas Kline 08/07/2001 MILLER & ASSOCIATES Deputy S~J' f f SHERIFF'S RETURN - REGULAR CASE NO: 2001-04588 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SUSQUEHANNA OIL CO VS KINNEY ASSOCIATES ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to says, the within MECHANICS LIEN CLAIM was served upon KINNEy THOMAS M SR the law, OWNER , at 0017:25 HOURS, on the 3rd day of August at 211 BEAVER DR , 2001 MECHANICSBURG, PA 17055 PAULA KINNEY (CO-OWNER) by handing to a true and attested copy of MECHANICS LIEN CLAIM together with and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this _~--~ day of A.D. ~r%thonot ary " So Answers: R. Thomas Kline 08/07/2001 MILLER & ASSOCIATES Deputy Shelf f SHERIFF'S RETURN - REGULAR CASE NO: 2001-04588 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SUSQUEHAA/NA OIL CO VS KINNEY ASSOCIATES ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within MECHANICS LIEN CLAIM was served upon KINNEY ASSOCIATESthe OWNER , at 0017:25 HOURS, on the at 211 BEAVER DRIVE 3rd day of August , 2001 MECHANICSBURG, PA 17055 PAULA KINNEY (CO-OWNER) by handing to a true and attested copy of MECHANICS LIEN CLAIM together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 7.80 Affidavit .00 Surcharge 10.00 .00 35.80 Sworn and Subscribed to before me this ~ day of Pr6t~onotary ' So Answers: R. Thomas Kline 08/07/2001 MILLER & ASSOCIATES Deputy sb~i f f SHERIFF'S RETURN - REGULAR CASE NO: 2001-04588 p COMMONWEALTH OF PENNSYLVANIA: COUNTy OF CUMBERLAND SUSQUEHANNA OIL CO VS KINNEY ASSOCIATES ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly SWorn according to law, says, the within MECHANICS LIEN CLAIM was served upon KINNEY THOMAs M SR the OWNER at 211 BEAVER DR at 0017:25 HOURS, on the _3rd day of A~ugust , 2001 MECHANICSBURG, PA 17055 PAULA KINNEY (CO-OWNER) by handing to a true and attested copy of MECHANICS LIEN CLAIM together with and at the same time directing ~er attention to the contents thereof. Sheriff,s Costs: So Answers: Docketing 6.00 ~ Service .00 ' .~~~/~ Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 16.00 08/07/2001 MILLER & ASSOCIATES Sworn and Subscribed to before me this . ~--- day of O.x.~ ~,.,~..6- ,~7.~r~ ~ A.D. ~rbthonotary "/ ~ eputy Sh~iff ' SHERIFF'S RETURN CASE NO: 2001-04588 p COMMONWEALTH OF PENNSYLVANIA: COUNTYOFCUMBERLAND .SUSQUEHANNA OIL CO VS KINNEY ASSOCIATES ET AL - REGULAR ~ERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within MECHANICS LIEN CLAIM was served upon KINNEY PAULA the OWNER , at 0017:25 HOURS, at 211 BEAVER DRIVE MECHANICSBURG, PA 17055 PAULA KINNEy a true and attested copy of MECHANICS on the _3rd day of August , 2001 by handin9 to LIEN CLAIM together with and at the same time directing ~er attention to the contents thereof. Sheriff,s Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this [~ day of O~ .... J- .%m~ [ A . D . So Answers: R. Thomas Kline 08/07/2001 MILLER & ASSOCIATES Deputy Skf6riff McN£ES, WALLACE & NURICK SUSQUEHANNA OIL CO. P.O. BOX 700 DILLSBURG, PA 17019 Claimant KINNEY ASSOCIATES, THOMAS M. KINNEY, SR. and PAULA KINNEY 16 WEST MAIN STREET MECHANICSBURG, PA 17055 and 211 BEAVER DRIVE MECHAN1CSBURG, PA 17055 Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 01-4588 : MECHANICS' L1EN PRAECIPE FOR ENTRY OF APPEARANCE TO: Prothonotary Please enter our appearance on behalf of Defendants Kinney Associates, Thomas M. Kinney, Sr. and Paula Kinney. Respectfully submitted, 4 Jonathan H. Rudd, Esq. c; y C. Fazio, Esq. Nees Wallace & Nurick LLC Pine Street ..... P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Date: September(~, 2001 SUSQUEHANNA OIL CO. P.O. BOX 700 DILLSBURG, PA 17019 Claimant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA KINNEY ASSOCIATES, THOMAS M. KINNEY, SR. and PAULA KINNEY 16 WEST MAIN STREET MECHANICSBURG, PA 17055 and 211 BEAVER DRIVE MECHANICSBURG, PA 17055 Defendants No. 01-4588 IVIECHANICS' LIEN PRAECIPE FOR ENTRY OF APPEARANCE TO: Prothonotary Please enter our appearance on behalf of Defendants Kinney Associates, Thomas M. Kinney, Sr. and Paula Kinney. Respectfully submitted, ~:;q~fi' ck LL~~CC~ Harrisburg, PA 17108-1166 (717) 232-8000 Date: September~ 2001 CERTIFICATE OF SERVICE I, Jonathan H. Rudd, Esquire, hereby certify that on this l~ day of September, 2001, a tree and correct copy of the foregoing document was served by first-class, United States mail, postage prepaid, upon the following: Anthony E. Marrone, Esquire Miller & Associates, P.C. 1822 Market Street Camp Hill, PA 17011 SUSQUEHANNA OIL CO. P. O. BOX 700 DILLSBURG, PA 17019 Claimant KINNEY ASSOCIATES, THOMAS M. KINNEY, SR. and PAULA KINNEY 16 WEST MAIN STREET MECHANICSBURG, PA 17055 and 211 BEAVER DRIVE MECHANICSBURG, PA 17055 Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 01-4588 Mechanics' Lien : . : : PRAECIPE FOR ENTRY OF SATISFACTION TO: PROTHONOTARY OF CUMBERLAND COUNTY Please mark the docket in the above-captioned matter as the Plaintiffhas been paid and the above lien entered in the mechanics' lien indices should be marked as Plaintiff satisfied. Dated: Respectfully submitted, MILLER & ASSOCIATES, PC By: 511i~ E! 'M~quire Anthony E. Marrone, Esquire 1822 Market Street Camp Hill, PA 17011 I.D. Nos. 07220 and 48182 (717) 737-9211 Attorneys for Claimant