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