The URL can be used to link to this page

Home My WebLink About03-1604MONROE TOWNSHIP MUNICIPAL AUTHORITY, Claimant vs. PAUL ROMANO, JR., .~ /~m ~/c ~. ~w. ner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA o3-1 NO. 01-4363 MUNICIPAL LIEN DOCKET 2001 MUNICIPAL LIEN PRAECIPE FOR THE WRIT OF SCIRE FACIAS SUR MUNICIPAL CLAIM To: Curtis R. Long, Prothonotary Dear Sir: On behalf of the Monroe Township Municipal Authority, claimant in the above-captioned matter, kindly issue the attached Writ of Scire Facias Sur Municipal Claim. Please be advised that said claim is still due and unpaid, and remains a lien against said property described therein. April 8, 2003 Mon~ Town~ip Municipal Authority James D. ~o~ar, Esquire J B. Hipp, Esquire Solicitors for the Monroe Township Municipal Authority MONROE TOWNSHIP MUNICIPAL AUTHORITY, Claimant vs. PAUL ROMA-NO, JR. Owners IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4363 MUNICIPAL LIEN DOCKET 2001 MUNICIPAL LIEN WRIT OF SCIRE FACIAS SUR MUNICIPAL CI2%IM The Commonwealth of Pennsylvania to Paul Romano, Jr., Greeting: Whereas, the Monroe Township Municipal Authority, of 1220 Boiling Springs Road, Mechanicsburg, Pennsylvania, 17055, (hereinafter referred to as the "Authority"), on July 19, 2001 filed its Municipal Lien for Sewer Connection in the Court of Common Pleas of Cumberland County, Pennsylvania, at No. 01-4356 Municipal Lien Docket 2001, for the sum of $3,000.00, with interest in the amount of ten (10) percent, along with penalties and all costs, including attorneys' fees, for a sewer connection fee against all that certain lot of ground, including any improvements located thereon, same being known and numbered as 324 North Street, Boiling Springs, Monroe Township, Cumberland County, Pennsylvania, owned or reputed to be owned by you, said property being more fully described as follows: ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in Monroe Township, Cumberland County, Pennsylvania, in accordance with a survey prepared by C.W. Junkins, R.S., dated August 11, 1994, as follows, to wit: BEGINNING at a point in concrete curving at corner of lands of John B. Backenstoes; thence along lands of Backenstoes, South 74 degrees 12 minutes 20 seconds West 84.40 feet to a corner of concrete curbing; thence along lands of Christopher M. Pass and Genevieve A. Diehl, the following three courses and distances: 1) North 15 degrees 47 minutes 00 seconds West 40.50 feet; 2) South 74 degrees 50 minutes 00 seconds West 39.93 feet; 3) North 14 degrees 14 minutes 39 seconds West 167.76 feet to corner of concrete curbing; thence along lands of David J. Miller, North 74 degrees 02 minutes 45 seconds East 114.75 feet to corner of concrete curbing; thence along intersection of West Street and continuing along North Street, South 17 degrees 10 minutes 28 seconds East 209.02 feet to a point in concrete curbing, the Place of BEGINNING. CONTAINING 23,423 square feet, having thereon erected 2 - two story frame dwellings. BEING THE SAME PREMISES which John C. Harbold, by his Attorney-In-Fact, Debra A. Bender, by Deed dated November 1, 1995 and recorded in the Cumberland County Recorder of Deeds Office on November 8, 1995, in Deed Book 130, Page 1042, granted and conveyed unto Paul Romano, Jr., owner. Tax Property Map Parcel Number: 22-28-2401-004 And whereas, We have been given to understand that said municipal claim is still due and unpaid, and remains a lien against the said property; NOW, you are hereby notified to file your affidavit of defense to said claim, if defense you have thereto, in the office of the Prothonotary of our said Court, within fifteen (15) days after service of this writ upon you. If no affidavit of defense be filed within said time, judgment may be entered against you for the whole claim, and the property described in the claim be sold to recover the amount thereof. Witness, the Honorable George E. Hoffer, President Judge of our said court, this day of , 2003. Curt isLong,' P~th6~tary Ja~es D. B~a~, Esquire Attorney ~D. ~o. 19475 One West Ma~i-D_3Street Shiremanstown, PA 17011 (717) 737-8761 Jennifer~B. Hipp, Esquire Attorney ~.D. No. 86556 One West main Street Shiremanstown, PA 17011 (717) 737-8761 April 8, 2003 Solicitors for Monroe Township Municipal Authority MONROE TOWNSHIP, Claimant vs. PAUL ROMANO, JR. Owner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-4363 MUNICIPAL LIEN : DOCKET : MUNICIPAL LIEN VOLUNTARY SUBSTITUTION OF MONROE TOWNSHIP MUNICIPAL AUTHORITY AS A PARTY CLAIMANT 1. The Monroe Township Municipal Authority (hereinafter the "Authority") is the successor in interest of Monroe Township, who is the claimant herein, and desires to substitute itself for Monroe Township as the claimant herein. 2. The material facts on which the Authority's right of succession and substitution are based are as follows: a. On December 31, 2002, the Authority was created as an independent operating authority. b. Thereafter, Monroe Township transferred any municipal liens and any other pending litigation that should rightfully be handled by the Authority to the Authority. c. On July 19, 2001, Monroe Township filed a Municipal Claim for Sewer Connection. The amount of the sewer connection was $3.000.00, which sum was duly assessed against PAUL ROMANO, JR., owner of real property, including improvements thereon, located at 324 North Street, Boiling Springs, Pennsylvania. d. The Monroe Township sewer connection fee was levied and assessed pursuant to Township Ordinance No. 3 of 1978, same being known and cited as the "Monroe Township Sewer Rental and Charge Ordinance," as amended. 3. The Monroe Township Municipal Authority hereby voluntarily substitutes itself as a claimant herein in the place and stead of Monroe Township. Monroe Township Municipal Authority Jades D. Bog<r} Esquire Jenni~e~B. Hip~, Esquire April 8, 2003 Solicitors for Monroe Township Municipal Authority -2- PROOF OF SERVICE We, James D. Bogar, Esquire, and Jennifer B. Hipp, Esquire, hereby certify that we are this day serving the foregoing Voluntary Substitution of Monroe Township Municipal Authority as a Party Claimant upon the person and in the manner indicated below: Service by first-class mail addressed as follows: Paul Romano, Jr. 324 North Street Boiling Springs, PA 17007 April 8, 2002 M onr~/~wns h~uni c ipa 1 Authority Ja~s D. Bo~rI, Esquire Jenni~e~ B. Hipp~~ Esquire 3 Solicitors for Monroe Township Municipal Authority -3- MONROE TOWNSHIP MUNICIPAL AUTHORITY, Claimant vs. PAUL ROMANO, JR. Owner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4363 MUNICIPAL LIEN DOCKET 2001 MUNICIPAL LIEN ENTRY OF APPEAPJ%NCE To The Prothonotary: We enter our appearance for the Monroe Township Municipal Authority as a party claimant herein. B~a% Esquire Attorney I...N~_~o. 19475 One West Main Street Shiremanstown, PA 17011 (717) 737-8761 Jenn~-f~B. Hipp) % Esquire Attorney~I. D. No. 86556 One West Main Street Shiremanstown, PA 17011 (717) 737-8761 April 8, 2002 Solicitors for Monroe Township Municipal Authority SHERIFF'S RETURN CASE NO: 2003-01604 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MONROE TOWNSHIP MUNICIPAL VS ROMANO JR PAUL REGULAR DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SCIRE FACIAS was served upon ROMANO PAUL JR the DEFENDANT , at 1525:00 HOURS, on the llth day of April , 2003 at 324 NORTH ST BOILING SPRINGS, PA 17007 by handing to PAUL ROMANO JR a true and attested copy of WRIT OF SCIRE FACIAS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.83 Affidavit .00 Surcharge 10.00 .00 32.83 Sworn and Subscribed to before me this 23~ day of ~.r~,, i~. ~)~0 !~ A.D. - ;P~othonotary So Answers: R. Thomas Kline 04/14/2003 JAMES D BOGAR By: %~o~v~r~ ~ Deputy Sheril~f