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Home My WebLink About03-1605MONROE TOWNSHIP MUNICIPAL AUTHORITY, Claimant vs. STEVEN P. DOODAN, ~R/~C'I'~E FOR THE WR'rT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4372 MUNICIPAL LIEN DOCKET 2001 MUNICIPAL LIEN 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 q ~gar, Esquire Jennifer~B. Hipp, Esquire Solicitors for the Monroe Township Municipal Authority MONROE TOWNSHIP MUNICIPAL AUTHORITY, Claimant vs. STEVEN p. DOODAN, Owner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4372 MUNICIPAL LIEN DOCKET 2001 MUNICIPAL LIEN WRIT OF SCIRE FACIAS SUR MUNICIPAL CLAIM The Commonwealth of Pennsylvania to Steven p. Doodan, 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. 01-4372 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 the sewer connection fee against all that certain lot of ground, including any improvements located thereon, same being known and numbered as 339 and 339B Old Stone House Road, 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 house and lot of ground situate in the Village of Churchtown, Monroe Township, Cumberland County, Pennsylvania, bounded and described as follows: ON the north by property now or formerly of Riley Urich; on the east by an alley; on the south by property now or formerly of Sarah Garver or Murray Brownawell; and on the west by Main Street. CONTAINING 33 feet in front on said Main Street and extending in depth 200 feet to said alley. HAVING THEREON ERECTED a two and one-half story brick dwelling house, now containing two residences, and outbuildings, known as and numbered 339 and 339B Old Stonehouse Road, Boiling Springs, Pennsylvania, 17007 BEING the same premises which Isabella E. Lear, widow, by her Attorney-in-Fact Betty E. McCleaf of Gettysburg, Adams County, Pennsylvania, by deed dated August 1, 1991, and recorded August 1, 1991, in the Cumberland County Recorder of Deeds Office in Deed Book G, Volume 35, Page 34, granted and conveyed unto Steven p. Doodan, owner. Tax Property Map Parcel Number: 22-28-2401-103 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. ~urtis R. Long, Prothonotary- One West Main Street Shiremanstown, PA 17011 (717) 737-8761 April 8, 2003 Jenn~r B. Hipp, Esquire Attorney I.D. No. 86556 One West Main Street Shiremanstown, PA 17011 (717) 737-8761 Solicitors for Monroe Township Municipal Authority MONROE TOWNSHIP, Claimant vs. STEVEN P. DOODAN, Owner : IN THE COURT OF COMI4ON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-4372 MUNICIPAL LIEN : DOCKET 2001 : : : 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 STEVEN P. DOODAN, owner of real property, including improvements thereon, located at 339 and 339B Old Stone House Road, Boiling Springs, Pennsylvania. 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. April 8, 2003 Monroe Township Municipal Authority Ja~es D. Bo~r, Esquire Jenni~e~ B. Hipp, Esquire 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: Steven P. Doodan 197 Village Road Harrisburg, PA 17112 April 8, 2002 MonrQe~Towgs~ip Municipal Authority a~es D.-~Og~r, Esquire Jennifer~B. Hipp, Esquire Solicitors for Monroe Township Municipal Authority -3- MONROE TOWNSHIP MUNICIPAL AUTHORITY, Claimant vs. STEVEN P. DOODAN, Owner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4372 MUNICIPAL LIEN DOCKET 2001 MUNICIPAL LIEN ENTRY OF A/~PEA/~3~NCE TO The Prothonotary: We enter our appearance for the Monroe Township Municipal Authority as a party claimant herein. James D. B~4r, Esquire Attorney ~...~ No. 19475 One West Main Street Shiremanstown, PA 17011 (717) 737-8761 Jen~rflf%r B. lpp, Esquire Attorn~ 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 - OUT OF COUNTY CASE NO: 2003-01605 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MONROE TOWNSHIP MUNICIPAL VS DOODAN STEVEN P R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: DOODAN STEVEN P but was unable to locate Him deputized the sheriff of DAUPHIN in his bailiwick. He therefore County, Pennsylvania, to serve the within WRIT OF SCIRE FACIAS On May 8th , 2003 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin County 18.00 9.00 10.00 30.50 .00 67.50 o5/o8/2oo3 JAJ4ES D BOGAR So answers~~ ~ ..... ~. Thomas ~lzhe/-/ Sheriff of Cumberland County Sworn and subscribed to before me this /~ day of~ A.D. P~-ot honot ar~ ~ Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania : MONROE TOWNSHIP MUNICIPAL AUTHORITY vs County of Dauphin : DOOD/k_N STEVEN 0 Sheriff' s Return No. 0887-T - -2003 I~o~ OTHER COUNTY NO. 03 AND NOW:May 1, 2003 at 4:28PMserved the within WRIT OF SCIRE FACIAS SUR MUNICIPAL CLAIM upon DOODAN STEVEN 0 by personally handing to DEF 1 true attested copy(les) of the original WRIT OF SCIRE FACIAS SUR MUNICIPAL CLAIM and making known to him/her the contents thereof at SHERIFF'S OFFICE 112 MARKET STREET, 5TH FLOOR HARRISBURG, PA 17101-0000 Sworn and subscribed to before me this 5T~day of MAY, ~ROTHONOTAR¥ 2003 So Answers, Sheriff of Dauphin County, Pa. Sheriff's Costs: $30.50 PD 04/14/2003 RCPT NO 177608 Fa The Court of Common Pleas of Cumberland County, Pennsylvania Monroe Township Municipal Authority VS. Steven P. Doodan SERVE: s~ne No. 03-1605 civil Now, April 11, 2003 hereby deputize the Sheriff of , I, SHERIFF OF CUMBERLAND COUNTY, PA, do Dauphin County to execute this Writ, this deputation being made at hhe request and risk of the Plaintiff. / Sheriff of Cumberland County, PA Affidavit of Service Now~ within ,20~, at o'clock M. served the upon at by handing to and made known to copy of the ori~nal the contents thereof. So answers, Sheriffof County, PA Sworn and subscribed before me this ~ day of ., 20 COSTS SERVICE MILEAGE~ AFFIDAVIT SHERIFF'S RETURN CASE NO: 2003-01608 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MONROE TOWNSHIP MUNICIPAL VS HINKLE HARRY ADEN REGULAR ROBERT BITNER , 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 HINKLE HARRY ADEN the DEFENDANT , at 0919:00 HOURS, on the 6th day of May at 1330 CHURCH ST CARLISLE, PA 17013 by handing to HARRY HINKLE a true and attested copy of WRIT OF SCIRE FACIAS together with , 2003 and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 12.42 Affidavit .00 Surcharge 10.00 .00 40.42 Sworn and Subscribed to before me this /~ day of A.D. · r~othonot ary So Answers: R. Thomas Kline 05/07/2003 JAMES D BOGAR By:~~~~ )'-DEputY ~hermff MONROE TOWNSHIP MUNICIPAL AUTHORITY, Claimant vs. STEVEN P. DOODia_N 339 and 339B Old Stone House Road Boiling Springs, PA 17007, Owner IN THE COURT OF COM~4ON PLEAS OF CUMBERLAND COUNTY, PENNSYLVia/qIA NO. 03-1605 CIVIL ACTION - LAW MUNICIPAL LIEN PPJ%ECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: The Defendant having failed to file an Affidavit of Defense or otherwise respond to the Writ of Scire Facias served in the within matter, please enter judgement in favor of the Plaintiff and against the Defendant in the amount of $3,000.00, plus interest in the amount of $599.34 plus interest from June 10, 2003 at the rate of $0.90 per day, plus attorney's fees in the amount of $373.67, plus costs. Pursuant to the Municipal Lien Law, 521 P.S. ~ 7106, please assess attorney's fees in the above amount. Notice as required by law has been previously provided to the Defendant. By: Ja~es D. Bo~a~, Esquire Attorney I.~. INo. 19475 One West Maih-~Street Shiremanstown, PA 17011 (717) 737-8761 Jenn-~r B. H~pp, Esquire Attorney I.D. No. 86556 One West Main Street Shiremanstown, PA 17011 (717) 737-8761 June 10, 2003 Solicitors for Monroe Township Municipal Authority CERTIFICATE OF SERVICE We hereby certify that we are this date serving a copy of the Praecipe as filed this date with the P~othonotary of Cumberland County, by sending the same upon the persons and in the manner indicated below: Service by first-class mail addressed as follows: Steven P. Doodan 197 Village Road Harrisburg, PA 17112 Monroe Township Municipal Authority By: )[ ~ Jennl~e~B. }[[pp¥ )Esquire Pa. I.D.~o. 86556 Ja~es D. Bo~, Esquire Pa. I.D. No~.~9475 Solicitors for the Monroe Township Municipal Authority One West Main Street Shiremanstown, PA 17011 (717) 737-8751 June 10, 2003