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Home My WebLink About00-08092 " - WAYNEF. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 . I, -I ."'~, 'f&im~l'(t~t; JOHN W. GLEIM, JR., INC., Claimant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00-8092 MiD TERM DAVID G. BOWERS and DEBORAH J. BOWERS, Owners : MECHANIC'S LIEN NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the pleadings and Notice are served, filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the pleadings or for any other claim of relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 t;t/~ r--~ W ayniF. Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff ^ , WAYNEF.SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 . . . . ""-" "1Ii1JtklJ!-5' JOHN W. GLEIM, JR., INC., Claimant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00-8092 MLD TERM DAVID G. BOWERS and DEBORAH J. BOWERS, Owners : MECHANIC'S LIEN COMPLAINT 1. Plaintiff JOHN W. GLEIM, JR., INC., is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its main office and principal place of business located at 90 Stover Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendants DAVID G. BOWERS and DEBORAH J. BOWERS are adult individuals and husband and wife, who reside at 1541 West Acre Drive, Muscatine, Iowa 52761. 3. On November 15,2000, Plaintiff filed a Mechanic's Lien Claim against Defendants. WAYNEF.SHADE Attorney at Law 53 West Pomftet Street Carlisle, Pennsylvania 17013 ~ ,', ~" ~_ '_C I __ 'ri~_' ,_, '" _'~ _ , _,'_ " - - ,,- ~,,-' i. '_'" '~---w- 4. Said Mechanic's Lien Claim was docketed to No. 00-8092 MLD Term in this Court, and a copy thereof is attached hereto and incorporated by reference as though fully set forth. 5. Plaintiff submitted its invoice to Defendants on September 20, 2000. WHEREFORE, Plaintiff demands judgment against Defendants in the amount of $12,390 plus costs and interest from October 5, 2000. w~~a~ Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff -2- WAYNEF. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 .' " '.~"~'.i I, E. STEVE CLEVER, C.P.A., Controller for Plaintiff JOHN W. GLEIM, JR., INC., make this verification on behalf of Plaintiff, being authorized to do so. The statements made in the foregoing Complaint are based upon information which I have given to my counsel and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. Date: November 16, 2000 ~~ E. Steve Clever ~ WAYNEF. SHADE Attorney at Law 53 West Pomftet Street Carlisle, Pennsylvania 17013 .'- ,~ JOHN W. GLEIM, JR., INC., Claimant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. DO - cf'O?'~ mAJ) ~ v. DAVID G. BOWERS and DEBORAH J. BOWERS, Owners : MECHANIC'S LIEN MECHANIC'S LIEN CLAIM Claimant JOHN W. GLEIM, JR., INC., through its undersigned counsel, files this claim against the improvements and property situate in Dickinson Township, Cumberland County, Pennsylvania, and more particularly bounded and described in Cumberland County Deed Book "M", Volume 36, Page 253, for the payment of a debt due to Claimant as a contractor for labor, equipment and materials furnished by Claimant toward the erection and construction of improvements to the subject premises. In support of the claim, Claimant makes the following statement: 1. The owners of the property are David G. Bowers and Deborah 1. Bowers, husband and wife, who reside at 1541 West Acre Drive, Muscatine, Iowa 52761. 2. The improvements to the above-described property were effected at the request of . . . . \fINWilf..SNN3d. the SaId DaVId G. Bowers, as agent for both owners, to facIhtaJ.~~MO!!RY~.i.~l'!I'l1Ul usage ofthe subject premises as a residential dwelling. OZ :[ \,!d c,! llUN 00 '. :i =() WAYNEF. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 -" ",- 1'.'__"1 .1' ',5' ~ - ~ ^ So,.,:;;" '-'0 3. The labor, equipment and materials for which the debt is due were furnished for the agreed sum of$12,516 in accordance with the accepted proposal therefor, a copy of whiCh is attached hereto and incorporated herein by reference as though fully set forth. 4. Claimant completed its work at the property on August 10, 2000. 5. Owners have paid $126 toward the debt due Claimant for the stated labor, equipment and materials. An attempt by Owners to pay an additional $300 has been refused because it is conditional upon acceptance oftermswhich are at variance from the terms of the agreement among the parties. Therefore, the amount of this claim is $12,390. ~L f.LZLt Wayn . Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Claimant - II ,,-- " -=,,~', :L IT/~7~v~J"~~-V'":i..;~Ui~U_ _';:'~~!-I_ !,,____\::Ile,m, ...Jr.., ~nc.. 717 243 3617 P..03 q~.~"'-~O 1:S:~ .John w. c:1e1.... .J.,.... ~ I~c;. 717 243 3617. ~ P.02 dOlIN W. CUlM. dB.. INC. ~{~s ~ excAVA'RNG CCNTllAatlR ~ PROPOSAL 30 STOVCI OllI\IE CNWSlL'~ llQ13 at)) ~471iO 766-44lQ Jack 03ughell Dale: May 23.. 2000 Site: 34a West 014 Y otlc Road We pro~ to ,upply materia!, equiplllCftt alld lahor ~ to CUIIIICl1Ict the CoIlowiDg: 'Price Iacl1ldcs: t. LasuJling Eco ~o ,ews. system. 2. 1- SOO pi Jeptill tlJIk witb Z2bel filler. 3. 1,-500 pi plIlIl\l tlUIk pa~ 4. BeddiDg aad fabric tor EcJI Flo laDle. ~. 1B 5III1le for c1raiDae= he.lud EClI Flo tal1L 6. W-'riq of pump aak. 7. Condllu fo.,lIndergrouad wire. 8. 1Il1lM.~!e:s for "'I1IIPIlleJrt. Price does lIot Inclllde: 1. Pel'1l1iCS de or permit fee. %. lmpor1i1l; of toploiL 3. Rode RemovaL 4. Seeding ~nd OJr Iantis~!lin1:. -Note to~$).40.1JO a ni-I%le.load if Deeded. . ( ..... We =' c:O 1Umisl1 m~;ri~~abor cOIJI!)l'::e in aceordanc=: with the ~bOYe =ificalions for:he of (.srZ..516.00) ~ thousaDd five hlllldred sixteen dollars and no cem. Payment tcm:s are. . <, 1 l'.:% 'e:'VICC after 1$ days. . -----------~ Si~ly, JOHN W. (;1 "::lM. JR.., lNC. )!;z:P 'ng belew, I !lCc:pt the above coninl;t. iGm p. I.e:llo:r ~csOivisi01'l.~ !-( WAYNEF. SHADE Attorney at Law 53 WestPomfretStreet Carlisle, Pennsylvania 17013 . J.,.;_'.." '~~,","." ~;, ~ . JOHN W. GLEIM, JR., INC., Claimant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. mi}J ~.- : NO. Co - R09~ '~ DAVID G. BOWERS and DEBORAH J. BOWERS, Owners : MECHANIC'S LIEN MECHANIC'S LIEN CLAIM Claimant JOHN W. GLEIM, JR., INC., through its undersigned counsel, files this claim against the improvements and property situate in Dickinson Township, Cumberland County, Pennsylvania, and more particularly bounded and described in Cumberland County Deed Book "M", Volume 36, Page 253, for the payment of a debt due to Claimant as a contractor for labor, equipment and materials furnished by Claimant toward the erection and construction of improvements to the subject premises. In support of the claim, Claimant makes the following statement: 1. The owners of the property are David G. Bowers and Deborah J. Bowers, husband and wife, who reside at 1541 West Acre Drive, Muscatine, Iowa 52761. 2. The improvements to the above-described property were effected at the request of the said David G. Bowers, as agent for both owners, to facilitate the continued lawful usage of the subject premises as a residential dwelling. ;,~ ""'-," *- WAYNEF.SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 . . -, ~ "~'il~::';'r- '~_ol I - ,,,.., 3. The labor, equipment and materials for which the debt is due were furnished for the agreed sum of$12,516 in accordance with the accepted proposal therefor, a copy of which is attached hereto and incorporated herein by reference as though fully set forth. 4. Claimant completed its work at the property on August 10,2000. 5. Owners have paid $126 toward the debt due Claimant for the stated labor, equipment and materials. An attempt by Owners to pay an additional $300 has been refused because it is conditional upon acceptance of terms which are at variance from the terms of the agreement among the parties. Therefore, the amount of this claim is $12,390. ~~*~ Wayn . Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Claimant ---~. ~ " ,",,' -. ,"> ~--, -'" ~~ "~" j7/U7u;\J.I.~~-..":;,,.~u;.~- ...~~r..!!l_ !W_.~_l::Ilelm~ ..Jr." .lnc.. 71.7 243 3617 P.03 q~'~'r-oo u:~ .John W. c:1e1.... .;J...... Inc:. 7J.7 2~; 'ir~ "P.C2 JOHN W. GLEIM. dR.. INC. . rr' 3~. S ~ excAV"llI'lG C;CNlllAC70R ~ PROPOSAL 90 STCMll QAI\IE CMUSIL '''17<113 l7t1l 2*71&0 76&i'7<1 Jack 0augI1ell Da1e: May 23, 2000 Sire: 843 West Old. Y orlc Road We prGflGSe to sop,l)' materia!, ettuilllllCftt and I. bor nqain:1i tll anIItr1Ict the l'olIowiag: Price Iodudcs: 1. IaW~ Eas Flo sews,e ~tem. 2. 1- SOO pi septic: WIg with Z2bel filter. J. 1:-500 pl palll\l tuk paclcace- 4. BeddiDg aad fabric for Eca Flo !aDIe. S. 1B 50lIle for draill. bed aad Eco Flo !aak. 6. Wiriq of PUlII' bDk. i. Concluet for Und~"DQ wire. i. 11l1ovi.~ 1'ee fDr equ1\1l1lexi. Price does not llIdude: 1. Permits Jc or perlllit fee. %. lmpor1i1lg of ropaoiL 3. Rock ~emovaL 4. Seedillg 2nd ;)1' Iandso!lin~. "Note tO~-be.$!_40.00 a tri-.:de.load if Deeded. . , , We ~' e ~ turnish m~~ and labor eomllle:c in a=rclano: widt 1hc: iCove soecifi.:atiQl1S for:he 01'($12,.516.00) ~~ thol.lSand five l1Ul1dred si:a:=, dcllsrs and no cems.. P1yment = are . <, I 'f.:o/. ~ervia: c:h~ after 15 days. ----~--_____.J Sinc:::ely, !OHN W, Gl "'llvt.JR., CNC. )!:/L i iug below, 1 !Il:C:pt th= above eonir3ct. Kim P. t.cllI= S\ll:Cishics Division Manager /~I WAYNEF.SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 ~ I JOHN W. GLEIM, JR., INC., Claimant v. DAVID G. BOWERS and DEBORAH J. BOWERS, Owners TO: Curtis R. Long, Prothonotary 'J L r -,_.-,"" ~- "'" ~~: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 00-8092 MLD TERM : MECHANIC'S LIEN PRAECIPE Please mark the Mechanic's Lien in the above matter satisfied including Court costs. Date: February 14,2001 ~~C~e Attorney for Claimant ~~~~~j;!,lkM~~_~"'laloJtili1l!';!Ilfu~~iilll" ~~*' ~ --..,J ~ ~ ~ >.."!_m_,, ","',__ .~,~-"-=~ Ci) ~ ~~ 9't ~ j (J:, I- ~~ ~- ~ . " ~~~., . - ~ '.1 f: 0 ~< ., rn \[1 r'1 Z S~J co 2'r-' .f? i~~' { r' .- =.'...J ..o---"c.... -_ 5:g J~_,? ""- -., -< <::> L~_ . , o ~Tl ;d! '.m ~ -~~ C~l ~(~) ,-- ""I i_~f-3 ;.~-:;: fT] ,~ :;~ ::0 -< m