HomeMy WebLinkAbout01-05411THE BOROUGH OF SHIREMANSTOWN,
Plaintiff
v.
JOHN G. BROADS, MAY D. BROADS,
FRANK E. PUTT, GILBERT W. BROADS,
CRYSTAL D. BROADS AND TRUDY A.
DEIMI,ER,
Owners or reputed
Owners
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, ENNSYLVANIA
NO: ~ ~ _ may/ 1 ~Ic-~
M.L.D.
The Borough of Shiremanstown, Plaintiff hereby files this claim against John G. Rhoads, Gilbert W.
Rhoads (collectively "Record Owners"), and May D. Rhoads and Crystal D. Rhoads to the extent of any interest
they may have by virtue of their marriages to John G. Rhoads and Gilbert W. Rhoads respectively and Frank E.
Putt and Trudy A. Deimler, equitable owners under the Sales Agreement recorded in the Cumberland County
Recorder of Deeds office at Book 546 Page 375 (all of the foregoing are collectively referred to herein as
"Owners") and all that certain lot or piece of ground and improvements erected thereon known and numbered as
3 South Locust Street, Shiremanstown, Pennsylvania 17011 for work and labor done and materials furnished in
removing and relaying concrete footway paving and removing and rebuilding concrete curbing in front of said
lot of ground; said work having been done under the authority of an Ordinance passed by Council of the
Borough of Shiremanstown being Part Twelve, Chapter 2, Article A, Section 12-2009 and in pursuance of
which Ordinance, and in accordance with the Acts of Assembly, a contract dated May 20, 1998 was duly made
and executed between the Borough of Shiremanstown and the Pennsylvania Department of Transportation for
doing said work, which improvement was completed on December 7, 1999 and a certificate thereof duly filed
by the surveyor supervising said improvement in the Pennsylvania Department of Transportation, that being the
proper office in which to file the same and the Borough of Shiremanstown having been provided with the actual
cost of said improvement under the above-referenced Contract by the Pennsylvania Department of
Transportation for the first time on or about Apri124, 2001. The following is a statement of the kind and
character of the work so done and the price charged for the same namely:
Deed Property Frontage: 91.70 L.F.
Installed Curbing Length: 91_70 L.F.
F
Curbing cost (14.35/L.F.): $1,315.90
Installed Sidewalk Width: 4.00 L.F.
Installed Sidewallc Area: 40.76 S.Y.
Sidewalk cost ($40.50x50%=$20.25/S.Y.): 852.39
Total Cost $2,141.29
Which said sum of Two Thousand One Hundred Forty One and 29/100 Dollars ($2,141.29) was duly assessed
against said above described premises on the 25th day of Apri12001 and for which sum together with interest at
a rate of 10% per annum, penalties, reasonable legal fees and costs, a lien is claimed against the above described
premises agreeably to the provisions of the Acts of Assembly in such case made and provided.
The said Record Owners were notified by the Council for the Borough of Shiremanstown to construct
the work in front of said property on February 10, 1997 by written notice to that effect served on John G. and
Gilbert W. Rhoads, and said Record Owners neglected to do for more than thirty (30) days after the service of
said notice.
The Borough of Shiremanstown caused written notice to be served on the said Record Owners of the
intention to file this claim unless the amount due the claimant for said work was paid within one month from
said notice by mailing via certified Unites States Mail, postage prepaid, return receipt requested addressed to
John G. Rhoads at 3 South Locust Street, Shiremanstown, Pennsylvania 17011 on June 20, 2001 prior to the
filing of this claim.
Respectfully submitted,
THE BOROUGH OF SHIREMANSTOWN
By:
~'upreme Court ID # 59012
2109 Market Street
Camp Hill, PA 17011
(717)737-3405
Attorney for Plaintiff
Borough Solicitor
COMMONWEALTH OF PENNSYLVANIA
CITY OF SHIREMANSTOWN : SS:
Karl M. Ledebobm solicitor for The Borough of Shiremanstown, Plaintiff being duly sworn, deposes
and says that he is the Solicitor of the Borough of Shiremanstown, the above-named Claimant, and that the facts
set forth in the foregoing claim aze true to the best of his knowledge, information and belief.
Sworn to and described before me this day oi~~j 2001.
?k~-
Notarial Seel
Stacy L. Frick, Notary public
East Pennsboro Twp. Cumberland County
My Commisalon Expires Jan. 12, 2004
C.P. No.
Term, 2001
M.L.D
The City of Shiremanstown
to the use of
vs
John G. Rhoads, May D. Rhoads, Frank E. Putt, Gilbert W. Rhoads,
Crystal D. Rhoads and Trudy A. Daimler,
Owners
Premises:
3 South Locust Street, Shiremanstown, Pennsylvania 17055
Claim for $2,141.29 together with interest at the rate of 10% per annum, penalties, reasonable
legal fees and costs.
Karl M. Ledebohm, Esquire, Borough Solicitor
Saidis, Shuff, Flower & Lindsay
2109 Mazket Street
Camp Hill, PA 17011
Attorney for Claimant
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THE BOROUGH OF SHIREMANSTOWN,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO: 01-5411 MLD
JOHN G. BROADS, MAY D. BROADS,
FRANK E. PUTT, GILBERT W. BROADS,
CRYSTAL D. BROADS AND TRUDY A.
DEIMLER,
Owners or reputed
Owners
M.L.D.
PRAECIPE
TO THE PROTHONOTARY:
Please mark satisfied the lien filed in the above-captioned matter on September 17, 2001.
Respectfully submitted
Date: [ ['2`~ ~ 1
SAIDIS, SHUFF, FLOWER & LINDSAY
T{arl M. Ledebohm, Esquire,
Borough Solicitor for the Borough of
Shiremanstown
Supreme Court ID #59012
2109 Market Street
Camp Hill, PA 17011
(717) 737-3405
Attorney for Plaintiff
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