HomeMy WebLinkAbout01-05804
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COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001- 51JCKf /11 t.--()
MECHANIC'S LIEN
WIRL BUILDERS
Claimant
DIMITRIOS T. TSITSIRIS,
Owner
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NICHOLAS GIAMBILlS,
PETER TSIRIGOTIS
GENNY BELIZE, INC., A1KJA
BELIZE GENNY CORPORATION AND
ST. JOSEPH'S & MARY INC.,
EQUITABLE OWNERS
MECHANIC'S LIEN CLAIM
Claimant, Wirl Builders, through the undersigned counsel, files this claim
against the improvements and property at 3449 Simpson Ferry Road, Camp Hill,
Pennsylvania, known as the CamP Hill Diner and also known as that certain lot with
any improvements erected thereon situate in Hampden Township, Cumberland
County, Pennsylvania, being Lot NO.1 of a Subdivision Plan of Sanndrel of
Pennsylvania, Inc. recorded in Cumberland County Plan Book 34, Page 98, for the
payment of a debt due to Claimant as contractor for labor furnished by Claimant under
a contract for the erection and construction of new improvements at the property, but
for which only the demolition of prior improvements and some site preparation was
completed before Claimant ceased work on property for non-payment of bills. In
support of the claim, the Claimant makes the following statement:
1. (a) The owner of the property is Dimitrios T. Tsitsiris, an adult individual,
whose address according to Cumberland County assessment records is 3449
Simpson Ferry Road, Camp Hill, Pennsylvania 17011 and whose address on the
deed by which he took title was RD #2, Box 2414, Reading, Pennsylvania 17070.
(b) By Memorandum of Installment Sales Agreement, recorded June 18,
1997 in Cumberland County Miscellaneous Record Book 550, Page 299, Nicholas J.
Giambilis and Dimitrios T. Tsitsiris, purported owners of the property which is the
subject of this Claim, sold such property to Peter Tsirigotis. The said Memorandum of
Installment Sales Agreement does not provide any addresses for any parties thereto
but Claimant believes that Nicholas J. Giambilis resides at 7 Graham Road, Newville,
PA 17241 and Claimant believes that Peter Tsirigotis has a place of business at New
City View Diner, Allentown, PA 18105. The said Memorandum of Installment Sales
Agreement also recites that Peter Tsirigotis had assigned his interest in the
Installment Sales Agreement to a Pennsylvania Corporation known as Genny Belize,
Inc.
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(c) A certain Memorandum of Lease with Option to Purchase was
recorded on June 18, 1997 in Cumberland County Miscellaneous record Book 550,
Page 304 whereby the parties intended to memorialize a Lease with Option to
purchase granted by Genny Belize, Inc. to St. Joseph's & Mary, Inc. Neither
Corporation was identified as to address or state of incorporation in said instrument.
Since Genny Belize, Inc. is identified as a Pennsylvania Corporation in the
aforementioned Memorandum of Installment Sales Agreement, a search of the
Pennsylvania Department of State Corporation Bureau records was made for that
corporation and none was found, however, a corporation identified as Belize Genny
Corporation of 1831 Macarthur Road, Whitehall, Pa. 18052 was found and Claimant
believes it may be one and the same entity as that identified as Genny Belize, Inc. A
further search of the Pennsylvania records for St. Joseph's & Mary, Inc. found no
record.
2. The improvement and the property which are the sUbject of this claim is all
that certain tract or parcel of land situate in the Township of Hampden, County of
Cumberland, Commonwealth of Pennsylvania, known as Lot No.1 of a Subdivision
Plan of Sanndrel of Pennsylvania, Inc. recorded in Cumberland County Plan Book 34,
Page 98, and which property is further described by copy of the deed from James P.
Ross et al. to Dimitrios T. Tsitsiris, dated June 20, 1995 and recorded June 21, 1995,
in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle,
Pennsylvania, in Deed Book 123, Page 993, a copy of which deed is marked Exhibit
"A," is attached hereto, and is incorporated herein by reference thereto. This property
was occupied by a restaurant known as The Camp Hill Diner having an address of
3449 Simpson Ferry Road, Camp Hill, Pennsylvania 17011, which Diner burned.
3. Claimant was hired on a time and materials basis to construct a new
restaurant on the property, including the demolition of the remains of the prior
structure.
4. The labor for which the debt is due consisted of labor and equipment
supplied for the demolition of the prior structure and the beginning of site preparation
and work on the replacement restaurant as described in the statement dated June 7,
2001, a copy of which is marked Exhibit "B" is attached hereto and is incorporated
herein by reference thereto.
5. The Claimant began work on May 23, 2001 and ceased work for non-
payment of bills on June 7, 2001 which is less than four months before the filing of
this claim.
6. Claimant has been paid nothing on the total amount billed of $14,365.00
as shown on the attached Exhibit "B" and that is the amount which remains due and
owing and for which the claim is made in the amount of $14,365.00.
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Respectfully Submitted,
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S eph n D. Tiley, Esquire
Attorney for Claimant, Wirl Builders
5 South Hanover Street
Carlisle, PA 17013
Tel: (717) 243-5838
VERIFICATION
I verify that the statements made in the foregoing Mechanic's Lien Claim
are true and correct, partially upon personal knowledge and partially upon my belief;
to the extent language in the Mechanic's Lien Claim is that of my attorneys, I have
relied upon my attorneys in making this Verification. I understand that false
statements herein are made and subject to the penalties of 18 Pa. C.S. 94904
relating to unsworn falsification to authorities.
Dated: !2f~ S, 2COJ
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RDOERr ~. ZlE~lEH
nECORDEn OF DEEDS
r;UMBERLAlID COUNTY - p~
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',95 JUIJ 21 nl'l10 3~ THIS DEED
Made the .;;tJ~I.' day of ~p."v.- in the year of our Lord one
thousand. nine hundred and m.nety-five (1995) Between JAMES P.
ROSS, STEPHEN E. BENSON, DAVID G. BENSON and WILLIAM P. KINSEY,
trading and doing business as RBK PROPERTIES, a general
partnership with its principal office at 6-D Springridge_ Court.
Baltimore, MD 2l~44, lIGRANTOR", and party of the first part
AND
DIMITRIOS T. TSITSIRIS, an adult individual, of Reading, Berks
County, fennsylvania. "GRANTEE", and party of the second part
WITNESSETH, that the said Granto~, party of the first part,
for and in consideration of the sum of Three Hundred Thirty-Three
Thousand Five Hundred Dollars ($333.500.), lawful money of the
United Scates of America, unto it well and truly paid by the said
party of the second part, at or before the sealing and delivery
of these presents, the receipt whereof is hereby acknowledged,
and by these Presents does hereby grant, bargain, sell, alien,
enfeoff, release, convey and confirm unto the said party of the
second part, its successors and assigns
ALL THAT CERTAIN tract or larcel of land situate in
Township of Hampden, County o' Cumberland, Commonwealth
Pennsylvania, bounded and described as follows: .
COMMENCING at the Intersection of the Centerline of
Zimmerman Drive, and the Centerline of Simpson Ferry
Road (t. R. 570), thence westerly along the Centerline
of Simpson Ferry Road a distance of 746.79 feet, to a
point in the Centerline of Simpson Ferry Road, said
point being the Southwest corner of property of
Sanndrel af rennsylvania, Inc. of which this Tract was
formerly a part; thence along land now or formerly of
Annplyco Properties, Inc. North 130 53' west a distance
of 72.37 feet to a point on the ultimate right-at-way
line of Simpson Ferry Road; thence along said ultimate
right-of~way line of Simpson Ferry Road north 760 33'
east a distance of 47.74 feet to a paint, the PLACE OF
BEGINNING of the tract herein described; thence alonl?
land of Sanndrel of Pennsylvania, Inc. north 130 27
west a distance of 175 feet to a point; thence
continuing along the same north 760 33' east a distance
of 160 feet to a point; thence continuing along the
same south 130 27' east a distance of 175 feet to a
point on the ultimate right-of-way line of Simpson
Ferry Road; thence along the ultimate right-at-way line
the
of
~Qtii 123 PACf 993
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of Simpson Ferry Road south 76G 33' west a distance of
160 feet to the place of beginning, CONTAINING 28,000
square feet of land.
BEING lot n of a subdivision plan of Sanndrel of
Pennsylvania, Inc. I ~re~ared by John C. Brillhart
Surveying and Mapping Services of Mechanicsburg,
Pennsylvania, as recorded in Plan Book 34, Page 98, of
the Cumberland County Records and being the same
property conveyed by Hampden Industrial .Development
Authority to RBK Properties by deed dated )I..d.tJ ,r ,
1995 and recorded in the Recorder of Deeds plttl.ce of
Cumberland Cnunty, in Bookl::>,3 PageqR1'
Containing .64 acres mare or less.
UNDER AND SUBJECT nevertheless to those restrictions
as appear of record in Deed Book G 28. Pages 414
through 417.
ALSO UNDER AND SUBJECT to that agreement not to erect
a barrier as set forth in Deed Book G 28, Page 417
recorded in the Office of the Recorder of Deeds.
Cumbe~land County, Pennsylvania.
TOGETHER with the easement of ingress and egress
granted by a predecessor in title, SANNDREL OF
PENNSYLVANIA, INC. and set forth in Deed Book G28, Page
417 rec'orded in the Office of the Recorder of Deeds,
Cumberland County, Pennsylvania.
AND TOGETHER with all interests of RBK Properties,
Grantor. and subject to the duties, terms and
conditions as set forth in that certain lease dated
August 20, 1979 between SANNDREL OF PENNSYLVANIA, INC.
and Grantor relating to property as therein described
for an underground water line, natural gas line and
electLic and telephone service which lease is subject
of a Memorandum of Lease, recorded on September 28,
1979 in the Office of Recorder of Deeds. Cumberland
County at Book 247, Page 131.
AND TOGETHER with all and singular the improvements,
ways. waters, watercourses, rights, liberties,
privileges, hereditaments and appurtenances to the same
be longing, or in anywise appertaining, and the
reversion and ~eversians. remainder and remainders,
rents, issues and profits thereof; AND ALSO all the
estate, right, title, interest, property, claim and
demand whatsoever, both in law and equity, of the said
aooK 123 llIee 994
exHIBIT "At
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Grantor, of, in, to or out of the said tract of land,
and every part and parcel thereof.
TO HAVE AND TO HOLD the said tract of land. with all and
singular the hereditaments and premises hereby granted or
mentioned, and intended so to be, with the appurtenances, unto
the said Grantee, its successors and assigns, to and for the only
proper use and behoof of said Grantee. its successors and assigns
forever~ SUBJECT to the restrictions as appear of record in Deed
Book G 2B. Pages 414 through 417 in the Office of Recorder of
Deeds for Cumberland County.
AND the said Grantor, for itself and its successors does by
these presents, covenant, grant and agree to and with the said
Grantee) his heirs, successors and assigns, that the said
Grantor, its successors and assigns, all and singular the
hereditaments and premises herein above-described and granted, or
mentioned and intended so to be, with the appurtenances unto the
said Grantee, his successors and assigns, against the Grantor,
its successors and assigns, and against all and every other
person or persons, whomsoever, lawfully claiming or to claim the
same or any part thereof, by, from or under it, him, her, them or
any of them, Shall and Will SPECIALLY WARRANT AND FOREVER DEFEND.
IN WITNESS WHEREOF, the said Grantor, has caused this Deed
to be executed by its proper rep14esentat!ve the day and year
first above written. .
;lITNESS,
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GRANTOR:
RDK PROPERTIES
JAMES P. ROSS, STEPHEN E.
DENSON, DAVID G. DENSON &
WILLIAM P. KINSEY
Dy, R~Qog[Ci2Q
Attorney-in-fact
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF P+.J
On this d,t1 t.vday Of~, 1995, before me, a NotLlry Public,
t ~ undersigned officer. personally appeared '"t;',rf{ 11_/1 E.
, who acknowledged hl e to be the
attorneY-ln- act or JAMES P. ROSS, STEPHEN E. BENSON, DAVID G.
BENSON and WILLIAM P. KINSEY, individually and for RBI<
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BuoR 123 fACE 995
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Properties. a general, partnership, as appointed by its partners,
and that, being authorized to do 50, executed the foregoing
instrument for the purposes therein contained by signing the
names of the said Partnership, and its individual partners by him
as attorney-in-fact.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial
seal.
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otary Public .1
My Commission Expires: ~ -/<j'.lY
(SEAL)
I. hereby certify
herein is as follo~s:
NolarialSeal
Gloria A. Cuddington, Notary Public
Harrlsburg, Dauphin County, PA
My Commission Expires Feb. 14, 1998
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that the precise residence of the Grantee
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CERTIFICATE OF RESIDENCE
,
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Attorney for Grantee
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SS
Recorded on this day 1995 A.D. in the
Recorder's office of the said B~ok Volume
Page
Given under my hand and seal of the the day and
year aforesaid.
Recorder
BPOK 123 "ICE 996
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TO: Camphill Diner
3449 Simpson Ferry Road
Camphill, PA.
June 7, 2001
FROM:
Wirl Builders
855 York Road
Carlisle, P A. 17013
258-3435
PROJECT: Demolition of existing building.
tvlay 23'" - LABOR 850.00
May 24'h - Labor 1100.00 ,backhoe/delivery 570.00
May 25'h - Labor 700.00, backhoe 240.00, dump truck 340.00
May 28'h no dumpsters
May 29'h - Labor 1100.00, backhoe 480.00, dump truck 405.00
May 30th - Labor 820.00, backhoe 480.00
June 151 - Labor 1100.00, backhoe 480.00, dump truck 210.00
June 4'h - Labor 900.00, backhoe 440.00, truck 360.00,jackhammer 200.00
June 5'h - Labor 950.00, backhoe 440.00, truck 380.00, ram/hoe 360.00
June 6'h - Labor 32000, backhoe 440.00, truck 135.00
June 7'11 - Labor 240.00, backhoe 190.00, truck 135.00
TOTAL COST OF DEMOLITION $14,365.00
Note: Much of the work done on June 5, and all work on June 6 and 7 should be
considered as part of the re-construction. Slabs areas were removed for leveling
purposes, parts of the concrete slab were demolished for plumbing, and masonary
Ivai Is were begun to be reconfigured for the new roof line and perimeter changes.
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SHg~IFF'S RETURN -OUT OF COUNTY
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CASE NO: 2001-05804 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WIRL BUILDERS
VS
TSITSIRIS DIMITRIOS T ET AL
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 OWNER
, to wit:
TSITSIRIS DIMITRIOS T
but was unable to locate Him
in his bailiwick. He therefore
deputized the sheriff of BERKS
County, Pennsylvania, to
serve the within MECHANICS LIEN CLAIM
On February 25th, 2002 , this office was in receipt of the
attached return from BERKS
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep Berks County
18.00
9.00
10.00
21.14
.00
58.14
02/25/2002
FREY & TILEY
s~,swe. ~'~~'
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R. Thomas Kline
Sheriff of Cumberland County
Sworn and subscribed to before me
this Olf"!!" day of 5~
.]c-tJ."l. A.D.
( )1''- 0. )w"C".-' ~.
Prothonotary
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SHERIFF'S RETURN - OUT OF COUNTY
,
.
CASE NO: 2001-05804 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WIRL BUILDERS
VS
TSITSIRIS DIMITRIOS T ET AL
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 OWNER
, to wit:
TSIRIGOTIS PETER
but was unable to locate Him
in his bailiwick. He therefore
deputized the sheriff of LEHIGH
County, Pennsylvania, to
serve the within MECHANICS LIEN CLAIM
On February 25th, 2002 , this office was in receipt of the
attached return from LEHIGH
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep Lehigh County
6.00
9.00
10.00
30.00
.00
55.00
02/25/2002
FREY & TILEY
So answe~. /~~., ././' ./-~.,
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R. Thomas Kline
Sheriff of Cumberland County
Sworn and subscribed to before me
this ;(g'::; day of j~,. A")
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SHERIFF'S RETURN - OUT OF COUNTY
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CASE NO: 2001-05804 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WIRL BUILDERS
VS
TSITSIRIS DIMITRIOS T ET AL
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 OWNER
, to wit:
BELIZE GENNY INC A/K/A BELIZE GENNY CORPORATION
but was unable to locate Them
in his bailiwick. He therefore
deputized the sheriff of LEHIGH
County, Pennsylvania, to
serve the within MECHANICS LIEN CLAIM
On February 25th, 2002 , this office was in receipt of the
attached return from LEHIGH
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep Lehigh County
6.00
9.00
10.00
30.00
.00
55.00
02/25/2002
FREY & TILEY
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R. Thomas Kli
Sheriff of Cumberland County
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Sworn and subscribed to before me
this J?~ day of J~
JvI.JV2.., A.D.
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I Prothonotary
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-05804 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WIRL BUILDERS
VS
TSITSIRIS DIMITRIOS T ET AL
DAVID MCKINNEY
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within MECHANICS LIEN CLAIM
was served upon
ST JOSEPH'S & MARY INC
the
OWNER
, at 1537:00 HOURS, on the 11th day of October ,2001
at 3449 SIMPSON FERRY RD
CAMP HILL, PA 17011
by handing to
POSTED PROPERTY AT 3449
SIMPSON FERRY RD CAMP HILL
a true and attested copy of MECHANICS LIEN CLAIM
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Posting
Affidavit
Surcharge
So Answers:
6.00
6.00
.00
10.00
.00
22.00
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R. Thomas Kline
02/25/2002
FREY & TILEY
Sworn and Subscribed to before
By: P} rJ /mL"
.JV' ~ 11 ,
- Deputy Sheri f~
-10
me this ;) f~ day of
J~ _~~ A.D.
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rothonotary .
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-05804 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WIRL BUILDERS
VS
TSITSIRIS DIMITRIOS T ET AL
DAVID MCKINNEY
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within MECHANICS LIEN CLAIM
was served upon
TSITSIRIS DIMITRIOS T
the
OWNER
, at 1537:00 HOURS, on the 11th day of October
2001
at 3449 SIMPSON FERRY RD
I
,
i
CAMP HILL, PA 17011
by handing to
POSTED PROPERTY AT 3449
SIMPSON FERRY RD CAMP HILL
a true and attested copy of MECHANICS LIEN CLAIM
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Posting
Surcharge
So Answers:
6.00
8.95
6.00
10.00
.00
30.95
i~~~
R. Thomas Kline
Sworn and Subscribed to before
me this PI f"!f: day of
J~'<~'J ,2f>o.:L- A.D.
0'i'L- () '/n1/#,A/ 1~/f'
Prothonotary
02/25/2002
FREY & TI LEY
t)N~~L~:i,~
By:
'~,:,i.rr'.r-"1'-"='~_""""~",,,, _, ~~-.l ,,_, ^ ._,_
, ',-
- "~,-
~~-
n~_
1 _ ....
"1 'iT ..,~~'~, ,. . ill) !II
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-05804 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WIRL BUILDERS
VS
TSITSIRIS DIMITRIOS T ET AL
DAVID MCKINNEY
,,'
:'1
;'.1
,
"i
~-I
Cumberland County, Pennsylvania, who being duly sworn according to law,
,'I
"I
, Sheriff or Deputy Sheriff of
was served upon
says, the within MECHANICS LIEN CLAIM
the
:.!
GIAMBILIS NICHOLAS
OWNER , at 1704:00 HOURS, on the 12th day of October ,2001
,OJ
'!
at 7 GRAHAM RD
':,1
NEWVILLE, PA 17241
JAMES GIAMBILIS, SON
by handing to
a true and attested copy of MECHANICS LIEN CLAIM
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
5.85
.00
10.00
.00
21.85
Sworn and Subscribed to before
me this .22~ day of
.1..J.... h "1 d/X).:l., A.D.
Q'I/' ,D n"Ct-<---" ~.
rothonotary
J!~,;j'~~rr'''''-''''''\--" _'" .",,,,,,,,"~ ",,"_"oj
I
So Answers:
r~~'~~
R. Thomas Kline
02/25/2002
FREY & TILEY
By: ~~ ~lJ!~~"A
Deputy Sheriff 2'
.
~""""'n"-~
1"."'!~~
~ .,"__Z~_ C---~n' - "_ Li"]
SHERIFF OF BERKS COUNTY
633 Court Street, Reading, PA 19601
Phone: 610-478-6240 Main Fax: 610-478-6222
Sheriff Fax: 610-478-6072
Barry Jozwiak, Sheriff
Eric J. Weaknecht, Chief Deputy
AFFIDAVIT OF SERVlCE
DOCKET NO. 01-5804
COMMONWEALTH OF
PENNSYLVANIA:
COUNTY OF BERKS
Personally appeared before me, STEPHEN DEVORE, Deputy for Barry J. Jozwiak, Sheriff of Berks
County, Pennsylvania, who being duly sworn according to law, deposes and says that after diligent search
having been made by him, he was unable to fmd DIMTRIOS T. TSITSIRIS, within named defendant,
within this bailiwick.
. ~.Lr--
DEPUTY SHERIFF OF BERKS CO., PA
NOTE: THE WITHIN NAMED DEFENDANT IS NOT KNOWN AT THE GIVEN ADDRESS.
Sworn and subscribed before me
this 15 day of NOVEMB R, 2001
.,PA
NOTARIAL SEAL
TAMMY IiODRIGUEZ, Notary Public
RrlOllln~j, Borks County, PA
My CCI''flO1IS>lOII Expires 10-06.2003, I
.-,...,..,-,,-
"NOT FOUND" as to the above
named defendant.
~Answe(j
, (J,.J
SHERIFF OF BERKS COUNTY, PA
Sheriff's Costs in Above Proceedings
$ 75.00 DEPOSIT
$ 21.14 ACTUAL COST OF CASE
$ 53.86 AMOUNT OF REFUND
All Sheriff's Costs shall be due and payable when services are performed, and it shall be lawful for him to
demand and receive from the party instituting the proceedings, or any part liable for the costs thereof, all
unpaid sheriff's fees and the same before he shall be obligated by law to make return thereof.
_Sec. 2, Act ofJune 20,1911, P.L. 1072
"",'j....""~"""'''''''_r.;,~ 'r~ ~
-
,~
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"'
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In The Court of Common Pleas of Cumberland County, Pennsylvania
wirl Builders
VS.
Dimitrios T. Tsitsiris et a1
Dimitrios T. Tsitsiris
No.
01
5804 civil
SERVE:
Now,
October 9. 2001
, I, SHERIFF OF CUMBERLAND COUNTY, P A, do
hereby deputize the Sheriff of
Berks
County to execute this Writ, this
:'-;
,
deputation being made at the request and risk of the Plaintiff.
r~d<~
Sheriff of Cum berland County, P A
"
,
Affidavit of Service
i:-,
F',
Now,
,2D_,at
o'clock
M. served the
within
upon
at
, I
,
by handing to
a
copy of the original
and made known to
the contents thereof.
So answers,
Sheriff of
County, PA
Sworn and subscribed before
methis_dayof ,20_
COSTS
SERVICE
MILEAGE
AFFIDAVIT
$
$
_ :{Y'-"'-'!>~'T,,"'~~
~
,~~ -
'''1-
-, 1,' l'
-~~""I5'-<t(,;.(('i),V1 ^"',, r ^ , - ':' :--1-_-"_ "'"' ,
In The Court of Common Pleas. of Cumberland County, Pemnsylvan:ia
- < .'.)
Wirl Builders
VS.
Dimitrios ,T. Tsitsiris et a1
Peter Tsirigotis
No.
01
5804 civil
SERVE:
Now,
Octo'Der9,2001
, I, SI-IERIFF OF CUMBERLAND COUNTY, P A, do
hereby deputize the Sheriff of
Lehigh
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
F'/"') / L~
~~~'1~~-F'
Sheriff of Cumberland County, PA
Affidavit of Service
Now,
, 20_, at
o'clock
M. served the
within
upon
at
by handing to
a
copy of the original
and made known to
the contents thereof
So answers,
SjJeriff of
County, PA
Sworn and subscribed before
me this _ day of ,20_
COSTS
SERVICE
MILEAGE
AFFIDA VIT
$
$
-"'''l'<''",}Wj'''''~~
,
, ,
, ,
~, 11 ~-~~~'1
i:;:,j!!it~~R~oo:l;jj-f~!j<tlo~Eh~N;;Ni-a~'~.;)';;;j,;-"<,><":(.,,,, ""j"
,....._ ~,_i~
,-<-"
...~ ~, ,-I
- TO
,;""f'~'-::-.f"t"';L',"';;\,,,,.Jj"'iffi~1ft~!iIl!it1M*~~~,\;jj~~~~'" ,;-~; "'""'~
;".,""
,~ -
Hi1.ND
'-.-,
.-
..... -,0
'"-c: -:'0
,. ~,:,\;,-,.' ,',
f~ft;;:,~:iti;';!:~T)!'.;,~l~lJ~JU""". LJ."~"-,~,4mo'\';,'~~~!~Y",:'!:f:~":l};~JM~LLJL,,,:,:!Jll!U,, >~;:-,:e \M ;~,~" 0' ,_~
,,~
m
r~::fiE'iWlrTjl 'if;"" or ''---'" {fif ~
In The Court of Common Pleas of Cumberland County, PenI.lsylvania
Wirl Builders
vs.
Dirnitrios T. Tsitsiris et al
SERVE :
Germy Belize, Inc. a/k/a
Belize Germy Corporation
No.
01
5804 civil
Now,
November 19, 2001
, I, SI-IERlFF OF CUMBERLAND COUNTY, P A, do
hereby deputize the Sheriff of
Lehigh
County to execute thi s Writ, this
deputation being made at the request and risk of the Plaintiff.
~~~~4~~
Sheriff of Cumberland County, P A
Affidavit of Service
Now,
,20_, at
0' clock
M. served the
within
upon
at
by handing to
a
copy of the original
and made known to
the contents thereof.
So answers,
Sheriff of
County, PA
Sworn and subscribed before
me this _ day of ,20_
COSTS
SERVICE
MILEAGE
AFFIDAVIT
$
$
,
HI
. ~
bHER I F:F OFF I CE LEH I GH COUN'rV COURTHOUl,E
455 W HAMILTON ST
ROlWI 10'=, ,ciLLENTOWN pp, 18101" 1 E,:1. 4
PArD
tJC:'
v..J
DOC#: 2001-CV-4234
CASE, 200:l.-NC-4072
EXPIR. 04-Nov-2001
DEPOSIT, :30.00
ENTRV, 16-0ct-2001
IJJ I F(L BU I LDERS
DIMITRIOS T TSITSIRIS; ET AL
(CUMBERL.,AND)
~.tJF~ I 'Or :;
AND NOTICE
SERVE, ~=TER TSITSIRIS
;:, I' NEI~ C I TV V I EW DINER {'iU_ENTOWN, PA
----------------------------------------------------------------------------
RETURN OF SERVICE
", ""110' C'IF':' 'I I"r, 'I' 'J'" ["', JAI c'....'..'\!E'I..'" po I ~ .r -'-;S,' -Is /r,' I"
]." 1\1141- _, , '\.I,.... 1 ,_ _ ,.ll::.r\. ,_ _ ",.__~_~....~,_MH.S:::::___~..:.l..____...!~__...__,_,.,_......_,..,__LH__'....'..'HH___.....H__..___...,.._HH_H_n....._.......__.~..,..,__..._,.__
<:.'" RE U"i '1' I UNSHII'rD OEF:ENO,ciNT, ._..............._.....f~C~JJ.~.~_L,........~~~,~!.:.!~..~_.._._.._.._._.....__._._..._.._....._._,_....___....._...
:'" 0,:1 TE ,._....Lll........=....L:1.....__.__...._ 20 __~J '1' I !'IE ,.._....L.~?LQ.,............-._...... HDUF6 ,.._......_..._.._
,+" LOCI:,l I ON OF ::;EI~V I CE ,.............f1n.f!....~..Jh...c__LL__ + (r....cCifL...1.1r:{,,:c::h..-..-......-...........--....-.
.............._....,....._...._.__..........._.._............_.._................._..........__..__...........w..-':lt'1....h.!i..LL.................._............._.........................................................._......,.................................,........................_.
5. UNABLE TO Lm:ATE,
( ) NI.WIBEF: UF ,clTTEi'IPT:3 TD LUCATE DEFEI\IDAN'r AT LA,3T I(I\IUWN ADDf':ESS,
:I.. DATE & TIME 2. DATE & TIME
~:" DI...\'TE i;, '1 I ~IE
Lf" DATE &1' II'IE
:"5. D?\TE t, Tl~IE
b" D?HE & r I1vIE
i'.\CCEF'T?\I\ICE UF SEI:~V I CE
I HH(EBY I',CCEPT SH(VlCE ClF THE LE(3I~L. F'HUCE:3S ?\S OUTLINED ON THE FRCJI\lT tlF THE
DDCUlvIENT" THlL:; SEF:VICE IS {'iCCEPTED UN BEHI~LF OF THE us'rED DEFENDI'iNT (8) M\lD
I HEREBY CEI":T I i:::V THin I i~~1 AUTHOR I ZED Tt! Dt! 8t!"
P!'iIhJTETI 1\){.lJ'1E OF AUTHOF:IZED ,c,GENT
S I GNf'i TUHE UP ?\UTHUI"( I ZED (-\GENT
Dr4'fl::: ::
TI~IE ,
.
c>f~'~:.F:~..J:.F:.7F~....0""1::-.I..;:I.:;...I'...i:::.~I...-"::0::.[..'-11';;::1:.;..:...............................-............'
.... r:::. \ , .,_r~.. 1 . .:1. L.; H "I '(
---:
~
SHERIFF OFFICE LEHIGH COUNTY COUron-HOUSE
L1.!:;!5 W HAMIL TON ST
.. I'<OO~I 106 ALL.EI~TIJWN PA 18101,-161"1.
P A.ID
...
WIRL BUIL.DERS
VS
DIMITRIOS T TSITSIRIS; ET AL
(CU~IBERL.AND )
DOC#: 2001-CV-4234
SASE: 2001-NC-4072
EXPIR: 04-Nov-2001
,DEPOSIT: 30.00
ENTRY: 1.6'-Oct'-2001.
WRIT :
AND NOT I CEo
SERVE: PETER TSITBIRIS
AT NEW CITY V I EW DINER ALLENTOWN, PA
RETURN OF SERVICE
1. 1~(~~lE OF I ND I V I DUAL SERVED: P e... h r 7S / -I- s /" i/______._.._.__.._._....__.____
2. RELA T I ONSHI PTO DEFEI',D,clNT: _._.__e_~.F'; P_llqJ......_.!~~.~.!' ( ~____.__._.______
:.>. Do'''TE: ----.I tL_:_L._:l__._....._._.._ 20 ~1 T I I"IE: --L..s;:p () ...____..._ HDURS : ___
4.. LDC!'! T I DN DF SEI'<V I CE : ---LJn.Q.s..k-~"''-:-LJ.-...-..d:=.---G:(gfL-{ir.(..{:.t.-.---..-----
___._____.___.________w. h,~ h"i ,) _._.__.___._....._..._......._.....
5. UNABL.E TO LOC(:HE:
( ) NUMBER OF ATTEMPTS TD LOCATE DEFEI\IDANT AT LAST I<NDWN ADDRESS:
, DATE & T Ii'1E 2. DATE & TIME
.. . ------,-------
., DATE & TI~IE 4. DATE & T I i"IE_._._._
-' . ._-~-.-~_._---,------- ~----_._,._._-
~5 = DATE & TIt'IE ---.-. 6. DATE & '1 Ii'1E ----.-...---~--_.~_._------
ACCEPTANCE OF SEI'<'VICE
I HEREBY ACCEPT SEFN I CE OF THE LEGAL F'I'<DCESS AS OUTL rNED ON THE FRONT llF THE
DOCU~IENT. TI../:[S SERVICE IS ACCEPTED ON BI::HALF OF THE LISTED DEFENDANT (S) AI\lD
I HEREBY CERT IF'Y THAT I ,~l"J AUTHORIZED TO DO SO.
PRINTED NAME OF AUTHORIZED AGENT
SIGNATURE OF (~UTHDI"I;;::ED AGENT ,
DATE,
TIIVIE:
,
SD ANSWERS
SHERIFF OF U::HIGH COUNTY
. .
WIRL BUILDERS
Claimant
COURT OF COMMON PLEAS OF
CUMBERLANDCOUNTY,PENNSYLVAN~
V.
NO. 2001- .>!f't? Y
MECHANIC'S LIEN
....,
c::_"
9
DIMITRIOS T.TSITSIRIS,
Owner
NICHOLAS GIAMBILlS,
PETER TSIRIGOTIS
GENNY BELIZE, INC., A1KlA
BELIZE GENNY CORPORATION AND
ST. JOSEPH'S & MARY INC.,
EQUITABLE OWNERS
n--J
o
-,('
f<)
CD
TO: DIMITRIOS TSITSIRIS
RD #2, Box 2414
Reading, PA 17070
DIMITRIOS TSITSIRIS
c/o Camp Hill Diner
3449 Simpson Ferry Road
Camp Hill, PA 17011
Owner
NICHOLAS GIAMBILlS ST. JOSEPH'S & MARY INC.
PETER TSIRIGOTIS , c/o Camp Hill Diner
GENNY BELIZE, INC. a/k1a 3449 Simpson Ferry Road
BELIZE GENNY CORPORATION Camp Hill, PA 17011
Equitable Owners
NOTICE OF FILING OF MECHANIC'S LIEN CLAIM
You are notified that a mechanic's lien claim in the amount of $14,365.00 has
been filed on behalf of Wirl Builders against the property at 3449 Simpson Ferry Road,
Camp Hill, Pennsylvania 17011, of which you are the owner or reputed owner. The
claim was filed on October 5, 2001 in the Court of Common Pleas of Cumberland
County to No...;z..fJ(~5"t'8Y A copy of the claim is attached.
,,"",,
'\.-
tlam:!
~ ZJ~7~
sf phe D. Tiley, Esquire
Attorney for Wirl Builders
5 South Hanover Street
Carlisle, PA 17013
Tel: (717) 243-5838
/~it!J1
"'.,"<',;,
',.:'.';~)
"",,,"
',,':> ;,:':' :~, ::,.: :'-,,~~-'~;n 2)'~ G<~i;tsk1. t~o
," r' """ n: CJd ~5T
.,..~~~;::' ~ .-P~?~
PrOil~..,n!i1~..:,;iY
I""~._,,,...-
.~~-
WIRL BUILDERS
Claimant
V.
DIMITRIOS T. TSITSIRIS,
Owner
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-
MECHANIC'S LIEN
NICHOLAS GIAMBILlS,
PETER TSIRIGOTIS
GENNY BEliZE, INC., AlK/A
BELIZE GENNY CORPORATION AND
ST. JOSEPH'S & MARY INC.,
EQUITABLE OWNERS
MECHANIC'S LIEN CLAIM
Claimant, Wirl Builders, through the undersigned counsel, files this claim
against the improvements and property at 3449 Simpson Ferry Road, Camp Hill,
Pennsylvania, known as the Camp Hill Diner and also known as that certain lot with
any improvements erected thereon situate in Hampden Township, Cumberland
County, Pennsylvania, being Lot No. 1 of a Subdivision Plan of Sanndrel of
Pennsylvania, Inc. recorded in Cumberland County Plan Book 34, Page 98, for the
payment of a debt due to Claimant as contractor for labor furnished by Claimant under
a contract for the erection and construction of new improvements at the property, but
for which only the demolition of prior improvements and some site preparation was
completed before Claimant ceased work on property for non-payment of bills. In
support of the claim, the Claimant makes the following statement:
1. (a) The owner of the property is Dimitrios T. Tsitsiris, an adult individual,
whose address according to Cumberland County assessment records is 3449
Simpson Ferry Road, Camp Hill, Pennsylvania 17011 and whose address on the
deed by which he took title was RD #2, Box 2414, Reading, Pennsylvania 17070.
(b) By Memorandum of Installment Sales Agreement, recorded June 18,
1997 in Cumberland County Miscellaneous Record Book 550, Page 299, Nicholas J.
Giambilis and Dimitrios T. Tsitsiris, purported owners of the property which is the
subject of this Claim, sold such property to Peter Tsirigotis. The said Memorandum of
Installment Sales Agreement does not provide any addresses for any parties thereto
but Claimant believes that Nicholas J. Giambilis resides at 7 Graham Road, Newville,
PA 17241 and Claimant believes that Peter Tsirigotis has a place of business at New
City View Diner, Allentown, PA 18105. The said Memorandum of Installment Sales
Agreement also recites that Peter Tsirigotis had assigned his interest in the
Installment Sales Agreement to a Pennsylvania Corporation known as Genny Belize,
Inc.
'r'!1~~",""'-'<!I\l""
-" '1--':'--,-
1j""
~, ,
- -,~
.
(c) A certain Memorandum of Lease with Option to Purchase was
recorded on June 18, 1997 in Cumberland County Miscellaneous record Book 550,
Page 304 whereby the parties intended to memorialize a Lease with Option to
purchase granted by Genny Belize, Inc. to St. Joseph's & Mary, Inc. Neither
Corporation was identified as to address or state of incorporation in said instrument.
Since Genny Belize, Inc. is identified as a Pennsylvania Corporation in the
aforementioned Memorandum of Installment Sales Agreement, a search of the
Pennsylvania Department of State Corporation Bureau records was made for that
corporation and none was found, however, a corporation identified as Belize Genny
Corporation of 1831 Macarthur Road, Whitehall, Pa. 18052 was found and Claimant
believes it may be one and the same entity as that identified as Genny Belize, Inc. A
further search of the Pennsylvania records for St. Joseph's & Mary, Inc. found no
record.
2. The improvement and the property which are the subject of this claim is all
that certain tract or parcel of land situate in the Township of Hampden, County of
Cumberland, Commonwealth of Pennsylvania, known as Lot NO.1 of a Subdivision
Plan of Sanndrel of Pennsylvania, Inc. recorded in Cumberland County Plan Book 34,
Page 98, and which property is further described by copy of the deed from James P.
Ross et al. to Dimitrios T. Tsitsiris, dated June 20, 1995 and recorded June 21, 1995,
in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle,
Pennsylvania, in Deed Book 123, Page 993, a copy of which deed is marked Exhibit
"A," is attached hereto, and is incorporated herein by reference thereto. This property
was occupied by a restaurant known as The Camp Hill Diner having an address of
3449 Simpson Ferry Road, Camp Hill, Pennsylvania 17011, which Diner burned.
3. Claimant was hired on a time and materials basis to construct a new
restaurant on the property, including the demolition of the remains of the prior
structure.
4. The labor for which the debt is due consisted of labor and equipment
supplied for the demolition of the prior structure and the beginning of site preparation
and work on the replacement restaurant as described in the statement dated June 7,
2001, a copy of which is marked Exhibit "B" is attached hereto and is incorporated
herein by reference thereto.
5. The Claimant began work on May 23, 2001 and ceased work for non-
payment of bills on June 7, 2001 which is less than four months before the filing of
this claim.
6. Claimant has been paid nothing on the total amount billed of $14,365.00
as shown on the attached Exhibit "B" and that is the amount which remains due and
owing and for which the claim is made in the amount of $14,365.00.
;>1l~_,,,.4.,,~ ",'
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, ~ .
-
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Respectfully Submitted,
/Y7/
~ '
A ~7..A
S eph n D. Tiley, Esquire
Attorney for Claimant, Wirl Builders
5 South Hanover Street
Carlisle, PA 17013
Tel: (717) 243-5838
VERIFICATION
I verify that the statements made in the foregoing Mechanic's Lien Claim
are true and correct, partially upon personal knowledge and partially upon my belief;
to the extent language in the Mechanic's Lien Claim is that of my attorneys, I have
relied upon my attorneys in making this Verification. I understand that false
statements herein are made and subject to the penalties of 18 Pa. C.S. s4904
relating to unsworn falsification to authorities.
Dated: Wd'-'-L S; 2COJ
ttfw/d:AJ)
, "- \ ',,,,~_. - - ,,"- '1'" -' I
,
, "
-.~
1;;19 'l8
/(.-(
ROBERT :'), ZlEGLEll
RECORDER Or DEEDS
l;UMBEnLI.IID COUNTY-fA
J &-1-7-- bOf-6l.:>
:95 JUli 21 fil'l10 3~ THIS DEED
Made the r21/L day of ~,....,v- in the year of our Lord one
thousand. nine hundred and m.nety-five (1995) Between JAMES P.
ROSS, STEPHEN E. BENSON, DAVID G. BENSON and WILLIAM P. KINSEY,
trading and doing business as RBK PROPERTIES, a general
partnership with its principal office at 6-D Springridge Court.
Baltimore, MD 21244. "GRANTOR". and party of the first part
AND
DIMITRIOS T. TSITSIRIS, an adult individual, of Reading, Berks
County, Pennsylvania, "GRANTEE", and party of the second part
WITNESSETH, that the said Grantor, party of the first part.
for and in consideration of the sum of Three Hundred Thirty-Three
Thousand Five Hundred Dollars ($333,500.), lawful money of che
United States of America, unto ,it well and truly paid by the said
party of the second part, at or before the sealing and delivery
of these presents, the receipt whereof is hereby acknowledged,
and by these Presents does hereby grant. bargain, sell, alien,
enfeoff, release, convey and confirm unto the said party of the
second part, its successors and assigns
ALL THAT CERTAIN tract or parcel af land situate in the
Township of Hampden, County of Cumberland, Commonwealth of
Pennsylvania, bounded and described as follows:
COMMENCING at the Intersection of the Centerline of
Zimmerman Drive. and the Centerline of Simpson Ferry
Road (L. R. 570). thence westerly along tbe Centerline
of Simpson Ferry Road a distance of 746.79 feet. to a
point in the Centerline of Simpson Ferry Road, said
point being the Southwest corner of property of
Sanndrel of Pennsylvania, Inc. of which this Tract was
formerly a part I thence along land now or formerly of
Annplyco Properties, Inc. North 130 53' west a distance
of 72.37 feet to a point on the ultimate right-of-way
line of Simpson Ferry Road; thence along said ultimate
right-of-way line of Simps'on Ferry Road north 760 33'
east a distance of 47.74 feet to a point, the PLACE OF
BEGINNING of the tract herein described; thence alon~
land of Sanndrel of Pennsylvania, Inc. north 130 27
west a distance of 175 feet to a point; thence
continuing along the same no~th 760 33' east a distance
of 160 feet to a point; thence continuing along the
same south 130 27' east a distance of 175 feet to a
point on the ultimate right-of-way line of Simpson
ferry Road. thence along the ultimate right-of-way line
l(ifo~ i23 PAGE 993
iEXHIBrr '"A"
a
,"-"....',r.,e>'t' <,"",,"_, "",~ _N_~'~
"C.'""",
" ""'~',;,'d
'" "~>.,_~,, 'T""__"'_,~'~ ~ ._~
of Simpson Ferry Road south 760 33' west a d1stance of
160 feet to the place of beginning, CONTAINING 28,000
square feet of land.
BEING lot U1 of a subdivision plan of Sanndre! of
Pennsylvania, Inc., prepared by John C. Brillhart
Surveying and Mapping Services of Mechanicsburg,
Pennsylvania, as recorded in Plan Book 34, Page 98, of
the Cumberland County Records and being the same
property conveyed by Hampden Industrial .Development
Authority to RRK Properties by deed dated ){t1:iJ r
1995 and recorded in the Recorder of Deeds Qtt1ce of
Cumberland County, in BooltJ~3 Pageq~1'
Containing .64 acres more or less.
UNDER AND SUBJECT nevertheless to those restrictions
as appear of record in Deed Book G 28, Pages 414
through 417.
ALSO UNDER AND SUBJECT to that agreement not to erect
a barrier as set forth in Deed Book G 28, Page 427
recorded in the Office of the Recorder of Deeds,
Cumbe~land County, Pennsylvania.
TOGETHER with the easement of ingress and egress
granted by a predecessor in title. SANNDREL OF
PENNSYLVANIA, INC. and set forth in Deed Book G28, Page
417 recorded, in the Office of the Recorder of Deeds.
Cumberland County, Pennsylvania.
AND TOGETHER with all interes ts of RBK Properties.
Grant:or. and subj ect: t:o the duties, terms and
conditions as set forth in that certain lease dat:ed
August 20. 1979 between SANNDRltL OF PE.NNSYLVANIAI INC.
and Grantor relaring to property as therein described
for an underground water line, natural gas line and
electric and telephone service which lease is subj ect
of a Memorandum of Lease, recorded on September 281
1979 in the Office of Recorder of Deeds, Cumberland
County at Book 247, Page 131.
AND TOGETHER with all and singular the improvements.
ways, waters, watercourses, rights I liberties,
privileges, hereditaments and appurtenances to the same
belonging, or in anywise appe:ttaining, and the
reversion and reversions, remainder and remainders,
rents. issues and profits thereof; AND ALSO all the
estate, right, title, interest, property, claim and
demand whatsoever, both in law and equity, of the said
nOOK 123 flCCC 994
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Grantor, ofl in,- to or out of the said tract of land,
and every part and parcel thereof.
TO HAVE ANO TO HOLD the said tract of land, with all and
singular the hereditaments and premises hereby granted or
mentioned, and intended so to be, with the appurtenances I unto
the said Grantee, its successors and assigns, to and for the only
proper use and behoof of said Grantee, its successors and assigns
forever. SUBJECT to the restri~tions as appear o~ record in Deed
Book G 28, Pages -414 through 417 in the Office of Recorder of
Deeds ~or Cumberland County.
AND the said Grantor, for itself and its successors does by
t.hese presents, covenant, grant and agree to and with the said
Grantee, his heirs, successors and assigns, that the said
Grantor, its successors and assigns, all and singular the
hereditaments and premises herein above-described and granted. or
mentioned and intended so to be, with the appurtenances unto the
said Grantee, his successors and assigns, against the Grantor,
its successors and assigns I and against all and every other
person or persons, whomsoever, lawfully claiming or to claim the
same or any part thereof, by, f~om or under it, him, her, them or
sny of them, Shall and Will SPECIALLY WARRANT AND FOREVER DEFEND.
IN WITNESS WHEREOF, the said Grantor, has caused this Deed
to be executed by its proper representative the day and year
first above 'Written. '
'lITNESS,
!ta;
.,p.~
GRANTOR:
RilK. PROPERTIES
JAMES P. ROSS, STEPHEN E.
BENSON, DAVID G. BENSON &
WILLIAN P. KINSEY
By, R,~~Ci!Q
Attorney-in-fact
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF j)+J
On this...{of,vday of~, 1995, before me, a NotC\ry Public,
undersigned officer, personally appeared .~'rf-":,A...I.I C.
, who acknowledged fi~ e f to be the
attorney-in- act or J ES P. ROSS, STEPHEN E. BENSON, DAVID G.
DENSON and WILLIAM P. KINSEY, individually and for RBK
SS
BOOK 123 fACE 995
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Properties, a genera~ partnership, as appointed by its partners,
and tha t I being authorized to do 50 I executed the foregoing
instrument for the purposes therein contained by signing the
names of the said Partnership, and its individual partners by him
as attorney-in-fact.
IN WITNESS WHEREOF, I have here~nto set my hand and notarial
seal.
&/ (I '
'1 c,,.'; a, :...dL,/J
otary Public .
My Commission Expires: ,;o{~/';'ly'
(SEAL)
CERTIFICATE OF RESIDENCE
NolarialSeal
Gloria A, CIlddingloo, NoialY Public
Harrisburg, Dauphin County, PA
MyCommlsslonExpirosFeb,14,1998
._.Io..."~..,,,...-
that the ~recise residence of the Grantee
Ro.,,!;J, 'J;", al.\l'1
R~l\'\,('f\ rA 11o'!-(")
,
,
.-/'
I, hereby certify
herein is as follows:
Attorney for Grantee
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SS
Recorded on this day of
Recorder's office of the said County
Page
, 1995 A, D. in the
Dook Volume
Given under my hand and seal of the
year aforesaid.
the day and
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8!JOK 123 P.\CE 996
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TO: Camphlll Diner
3449 Simpson Feny Road
Camphill, FA.
June 7,2001
FROM:
Wir! Builders
855 York Road
Carlisle, P A.. 17013
258-3435
PROJECT: Demolition of existing building.
[vlay nru - LABOR 850.00
May 24th - Labor 1100.00 ,backhoe/delivery 570.00
May 25th - Labor 700.00, backhoe 240.00, dump truck 340.00
[vlay 28th no dumpsters
May 29th - Labor 1100.00, backhoe 480.00, dump truck 405.00
May 30th - Labor 820.00, backhoe 480.00
June 1st - Labor 1100.00, backhoe 480.00, dump truck 210.00
June 4th - Labor 900.00, backhoe 440.00, truck 360.00, jackhammer 200.00
June 5'11 - Labor 95000, backhoe 440.00, truck 380.00, ram/hoe 360.00
June 6th - Labor 320.00, backhoe 440.00, truck 135.00
June 7'h - Labor 240.00, backhoe 190.00, truck 135.00
TOTAL COST OF DEMOLITION $14,365.00
Note: Much of the work done on June 5, and all work on June 6 and 7 should be
considered as part of the re-construction. Slabs areas were removed for leveling
purposes, parts of the concrete slab were demolished for plumbing, and rnasonar\
walls were begun to be reconfigured for the new roofline and perimeter changes.
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Wirl Builders
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