The URL can be used to link to this page

Home My WebLink About07-5862r CUMBERLAND-FRANKLIN JOINT MUNICIPAL AUTHORITY, Plaintiff v. INDIAN SPRINGS ASSOC. LLC, Defendant IN THE COURT OF COMMON PLEAS OF FRANKLIN COUNTY, PENNSYLVANIA NO.o~-SSro~ MLD MUNICIPAL LIEN MUNICIPAL LIEN Cumberland-Franklin Joint Municipal Authority files its claim in the amount of Nine Thousand, Six Hundred Fourteen and 00/100 ($9614.00) Dollars, plus costs and late charges of One Hundred Forty-nine and 00/100 ($149.00) Dollars, for a total due of Nine Thousand, Seven Hundred Sixty-three and 00/100 ($9,614.00) Dollars as of October 3, 2007 and sets forth in support thereof the following: 1. Claimant is Cumberland-Franklin Joint Municipal Authority, Cumberland and Franklin Counties, Pennsylvania, with its principal office located at 725 Municipal Drive, Shippensburg, Franklin County, Pennsylvania, 17257. 2. Bob Erwin is the authorized representative and part owner of Indian Springs Assoc. LLC, owner of the property against which this Municipal Lien is filed. Mr. Erwin's last known address is 242 West Chocolate, Hershey, PA 17033. 3. The property against which this Municipal Lien is filed is all that tract of land with improvements thereon situated on Kline Road, in the Township of Southampton, County of Cumberland, Commonwealth of Pennsylvania, being known as Indian Springs Manor Mobile Home Park, Shippensburg, Pennsylvania, 17257. 4. The authority under which this Lien is filed is the Municipal Claims Act of 1923, P.L. 207, as amended (53 P.S. §7101, et seq). 5. This Municipal Lien is filed to secure an interest for unpaid sewer rents levied, assessed or established for the period through September 30, 2007. 6. The sewer rentals were duly established, levied, and assessed by the Cumberland-Franklin Joint Municipal Authority, being the lawful authority for doing so under the several Acts of Assembly of the Commonwealth of Pennsylvania which govern such matters, and were levied, established and assessed for the purpose of providing sewer service to the properties of said Township. WHEREFORE for all the above reasons, Cumberland-Franklin Joint Municipal Authority hereby does place a lien against the said property in the amount of $9,614.00. Respectfully Submitted TURD LAW OFFICES Date -'`" Richar och, Esquire Authority Solicitor 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Municipal Lien, upon the defendant, by depositing same in the United States Mail, first class mail, postage prepaid, on the 4th day of October, 2007, from Carlisle, Pennsylvania, addressed as follows: Indian Springs Assoc. LLC c% Bob Erwin 242 West Chocolate Hershey, PA 17033 RESPECTFULLY SUBMITTED, TORO LAW OFFICES // .~- L/ ichard Koc quire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 ID# 92956 ~ ~ ~~ J v7 -D 4 ~ V r' ; r~,> ,1( r~ ~~ v n T~ ~ ~"~ ' ~ C ~ ~~ r- _~ tl ~,_ ~,: ~ ' p I -~.. ; .w ~ _ CY } ~ CUMBERLAND-FRANKLIN JOINT i MUNICIPAL AUTHORITY, Plaintiff v. IN THE COURT OF COMMON PLEAS OF FRANKLIN COUNTY, PENNSYLVANIA NO. 07-5862 MLD INDIAN SPRINGS ASSOC. LLC, Defendant :MUNICIPAL LIEN PETITION TO AMEND 1. Petitioner is plaintiff in the above captioned matter. 2. In October 2007, petitioner's counsel became aware that the petitioner's lien had some typographical errors concerning late charges and other costs. 3. The petitioner's lien included costs but neglected to add that figure to the total due and outstanding, in two places. 4. A proposed amended version of the lien is attached. Wherefore, petitioner respectfully requests this honorable court grant the petition tp ', amend the petitioner's lien. Respectfully Submitted, ~. 20~~ Date `~/(//l.J~// /Lt Richard Koch, Esquire Turo Law Offices Supreme Court Number 92956 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 a CUMBERLAND-FRANKLIN JOINT MUNICIPAL AUTHORITY, Plaintiff v. INDIAN SPRINGS ASSOC. LLC, Defendant IN THE COURT OF COMMON PLEAS OF FRANKLIN COUNTY, PENNSYLVANIA NO. 07-5862 MLD MUNICIPAL LIEN AMENDED MUNICIPAL LIEN Cumberland-Franklin Joint Municipal Authority files its claim in the amount of Nine Thousand, Six Hundred Fourteen and 00/100 ($9,614.00) Dollars, plus costs and late charges of One Hundred Forty-nine and 00/100 ($149.00) Dollars, for a total due of Nine Thousand, Seven Hundred Sixty-three and 00/100 ($9,763.00) Dollars as of ~r 3, 2007 and sets forth in support thereof the following: 1. Claimant is Cumberland-Franklin Joint Municipal Authority, Cumberland nd Franklin Counties, Pennsylvania, with its principal office located at 725 Municipal e, Shippensburg, Franklin County, Pennsylvania, 17257. 2. Bob Erwin is the authorized representative and part owner of Indian ngs Assoc. LLC, owner of the property against which this Municipal Lien is filed. Mr. in's last known address is 242 West Chocolate, Hershey, PA 17033. 3. The property against which this Municipal Lien is filed is all that tract of with improvements thereon situated on Kline Road, in the Township of thampton, County of Cumberland, Commonwealth of Pennsylvania, being known as ~n Springs Manor Mobile Home Park, Shippensburg, Pennsylvania, 17257. 4. The authority under which this Lien is filed is the Municipal Claims Act of 923, P.L. 207, as amended (53 P.S. §7101, et seq). 5. This Municipal Lien is filed to secure an interest for unpaid sewer rents led, assessed or established for the period through September 30, 2007. 6. The sewer rentals were duly established, levied, and assessed by the Cumberland-Franklin Joint Municipal Authority, being the lawful authority for doing so under the several Acts of Assembly of the Commonwealth of Pennsylvania which govern such matters, and were levied, established and assessed for the purpose of providing sewer service to the properties of said Township. WHEREFORE for all the above reasons, Cumberland-Franklin Joint Municipal '~ Authority hereby does place a lien against the said property in the amount of $9,763.Op. Respectfully Submitted TURD LAW OFFICES ~20 ichard och, Esquire Authority Solicitor 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Petition to Amend and the Amended Municipal Lien, upon the defendant, by depositing same in the United States Mail, certified mail, postage prepaid, on the 9th day of November, 2007, from Carlisle, Pennsylvania, addressed as follows: Indian Springs Assoc. LLC c/o Bob Erwin 242 West Chocolate Hershey, PA 17033 RESPECTFULLY SUBMITTED, TURO LAW OFFICES ha och, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 ID# 92956 C'? ~ ~ ~~ t?r ~ ~ ~ <<~ 4 t~° tv ~"-~ ~ ~ "fi , { r F~ .~' °"'"C~ ~ '".,y ~ CUMBERLAND-FRANKLIN IN THE COURT OF COMMON PLEAS OF JOINT MUNICIPAL CUMBERLAND COUNTY, PENNSYLVANIA AUTHORITY, Plaintiff v, CIVIL ACTION -LAW INDIAN SPRINGS ASSOC., LLC, Defendant NO. 07-5862 CIVIL TERM ORDER OF COURT AND NOW, this 16`h day of November, 2007, upon consideration of Plaintiff's Petition To Amend, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days from the date of this order. BY THE COURT, r V7 esley Oler, r., Richard Koch, Esq. South Pitt Street Carlisle, PA 17013 Attorney for Plaintiff ~dian Springs Assoc., LLC c/o Bob Erwin 242 West Chocolate Avenue Hershey, PA 17033 :rc ~~~ n,~r! t~sr~r~l~d ~~r ~~ ~~ i~d J ~ ~{1~~~(IZ ~tr~b1GP~~ J~'d ~ yet 4-~~~~~ ~0 CUMBERLAND-FRANKLIN JOINT : IN THE COURT OF COMMON PLEAS OF MUNICIPAL AUTHORITY, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 07-5862 MLD ' ' i _ l M13 INDIAN SPRINGS ASSOC. LLC, : MUNICIPAL LIEN =? - Defendant a' Y.... , i try + +t p PRAECIPE ? c? co TO THE PROTHONOTARY: Please satisfy, settle, withdraw and discontinue the above-captioned matter on behalf of the Plaintiff. Respectfully Submitted, TURO ROBINSON ATTORNEYS AT LAW 13 I I Date A r J m s M. Robi on, Esquire 129 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Supreme Court ID # 84133 Authority Solicitor A- 0.4 ?k1?S1?