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Home My WebLink About07-7503S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ACCU-TECH CORPORATION, Claimant, VS. DICKINSON COLLEGE TRUSTEES, Owner or Reputed Owner, vs. WARD COMMUNICATIONS, INC., Contractor. PROPERTY LOCATION: West Louther and North College Streets Carlisle, PA 17013 Tax Assessor Parcel # 05-21-0320-079 EX No. 07- 7503 M LD STATEMENT OF MECHANIC'S LIEN CLAIM FILED ON BEHALF OF: Claimant COUNSEL OF RECORD FOR THIS PARTY: NICHOLAS D. KRAWEC, ESQUIRE PA ID NO. 38527 CHRISTOPHER M. BOBACK, ESQUIRE PA ID NO. 91730 SHAWN P. MCCLURE, ESQUIRE PA ID NO. 205951 Bernstein Law Firm, P.C. Firm #718 Suite 2200 Gulf Tower 707 Grant Street Pittsburgh, PA 15219 412456-8100 BERNSTEIN FILE NO. C0057291 Ib002072V001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ACCU-TECH CORPORATION, Claimant, VS. No. 01- 7S6 3 /h )-D DICKINSON COLLEGE TRUSTEES, Owner or Reputed Owner, vs. WARD COMMUNICATIONS, INC., Contractor. STATEMENT OF MECHANIC'S LIEN CLAIM AND NOW COMES Claimant, Accu-Tech Corporation, by its legal counsel, Bernstein Law Firm, P.C., and files this Statement of Mechanic's Lien Claim as a material supplier to a contractor, pursuant to the Mechanic's Lien Law of 1963, 49 P.S. Section 1101 et. seq., against the premises herein described, any and all buildings erected thereupon, and the curtilage appurtenant thereto, for the payment of $30,172.00, together with interest from June 19, 2007, due it as a material supplier to the contractor under the contract herein described. The following is a statement of its claim: 1. Claimant is Accu-Tech Corporation, a corporation organized and existing under the laws of Georgia with a place of business located at 200 Hembree Park Drive, Roswell, Georgia 30076. 2. Owner is Dickinson College Trustees, a non-profit corporation organized and existing under the laws of Pennsylvania, with offices located at 272 West High Street, Carlisle, Cumberland County, Pennsylvania 17013. lb002072V001 3. Contractor is Ward Communications, Inc., a Pennsylvania business corporation whose address and place of business is 6951-D Allentown Blvd., Harrisburg, Pennsylvania 17112. 4. This claim relates to materials provided by Claimant as a material supplier to Contractor upon the premises designated at West Louther and North College Streets, Carlisle, Cumberland County, Pennsylvania, being more fully described in the Deed conveying said premises to Owner, recorded in the Office of the Cumberland County Recorder of Deeds, identified as tax assessor's parcel number 05-21-0320-079 EX. 5. On or about June 19, 2007, Claimant, pursuant to a contract with Contractor, agreed to furnish network cabling products and related connectivity materials for construction at the premises above described. A true and correct copy of the invoice describing the aforesaid materials supplied by Claimant to said premises is attached hereto, marked Exhibit "1" and made a part hereof. 6. Claimant last supplied the aforesaid materials to the above-described premises on or about June 19, 2007. 7. The materials supplied were utilized in the construction at the above-described premises and were free from defect and were in accordance with Claimant's agreement with Contractor. 8. The total amount claimed by Claimant to be due is $30,172.00, together with interest from June 19, 2007, for the aforesaid materials provided in connection with the agreement to provide construction materials to Contractor upon the premises above described. 9. Formal Notice of Claimant's Intention to File Mechanic's Lien Claim was sent to the Owner on November 16, 2007, via overnight delivery through the DHL courier service, and served upon Owner on or about November 19, 2007. A true and correct copy of Claimant's Formal Notice of Intention to File Mechanic's Lien Claim, dated November 16, 2007, and the delivery 1b002072V001 confirmation report from DHL, evidencing service of said Notice, are attached hereto, collectively marked Exhibit "2", and made a part hereof. 10. This lien is claimed against the premises designated as West Louther and North College Streets, Carlisle, Cumberland County, Pennsylvania. Dated: De",t, BERNSTEIN LAW FIRM, P.C. Attorneys for Claimant By: e4w Christopher M. Boback, Esquire Pa. ID No. 91730 Suite 2200 Gulf Tower 707 Grant Street Pittsburgh, PA 15219 (412) 456-8100 BERNSTEIN FILE NO. 00057291 lb002072V001 NOV.13.2007 3:OOPM SENT BY ACCUTECH/710 140 2251 NO. 2398 P. 3 A=,TNM WRPb1A7'SO8' 200 fZRSE PARR DRIVE 11PXeat6 Remit tot i1WOICB No. 271333671 ROXIEUG, 6A 30076.3890 JACCU-TECH CORPORATION I INVOICE DTE. 06/19/07 (770) 740-2240 (P.O. SOX 100689 (CUSTOMER NO. J24011 RGLL FRE6t 1-4068-222-0032 ATLANTA, GA 30384-0489 JPAGE. 11 MX# (7701 740-2260 i I SALES INV01 CE ORDER NO. 216790 Ward Co mA nic:ations, Inc. ward Csmmmicatione, Tnc. Dj.akja8on Science Ct:r./,7ob Makinaon Saieaae ft=./t% P.O. Box 1068 6951-D hueneewn DZrd. D7osi:h Wales, PA 19454 Xarriob=g, VA 371" Ole-tamer Pe Number Shp Pte. 310 Rp Tea'ma oR De]ivery Ship Via lreYght Te=ed PR07-DC-001tx 06115/07 215444 Net 30 Days Best Way-around PPP & AL Lowed PO.# Description Qty to Shp ow 9up Qty 3/0 tr/N unit price Per lubenoioa 1/ 0 5E55-6W-CS 140000 140000 0 ft 178.00 mft 24920.00 24/4PR SOL NS CAT5E CMP BLUE 2/ 0 5E55-9W-CS 24000 24000 0 ft 178.00 raft 4272.00 24/4PR SOL NS CATSE W-WHITE 3/ 0 4F241O0/3-8-Hrr 700 700 0 ft 1400.00 mft 980.00 24/10OPR CAT3 PVC CMR GRAY Nerchandise Subtotal 30172.OD Total Due: 30172.00 cmimbs ORDER COMPLETE Please Remit In U.S. Funds 11/1312007 13:55 See Next Purge for Terms and Conditions EXHIBIT ------- -- --- ---- -- B I T IN CREDTTORs' RIGHTS AT BERNSTEIN LAW WWW.BERNSTgiNLAw.com/cREDrrOR A BUSINESS APPROACH CHRISTOPHER M. BOBACK. ESQ. TO LEGAL SERVICE CBOBACK@BERNSTEINLAW.COM 412,456-8115 FAx:412,456-8274 November 16, 2007 VIA DHL OVERNIGHT DELIVERY Dickinson College Trustees 272 West High Street Carlisle, PA 17013 Re: Accu-Tech Corporation Vs: Ward Communications, Inc. Project: Dickinson Science Center College and Louther Streets Carlisle, PA 17013 BERNSTEIN FILE NO. C0057291 FORMAL NOTICE OF INTENTION TO FILE MECHANIC'S LIEN CLAIM Gentlemen: This office represents Accu-Tech Corporation of Roswell, Georgia, the supplier of network cabling products and related connectivity materials to Ward Communications, Inc., on the job at the Dickinson Science Center located at College and Louther Streets in Carlisle, Pennsylvania. Enclosed please find a true and correct copy of the invoice reflecting the materials supplied by my client to Ward Communications, Inc. on the above mentioned job. The last date on which the aforesaid materials were supplied to the Dickinson Science Center was June 19, 2007. There remains an unpaid balance due from Ward Communications, Inc. in the amount of $30,172.00 for those materials. Please consider this letter your notice under the Pennsylvania Mechanic's Lien Law, 49 P. S. § 1101 et. seq., that if payment of said amount is not made in full to Accu-Tech Corporation within thirty (30) days of the date of this notice, it is Accu-Tech Corporation's intention to file a Mechanic's Lien Claim against the project property located at College and Louther Streets in Carlisle, Cumberland County, Pennsylvania. EXHIBIT 707 GRANT STREET • Sum 2200 GULF TOWER • PtrrsBURGH. PA 15219 • 800.927.3197 • 412.456.8100 • FAx 412.456.8135 • MAIL@Q RERNSTEINLAW.COM • WWw.BERNSTEINLAW.COM Dickinson College Trustees November 16, 2007 Page 2 If you have any questions regarding this notice, please contact the undersigned. Very truly yours, BERNSTEIN LAW FIRM, P.C. 61?w Christopher M. Boback CMB/lb cc: Ward Communications, Inc. 6951-D Allentown Blvd. Harrisburg, PA 17112 (VIA CERTIFIED MAIL) cc: NCS Attn: Gina Said Via Fax - 440-461-6202 Your File No. L117512 PLEASE TYPE OR PRINT _ "Faws"MMIMTS WittFgllw U .'s. Orky D! 0 tnl rn n e 14 i i ! N i f i N v p iy?'t; y {DCn p 409 a DHL.: Track (By number) Detail Page 1 of 2 Contac Ship Track Services About DHL Help DHL USA Home DHL Global Track results detail ? Fri Track Current status for 70770946245... Shipment delivered. V / Track by number ? View signature ? Track by reference ? Get delivery signature Delivered on: 11/19/2007 2:15 pm ? Track DHL Some Day service Delivered to: Receptionist ? Monitor shipments ; Signed for by: C CRAIN What is this? I Want to get the status of all your shipments in one place? Loam more about DHL ProViel L-- - - .......... . ............_............................................................._............................ ..................,..: Log in to DHL User ID Password r Remember my User ID Log In ? Forgot password/user ID? New to DHL online? Registration Is quick and free. ? Sign up now Tracking history... Data and time stews 11/19/2007 2:15 Shipment delivered. pm 8:10 '.am 11/17/2007 8:43 am 6:44 am With delivery courier Arrived at DHt_ facility i Depart Facility 2:02 Processed at DHL Location. am 11116/2007 11:53 Depart Facility pm 10:01 Processed at DHL Location. fPM 7:37 Shipment picked up Ipm DHL Facility Location Harrisburg, PA Why is this? i t Harrisburg, PA Harrisburg, PA i Wilmington - Clinton Field, OH Wilmington - Clinton Field, OH Downtown Pittsburgh, PA Downtown Pittsburgh, PA Downtown Pittsburgh, PA Shipment details... From . ( To Shipment Information BERNSTEIN LAW FIRM DICKINSON COLLLEGE ! Ship date: 11/18/2007 Pittsburgh, PA 15219 i Carlisle, PA 17013 Pieces: 1 United States United States ! Total weight: 1 lb Note Attention: Attention: ;. Ship type: Letter I BERNSTEIN LAW FIRM DICKINSON COLLLEGE Shipment reference: 0005' .....__._.._..... _....,..:,,:,, ... :.............__..... .__.........._...__........_. :Service: Express More _...__......_......._........ Express ? Track new shipment Tracking detail provided by DHL: 1111912007, 1:28:59 pm pt. Next Day service guaranteed. Questions? Open an account today and we'll guarantee your We're here to help! http://track.dW-usa.com/TrackByNbr.asp?nav=Tmcknbr 11/19/2007 11/14/2007 10:28 3 PAGE 02/02 n ° a VERIFICATION The undersigned does hereby verify under penalty of perjury, that he/she is the DIRecn& of G6fz %.r M7,vjAf5 of kcGu 7yaN CoiUg9-4-Tl p 14 , PlaitWff' herein, that he/she is duly authorized to make this Vexifiicador4 and that the facts set forth in the foregoing STATEMENT OF MECHANIC'S LIEN CLAIM are true and correct to the best of his/her knowledge, information and belief. (Sign in Blue Ink) Ib002038 V Q0I El s? 8 C-ZI 0 8 0 CZ7 4.- c -n 1 CASE NO: 2007-07503 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ACCU-TECH CORPORATION VS DICKINSON COLLEGE TRUSTEES RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within STATEMENTMECHLIENCLAIM was served upon DICKINSON COLLEGE TRUSTEES the DEFENDANT , at 1017:00 HOURS, on the 4th day of January , 2008 at WEST BUILDING DICKINSON LAW SCHOOL CARLISLE, PA 17013 by handing to DANA SCADUTO, ADULT IN CHARGE a true and attested copy of STATEMENTMECHLIENCLAIM together with and at the same time directing Her attention to the contents thereof. SHERIFF'S RETURN - REGULAR Sheriff's Costs: Docketing Service Affidavit Surcharge illbl08' 18.00 4.80 2.50 10.00 .00 35.30 So Answers: Sworn and Subscibed to before me this day of , R. Thomas Kline 01/08/2008 BERNSTEIN LAW FIRM By. Deputy She Ziff A. D. i .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ACCU-TECH CORPORATION, Claimant, VS. No. DICKINSON COLLEGE TRUSTEES, Owner or Reputed Owner, VS. WARD COMMUNICATIONS, INC., Contractor. AFFIDAVIT OF SERVICE Before me, the undersigned authority, personally appeared ?or,G1A. No?Jer who being duly sworn according to laws deposes and says as follows: That Affiant is a Deputy Sheriff of Cumberland County, Pennsylvania. 2. That on the y day of a r?r 215-0-6 as evidenced by a copy of the Sheriffs return attached hereto and marked Exhibit AfFiant personally served upon Dickinson College, Owners herein, the notice of filing of Mechanic's Lien Claim, specifying the Court, term, number and date of filing of the Statement of Mechanic's Lien Claim, and a true and correct copy of the Statement of Mechanic's Lien Claim. Sworn to and subscribed before me this ? flLday V=?, - Notary Public EMC DLA A, BRNOTANAL SEAT, NOTARY PUBLIC arlisl0 8=,C=bftW County Commission Expires April4,_2009 lb0020'72V001 Deputy Sheriff, ?uinberland County, Pennsylvania I. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ACCU-TECH CORPORATION, Claimant, VS. No. 07-7503 DICKINSON COLLEGE TRUSTEES, SATISFACTION OF Owner or Reputed Owner, STATEMENT OF MECHANIC'S LIEN CLAIM vs. WARD COMMUNICATIONS, INC., Contractor. FILED ON BEHALF OF: Claimant COUNSEL OF RECORD FOR THIS PARTY: NICHOLAS D. KRAWEC, ESQUIRE PA ID NO. 38527 CHRISTOPHER M. BOBACK, ESQUIRE PA ID NO. 91730 SHAWN P. MCCLURE, ESQUIRE PA ID NO. 205951 Bernstein Law Firm, P.C. Firm #718 Suite 2200 Gulf Tower 707 Grant Street Pittsburgh, PA 15219 412=456-8100 BERNSTEIN FILE NO. C0057291 PROPERTY LOCATION: West Louther and North College Streets Carlisle, PA 17013 Tax Assessor Parcel # 05-21-0320-079 EX lb002120V001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ACCU-TECH CORPORATION, Claimant, VS. No. 07-7503 DICKINSON COLLEGE TRUSTEES, Owner or Reputed Owner, Vs. WARD COMMUNICATIONS, INC., Contractor. PRAECIPE FOR SATISFACTION OF MECHANIC'S LIEN CLAIM At the request of the undersigned attorneys for the Claimant, you are directed to satisfy the above-captioned Mechanic's Lien Claim. Sworn to and before Fm4hi day of Urfa BoVK NoWy PW* Of Pftbuo% AAe"N coin 3niftsim Expkw Oct 2% 2011 BERNSTEIN LAW FIRM, P.C., By A orneys for Plaints Suite 2200 Gulf Tower Pittsburgh, PA 15219 (412) 456-8100 BERNSTEIN FILE NO: 00057291 lb00212OV001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ACCU-TECH CORPORATION, Claimant, Vs. DICKINSON COLLEGE TRUSTEES, Owner or Reputed Owner, VS. WARD COMMUNICATIONS, INC., Contractor. No. 07-7503 CERTIFICATE OF SERVICE I, Nicholas D. Krawec, Esquire, hereby certify that a true and correct copy of the foregoing Satisfaction of Mechanic's Lien Claim was served on the parties by regular U. S. Mail, postage prepaid, this T day of rl , 2008, addressed as follows: Dickinson College Trustees 272 West High Street Carlisle, PA 17013 Ward Communications, Inc. 6951-D Allentown Blvd. Harrisburg, PA 17112 c 1b002120V001 AA- C `' 90