HomeMy WebLinkAbout08-30360
SUPERIOR METALWORKS, INC.,
Claimant
V.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
MECHANIC'S LIEN CLAIM
GIUSEPPE BARONE and GOVANNI
BARONE,
Owners NO. Dg - 3p3 (? /n4J) -T9z..,?
MECHANIC'S LIEN CLAIM
AND NOW comes the Claimant, Superior Metalworks, Inc. ("Superior"), who, by
and through its attorneys, Elizabeth S. Beckley, Esquire, Thomas S. Beckley, Esquire,
and Beckley & Madden, of Counsel, files this Mechanic's Lien Claim, and in support
thereof, avers as follows:
1. Claimant, Superior Metalworks, Inc., is a corporation organized and existing
under the laws of the Commonwealth of Pennsylvania with a business address of 1416
Trindle Road, Carlisle, Pennsylvania 17013. Superior is filing this claim as a
subcontractor under the Mechanic's Lien Law of 1963. 49 P. S. § 1101 et seq.
2. The owners of the property subject to the lien are Giuseppe Barone and
Giovanni Barone, both of whom are adult individuals with a business address of 700
Valley Road, Enola, Pennsylvania 17025. Upon information and belief, Giuseppe
Barone and Giovanni Barone trade and do business as Brothers Pizza.
3. The date on which Superior completed the work for which this claim is being
made was November 14, 2007.
4. Superior served as a subcontractor to Anything Goes Construction &
Remodeling, LLC, the general contractor.
5. The amount claimed to be due is $6,380.00 and is for the following labor and
materials:
Materials: $4,135.00
Labor: $2,245.00
Total owed: $6,380.00
A true and correct copy of the written Proposal setting forth the work Superior performed
is incorporated herein, made a part hereof, and attached hereto as Exhibit A.
6. Superior served its formal notice of intent to file a mechanic's lien claim on
March 4, 2008. A true and correct copy of the notice is attached hereto as Exhibit B.
7. The improvement and property claimed to be subject to the lien is the real
property (including all improvements thereon) located at 700 Valley Road, Enola,
Pennsylvania 17025. A true and correct copy of the deed to the property subject to the
lien is incorporated herein, made a part hereof, and attached hereto as Exhibit C.
2
WHEREFORE, Claimant, Superior Metalworks, Inc., claims to have a lien upon
the premises herein described in the amount of $6,380.00, plus interest, costs of suit and
such other and further relief as the Court may deem appropriate.
DATED: May 13, 2008
Of Counsel
BECKLEY & MADDEN
212 North Third Street
Post Office Box 11998
Harrisburg, Pennsylvania 17108-1998
(717) 233-7691
Respectfully submitted,
f /I
lw? I ?IZ4?Aa
Elizabeth S. Bec ley, quire
i
Thomas S. Beckley, Esquire
Attorneys for Claimant
Superior Metalworks, Inc.
05/13/2008 08:13 7172450521 SUPERIOR METALWORKS PAGE 02/02
P. 'gno% jr., hereby verify tbW I am an adult individual, that I am the
I, Robert ? ent on behalf of
president of Superior Mctalwmt-% Inc., that I am au*mind to make this a??
, Inc., that I have road the foregoing dMIMent, and that the facts set forth m
$upenor Metaly, on and belief. I
the fig document are true to the best of my knowledge or informati
falso SW=enu hcaein are made subject to 'the penalties of 18 pa.C.S. § 4904
,Mdmtand that
relat mg to unsvv.ra fslsificauon to authorities.
gipgrior Metalworics, Inc.
rt P. t
Robe
By: 0S7*r
4
Cx 4, 6;fA
Design - FaFn+aminn . hart
I?17.?tiT$ M
u
NFPA #96
Attn: Dwayne Gilbert
Anything Goes Consowim
P.O. Box 61653
October 25, 2007
Job: Brothers pizza
?Iarrisbmg, PA 17106
Tob Location: Valley Rd. EEnola
Fabrioation and Installation of Commercial Kitchan Ventilat km to the following twifications:
> (1) NSF approved Stainless Steel Type I Kiot bond with filter rack, Stainless Steel baffle type
filbert, grease collectiae cup, (2) inewd?esoent N S.F. and U.L. approved vqw-prod ?tq aid
eompleat iott y dated Makeup, air plaium with aluminum, !trout dboha rp regioars, and
hoe for perforated Stainless Steel air delivery. Flood to be (10'-0" lg. X 4'-6" wd_ X 24" higb).
> (1) NSF approved Stainless Steel Type II Kndhe?n, hood with interior baffle W exhaust heat and
combustion gas $+om customer's Pizza Oven. Hood to be (6'-6" 1g. X 5'-6" wd. X 24" high).
> The exuding 22 gauge Stainless Steel wall pawls an rear and side hood walls shall remain as is.
> 22 gates Stainless Steel ceiling encloaurc ftm. tap ofhood(s) to ceiling.
> All asso4ated wdded galvanized areal and round galvanixod steel edaust duatwork?to extend i?
hood(s) dwougb roof.
> All. associated TC Firemaste?r zero clearance Chit insulation blanket where exhaust duct passes
through oombastibk roof mftces.
> All associated insulated, VN=imd steel mob-up air ductwork to extend om (2) fire damper
protected hood pe?a?iou*, through roof.
> (3) 16 gauge galvanized Roof Curbs.
> (J) i s" Roof mounted 11/2 13.P.,208 v., thrx phase, upblast style exhaust fan ® 4000 ? with
hinge lit and grow oath pan.
> (1) 13" Roof mounted 112 HY-408 v., tired phase, upblast style exhaust fan @ 1300 dm with hinge
kit and grease catch pan.
> (1)12" Roof mormmted 2 H.P., 208 V., three phase, Filtered Supply air ventilator producl?ag `1240 a&
Of uatempered oubtside air,
> A complete wet chemical ;fibre lion system will be installed for the protection of the hood plenum
area, exhaust ductwork (1) on £tyer, (1) 48" griddle, and (2) 2 comer gas ranges. A mechanical gas
shut-off val+?e and an electric micro awildt w?l be suppiicd wM the system. Any fees for tam by
tutboegW wN be as addidond Cost at S73?W4W.
1416 Trbtdk RA /Cam PA 17015 'Plitoase: (717) 245-2446 Haar: (717) 245-0521
loft
METALWORK3
-cvsroas INC.
n?T,uwi
--- cvsroM ?TAI.wolzx -
t?tgn i?rn» • !nslatdadnn
? P1\1 yyI y,
MUALWORKS
;1U MV E
METALWORK -
Aet gn - Fabrication . 1?nsra M jon
t?
su oR
- CUSTOM - All gas plumbing work including installation of the shut-off valve for the fire, suppression.
system, by others.
All *1,14cal wiring, "wild" and controls i=lvding &W co®uecdOW to all ventilators
pertaining to the hood system, by others.
- S.M.L 6211 fabricate, install and "V =ft seal (3) roof cur biockug (if neoesary)
dt &W flashing to customers rubber rootand all aadoft roof by
Far Wes?r>rvr
All ftralshed exhaust/sppply fans are guaranteed for one (1) year ftnna the date of pumbase.
PSft and labor. Pleame be aware that V-behe are; a wearable item depending on tho tompot=
range and length of owwon of the Pan(s). These belt are not cc ver,od ender weaanty by the iba
mangy or S.M.L
- No pemit or ingmdon fees m inch" these costs will be additional ifrequired.
- This proposal is boned upon our petsonnlel having contmom freedom Of 8COM to the working
area during the normal daydw hours. Ni e, weekend, and/or
has begun wM involve eztaa eoda. my otrs after want
- S.M.I. will provide accurate scale drawiirgw of the new system for submittal to authorities.
- This proposed Kitchen Vendledon system, stroll be MANn engineered aorling to the
customers' cooling aquipmaat, and shall be Fabrkated and Installed according to NSF, and
NY.PA. *96 regulations, latest edidons,
- In order to comply with. current LKC. Repladons, local audwriides may require dnt a
Tempered make-up air oak be instalied sd tW the tesuperatwo dim between the make-up
air and the air in the oonditioued space do; rat exceed 10 degrm F. This we hvohm additional
casts beyond 66 preposa! sl mM fills be ftqu red by Ieami 2seer ow
YPAW . ' l tin n"
093LIP, ? ?v4r
fi'md Of s ay: Rebut P. ?r#g?mey .i.,1?s.
.a ; lhie pagnset is to be kept caidxidentiel betwo?a and tti
m0eob e
are hereby nodbW that h say deeloeutes, wPySy, woe or *ft Uniateoded
thb doantapnt br ?bW' prp pad If ybtt t+oooived in error plan soy notice in rellowe ud nvFpe?pg the comb of
ah docoro of
dfittt?oLQl?eofr?G I UPC reed. and understand this a is ft W d 0manibed ell Wcd&gWM coadAwns, and tir f-w pay are ndshc ory and are busby aCCRY'tNCL You are ?tMq. * antlnotizod to do th k ??4
work es spacitied,
Payment wilt be Made as oofted by the trams indicated below.
Zlerarsr 50% dquask raga kvW wjj* order, Bad k dae Ap m
of work '
ter. ?-7_
?k?le7GR?A ?c?tlkaakrp?e?e?kM/+N4Q4?k??*+k?k4?uk+FM+MiR+Wk4+k#?b?k?k+kMa?k+kit:lRMeR?k1R?kJR?Ic?/Nle?k?lo-/??kt?k?k?eNlle+k+k4r+k+k+k+k+k+krlt?lt+Itatititaw?fi?s?K?k+lt+k#
1416 TihvAe Rd lCer&k PA 17015 Phone (717) 245-2446 Fay (717) 215-0521
Page 2 of 2
?x ?' ?'t ?
BECRIXY& MADDEN
ATTORNEYS AT LAW
CRANBERRY COIIRT
212 NORTB Tin STREET
POST OFFICE BOX 11986
HARRTQBURG. RrNN8Y1,VAN7A 171OS'1998
PHONE: (717) M-7681
r.A (717) 2a3-3740
E-MAIIe beddey@p&iwt FII,E NO.
311410
March 4, 2008
Giuseppe Barone VIA FIRST CLASS AND CERTIFIED MAIL
Giovanni Barone
700 Valley Street
Enola, PA 17025
RE: 700 Valley Street, Enola, Pennsylvania
Gentlemen:
This office represents Superior Metalworks, Inc. ("Superior"). Superior served as
a subcontractor to Anything Goes Construction & Remodeling, LLC. Superior fabricated
and installed a commercial kitchen ventilation system at the above-referenced property.
We have enclosed a copy of the subcontract for your reference. Superior completed its
work on November 14, 2007.
At this point, Superior is owed the principal amount of $6,380.00 for its work on
the project. This letter constitutes Superior's formal notice of its intent to file a
mechanic's lien claim on the above-referenced property. Please let this matter have your
immediate attention.
Very truly yours,
BECKLEY & MADDEN
Thomas S. Beckley
Cc: Superior Metalworks, Inc.
Anything Goes Construction & Renovation, LLC (w/encl.)
Brothers Pizza (w/encl.)
SUpe"M
METALWORK8
INC.
;WqHE
USTOM METALWORK --
Design - Fabriaadon * I umaadon
0 riufxusttl
CSC
NFPA #99
Attn: Dwayne Gilbert
Anything Goes Cotufuotion
P.O. Box 61653
October 25, 2007
Job: Brothers Pizza
Harrisburg, PA 17106 Tob Location: Valley Rd. Enola
?IC.+lelh?IcMt1k?R?k+k7k+l??ek?lii#?#M??kae?k#*?k???ka?ttk7tal:.?t?ItNCIMdklk k+Iclk+ki?k+K?:+F.?t?+gtk•?II+ISiti:it?IC7t?tat+It+kltMt+R+k?k+RdNlnk#+k?bk'k+M#?k#'k*'k?k?ei./r?Ai?ikM+kMat?JMk
Fabdoadon and Installation of Commercial Kiteben Ventilation to the fo g specifications:
> (1) NSF approved Stainless Steel Type I Kitchen, bood with finer rack, Stsinlew Steel bale type
filtusr% grease collectiem cup, (2) inewdescent:N.S.F. and UZ.. approved vaW-p roof lights 'and
complete internally k hftd Make-up afr pkicmn, with ahaaimmt front discharge registers, and
iaterior per Forated Stainless Steel air deNvery. Hood to be (101-0" ]g. X 4'-6" wd_ X 24" high),
> (1) NSF approved Stainless Steel Type 11 Kitchen bood with interior baffle to exhaust heat and
combustion gas Iii nm ms's Pisa Oven. Hood to be (61-6" lg. X 5'-6" wd. X 24" high).
> The existmg:22 gauge Staialess Steal wail gels an rear and side hood wal}s shall remain as is.
> 22 gauge Stainless Steel ceiling enclovift frier. top of hood(s) to ca&g.
> All associated welded galvanized steal and round galvanized gad whaust ductwork-to extend from
hood(a) dwOU b rood
> All, associated TC Firemaste r zero char cc cezamir kadat ion blanket where exhaust dud passes
through combustible roof suuftes.
> All anookied insulated, galvanized steel make-up air *wtwoik to end Arom (2) fire damper
protected hood pft tr*Waa, tbraugh roof
> (3) 16 gauge galvanized Roof Curbs.
> (3) 18" Roof marmted 1 V2 H.P.,208 v., three phase, upblast awle exhaust fan ® 4400 oft with
hinge kit and grease catch pan.
> (1) 13" Roof mounted 1/2 HY-,208 v., three *tse, upblast style exhaust fan @ 1300 chn with hinge
kit and grease catch pan.
> (1)12" Roof mounted 2 H.P., 208 v., throe pbase, Filtered Supply air ventilaft prodoWng 4240 ohm
of untempe ed outride
> A complete wet che>mieal fire sumession system will be installed for the protection of the hood plenum
area, exhaust dwtwc'k, (1) gas fryer, (1) 48" griddle, and (2) 2-burner gas ragW. A mechanical gar
shut-aff valve and as electric mica+o switch will be supplied wit dw system. Any hes for Ueft by
and oMW wNl be = addidead cost at $7&ft4 ter.
rk?M#+IeM'??k#+k+??Nl7kk7kit?kir7leacikllk?t?l0k?k.?'iM?ltil7kX'?'?n?e?tat?Nkal?R?k?N?k?t.MUk?FJk-'krk7k?INk+R?k+IC.R+kk+Mk?k+k?kfi.+1d1:+Mk.R+1:+ItAi?R+kitfi.+k?.'+R?IsL'+k+R+k?kNwk?k?kk'#t'
1416 Trbedle Rdt I Cwftk, PA 17015 '.Phase: (717) 245-2446 Fauw (717) 245-0521
age 1 of 2
SUPWOR
MV ALWORKS
EINC.
Design - Fabrication • &Trallatton
-
CrtJSTOM METALWORK -
All !lam Plumbing work including installation of the shut-off valve for the fire suppression.
system, by others.
- All electrical wiring, swfches sad caatrola iucludi S final OOtONCUOns tD all V01M) NS
perlaiub g to the hood system, by others.
- W- shall Mkicate' install acrd kmpwm* seal (3) roof eut%. Wood blocking (if necessary)
fleshm to customers rubber roof sad all exisftg roof warranties, by otim.
Pear Werrnmrrvr
All famished exhast/supply fans are guaranteed for one (1) year from the date of pucobaw.
Parts and labor. Please be aware that V-belts are a wearable item depending on the tempentm
rmp and length of operation of the fan(s). These belie are not covered tinder mimm-tv by the fan
manuf cow or S.M.I.
- No Permit or inspection fees are include these costs will be addkkmd if required.
- This proposal is based upon our 1 having continuous 6=dom of acoess to the working
am during the normal daytitoo hours. N weekend, and/or any m rgdons after work
has bean wM involve rears cosh.
- S.Iv L will provide accurate scale drawitsgs ofthe new system for submittal to andwi ies.
- This proposed Kitchen 1VeatlWou sy shall be CtlAM engineered accw&g to the
customem cooking equOmeM and s1taII be Fabricated and I wwied aooorft to NSF, and
N.F.P.A. #96 reguludoow, latest editions.
- In order to comply wilt curxmt Ll1it,C. Reguldions, local sathwWw MW r+quim dw a
Tempered make-up air unfit be installed sa that the tempom ne dill belweeat the make-up
air aad the sir in the condidoned Vace donut emceed 10 degrm F_ Thk wn involve additiond
corm beyeod tr>bfs Preposd st weld thb be nquiired by local awftriges,
Your
WAA IN 61CPL?P, "00;
Sarb?doaeday: Rote. ?i,aou, jr,1
Cadd ? ,,- Thin taoponi k to be kept =icdY Mode" bdwaca SM and erePa:=mod. Uwatwed
rook finis are hweby nodbed that aw dbotosurca, aWyb>&ae or ta»g my u im in ral3am
thb doe w"
fifnemaAW4 in *kdy FaMbdeed, Zyott nooeavod tbb dowamw in error phone w* an mane y mprftg the content of
I brave rued ad uaduiftd this Propoaat in its emot m v. The 8as11 4 boas, cw pdonre,
mom, and terms ? Pry are aatMototy nod as tasty accepted. You are agbodzod to do dw work as specdki&
Payment win be amts as ondioe d by ft', macded briaw.
T kfmw 50% deposd „etm,rd wA* or, B&Unw is dtae mpw ' of work .
Dare ofx:
+ic,?tssttet+c+ieM?.+kut+?r?eM?KMW'e+h?waM?+k4?+k+kNM?4###?NcM?w?M+k#+k*+/,+MMak+k?k+rr?vwk+?c?ksJr.?r+kiNRi?Nw+lNI:iW:?1:?tN?#+k+k+R+t+k+ItMe+k+L?ltaed?at:?ft?a?er. fixs+?et
1416 TnWd drRd /C,snlLtk PA 17015 ^o a= (717) 245-2446 Face (717) 245-0521
Pap 2off2
BECKLEY& MADDEN
ATTORNEYS AT Law
CRANBERRY COURT
212 NORTH THnm sTRi=T
POST OFFICE BOB 11888
HARRISBURG, PENNSYLVANIA 17108-1998
PHONE: (717) 833-7881
FAX: (717) 833-3740
FIL NO.
E
EMAIL: Cy@pS.11P1
311410
March 4, 2008
Brothers Pizza VIA FIRST CLASS AND CERTIFIED MAIL
700 Valley Street
Enola, PA 17025
RE: 700 Valley Street, Enola, Pennsylvania
Gentlemen:
This office represents Superior Metalworks, Inc. ("Superior"). Superior served as
a subcontractor to Anything Goes Construction & Remodeling, LLC. Superior fabricated
and installed a commercial kitchen ventilation system at the above-referenced property.
We have enclosed a copy of the subcontract for your reference. Superior completed its
work on November 14, 2007.
At this point, Superior is owed the principal amount of $6,380.00 for its work on
the project. This letter constitutes Superior's formal notice of its intent to file a
mechanic's lien claim on the above-referenced property. Please let this matter have your
immediate attention.
Very truly yours,
BECKLEY & MADDEN
cam''
Cc: Superior Metalworks, Inc. Thomas S. Beckley
Anything Goes Construction & Renovation, LLC (w/encl.)
Giuseppe Barone (w/encl.)
Giovanni Barone (w/encl.)
SNPSRIOR
MEfALWORKS
INC.
CUSTOM METALWORK --
Assign - Fahricar n,j
• !nslallatirn?
j 0 r
NSF
NFPA #96
°k?k+k*+le?k?k?R?Ir?MiW???lt?lr#Nk Ynk?INl:?k?k#+k#iE?k?e?e#yel?+lk?4?!?#al?k-k!t?lUk?+k?lc?k?l:?k#?k#+ka:Xc?tvk#: aHk#+bR#?1l?k+k+l'+K+It?IaR?Riat#4c?k?bk##+k##!krk?lrtat#+k###A?e#4
Attu: Dwayne Crilbert
Anything Goes Con&4ruadon
F.O. Box 61653
October 25, 2007
Job: Brothers Pizza
Harrisbw& PA 17106 Tob Locadon: Valley Rd. Enola
?c?rscs;?Ic?k+R#?k#ek?kk?k?*?r?#?k?k??k?k?k??a?xx?dc+R+rxa#+??*+r?:?=?k+r?+x+kM?raacaeae+ta?ae###*+k##+?+wk+k*rt?k?+k??e?r*??k?k«?F?h M?k???s..+wx
Fabtioadcm and Installation of Commercial Kitchen ventilmtioa to the following specifications:
> (1) NSF approved Stainless Steel Type I Kitobm. hood with filta rack, Stainless Steel bale type
filters, grease collOW00 cup, (2) inamdesoeut, N.S.F. and U.L. approved vapor-pW lights and
eorrrplete iDWMaHY Insulated Make-up air pleeum with aluminum 5ront disclwrge rVOws, and
interior P Stainless Steel air delivery. Hood to be (10'-0" lg. X 4'-6^ wd_ K 24" high).
> (1) NSF approved Stainless Steel Type B Kbd m bond with interior bale to exhaust heat and
combustion an fh m eustoma's Pizza Oven. Hood to be (6'-6" 1g. X 5'-16" wd. X 24" high).
> TWe existing 22 8 Stainless Steel wall panels on mar and side hood walls shall remain as is.
> 22 gauge Stainless Steel ceiling enclosm £row. top of bood(s) to ceiling.
> All associated welded Salvanimil steel and round galvanized steel exhaust ductwork'to extend from
hood(s) ftvagb roof.
> All. associated TC Fitamaster zero clearance clmamic insulation bhnkd where exhaust duct passes
through coembud ble roof sur&ces.
> All associated kadated, galvanized steel male-up air &xtwork to wand from (2) fire damper
protected hood pe c us, through roof.
> (3) 16 gauge galvanized Roof Coft.
> (1)1,8" Roof momited 11/2 H.P.,208 v, three phase, upblast style exhauat fan @ 4000 dkn with
hinge kit and grease catch pmm.
> (1) 13" Roof mounted la H.P.,208 v., three phase, upblast style exhaust fan @ 1300 cfrn with hinge
kit and grease catch pan.
> (1)12" Roof mounted 2 H.P, 208 v., three passe, Filtered Sulrply air ventlla a producing 4240 of t
of untempm,ed outside
> A complete wet chemical fin's s ession system will be installed for the protection of the hood plenum
area, exhaust dauetwork, (1) gas firy'er, (1) 48^ griddle, sad (2) 2-burner gas ranges. A mechanical gas
abut-off valve and an electric micro switch will be supplied whin ihe aymem. Any fees upft by
autheri" WM be as additioael cost at S708/ ,
1416 Trkdle Rd t Cafitvk PA 17013 'Phm e: (717) 245-1446 Fins: (717) 245-0521
Pawn I
e 1 of 2
? r'.4.? VVf V.7
SUPWOR
AL-`WORKS
CUSTOM METALWORK -
Design - Fabrnicadon - Insrallat£on
INC
-
- AR ass Plumbing work including installation of the shut-off valve for the Sre suppression.
system, by others.
- All electrical wiring, switches and controls includwg &al COUD%dO95 to all ventihom
Wtaiwuog to the hood system, by others.
- S.M.I. shall Mxicabe, install and tmporw* seal (3) roof curbs. Brood blocking (if necessary)
do flint Sashiag to c ustomus rubber roof and all exioft roof warranties, by others.
Fur iPRaxrvr
All famished exhaust/supply fans are guaranteed for one (1) year fi-am tho date of purchase.
Parts and labor. Please be aware that V brjta am a wearable item depending on 6* tempmatm
range and length of operation of the fan(s). These belts are not covered under war?riv by the fan
manufacturer or S.MI
- No pert * or inspection fees are included these costs will be additional if required.
- This proposal is based Upon ew PftV0W1 loving continuan freedoz at of acoess to the working
aria daring the normal daytime hours, , weekend, and/or arty m0eiraptfrons after work
has begin wfM mvohre eras' costa.
- S.M.I, will provide accurate scale dmwibp of tbo inch systom for submittal to autliodties.
- This proposed KiEcben Ventri'oo. sy0em " be custom engiueamd ammftg to the
customers' cooldng equtpnrent, and shell be Fabricated and Installed according to NSF, and
N.F-PA. #% regulatioaas, latest editions.
- In order to comply with. cameo I.M.C. Regalations, local aadiodda may require &U a
Tempered make-up air unit be installed so that the dim between the make-up
air acrd the air in the oondidoned spiv do:not exceed to degrees F. TW Wn iavoitre adaimai
costs beyond thb proposal sbaidd rites be Pequ ed by local mdho>rfges.
Your
1 8A.00
dVLYP, / ? 01640jr
SarBrt beep Robert P..?r SP19 /, Jr., Plres
radiffidift
Thin Pr opoaat is to be loept strictly e ' botwbea Sh9 and the
reapimb are hereyby notified that sey di iamuck capyhog, d on or'W ft my w ft UTtintraded
d* &MOE* ba ettldtlY PR+pl?dIA If you facer ul this doomneat m error please satin. sW el $ the coinfts or
I have rand ad andarstmd this Pmpwd m ft ewhvV. Mw dem*cd ap 0M exeeptims,
and teens ft Pay = 99Wbetory and = hereby accepted. You are Mfflw nd to do the work as MecitIG&
ftineet wM be smile as omhined by the tams mdicatcd below. TWM.- Shit d9mew r negsmrd wftb per, Ba kfice k dm e jWM a of wmrk ;
Data ofr._?I r ??
1416 Tf *l&e JU f C'srfk/4 PA I701S Pncr (717) 245-2"6 Fac (7) 7),245-0521
Page 2 of 2
?. i ? %`? ?
?x
L ^?
t O
DEED
THIS DEED is made the Al da of August 2005
y ZOQS ,c.EP 8 PM 3 21
BETWEEN
CRL HOLDINGS, L.P.,,wPennsylvania limited partnership ("Grantor"),
AND
GIUSEPPE BARONE and GIOVANNI BARONE, adult individuals (collectively,
"Grantee"):
WITNESETH
That the Grantor in consideration of One Hundred Eighty-Five Thousand Dollars
($185,000) paid by the Grantee to the Grantor, the receipt whereof is hereby
acknowledged, does hereby grant and convey unto the Grantee:
Tract Number 1:
ALL THAT CERTAIN tract or parcel of land, situate in East Pennsboro
Township, Cumberland County, Pennsylvania, more particularly bounded
and described according to a survey of D.P. RaffensI - ger Associates,
Registered Surveyors, dated April 19, 1973, as follows:
BEGINNING at a point at the southwest comer of Valley street (Legislative
Route,21051) (50 foot right-of-way) and "B" Street (erroneously identfied
as "D" Street in a prior deed) (50 foot right-of-way); thence along the
Western line of "B" Street (erroneously identified as "D" Street in a prior
deed) the following courses and distances; South 13° 01' East, 15.77 feet;
a curve to the right having a radius of 245 feet, an arc distance of 93.13
feet, South Mr 45' 43" West, 93.65 feet to a point in line of other lands
now or fonrmiy of Dale J. Hildebrandt; thence North 03° 00' West along
said Hildebrandt lands, 105.12 feet to a point; thence North 05° 48' West
along the eastern line of other lands now or formerly of Date J.
Hildebrandt, 175.38 feet to a point in the southern line of Valley Street
aforesaid, thence North 84° 12 East along said line of Valley Street, 130
feet to a point in the western line of "B" Street (erroneously identified as
"D" Street in a prior deed), the place of BEGINNING.
BOOK 270 PAC14399
Tract Number 2:
The above-described Tract Number 1 is also shown on the site plan dated
September 15, 1993, attached as Exhibit "A" hereto (the "Plan").
BEING the same premises which CRL Holdings, L.P., a Pennsylvania limited
partnership, by Corrective Deed dated July 30, 2003 and recorded in Cumberland
County Deed Book 258, page 3551, granted and conveyed unto CRL Holdings, L. P.,
Grantor herein.
UNDER AND SUBJECT, nevertheless, to all other easements, restrictions,
encxrmbranoes and other matters of record or that a physical inspection or survey of the
premises would reveal.
Attached as Exhibit "B" hereto and made an integral part hereof is a certain
notice pursuant to the Pennsylvania Solid Waste Management Act and the Land
Recycling and Environmental Remediation Standards Ad (the "Notice"). All future
deeds must contain the Notice unless written approval to remove the Notice is obtained
from the Pennsylvania Department of Environmental Protection and evidence of such
approval is placed of record with the Cumberland County Recorder of Deeds.
Grantor hereby covenants and agrees that Grantor will warrant SPECIALLY the
property hereby conveyed described as Tract Number 1 above.
To the extent that Tract Number 2 described in accordance with the Plan
includes any additional land not included in the property described as Tract Number 1
above (the 'Additional Property"), Grantor hereby covenants and agrees that Grantor
does hereby release, remise and fbrww quNdalm to the Grantee all of Grantor's
right, title and interest in and to the Additional Property.
IN WITNESS WHEREOF, the Grantor has caused this Deed to be duly executed
as of the day and year first written above.
WITNESS:
-day
CRL Holdings, L.P.
By its General Partner CRL GP, LLC:
By e
John Byler, Co-Chain
ND
By
Patrick J. C gna, Co-Cha' an
2 BOOK 270 PACE4400
COMMONWEALTH OF PENNSYLVANIA
L? Cogs ?? SS:
COUNTY OF
On this, the day of , 2005, before me, a Notary Public, the
undersigned officer, personally appeared John E. Byler who acknowledged himself to
be the Co-Chairman of CRL GP, LLC, which is the general partner of CRL Holdings,
L.P., a Pennsylvania limited partnership, and that he as such Co-Chairman, being
authorized to do so, executed the foregoing instrument for the purpose therein
contained by signing the name of the limited partnership by himself as such Co-
Chairman.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
Notary Public
My Commission Expires:
NOTARIAL SEAL EAL)
JotNYe L Lauver, Notary Public
Mold wk. Twp., County of L.errcaster
My Commission Expires Apol B, 2007
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tr BOOK 270 PACE4401
x_n c> :j, in u ca c_r r..n rW ? ."--- •.:,. ,,,n KJt
c?
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF Low1(-ash
SS:
On this, the Q +tday of 2005, before me, a Notary Public, the
undersigned officer, personally appeared Patrick J. Castagna who adawmedged
himself to be the Co-Chairman of CRL GP, LLC, which is the general partner of CRL
Holdings, L.P., a Pennsylvania limited partnership, and that he as such Co-Chairman,
being authorized to do so, executed the foregoing instrument for the purpose therein
contained by signing the name of the limited partnership by himself as such Co-
Chairman.
IN WITNESS WHEREOF, I have hereunto set my hand and official sea.
ZX-R-_
Notary Public
My Commission Expires:
NOTARIAL SEAL
Jw" L Lauver, Naouy Public
Mwtwim TwP., County Of t ancader
My Commission Expires AprN 8, 2007
(SEAL)
4
GOOK 270 PACE4402
CERTIFICATION OF ADDRESS
I hereby certify that the precise residence of the Grantee(s) in the within Deed is:
700 VMry Road
E la_ PA 17011
0
Agent fior Grantee Q?)
Recorder of Deeds
BOO 270 PACE4403
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SHERIFF'S RETURN - REGULAR D
Y . a
CASE NO: 2008-03036 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SUPERIOR METALWORKS INC
VS
BARONE GIUSEPPE ET AL
MARK CONKLIN
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within MECHANICS LIEN CLAIM
was served upon
BARONE GIOVANNI
the
OWNER at 1100:00 HOURS, on the 17th day of may 2008
at 700 VALLEY RD
ENOLA, PA 17025
by handing to
GIUSEPPE BARONE, FATHER
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 6.00
Service .00
Affidavit 2.50
Surcharge 10.00
.00
3 8? ? 18.50
So Answers:
r-
R. Thomas Kline
05/19/2008
BECKLEY & MADDEN ,
Sworn and Subscibed to
b
By: gepu
efore me this day y Sheriff
of
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-03036 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SUPERIOR METALWORKS INC
VS
BARONE GIUSEPPE ET AL
MARK CONKLIN , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within MECHANICS LIEN CLAIM was served upon
BARONE GIUSEPPE the
OWNER , at 1100:00 HOURS, on the 17th day of May , 2008
at 700 VALLEY RD
ENOLA, PA 17025
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 18.00
Service 15.00
Affidavit 2.50
Surcharge 10.00
5/?X2/Of ?;. 00
45.50
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
05/19/2008
BECKLEY & MADDEN
By.
D putt' Sheriff
A. D.
SUPERIOR METALWORKS, INC.,
Claimant
V.
GIUSEPPE BARONE and GIOVANNI
BARONE,
Owners
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
: MECHANIC'S LIEN CLAIM
NO. 08-3036-MLD
AFFIDAVIT OF SERVICE OF NOTICE
I, Mock Cankl-tn , being duly sworn according to law, depose and say as
follows:
1. I am an adult individual employed by the Cumberland County Sheriff's Office,
Carlisle, Pennsylvania, as a Deputy Sheriff,
2. On May 11 , 2008, I served a Notice of Mechanic's Claim upon Giuseppe
Barone, in the following manner: hanA zA }, G luf,%N- e. -3,, e,
at the following address: 700 Valley Road, Enola, Pennsylvania 1?05
Sworn to and subscribed before
me this y
da of
May, 2008
NOTARIAL SEAL
CLAUDIA A. BREWBAKER, NOTARY PUBUC
Carlisle Boro. Cumberland County
My Commission Expires April 4, 2009
C
p
=
w 'sr
73•
.. 3
.? G?3 .':r
t.
SUPERIOR METALWORKS, INC.,
Claimant
V.
GIUSEPPE BARONE and GIOVANNI
BARONE,
Owners
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
: MECHANIC'S LIEN CLAIM
: NO. 08-3036-MLD
AFFIDAVIT OF SERVICE OF NOTICE
I, mark Con kl. n , being duly sworn according to law, depose and say as
follows:
1. I am an adult individual employed by the Cumberland County Sheriff's Office,
Carlisle, Pennsylvania, as a Deputy Sheriff,
2. On May I 1 , 2008, I served a Notice of Mechanic's Claim upon Giovanni
Barone, in the following manner: hanAeA -o Gnus ax-one. ad?? ac
at the following address: 700 Valley Road, Enola, Pennsylvania 1702
Sworn to and subscribed before
me this I -I- day of
May, 2008
NOTARIA1_ SEAL
CLAUDIA A. BREWBAKER, NOTARY PUBLIC
Carlisle Boro. Cumberland County
My Commission Expires April 4, 2009
C,
xV rte:
co _
r r'
r "-
0
V
SUPERIOR METALWORKS, INC.,
Plaintiff
V.
GIUSEPPE BARONE and GIOVANNI
BARONE,
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
MECHANIC'S LIEN CLAIM
NO. 08-3036-MLD
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 this
Complaint and Notice are served, by entering a written appearance personally or by
attorney and 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 Complaint or any other claim for relief requested by the
Plaintiff. You may lose money or property or other right 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.
IF YOU DO NOT HAVE A LAWYER CONTACT:
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17103
Telephone Number (717) 249-3166
SUPERIOR METALWORKS, INC.,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
V.
GIUSEPPE BARONE and GIOVANNI
BARONE,
MECHANIC'S LIEN CLAIM
Defendants : NO. 08-3036-MLD
COMPLAINT UPON MECHANIC'S LIEN CLAIM
AND NOW comes the Plaintiff, Superior Metalworks, Inc. ("Superior"), which,
by and through its attorneys, Elizabeth S. Beckley, Esquire, Thomas S. Beckley, Esquire,
and Beckley & Madden, of Counsel, files this Complaint Upon Mechanic's Lien Claim,
and in support thereof, avers as follows:
1. Plaintiff, Superior Metalworks, Inc., is a corporation organized and existing
under the laws of the Commonwealth of Pennsylvania with a business address of 1416
Trindle Road, Carlisle, Pennsylvania 17013.
2. The Defendants are Giuseppe Barone and Giovanni Barone, both adult
individuals who have a business address of 700 Valley Road, Enola, Pennsylvania 17025.
3. Superior served as a subcontractor to Anything Goes Construction &
Remodeling, LLC, the general contractor.
4. Superior filed a mechanic's lien claim in the Court of Common Pleas of
Cumberland County, Pennsylvania as of 2008 Term, Number 3036 MLD, a true and
correct copy of which lien is incorporated herein, made a part hereof, and attached hereto
as Exhibit A.
WHEREFORE, Plaintiff, Superior Metalworks, Inc., respectfully requests the
Court to enter a judgment in its favor, and against the Defendants, Giuseppe Barone and
Giovanni Barone, in the principal amount of $6,380.00, plus interest, fees, costs of suit
and such other and further relief as the Court may deem appropriate.
DATED: August 27, 2008 Respectfully submitted,
Of Counsel
BECKLEY & MADDEN _ ?' 1
212 North Third Street Elizabeth S. Beckley, squire
Post Office Box 11998
Harrisburg, Pennsylvania 17108-1998
(717) 233-7691 --"''
homas S. Beckley, Esquire
Attorneys for Plaintiff
Superior Metalworks, Inc.
2
08/27/2008 11:22 7172450521 SUPERIOR METALWORKS PAGE 02/02
VF.R1FiCA?.Q?
I, Robert P. Sgrignoli, hereby verify that I am an adult individW; then I am the Presldent
of Superior Metalworks, Inc.; that I am authorized to make this statement an behalf of Supcrior
Metalworks, Inc.; that I have reed the foregoing docmned? and that ft facts set forth in the
forcgoing document are true to the beg of my knowledge, informWan and belief I understand
tbt f rise stets herein are made subject to the penalties of 18 Pa-C.S. $ 4904 relating to
unswom falsification to andwritim
superior
BY.
309EPCW
SUPERIOR METALWORKS, INC.,
Claimant
V.
GIUSEPPE BARONE and GOVANNI
BARONE,
Owners
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
MECHANIC'S LIEN CLAIM cp
NO.6e - 3o3? ImZ
`°
z
a
W
n-?
0
i
`I
din
MECHANIC'S LIEN CLAIM
AND NOW comes the Claimant, Superior Metalworks, Inc. ("Superior"), who, by
and through its attorneys, Elizabeth S. Beckley, Esquire, Thomas S. Beckley, Esquire,
and Beckley & Madden, of Counsel, files this Mechanic's Lien Claim, and in support
thereof, avers as follows:
1. Claimant, Superior Metalworks, Inc., is a corporation organized and existing
under the laws of the Commonwealth of Pennsylvania with a business address of 1416
Trindle Road, Carlisle, Pennsylvania 17013. Superior is filing this claim as a
subcontractor under the Mechanic's Lien Law of 1963. 49 P. S. § 1101 et seq.
2. The owners of the property subject to the lien are Giuseppe Barone and
Giovanni Barone, both of whom are adult individuals with a business address of 700
Valley Road, Enola, Pennsylvania 17025. Upon information and belief, Giuseppe
Barone and Giovanni Barone trade and do business as Brothers Pizza.
3. The date on which Superior completed the work for which this claim is being
made was November 14, 2007.
4. Superior served as a subcontractor to Anything Goes Construction &
Remodeling, LLC, the general contractor.
5. The amount claimed to be due is $6,380.00 and is for the following labor and
materials:
Materials: $4,135.00
Labor: $2,245.00
Total owed: $6,380.00
A true and correct copy of the written Proposal setting forth the work Superior performed
is incorporated herein, made a part hereof, and attached hereto as Exhibit A.
6. Superior served its formal notice of intent to file a mechanic's lien claim on
March 4, 2008. A true and correct copy of the notice is attached hereto as Exhibit B.
7. The improvement and property claimed to be subject to the lien is the real
property (including all improvements thereon) located at 700 Valley Road, Enola,
Pennsylvania 17025. A true and correct copy of the deed to the property subject to the
lien is incorporated herein, made a part hereof, and attached hereto as Exhibit C.
2
WHEREFORE, Claimant, Superior Metalworks, Inc., claims to have a lien upon
the premises herein described in the amount of $6,380.00, plus interest, costs of suit and
such other and further relief as the Court may deem appropriate.
DATED: May 13, 2008
Of Counsel
BECKLEY & MADDEN
212 North Third Street
Post Office Box 11998
Harrisburg, Pennsylvania 17108-1998
(717) 233-7691
Respectfully submitted,
Elizabeth S. Bec cley, quire
Thomas S. Beckley, Esquire
Attorneys for Claimant
Superior Metalworks, Inc.
05/13/2088 88;13
7172450521
S'PERIOR METALWOWS
PAGE 82/0.-
I, Robert P. Sgrlgnoli, Jr., hereby verify that I am an a"t individual, that I am the
President of SuNdor Mctalwoft Inc., tbat I am audxwixed t0 make this staftmast on bealf of
Superior Metulwork% Inc., that I have road the foregoing document, and that the faM set fDrth in
the foregoing document arc true to the best of my knowledge or upon sod belief. I
umda*W dW files statemeats herein are made subject to the penslties of 19 MC.S. § 4904
relating to unworn fwAfic a6m to au*,orlties.
Superior Metalwoft Inc.
B'y" ,-
Robert P. S ' r., tat
4
EXHIBIT A
SUPOWR
METALWORKS
;WO(WENC.
CUSTOM METALWORK -
Design - Fabricad,* • &Valladm,
NFPA
ak•?R+k+k+k+Nra4{.??ac?e?lc?lc-w?kMr#?k+klc?k?;#?bt+lexr?rfk?t?e#?:?4 ?k?t?ae.*?c:cat?kd; ?k?It?k?tx+?kat+Mgcaey.?rx•Iez?c+R?{e+wxatassta?k?k+kt###+krt?k?k+?k#kkA?l:.}i+kt
Alta Dwayne Gilbert
Anything Goes ConWucgon
P.O. Boat 61653
October 25, 2007
Job: Srothera Pir2ra
Harrisbmg, PA 17106 Job Location: Valley Rd. Book
?k+R?kakMe?k+k+le+k+?###ok####k?le#ae?l'qe*?#?kakalWkxalt?eRNrkkk+R+RAC+k+?k+kk#?k#4e?reiR?t?l:a: atiuit?ae?k#k#+k##?l+k#+k+kA?k#+1?##+k+R#?+++k+ha??l:?hiE?k?ukNaM:+41t
Fabnostion and kwuHadon of Commwisd Kit cbm Venwat m to the fallowing speaificatc es.
> (1) NSF approved Stainless Steel Type I Slur hood with fikw rack, Stainless Steel baffle type
filtem grease collec6cm cup, (2) incandescent., N.S.F. avd U.L. approved vapor.proalights =d
complete WftrftIIY insulated Makv-tw skr plenma with doaimm fi+ont dte chwp mister, and
bdedorperfix livery. Hood m be (IO -0 ]g. X 4 -6" wd_ 3X 24 hrgb).
> (1) NSF approved Standen Steel Type D KiO*m bood with interior be le m exhaust heat and
combusdon gas $om custom es Pizza Oven. Hood to be (61-6" 1g. X 5'-S°' wd. X 24" hi h).
> The wdsdng 22 saw SbWm Steel wall panels on Leer and side hood walls sball remain aS is.
> 222 gage Stainless Steel ceiling enclosure frm tap ofhocd(s) to ceiling.
> All assomated welded galvanized steel and round galvanised steel eacbaua ductwork-to extsnd'ftm
•hood(s) through roof
> ,coil. associated TC Firemaster aero clearance c.wamic insulation blanket where exhaust duct passes
tbuough combusOle motmt *css.
> All assodaEed insulated, galvanized steel mibe-up or ductwork to atend fiam (2) fire damper
protected hood pe vov, t>irough roof
> (3) 16 gauss gahwAlud Roof Croats.
> (1) Is- Roof mounted 11/2 H.P,209 v, lbws phase, upblan style aWwat fan ® 4000 cfin with
hinge bit and gum catch Pin.
Y (1) 13" Roof mounted 112 H.P.,208 v., three p6se, upblast style exhaust fan @ 1300 cfia with Mugs
kit and grease catch psa.
> (1) 12" Roof mounted 2 !LP., 208 v., tbree pb wo, Filtered Supply nit ventildw producing 4240 aft
of uctempwad outside W.
> A complete wet chavied Bre session nvkm will be installed for the pr+oteatim of the hood plenum
area, =ham duetw?olk (1) gas Beyer, (1) 48" griddle, and (2) 2-bmnw is ranges. A mecluaaical ps
shut.oo$vs&m and an electric micro mneh will be snppliod with the ayatem. Any ins for uwft by
aurtDo m s WO be as skull ad coat at S75tft r,
M?t4+kM?rk iek#?e+te?kJpk?e?le+k7lek?le7t#arak?le#tt?'?It*?t#?e?e?ta!gei2?lr?ept?t?R?h?kgtXc•+k?k?k.'k#7t+k+k+Itt+IF+kkrfC#?k+R?kAI'+R+k2kMnk+R+1:+?tQGR*ffi-f1e+k?R?R+k+R+k*ie2RkN?1e?K+k
1416 Tibtdle Rd /Carte PA 17015 •, hme (717 245-fib Pax~ (717) 245-05,21
.0 1 of 2
1
S
MRALWORKS
ANC.
- CUSTOM METALWORK -
Design - fobncativn - bssmUarfnn
- AQ Sse plumbing work including inMallat9.on of the shut-off valve for the fire suppressiott
aystema, by odws.
- All electrical wiring, "itches and canlrols molucing ftd coamections to all VICUdI NS
pertaining to the hood system, by others.
- S.M.L shall fsbt'icaie, install and texrapct N* seal (3) roof Cuft. Wood blocid no (if neonsmy)
& finial flssbing to customers nsbber roof and all wdedug roof warranties, by others.
FM lWMrraaes!t±;
All flrnutshed exbaust/mVply fans are gnaiauteed for one (1) year horn the date of purebase-
Ptu"bs and bbor. Please be aware tbst V-Moire are a weatsble item depending as"te mpeam
rop and length of operation of the fern(s). These belts are no covered motor vraaaeM? by the fm
mtntu or S.M.I.
- No permit or inspection flees are includell tbese com will be additional if requited.
- This proposal is based upon oar i 1 having continuous ft eedomn of acooee to the wmidng
area during the normal daytiuhe bouts. weekend, and/or any ueeerruptions after work
has began wAl involve er I ewes.
- SJN L L wM pwvWe socmaw scale dtswitts of tbio new system for submittal to authorities.
- This proposed Kitcben Ventilatiaa s sam shall be ea Wm eo&w=-ad according to the
customers' cooking egutpat=4 anal"be F"osted and Installed according to NSF, and
M.F.FA #96 repktions, latest editions.
- In oi+der to comply with. entree I.M.C. Replations, local andww ties may require dw a
TetapKvd make-up air unit be mod sd tint the tempersture di ntial bstwoaa the maim-up
air and the sir in *a oondiidoned space do; not exceed 10 degtbes F. Tidy w1 iweive addideam
coats boymA ttbb propoad W6onld tide tie regdeert by Iced ntbexf0W&
Bg?ur?. l/ 0,10 r
S"N~ By.. Robot P. y ?F, PhM
it#?e?K Mvk?kl.MikrkaRlb?t?ld??k71tok1eAdle+IclnMlrale?r7ltaWlNleydkyr?s?ICJINt# A*4! tjII +?***Alt"+k4"Ak4t4W1tMMd4ik+MkiNR+l??k+k?k +k#?kik'R?k k
• TMB p mpad is to be inept sldcO caiddeaW bONO m SbG end the l , - , soloed Unmtraded
mapim b we heeeby ss *rxd total say dbelatme*, *WAS disbibaII a Wft sty evaioa in mince rsprpj the of
dde doom od It tat kdy p mbbd A Myou rod ved lisle docon sd in error plan notify Sa may.
I Inve nerd. sod msdsntasd tie propoael is its eadraq?. 'The dosanbad sped$ectioos, eroepsioae,
moons, sad two fw papcae a ere =dx&csory sod we booby sempsed. You we etnboriaod to do the work es spec dej
I+gmeet wilt be me& ea andined by the tams ndiaded below.
ZWOL SdaG dgMWd MWAdnei Wo order, Baiateee alt dam of WW*. /
D&v of'meepea» z/fJ ??y fJ/
+?c?c7aweae+grew,r.+k??+rrkwt*+kf«4??+k1a+k+k?t*4r+k4vkx?cs+.?rt?ki?k:i?k?k*4N?#+k+k+t+k?k+k+h+kMt##?c?rXS.G.?+??s+rrr?
1616 Tp*sAeRd /Catgsk PA 17015 ^on• (717) 245-2"6 Fates (717) 245-0521
Page 2 of 2
BECKLEY& MADDEN
ATTORNEYS AT LAW
CRANBERRY COURT
212 NORTS Tito STREET
P08T OrMC8 9=11998
I ARRrsBURG, PENNSYLVANIA 17108-1998
PRONE- [7171 888-7691
FAM 471M 283-3740
E-xAxr_ bed ey@pamd
March 4, 2008
rux NO.
311410
Giuseppe Barone VIA FIRST CLASS AND CERTIFIED MAIL
Giovanni Barone
700 Valley Street
Enola, PA 17025
RE: 700 Valley Street, Enola, Pennsylvania
Gentlemen:
This office represents Superior Metalworks, Inc. ("Superior"). Superior served as
a subcontractor to Anything Goes Construction & Remodeling, LLC. Superior fabricated
and installed a commercial kitchen ventilation system at the above-referenced property.
We have enclosed a copy of the subcontract for your reference. Superior completed its
work on November 14, 2007.
At this point, Superior is owed the principal amount of $6,380.00 for its work on
the project. This letter constitutes Superior's formal notice of its intent to file a
mechanic's lien claim on the above-referenced property. Please let this matter have your
immediate attention.
Very truly yours,
BECKLEY & MADDEN
Thomas S. Beckley
Cc: Superior Metalworks, Inc.
Anything Goes Construction & Renovation, LLC (w/encl.)
Brothers Pizza (w/encl.)
;WqKDINC.
0 1?iT?7IIS FI
NSF
NFPA ON
Attn: Awayue G lbws
Anything Goes Constnwft
P.O. Box 61653
October 25, 2007
Job: Brothers Pixm
Fbmsbum PA 17106 Job Location: Valley Rd. Fnola
Fabrication and Installation of Commercial Kitoberr Ventilation to the following slwifications:
> (1) NSF approved Stainless Steel Type 1 Pitobe?nr bond with film rack, Stainless Steel baffle type
f item, 8me collation cep, (2) incvnhdesoeat; N S.F. and U.L, approved vapowe-proof 110ts =d
ooem0ft iotern.lly insoleW Msl?e up sir plenum with akm iz m froat dbcbaW ragj?, and
h*60r P 5tsialess Steel ah delivery. Hood to be (10'-0" It. X 4'-6" wd_ X 24" high).
> (1) NSF approved Stainless Steel Type It Kitt w bood with htofor baffle to exhaust heat and
cambuatlort gas ft m onstomar's NEE Oven. Hood to be (6'-6" 1g. X 5'-16" wd. X 24" high).
> The existing 22 gathge Stainless Steel wall panels an iew and side hood walls shhill remain as is.
> 22 gaup Stainless Steel tailing entloM Item top of hood(s) to cei ng.
> All assocuded wddod galvanized steel and round galvanized steel OA" ductwork to extend from
blood(s) tbrougb roof
> All associated TC Fftw=ter zero clearance de:amic insahtion blanket wham exhaust dud passes
through combustible roof mulihoes.
> All associated kmdted, galvanized steel malm-up am ductwork to extend ;tl om (2) fire damper
pmrected hood pe?oos, tb,rougah roof.
> (3)16 gauge galvanized Roof Cuft
> (1) 1S" Roof motmted 1 U2 H.P.,208 v., throe phu^ upblea style exhaust fan ® 4000 oft whit
hinge kit and grease catch pan.
> (1) 13" Roof motmted 1/2 REAM v., three phase, upblast style exhaust fan @ 1300 dm with hinge
kit and grease catch pan.
> (1)12" Roof mounted 2 H.P., 208 v., Hiroo pbase, Filtered Supply air vetkIdar ptvbcing 4240 c&
of tmtempered out" air.
> A complete wet chemical ?i re appre4sion system will be iastahled for the Protection of the hood plenum
areal exhaust ductwork, (1) gas flyer, (1) 48" griddle. and (2) 2-burner gas ranges. A ?aw haniod gee
ibut o ff +valve and as electric micro switch wr9l be u*ptiod with the system. Any few for tinning by
autbm t m wig be are additional coat at S7&ft,?tr.
1416 T rbdle Rd. /Corms PA .17015 'Pl me. (717) 245-2446 Flax. (717) 245-0521
loft
META
METALWORIM
US70M SUPWWR
USTOM b1PTALW(
METALWORK ---
Aasr8n - falrric?arin» • Jrslellatinn
SUPERIOR
MRALWORO
INC.
-- CrtJSTOM METALWORK - Design - Fabrication • bmwHada)l
- AD gas ph mbiug work including installation of the shut-off valve for the fire suppression.
system, by others.
- All ebeftial wiling, swkches and controls inecluding final coamections to all vantiJu om
peM&iug to the hood system by others.
- S.M.L stall fabricate, int tH aW tempotsaily seal (3) roof cw%. Wood bloddag (if necessary)
& final Bribing to customers rubber root;' mind aU ea loftg roof werrandes, by others.
Fm Watrrrmr Y
,All fWWSl'hed exbausNsW* fans are VW=teed ft one (1) year fiom the date of pwrbase.
Pans and labor. Please be aware that V4 ft are a wearable items depandtng on the tem patat n
range end length of operation of dae hm(s) . Then bens are not covemd under waimi ty by the fan
Manuftoarw ar S.M.I.
N913M
- No penal or inspection fan are includeO these oast wM be a&Wond if required.
- This proposal is based upon our ? 1 having eontmocus Ovedooa of amess to ttae wotlang
am during the normal daydme bowls, e, weekend, and/or any &ftrrupdow after work
has Wpm will mvolve ezt m costs.
- 3.M.L val provide somnate scale dtawiogs ofthe now system for submittal to audioddes.
- This proposed Kkchen'1tentiialfon system stutll be a am! m m euu shmamd aocordatag to the
customers' cooldag egWp nera, mad sl+ail be Fsbdctted and Inatalhd avow dirag to NSF, and
NAPA. #96 regulations, latest editbes.
- In order to comply with aw ad LKC. Regulations, local andw ties may requite dw a
Tempered make-up air unk be died w that the tamps stn diffemuiisl beween the make-W
air and the akin the..aWitioned space do;not exceed t0 degre+es F. Thk Mt fooolo addklmad
eom bsyma d tffis prepmsel amidst this lie regadured try local des.
your Cost. ,1,09
Sway. Ro+botA 4fF*M4 Jr-, PhM
+as+.*.«s?.a?,«.,.u?.t«.?w?e,.+r+e+were+wrM,r++.,?+#,*+?x+?,r,,,+??r*.
• Thin proposal h to be leapt y }d batwroon S? and to Pam unarned Uniotendw
?eaipieab see y 0 F OW d *9 w7 dbdootaw, oolrylego dlu or Wft sly soda t ME= repmag the caateM of
9ais doaarnart it WAdy prmltit IN& iiyou roeoirod this dominant is error pkaee ate' SW dY
dgNWWALgfjMMjjL- I We red and mWaft and dds proposal to it 4au0my. Mic domtwd a ecdcwA • cwq*acks,
sad terms for pwyutmmurt sure aeuddkomy ad an busby samiled You are M od=d m do to wakes sped.
P ment wM be mob a oodined by die ems fueled below.
Titrnes: S97i dePoatt ngamttd tviNlr eater, Hainan >is dwsp-, --peon We d
of work. i /?'
2? t?'aaorpta+ees: ? r < f
1416 TWW&eRd /CoOd4 PA 17915 :Pkonw- (717) 24-55-2"6 Face (717)N5-0521
Page 2 *f2
BECHI.EY& MADDEN
ATTORNEYS AT LAw
CRANBERRY COURT
212 NoRTa TRZRa STR*rzT
POST OFFICE 8Oa 11998
HARRISBURG, PENNSYLVANIA 17108-1998
PHONE: (717) 838.7891
FA%:(717) 233-3740
E-MAIL: bed&ll@pa.nex
March 4, 2008
FILE 140.
311410
Brothers Pizza VIA FIRST CLASS AND CERTIFIED MAIL
700 Valley Street
Enola, PA 17025
RE: 700 Valley Street, Enola, Pennsylvania
Gentlemen:
This office represents Superior Metalworks, Inc. ("Superior"). Superior served as
a subcontractor to Anything Goes Construction & Remodeling, LLC. Superior fabricated
and installed a commercial kitchen ventilation system at the above-referenced property.
We have enclosed a copy of the subcontract for your reference. Superior completed its
work on November 14, 2007.
At this point, Superior is owed the principal amount of $6,380.00 for its work on
the project. This letter constitutes Superior's formal notice of its intent to file a
mechanic's lien claim on the above-referenced property. Please let this matter have your
immediate attention.
Very truly yours,
BECKLEY & MADDEN
i
Thomas S. Beckley
Cc: Superior Metalworks, Inc.
Anything Goes Construction & Renovation, LLC (w/encl.)
Giuseppe Barone (w/encl.)
Giovanni Barone (w/encl.)
SI pm"OR
MITALWORKS
fNC.
-- CUSTOM METALWORK -
rDcsign - fnhrimdon • lizoaUadan
?x?u{r.asttl
CSC
NFPA #9S
Attn: Dwayne Gilbert
Anything Goes Construction
P.O. Bois 61653
October 25, 2007
Job: Brothers Pizza
Harrisburg, PA 17106 Job Location: Valley Rd. Enole
?It?lt#?ItMU1NR#+k+ltt?lcae# ?f#%k#*#?k?ki??kk?t*#?k?'k?kkalr]k7kyttaC+ItNc+R+NR7k1:+RJk?l:?k*#?k?1:+R+?t?k?lpk l:7Ckt7etleatdt+knFNt+Ie+krkA?+l?+b9ti+k+kMN*+k4?k+lxfe?e+?dk?Ir1:•?k?k?NhkikNatk#JMk
Falxioetion and Znstlladon of Commercial Kite = Ventiilation to the fallowing specifieWons:
> (1) NSF approved Stainless Steel Type I Kbolon hood with filter rack, Stainless Steel baffle type
fiiteM grease collaWan cup, (2) is neat N S.F. and UJL approved vapm-pr of lJote sod
oomplcee iowmally insab od MWw-up aft plainva with Wumimm front dbobKV re&aeM sad
Warior pfd Stainless Steel air delivery. Hood tv be (10'-0" IS. X 4'-6" wd X 24" higb).
> (1) NSF approved S'tav?less Steel Type H K,Wsrn. bood with interior baffie to exhaust heat and
combustion on $nm awtomer's Pizza Oven. Flood to be (6'-6" 1g. X 5'-16" wd. X 24" high).
> The existing 22 ~ Stainless Steel wall panels on rear and side hood walls shall remain as is.
> 22 PAw Stainless Steel ceilins endost" ftm trop of bood(s) to ceiling.
> All associated welded saivsaizcd steel and round galvaniaod steel WdIMost dudwerk td eaatewd f OM
hood(s) ftmqu h roof.
> ,All. associated TC Fhwxstar zero clearance cpsamic insulation blanket whore exhaust dues passes
through cosaWdiible roof mr6ces.
> All associated inxd tad, galvanized steel nwke-up air duetwodt to amend, $+om (2) fee daunper
protected hood pagans, through roof.
> (3)16 geeuge g dvaniaed Roof CuA*.
> (1) Ir Roof momated 1 In H.P,208 v, three phase, upblast style a dmut fan ® 4000 ofin with
hinge kit and g oath pan.
> (1)13" Roof mounted 112 ILP MS v., lftM phase, upblast AYU exhaust fast Qa 1300 cfm with hinge
Idt and gram catch pen.
> (1) 12" Roof mounted 2 H.P., 208 v., three phase, Filtered Supply air ventlldor producing 4240 ch
of n otempard outside au.
> A complete wet cbemieal fire vVpressim sysb m will be iastalkd for the pcotecdm of the hood plain m
area, exhaust doetwo dc, (1) gas ii yer, (1) 48" griddle. end (2) 24mmer gas ranges. A nmwhaaical Rae
sbut aff valve and an electric micro switch will be snppliad wfth do sysum. Any Jess for taft by
autborldas wM be M additised cast at $76ftllar.
+k7?k?N?ikMNk*?hMe?4kiMakik?It?kae?Ic7kak.?tu+k+luR7N7R7k?1.'.R?kJI t#?Ie1NI r.11?It?1i?e?lt?k?R?I gk+k?ICAC?k7k?k+kY.+fCik+k?IC+R7k#+kAtlk+kM.?MRrR+IuR#+IC?kAtfil?RQ+k+k?R?k+RirakdeNNnRk'
1416 mdse Rd /Casfiteley PA 17015 •Pbmm- (7717) 245-2446 Far. (71) 245-0521
age 1 of 2
. . - V-I
NItWWORKS
INC. '- CUSTOM METALWORK -
Derfgn - Fabrkadon • hsra1kn m
All go plumbing work including itwalWon of the shut-o$ valve for the fire session
syeeem, by others.
-All electrical wiring, switches and controls it ebx tig final connections m all venfilow
pcrtaW ng to the hood system, by others.
- S.M.I. eball fabricate, install and twopotatTily seal (3) roof curbs. Wood biock*g (if necessary)
& Errand flashing to mWomers rubber roof' sod all edstirrag roof watraujes, by others.
Per Wes:
All fandebed exbauWavply fans are guaranteed for one (1) yew fresh the date of parcbaw.
Px* rmd labor. Please be aware that V-blahs are a wearable item depending ov the tempeetaeture
range and length of operation of the fine(s). These belts are not covered av?aasnty by the fan
ttsanufecftW or S.M.I.
- No pwmit or hupeodoun flees am included these costs will be odditimal if req? h*&
- This proposal is based upon our ? Persom"I having continuous Ovedom of access to the wmi&g
area daring the normal daytime bouts. NOW=, wee1=4 and/or any irfetrapdtotts sf-w work
has begun wM Wvolve extra coed.
- S.M.I. will provide accurate scale of the ww syeoeta for suboeittal to avilkw res.
- This proposed Kkchgd Vaatflat M rJOM shall be oustom aogirmered according to the
customers' cooking equipmeA a94 d all be Fabriested and Installed according to NSF, and
N.FPA. #96 reguletiotk4 low editions.
- In ot+dW to comply with, owed LKC. Regulations, local amborides mey require do a
Tempered make-up air unk be Installed to treat the tempaaawu ftkrenti l between the make-up
air and the stir in the oo xUdoned space do;not e=wd 10 degrees F. Thk wR hwake adad=w
casts bey end Alp proposal sI mtid this be requkvd by hmW =dhoddeg.
Yarn Cost' a 1.3 a00
Sabmoraa By: Roikrt P..S?r#aaenti, .fr., PhM
• TMe p+op=d is to be kept st<fetli?
n pieob E bDtwomSIGadibeperson smedtninkad
arehumbynoO, *Mardisdosresoopyfn& or nkft asy nonuse to rattaoe nstpeftS the corrtena of MIN 11 Wis doossaaR if tlrlatly pt+oldb?ed, If you roooi+red Sh dooxoent is enw please no* SM may.
• I have tread and mdarsUnd dds prapood be its aatit". MIC daeaibed Fiona, acoep aw%
oandMons, and teas for paymas ate x0shc ory and an busby accepnd, You are mdlodnd to do the work a apedfed,
Pgmmt wttt be made ae odlined by do texas b dieded below.
T vas: 5M depot ncgsencd wlte vr&r, Balmea h drre jWon v fort of tank. i
Den ?? ? r c??
+k+k?c+rr*eerx+?+k+?e+k+k??+Wk?w+Wk?t?*#1?sukMc*a*?Iak+r+kMMc*?Yr?lc7r?s?k?kir?#?ki??k+h#*#??R+s+k*+k+k+RMr#M?:?Itm+r.+??Tr.+?r+Rler
,1416 Tfr+bndte M /Cw&&, PA I7®IS ^oj• (717) 245-2446 Fm {717) 243-032.1
Page 2 of z
EXHIBIT C
o.
V DEED
I IN
THIS DEED is made the day of August 2005005 SEP 8 PM 3 21
BETWEEN
CRL HOLDINGS, L.P..,-&Pennsylvania limited partnership ("Grantor"),
AND
GIUSEPPE BARONE and GIOVANNI BARONE, adult individuals (collectively,
"Grantee"):
WITNESETH
That the Grantor in consideration of One Hundred Eighty-Five Thousand Dollars
($185,000) paid by the Grantee to the Grantor, the receipt whereof is hereby
acknowledged, does hereby grant and convey unto the Grantee:
Tract Number 1:
ALL THAT CERTAIN tract or parcel of land, situate in East Pennsboro
Township, Cumberland Canty, Pennsylvania, more particularly banded
and described according to a survey of D.P. Raffenspager Associates,
Registered Surveyors, dated April 19, 1973, as follows:
BEGINNING at a point at the southwest corner of Valley street (Legislative
Route.21051) (50 foot right-of-way) and "B" Street (erroneously identified
as "D" Street in a prior deed) (50 foot right-d-way); thence along the
western One of "B" Street (erroneously identified as "D" Street in a prior
deed) the following courses and distances; South 130 01' East, 15.77 feet;
a curve to the right having a radius of 245 feet, an arc distance of 93.13
feet, South W 45' 43" West, 93.65 feet to a point in line of other lands
now or formerly of Dale J. Hildebrandt; thence North 03° 00' West along
said Hildebrandt lands, 105.12 feet to a point; thence North 05° 48' West
along the eastern line of other lands now or formerly of Dale J.
Hildebrandt, 975.38 feet to a point in the southern line of Valley Street
aforesaid, thence North 84° 12' East along said line of Valley Street, 130
feet to a point in the western line of "B" Street (erroneously identified as
"D" Street in a prior deed), the place of BEGINNING.
BOOK 270 PAC14399
Tract Number 2:
The above-described Tract Number 1 is also shown on the site plan dated
September 15, 1993, attached as Exhibit "A" hereto (the "Plan").
BEING the same premises which CRL Holdings, L.P., a Pennsylvania limited
partnership, by Connective Deed dated July 30, 2003 and recorded in Cumberland
County Deed Book 258, page 3551, granted and conveyed unto CRL Holdings, L.P.,
Grantor herein.
UNDER AND SUBJECT, nevertheless, to all other easements, restrictions,
encumbrances and other matters of record or that a physical inspection or survey of the
premises would reveal.
Attached as Exhibit "B" hereto and made an integral part hereof is a certain
notice pursuant to the Pennsylvania Solid Waste Management Act and the Land
Recycling and Environmental Remediation Standards Act (the "Notice"). All future
deeds must contain the Notice unless written approval to remove the Notice is obtained
from the Pennsylvania Department of Environmental Protection and evidence of such
approval is placed of record with the Cumberland County Recorder of Deeds.
Grantor hereby covenants and agrees that Grantor will warrant SPECIALLY the
property hereby conveyed described as Tract Number 1 above.
To the extent that Tract Number 2 described in accordance with the Plan
includes any additional land not included in the property described as Tract Number 1
above (the `Additional Property'), Grantor hereby covenants and agrees that Grantor
does hereby rokl e, ren dse and forever quitclaim to the Granbe all of Grantor's
right, title and interest in and to the Additional Property.
IN WITNESS WHEREOF, the Grantor has caused this Deed to be duly executed
as of the day and year first written above.
WITNESS:
C,4f-
CRL Holdings, L.P.
By its General Partner CRL GP, LLC:
By Q
John Eyler, Co-Chaff
z4ND
By
Patrick J. C
gna, Co-Chaj an
20*
2 600K 270 PACE4400
COMMONWEALTH OF PENNSYLVANIA
Low CCL5?-ems SS:
COUNTY OF
On this, the /O+A day of 2005, before me, a Notary Public, the
undersigned officer, personally appeared John E. Eyler who acknowledged himself to
be the Co-Chairman of CRL GP, LLC, which is the general partner of CRL Holdings,
L.P., a Pennsylvania limited partnership, and that he as such Co-Chairman, being
authorized to do so, executed the foregoing instrument for the purpose therein
contained by signing the name of the limited partnership by himself as such Co-
Chairman.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
My Commission Expires:
Q4V-V-?? COIL art-
Notary Public
NOTARIAL sou. AL)
JonNle L Lauver, Notary Public
Mwftkn Twp., Courdy of Lenceaw
My 0ommission Expires April 8, 2007
T
to C? + r" s> a m
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BOOK 270 PACE4401
COMMONWEALTH OF PENNSYLVANIA :
COUNTY OF Lanc SS:
.a5?r
On this, the YO 7 "day of 2005, before me, a Notary Public, the
undersigned officer, personally appeared Patrick J. Castagna who acknowledged
himself to be the Co-Chairman of CRL GP, LLC, which is the general partner of CRL
Holdings, L.P., a Pennsylvania limited partnership, and that he as such Co-Chairman,
being authorized to do so, executed the foregoing instrument for the purpose therein
contained by signing the name of the limited partnership by himself as such Co-
Chairman.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
.Q p0
Notary Public
My Commission Expires:
NOTARIAL SEAL
Joneft L Lauver, Notary Pubib
Alud 1, Up., County of UUW=W
Corrn*ejon Expire AprN 8, 2007
(SEAL)'
?r
.i.F'bj?.'4 Vsw• *? ..
4
600 270 PACE4402
.. ANN-.
CERTIFICATION OF ADD
I hereby certify that the precise residence of the Gnmtee(s) in the within Deed is:
700 Y aft Road
En low PA 17011
0
Agent for Grantee
Recorder of Deeds
BOOK 270 PACE4403
4J j
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-03036 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SUPERIOR METALWORKS INC
VS
BARONE GIUSEPPE ET AL
R. Thomas Kline Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named OWNER
BARONE GIUSEPPE but was
unable to locate Him in his bailiwick. He therefore returns the
MECHANICS LIEN CLAIM r
the within named OWNER
, BARONE GIUSEPPE
700 VALLEY STREET
NOT FOUND , as to
ENOLA, PA 17025
PER POST OFFICE, DEFENDANT MOVED AND
LEFT NO FORWARDING ADDRESS.
Sheriff's Costs: So
Docketing 18.00
Service 15.00
Not Found 5.00
Surcharge 10.00 /S
a
9111 J
^
F? .00
r
d
? 48.00 B
Sworn and Subscribed to before
me this day of
R. Thomas Kline
her ff of Cumberland County
CKLEY & MADDEN
9/08/2008
A. D.
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-03036 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SUPERIOR METALWORKS INC
VS
BARONE GIUSEPPE ET AL
R. Thomas Kline Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named OWNER
BARONE GIOVANNI but was
unable to locate Him in his bailiwick. He therefore returns the
MECHANICS LIEN CLAIM
the within named OWNER
700 VALLEY STREET
, BARONE GIOVANNI
, NOT FOUND , as to
ENOLA, PA 17025
PER POST OFFICE, DEFENDANT MOVED AND
LEFT NO FORWARDING ADDRESS.
Sheriff's Costs:
Docketing 6.00
Service .00
Not Found 5.00
Surcharge 10.00
.00
21.00
So
R. 'Thomas Ki ine
he i f of Cumberland County
CKLEY & MADDEN
09/08/2008
Sworn and Subscribed to before
me this day of
A. D.
SUPERIOR METALWORKS, INC.,
Plaintiff
V.
GIUSEPPE BARONE and GIOVANNI
BARONE,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
MECHANIC'S LIEN CLAIM
Defendants : NO. 08-3036-MLD
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY OF SAID COURT:
Please reinstate the Complaint in the above-referenced matter.
DATED: September 26, 2,008
Thomas S. Beckley, Esquire
BECKLEY & MADDEN
212 North Third Street
P.O. Box 11998
Harrisburg, PA 17108-1998
(717) 233-7691
Attorney for Plaintiff
a
? O
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2008-03036 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SUPERIOR METALWORKS INC
VS
BARONE GIUSEPPE 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:
BARONE GIUSEPPE
but was unable to locate Him in his bailiwick. He therefore
deputized the sheriff of DAUPHIN County, Pennsylvania, to
serve the within MECHANICS LIEN CLAIM
On October 14th , 2008 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs: So answera4---
Docketing 18.00
Out of County 9.00
Surcharge 10.00 R. Thomas Kline
Dep Dauphin County 49.25 Sheriff of Cumberland County
Postage 2.27
88.52 ? l0?(4?19P
10/14/2008
BECKLEY & MADDEN
Sworn and subscribe to before me
this day of
A. D.
t
In The Court of Common ]Pleas of Cumberland. County, Penaisylvahia
Superior Metalworks Inc
vs.
Giuseppe Barone et al No. 08-3036 civil
Now, October 6, 2008 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Dauphin County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Now,
within
upon
at
by handing to
a
and made known to
copy of the original
So answers,
Sworn and subscribed before -
me this day of , 20
the contents thereof.
AFFIDAVIT
County, PA
Affidavit of Service
20 at
o'clock M. served the
Sheriff of
COSTS
SERVICE
MILEAGE
41
Sheriffs Return
No. 2008-T-2140
OTHER COUNTY NO.083036-MLD
And now: OCTOBER 9, 2008 at 10:29:00 AM served the within MECHANICS LIEN CLAIM upon
GIUSEPPE BARONE by personally handing to MICHAEL MECK 1 true attested copy of the original
MECHANICS LIEN CLAIM and making known to him/her the contents thereof at 2308 PATTON
ROAD (GIOTTI'S RESTURANT) HARRISBURG PA 17112
COOK
(Ptlitt Ed the'siterff
Mary Jane Sny?yder
R Estate Depu
William T. Tully
Solicitor Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 780-6590 fax: (717) 255-2889
Jack Lotwick
Sheriff
Charles E. Sheaffer
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Commonwealth of Pennsylvania SUPERIOR METAL WORKS INC.
VS
County of Dauphin GIUSEPPE BARONE
Sworn and subscribed to
before me this 10TH day of October, 2008
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NOTARIAL SEAL
ARY JANE SNYDER, Notary Publi
Highspite, Dauphin County
IhMy Commission Expires St 1 2010
So Answers,i ?
Sheriff of Dau
By
Deputy Sheriff
Deputy: W CONWAY
Sheriff's Costs: $49.25 10/8/2008
4-
SUPERIOR METALWORKS, INC.,
Claimant
V.
GIUSEPPE BARONE and GIOVANNI
BARONE,
Owners
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
: MECHANIC'S LIEN CLAIM
NO. 08-3036-MLD
PRAECIPE TO MARK ACTION SETTLED, DISCONTINUED
AND ENDED, AND TO WITHDRAW MECHANIC'S LIEN CLAIM
TO THE PROTHONOTARY:
Please mark the above-captioned action as settled, discontinued and ended, and
the mechanic's lien claim as withdrawn.
DATED: December 3, 2008
Respectfully submitted,
Of Counsel
BECKLEY & MADDEN
212 North Third Street
Post Office Box 11998
Harrisburg, Pennsylvania 17108-1998
(717) 233-7691
Thomas S. Beckley, Esquire
Attorneys for Claimant
Superior Metalworks, Inc.
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CERTIFICATE OF SERVICE
I, Thomas S. Beckley, Esquire, hereby certify that on this day a true and correct
copy of the foregoing document was served upon the person and in the manner indicated
below:
SERVICE BY FIRST CLASS MAIL
Susan E. Good, Esquire
Smigel, Anderson & Sacks, LLP
4431 North Front Street
Harrisburg, PA 17110
DATED: December 3, 2008
Thomas S. Beckley, Esquire
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