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HomeMy WebLinkAbout08-4152ON IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, No.: Z?- MLD VS. MICHAEL WHITEHEAD and JEAN WHITEHEAD 274 RIDGE HILL ROAD MECHANICSBURG, PA 17050 PARCEL# 38-18-1346-010 Defendants. MUNICIPAL CLAIM FOR SEWER RATES TO: PROTHONOTARY SIR/MADAM: Silver Spring Township Authority, Cumberland County, Pennsylvania, by its attorneys JAMES, SMITH, DIETTERICK & CONNELLY, LLP, hereby files its claim for the sewer rate charged against the real estate hereinafter described, located in Silver Spring Township, Cumberland County, Pennsylvania, and sets forth its claim as follows: Statement of Claim 1. The name of the municipality by which this claim is filed is Silver Spring Township Authority. 2. The Authority under and by virtue of which this sewer rate was charged is as follows: (a) Section 4 of the Act of 1945, P.L. 382, 53 P.S. §306, Municipalities Authorities Act of 1945, as amended; and (b) Resolution of Silver Spring Township Authority, adopted December 11, 1991, establishing the sewer rates and regulations of Silver Spring Township Authority for the sewer system for the Township of Silver Spring, and authorizing the collection and enforcement of sewer rates in this manner prescribed by law. 3. All acts, conditions, events and things required to be done by Silver Spring Township Authority under the Acts of Assembly of the Commonwealth of Pennsylvania have been done and performed in due and legal form so as to entitle Silver Spring Township Authority to a lien for the payment of the sewer rates for which this claim is filed. 4. The name of the owner(s) or reputed owner(s), of the property against which this claim is filed, is/are Michael Whitehead and Jean Whitehead. i? 5. The property against which this claim is filed is known and numbered as 274 Ridge Hill Road, Mechanicsburg, PA 17050. 6. This sewer rate was charged for sewer service furnished to the above-described property, the sewer lines which services same being installed in 1979 and the sewer rate being charged for the period commencing April 11, 2007 to and including the present. Rental, Penalties, Interest, Collection Fee and Costs AS OF July 10, 2008 Sewer Rents through 2nd Quarter 2008 $ 435.13 Penalties through December 10, 2008 Sheriff Sale $ 134.00 Attorney' Fees through December 10, 2008 Sheriff Sale $ 2,255.00 Court Costs and Fees through Dec. 10, 2008 Sheriff Sale L1,630.00 TOTAL: $ 4,454.13 Plus additional attorneys' fees and costs incurred by Silver Spring Township Authority in collection of the above claim in accordance with the attached fee schedule authorized by Resolution of Silver Spring Township Authority. 7. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) does so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof, otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. Payment of the above claim not having been made, enter the same in the proper Municipal Lien Docket and Judgment Index. JAMES, SMITH, DIETTERICK & By: Sc A. Diette Attorn ey for Plai PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 N_ .7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, No.: MLD VS. MICHAEL WHITEHEAD and JEAN WHITEHEAD 274 RIDGE HILL ROAD MECHANICSBURG, PA 17050 : PARCEL # 38-18-1346-010 Defendants. CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the Municipal Claim for Sewer Rents was served on the following this W day of July, 2008, via First Class U. S. Mail, Postage Pre- paid: Michael Whitehead Jean Whitehead 274 Ridge Hill Road Mechanicsburg, PA 17050 Respectfully Submitted: JAMES, M1'H, DIETI'ERICK & CONNELLY, LLP By: V. Sco A. Diette Attorney I.D. #5 0 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 t? o r Co 9j _.. f?-^? ry % . PQ 21 4:_ SHERIFF'S RETURN - NOT FOUND ':ASE NO: 2008-04152 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SILVER SPRING TOWNSHIP AUTHORI VS WHITEHEAD MICHAEL 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 DEFENDANT WHITEHEAD MICHAEL but was unable to locate Him in his bailiwick. He therefore returns the WRIT OF SCIRE FACIAS NOT FOUND , as to the within named DEFENDANT WHITEHEAD MICHAEL 247 RIDGE HILL RD MECHANICSBURG, PA 17050 ALTHOUGH NUMEROUS ATTEMPTS WERE MADE, WE WERE UNABLE TO MAKE SERVICE PRIOR TO EXPIRATION. Sheriff's Costs: Docketing 18.00 Service 20.00 Not Found 5.00 Surcharge 10.00 g/t?/oP 00 ;"53.00 So R. Thomas Kline -- S-htES f of Cumberland County SMI TH DIETTERICK CONNELL 09/08/2008 Sworn and Subscribed to before me this day of A. D. SHERIFF'S RETURN - NOT FOUND 'EASE NO: 2008-04152 P •.•r COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SILVER SPRING TOWNSHIP AUTHORI VS WHITEHEAD MICHAEL 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 DEFENDANT WHITEHEAD JEAN but was unable to locate Her in his bailiwick. He therefore returns the T.7n TT n? Of" T= LAf! TTC , NOT FOUND , as to the within named DEFENDANT 247 RIDGE HILL RD , WHITEHEAD JEAN MECHANICSBURG, PA 17050 ALTHOUGH NUMEROUS ATTEMPTS WERE MADE, WE WERE UNABLE TO SERVE DEFENDANT PRIOR TO EXPIRATION. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 ?'"/??/° ?? 21.00 So ans 'i'nomas xi ine Shff of Cumberland County J S SMITH DIETTERICK CONNELL 9108 Sworn and Subscribed to before me this day of A. D.