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HomeMy WebLinkAbout08-4817 Larry L. Miller, Esquire Pa. Supreme Court I.D. No. 28122 1423 State Road Duncannon, PA 17020 Telephone: [717] 541-5225 Attorney for Plaintiff: MID-ATLANTIC MATERIALS, INC. MID-ATLANTIC MATERIALS, INC. 6813 Quad Avenue Baltimore, MD 21237 Claimant V. ALTIERI ENTERPRISES, INC. 9017 Red Branch Road, Ste 201 Columbia, MD 21045 Owner/Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 68 - 1811 Ind LD MECHANIC'S LIEN CLAIM 1. The name of the party claimant is Mid-Atlantic Materials, Inc. ("Claimant"), a Maryland business corporation with offices located at 6813 Quad Avenue, Baltimore, Maryland 21237. The Claimant files this mechanic's lien claim as a supplier to a subcontractor. 2. The name and address of the owner of the property subject to the lien is Altieri Enterprises, Inc., 9017 Red Branch Road, Suite 201, Columbia, Maryland 21045. 3. The Claimant furnished drywall, joint treatment and related accessories on the project known as Lot 23, Hunt Place, Foxwood Estates, Mechanicsburg, Cumberland County, Pennsylvania. 4. The Claimant last furnished materials to the project on or about April 22, 2008. 5. Claimant provided the materials to R & L Drywall which had a contract with Altieri Enterprises, Inc. and gave preliminary notice of its intention to file this claim on June 19, 2008 and formal notice of its intention to file this claim on July 7, 2008. 6. The amount owing to Claimant for materials to this lot is $4,454.46. 7. The real estate and improvements subject to this mechanic's lien claim consist of all that property known as Lot 23, Hunt Place, Foxwood Estates, Mechanicsburg, Cumberland County, Pennsylvania and all improvements at this location. Attached hereto as Exhibit "A" is a plan of the development which depicts Lot 23 subject to this lien and it is incorporated herein by reference. WHEREFORE, Claimant, Mid-Atlantic Materials, Inc., respectfully requests and demands that this Honorable Court lien the above-described property and file the 1'e in the judgment index. DATE: August 8, 2008 By: LARRY L. M LLER Attorney I. . #28122 VERIFICATION I, LARRY L. MILLER, hereby state that I am counsel for the Claimant in the within action and that the facts set forth in the foregoing Mechanic's Lien Claim are true and correct to the best of my knowledge. The information set forth in this lien claim was provided by Charles E. Gibson, President of Mid-Atlantic Materials, Inc. Mr. Gibson's verification could not be obtained within the time allowed for filing this document. I understand that the statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Section 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be sub ect to criminal penalties. ' ?j Date: August 8, 2008 LAR Y L. M LLER Image Viewer Page 1 of 1 Close Print ALMRI .'HOME "Where ExAvilencc it a Family, TrMftl*)M 14, 20 SS 29 3t7 3 FO WOOD ESTATES 15 RS 11 ?? 3p !E! 9 26 S R5 24 23 22 32 33 36 S4 2 4 31 30 EXHIBIT k http://www. altierihomes.com/display_image.php?image=./photos/communities/53_comm_plan_photo. j p... 6/19/2008 C'j ?v 39 !? 00 f N C5 Larry L. Miller, Esquire Pa. Supreme Court I.D. No. 28122 1423 State Road Duncannon, PA 17020 Telephone: [717] 957.2828 MID-ATLANTIC MATERIALS, INC. 6813 Quad Avenue . Baltimore, MD 21237 Claimant V. ALTIERI ENTERPRISES, INC. 9017 Red Branch Road, Ste 201 Columbia, MD 21045 Owner/Defendant Attorney for Plaintiff: MID-ATLANTIC MATERIALS, INC. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 08-4817 MLD AFFIDAVIT OF SERVICE I, Larry L. Miller, counsel for Mid-Atlantic Materials, Inc., being duly sworn according to law, depose and say that by letter dated August 15, 2008, the attached Notice of Filing of Mechanic's Lien Claim and Mechanic's Lien Claim for property known as Lot 23, Hunt Place, Foxwood Estates, Mechanicsburg, Cumberland County, Pennsylvania, was served upon Altieri Enterprises, Inc., the owner of the property against which the claim was filed by certified and first class mail addressed to Altieri Enterprises, Inc., 9017 Red Branch Road, Suite 201, Columbia, MD 21045. A true and correct copy of the August 15, 2008 service letter with the signed certified mail receipt is attached hereto as Exhibit "A." This Verification is made subject to the penalties of 18 Pa. Cons. Stat. Section 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penalties. DATE: September 3, 2008 By: LARFfY L. MI LER Att n y I. . #28122 Attorney fo Claimant Larry L. Miller, Esquire Pa. Supreme Court I.D. No. 28122 1423 State Road Duncannon, PA 17020 Telephone: [717] 541-5225 Attorney for Plaintiff: MID-ATLANTIC MATERIALS, INC. MID-ATLANTIC MATERIALS, INC. 6813 Quad Avenue Baltimore, MD 21237 Claimant v. ALTIERI ENTERPRISES, INC. 9017 Red Branch Road, Ste 201 Columbia, MD 21045 Owner/Defendant TO: ALTIERI ENTERPRISES, INC. 9017 Red Branch Road, Ste 201 Columbia, MD 21045 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 08-4817 MLD NOTICE OF FILING OF MECHANIC'S LIEN CLAIM You are hereby notified that a mechanic's lien claim in the amount of $4,454.46 has been filed on behalf of Mid-Atlantic Materials, Inc. against the property known as Lot 23, Hunt Place, Foxwood Estates, Mechanicsburg, Cumberland County, Pennsylvania, of which you are the owner or reputed owner. The claim was filed in the Court of Common Pleas of Cumberland County at No. 08-4817 MLD n on August 11, 2008. A copy of the claim is attached. ' L1 DATE: August 15, 2008 By: LARK L. ILLER Atto ney .D. #28122 p - Larry L. Miller, Esquire Pa. Supreme Court I.D. No. 28122 1423 State Road Duncannon, PA 17020 Telephone: [717] 541-5225 MID-ATLANTIC MATERIALS, INC. 6813 Quad Avenue Baltimore, MD 21237 Claimant V. ALTIERI ENTERPRISES, INC. 9017 Red Branch Road, Ste 201 Columbia, MD 21045 Owner/Defendant Attorney for Plaintiff: MID-ATLANTIC MATERIALS, INC. IN.THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. C9 -8811 ku MECHANIC'S LIEN CLAIM 1. The name of the party claimant is Mid-Atlantic Materials, Inc. ("Claimant"), a Maryland business corporation with offices located at 6813 Quad Avenue, Baltimore, Maryland 21237. The Claimant files this mechanic's lien claim as a supplier to a subcontractor. 2. The name and address of the owner of the property subject to the lien is Altieri Enterprises, Inc., 9017 Red Branch Road, Suite 201, Columbia, Maryland 21045. 3. The Claimant furnished drywall, joint treatment and related accessories on the project known as Lot 23, Hunt Place, Foxwood Estates, Mechanicsburg, Cumberland County, Pennsylvania. 4. The Claimant last furnished materials to the project on or about April 22, 2008. 5. Claimant provided the materials to R & L Drywall which had a contract with Altieri Enterprises, Inc. and gave preliminary notice of its intention to file this claim on June 19, 2008 and formal notice of its intention to file this claim on July 7, 2008. 6. The amount owing to Claimant for materials to this lot is $4,454.46. 7. The real estate and improvements subject to this mechanic's lien claim consist of all that property known as Lot 23, Hunt Place, Foxwood Estates, Mechanicsburg, Cumberland County, Pennsylvania and all improvements at this location. Attached hereto as Exhibit "A" is a plan of the development which depicts Lot 23 subject to this lien and it is incorporated herein by reference. WHEREFORE, Claimant, Mid-Atlantic Materials, Inc., respectfully requests and demands that this Honorable Court lien the above-described property and file the l: index. DATE: August 8, 2008 in the judgment By : /, LARRY L. M LLER Attorney I. S. #28122 VERIFICATION I, LARRY L. MILLER, hereby state that I am counsel for the Claimant in the within action and that the facts set forth in the foregoing Mechanic's Lien Claim are true and correct to the best of my knowledge. The information set forth in this lien claim was provided by Charles E. Gibson, President of Mid-Atlantic Materials, Inc. Mr. Gibson's verification could not be obtained within the time allowed for filing this document. I understand that the statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Section 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penalties. Date: August 8, 2008 Lill 16C Y !C W M Page 1 of 1 Close Print r.. r? ter Fstrlrancc i,Y & Faintly T?ruk'Yic?rr" -'as m. 15 kA FOXWOOD ESTATES 13 l4+ if SR 38 9 .. 26 3? 9 35 221, 1 32 3? 6 36 2 3. 4 33 EXHIBIT Ik http://www. altierihomes.com/display_image.plip?image=./photos/communities/53_comm-plan photo. jp... 6/19/2008 . -MILLER LAW OFFICES, P.C. Pennsylvania Office New Jersey Office - 1423 State Road Suite 108, 50 Chestnut Ridge Rd. Duncannon, PA 17020 Montvale, NJ 07645 717 957 2828 V971 VM • i EMAIL Iimmillerlaw@earthlink.net Fax 717 957 4843 RE: #3645 8/15/08 #3645 7184 3875 4490 0000 0370 August 15, 2008 VIA CERTIFIED & IsT CLASS MAIL Altieri Enterprises, Inc. 9017 Red Branch Road, Suite 201 Columbia, MD 21045 Re: Mechanic's Lien Claim; Cumberland County Docket 08-4817 MLD Mid-Atlantic Materials, Inc. v. Altieri Enterprises. Inc. Lot 23, Hunt Place, Foxwood Estates, Mechanicsburg, Cumberland County, PA. Our File #3645 Dear Sir/ Madam: I enclose and serve upon you a Notice of Filing of Mechanic's Lien Claim. Sincerely, r i' Lary L. ?iller Enclosure LARRY..-L • -MItLER, ESQUIRE__. -- MILLER LAW OFFICES,°"F•C-. I 1423 STATE ROAD I" DUNCAN-NON., PA 17020 8174/08 #3645 A. SignaUge: (?Addressee or ?Agent) U? o g g i 0- Cr Nov Z N J w ^ I pwm 0 FOB I n 03M E Z Q r>' u_ L i U LL co LL B. Received By: (Please Print Clearly) ASHLEY ALL19TT C. Date of Delivery AUG 181008 0. Addressee's Address Ix0nre..tF.mAddea.u:edays..de0 city ------- -------------------Co - - Shte ZIP r 4 de EXHIBIT A ..._ _- ___ _- d:,i2estricted Delivery? & Service Type (Extra Fee) Yes CERTIFIED. I i 2. Article Number 7184 3875 4490 0000 0370 1111111111111111111111111111111111111111 7184 3875 4490 ooao 031 1. Article Addressed To: ALTIERI ENTERPRISES, INC- 9017 RED BRANCH ROAD, SUITE 201 COLUMBIA MD 21045 _J %woo *%,o CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing AFFIDAVIT OF SERVICE this 3rd day of September 2008 by placing the same in the United States Mail, first class mail, postage prepaid addressed as follows: Altieri Enterprises, Inc. 9017 Red Branch Road, Suite 201 Columbia, MD 21045 ,? By: r 5l . i c..-°