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HomeMy WebLinkAbout08-4818fe 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. M - JM g M 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 11, Foxwood Boulevard, Foxwood Estates, Mechanicsburg, Cumberland County, Pennsylvania. 4. The Claimant last furnished materials to the project on or about April 18, 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 $3,459.84. 7. The real estate and improvements subject to this mechanic's lien claim consist of all that property known as Lot 11, Foxwood Boulevard, Foxwood Estates, Mechanicsburg, Cumberland County, Pennsylvania and all improvements at this location. Attached hereto as Exhibit "A" is a plan of the development which depicts Lot 11 subject to this lien and it is incorporated herein by reference. WHEREFORE, Claimant, Mid-Atlantic Materials, Inc., respectfully requests and demands that this Honorable Court lien the above-described property and file theZ_'1?en in the judgment index. DATE: August 8, 2008 By: - v LA L. ILLER Attorney D. #28122 VERIFICATION I, LARRY L. MILLER, hereby state that I am counsel for the Claimant in the within action and that the facts set forth in the foregoing Mechanic's Lien Claim are true and correct to the best of my knowledge. The information set forth in this lien claim was provided by Charles E. Gibson, President of Mid-Atlantic Materials, Inc. Mr. Gibson's verification could not be obtained within the time allowed for filing this document. I understand that the statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Section 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penalties. Date: August 8, 2008 Image Viewer Pa-e I of 1 I Close I ? Print I FMK . • HOW f "Whin EscWtrnre is a Family rrOW&O 1,b 15, '4 FOXWOOD ESTATES 1'7 9 Ili g 3t: 26 23 8 ?5 3CJ 24 3k #r 32 33 35 34 2 3 d 3'1 3$ I 9 __j EXHIBIT A http://www.altierihomes.com/display_image.php?image=./photos/communities/53_comm_plan_photo.jp... 6/19/2008 C-?) P-4 F c' :? .O +Ik r 8 _ ? ern CJ 00 -.t D 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. 08-4818 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 11, Foxwood Boulevard, 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: LA Y L. M LLER At o ney I D. #28122 Attorney for Claimant 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 TO: ALTIERI ENTERPRISES, INC. 9017 Red Branch Road, Ste 201 Columbia, MD 21045 Attorney for Plaintiff: MID-ATLANTIC MATERIALS, INC. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 08-4818 MLD NOTICE OF FILING OF MECHANIC'S LIEN CLAIM You are hereby notified that a mechanic's lien claim in the amount of $3,459.84 has been filed on behalf of Mid-Atlantic Materials, Inc. against the property known as Lot 11, Foxwood Boulevard, 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. 08-4818 MLD on August 11, 2008. A copy of tYet claim is attached. DATE: August 15, 2008 By: f G LARRI L. MILL R Attorey I.D. 28122 0 h P p C= A :ts Cn 1< co Larry L. Miller, Esquire Pa. Supreme Court I.D. No. 28122 1423 State Road Duncannon, PA 17020 Telephone: [7171 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. 09- NO GILD 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 11, Foxwood Boulevard, Foxwood Estates, Mechanicsburg, Cumberland County, Pennsylvania. 4. The Claimant last furnished materials to the project on or about April 18, 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 $3,459.84. 7. The real estate and improvements subject to this mechanic's lien claim consist of all that property known as Lot 11, Foxwood Boulevard, 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 11 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,''lien in the judgment 1 index. ` r (.? ! DATE: August 8, 2008 By: Y L. ILLER Attorney D. #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, penalties. Date: August 8, 2008 I may be subject to criminal ?= (jJ R L . ) MILLER Gose Print F 0) MO) ;? :a FcrmitY Tr?µita?rt.. ^fVi?+y ??rltrncti 15, ,4 EXHIBIT - 6/19/2 •com/ / ? ?unitiesi53 commJl?-•photo'lP••• dis lay image•php?image` /photos/co http://,rw•altieriho ne5 p /, 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 RE: #3645 EMAIL llmmillerlaw@earthlink.net Fax 7179574843 8/15/08 #3645 7184 3875 4490 0000 0394 August 15, 2008 VIA CERTIFIED 8, 1ST CLASS MAIL Altieri Enterprises, Inc. 9017 Red Branch Road, Suite 201 Columbia, MD 21045 Re: Mechanic's Lien Claim; Cumberland County Docket 08-4818 MLD Mid-Atlantic Materials, Inc. v. Altieri Entert)rises. Inc. Lot 11, Foxwood Boulevard, 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, L4ry L. Miller Enclosure __ LARRY L •?MILLER T -E.SQUIR?', ,x MILLER. LAW OFFICES, P.C. 1423 STATE ROAD ;I DUNCANNON, PA 17020 8/14/08.. #3645 A. SignatuLow.) (OAddressee or ?Agent) B. Received-8y: (Please Print Clearly) A$*tf"LLKUTT C. Date of Delivery AUG 18 2008 f- I D.Addressee's Address(MDNMnntF..Addnas UaadbySanday zV) -d o v7 ? Secondary Address /Suite /?,4pt. I Floor Please Pnnf Clearly) v KS? W i1'i ' ° `? K Z 0 q ? I . ..... .. .............................................................. Delivery Address Uv ? WA U) a ? Wig - + °D m W K ----------------------------------------------- Cit C T G C W 7 Q J O y State ZIP + 4 Code A J m 3 a ifi v W a 912 C ~ LL ----- 0 --^_ a i O -,T__ -_- EXHIBIT A 4. Restricted Deli' gy?, "x SitVice Type 1 (Extra Fee) E]Yes CERTIFIED I 2. Article Number 7184 3875 4490 0000 0394 11111111111111111111111111111111111111111 7184 ,,,s 4490 0000 0394 1. Article Addressed To: ALTIERI ENTERPRISES, INC. 9017 RED BRANCH ROAD, SUITE 201 COLUMBIA MD 21045 7 .000 600, 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: i 7