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HomeMy WebLinkAbout08-4820 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. y0 - A1811) MLD 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 29, Hunt Place, 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 $4,463.38. 7. The real estate and improvements subject to this mechanic's lien claim consist of all that property known as Lot 29, 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 29 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 li.6n /in the ju gment index. DATE: August 8, 2008 By: r` LARR LER Attorney I.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 Imag Viewer Page 1 of 1 Close Print =ALLM RJl*' H =OW "ahem .ExAvIlorm it a Fcr a ly Tiut tttt)rt" FOXWOOD ESTATES ho !9 ^ 1 s 2G` 26 j 32 33 36 d 30 EXHIBIT A http://www.altierihomes.com/display_image.php?image=./photos/communities/53_comm_plan_photo.jp... 6/19/2008 O om O ' S a p ?: w a ? r,.? ? C D ? ? 7 ? (. ? _.? J s? ,., i ? - m ?- N ? _3 ..... ..? Larry L. Miller, Esquire Pa. Supreme Court I.D. No. 28122 1423 State Road Duncannon, PA 17020 Telephone: [717] 957.2828 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. 08-4820 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 29, 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: (. LA y L. ILLER Attorney 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. 08-4820 MLD NOTICE OF FILING OF MECHANIC'S LIEN CLAIM You are hereby notified that a mechanic's lien claim in the amount of $4,463.38 has been filed on behalf of Mid-Atlantic Materials, Inc. against the property known as Lot 29, 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 COL on August 11, 2008. A copy of the claim is DATE: August 15, 2008 By: LARRY L. Attorn 'y T aty at No. 08-4820 MLD attached.: ?--- v MILL kR I.D. #28122 Larry L. Miller, Esquire Pa. Supreme Court I.D. No. 28122 1423 State Road Duncannon, PA 17020 Telephone: [717] 541-5225 C7 ;? -Y s (TI 3ti 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. (S - yut) MLI) 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 29, Hunt Place, 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 $4,463.38. 7. The real estate and improvements subject to this mechanic's lien claim consist of all that property known as Lot 29, 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 29 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 index. DATE: August 8, 2008 By: ? LARR)(_.L. ?fIILEk Attorney I. 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 LAkRY L MILLER imugc v rewer Page 1 of 1 Close Print knFERI HOMES "When ?url,crxr ix a Famib, Trodfd ft" d `3 I6 ! / k2 FOXWQOD ESTATES rT 11 R6 . to (o 20 26 5 79 . 30 ? 23 ? 33 32 33 X18 °34 _ 36 1 9 d 3T 38 12r EXHIBIT A http://www. altierihomes.comldisplay_image.php?image=./photos/communitiesl53_comm_plan_photo. j p... 6/19/2008 . (MILLER LAW OFFICES, P.C. Pennsylvania Office New Jersey Office - 1423 State Road Suits 108, 50 Chestnut Ridge Rd. Duncannon, PA 17020 y Montvale, NJ 07645 717 957 2828 ° EMAIL Ilmmillerlaw@earthiink.net Fax 717 957 4843 RE: #3645 8/15/08 #3645 7184 3875 4490 0000 0387 August 15, 2008 VIA CERTIFIED & 1ST CLASS MAIL Altieri Enterprises, Inc. 9017 Red Branch Road, Suite 201 Columbia, MD 21045 Re: Mechanic's Lien Claim; Cumberland County Docket 08-4820 MLD Mid-Atlantic _Materials. _Inc. v. Altieri Enterprises. Inc. Lot 29, 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,' / j Larry L. #iller Enclosure LARIRY L • 'MILLER, ESQUIRE MILLER LAW OFFICES, P.C. 1423 STATE ROAD DUNCANNON, PA. 17020 8/14/08 #3645 A. Sign e: ( Addressee or 0Agent) X S. Recei By: (Please Print Clearly) ASHLEY ALLNUTT C. Date of Delivery At IG 18 2008 4. Restricted Delivery? & Ser vice Type (Extra Fee) [] Yes CERTIFIED 2. Article Number 7184 3875 4490 0000 0387 11111111111111111 11111111111111111111111F __ 7184 3875 449D?? 0387 1. Article Addressed To: i I D. Addressee's Address (nolamemFmmadd,ersusedbysende0 A L T I E R I ENTERPRISES, INC. i 9017 RED BRANCH ROAD, SUITE 201 COLUMBIA MD 21045 2 ? -Secondary Address /Suite /Apt. /Floor (Please Print Clearly) I ^ I c ha ,? to ? W ' Delivery Addrnsa W c ,A E N o aU W^ ?vyt Z ma3 w?¢ I City ..................................... .State ..-....--.ZIP + 4 Code @ Tint) Q G j W 5, _ ?o -9 _ W a 88 R w a d sa- O EXHIBIT A f LL co U_ 0 a ,mop 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: ,_.t ?..? --? - ?? :? t.??, ,_? r ,r} '- _1 !1 3 ?_ t _ ?? ? k.;?