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HomeMy WebLinkAbout08-5139IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SII,VER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 . Plaintiff, No.: Og - S~~ MLD vs. RAYMOND PROZOIC and HARVEY J. CASSELL 2 RASPBERRY DRIVE MECHANICSBURG, PA 17050 PARCEL# 38-21-0289-020P Defendants MU1yICIPAL CLAIM FOR SEWER RATES TO: PROTHONOTARY SIl2/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 Raymond Prozoic and Harvey J. Cassell. 5. The property against which this claim is filed is known and numbered as 2 Raspberry Drive, Silver Spring Township, 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 Apri113, 2007 to and including the present. Rental. Penalties, Interest, Collectio AS OF Aueust 22.2008 Sewer Rents through 2"d Quarter 2008 Penalties through March 4, 2009 Sheriff Sale Attorney' Fees through March 4, 2009 Sheriff Sale Court Costs and Fees through March 4, 2009 TOTAL: n Fee and Costs $ 825.30 $ 92.35 $ 4,165.00 1 594.00 $ 6,676.65 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, S~VIITH, DIF~,'~ERICK & Scott ietten~k, Esquire Attorn y for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, . vs. RAYMOND PROZOIC and HARVEY J. CASSELL 2 RASPBERRY DRIVE MECHANICSBURG, PA 17050 PARCEL# 38-21-0289-020P Defendants. CIVIL DIVISION No.. MLD 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 22°d day of August, 2008, via First Class U. S. Mail, Postage Pre- paid: Raymond Prozoic 2 Raspberry Drive Mechanicsburg, PA 17050 Harvey J. Cassell 6160 Springford Drive, Apt. C-6 Harrisburg, PA 17111 JAMES, By: Attorney LD. #556g P.O. Box 650 Hershey, PA 17033 (717) 533-3280 & CONNELLY, LLP ~ ~ ~ C c n r.~ ~~ ~, ~' ~ ~ ` J ~ V '~ r '~",; t -~ ~ + -- -T .. - ~} w°°" ti` , ~