HomeMy WebLinkAbout04-1745ROBERT B. COLLINS d/b/a COLLINS
CONTRACTING GROUP,
CLAIMANT
LEE A, WOODALL d/b/a LEE
WOODALL'S ESCAPE FITNESS and/or
LEE WOODALL ENTERPRISES,
OWNER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MECHANICS LIEN CLAIM
Claimant, Robert B. Collins, d/b/a Collins Contracting Group, through the undersigned
counsel, files this claim against the improvements and property at Gateway Drive, Hampden
Township, Cumberland County, Pennsylvania, for the payment ora debt due to Claimant as a
contractor for labor and materials furnished by Claimant in the demolition and alteration of the
improvements. In support of the claim, the Claimant makes the following statement:
1. The leasehold owner of the property is Lee A. Woodall, d/b/a Lee Woodall's
Escape Fitness and/or Lee Woodall Enterprises, with an address at 21 West Mulberry Hill Road,
Carlisle, Pennsylvania 17013.
2. The improvement and the property which are subject to this claim are a certain
18,500 square foot section ora retail strip shopping center known as Gateway Square located at
Gateway Drive, Hampden Township, Cumberland County, Pennsylvania, being a portion of the
premises owned by Gateway Square Association, LLC, pursuant to a certain deed recorded in
Deed Book 127 at page 62 in the Recorder of Deeds Office of Cumberland County,
Pennsylvania.
3. The labor and materials for which the debt is due were furnished pursuant to an
oral agreement with said leasehold owner, under which contractor was to be paid for time and
materials furnished by it and its subcontractors at their standard rates and the prices paid by them
for the materials, plus a reasonable percentage. A copy of the contractor's final invoice dated
February 26, 2004, addressed to said leasehold owner is attached as Exhibit "A".
4. The Claimant completed his work at the preperty on February 19, 2004, which is
less than four months before the filing of this claim.
5. Claimant has been paid $4,106.27 toward the debt due Claimant for the stated
labor and materials and there is due and owing a balance of $18,690.70 for which claim is made
of $18,690.70, plus reasonable attorneys fees and costs.
DATE
Respectfully submitted,
ROBERT P. KLINE, ESQUIRE
714 Bridge Street
Post Office Box 461
New Cumberland, PA 17070-0461
(717) 770-2540
Attorney for Robert B. Collins d/b/a Collins
Contracting Group
COLLINS CONTRACTING GROUP
1101 Lindham Court
Bldg. #502
Mechanicsburg, PA. 17055
Lee Woodall
Lee Woodalls' Escape Fimess
21 West Mulberry Hill Road
Carlisle, Pa. 17013
Final Invoice
02/26/2004
Roll-off and debris
Equipment
Mater/als
Labor
Labor - Rob
TOTAL
Received 01/08/04
Received 02/10/04
Total due
Net 10 days
$ 6486.10
$ 2204.53
$ 251.34
$ 5575.O0
$ 8280.00
$ 22796.97
$ 2076.27
$ 2030.0O
$18690.70
CC:RPK,Esq.
EXHIBIT "A"
VERIFICATION
I verify that the statements made in the foregoing Mechanics Lien Claim are true and
correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unswom falsification to authorities.
Date
ROBERT B. COLLINS
SHERIFF'S
CASE NO: 2004-01745 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COLLINS ROBERT B DBA COLLINS
VS
WOODALL LEE A DBA LEE WOODALLS
RETURN - REGULAR
CHIEF DEPUTY RONNY ANDERSON , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within MECH~NICS LIEN CLAIM was served upon
WOODALL LEE A DBA LEE WOODALLS ESCAPE FITNESS/LEE WOODALL EN the
OWNER , at 1546:00 HOURS, on the 26th day of April , 2004
at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
LEE A WOODALL
a true and attested copy of
by handing to
MECHANICS LIEN CLAIM
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs':
Docketing 18.00
Service .00
Affidavit .00
Surcharge 10.00
.00
28.00
Sworn and Subscribed to before
me this ~9~ day of
~ A.D.
~ ~Prothonotary '
So Answers:
R. Thomas Kline