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HomeMy WebLinkAbout09-1701CUMBERLAND-FRANKLIN JOINT MUNICIPAL AUTHORITY, Plaintiff v. INDIAN SPRINGS ASSOC. LLC, Defendant IN THE COURT OF COMMON PLEAS OF FRANKLIN COUNTY, PENNSYLVANIA NO. 09- ~ 7 D ~ MLD MUNICIPAL LIEN MUNICIPAL LIEN Cumberland-Franklin Joint Municipal Authority files its claim in the amount of Thirteen Thousand Six Hundred and 45/100 ($13,600.45) Dollars, plus costs and late charges of Two Thousand Forty and 07/100 ($2,040.07) Dollars, for a total due of Fifteen Thousand, Six Hundred Forty and 52/100 ($15,640.52) Dollars as of January 31, 2009 and sets forth in support thereof the following: 1. Claimant is Cumberland-Franklin Joint Municipal Authority, Cumberland and Franklin Counties, Pennsylvania, with its principal ofFce located at 725 Municipal Drive, Shippensburg, Franklin County, Pennsylvania, 17257. 2. Bob Erwin is the authorized representative and part owner of Indian Springs Assoc. LLC, owner of the property against which this Municipal Lien is filed. Mr. Erwin's last known address is 242 West Chocolate, Hershey, PA 17033. 3. The property against which this Municipal Lien is filed is all that tract of land with improvements thereon situated on Kline Road, in the Township of Southampton, County of Cumberland, Commonwealth of Pennsylvania, being known as Indian Springs Manor Mobile Home Park, Shippensburg, Pennsylvania, 17257. 4. The authority under which this Lien is filed is the Municipal Claims Act of 1923, P.L. 207, as amended (53 P.S. §7101, et seq). 5. This Municipal Lien is filed to secure an interest for unpaid sewer rents levied, assessed or established for the period through November 30, 2008. 6. The sewer rentals were duly established, levied, and assessed by the Cumberland-Franklin Joint Municipal Authority, being the lawful authority for doing so under the several Acts of Assembly of the Commonwealth of Pennsylvania which govern such matters, and were levied, established and assessed for the purpose of providing sewer service to the properties of said Township. WHEREFORE for all the above reasons, Cumberland-Franklin Joint Municipal Authority hereby does place a lien against the said property in the amount of $15,640.52. ~~-~~05 Date Respectfully Submitted TURD LAW OFFICES ~~.--~ J s M. Robi n, Esquire 2 outh Pitt teat Carlisle, PA 17013 (717) 245-9688 Supreme Court ID #84133 Authority Solicitor CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Municipal Lien, upon the defendant, by depositing same in the United States Mail, first class mail, postage prepaid, on the 18"' day of March, 2009, from Carlisle, Pennsylvania, addressed as follows: Indian Springs Assoc. LLC c% Bob Erwin 242 West Chocolate Hershey, PA 17033 RESPECTFULLY SUBMITTED, TURO LAW OFFICES Ja a M. Robi n, Esquire 28 uth Pitt rest Carlisle, PA 17013 (717) 245-9688 Supreme Court ID #84133 Authority Solicitor "9 \~l I - ` d ~ ~ W es ` V W W ) C 1 d rv c":~ ~' ~~ ~ ..n ,_ . ; ~ ~ --t ~~ E `e+4 ~ . . ~~ .- y.n~ ~ W ' "'~ s . ,~ - ,3 C. -r` w \~,. 4 4~ ~ ~ ~V _ ~r '\ CUMBERLAND-FRANKLIN JOINT MUNICIPAL AUTHORITY, Plaintiff V. INDIAN SPRINGS ASSOC. LLC, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-1701 NO. 2009-2640 : MUNICIPAL LIEN PRAECIPE MLD CIVIL TERM ?5 -.6 ?a Please satisfy, settle, withdraw and discontinue the above-captioned matter on behalf of the Plaintiff. Respectfully Submitted, TURO ROBINSON ATTORNEYS AT LAW it 3 II _ Date ,Japes M. Robi on, Esquire t?arlisle, South Pitt treet PA 17013 (717) 245-9688 Supreme Court ID # 84133 Authority Solicitor Ck+ e. s_7/