HomeMy WebLinkAbout09-3806ABRAHAM LAW OFFICES
45 East Main Street, Hummelstown, PA 17036
(717) 566-9380
LAPORTE PAINTING, INC.
Plaintiff/Claimant
V.
INSITE DEVELOPMENT, LLC
d/b/a INSITE DEVELOPMENT
Defendant/Owner
: IN THE COURT OF COMMON PLEAS
: DAUPHIN COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - MECHANIC'S LIEN
NOTICE OF MECHANIC'S LIEN
To: INSITE Development, LLC
1943 Monterey Drive
Mechanicsburg, PA 17050
You are hereby notified that on June 9, 2009 a Claim Of Mechanic's Lien
in the amount of Seventy One Thousand Seven Hundred Fifteen ($71,715.00) Dollars,
was filed on behalf of the above-referenced Plaintiff/Claimant, against the improvements
and property located at 2055 Technology Parkway, Mechanicsburg, Pennsylvania, 17055,
Lot No. 5 of the Cumberland Technology Park, tax parcel number 10-14-0839-023, in
the Court of Common Pleas, Cumberland County, Pennsylvania in the above-captioned
action and at the above-referenced docket number, a copy of which is attached hereto.
ABRAHAM LAW OFFICES
James W. Abraham, Esquire
45 East Main Street
Hummelstown, PA 17036
(717) 566-9380
Attorney for Plaintiff/Claimant,
DATE: 6/9/09 LaPorte Painting, Inc.
a
LAPORTE PAINTING, INC. : IN THE COURT OF COMMON PLEAS
Plaintiff/Claimant : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.
INSITE DEVELOPMENT, LLC : CIVIL ACTION - MECHANIC'S LIEN
d/b/a INSITE DEVELOPMENT
Defendant/Owner
CLAIM OF MECHANIC'S LIEN
AND NOW, comes Plaintiff/Claimant, LaPorte Painting, Inc., by and through its
attorney, Abraham Law Offices, Hummelstown, Pennsylvania, and files the following:
1. Plaintiff/Claimant, LaPorte Painting, Inc. (hereinafter "LaPorte") is a
Pennsylvania corporation whose main office is located at 951 Peiffers Lane, Harrisburg,
Dauphin County, Pennsylvania.
2. Defendant/Owner, Insite Development, LLC d/b/a Insite Development
(hereinafter "Insite"), is a limited liability company, whose principal place of business
and/or address is 1943 Monterey Drive, Mechanicsburg, Cumberland County,
Pennsylvania, 17050.
3. According to the deed and land records of the Office of Recorder of Deeds,
Cumberland County, Pennsylvania, specifically Deed Book 279, Page 396 of said
records, Defendant/Owner is the owner of the land and/or structures of Lot No. 5, in the
Cumberland Technology Park, 2055 Technology Parkway, Mechanicsburg, Cumberland
County, Pennsylvania (hereinafter "the Property"), under construction to be a Comfort
Inn hotel.
4. LaPorte contracted with Insite and was authorized by Insite to provide labor
and materials for interior and exterior commercial painting of the Property, which is a
new hotel and adjoining parking garage and to provide and install thousands of yards of
vinyl wall covering and the last day of work by LaPorte at the Property was May 27,
2009.
5. The costs of the aforesaid labor and materials provided by LaPorte to the
Insite at the Property totaled One Hundred Eighty Four Thousand One Hundred Seventy
Seven ($184,177.00) Dollars, and the amount of Seventy One Thousand Seven Hundred
Fifteen ($71,715.00) Dollars remains unpaid by Insite and is due to LaPorte.
6. LaPorte hereby certifies that the address of the Property, specifically:
2055 Technology Parkway
Lot 5, Cumberland Technology Park
Mechanicsburg, PA 17055
which deed to the Property is recorded at Deed Book 279, Page 396 in the Office of
Recorder of Deeds, Cumberland County, Pennsylvania, tax parcel number 10-14-0839-
023, is the true and correct address upon which this Mechanic's Lien is to be placed.
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WHEREFORE, Plaintiff/Claimant, LaPorte Painting, Inc. hereby respectfully
requests that a Mechanic's Lien be placed against the Property in the amount of Seventy
One Thousand Seven Hundred Fifteen ($71,715.00) Dollars, as well as any other relief
the Court may deem proper.
Respectfully submitted:
James W. Abraham, Esquire
Abraham Law Offices
45 East Main Street
Hummelstown, PA 17036
(717) 566-9380
Attorney for Plaintiff/Claimant
LaPorte Painting, Inc.
DATE: 6/9/09
. , . k ? . .
VE?F? A?I?N
I, Vincet j. LaPorte the undersigned, hereby verify and confirm that I have reviewed
the foregoing document and the statements made therein are true and correct to the best of my
knowledge, information and belief. I further understand that any false statements made herein
are subject to the penalties of 18 P&C.S.A. Section 4904 relating to unsworn falsification to
authorities.
DATE: G/,J/ 0 0 9
Vincent J. LaPorte, Pi
LaPorte Painting, Inc.
Al PD-OFFlICE
OF THE FFOT". ;%!OTA?Y
2009 JUN -9 FM 1: 26
PENNSYW,-!NIA
?A. ?i9 ob Any
'77 75--
NO Ws--s-
Sheriff s Office of Cumberland County
R Thomas Kline ~a~~wxtn nt ~,re~6rrfi Edward L Schorpp
Sheri ~ ~ ~ Solicitor
fix.
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Ronny R Anderson ~ ~~~°*~* Jody S Smith
Chief Deputy ¢~~+e~ or rtes ~~~~~` Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
06/12/2009 12:42 PM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on June 12,
2009 at 1242 hours, he served a true copy of the within Mechanics' Lien Claim, upon the within named
defendant, to wit: Insite Development, LLC, by making known unto Don Erwin, Owner at 2055 Technology
Parkway Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $46.44
SO ANSWERS,
~.a
June 15, 2009
2009-3806
Laporte Painting
v
Insite Development
R THOMAS KLINE, SHERIFF
De ty Sheriff
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