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HomeMy WebLinkAbout09-7615IN 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. CIVIL DIVISION : No.: O'9- fl(D15 MLD RONALD L. CONAWAY, II and KIMBERLY CONAWAY 5 LOCUST CIRCLE MECHANICSBURG, PA 17050 PARCEL# 38-21-0291-028 Defendants. MUNICIPAL CLAIM FOR SEWER RATES TO: PROTHONOTARY SIR/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 Ronald L. Conaway, 11 and Kimberly Conaway. ti 5. The property against which this claim is filed is known and numbered as 5 Locust Circle, 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 March 30, 2009 to and including the present. Rental, Penalties, Interest, Collection Fee and Costs AS OF November 3. 2009 and/or June 2. 2010 Sewer Rents through 4th Quarter 2009 Billing $ 376.05 Penalties through June 2, 2010 Sheriff Sale $ 82.24 Attorney' Fees through June 2, 2010 Sheriff Sale 3,465.00 TOTAL: $ 3,923.29 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, SA#TH, DIETTERICK & By: S A. Dietterick, Esquire Attorney for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 . a 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. RONALD L. CONAWAY, II and KIMBERLY CONAWAY 5 LOCUST CIRCLE MECHANICSBURG, PA 17050 PARCEL# 38-21-0291-028 Defendants. CERTIFICATE OF SERVICE CIVIL DIVISION No.: MLD The undersigned hereby certifies that a true and correct copy of the Municipal Claim for Sewer Rents was served on the following this 3`d day of November, 2009, via First Class U. S. Mail, Postage Pre-paid: Ronald L. Conaway, II Kimberly Conaway 5 Locust Circle Mechanicsburg, PA 17050 I: IETTERICK & CONNELLY, LLP Scott A. Dietterick, Esquire Attorney I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 ARY 1009 Nov - 4 PH 2:50 Cum, $!Q .oo po AM ? a aa49 ? I)o-h d'C P" d i~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, No.: 09-8144 Civil vs. . No.: 09-7615 MLD RONALD L. CONAWAY, II and KIMBERLY CONAWAY 5 LOCUST CIRCLE MECHANICSBURG, PA 17050 PARCEL# 38-21-0291-028 Defendants. PRAECIPE TO SATISFY MUNICIPAL LIEN TO THE PROTHONOTARY: SIR/MADAM: Please mark the Municipal Lien filed at the above -captioned term and number satisfied. r. ., ~, ~~ i N C'l r V. t ~~ :~ u Z t,e„ c~ O ;~ L 2 ° v By: ~ ~.o~~~ A~-~j e~*+ S~r3s rte- ~3 s z39 Attorney 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 CIVIL DIVISION 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 . Plaintiff, No.: 09-8144 Civil vs. RONALD L. CONAWAY, II and KIMBERLY CONAWAY 5 LOCUST CIRCLE MECHANICSBURG, PA 17050 PARCEL# 38-21-0291-028 . No.: 09-7615 MLD Defendants. CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the Praecipe to Satisfy Municipal Lien was served on the following this 26th day of February, 2010, via First Class U. S. Mail, Postage Pre-paid: Ronald L. Conaway, II Kimberly Conaway 5 Locust Circle Mechanicsburg, PA 17050 Respectfully Su itted• JAMES, SM , ~~~TERICK & CONNELLY, LLP By: Scott A. ~ietterick, Esquire Attorney I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280