HomeMy WebLinkAbout09-8928'V
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KINSLEY CONSTRUCTION, INC.,
V.
Claimant
LIT INDUSTRIAL LIMITED PARTNERSHIP,
Owner
No. 6/ - Rl d- 0, t4LD
Mechanics' Lien Claim
NOTICE OF FILING MECHANICS' LIEN CLAIM
To: LIT Industrial Limited Partnership
2650 Cedar Springs Rd., Suite 850
Dallas, TX 75201-1491
TAKE NOTICE that Kinsley Construction, Inc., filed a Mechanics' Lien Claim against
premises owned by you situate in South Middleton Township, Cumberland County,
Pennsylvania, identified as parcel 40-08-0579-019, and known as 70 and 90 Logistics Drive,
Carlisle, PA 17013.
Said Mechanics' Lien Claim is for the sum of $534,470.14, plus interest as allowed by
law, and costs of suit.
1
Said Mechanics' Lien Claim was filed in the Court of Common Pleas of Cumberland
County, Pennsylvania, to No. and was filed on December 31, 2009. A copy of
said Claim is attached hereto.
BARLEY SNYDER
By:
Paul WG Mi+i h
100 East Market Street
P.O. Box 15012
York, PA 17405-7012
717-846-8888
Fax: 717-843-8492
E-Mail: pminnich@barley.com
PA 74453
Attorneys for Claimant
2783888
2
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KINSLEY CONSTRUCTION, INC.,
V.
Claimant
LIT INDIJ STRIAL LIMITED PARTNERSHIP,
Owner
No. o y., gyrd__6--- M
Mechanics' Lien Claim
MECHANICS' LIEN CLAIM
Kinsley Construction, Inc., by and through its undersigned counsel, files the following
Mechanics' Lien Claim:
1. The Claimant is Kinsley Construction, Inc., a Pennsylvania corporation which has
a principal office and place of business at 2700 Water Street, York, York County, Pennsylvania
17403. Claimant files this Lien as a Sub-Contractor.
2. The owner of the real estate against which this claim is filed is LIT Industrial
Limited Partnership, a Delaware limited partnership registered to do business in Pennsylvania
which has a principal office and place of business at 2650 Cedar Springs Rd., Suite 850, Dallas,
Texas 75201.
3. Claimant's last day of work was June 30, 2009.
4. The party with whom Claimant contracted was ING Clarion Partners, 3141 Hood
Street, Suite 700, Dallas, TX 75219, whose present address is 2650 Cedar Springs Rd., Suite
850, Dallas, TX 75201.
1
The labor and material supplied by Claimant accorded with the Fixed Price
Design/Build Construction Services Contract between ING Clarion Partners and Claimant, with
an effective date of January 18, 2008 (Contract). The relevant excerpts from the Contract are
attached and made a part hereof as Exhibit A.
6. The general nature and character of the labor and materials furnished by Claimant
included the construction of a 575,000 square foot tiltwall, steel frame warehouse and office
facility, all as more fully set forth in the Contract.
7. The amount claimed to be due is $534,470.14, as shown on the Accounts
Receivable Aged Analysis attached and made a part hereof as Exhibit B, plus interest and costs
of collection.
Notice of Claimant's intent to file the within Mechanics' Lien Claim was mailed
on November 23, 2009, a true and correct copy of which is attached and made a part hereof as
Exhibit C.
9. The real property subject to the lien is situate in South Middleton Township,
Cumberland County, Pennsylvania, known as 70 and 90 Logistics Drive, Carlisle, Pennsylvania,
and identified as Parcel 40-08-0579-019 in the Cumberland County records. Said real property
is further described in the Deed dated December 19, 2007, and recorded in the Office of the
recorder of Deeds of Cumberland County, Pennsylvania in Deed Book 2007, page 47518, a true
and correct copy of which is attached and made a part hereof as Exhibit D.
2
WHEREFORE, Claimant, Kinsley Construction, Inc., claims to have a lien upon the
premises herein described in the sum of $534,470.14, plus interest as allowed by law, and costs
of suit.
BARLEY SNYDER LLC
By: Z// /
Paul i i
100 East Market Street
P.O. Box 15012
York, PA 17405-7012
717-846-8888
Fax: 717-843-8492
E-Mail: pminnich@barley.com
PA 74453
Attorneys for Claimant
2783888
VERIFICATION
I, Jerry L. Caslow, Vice-President-Finance of Kinsley Construction, Inc., hereby verify
that the facts set forth in the foregoing Mechanics' Lien Claim are true and correct to the best of
my knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S.A. §4904 relating to unswom falsification to authorities.
Dated: f 7 3 0
erry L. Caslow
E? A
Tr???I
7 i3--<-7
FIXED PRICE DESIGN/BUILD
CONSTRUCTION SERVICES CONTRACT
by and between
ING CLARION PARTNERS
3141 Hood Street
Dallas, TX 75219
as Owner
and
Kinsley Construction, Inc.
2700 Water Street
York, Pennsylvania 17403
as Design/Builder
for a 575,000 sf concrete tiltwall, steel frame warehouse and
office facility located in South Middleton Township, PA
O01?\NP1.
FIXED PRICE DESIGN/BUILD
CONSTRUCTION SERVICES CONTRACT
This Fixed Price Design/Build Construction Services Contract ("Contract") is made, effective as of the 1 e day of
January, in the year 2008, by and between:
the Owner: ING Clarion Partners
(Name and address) 3141 Hood Street, Suite 700
Dallas,.Texas 75219
Attn: John Clinton
and the Design/Builder: IUnsley Construction, Inc.
(Name and address) 2700 Water Street
York, PA 17403
Attn: Rich Ness
For the Project known as: An approximately 575,000 sf single story concrete flit wall steel frame
(Name and location) warehouse and office facility located on a 41.3 acre site In South Middleton
PA.
For the Contract Price of: $14, 805,784.00
And Shall be Substantially Complete: By November 3, 2008, as such date may be adjusted pursuant to this
Contract.
The Owner and Design/Builder agree as set forth below.
Fbmd Price Design/Build Agreement Page 1
November 2007
IN WITNESS WHEREOF, the parties hereto have executed this Contract effective as of the date and year first above
written.
KINSLEY CONS UCTION, INC.
By:
N e: Jonathan R. Kinsley
ING CLARION PARTNERS:
By: SEE ATTACHMENT
Name: John M. Clinton
Title: President
Date: P
Title: Vice President -Development Manager
Date:
1 407 A&
Fixed Price DesigrAkAd Agreement Pepe 50
November 2007
LIT INDUSTRIAL TEXAS LIMITED
PARTNERSHIP, a Delaware limited
partnership
By: LIT-FTGP, L.L.C., a Delaware limited
liability company, its general partner
By: LIT Industrial Limited Partnership, a
Delaware limited partnership, its sole
member
By: LIT Holdings GP, LLC, a Delaware
limited liability company, its sole
general partner
By: Lion Industrial Properties, L.P., a
Delaware limited partnership, its sole
member
By: LIT GP Sub, LLC, a Delaware limited
• liability company, its sole general
partner
By Lion Industrial Tract, a Maryland real
estate investment trust, its sole
m ber m
By.
Name: ohn M. Clinton
Title: Development Manager V.P.
0
AR Aged Analysis By Customer and Contract
Age On: Due Date Through Month: 12/09 Aging Date: 12/31/09
Include Invoices Through: All Dates Other Trans Through: 12/31/09
Receivable Types: All Deduct Discounts? N
Invoice DusDate Total Aged Future Current 31-60 61-90 Over 90 Retalnage
Customer: 5900 ING CLARION PARTNERS Contact
Last Payment: Date: 11/17/09 Phone:
Contact : 71307- EXEL ROYER LOT 4
29875 08/30/09 JBApp#18 161,285.01 161,285.01
29875 08130/09 Released Retainage 105,950.06 105,950.06
30057 09130/09 JB App #19 15,406.01 15,406.01
30057 09/30109 Released Retainage 251,829.06 251,829.06
Total For Contract: 71301- 534,470.14 0.00 0.00 0.00 0.00 534,470.14 0.00
Total Aged + Retain: 534,470.14
Total For Customer: 5900 534,470.14 0.00 0.00 0.00 0.00 534,470.14 0.00
Total Aged + Retain: 534,470.14
Total For Company: 10 534,470.14 0.00 0.00 0.00 0.00 534,470.14 0.00
Total Aged + Retain: 534,470.14
Note: ` Indicates partial payments for the invoice.
10 KINSLEY CONSTRUCTION INC. Page 1 12131109 09:31:54 AM
Date Format - MM/DD/YY ARAgeNewCustCont.rpt
EXHIBIT C
K1r1SLE?,F,J1
CONSTRUCTIONII41Direct Extension: (717) 741-8415
bsarde11a@r1dns1ey.com
VIA CERTIFIED MAIL NO. 7007 0220 0002 0815 2673
November 23, 2009
LIT Industrial Limited Partnership
Clarion/ ING Lion Industrial Trust
2650 Cedar Springs Rd., Suite 850
Dallas, TX 75201
Re: Notice of Claim under Mechanics' Lien Law of 1963
Property: 70 and 90 Logistics Drive, South Middleton Township,
Cumberland County, Pennsylvania
Dear Sir/ Madam:
This is formal notice of a claim by a subcontractor for certain work and services
performed as follows:
1. Name of party claimant: Kinsley Construction, Inc. ("Subcontractor").
2. Name of person with whom Subcontractor contracted: ING Clarion Partners,
3141 Hood Street, Suite 700, Dallas TX 75219.
3. Amount claimed to be due: $534,470.14 plus interest at the prime rate of interest
from August 30, 2009 and all costs of collection.
4. General nature and character of labor and materials furnished: Construction of
575,000 SF concrete tiltwall, steel frame warehouse and office facility.
5. Date of completion of work: June 30, 2009.
6. Property claimed to be subject to the lien: 70 and 90 Logistics Drive, South
Middleton Township, Cumberland County, Pennsylvania, more particularly
described in the enclosure.
Very truly yours,
O STRUCTION, INC.
CZ a e la
General Counsel
cc: ING Clarion Partners
2700 Water Street • P.O. Box 2886 9 York, PA 17405 • (717) 741-3841 • Fox (717) 741-9054
¦ Compote ftms 1, 2, and 3. Also oornplste
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Ps Form 3811, February 2004 Domestic Return Ra)W 1026140244-1610
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PREPARED BY:
Squire, Sanders and Dempsey L.L.P.
41 South High Street
Suite 1300
Columbus, Ohio 43215
Attn: H. Cort Doughty, Esq.
RECORD AND RETURN TO:
RETURN T0:
Chicago Title Insurance Co.
1601 Market Street, Ste. #2550
Philadelphia. PA 19103
S,16 7--00 -35-500
Tax Parcel No. (Being a portion of Tax Map No. 40-08-0579, Parcel 008)
SPECIAL WARRANTY DEED
COMMONWEALTH OF PENNSYLVANIA §
§ KNOW ALL MEN BY THESE PRESENTS:
COUNTY OF CUMBERLAND §
EXEL INC., a Massachusetts corporation formerly known as Exel Logistics, Inc. ("Grantor"),
for an in consideration of the sum of $5,227,287.00 and other good and valuable consideration, unto
LIT INDUSTRIAL LIMITED PARTNERSHIP, a Delaware limited partnership, whose tax mailing
address is ClarionANG Lion Industrial Trust, 3141 Hood Street, Suite 700, Dallas, TX 75219
("Grantee'), well and truly paid by the said Grantee, at or before the sealing and delivery hereof, the
receipt whereof is hereby acknowledged, has granted, bargained and sold, released and confirmed, and
by these presents does grant, bargain, sell, release and confirm unto the said Grantee its successors and
assigns, as partnership property for the uses and purposes of said partnership, the real property located
in Cumberland County, Pennsylvania, fully described in Exhibit A hereto, together with all and
singular the improvements, ways, streets, alleys, driveways, passages, waters, watercourses, rights,
liberties, privileges, hereditaments and appurtenances, whatsoever unto the hcrcby grantcd premiscs
belonging, or in any wise appertaining, and the reversions and remainders, rents issues, and profits
thereof, and all the estate, right, title, interest, property, claim and demand whatsoever of the Grantor,
as well at law as in equity, of, in, and to the same (collectively, the "Property").
This Special Warranty Deed and the conveyance hereinabove set forth is executed by Grantor
and accepted by Grantee subject to the matters described in Exhibit B hereto (collectively, the
"Permitted Encumbrances').
COLUMBUS1601583.1
016348.00273
r.
EXHIBIT A
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate north of US Interstate Route 81 and south of
Logistics Drive, in South Middleton Township, Cumberland County, Pennsylvania, and
comprising Lot 4 as shown on the "Revised Final Subdivision And Land Development Plan For
Exel, Inc. - Royer Tract Lot-3 and Lot 4", as prepared by Herbert, Rowland, and Grubic, Inc.,
Project No. 3456.406, dated October 25, 2007, last revised November 30, 2007; said tract being
more fully bounded and described as follows:
BEGINNING at a point on the southern right-of-way line of Logistics Drive (60 foot wide right-
of-way) at the line dividing Lot 3 and Lot 4 of the Exel Subdivision; THENCE by said right-of-
way line North 64 degrees 17 minutes 00 seconds East, a distance of 355.00 feet; THENCE
continuing by a line on a curve to the right having a radius of 270.00 feet, an arc length of 424.12
feet, and a chord bearing of South 70 degrees 43 minutes 00 seconds East, a distance of 381.84
feet to a point on the southwest right-of-way line of Logistics Drive, THENCE by said line South
25 degrees 43 minutes 00 seconds East, a distance of 1441.54 feet; THENCE continuing by a
line on a curve to the right having a radius of 25.00 feet, an are length of 23.83 feet, and a chord
bearing of South 01 degree 35 minutes 43 seconds West, a distance of 22.94 feet; THENCE
continuing by a line on a curve to the left having a radius of 70.00 feet, an arc length of 176.69
feet, and a chord bearing of South 43 degrees 24 minutes 16 seconds East, a distance of 133.38
feet to a point in an emergency access road; THENCE passing through said road South 25
degrees 43 minutes 00 seconds East, a distance of 388.94 feet to a point on the northern right-of-
way line of US Interstate Route 81; THENCE by said line South 86 degrees 57 minutes 00
seconds West, a distance of 1092.43 feet to lands of Robert M. Frey; THENCE by lands of Frey
North 30 degrees 10 minutes 00 seconds West, a distance of 609.07 feet to Lot 3 of the Exel
Subdivision; THENCE by said line the following four (4) courses and distances: (1) North 66
degrees 45 minutes 00 seconds East, a distance of 90.39 feet; (2) THENCE North 25 degrees 43
minutes 00 seconds West, a distance of 779.61 feet, (3) THENCE North 64 degrees 17 minutes
00 seconds East, a distance of 310.00 feet; (4) THENCE North 25 degrees 43 minutes 00
seconds West, a distance of 444.00 feet to a point on the southern right-of-way line of Logistics
Drive, the POINT OF BEGINNING.
Containing 1,802,864 Square Feet or 41.3881 Acres
COLUMeUS6601583.1
016348.00273
EXHIBIT B
PERMITTED ENCUMBRANCES
Possible additional assessment for taxes on any new construction or major improvements
to premises.
2. Taxes and assessments not yet due and payable.
3. Rights granted to Pennsylvania Power and Light Company as more fully set forth in
Miscellaneous Book 228, Page 875.
4. Right of Way Grant to UGI Utilities, Inc. as set forth in Miscellaneous Book 737, Page
2775.
5. Conditions if any, in Plan Book 94, page 40, as superseded by conditions, if any in that
Revised Final Subdivision and Land Development Plan for Exel Inc. filed in the Office of
Recorder of Deeds, Cumberland County, Pennsylvania as Instrument No. 200746577.
6. Covenants, conditions and easements as set forth in that certain Declaration of Covenants
and Restrictions For Phase I of South Middleton Distn'bution Center, dated and recorded
simultaneously herewith in the Office of Recorder of Deeds, Cumberland County,
Pennsylvania.
7. Terms and conditions as set forth in that certain Encroachment Agreement by and
between PPL Electric Utilities Corporation, a Pennsylvania corporation, and Exel Inc., a
Massachusetts corporation, dated and recorded simultaneously herewith in the Office of
Recorder of Deeds, Cumberland County, Pennsylvania.
COWMBUSJ601M.1
01634$.00273
To have and to hold the said Property unto the said Grantee, its successors and assigns, and for
the only proper use and behalf of the said Grantee, its successors and assigns, forever, for the uses and
purposes of Grantee.
AND, the said Grantor, for itself and its successors, does hereby covenant to and with the said
Grantee, its successors and assigns, by these presents, that it, the said Grantor, is successors and
assigns, SHALL AND WILL Warrant and forever defend the Property, with the hereditaments and
appurtenances, unto the said Grantee, its successors and assigns, against the said Grantor and its
successors and against every other person lawfully claiming or who shall hereafter claim the same or
any part thereof, by, from or under it, them, or any of them.
IN WrINESS WHEREOF, the said Grantor has caused these presents to be duly executed, this
day of December, 2007.
SEALED AND DELIVERED,
In the presence of us.
Attest:
STATE OF OHIO
COUNTY OF DELAWARE
This
EXEL MCI
By:
instrument was acknowledged before me on December, 2007, by
the t' E D M rr: C''( S of Exel Inc., a Massachusetts
Kof said corporation.
Sl00 SWETNAM
My a fN'?ot0 Notary Public Wesrrwflc,6,9 of 6--61 ( Ch in
Grantee's address is: 3141 Hood Street, Suite #700, Dallas, TX 75219
U.
On Behalf of Grantee
COLUMBUS/601583.1 2
016348.00273
s*
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number - 200747518
Recorded On 12127/2007 At 12:08:52 PM
* Instrument Type - DEED
Invoice Number -11458 User ID - KW
* Grantor - EXEL INC
* Grantee - LIT INDUSTRIAL. L P
* Customer - CHICAGO TITLE INSURANCE CO
* FEES
STATE TRANSFER TAX
STATE WRIT TAX
STATE JCS/ACCESS TO
JUSTICE
RECORDING FEES
RECORDER OF DEEDS
AFFORDABLE HOUSING
COUNTY ARCHIVES FEE
ROD ARCHIVES FEE
SOUTH MIDDLETON
SCHOOL DISTRICT
SOUTH MIDDLETON
TOWNSHIP
TOTAL PAID
$52,272.87
$0.50
$10.00
$11.50
$11.50
$2.00
$3.00
$26,136.44
$26,136.43
$104,584.24
Certification Page
DO NOT DETACH
This page is now part
of this legal document.
I Certify this to be recorded
in Cumberland County PA
oM
?' 110 JAA
RECORDER O DS
- Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
* Total Pages - 5
OwLM
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
FILES :fir; i~;~=
Edward L Schorpp
Solicitor
1Q10 JA~i I ~ ~~~ fQ~ ~~
V~h~~` ~.f€..~i0.`~i~s
Kinsley Construction Inc.
vs.
LIT Industrial Limited Partnership
Case Number
2009-8928
SHERIFF'S RETURN OF SERVICE
01/12/2010 02:00 PM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on January
12, 2010 at 1400 hours, he served a true copy of the within Notice of Filing Mechanics' Lien Claim and
Mechanics' Lien Claim, upon the within named defendant, to wit: LIT Industrial Limited Partnership, by
making known unto Scott Foulds, Operations Manager at 70 & 90 Logistics Drive, Carlisle, Cumberland
County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and
correct copy of the same.
SHERIFF COST: $33.84
January 13, 2010
SO ANSWERS,
O NY R ANDERSON, SHERIFF
~'
1Je ty Sheriff
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2D 10 JT,t'~ 2 0 ~, ~ ~~ ~ ~ ,;
IN THE COURT OF COMMON PLEAS OF CUMBERLAND.-~(O~%Y;",,;1~, ~
PENNSYLVANIA
x1N5Lt/Y CONSTRUCTION, INC.,
Claimant
v.
LIT INDUSTRIAL LIMITED PARTNERSHIP,
Owner
No. 09-8928
Mechanics' Lien Claim
AFFIDAVIT OF SERVICE
Commonwealth of Pennsylvania
County of York
I, Paul W. Minnich, being duly sworn according to law, depose and state that the
Notice of Filing Mechanics' Lien Claim in the above matter, was served upon LIT
Industrial Limited Partnership, on January 15, 2010, by mailing a true and correct copy of
said Notice of Filing Mechanics' Lien Claim by certified mail, return receipt requested,
restricted delivery, addressed to LIT Industrial Limited Partnership, as follows:
LIT Industrial Limited Partnership
2650 Cedar Springs Road, Suite 850
Dallas, TX 75201-1491
The return receipt card evidencing receipt of the Notice of Filing Mechanics' Lien
Claim by LIT Industrial Limited Partnership is attached and made a part hereof as Exhibit
A.
Sworn and subscribed to
before me this 20th day
of January, 2010.
Paul W i
,r
tary Public
2799501
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Debra D. Bankert, Notary Public
Gity of York, York County
My Commission Expires April 1, 2012
Member, Pennsylvania Association of Notaries
EXHIBIT A
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~ER*~ ILt~ItltJt~tIJII~t~~~Jl~ttILL~IItL~~ttlll
LIT Industrial Limited Partnership
2650 Cedar Springs Road
Suite 850
L8b8~ #1 Dallas, TX 75201-1491
Paul W. Minnich, Esquire
Barley Snyder, LLC
Label ~ 100 East Market Street
P.O. Box 15012
York, PA 17405
Paul W. Minnich, Esquire
Barley Snyder, LLC
100 East Market Street
Label #3 P.O. Box 15012
York, PA 17405
FOLD AND TEAR THIS WAY-- OPTIONAL
LIT Industrial Limited Partnership
'rQ; 2650 Cedar Springs Road
Suite 850
Dallas, TX 75201-1491
Z
_ _ ~ SENDER: Paul W. Minnich, Esquire ''
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z REFERENCE: Kinsley v. LIT Ind.
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.~ Total Postage & Fees 6
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Date Produced: 01/18!2010
WALZ CERTIFIED MAIL SOLUTIONS LLC
The following is the delivery information for Certified MaiIT"" item number 7160 3820 3530
0591 9462. Our records indicate that this item was delivered on 01/15/2010 at 02:43 p.m. in
DALLAS, TX, 75201. The scanned image of the recipient information is provided below.
Signature of Recipient:
Address of Recipient
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Sincerely,
United States Postal Service
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNS LVANIA
KINSLEY CONSTRUCTION, INC.,
v.
Claimant
LIT INDUSTRIAL LIMITED PARTNERSHIP
Owner
Mechanics' Lien Claim
M.K.
No. 09-8928 MLD
PRAECIPE TO REMOVE
To the Prothonotary:
Please mark the above captioned Mechanics' Lien Claim settled and satisfied.
BARLEY SNYDER LLC
By:
au i
100 Eas Market Street
P.O. Box 15012
York, PA 17405-7012
717-846-8888
Fax:717-843-8492
E-Mail: pminnich@barley.com
PA 74453
Attorneys for Claimant
2838178
CERTIFICATE OF SERVICE
I hereby certify that on this date a true and correct copy of the foregoing Praecipe to
Remove is being served by first class mail, postage prepaid at York, Pennsylvania, addressed as
follows:
LIT Industrial Limited Partnership
2650 Cedar Springs Road, Suite 850
Dallas, TX 75201-1491
BARLEY SNYDER LLC
By:
Paul W. Mixtni~lt,~
100 East arket Street
P.O. Box 15012
York, PA 17405-7012
717-846-8888
Fax: 717-843-8492
E-Mail: pminnich@barley.com
PA 74453
Attorneys for Claimant
.~~~/,~