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Home My WebLink About10-7717c ~ -y; '"t7 ~ ca -t ~~ ~ ~~. rn ~ ~~ A "` c~ Mechanic's Lien Claim `~~ ~ ~t~ 49 p.s. § 1503 ~c = ~ ~ COURT OF COMMON PLEAS ,; 'v ~„^, CUMBERLAND COUNTY, PENNSYLVANIA =-~ BIN, Incorporated y) 9 • DD P ~ ~l~ ~ws I~ v. ~aS~y7 ~ Gerald Morten, Chong Huang, or Huang Chong / Chong Hwang / Hwang Chong MECHANIC' S LIEN CLAIM 1. Claimant, BIN Incorporated, a Pennsylvania Corporation with offices at 4209 Cumberland Avenue, Harrisburg, PA 17110, files this mechanic's lien as a subconctractor. 2. The owner or owners of the property subject to lien is /are Gerald Morten and/ or Chong Huang whose address is 5128 Jennifer Circle, Mechanicsburg, PA 17050. 3. The date on which the Claimant completed work for which claim is made was June 20, 2010. 4. Claimant files this claim pursuant to that contract with Dennis Gross dated December 28, 2009 wherein Claimant agreed to provide framing labor, general labor, electrical supplies, materials and labor for their installation and tle supplies and labor for their installation at 5128 Jennifer Circle, Mechanicsburg, PA. 5. Claimant gave formal notce of intent to file a lien claim to owner by first class mail and by priority mail with confirmed delivery to owners' residence on October 23, 2010. 6. The amount claimed to be due is $6,225.00, together with lawful interest from July 5, 2010. The Claimant has no note or other collateral security for the claim. 7. The improvements to the property claimed to be subject to lien are all the improvements and electrical wiring, devices and appurtenances in the addition to the single family dwelling. '3 ~~~ / c ~011M1~4Nt .ION r~ ~3QG~ 30~ /'L//S/Zveo SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ILED-OF rr° r- 19i0OEC27 Ahi!C . ???BERL pENNS ' fQ Crdltl ; d t+'I f BIN, Incorporated Case Number vs. 2010-7717 Gerald Mortell (et al.) SHERIFF'S RETURN OF SERVICE 12/20/2010 05:12 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to December 20, 2010 at 1712 hours, he served a true copy of the within Mechani, within named defendant, to wit: Gerald Mortell, by making known unto hi If p Circle, Mechanicsburg, Cumberland County, Pennsylvania 17050 its co 7to;t s handing to him personally the said true and correct copy of the same. S 2/20/2010 05:12 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, 1 December 20, 2010 at 1712 hours, he served a true copy of the within Mechanics' within named defendant, to wit: Chong Huang, by making known unto hims If pers Circle, Mechanicsburg, Cumberland County, Pennsylvania 17050 its cont n an a handing to him personally the said true and correct copy of the same. states that on ;n Claim, upon the ally, at 5128 Jennifer the same time 11 ,DEPUTY es that on ;laim, upon the at 5128 Jennifer same time ,DEPUTY SHERIFF COST: $53.44 December 21, 2010 SO ANS S, R R ANDERSON, SHERIFF NOTARY Affirmed and subscribed to before me this day of ;ci Cou,um, 5 c B'. T?! eo ^,•t tai;. ILEED-OFF ICS' i F f -6 PM 3: 07 Y Z;IAII //.5 L 7717 G elCk l (-7/7) 7?v ? 3? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 4rxxu ofutnbrf Jody S Smith Chief Deputy t . . w Richard W Stewart Solicitor O=f-E ?,FF BIN, Incorporated vs. Case Number Gerald Mortell (et al.) 2010-7717 SHERIFF'S RETURN OF SERVICE 12/20/2010 05:12 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law tates that on December 20, 2010 at 1712 hours, he served a true copy of the within Mechanics' i n Claim, upon the within named defendant, to wit: Gerald Mortell, by making known unto himself p so ally, at 5128 Jennifer Circle, Mechanicsburg, Cumberland County, Pennsylvania 17050 its co epts avid a the same time handing to him personally the said true and correct copy of the same. /?/ ) DEPUTY 12/20/2010 05:12 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, tes that on December 20, 2010 at 1712 hours, he served a true copy of the within Mechanics' C-l laim, upon the within named defendant, to wit: Chong Huang, by making known unto hims If pers nal y, at 5128 Jennifer Circle, Mechanicsburg,.Cumberland County, Pennsylvania 17050 its cont n an at t same time handing to him personally the said true and correct copy of the same. 1? ,DEPUTY SHERIFF COST: $53.44 December 21, 2010 SO ANS S, R R ANDERSON, SHERIFF ----- ... ...................... - - - Affirmed and subscribed to before me this NOTARY day of ic:, Couo?ysuit€ Shent Te:eoso`t. 6?, . /AR r z413 DEC 20 Pry 1, 2 CUHSERL 1{ND PENNSY-°COUNT Y REAGER& ADLER, P.C. Thomas O. Williams, Esquire Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 Attorneys for Gerald Mortell and Chong Huang BIN, Inc, : IN THE COURT OF COMMON PLEAS OF Claimant, : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 10-7717 MLD Gerald Mortell and Chong Huang, Respondents. • PETITION TO STRIKE OFF MECHANIC'S LIEN CLAIM FOR FAILURE TO COMMENCE ACTION AND NOW, come Petitioners, Gerald Mortell and Chong Huang, by and through their attorneys, Reager & Adler, PC, and submit this Petition to Strike Off Mechanic's Lien Claim, and in support thereof aver the following: 1. Petitioners are, and at all times herein mentioned were, residents of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, and are the owners of the following described premises: 5128 Jennifer Circle, Mechanicsburg, PA 17050. 2. Respondent is, and at all times herein mentioned was, a resident of Harrisburg, Dauphin County, Pennsylvania. 3. On or about December 15, 2010, Respondent, as Claimant, caused to be filed in the Office of the Prothonotary of the Court of Common Pleas of the County of Cumberland, Commonwealth of Pennsylvania, a claim for a Mechanic's Lien against the interest of Petitioners in the above-described real property, a copy of which claim is attached hereto and made a part hereof as Exhibit"A." 4. Respondent/Claimant failed, however, to commence an action to obtain judgment upon the Mechanic's Lien claim within two years of the filing of its lien claim, or on or before December 14, 2012, as required by Act of August 24, 1963, PL 1175,No. 497 § 701(b), Act of December 28, PL 1640, No. 343 § 1; 49 PS § 1701(b), and the lien has not been otherwise discharged or canceled of record. As of the date of this Petition, no Complaint to Obtain Judgment on the Mechanic's Lien has been filed. 5. No previous application has been made for this or any similar Order. 6. Petitioners' undersigned counsel sent a letter to Respondent, dated December 2, 2013, requesting that Respondent's Mechanic's Lien be voluntarily withdrawn given the failure of Respondent to timely file a Complaint to Obtain Judgment on the Mechanic's Lien. A true and correct copy of the aforesaid letter is attached hereto as Exhibit"B." As of the time of this Petition, no response has been received from Respondent or any attorney representing Respondent. WHEREFORE, Petitioners pray that the Mechanic's Lien Claim filed as aforesaid against said real property of Petitioners be stricken, removed, and canceled of record, and that Petitioners have such other and further relief as the Court may deem equitable and proper. REAGER& • 0 LER, P.C. / Date: December 18, 2013 Tho .s O. Williams, Esquire Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 Attorneys for Petitioners 2 EXHIBIT "A" z� C) rnr- Fri -o m Mechanic's Lien Claim :<a Qo 49 ps. §1503 Dpi Z cp c, COURT OF COMMON PLEAS �t�z ry -tm v CUMBERLAND COUNTY,PENNSYLVANIA -�r _=o BIN,Incorporated $ N. OD p°t v. aS.2y7.Z Gerald Mortell,Chong Huang,or Huang Chong/Chong Hwang/Hwang Chong MECHANIC'S LIEN CLAIM 1. Claimant,BIN Incorporated,a Pennsylvania Corporation with offices at 4209 Cumberland Avenue,Harrisburg,PA 17110,files this mechanic's lien as a subcontractor. 2. The owner or owners of the property subject to lien is/are Gerald Mortell and/ or Chong Huang whose address is 5128 Jennifer Circle,Mechanicsburg,PA 17050. 3. The date on which the Claimant completed work for which claim is made was June 20,2010. 4. Claimant files this claim pursuant to that contract with Dennis Gross dated December 28,2009 wherein Claimant agreed to provide framing labor,general labor,electrical supplies,materials and labor for their installation and tile supplies and labor for their installation at 5128 Jennifer Circle,Mechanicsburg,PA. 5. Claimant gave formal notice of intent to file a lien claim to owner by first class mail and by priority mail with confirmed delivery to owners'residence on October 23,2010. 6. The amount claimed to be due is$6,225.00,together with lawful interest from July 5,2010. The Claimant has no note or other collateral security for the claim. 7. The improvements to the property claimed to be subject to lien are all tile improvements and electrical wiring,devices and appurtenances in the addition to the single family dwelling. Respectfu fitted, 411111111 , - gory Woods fir-0S•••• ,, C..E-c. a,iy, 4.., /L r=liararqbawk ilesoratelarnavaikrasen PA .13267 30 01/4,....qc..freee pti--- SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff riL ED n,,,of�tltui6rp,�hm +- Tprpf�p rICEM1 ,,, Jody S Smith Chief Deputy "'KW 291°DEC 27 A T" Richard W Stewart M(Q: 3q Solicitor OFFICE OF THE St?ERIFF C(J BER PIL[Ei7GGN LAND h 1 iU L. BIN, Incorporated Case Number vs. 2010-7717 Gerald Mortell (et al.) SHERIFF'S RETURN OF SERVICE 12/20/2010 05:12 PM-Shawn Harrison, Deputy Sheriff,who being duly sworn according to law states that on December 20,2010 at 1712 hours, he served a true copy of the within Mechanics' -n Claim, upon the within named defendant,to wit: Gerald Mortell, by making known unto hi --If p- -• ally,at 5128 Jennifer Circle, Mechanicsburg, Cumberland County, Pennsylvania 17050 its co e is a, • - the same time handing to him personally the said true and correct copy of the same. / S ►T HA''' N, DEPUTY 12/20/2010 05:12 PM-Shawn Harrison, Deputy Sheriff,who being duly sworn according to law, =tes that on December 20, 2010 at 1712 hours, he served a true copy of the within Mechanics' - Claim, upon the within named defendant, to wit: Chong Huang, by making known unto hims-If pers. - , at 5128 Jennifer Circle, Mechanicsburg, Cumberland County, Pennsylvania 17050 its cont- - an. - = same time handing to him personally the said true and correct copy of the same. / S HARRI'I', DEPUTY SHERIFF COST: $53.44 SO ANSI -S, December 21, 2010 R• ' RANDERSON, SHERIFF NOTARY Affirmed and subscribed to before me this day of tai CouutiySute Shenff Teiroso'1.Inc. FILED-OFFICE C F THE PROTHONOTARY -147/e.-6 }-4#N -6 PM 3: 47 CUMBERLARO COU1• PENNSYLVANIA ^, f 7 7'4 fr..47 ..S .../v6 de A 744 e l 4 ate! �C -�-Ge C e ' /eat ^7 ( `d!/. _-I g'r'ter /-c • uee.),,x (717) 7?b- q. "3/ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff d�aoi at+Cuirthoi Jody S Smith '` Chief Deputy Richard W Stewart Solicitor OFFICE OF THE SHERIFF BIN, Incorporated Case Number vs. 2o10-n17 Gerald Mortell (et al.) SHERIFF'S RETURN OF SERVICE 12/20/2010 05:12 PM-Shawn Harrison, Deputy Sheriff,who being duly sworn according to law tates that on December 20,2010 at 1712 hours, he served a true copy of the within Mechanics' •n Claim, upon the within named defendant, to wit: Gerald Mortell,by making known unto hi =1f p= • ally, at 5128 Jennifer Circle, Mechanicsburg, Cumberland County, Pennsylvania 17050 its co e is a, • - the same time handing to him personally the said true and correct copy of the same. / S HA' N, DEPUTY 12/20/2010 05:12 PM-Shawn Harrison, Deputy Sheriff,who being duly sworn according to law, - =tes that on December 20,2010 at 1712 hours, he served a true copy of the within Mechanics' = Claim, upon the within named defendant, to wit: Chong Huang, by making known unto hims-If per a - , at 5128 Jennifer Circle, Mechanicsburg,.Cumberland County, Pennsylvania 17050 its cont, an. - - same time handing to him personally the said true and correct copy of the same. A V S HARRI , DEPUTY • SHERIFF COST: $53.44 SO ANS k 'S, 'P:CZa.ag • December 21, 2010 R. R ANDERSON, SHERIFF NOTARY Affirmed and subscribed to before me this day of (cI CountySuite Sheriff.Teieosofft.Inc. EXHIBIT " B " Theodore A.Adler* John P.Neblett** Reager& David W.Reager Susan H.Confair Linos E.Fenicle Wayne S.Martin,P.E*** Adler,1 p ATTORNEYS AND COUNSELORS AT LAW Thomas 0,Williams Jay C.Whittle**** *Certified Civil Trial Specialist **Certified in Consumer Bankruptcy ***Licensed to Practice in N.J. ****Of Counsel December 2, 2013 Writer's Email Address: TWilliams @ReagerAdlerPC.com VIA FIRST CLASS U. S. MAIL Gregory Woods, President BIN, Inc. 4209 Cumberland Avenue Harrisburg, PA 17110 Re: Our Clients: Gerald Mortell and Chong Huang Removal and Discharge of Mechanic's Lien Claim Cumberland County Docket No. 10-7717 MLD Dear Mr. Woods: This firm represents Gerald Mortell and Chong Huang regarding the wrongful Mechanic's Lien you filed on their residential property located at 5128 Jennifer Circle, Mechanicsburg, Pennsylvania 17050. You filed the referenced Mechanic's Lien Claim on behalf of BIN, Inc. on or about December 15, 2010. In addition to several other defects in the Mechanic's Lien Claim, the Pennsylvania Mechanic's Lien Law requires that a Mechanic's Lien claimant file a complaint within two years after the filing of a Mechanic's Lien claim. As BIN, Inc. has not filed a Complaint to obtain judgment on the Mechanic's Lien Claim in accordance with the requirements of the Pennsylvania Mechanic's Lien Law, the Mechanic's Lien Claim cannot be pursued and must be dismissed and discharged. We are writing this letter on behalf of our clients demanding that you take the necessary steps with the Prothonotary of the Court of Common Pleas of Cumberland County to remove, dismiss and discharge the Mechanic's Lien Claim. If you do not do so within ten days of the date of this letter, we will be forced to file a motion requesting the Court to remove, dismiss and discharge the Mechanic's Lien Claim. If we are forced to do so, we will seek attorney's fees on behalf of our clients. We trust that this will not be necessary and that you will immediately take steps to have the Mechanic's Lien Claim removed, dismissed and discharged. I ask that you send my office a copy of a clocked-in praecipe indicating that you have done so. Should you have any questions regarding this matter, please contact me. Very truly yours, 12 if Thomas O. Williams TOW:als cc: Gerald Mortell Chong Huang PR 0 V EN R E S O U R C E S 2331 Market Street, Camp Hill, Pennsylvania 17011-4642 T: 717 763-1383 F: 717 730-7366 www.reageradlerpc.com CERTIFICATE OF SERVICE I, Alana L. Souders, Paralegal to Thomas 0. Williams, Esquire, hereby certify that I have this date caused a true and correct copy of the foregoing Petition to be served upon the following party of record via First Class U.S. Mail, postage prepaid, addressed as follows: Gregory Woods, President BIN, Inc. 4209 Cumberland Avenue Harrisburg, PA 17110 Dated: December 18, 2013 ` � .. BIN, INC., : IN THE COURT OF COMMON PLEAS OF Claimant •▪ CUMBERLAND COUNTY, PENNSYLVANIA v. •• CIVIL ACTION—LAW GERALD MORTELL and • CHONG HUANG, Respondents •▪ NO. 10-7717 CIVIL TERM IN RE: PETITION TO STRIKE OFF MECHANIC'S LIEN CLAIM FOR FAILURE TO COMMENCE ACTION ORDER OF COURT AND NOW, this 2nd day of January, 2014, upon consideration of Respondents' Petition to Strike Off Mechanic's Lien Claim for Failure To Commence Action, a Rule is hereby issued upon Claimants to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, Christ ee L. Peck, J. Gregory Woods, President BIN, Inc. 4209 Cumberland Avenue Harrisburg, PA 17110 Claimant, pro Se ".. homas O. Williams, Esq. 2331 Market Street - =: Camp Hill, PA 17011 r 4 Attorney for Respondents f./5 :rc >c "' CID ekc //z/iy r r.. 20,14 AN 16 AM 11, 54 CUMBERL"D COUNTY REAGER&ADLER, P.C. PENNSYLVANIA Thomas O. Williams, Esquire Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorney for Gerald Mortell and Chong Huang BIN, Inc, IN THE COURT OF COMMON PLEAS OF Claimant, CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 10-7717 MLD Gerald Mortell and Chong Huang, Respondents. AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF CUMBERLAND ) I, Thomas O. Williams, being duly sworn, upon oath, deposes and says as follows: 1. I am the attorney for Gerald Mortell and Chong Huang in the captioned case. On January 6, 2014, I caused to be transmitted, by a form of mail requiring a signed receipt, a copy of the Petition to Strike Off Mechanic's Lien Claim and the Order of Court entered on January 2, 2014 filed in this action to the following: BIN, Inc., 124 Crimson Lane, Elizabethtown, PA 17022. 2. I further depose and say that I thereafter received from the U.S. Postal Service, a return receipt indicating a date of Delivery of January 7, 2014. A copy of the return receipt and tracking information is attached hereto. REAGER& DLER, P.C. Thom s 6. Williams, Esquire Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Sworn to and subscribed before me this 14th day of January, 2014 COMMONWEALTH OF PENNSYLVANIA Notarial Seal LN-o ubliC Jennifer S.K.Gross,Notary Public Camp Hill Boro,Cumberland County My Commission Expires Sept.11,2016 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES x Postal CERTIFIED-IVIAIL. RECEIPT a m ' M (Domestic Mail Only; f`- O u'1 f`- Postage C] certified Fee O Postmark (Endorsemrrtent Rceq Io Here O Restricted Delivery Fee ro f1J (EndorsementRequitoo r� Total Postage&Fees tr) C3 S C orF06cxN& 21 COMPLETE •N COMPLETE THIS SECTION ON DELIVERY ■ Complete items 1,2,and 3.Also complete A. Signature item 4 if Restricted Delivery is desired. X � &J4 E3 Agent 11111 Print your name and address on the reverse ❑Addressee j so that we Can return the Card to you. B. Received by(Pn* ed Name) C. Date of Delivery I ■ Attach this card to the back of the mailpiece, /I�DAf/ t or on the front if space permits. '6 �/ 1. Article Addressed to: D. Is delivery address different from item 17 ❑Yes If YES,enter delivery address below: ❑No a� Cy � 3 Service Type i all ❑Egress Mall /1� ,��X egistered ❑Retum Receipt for Merchandise NN l/ ❑ Insured Mail ❑C.O.D. 4. Restricted Delivery?(Extra Fee) ❑Yes ! 2. Article Number -,2,' (Transfer from service tabu) 7 0 3 5 18'2 0007 75[11.i 7'3 3 D (Tr PS Form 3811,February 2004 Domestic Return Receipt 102595-02-M-1540 USPS.com®-USPS Trackinem https://tools.usps.conVgo/TrackConfirmAction!input.action?tRef--gt&t... t English Custom Service USPS Mobile Register/Sign In USPSCOM* Search USPS.com or Track Packages Quick Tools Track Find Ship a Package Send Mail Manage Your Mail Shop Business Solutions Find USPS Locations BuyStamps _.__.. _.__- -_... ..... ................................... Scn tl e P'I�up F nIPW:�Ie' Tracking T"" Customer Service> . Hold Mail Have questions?We're here to help. Change of Address - - Tracking Number:70051820000775017330 Product & Tracking Information Available Options Postal Product: Features: Email Updates Certified Mail`' DATE&TIME STATUS OF ITEM LOCATION January 7,2014,3:15 1 Delivered pm ELIZABETHTOWN,PA 17022 January 7,2014 Depart USPS Sort HARRISBURG,PA 17107 Facility January 7,2014,12:03 Processed through am USPS Sort Facility HARRISBURG,PA 17107 Track Another Package What's your tracking(or receipt)number? Track It __ .......,.... _.. ...... .... .......... LEGAL ON USPS.COM ON ABOUT.USPS.COM OTHER USPS SITES Privacy Policy> Government Services) About USPS Home> Business Customer Gateway> Terms of Use) Buy Stamps&Shop) Newsroom) Postal Inspectors> FOIA> Print a Label with Postage> USPS Service Alerts, Inspector General> No FEAR Act EEO Data> Customer Service> Forms&Publications> Postal Exiolorer> Delivering Solutions to the Last Mile> Careers> Site Index> CopyrightQ 2014 USPS.All Rights Reserved. 1 of 1 1/14/2014 12:02 PM p , CERTIFICATE OF SERVICE I, Alana L. Souders, Paralegal to Thomas O. Williams, Esquire, hereby certify that I have this date caused a true and correct copy of the foregoing Affidavit to be served upon the following party of record via First Class U.S. Mail,postage prepaid, addressed as follows: BIN, Inc. 124 Crimson Lane Elizabethtown, PA 17022 Dated: January 14, 2014 CA&I6,L 2014 FEB —b �t!: 22 C(.i, BERtAND c PENNS uNTI Y[yAtdlA REAGER & ADLER, P.C. Thomas O. Williams, Esquire Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 Attorneys for Gerald Mortell and Chong Huang BIN, Inc, : IN THE COURT OF COMMON PLEAS OF Claimant, • CUMBERLAND COUNTY, PENNSYLVANIA vs. • • No. 10-7717 MLD Gerald Mortell and Chong Huang, • Respondents. • MOTION TO MAKE RULE ABSOLUTE Petitioners, Gerald Mortell and Chong Huang, by and through their attorneys, Reager & Adler, PC, hereby move for a Rule Absolute in regard to their Petition to Strike Off Mechanic's Lien Claim filed in the captioned matter, and in support thereof aver the following: 1. On December 20, 2013, Petitioners filed its Petitions to Strike Off Mechanic's Lien Claim for Failure to Commence Action. 2. On January 2, 2014, this Court entered a Rule to show cause as to why the relief requested should not be granted. Such Rule to Show Cause was made returnable within 20 days of service. 1 3. On January 16, 2014, undersigned counsel filed an Affidavit of Service verifying that the Petition to Strike Mechanic's Lien and Rule issued January 2, 2014 were served upon BIN, Inc. by certified mail on January 7, 2014. 4. As of the date of the motion, undersigned counsel has not been served with any response to the Motion to Strike Mechanic's Lien Claim, nor is counsel aware of any such response having been filed with the Court. WHEREFORE, Petitioners request that this Court grant their Petition to Strike off Mechanic's Lien Claim and that the Mechanic's Lien Claim filed as aforesaid against said real property of Petitioners be stricken, removed, and canceled of record, and that Petitioners have such other and further relief as the Court may deem equitable and proper. Respectfully submitted, REAGER& A'DER, P.C. Date: February 4, 2014 Thom.- O. Williams, Esquire PA I.D. 67987 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 Attorneys for Petitioner 2 CERTIFICATE OF SERVICE I, Alana L. Souders, Paralegal to Thomas 0. Williams, Esquire, hereby certify that a true and correct copy of the foregoing Motion was served upon the following party of record via First Class U. S. Mail, postage prepaid, addressed as follows: BIN, Inc. 124 Crimson Lane Elizabethtown, PA 17022 Dated: February 4, 20141 r S S IC FILE =gip: tip i HOO ' 2014 FEB 12 PM 2= 27 CUMBERLAIND COUNTY PENNSYLVANIA BIN, Inc, IN THE COURT OF COMMON PLEAS OF Claimant, CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 10-7717 MLD Gerald Mortell and Chong Huang, Respondents. ORDER AND NOW, this „day of , 2014, upon consideration of ,V-the Motion to Make Rule Absolute filed by Gerald Mortell and Chong Huang, and any response thereto, the same is hereby GRANTED. It is hereby ORDERED that the Petition to Strike Mechanic's Lien is GRANTED and the Mechanic's Lien shall be deemed stricken and removed. The Prothonotary of the Court of Common Pleas of Cumberland County shall mark the mechanic's lien stricken and removed. BY THE COURT i J. Distribution: v” IN, Inc. 124 Crimson Lane Elizabethtown, PA 17022 Thomas O. Williams, Esquire Reager & Adler, P.C. 2331 Market Street Camp Hill, PA 17011 126 c L'k a