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HomeMy WebLinkAbout11-2038IN 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.: MLD VS. ADELLE G. KURTZ and I-' 7 --t BENJELLOUN NAJIB, - ,-ten-n 16 S. MADDER DRIVE r-l M r i MECHANICSBURG, PA 17050 co ?°, PARCEL ID# 38-08-0567-108 Defendants. MUNICIPAL CLAIM FOR SEWER RATES TO: PROTHONOTARY: 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. (??d S0 4. The name of the owners or reputed owners, of the property against which this claim is filed, is Adelle G. Kurtz and Benjelloun Najib. ?'C#? 5. The property against which this claim is filed is known and numbered as 16 S. Madder Drive, Mechanicsburg, Pennsylvania 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 2010 to and including the present. Rental, Penalties, Interest, Collection Fee and Costs AS OF February 15, 2011 and/or September 7, 2011 Sewer Rents through 1St Quarter 2011 Billing $ 674.80 Penalties through 1sT Quarter 2011 Billing $ 104.43 Attorney' Fees through September 7, 2011 Sheriff Sale 3,465.00 TOTAL: $ 4,244.23 Plus additional attorneys' fees and costs incurred by Silver Spring Township Authority in collection of the above claim in accordance with the 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. Y, TTERICK & By/ V\__ 44Z Scott A. Die eric Esquire Attorney for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 DATE: February 15, 2011 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. ADELLE G. KURTZ and BENJELLOUN NAJIB, 16 S. MADDER DRIVE MECHANICSBURG, PA 17050 PARCEL ID# 38-08-0567-108 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 15th day of February, 2011, via First Class U. S. Mail, Postage Pre-paid: Adelle G. Kurtz Benjelloun Najib 16 S. Madder Drive Mechanicsburg, PA 17050 JAMES, $r91TR D By: Attorney I.D. #55650 P.O. BOX 650 Hershey, PA 17033 (717) 533-3280 CK & CONNELLY, LLP 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, . VS. NO.: 11-2038 MLD ADELLE G. KURTZ and -' 3 BENJELLOUN NAJIB 16 S. MADDER DRIVE '?? MECHANICSBURG, PA 17050 ??", {? PARCEL ID #38-08-0567-108 Defendants. cn - PRAECIPE TO SATISFY MUNICIPAL LIEN TO THE PROTHONOTARY: SIRIMADAM: Please mark the Municipal Lien filed at the above - captioned term and number satisfied. By: PO. Scott A. Diettenck, tJsquire 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, VS. NO.: 11-2038 MLD ADELLE G. KURTZ and BENJELLOUN NAJIB 16 S. MADDER DRIVE MECHANICSBURG, PA 17050 PARCEL ID #38-08-0567-108 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 ls` day of March, 2011, via First Class U. S. Mail, Postage Pre-paid: Adelle G. Kurtz Benjelloun Najib 16 S. Madder Drive Mechanicsburg, PA 17050 Respectfully Submitted: JAMES, SMIT TTE CK & CONNELLY, LLP By: Sc A. erick, Esquire Attorney I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280