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.
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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