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HomeMy WebLinkAbout11-4445f Y UPPER ALLEN TOWNSHIP, IN THE COURT COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Claimant n ? c NO ,? rT . rqW ! -? KELLY GARRETT Defendant zo 5c: .?„'m MUNICIPAL LIEN MUNICIPAL LIEN FOR SEWER/WATER RATES NOW COMES Upper Allen Township, Cumberland County, Pennsylvania, by its Township Solicitor, J. Stephen Feinour, and files the within claim for charges assessed with respect to sewer and/or water rates against above named owner or owners and against the hereinafter described real estate as follows: STATEMENT OF CLAIM 1. This claim is filed by UPPER ALLEN TOWNSHIP, a first class township organized and existing in accordance with the laws of the Commonwealth of Pennsylvania. 2. The owner or reputed owner of the property, or party or parties responsible or liable, for which this claim is filed is the Defendant (s). 3. The authority under which the sewer and/or water rates were charged and assessed is the Act of July 18, 1935, P.L. 1286. Section 1, 53 P.S. § 2231, as amended. 'of S/??4'0v? P#vS9ye17 4. The authority under which this claim is filed is the Act of May 16, 1923, P.L. 207, Section 9, et sea. 53 P.S. §7143, as amended. 5. A description of the property against which this claim is filed is: 709 Cedar Ridge Lane Upper Allen Township Cumberland County Mechanicsburg, Pennsylvania 17055 Tax parcel Number: 42-24-0792-001E 6. This claim has not been the subject of any previous claim and judgment in the Court of Common Pleas of Cumberland County for sewer/water charges. 7. The total amount of the charges for which this claim is filed is Two Thousand Forty Seven and 84/100 dollars ($2,047.84) plus costs. 8. The time period for which these charges are filed is April 2007 to March 2011. WHEREFORE, Claimant requests that a Municipal Lien be entered in its favor and against the Defendant in the amount of Two Thousand Forty Seven and 84/100 dollars ($2,047.84) plus costs. Dated: May 19, 2011 UPPER ALLEN TOWNSHIP By: .?."" . St phen Feinour Township Solicitor Upper Allen Township 100 Gettysburg Pike Mechanicsburg, PA 17055 (717) 766-0756 Z:\Sewer\Administration\Billing Information\DELINQUENT-LIEN MO\Master Lien Filing Form.doc IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA rnc" -0 UPPER ALLEN TOWNSHIP ) CASE NO. 11-4C1N Plaintiff ) rev vs. KELLY GARRETT Defendant -o rn C) _4 CD = -n C) -11 °4 rrt D NOTIFICATION OF FILING UNDER BANKRUPTCY ACT AND SUGGESTION OF STAY KELLY LAUREN GARRETT, hereby notifies the Court that on the 29`" day of June, 2011, she filed with the Clerk of the United States Bankruptcy Court for the Northern District of West Virginia a petition in bankruptcy under Chapter 7 of the Bankruptcy Code. The petition is pending before the Honorable Patrick M. Flatley, Bankruptcy Judge, and has been assigned Case No. 11-01190. The filing invoked Section 362 of the Bankruptcy code, which stays all court actions and collection proceedings against the debtor as well as all acts to perfect or enforce liens or to obtain possession of the Debtor's property. Upper Allen Township is listed as an unsecured creditor in said petition. By: D. William Davis, 8650 407-A Howard Street Bridgeport, OH 43912 Phone: (740) 635-1217 Fax: (740) 633-9843 E-mail: dwilliamdavisacomcast.net Attorney for Defendant Kelly Lauren Garrett CERTIFICATE OF SERVICE The undersigned certifies that a photocopy of the foregoing Notice was served upon the following parties by first-class mail, postage prepaid, this 29 h day of June, 2011: 1) Commissioners of Upper Allen Township, 100 Gettysburg Pike, Mechanicsburg, PA 17055-5698 2) J. Stephen Feinour, Township Solicitor, 100 Gettysburg Pike, Mechanicsburg, PA 17055. DAVIS LAW FFICE tv'? \ Vv- By: t. D. William Davis, 8650 Attorney for Defendant Kelly Lauren Garrett UPPER ALLEN TOWNSHIP, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA VS. No. 11-4445 MLD • x KELLY GARRETT, n Q Defendant MUNICIPAL LIEN Mrs .. Mf= r , -< —�C o D C-> �= PRAECIPE TO SATISFY MUNICIPAL LIEN p TO THE PROTHONOTARY: Please mark the Municipal Lien in the above-captioned matter satisfied and discontinued. Respectfully submitted, By: Step en Feinour,Esquire Solicitor for Upper Allen Township Supreme Court I.D. #24580 Nauman, Smith, Shissler&Hall, LLP 200 North Third Street, 18`"Floor Harrisburg, PA 17101 Phone: (717) 236-3010 Dated: y � 2D1 C' 1:5&&