HomeMy WebLinkAbout11-7966- r 0 L
IN THE COURT OF COMMON PLEAS OF 19 P11 2' 10
CUMBERLAND COUNTY, PENNSYLVANIA =J ;iL'A H D CQUdT``
PE-NINSYa VANIA
CAMP HILL BOROUGH CIVIL DIVISION
2145 WALNUT STREET
CAMP HILL, PA 17011 Plaintiff, No.:
_Q p MLD
VS.
KIMBERLY S. BANZHOFF
632 DEVON ROAD
CAMP HILL, PA 17011
PARCEL ID #01-19-1594-116
Defendant.
MUNICIPAL CLAIM FOR SEWER RATES
TO: PROTHONOTARY
SIR/MADAM:
Camp Hill Borough, 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 the Borough of Camp Hill, 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 Camp Hill Borough.
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 Camp Hill Borough
adopted on June 8, 2011, establishing the sewer rates and regulations of Camp
Hill Borough for the sewer system for the Borough of Camp Hill, 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 Camp Hill Borough
under the Acts of Assembly of the Commonwealth of Pennsylvania have been
done and performed in due and legal form so as to entitle Camp Hill Borough to
file a lien for the payment of the sewer rates for which this claim is filed.
4. The name of the owner(s) or reputed owner(s), of the property against which this
claim is filed, is/are Kimberly S. Banzhoff.
5. The property against which this claim is filed is known and numbered as 632
Devon Road, Camp Hill, Pennsylvania 17011.
tI C1,00
OaA
cy- 6. ot 19 0%
,? a6
6. This sewer rate was charged for sewer service furnished to the above-described
property, the sewer lines and the sewer rate being charged for the prior years to
and including the present.
Rental, Penalties, Interest, Collection Fee and Costs
AS OF October 18, 2011 and/or March 7, 2012
Sewer Rents through 1St Quarter 2012 Billing $ 1,303.44
Penalties through 1St Quarter 2012 Billing $ 285.77
Attorney' Fees through March 7, 2012 Sheriff Sale $ 3,465.00
TOTAL: $ 5,054.21
Plus additional attorneys' fees and costs incurred by Camp Hill Borough in collection of
the above claim in accordance with the fee schedule authorized by Resolution of Camp Hill
Borough.
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 m=.RICK e proper
Municipal Lien Docket and Judgment Index.
.T &
By.
Scott A. ietterick, Esquire
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
CAMP HILL BOROUGH CIVIL DIVISION
2145 WALNUT STREET
CAMP HILL, PA 17011
Plaintiff,
VS.
KIMBERLY S. BANZHOFF
632 DEVON ROAD
CAMP HILL, PA 17011
PARCEL ID #01-19-1594-116
Defendant.
CERTIFICATE OF SERVICE
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 18th day of October, 2011, via First Class U. S. Mail, Postage
Pre-paid:
Kimberly S. Banzhoff
632 Devon Road
Camp Hill, PA 17011
DIETTERICK & CONNELLY, LLP
By'.. A. i k, Esquire
Attorney D 50
P.O. Box 5
Hershey, P 17033
(717) 533-3280
r?
?i
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
idtr
CAMP HILL BOROUGH CIVIL DIVISION ?LVA d/A`?
2145 WALNUT STREET
CAMP HILL, PA 17011 :
Plaintiff, No.: 11-7966 MLD
vs.
KIMBERLY S. BANZHOFF
632 DEVON ROAD :
CAMP HILL, PA 17011 :
PARCEL ID #01-19-1594-116
Defendant.
No.: 11-8636 Civil
PRAECIPE TO SATISFY MUNICIPAL LIEN
TO THE PROTHONOTARY:
SIR/MADAM: Please mark the Municipal Lien filed at the above - captioned term and number
satisfied.
Date: April 11, 2012
By:
Scott AYDi erick, Esquire
Attorney for laintiff
PA I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
axj 4L
1
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CAMP HILL BOROUGH
2145 WALNUT STREET
CAMP HILL, PA 17011
Plaintiff,
vs.
KIMBERLY S. BANZHOFF
632 DEVON ROAD
CAMP HILL, PA 17011
PARCEL ID #01-19-1594-116
Defendant
CIVIL DIVISION
No.: I1-7966 MLD
No.: 11-8636 Civil
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 I l 1h day of April, 2012, via First Class U. S.
Mail, Postage Pre-paid:
Kimberly S. Banzhoff
632 Devon Road
Camp Hill, PA 17011
Respectfully Subm to
JAMES, SM TERICK & CONNELLY, LLP
By: _
Scott Pi rick, Esquire
Attorney I. #55650
P.O. Box 6
Hershey, A 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CAMP HILL BOROUGH CIVIL DIVISION
2145 WALNUT STREET
CAMP HILL, PA 17011
Plaintiff, No.: 11-7966 MLD
vs. _.,
No.: 11-8636 evil`'-
KIMBERLY S. BANZHOFF ?
632 DEVON ROAD
r-
CAMP HILL, PA 17011
PARCEL ID #01-19-1594-116 -0
Defendant. ; d t
PRAECIPE TO DISCONTINUE ACTION
TO THE PROTHONOTARY:
Please mark the above captioned matter settled and discontinued.
Respectfully Submitted:
DATE: April 11, 2012
JAMES, SMITH, DITTERICK &
CONNELLY LLP?
BY:
Scott A: i t ck, Esquire
PA I.D. # 6
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280