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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