HomeMy WebLinkAbout11-7971
i
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA -'1i 1BERLAND COUiN T Y
71 °1E•'SYLVANIA
CAMP HILL BOROUGH
2145 WALNUT STREET
CAMP HILL, PA 17011
VS.
JOSEPH E. JIRAS
ATHENA J.BRELLOS
2014 LINCOLN STREET
CAMP HILL, PA 17011
PARCEL ID #01-21-0271-13513
CIVIL DIVISION
Plaintiff, No.: - "l MLD
Defendants.
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 Joseph E. Jiras and Athena J. Brellos.
5. The property against which this claim is filed is known and numbered as 2014
Lincoln Street, Camp Hill, Pennsylvania 17011. CLM* lcj.co a al
C? Cl 20
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 $ 1,500.00
Penalties through 1St Quarter 2012 Billing $ 350.02
Attorney' Fees through March 7, 2012 Sheriff Sale $ 3.465.00
TOTAL: $ 5,315.02
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 made, en r th e in the proper
Municipal Lien Docket and Judgment Index.
JAMES, ITH? ETTERICK &
By.
Scott A. ette ' squire
Attorney for Plaintiff
PA I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
-r
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CAMP HILL BOROUGH CIVIL DIVISION
2145 WALNUT STREET
CAMP HILL, PA 17011
Plaintiff, No.: MLD
vs.
JOSEPH E. ERAS
ATHENA J. BRELLOS
2014 LINCOLN STREET
CAMP HILL, PA 17011
PARCEL ID #01-21-0271-135B
Defendants.
CERTIFICATE OF SERVICE
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:
Joseph E. Eras
Athena J. Brellos
2014 Lincoln Street
Camp Hill, PA 17011
JAMES, "OH, IWTTERICK & CONNELLY, LLP
By:
Sco . D tterick, Esquire
Attorney I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280