HomeMy WebLinkAbout11-8326Johnson, Duffle, Stewart & Weidner
By: Michael J. Cassidy
I.D. No. 82164
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
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Attorneys for Plairxtifi .t
BOROUGH OF LEMOYNE, IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v. NO. WL J
MUNICIPAL LIEN
JAMES K. CONWAY and
PATRICIA M. CONWAY,
Defendants
MUNICIPAL CLAIM
AND NOW, this 2nd day of November, 2011, BOROUGH OF LEMOYNE, a municipality of the
Commonwealth of Pennsylvania, herewith files its claim for sewer and refuse services against the real
estate hereinafter described in accordance with the Acts of Assembly of the Commonwealth of
Pennsylvania, thereunto enabling and appertaining, and sets forth the following claim:
1. The name of the municipality filing this claim is BOROUGH OF LEMOYNE.
2. The name of the owners or reputed owners of the property against which this claim is filed is:
JAMES K. CONWAY and PATRICIA M. CONWAY.
3. The property against which this lien is filed is situate in Cumberland County, Pennsylvania,
being more fully described as Tax Parcel Number 12-21-0265-353 and being known and numbered as 60
Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania 17043.
4. This claim is filed under and by virtue of the several Acts of Assembly of the Commonwealth
of Pennsylvania, relating thereto, and resolutions of BOROUGH OF LEMOYNE relating to rates and
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charges for sewer and refuse services, which services were provided by Plaintiff to the benefit of the
property against which this lien is filed.
5. The amounts and times for which the claims are filed are:
Sewer Service:
Principal (through December 31, 2010) $4,800.00
Penalty (through October 31, 2011) $3,175.45
Total Amount Owed for Sewer Service: $7,975.45
Refuse Service:
Principal (through December 31, 2010) $2,466.00
Penalty (through October 31, 2011) $1,508.69
Total Amount Owed for Refuse Service: $3,974.69
Attorneys' Fees $150.00
Court Costs 27.00
TOTAL AMOUNT OF LIEN: $1127.14
TO THE PROTHONOTARY:
Enter the above lien in the proper Tax and Municipal Lien Docket and upon the Judgment and
Locality Indices according to law.
BOROUGH OF LEMOYNE
By:
Michael J. assidy, Solicitor
:465499
1605-551
VERIFICATION
I, MICHAEL J. CASSIDY, Solicitor for BOROUGH OF LEMOYNE, hereby swear under penalty of law
that the facts set forth herein are true to the best of my knowledge, information, and belief. I understand that
false statements made herein are made subject to the penalties of 18 Pa. C.S.A §4904, relating to unswom
falsification to authorities.
Date: November 2, 2011 By: C?
Michael J. Cassidy, Solicitor
CERTIFICATE OF SERVICE
AND NOW, this 2"d day of November, 2011, the undersigned does hereby certify that she did this date
serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in
the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows:
James K. Conway
60 Hummel Avenue
Lemoyne, PA 17043
Patricia M. Conway
60 Hummel Avenue
Lemoyne, PA 17043
JOHNSON, DUFFIE, STEWART & WEIDNER
By:
Beth j&&1zkzFetterhoff
Johnson, Duffle, Stewart & Weidner
By: Michael J. Cassidy
I.D. No. 82164
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Plaintiff
BOROUGH OF LEMOYNE, IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 11-8326-MLD
V.
MUNICIPAL LIEN
JAMES K. CONWAY and
PATRICIA M. CONWAY,
Defendants
PRAECIPE TO SUBSTITUTE CERTIFICATE OF SERVICE
TO THE PROTHONOTARY:
In the above-captioned matter, please substitute the Substituted Certificate of Service
attached hereto as Exhibit "A" for the Certificate of Service which was attached to Plaintiffs
Municipal Claim which was time-stamped by the Cumberland County Prothonotary's office on
November 3, 2011.
Respectfully submitted,
JOHNSON, DUFFIE, STEWART & WEIDNER
By: t------ 1 1.
Michael J. Cassidy
Date: November 14, 2011
EXHIBIT "A"
SUBSTITUTED CERTIFICATE OF SERVICE
AND NOW, this 14th day of November, 2011, the undersigned does hereby certify that she
did this date serve a copy of the Municipal Claim upon the other parties of record by causing
same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne,
Pennsylvania, addressed as follows:
James K. Conway
1103 Dry Powder Circle
Mechanicsburg, PA 17050
Patricia M. Conway
1103 Dry Powder Circle
Mechanicsburg, PA 17050
JOHNSON, DUFFIE, STEWART & WEIDNER
By:
Beth Fetterhoff
:468481
BOROUGH OF LEMOYNE : In the Court of Common Pleas of
: Cumberland County, Pennsylvania
VS
JAMES K. CONWAY
PATRICIA M. CONWAY
: 11-8326 MLD
: Municipal Lien
Plaintiff in the above Judgment, do appear and acknowledge that Robert Ihlein, Borough
Manager, April 10, 2014, this day have had and received from the above defendant in the above
Judgment, full payment and satisfaction of the same, with interest and costs, and desired that the
satisfaction therefore shall be entered upon the records thereof.
And further, I do hereby authorize and empower David Buell, the Prothonotary of said Court, to
appear for me and in my name and stead to enter full satisfaction upon the record of said
Judgment, as fully and effectually, to all intents and purpose, as I could were personally present
in person to do so. And for so doing this shall be your sufficient warrant of authority.
In testimony whereof, have hereunto set our ds and seals this April 10, 2014.
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