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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 Fl' 77 7, , r p ,t 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 1 /9- 00 pw/?/j e-#3-7961 Pia 6601 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. (Seal) (Seal) (Seal) /1, 0 pot- P)( 1"- 3 Ca 66