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F:\FILES\Clients\13599 West Penn\13599.2\13522.2.Behrens\13522.2.behrens. lien l.wpd
Hubert X. Gilroy, Esquire L } I.D. I.D. No. 29943 ^~ 17 PH
R. Christopher VanLandingham, Esquire ? ?.
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I.D. No. 3074241=°SYLil,
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
WEST PENNSBORO TOWNSHIP
MUNICIPAL AUTHORITY,
Plaintiff
V.
DANIEL J. BEHRENS and
KIMBERLEE K. BEHRENS,
Defendants
MUNICIPAL LIEN FOR SEWER SERVICES
The Municipal Authority of West Pennsboro Township, Cumberland County, Pennsylvania, by its
Assistant Solicitor, MARTSON LAW OFFICES, hereby files its claim for sewer services against
the real estate hereinafter described and sets forth its claim as follows:
STATEMENT OF CLAIM
1
The name of the municipality by which this claim is filed is West Pennsboro Township Municipal
Authority, a municipal authority of the Commonwealth of Pennsylvania, located in the County of
Cumberland and organized pursuant to ordinances of West Pennsboro Township.
NO. 2012 - 5-/ (, oZ MLD
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0-J-37i'. I
P-1 c -?95'IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MUNICIPAL LIEN
2
The names of the owners or reputed owners of the property against which this claim is filed are
Daniel J. Behrens and Kimberlee K. Behrens, 707 Opossum Lake Road, Carlisle, PA 17015.
3
A description of the property against which this Lien is filed is attached hereto and marked as
Exhibit "A" with an address of 44 West Main Street, Plainfield, PA 17081.
R
4
The authorities under and by virtue of which this Lien is filed is the Municipal Claims and Liens Act
of May 16, 1923, P.L. 207, as amended and supplemented, 53 P.S. 7101 et seq.
5
The lien is claimed for unpaid sewer user fees against the above-described property in the amount
of $636.30, plus any additional fees incurred thereafter.
6
Interest is claimed on the above-mentioned fees until paid in full.
Date: f !? ?Z) aw&?-
TO THE PROTHONOTARY
Sir:
WEST PENNSBORO TOWNSHIP
MUNICIPAL AUTHORITY
By: ?% -
Hubert X. Gilroy, V1(
Assistant Solicit
Martson Law Offices
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Since payment of the above claim has not been made, please enter same in proper tax and municipal
lien docket, and upon judgment index and locality entities index, according to law.
WEST PENNSBORO TOWNSHIP MUNICIPAL
AUTHORITY
By:
Hu ert X. Gilroy squire
Assistant Soli ' or
Martson Law Offices
10 East High Street, Carlisle, PA 17013
(717) 243-3341
EXHIBIT "A"
' 3R, 113 f e,,
?Y ROBERT P. ZIEGL. R
RECORDER OF DEEDS
CUMBERLAND 000'i - PA
W AUG 11 PIS 9 42
TAX PARCEL NO.:
Thin Indenture, Made the U4 day of in the year of
TWO THOUSAND FOUR (2004)
Between: JONATHAN G. RITCHEY and SHERRI M. RITCHEY, HIS
WOE, of Cumberland County, PA
part, and
(hereinafter called the Grantor(s), of the one
DANIEL J. BEHRENS and KIMBERLEE K. BEHRENS, his wife
second part,
(hereinafter called the Grantee(s), of the
WITNESSETH, that the said Grantor(s), for and in consideration of the sum of One Hundred
Seventeen Thousand Nine Hundred ($117,900.00) Dollars, lawful money of the United States of
America, unto them well and truly paid by the Grantee(s), at or before the sealing and delivery
hereof, the receipt whereof is hereby acimowledged, have granted, bargained and sold, released
and confirmed, and by these presents, grant, bargain and sell, release and confirm unto the said
Grantee(s), their heirs and assigns:
ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in the
Village of Plainfield, Township of West Peansboro, County of Cumberland and Commonwealth
of Pennsylvania, being more particularly bounded and described as follows, to wit:
BEGINNING at a point in the center of the Carlisle-Newville State Road, Pennsylvania Route
641, at the corner of land formerly of Rebecca and Elizabeth Bear, thence by the same, South .
eighteen and three-fourths degrees West (S 18 3/4°W), for a distance of two hundred sixteen feet
six inches (216'6") to a post; thence by the same, South one and three-fourths degrees West (SO 1
tioox 264 WE33065
SLT moo Wo/ / 77
3/4°W) for a distance of twenty-eight feet three inches (28'3") to a point in the center of a public
alley; thence by the centerline of said public alley, North eighty-six and one-half degrees West
(N 861/2 W) for a distance of thirteen feet five inches (13' 5") to a point; thence by land now or
formerly of Ima C. Meyers, North two and three-fourths degrees East (N 02 3/4° E), for a
distance of one hundred eighty-three feet five inches (183'5") to a post; thence by the same North
eighteen degrees East (N18* East) for a distance of seventy-one feet three inches (71' 3") to a
point in the center of said Pennsylvania Route 641; thence by the centerline of said Pennsylvania
Route No. 641, South seventy-one degrees East (S 71 ° E) for a distance of fifty-six feet (561 to a
point, said point marking the Place of BEGINNING).
BEING IMPROVED with a building formerly known as The Reformed Mennonite Church of
Plainfield, Pennsylvania.
IT BEING the same premises which Michael A. Brookhart and Sharlene H. Brookhart, his wife,
by deed of April 30, 2001, and recorded in Deed Book 244 at page 17, granted and conveyed
unto Jonathan G. Ritchey and Sherri M. Ritchey, his wife, the Grantors herein.
UNDER AND SUBJECT, nevertheless, to easements, restrictions, reservations, conditions and
rights-of-way of record.
AND the said grantor/grantors do hereby SPECIALL Y WARRANT the property
hereby conveyed.
IN WITNESS WHEREOF, I/We set our hands and seals the day and year first above
written.
Seated and Delivered
in the presence of:
(SEAL)
A . RITCHEY
Q
SHERRI M. RITCHEY
BWK 264 PACE3307,
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47• 1f9 ll7 O IA In If7 O d Q O O L?;' `
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STATE OF PE YLV f,
COUNTY OF / ss
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On this the J??
Y of 2004, bef(We nip " a No
k- 4
undersiBned officer, permnally ap&med:
'
JONATHAN G. RITCHEY AND SHERRI M. RITCHEY, HIS WIFE
known to me, or satisfactorily proven to be the person(s) whose Name(s) are subscribed to the
within instrument, and acknowledged that they executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I have hereunto set and notarial
NOTARY PUBLIC
MY COMMISSION EXPIRES;
NOTAai
Ol MTy9 L HTsaA I hereby certify the precise residence of the Grantee(s) herein is as follows:
40? 44
-01 7
for Grantee(s)
Office of the Recording of Deeds in and for CUMBERLAND County, Pennsylvania,
Recorders' Certificate:
In Cuz??I--
1 '
9001( 264 PACE3308"`
CERTIFICATE OF SERVICE
I, Shelly R. Brooks, an authorized agent for Martson Deardorff Williams Otto Gilroy &
Faller, hereby certify that a copy of the foregoing Lien was served this date by depositing same in
the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Mr. Daniel Behrens
Ms. Kimberlee Behrens
707 Opossum Lake Road
Carlisle, PA 17015
MARTSON LAW OFFICES
Ten EasVHigh Street
Carlisle, PA 17013
(717) 243-3341
Dated: ol,"' a-
FAFILES\Clients\13599 West Penn\7 3599.2\13522.2.Behrens\I3599.2..behrens.pra.sat.wpd
Hubert X. Gilroy, Esquire
I.D. No. 29943
R. Christopher VanLandingham, Esquire
I.D. No. 307424
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
WEST PENNSBORO TOWNSHIP : IN THE COURT OF COMMON PLEAS OF
MUNICIPAL AUTHORITY, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
: NO. 2012 - 5162 MI
V. MCID to :.z--,,
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In
DANIEL J. BEHRENS and : MUNICIPAL LIEN .Cn� U
KIMBERLEE K. BEHRENS,
Defendants z C
> N CD
PRAECIPE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please mark the Lien in the above-captioned matter as satisfied and paid in full.
Respectfully submitted,
WEST PENNSBORO TOWNSHIP MUNICIPAL
AUTHORITY
B .
Hubert X. Gilroy, Isquire
I.D.No. 29943
Assistant Solicit
Martson Law O ces
10 East High Street, Carlisle, PA 17013
(717) 243-3341
Date: August 30, 2013 q. 5z�dlt�
CERTIFICATE OF SERVICE
I,Shelly R.Taylor,an authorized agent for Martson Deardorff Williams Otto Gilroy&Faller,
hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the
Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Mr. Daniel Behrens
Ms. Kimberlee Behrens
707 Opossum Lake Road
Carlisle, PA 17015
MARTS LAW OFFICES
B
elly'V4 yl;01
Ten Egh t
Carlisle, PA 17013
(717) 243-3341
Dated: August 30, 2013