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Home My WebLink About12-6231~:°; - ,_ ~' 1 ~~~ € F~TN:1~~?il?, ,,~ Zip ~? OCT -4 pM ~: ~ ~ k CUM~Et~LA~1~i %{ P~NhIS Yt~W~ t 1U~, ~ J~'~' KOPE & ASSOCIATES, LLC W. Creigh Manson PA 94759 395 Saint Johns Church Road Camp Hill, PA 17011 717-761-7573 cmartsonQkopelaw.com -~- I ~-tai 3 l Attorney for Claimant N~~p IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSLYVANIA Docket No. MECHANICS' LIEN rN AND NOW, this ~ day of October 2012, comes the Claimant, Russell Brown, by and through his counsel, Kope & Associates, LLC, and files this Mechanics' Lien and in support thereof avers the following: 1. The undersigned Claimant, Russell Brown ("Claimant'), hereby claims a Mechanics' Lien under 49 P.S. §1101 et seq., for the labor, services, equipment, and materials described below, furnished by Claimant for the improvement, erection, construction, alteration, and/or repair of residential property located in Cumberland County, Pennsylvania. 2. Said residential property having a Parcel No. 01-22-0536-026, Instrument No. 201033958, recorded in the Cumberland County Recorder of Deeds on November 19, 2010, and erected thereon a one and one-half story brick and frame dwelling house known and numbered as No. 55 South 19th Street, Camp Hill, Pennsylvania ("Property") Qw.! s~~ `~ pd aN•~ Ck-~b 4449 ~~+a8i~i 3. The owners of said residential property are Dean Foote and Elizabeth Krouse, 223 Wood Street, Camp Hill, Pennsylvania, 17011. 4. The persons with whom Claimant contracted to furnish the labor, services, equipment, and materials are Dean Foote and Elizabeth Krouse, 223 Wood Street, Camp Hill, Pennsylvania, 17011. 5. Claimant, pursuant to his contract with Mr. Foote and Ms. Krouse, furnished labor, services, equipment, and materials for the Property including, but not limited to, carpentry, plumbing, electrical work, heating/ ventilation/ air-conditioning work, painting, landscaping, appliance installation, removal of waste, and general construction work. 6. Claimant completed his work on the Property on April 18, 2012. 7. After adjusting for all just credits and offsets, the sum of $10,474.16, together with interest thereon, is due Claimant. Respectfully Submitted, KOPE & ASSOCIATES, LLC Dated: ~~ y ~~ By; W. Creigh Manson Attorney for Claimant VERIFICATION 1, Russell Brown, Claimant in this matter, have read the foregoing Mechanics' Lien. I verify that the averments therein are true and correct and are based upon my personal knowledge. I understand that any false statements herein are made subject to the penalties of 18 Pa. C. S. §4904 relating to unsworn falsification to authorities. Dated: -I-`~i ~' `~dd~~Xd~~~~1/~- Russell Brown, Claimant KOPE & ASSOCIATES, LLC W. Creigh Manson PA 94759 395 Saint Johns Church Road Camp Hill, PA 17011 717-761-7573 cmansonQkopelaw.com Attorney for Claimant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSLYVANIA Docket No. CERTIFICATE OF SERVICE I, W. Creigh Manson, hereby certify that on October 4, 2012, I served a true and correct copy of the foregoing Mechanics' Lien as follows: VIA HAND DELIVERY David D. Buell Cumberland County Prothonotary 1 Courthouse Square Suite 100 Carlisle, PA 17013 KOPE & ASSOCIATES, LLC W. Creigh Manson PA 94759 395 Saint Johns Church Road Camp Hill, PA 17011 717-761-7573 cmartsonQkopelaw.com r -oc~ 2Z P~ ~: ~ ~ °~~~ KOPE & ASSOCIATES, LLC W. Creigh IVlartson PA 94759 395 Saint Johns Church Road Camp I-Till, PA 17011 717-761-7573 cmartsonCkopelaw.com Attorney for Clamant IN 'THE COURT OF COMMON PLEAS OF CUMBER:LAND COUNTY, PENNSI'L~~ANIA Mechanics' Lien Docket No. 12-6231 MLD PROOF OF SERVICE The undersigned makes the following return of service: the Mechanics' Lien was served by personal service upon the Defendant, Dean Foote, on October 16, 2012, at 223 Wood Street, Camp Hill, 1'A. The .Affidavit of Service is attached hereto and made a part hereof as Exhibit 1. SIGNATURE AND AFFIDAVIT 1 verify that the statements made in this Affidavit and Proof of Service are true and correct to the best: of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities,. Respectfully Submitted, KOPE & ASSOCIATES, LLC Dated: / - ~~`-?i'~` t-' B ~ ' ~ ~'l' ~~~~ ~~-,----~ - Y• --~ W. Creigh Martson Atf:ornev for Claimant, Russell Brown AFFIDAVIT State of Pennsylvania County of Dauphin SS: Before me the subscribers personally appeared ~fulie A. Conti to me known, being duly sworn according to law, doth depose and say on October 16, 2012 @ 3:20 p.m., I ser~red Elizabeth Knouse at 223 Wood Street, Camp Hill, PA, a Mechanics' Lien; Cumberland County, Pennsylvania No. 126231 MLD, by handing the lien to Dean Foote, who accepted service on Elizabeth's behalf. And further deponent sayeth not. 'e A. Conti 23 N. Front St. a~ sburg, PA 17110 Sworn and subscribed before me this 1 ~') t 4, day o f 6~= C'1- o~e.~ Z_ 2 012 ,y \\ Notary ublic c ~. ., COMMONWEl1LTH OF PENNSYLVANL4 Notarial Seal )aoquelyn R. Ryan, Notary Pubik Susquehanna Tvrp., Dauphin County hty Cattmission Expires July 27, 2016 MEMBER,PENNSYLVANiA ASSOCIATION OF NOTARIES EXHIBIT ~ ~r ~ ~.~ ~~l2>~0~ 2I Pl~t 2: 3~ 7E~`dSY~t~~~±r l7J.S ~. ~ ~ ~~ f C~,~. ~~ ~~ KOPE & ASSOCIATES, LLC W. Creigh Martson PA 94759 395 Saint Johns Church Road Camp Hill, :PA 17011 717-761-7573 cmartson@kopelaw.com Attorney for Claimant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSLYVANIA Docket No. 12-6231 MLD SATISFACTION OF MECHANICS' LIEN sa- AND NOW, this ~ day of November 2012, comes the Claimant, Russell Brown, by and through his counsel, Kope & Associates, LLC, and files this Satisfaction of Mechanics' Lien pursuant to 49 P.S. ~ 1704 and in support thereof avers the following: 1. On or about October 4, 2012, the Claimant filed a Mechanics' Lien pursuant to 49 P.S. X1101 et seq., in connection with the labor, services, equipment, and materials furni,<~hed by Claimant for the improvement, erection, construction, alteration, and/or repair of the residential property situated at 55 South 19~ Street, Camp Hill, Pennsylvania. 2. On oi• about November 19, 2012, the Claimant was paid for his services and the Mechanics' Lien was satisfied through mutual agreement of the parties. ~p~~1 ~U~'~C 9 ~° P`~' 3 ~~ ~~ 3. Claimant, therefore, now desires to settle, discharge, and otherwise dispose of his Mechanics' Lien against the aforesaid property. WHF;REFORE, Claimant seeks to enter upon the record payment and satisfaction of his Mechanics' Lien pursuant to 49 P.S. X1704. Respectfully Submitted, KOPE & ASSOCIATES, LLC Dated: -! /~ ~ ~` >aZ ~/~ ~-c~'/ _ ----- By: -- W. Creigh Martson PA 94759 VERIFICATION I, Russell Brown, Claimant in this matter, have read the foregoing Satisfaction of Mechanics' Lien. I verify that the averments therein are true and correct to the best of my knowledge, information, and belief. I understand that any false statements herein are made subject to the penalties of 18 Pa. C. S. X4904 relating to unsworn falsification to authorities. Dated: "~~ Russell Brown, Claimant CERTIFICATE OF SERVICE I hereby certify that this ~rday of November, 2012, I served a true and correct copy of the foregoing Satisfaction of Mechanics' Lien as follows: VIA HAND DELIVERY David D. Buell, Prothonotary 1 Courthouse Square Suite 100 Carlisle, PA 17013 VIA FIRST CLASS MAIL Mr. and Mrs. Dean Foote 223 Wood Street Camp Hill, PA 17011 KOPE & ASSOCIATES, LLC W. Creigh Martson PA 94759 395 Saint Johns Church Road Camp Hill, PA 17011 717-761-7573 cmartson@kopelaw.com