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Home My WebLink About13-4026 �t LAW OFFICES OF PETER J. RUSSO, P.C. BY: Paul D. Edger, Esquire 3 Al 2 �'i is f PA Supreme Court ID: 312713 CUMBERLAND COUN Peter J. Russo, Esquire PENNSYLVANIA PA Supreme Court ID: 72897 5006 East Trindle Road, Suite 203 Lindsay Gingrich - Maclay PA Supreme Court ID: 87954 Mechanicsburg, PA 17050 Telephone: (717) 591 -1755 Attorneys for Claimant CHAD SEACHRIST, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW PEGGY MATANGOS, : N0.2013- ( in 1 Defendant : MECHANICS LIEN CLAIM MECHANICS' LIEN CLAIM AND NOW, COMES Chad Seachrist ( "Seachrist "), by and through his attorney, Paul D. Edger, Esquire, and the Law Offices of Peter J. Russo, P.C., files this Mechanic's Lien Claim, and, in support thereof, avers as follows: 1. Claimant, Chad Seachrist, is an adult individual with an address of record of 416 Hillside Road, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Seachrist is filing this claim as a contractor under the Mechanic's Lien Law of 1963.49 P.S. § 1101 et seq. 3. The owner or reputed owner of the property subject to the lien is Peggy Matangos ( "Matangos: ") with a mailing address of 1709 Sherwood Road, New Cumberland, Cumberland County, Pennsylvania 17070. 4. Notice pursuant to 49 P.S. § 1501 was served upon the owner, Peggy Matangos, on June 20, 2013, by certified mail upon the owner's legal counsel, John A. Davidson, Esquire, �� who accepted service on his client's behalf, as set forth on the affidavit attached hereto as Exhibit "A." 5. The builder is identified as Chad Seachrist with a mailing address of 416 Hillside Road, New Cumberland, Cumberland County, Pennsylvania 17070. 6. The date on which Seachrist completed the work for which this claim is being made was February 12, 2013, which is less than six months from the date of this filing. 7. Seachrist files this claim based on a written agreement with Matangos wherein Seachrist agreed to provide various remodeling services upon the subject property, including, but not limited to renovating the bedrooms, kitchen, garage, and other rooms of the home. A detailed description of the work Seachrist performed is set forth in the document which is attached hereto as Exhibit `B." 8. The amount claimed to be due is $8,100.00 9. The improvement and property claimed to be subject to the lien is renovations in the real property located at 1707 Sherwood Road, New Cumberland, Tax Parcel No. 26 -23- 0543 -226. A true and correct copy of the deed to the property subject to the lien is incorporated herein, made a part hereof, and attached hereto as Exhibit "C." WHEREFORE, Claimant, Chad Seachrist, claims to have a lien upon the premises herein described in the amount of $8,100.00 plus interest, costs of suit and such other and further relief as the Court may deem appropriate. ec u d, BY: e Law O es o bm' f Peter J. Russo, P.C. Peter J. Russo, Esquire PA Supreme Court ID: 72897 Lindsay Gingrich - Maclay, Esquire PA Supreme Court ID: 87954 PPaul D. Edger, Esquire PA Supreme Court ID: 312713 5006 East Trindle Road, Suite 203 Mechanicsburg, -PA 17050 f Telephone: (717) 591 -1755 Date: I ( 113 Attorneys for Claimant CHAD SEACHRIST, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW PEGGY MATANGOS, : NO. 2013- Defendant : MECHANICS LIEN CLAIM VERIFICATION I, Chad Seachrist, hereby verify that I am an adult individual; that I am a contractor under the laws of Pennsylvania, and that I am authorized to make this statement on my behalf, that I have read the foregoing document, and that the facts set forth in the foregoing document are true to the best of my knowledge, or 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. d eachrist Date: -� — / LAW OFFICES OF PETER J. RUSSO, P.C. BY: Paul D. Edger, Esquire PA Supreme Court ID: 312713 Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 East Trindle Road, Suite 203 Lindsay Gingrich - Maclay PA Supreme Court ID: 87954 Mechanicsburg, PA 17050 Telephone: (717) 591 -1755 Attorneys for Claimant CHAD SEACHRIST, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. . : CIVIL ACTION - LAW PEGGY MATANGOS, : NO. 2013- Defendant : MECHANICS LIEN CLAIM CERTIFICATE OF SERVICE 1, Derek M. Strouphauer, Paralegal, hereby certify that I am on this day serving a copy of the foregoing Mechanics Lien Claim upon the person and in the manner indicated below and addressed as follows: United States First Class Mail: John A. Davidson, Esquire Law Office of John A. Davidson 107 North Front Street, Suite 117 Harrisburg, PA 17101 Date: Stro phauer, aralegal EXHIBIT "A" I ■ Complete items 1, 2, and 3. Also complete h. dig u item 4 if Restricted Delivery Is desired. / ■ Print your name and address on the reverse Agent ` so that we can return the card to you. ec tved b Addressee 1 Attach this card to the back of the maiipiece, y (Prfntcd Name) C. Da of D live or on the front If space permits. �� I. Article Addre ssed. to: Is delivery address different from item 1? O Yes n (� If YES, enter delivery address below: ❑ No OCCVtG��C� a w , W c , n ._-« =• w .� a o ` ( � l 'r �- q �y� !'� �� 3. Serv'0 ype I I 3 3 n �'� m l f� s ly J , ertified Mail ❑ Express Mail 1 y G y o y m; m m l J O Registered "turn Receipt for Merchandise CD 00 L 3 ` 13 Insured Mail' O C.O.D. a CL m ti 4. Restricted Delive m f+ ,. W c ,° o y m m ry? (Extra Fee) 1:1 Yes -Z C w r- a a iv 2. Article Number _ °oN n o a< I (Transfer from sen! /ce Ia6eQ 7010 10 6 D i� 0 01 3 296 7 7 0 2 a m n c '3 CD O m c Form 3811 February 2004 Domestic RetuReturn Receipt w C, 0 y4 p 102595-02-M-1540: S vl Z - 3 0 �A D '-' ....�.... , .. . . O m y n v D IDFina9 • I _. 3 CD � _ rn �. y UNITED STATES POSTAL SERVI VRG CD a 9— Cr - _ A �' y CD o N ❑ p m _ •Sender: Please print up e, address, apd ZIP + m fin -, J a r =•_ C7 1 c �o m m m o m EL a m m ��l �Gl 0 (3 �� "nom �� \ C �` SIT w n 3 m a < v a a -� _ R-, P D a a J-)13 s C3 ael� ru m w a � 3 o i Cn 3 ❑❑ b `° N N S Z O D 3 w O N a co CL \ -9 a i , N O 0 W m W ! �_._. C EXHIBIT "B" Residential Remodeling Estimate Owner and Billing Address Jobsite Address Peggy Matangos 1707 Sherwood Road 1709 Sherwood Road New Cumberland, PA 17070 New Cumberland, PA 17070 Master Bed Room Remove , wall paper Patch holes New drywall on ceiling, mud all joints Paint entire room White Install 2 new windows 36 "x50 " - Replace 3 outlets, I switch, covers, and light fixture Replace register covers Replace 2 door knobs Bed Room 2 Remo ,, e wall paper Patch holes Paint entire room White a Install 2 new windows 36'x50" Replace 3 outlets, i switch, covers, a:(d light fixture Replace register covers U Replace 2 door knobs Bed Room 3 Remove wall paper Patch. holes Paint entire room White Install 1 new window 52 "x50" Replace 3 outlets, I switch covers, and light fixture Replace register covers Replace 2 door knobs Hal-- l Patch holes Replace Light Paint entire room White Replace switch and cover Initial _ Thu,6 Dec 2012 3:24 PM Bath Room. I" Floor Remove and Install New Tub and Shower, faucet, and plumbing Remove and Install New Toilet Remove and Install New Vanity, faucet, and plumbing Install New linoleum Flooring Install New Med. Cabinet Remove Old Cabinet and Replace Drywall Install New Window 18 "x37" Paint entire room White (mildew resistant) Remove outlet by Tub, patch hole Replace switch and new GFI outlet bye door, new double cover Replace register cover Replace door knob Livia Room Patch holes Paint entire room White Replace 5 outlets, 4 switches, covers and light Install New exterior Steel Door, Screen Door, and Knobs Install New Window 69 "x50" Remove " Half Wall " inside front door, Fix drywall Replace register covers Dining Room " f Patch Holes Paint entire room White Install new window 52 "x50" Replace register covers Kitchen Remove and Install New Cabinets as per plan (see attached plan) Remove and Install New Counter Tops as per plan ( see attached plan ) Install new single bowl sink and faucet. Install New Dishwasher ( provided by owner) Install New Range /Oven ( provided by owner) Install New Hood fan/light over Range Remove and Replace Refrigerator /Freezer. ( provided by owner) New linoleum Flooring Installed Replace 4 outlets, 2 GFI outlets, 3 switches and covers Install new light over sink Install new fan /light in kitchen Paint entire room White (mildew resistant) Install New window 36 "x37" Replace register covers _2_ �—- Initial Thu.6 Dec 2012 324 PM Basement Remove and Install new toilet Install new vanity, faucet, and plumbing Install new wash. room sink, faucet, and plumbing Drylock entire basement walls New drywall installed on " finished " portion of basement ( walls and ceilings) Paint entire room White Install new linoleum flooring on " finished " portion of basement Repair steps from first floor to basement Replace exterior Steel Door, Screen Door, and Knobs Install 4 new basement windows 15 "02" All materials and labor for above fisted are included in job estimate. Total Renovation Estimate $ 32,400.00 Any and all unforeseen repairs are to be billed on a Time and Materials .Rate. These rates are as follows Materials - at cost Labor - $ 25.00 per hour Payment will be as follows 50% down payment $ 16,200.00 25% at completion of first phase $ 8,I00.00 Remaining balance of renovation paid at final walk -thru First phase includes all bed rooms, hallway, bath room, and living room. The above terms are satisfactory and are hereby approved by owner and contractor. Pegg angos — owner Date uhf Seachrist — contractor Date 416 Hillside Rd. New Cumberland, PA 1 7070 PA # 083221 i Initial -3- Thii.6 DPC ?f11? 3• ?4 pnA EXHIBIT «C" ? •„ Inst. # 201300852 - Page 1 of 5 I I F26-23-0543-226 IFIED PROPERTY IDENTIFICATION NUMBERS - NEW CUMBERLAND2 Prepared by and Return to : IS REGISTRY 01/09/2013 BY DC I Guardian Transfer Corporation j Camp Hill, PA 17011 717 - 909 -4700 i File No. 12- 1855GC Parcel ID # 26 -23- 0543 -226 �� 3f i �er�tul'E, made the day of / �- �P1rLUEPYT THE ESTATE OF JOSEPH ZEDLAR, BY HIS EXECUTRIX AMY G. YOVANOVICH (hereinafter called the Grantor), of the one part, and PEGGY MATANGOS, AN ADULT INDIVIDUAL (hereinafter called the Grantee), of the other part, ItltE�gEtYj, that the said Grantor for and in consideration of the sum of Sixty -Two Thousand Five Hundred And 00 /100 Dollars ($62,500.00) lawful money of the United States of America, unto her well and truly paid by the said Grantee, at or before the sealing and delivery hereof, the receipt whereof is hereby acknowledged, has granted, bargained and sold; released and confirmed, and by these presents does grant, bargain and sell, release and confirm unto the said Grantee, as sole owner ALL THAT CERTAIN lot of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, bounded and described as follows: BEGINNING at a point on the easterly line of Sherwood Road at the Northerly line of five hundred sixty -three and six tenths (563.6) feet measured westwardly and northwardly along said line of Sherwood Road form the Norwest corner of the southerly intersection of Sherwood Road and Locust Street; thence Northeastwardly at right angles with Sherwood Road and along said line of Lot No. 7, Block `B ", ninety -eight and twenty -five one hundredths (98.25) feet to a point; thence northwestwardly along the westerly lines. of Lots Nos. 27 and 26, Block `B ", sixty -five and ninety -seven one - hundredths (65.97 feet to a point; thence southwestwardly along the southerly line of Lot NO. 9, Block `B" ninety -five and ninety -three one hundredths (95.93) feet to a point on the easterly line of Sherwood Road; thence southwastwardly at right angles along said line of Sherwood Road sixty -five and ninety -five one hundredths (65.95) feet to a point, the place of BEGINNING. BEING Lot No. 8, Block `B" on the plan of Lots of Highland Park Extension, said plan being recorded in the Cumberland County Recorder's Office in Plan Book 5, Page 59. T • Inst. # 201300852 - Page 2 of 5 I, i HAVING THEREON ERECTED a single dwelling house No. 1707 Sherwood Rd, New Cumberland, Penna. BEING the same premises which N.P. Ninneman, Inc., by Deed dated October 12, 1953, and recorded October 13, 1953, in the Office of the Recorder of Deeds in and for the County of Cumberland, Pennsylvania, in Book K -15, Page 364, granted and conveyed unto Joseph Zedlar, in fee. i AND THE SAID Joseph Zedlar departed this life on October 2, 2012 leaving a will dated July 13, 2012 and duly proven and probated in the Office of the Register of Wills in and for Cumberland County to Estate File No. 2012 -01106 whereby Letters Testamentary were granted October 11, 2012 to Amy G. Yovanovich, Executrix. ToyetY er Wit) all and singular the buildings and improvements, ways, streets, alleys, driveways, passages, waters, water- courses, rights, liberties, privileges, hereditaments and appurtenances, whatsoever unto the hereby granted premises belonging, or in anywise appertaining, and the reversions and remainders, rents, issues, and profits thereof, and all the estate, right, title, interest, property, claim and demand whatsoever of her, the said grantor, as well at law as in equity, of, in and. to the same. AGO *9 alto to 1)0[b the said lot or piece of ground described above, with the buildings and improvements thereon erected, hereditaments and premises hereby granted, or mentioned and intended so to be, with the appurtenances, unto the said Grantee, her heirs and assigns, to and for the only proper use and behoof of the said Grantee, her heirs and assigns, forever. 911b the said Grantor, for herself and her heirs, executors and administrators, does, by these presents, covenant, grant and agree, to and with the said Grantee, her heirs and assigns, that she, the said Grantor, and her heirs, all and singular the hereditaments and premises herein described and granted, or mentioned and intended so to be, with the appurtenances, unto the said Grantee, her heirs and assigns, against her, the said Grantor, and her heirs, will SPECIALLY WARRANT AND DEFEND against the lawful claims of all persons claiming by, through or under the said Grantor but not otherwise. 2 �+ Inst. # 201300852 - Page 3 of 5 e parry of e first part as ereunto set er an an sea . ate t e ay and year first above written. &Eateb anb Melibereb IN THE PRESENCE OF US: �p 1 {SEAL} Amy G. Y anovi , Executrix Commonwealth of Pennsylvania County of Cumberland ss On this, the day of before me, the undersigned Notary Public, personally appeared Amy G. Yovanovich, Executrix of the Estate of Joseph Zelarknown to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my d and o cial sea tary lic y c fission expires 6 ZO ? 6 The precise residence and the complete post office COMMON�� f P ENNSn � � address of the above -named Grantee is: Notarial vu biic suzz Aden l Cramer, Notary CountY o° ^� ^� Hampden 7wp., �� 2014 .�V Q �L�IN` -�Z`G� `� �v�� My Comm�sslon ExP! �n of Notaries Member, rennsvi-11a ASSOd &On 4bealf f Gr ee 3 Parcel ID # 26 -23- 0543 -226 The Estate of Joseph Zedlar, by his Executrix Airy G. Yovanovich TO Peggy Matangos N O W O O m N 1 ro w W m a 0 M Guardian Transfer Corporation 4075 Market St. Camp Hill, PA 17011 i Phone 717 - 909 -4700 Fax 717- 723 -4585 i Inst. # 201300852 - Page 5 of 5 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE :�- CARLISLE, PA 17013 717 -240 -6370 Instrument Number - 201300852 Recorded On 1/9/2013 At 10:26:17 AM * Total Pages - 5 * Instrument Type - DEED Invoice Number - 126408 User ID - SW * Grantor - ZEDLAR, JOSEPH * Grantee - MATANGOS, PEGGY * Customer - SIMPLIFILE LC E- RECORDING * FEES STATE TRANSFER TAX $625.00 Certification Page STATE WRIT TAX $0.50 STATE JCS /ACCESS TO $23.50 DO NOT DETACH JUSTICE RECORDING FEES — $12.50 RECORDER OF DEEDS This page is now part PARCEL CERTIFICATION $10.00 of this legal document. FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 WEST SHORE SCHOOL $312.50 DISTRICT NEW CUMBERLAND BOROUGH $312.50 TOTAL PAID $1,313.00 I Certify this to be recorded in Cumberland County PA cF CU )"14— .p. b V � RECORDER OF DEEDS Irao * - Information denoted by an asterisk may change during the verifleation process and may not be reflected on this page. FiLEL)-fiFfiu,- W: 1HE PRoilioN(fr.g, Ak., : Chad Seachrist 416 Hillside Road 2014 JAN -8 Anti: 40 New Cumberland, Pa 17070 CUMBERLAND COUNTY PLAINTIFF PENNSYLVANIA VS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION-LAW DOCKET NO. 13-4026 MECHANICS LIEN CLAIM Peggy Matangos 1709 Sherwood Road New Cumberland,Pa 17070 DEFENDANT PRAECIPE TO DISMISS /2-V-e .• Seachrist Po / Pe. . 'Matangos Asi.... 1. — . . .....- C* MONWEALTH OF PENNSYLVANIA Notarial Seal It Patricia A.Gordon,Notary Public Fairview Two.,York County I My Commission Expires July 31,2017 vF.,v:Ez =ENISYLVAIL;AssociKnorr OF mar oftitl ` 61°•`561PIPIrr nepyi I -.. U# SW 12.* gewl 1