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HomeMy WebLinkAbout13-4117 COYNE & COYNE, P.C. Lisa Marie Coyne, Esq. PA Supreme Court ID No. 53788 3901 Market Street Camp Hill, PA 17011 -4227 (717) 737 -0464 Fax: (717) 737 -5161 Solicitor for Borough of Mechanicsburg BOROUGH OF MECHANICSBURG, IN THE COURT OF COMMON PLEAS OF Claimant CUMBERLAND COUNTY, PENNSYLVANIA'' V. NO. /3" ��7 M.L.D. =m c rn .. r-- Michael P. Harris and, > ; CD Carrie M. Vogelsong ; E5 Defendant MUNICIPAL LIEN MUNICIPAL LIEN FOR SEWER /REFUSE RATES NOW COMES the Borough of Mechanicsburg Cumberland County, Pennsylvania, by its attorney Lisa Marie Coyne, Esquire, and files the within claim for charges assessed with respect to sewer and /or refuse rates against above named owner or owners and against the hereinafter described real estate as follows: STATEMENT OF CLAIM 1. This claim is filed by the Borough of Mechanicsburg, a borough organized and existing in accordance with the laws of the Commonwealth of Pennsylvania. 2. The owner or reputed owner of the property, or party or parties responsible or liable, for which this claim is filed is the Defendant(s). 3. The authority under which the sewer and /or refuse rates were changed and assessed is the Act of July 18, 1935, P.L. 1286, Section 1, 53 P.S. § 2231, as amended. 4. Plaintiff has made demands for payment for services; however, 4'4 Defendants) have not made payments for the services provided. As- 5. The authority under which this claim is filed is the Act of May 16, 1923 P.L. 207, Section 9, et seq ., 53P.S. §7143, as amended. 6. A description of the property against which this claim is filed is: 138 West Green Street Borough of Mechanicsburg Cumberland County Pennsylvania 17055 TAX PARCEL NUMBER 19-23- 0567 -090 7. This claim has not been the subject of any previous claim and judgment in the Court of Common Pleas of Cumberland County for sewer and /or refuse charges. 8. The total amount of the charges for which this claim is filed is six hundred twenty seven dollars and twenty five cents ($627.25), plus costs and reasonable attorney's fees. 9. The time period for which these charges are filed is October 1, 2012 to June 30, 2013 on Sewer and Refuse Account 4275 -0. WHEREFORE, Claimant requests that a Municipal Lien be entered in its favor and against the Defendant in the amount of six hundred twenty seven dollars and twenty five cents ($627.25), plus cost and reasonable attorney's fees. BOROUGH OF MECHANICSBURG T By: - Lisa Coyne, Esquire Solicitor for the Borough of Mechanicsburg PA Supreme Court ID No. 53788 Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011 (717)737 -0464 Dated: July 17, 2013 COMMONWEALTH OF PENNSYLVANIA) )ss COUNTY OF CUMBERLAND ) Patrick E. Dennis, being duly sworn according to law, deposes and says that -Fl is the (3f4ict Manager for the Borough of Mechanicsburg, and that the facts set forth in the foregoing instrument are true and correct to the best of ` knowledge, information and belief. Patrick E. Dennis, Borough Manager Sword to and subscribed before me NOTARIAL SEAL this I l th day of June, 2 l 3. Leslie S Hocker A Mechanicsburg Borro, Cumberland county ' My Commission Ex ires 04/02/2017 C Notary Public L4 5 - PA X006 �'1�Y 3 PIS 3 56 THIS DEED, MADE THE 28TH day of April in the year two thousand six (2006), BETWEEN JAIME M. ROHRBAUGH, an adult individual, of the Borough of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter called Grantor, AND MICHAEL P. HARRIS and CARRIE M. VOGELSONG, adult individuals, of the Borough of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter called Grantees, WITNESSETH, that in consideration of the sum of One Hundred Thirty -four Thousand and no /100 ($134,000.00) Dollars, the receipt whereof is hereby acknowledged, the said Grantor does hereby grant and convey unto the said Grantees, their heirs and assigns, as joint tenants with the right of survivorship and not as tenants in common; ALL that certain lot, parcel, piece of ground, with the improvements thereon erected, situate in Mechanicsburg Borough, Cumberland County, Pennsylvania, bounded and described in accordance with a survey prepared by D.P. Raffemberger Associates, dated August 13, 1982, as follows, to wit: BEGINNING at an iron pin on the northeast line of West Green Street at corner of property now or late of John A.H. Zeigler and Anna Zeigler, his wife; thence along said last mentioned land, North 2 degrees 15 minutes East, 12.80 feet of a point; thence along the same, North 9 degrees 54 minutes West, 16.43 feet to a point; thence along the same, North 80 degrees 4 minutes 38 seconds East, 4.19 feet to a point thence along the same, North 2 degrees 15 minutes East 92.40 feet to a post at a 15 foot alley, thence by said alley, North 79 degrees 15 minutes East 27 feet to a point at the dividing line between the lot herein described and Lot No. 2 as described in the above - referenced survey. thence along said last mentioned dividing line South 2 degrees 15 minutes West 122 feet to a point on the northern side of West Green Street; there 6 ox 274 PnFJ409 07/15/2013 10:11:37 AM CUMBERLAND COUNTY Instl 200614386 - Page 1 of 3 HAVING THEREON ERECTED a two -story frame dwelling house known and numbered as 138 West Green Street. AND BEING the same premises which Scott H. Vance and Lisa A. Vance, husband and wife, granted and conveyed unto Jaime M. Rohrbaugh, single woman, grantor herein, by deed dated January 29, 2002, and recorded in the Office of the Recorder of Deeds in Deed Book 250, Page 1669. AND the said Grantor hereby covenants and agrees that she will warrant specially the property hereby conveyed. IN WITNESS WHEREOF, said Grantor has hereunto set her hand and seal the day, month and year first above written. Signed, Sealed and Delivered in the pr, ence of EAL) AIME M. ROHRBAUGH M id i� h•i�••1.� -t t 1 A A 6 [4O] t ic. ,py C• N co Jb- IV cn m o •J to � w a 2 27 nox 274 wd410 07/15/2013 10:11:37 AM CUMBERLAND COUNTY Instl 200614386 - Page 2 of 3 COMMONWEALTH OF PENNSYLVANIA . SS: COUNTY OF CUMBERLAND �r On this, the �._ day of April, 2006, before me the undersigned officer, personally appeared JAIME M. ROHRBAUGH, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and seal. e�� (SEAL) OF PENNSYL -MV M Sea! III, Notary Pitlio M �l unb&iWd C WAV xpires Od 10. 20M Mwnbar, Pennsylvania Association d Notaries I do hereby certify that the precise residence and c plete st ffice address of the within named Grantee is J S? wwf l �tn44� x+•1.5 �a..�..+ 176 I � J April 2006 Attorney or e IRWIN & McKNIGHT ATTORNEYS AT LAW 60 West Pomfret Street Carlisle, PA 17013 717 -249 -2353 PA Rec rcler of Deeds 3 goo 2 74 PAUJAii 07/15/2013 10:11:37 AM CUMBERLAND COUNTY Intl 200614386 - Page 3 of 3