HomeMy WebLinkAbout13-4119 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, PENNSYLVAN
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William Lovett, and �> c,
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Patricia R. Eberts ma c - ,
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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, fit' pw
Defendant(s) have not made payments for the services provided.
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:
600 East Keller Street
Borough of Mechanicsburg
Cumberland County
Pennsylvania 17055
TAX PARCEL NUMBER 17 -23- 0563 -076
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
five hundred fifty nine dollars and fifty cents ($559.50), plus costs and
reasonable attorney's fees.
9. The time period for which these charges are filed is July 1, 2012 to June 30,
2013 on Sewer and Refuse Account 2509 -0.
WHEREFORE, Claimant requests that a Municipal Lien be entered in its
favor and against the Defendant in the amount of five hundred fifty nine dollars
and fifty cents ($559.50), plus cost and reasonable attorney's fees.
BOROUGH OF ECHANICS URG
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 s e is the &ffr<-c-
Manager for the Borough of Mechanicsburg, and that the facts set forth in the foregoing instrument
are true and correct to the best of laer knowledge, informatio e le .
Pa" trick E. Dennis, Borough Manager
Sworn to and subscribed before me
NOTARIAL SEAL
this-,I Ith day c f June, 2 rtiailie S Hooker
NOTARY PUBLIC
Mechanicsburg Boro, Cumberland County
My Commission Expires 04102/2017
Notary Public
.
4 /7'u?3� 65 &3-- alb
THIS DEED, 0 0155R
MADE THE dcl day of o i�bv in the year
of our Lord two thousand and eight (2008)
BETWEEN AMY H. KENNEDY, single person, by HAROLD L. KENNEDY, her
Attorney -in -Fact,
Grantor,
and PATRICIA'R. EBERTS, adult individual and WILLIAM LOVETT, adult
individual,
Grantees,
WITNESSETH, that in consideration of-------------------------
- -One Hundred Thirty -Nine Thousand Five Hundred ($139,500.00) -- Dollars
in hand paid the receipt whereof is hereby acknowledged, the said
grantor does hereby grant and convey to the grantees,
ALL THAT CERTAIN tract or lot of land situate in the Borough of
Mechanicsburg, Cumberland County, Pennsylvania, being more particularly
bounded and described as follows, to wit:
BEGINNING at a point on the south side of East Keller Street at the
dividing line between Lots Nos. 31 and 32 on the plan of lots referred
to hereinafter, which said point is also a distance of 374.85 feet
measured westwardly along the south side of East Keller Street from
Marble Street; and extending thence along the dividing line between Lots
Nos. 31 and 32, South 17 degrees 8 minutes East, a distance of 131.83
feet to a point; extending thence South 74 degrees 25 minutes 30 seconds
West, a distance of 67.86 feet to a point; extending thence North 28
degrees 30 minutes West, a distance of 130.23 feet to a point on the
south side of East Keller Street; extending thence along the south side
of East Keller Street, North 72 degrees 48 minutes East, a distance of
75.65 feet to a point, the place of BEGINNING.
BEING Lot No. 31, Section "H" on the Plan of Blackburn Village, recorded
in Plan Book 7, Page 7, Cumberland County Records.
HAVING THEREON ERECTED a one -story brick and frame dwelling house known
and numbered as 600 East Keller Street, Mechanicsburg, Pennsylvania.
THIS DESCRIPTION is made in accordance with a survey by Ernest J.
Walker, R.P.E., dated March 15, 1965 and corrects to the extent
inconsistent prior descriptions.
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BEING the same premises which Bryan Lee Junkins and Judith Ann Junkins,
his wife, by deed dated April 23, 1976 and recorded in the Cumberland
County Recorder of Deeds Office in Book ~ 0 0 26, Page 178, granted and
conveyed unto Amy M. Kennedy, single person.
THE WITHIN DEED is executed and delivered by Harold L. Kennedy as
Attorney -in -Fact for Amy M. Kennedy pursuant to a Power -of- Attorney
dated September 12, 2006 and recorded on in Record Book
in the Office of the Recorder of Deeds of Cumberland County,
Pennsylvania.
AND the said grantor hereby covenants and agrees that he will warrant
specially the property hereby conveyed.
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IN WITNESS WHEREOF, said grantor has hereunto set his hand and seal
the day and year first above written.
Signed, Sealed and Delivered
n the Presence of�
(A
AMY H. KENN Y by:'
HAROLD L. KENNEDY,
Attorney -in -Fact
f
State /Comm nwealth of �� j �i�?'�
��,,•• � � ss.
Y
Count of l.l� tv
On this, the day of &hbtl 2008, before me,
the undersigned officer, personally appeared Harold L. Kennedy,
Attorney -in -Fact for Amy H. Kennedy, single person, known to me (or
satisfactorily proven) to be the persons whose names are subscribed to
the within instrument, and acknowledged that they executed same for
the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my and and official seal.
C OMMONWEALTH OF PENNS YLVANIA
Notarial Seal
Kristen D. Shiva, Notary Public �u ✓�
Lt-C,, mp Hill 6oro, Cumberland County Otary Pu C Commission Ex ices June a, 2009
Title of Officer
State /Commonwealth of
County of
On this, the day of 2008, before me,
the undersigned officer, personally appeared
known to me (or satisfactorily proven) to be the person whose name
subscribed to the within instrument, and acknowledged that
executed same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Notary Public
Title of Officer.
07/09/2013 10:25:19 AM CUMBERLAND COUNTY Inst.# 200835350 - Page 3 of
do hereby certify that the precise residence and complete
post office address of the within named qrante is
; �J ?Z). / � 0J - 6
Attorney or
COMMONWEALTH OF PENNSYLVANIA
ss.
County of
RECORDED on this day of
A. D. 2008, in the Recorder's office of the said County, in Deed Book
Vol. , Page
Given under my hand and the seal of the said office, the date
above written.
Recorder.
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ROBERT P. ZIEGLER
RECORDER OF DEEDS 5 .
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013 -
4
717- 240 -6370
Instrument Number - 200835350
Recorded On 10/28/2008 At 3:06:16 PM * Total Pages - 5
• Instrument Type - DEED
Invoice Number - 31343 User ID - RAK
• Grantor - KENNEDY, AMY M
• Grantee- EBERTS, PATRICIA R
• Customer -1ST ADVANTAGE STL SER
* FEES
STATE TRANSFER TAX $1,395.00 Certification Page
STATE WRIT TAX $0.50
STATE JCS /ACCESS TO $10.00 DO NOT DETACH
JUSTICE
RECORDING FEES — $11.50 This page is now part
RECORDER OF DEEDS
PARCEL CERTIFICATION $10.00 of this legal document.
FEES
AFFORDABLE HOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
MECHANICSBURG SCHOOL $697.50
DISTRICT
MECHANICSBURG BOROUGH $697.50
TOTAL PAID $2,838.50
I Certify this to be recorded
in Cumberland County PA
* CU
° RECORDER O D EDS
trao
- Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
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