HomeMy WebLinkAbout13-5194 IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CAMP HILL BO ROUGH CIVIL DIVISION
2145 WALNUT STREET
CAMP HILL, PA 17011 3 �
Plaintiff, No.: / f MLD
VS.
JEREMY M. RUNKLE y
w cn rc ,
204 DEANHURS,T AVENUEf,, M
CAMP HILL, PA 17011 �' r`ri
PARCEL ID #01 -22- 0533 -050 ca:
Defendant.
MUNICIPAL CLAIM FOR SEWER RATES
`-,
TO: PROTHONOTARY
SIR/MADAM:
Camp Hill Borough, Cumberland County, Pennsylvania, by its attorneys JSDC Law
Offices, hereby files its claim for the sewer rate charged against the real estate hereinafter
described, located in the Borough of Camp Hill, Cumberland County, Pennsylvania, and sets
forth its claim as follows:
Statement of Claim
1. The name of the municipality by which this claim is filed is Camp Hill Borough.
2. The Authority under and by virtue of which this sewer rate was charged is as
follows: (a) Section 4 of the Act of 1945, P.L. 382, 53 P.S. §306, Municipalities
Authorities Act of 1945, as amended; and (b) Resolution of Camp Hill Borough
adopted on June 8, 2011, establishing the sewer rates and regulations of Camp
Hilli Borough for the sewer system for the Borough of Camp Hill, and authorizing
the collection and enforcement of sewer rates in this manner prescribed by law.
3. All acts, conditions, events and things required to be done by Camp Hill Borough
under the Acts of Assembly of the Commonwealth of Pennsylvania have been
done and performed in due and legal form so as to entitle Camp Hill Borough to
file a lien for the payment of the sewer rates for which this claim is filed.
4. The name of the owner or reputed owner of the property against which this claim
is filed, is Jeremy M. Runkle.
5. The property against which this claim is filed is known and numbered as 204
Deanhurst Avenue, Camp Hill, Pennsylvania 17011. ,4a /, �; V P
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6. This sewer rate was charged for sewer service furnished to the above - described
property, the sewer lines and the sewer rate being charged for the prior years to
and including the present.
Rental, Penalties, Interest. Collection Fee and Costs
As of September 3, 2013 and /or March 5 2014
Sewer Rents through 2 nd Quarter 2013 Billing $ 1,632.50
Penalties through 2 nd Quarter 2013 Billing_ $ 420:78
Attorney' Fees through March 5, 2014 Sheriff Sale $ 3,465.00
TOTAL: $ 5,518.28
Plus additional attorneys' fees and costs incurred by Camp Hill Borough in collection of
the above claim in laccordance with the fee schedule authorized by Resolution of Camp Hill
Borough. j
7. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq.
(1977), Defendant may dispute the validity of the debtor any portion thereof. If
Defendant does so in writing within fifteen (15) days of receipt of this pleading,
Counsel for Plaintiff will obtain and provide Defendant with written verification
thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested
within fifteen (15) days of receipt of this pleading, Counsel for Plaintiff will send -
Defendant the name and address of the original creditor if different from above.
Payment ofthe above claim not having been made, enter the same in the proper
Municipal Lien Doi ket and Judgment Index.
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JSDC CES
By:
S tt A.. Dietterick, Esquire
Supreme Court I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533 -3280
Attorney for Plaintiff
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DATE: September 13, 2013
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CAMP HILL BOROUGH CIVIL DIVISION
2145 WALNUT STREET
CAMP HILL, PA 17011
Plaintiff, No.: MLD
VS.
JEREMY M. RUNKLE
204 DEANHURST AVENUE .
CAMP HILL, PA 17011 .
PARCEL ID #0122- 0533 -050
Defendant.
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the Municipal Claim for Sewer
Rents was served on the following this 3` day of September, 2013, via First Class U. S. Mail, Postage
Pre -paid:
Jeremy M. Runkle
204 Deanhurst Avenue
Camp Hill, PA 17011
Respectfully Submitted:
J W OFFICES
By
Denise L. Foster, Paralegal