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COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CAMP HILL BOROUGH CIVIL DIVISION
2145 WALNUT STREET
CAMP HILL, PA 17011
Plaintiff, No.: 13 ' S7re MLD
VS.
DAVID J. HUGHES
KAREN J. HUGHES c � ^_
109 N. 21 STREET - :r Z3
MM
CAMP HILL, PA 17011 C
PARCEL ID #01 -21- 0271 -384 U r —
Defendants r- � "�- c
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MUNICIPAL CLAIM FOR SEWER RATES
--� C.)
TO: PROTHONOTARY
SIR/MADAM:
a
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 l/4y
described, located in the Borough of Camp Hill, Cumberland County, Pennsylvania, and sets
forth its claim as follows: .L
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
Hill 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 DAVID HUGHES and KAREN J. HUGHES.
5. The property against which this claim is filed is known and numbered as 109 N.
21" Street, Camp Hill, Pennsylvania 17011.
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 October 4, 2013 and /or March 5, 2014
Sewer Rents through 2 nd Quarter 2013 Billing $ 1,498.50
Penalties through 2nd Quarter 2013 Billing 1 $ 398.20
Attorney' Fees through March 5, 2014 Sheriff Sale $ 3,465.00
TOTAL: $ 5,361.70
Plus additional attorneys'. fees and costs incurred by Camp Hill Borough in collection of
the above claim in accordance with the fee schedule authorized by Resolution of Camp Hill
Borough.
7. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq.
(1977), Defendant may dispute the validity of the debt or 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 of the above claim not having been made, enter the same in the proper
Municipal Lien Docket and Judgment Index.
JSDC LAW IC S
By:
'9cottV'DTeTerick,VKsquire
Supreme Court I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533 -3280
Attorney for Plaintiff
DATE: October 4, 20.13
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY; PENNSYLVANIA
CAMP HILL BOROUGH CIVIL DIVISION
2145 WALNUT STREET
CAMP HILL, PA 17011
Plaintiff, No.: MLD
VS . ,
DAVID J. HUGHES
KAREN J. HUGHES
109 N. 21 STREET
CAMP HILL, PA 17011
PARCEL ID #01 -21- 0271 -384
Defendants
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 4` day of October, 2013, via First Class U. S. Mail, .Postage Pre- i
paid:
David Hughes
Karen J. Hughes
700 Middle Lane
Camp Hill, PA 17011
Respectfully Submitted:
J , aLAOFFICES
By:
Denise L. Foster, Paralegal