HomeMy WebLinkAbout02-0911 N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
S & W PETROLEUM SERVICES, INC.
Claimant :
:
v. : No. OD. g/! ~Oof 2002
KUSIC CAPITAL GROUP, IV, L.L.C. :
Owner : MECHANICS' LIEN
NOTICE OF FILING OF MECHANICS' LIEN CLAIM
To: Kusic Capital Group, IV, L.L.C.
4201 Crums Mill Road
Harrisburg, PA 17112
You are notified that a mechanics' lien claim in the amount
of $24,485.13 has been filed on behalf of S & W Petroleum
Services, Inc., against the property at 6035 Carlisle Pike,
Mechancisburg, Cumberland County, Pennsylvania, of which you are
the owner or reputed owner. The claim was filed on February 22,
2002 in the Court of Common Pleas of Cumberland County, as of
No. ~-91J ;~kD 7~,~ · A copy of the claim is attached.
Date: February 22, 2002
2423 North Third Street
Harrisburg, PA 17110
(717) 238-0434
Attorney I.D. No. 23705
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
S & W PETROLEUM SERVICES, INC. : Claimant
v. : No. o~.9t/ ~l~ of 2002
KUSIC CAPITAL GROUP, IV, L.L.C.
Owner : MECHANICS' LIEN
MECHANIC'S LIEN CLAIM
Claimant, S & W PETROLEUM SERVICES, INC., through the
undersigned counsel, files this claim against the improvements
at 6035 Carlisle Pike, Mechanisburg, Hampden Township,
Cumberland County, Pennsylvania, for the payment of a debt due
Claimant, as a contractor, for labor and materials furnished by
Claimant for the premises. In support of the claim the Claimant
makes the following statement:
1. The Owner of the property is Kusic Capital Group, IV,
L.L.C., with an address at 4201 Crums Mill Road, Harrisburg,
Dauphin County, Pennsylvania.
2. The improvements and the property which are subject to
this claim are a store, gasoline pumps and related improvements
and appurtenant land at 6035 Carlisle Pike, Mechanicsburg,
Hampden Township, Cumberland County, Pennsylvania.
3. The labor and material for which the debt is due were
furnished for an agreed sum pursuant to a contract of which
$24,485.13 is due, together with interest, costs and fees.
4. The labor for which the debt is due consists of
breaking up concrete, excavating underground oil tanks, removing
tanks, backfilling tank holes, replacing concrete, stockpiling
contaminated soil, loading contaminated soil, and supplying and
hauling materials and equipment to remove all petroleum
servicing equipment from the premises and numerous other related
matters. The labor and materials were a substantial addition to
the existing structure.
5. Claimant completed its work to the extent permitted by
Owner at the property on or about November 8, 2001, which is
less than four (4) months before the filing of this claim.
There is due and owing a balance of $24,485.13 together with
interest, costs and fees and claim is made therefore.
Date:
~regory R.~'Reed~ Esquire
Attorney for Claimant
2423 North Third Street
Harrisburg, PA 17110
(717) 238-0434
Attorney I.D. No. 23705
VERIFICATION
This ~ day of February, 2002, the foregoing Claimant
hereby verifies, subject to the penalties of 18 Pa.C.S. 4904
(relating to unsworn falsification to authorities), that the
facts set forth in the foregoing Mechanic's Lien Claim which are
within his knowledge are true, and as to the facts based on
information received, after diligent inquiry, he believes them to
be true.
C. L. Sterner, President of
S & W Petroleum Services, Inc.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
S & W PETROLEUM SERVICES, INC.
Claimant
KUSIC CAPITAL GROUP, IV, L.L.C.
Owner
: No. 02-911 MLD of
: MECH..~q'ICS' LIEN
2002
PRAECIPE
TO:
Curt Long, Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
Please discontinue the above captioned case "with prejudice"
to Claimant.
Date:
Gregory R. Reed, Esquire
Attorney for Plaintiff
2423 North Third Street
Harrisburg, PA 17110
(717) 238-0434
Attorney I.D. No. 23705
pc: Steve Kusic
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2002-00911 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
S & W PETROLEUM SERVICES INC
VS
KUSIC CAPITAL GROUP IV LLC
R. Thomas Kline , Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named OWNER , to wit:
KUSIC CAPITAL GROUP IV LLC
but was unable to locate Them
deputized the sheriff of DAUPHIN
in his bailiwick. He therefore
County, Pennsylvania, to
serve the within MECHANICS LIEN CLAIM
On March 14th , 2002 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep Dauphin County
18.00
9.00
10.00
30.50
.00
67.50
03/14/2002
GREGORY R REED
R. FTh°mas Kline ~
Sheriff of Cumberland County
Sworn and subscribed to before me
this /9 ~ day of ~
~ Lw~ 2~ A.D.
~ t Prothonotary
Mary Jane Snydcr
Real Estate Deputy
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 255-2660 fax: (717) 255-2889
Jack Lotwick
Sheriff
J. Daniel Basile
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Commonwealth of Pennsylvania
County of Dauphin
AND NOW:March 7, 2002
MECHANICS LIEN CLAIM
KUSIC CAPITAL GROUP IV
to KAREN CYPHERT, RECEPTIONIST
of the original MECHANICS LIEN CLAIM
to him/her the contents thereof at 4201 CRUMS MILL RD
HBG, PA 17112-0000
: S & W PETROLEUM SERVICES INC
vs
: KUSIC CAPITAL GROUP IV
Sheriff's Return
No. 0499-T - -2002
OTHER COUNTY NO. 02-911
at 8:45AMserved the within
upon
by personally handing
1 true attested copy(ies)
and makin9 known
Sworn and subscribed to
before this
me 8TH day of MARCH, 2002
PROTHONOTARY
So Answers,
Sheriff of D~in County, Pa.
By Deputy ~riff
Sheriff's Costs: $30.50 PD 03/01/2002
RCPT NO 160820
MARTIN
In The Court of Common Pleas of Cumberland County, Pennsylvania
S & W Petrole~n Services, Inc.
VS.
Kusic Capital Group IV
SERVE: s~ne No. 02 911 civil
NOW, February 25, 2002 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Dauphin County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
within
Affidavit of Service
,20 ,at
o'clock
M. served the
upon
at
by handing to
and made known to
copy of the original
So answers,
the contents thereof.
Sworn and subscribed before
me this __ day of ,20__
Sheriff of County, PA
COSTS
SERVICE
MILEAGE
AFFIDAVIT