HomeMy WebLinkAbout04-6388
Group & Group Excavating LP
1545 Holly Pike
CarIisle, PA 17013
IN THE COURT OF
COMMON PLEAS OF
CUMBERLAND
COUNTY, PENNSYLVANIA
v.
1800 High Street Corporatiou, a Pennsylvania
Corporation, 34 Teaberry Drive, Carlisle, PA; and,
Angel Pablo Oliva, individually; and, Carlisle Diner,
Inc., 800 West High Street, Carlisle, PA; and, Ruben : DOCKET NO: 0 Y - l. 3 Sf fV\ ~fJ .
Lemus, individually; and, Craig Berdenier, individually,:
1434 State Road, Duncannon, PA, 17020.
MECHANICS' LIEN CLAIM
1. Claimant, Group & Group Excavating, LP, files this claim against 1800 High Street
Corporation, Angel Pablo Oliva, individually, Carlisle Diner, Inc., Ruben Lemus,
individually, Craig Berdenier, and any other joint owner of record, and against the
property, building and improvements erected thereon at 800 West High Street, Carlisle,
P A 17013, for the payment of debt due to Claimant as a subcontractor.
2. Claimant, Group & Group Excavating LP, is a Pennsylvania business corporation with a
principal place of business of 1545 Holly Pike, Carlisle, PA 17013.
3. A record or reputed owner of the property at the time of furnishing the labor, goods and
materials and the attaching of the lien therefore is 1800 High Street Corporation, by and
through its agent Angel Pablo Oliva, with a principal place of business located at 34
Teaberry Drive, Carlisle, PA 17013.
4. Carlisle Diner, Inc. by and through its agent, Ruben Lemus, is also a record or reputed
owner as a tenant for years as evidenced by a written lease agreement dated May 9, 2002
as amended.
5. Carlisle Diner, Inc., and 1800 High Street Corporation are both herein known as
"Owners" ofthat certain real property at 800 West High Street, Carlisle, PA, 17013.
6. The Claimant, Group & Group Excavating, LP, orally contracted with Contractor Craig
Berdenier with a principal place of business 1434 State Road, Duncannon, P A, 17020. A
true and correct copies of all pertinent invoices between the Claimant and Craig
Berdenier are attached hereto and incorporated herein as Exhibit" A"
7. The new construction and property claimed to be subject to the lien is known as the
Carlisle Diner, located at 800 West High Street, Carlisle, P A 17013, whose property is
more fully described in Exhibit "B" which is attached hereto and incorporated herein.
8. The original contract price for the materials and labor, specifically set forth in Exhibit
"A" is Four- Thousand Three-Hundred Seventy-One and 98/100 ($4371.98) Dollars plus
applicable interest at a rate of One and One-Half Percent (I 1/2%) per month.
9. The principal amount still due as of December 21,2004, is Four-Thousand Three-
Hundred Seventy-One and 98/100 ($4371.98) Dollars plus applicable interest at a rate of
One and One-Half Percent (11/2%) per month.
10. The last day on which Claimant completed the new construction and excavation of the
addition was August 27,2004.
II. The work and materials supplied in the new construction and excavation for an addition
to the liened property were the following: I) Skidloader Load Concrete, 2) Mack Triaxle
and Trailer Haul Skidloader, 3) Mack Triaxle Dump Haul Broken Concrete, 4) Triaxle
loads of Topsoil, 5) Grass Seed, 6) Limestone, 7) 6.5 Ton of2b Stone, 8) Skidloaders of
Pavers (Wall Block) and all labor and activities associated therewith.
12. The materials used by Group & Group Excavating, LP, for the purposes stated herein
were delivered to the site and used for the purpose of the new construction and
excavation at the site of the Carlisle Diner.
13. On or about November 10, 2004, Claimant sent to Angel Pablo Oliva, as agent for 1800
High Street Corporation and to Ruben Lemus, as agent for Carlisle Diner, Inc., by regular
and certified mail a Notice ofIntention to File Mechanics Lien, a copy of which letter
and certified mail receipt is attached hereto as Exhibit "C" and incorporated herein by
reference.
WHEREFORE, Claimant claims this lien upon the premises herein described in the amount
of Four-Thousand Three-Hundred Seventy-One and 98/100 ($4371.98) Dollars, plus any
applicable interest as stated herein, together with court costs, attorneys' fee and other relief
deemed just against the owners of said premises.
Respectfully Submitted,
Salzmann, Hughes & Fishman PC
By:
~1/(7J( e(e
Kelly M. , Esq.
95 Alexander Spring Road, Suite 3
Carlisle, PAl 70 13
(717) 249-6333
Supreme Court J.D. No. 93167
Attorney for Claimant,
Group & Group Excavating, LP.
Date: December 21,2004
S'I h( b'lt .< H ,(
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9'vroP & Group Excavating La)
(545 Holly Pike
Carlisle, P A 17013
Phone (717) 258-9000
'-':F(}~(>2
Date Invoice #
,
8/31/2004 245
8ill10
Carlisle Diner
at1/6- f;W~'t>~NIE'I(
N 2 i/ YTJ1 ~ /?o,f 0
DV.vC;jNNt7A/ ,r.:'A 170;2.0
, /
c.a-L * 7/7-%,,)6- 2/7{
P.O. No. Tenns Project
-
Quantity Description Rate Amount
Re Carlisle Diner
3 Labor Charles Koser 7/28 30.00 9000
1.5 404- 85 Chevy C-70 Charlie 7/28 50.00 75.00T
4 Juan Carlos Prado- Davila 7/28 20.00 80.00T
1.5 Mack T riax]c and Trailer Hual Skldloader Carl 75.00 112.50T
8/12
I Mac.k Tri~le and Trailer Hual Backhoe Carl 8112 75.00 75.00T
2 80 Mack TriaxJe Dump Hual Broken Concrete Carl 60.00 120.00T
8112
35 85xt case Skidloader Load Concrete Carl 8/1 2 65.00 227.50T
0.5 85xt ca~e Skidloader Load Telephonc Pole 8/12 65.00 J2.50T
4.5 580 Super L Charlie SIl2 65.00 292.50T
1.5 Labor Charles Koser 8112 30.00 4500
6 Juan Carlos Prado- Davila 8/12 20.00 120.00T
2.75 580 Super L Don 8/] 2 65.00 1 78.75T
2.75 90 Case Skidloader 1845C Don 8/12 65.00 ] 78.75T
0.5 Labor Don Group 8/1 2 4000 20.00
Thank you for your busillCSS Sales Tax (6.0%)
Total
Payments/Credits
B3!w81lllce [Jlrt,qec -.
Page 1
~ )dlt tj;+
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I & Group Excavating LP
dolly Pike
.isle, PA 17013
,one (7 J 7)258-9000
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Date Invoice #
Sf} l/2004 245
Bill To
Carlisle D~ner
P.O. No. Tenns Project
Quantity Description Rate Amount
I Mack Triaxle and Trailer Curl 8/23 HuaJ 7500 75.00T
skidloadef
4 Triax\eLds of Topsoil 200.00 80000T
2.5 Labor Don Group 8/23 40.00 100.00
\.5 Labor Luis Perez-Reycs 8/23 20.00 30_00
4 85xt case SkidJoader Spn:ad topsoil Luis 8/23 6500 260_00T
5.5 Victoria Davilia-Rodriquez 8/23 20_00 110.00
Grass Seed 30.00 30.00
Union Quarries lnw 93-635 J 98 238.03 238.03
Overhead on materials or bills 10 ,00% 23.80
Thank you for YOllr business. Sales Tax (6.0%) $157.65
Total $3,47\'98
Payments/Credits $0.00
Ba,il9:!i?,ce Ojfl~e $3,471.98
Pf\O.f'>:?
11/20/04 02:58pm P. 001
Group & Group Excavating LP
1545 Holly Pike
Carlisle, P A 17013
Phone (717) 258-9000
hrnlonce
Date Invoice #
8/27/2004 326
Bill To
A~-t~'.
k e \ \ey
Craig Berdenier
1434 State Road
Duncannon, Pa 17020
P.O. No. Terms ProjlK:t
Quantity Description Rate Amount
Re Carlisle Diner Retaining Wall on 8/27/04
Carlos, Luis, Carl, Don Group Jr 470.00 470.00
1 Single Axle load of Topsoil 125,00 125.00
2 2 Skidls of Pavers (Wall Block) 120,00 240.00
6.5 6.5 Ton of2b Stone 10.00 65.00
Thank you for your business. Sales Tax (6.0%) $0.00
Total $900.00
Payments/Credits $0.00
lBalalllce OlUle $900.00
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EXlUBIT "B'
ALL THAT CERTAIN lot of ground situate in the Third Ward of the Borough of
Carlisle, Cumberland County, Pennsylvania, bounded and described as follows:
BEGINNING at an iron pin, the intersection of the Easterly line of a 24-foot wide
lane with the Southerly line of West High Street; thence Eastwardly along the
Southerly line of West High Street, One Hundred Seventy-Six and Five tenths
(176.5) feet, more or less, to a point on the line ofland now or formerly ofJ.E.
Bumbaugh, et ux; thence Southwardly along said land, One Hundred Twenty-
Eight and Five tenths (128.5) feet, more or less, to an iron pin on the line of the
land of East Pennsylvania Conference Association of Seven Day Adventists;
thence Westwardly along said land, One Hundred Four and Seven tenths (104.7)
feet, more or less, to an iron pin; thence Southwardly along said land, Eighty (80)
feet to an iron pin; thence Westwardly along a line parallel with the center line of
West Pomfret Street and Thirty (30) feet Northwardly therefrom Seventy-Nine
and Five tenths (79.5) feet, more or less, to an iron pin on the Easterly line of said
24-foot wide lane; thence Northwardly therefrom along the Easterly line of said
lane, Two Hundred Seven and Five tenths (207.5) feet, more or less, to an iron
pin, the place of BEGINNING.
fy. h\b It .' (?)"
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NOTICE OF INTENTION TO FILE MECHANICS' CLAIM
November 8, 2004
1800 High Street Corporation
ATTN: Pablo Oliva
34 Teaberry Drive
Carlisle, PA 17013
Dear Mr. Oliva,
This is to notifY you that Group & Group Excavating LP, of 1545 Holly Pike, Carlisle,
PA, 17013, intends to file a mechanics' lien against the following described property known as
800 West High Street, Carlisle, PA 17013:
ALL THAT CERTAIN lot of ground situate in the Third Ward of the Borough of Carlisle. Cumberland
Connty. Pennsylvania, bounded and described as follows:
BEGINNING at an iron pin. the intersection of the Easterly line of a 24-foot wide lane with the Southerly
line of West High Street; thence Eastwardly along the Southerly line of West High Street. One Hundred
Seventy-Six and Five tenths (176.5) feet, more or less, to a point on the line ofland now or fonnerly of J.E.
Bumbaugh, et ux: thence Southwardly along said land. One Hundred Twenty-Eight and Five tenths (128.5)
fect. more or less. to an iron pin on the line of the land of East Pennsylvania Conference Association of
Seven Day Adventists; thence Westwardly along said land. One Hundred Four and Seven tenths (104.7)
feet, more or less. to an iron pin: thcnce Southwardly along said land. Eighty (80) feet to an iron pin; thence
Westwardly along a line parallel with the center line of West Pomfret Street and Thirty (30) feet
Northwardly therefrom Seventy-Nine and Five tenths (79.5) feet, more or less, to an iron pin on the
Easterly line of said 24-foot wide lane; thence Northwardly therefrom alOllg the Easterly line of said lane.
Two Hundred Seyen and Five tenths (207.5) feet. more or less, to an iron pin, the place of BEGINNING.
The party with whom Group & Group Excavating LP contracted for the new construction
and excavation for an addition to the Carlisle Diner, 800 West High Street, Carlisle, PA 17013, is
Craig Berdenier, of 1434 State Road, Duncannon, PA, 17020, for the original contract price of
Four-Thousand Three-Hundred Seventv-One and 98/100 ($437198) Dollars
The labor and materials furnished by Group & Group Excavating, LP consisted of those
materials and labor necessary in the new construction and excavation for the addition to the
Carlisle Diner and all other activities associated therewith, True and correct copies of the
pertinent invoices are attached herein as Exhibit "A." The materials used by Group & Group
f'{hlb:-t- "C"
Excavating LP for the purpases stated herein were delivered to the site and used for the purpose
of the new constructian and excavation 0'1' the site at the Carlisle Diner.
The date an which Graup & Graup Excavation LP completed the new construction and
excavatian of the additian was August 27, 2004.
The principal amount still due, and the amount of the claim far which we intend to' file
said lien pursuant to the Pennsylvania Mechanics' Lien Law of 1963, Pa.S.A. S1502, is for the
sum of Four-Thousand Three-Hundred Seventy-One and 98/100 ($4371.98) Dallars, with
accumulating interest, casts and attorneys fees.
""".lII ,n
Unless the amaunt due is paid within thirty (30) days of receipt oft!iJs~tornIal ncidceta',
'.~ '~_~', .:,', ',,' ,,! .' II III
yau, Group & Group Excavating LP intends to file a lien against the premis~s ~6o;; de~ribed
for the total amount ofFour-Thausand Three-Hundred Seventy-One and 98/100 ($4371.98)
Dollars, plus applicable interest, costs and attorneys fees.
This letter constitutes our formal Notice afIntention to file such lien claim.
Sincerely,
Salzmann, Hughes, & Fishman, PC
By:
/ c'
&erL11{A~ (J ( C (' (
l./
Kelly M. Dick, Esquire
Attorney for
Group & Group Excavating LP
I.) ,i ('fA )Al/
Date r I O-::R.fl-l1Q...J'.1 () d C; u 7
,-
NOTICE: OF INTENTION TO FILE MECHANICS' CLAL\!
November 10, 2004
Carlisle Diner, Inc.
ATTN: Rubin
800 West High Street
Carlisle, PA 17013
Dear Rubin,
This is to notify you that Group & Group Excavating LP, of 1545 Holly Pike, Carlisle,
PA, 17013, intends to file a mechanics' lien against the following described property known as
800 West High Street, Carlisle, PA 17013:
ALL THAT CERTAIN lot of ground situate in the Third Ward of the Borough of Carlisle, Cumberland
County. Pennsylvania. botmded and described as follows:
BEGrNNING at an iron pin. the interscction of the Eastcrly line of a 24-foot wide lane with the Southerly
line of West High Street: thence Eastwardly along the Southerly linc of West High Street, One Hundred
Sevent;'-Si" and Fivc tenths (176.5) leet. more or less, to a point on the line of land now or formerly of J.E.
Bumb~ugh. et u,,; thence Southwardly along said land. One Hundred Twenty-Eight and Five tenth; (128.5)
feet morc or less, to an iron pin on the line of the land of East Pennsylvania Conference Association of
Seven Day Adventists: thence Westwardly along said land. One Hundred Four and Seven tenths (104.7)
feel, marc or less, to an iran pin; thence Southwardly along said land. Eighty (80) fcelto an iron pin; thence
Westwardly along a line parallel witll the center line of West Pomfret Streel and Thirty (30) feet
Northwardly tllerefrom Sey'enty-Niue and Five tenths (79.5) feel, more or less. to an iron pin on the
Easterly line of said 2-I-foot wide lane: theuee Northwardly therefrom along the Easterly line of said lane,
Two Hundred Seven and Five tenths (207.5) feet, more or less. to an iron pin. the plaeeofBEGINN[NG.
The party with whom Group & Group Excavating LP contracted for the new const:uction
and excavation for an addition to the Carlisle Diner, 800 West High Street, Carlisle, P A 17013, is
Craig Berdenier, of 1434 State Road, Duncannon, PA, 17020, for the original contract price of
Four-Thousand Three-Hundred Seventy-One and 98/\00 ($4371.98) Dollars.
The labor and materials furnished by Group & Group Excavating, LP consisted of those
materials and labor necessary in the new construction and excavation for the addition to the
Carlisle Diner and all other activities associated therewith. True and correct copies of the
pertinent invoices are attached herein as Exhibit "A." The materials used by Grollp & Group
Excavating LP tor the purposes stated herein were delivered to the site and used for the purpose
of the new constnIction and excavation of the site at the Carlisle Diner.
The date on which Group &. Group Excavation LP completed the new construction and
excavation of the addition was August 27.2004.
The principal amount still due, and the amount of the claim for which we intend to tile
said lien pursuant to the Pennsylvania ]',[echanics' Lien La"v of 1963, PaS.A SlS02. is for the
sum of Four-Thousand Three-Hundred Seventy-One and 98/100 ($4371.98) Dollars, with
accumulating interest, costs and attorneys fees.
Unless the amount due is paid within thirty (30) days of receipt of this formal notice to
you, Group &. Group Excavating LP intends to file a lien against the premises above described
for the total amount of Four-Thousand Three-Hundred Seventy-One and 98/100 ($437198)
Dollars, plus applicable interest, costs and attorneys fees
This letter constitutes our tormal Notice ofIntention to file such lien claim.
Sincerely,
Salzmann, Hughes, & Fishman, PC
By ~7)A, D { cl(
Kelly M Dick, Esquire
Attorney for
Group & Group Excavating LP
Date (J6 v'.t~~,,- /6-1'1 t 2 Go i
. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
.. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the maHpiece,
or on the front if space permits.
1. Article Addressed to:
CARLISLE DINER INC
ATI'N: RUBIN
800 WEST HIGH STREEIr
CARLISLE PA 17013
x
Cl Agent
o Addressee
B. Received by (Printed Name) C. Date of Delivery
\1 'il\
D. Is delivery address different from Item 1? 0 Yes
If YES, enter delivery address below: 0 No
3. SelVlce Type
f:g Certified Mall 0 Express Mail
o Registered 0 Return Receipt for Merchandise
o Insured Mail 0 C.O.D.
4. Restricted Delivery? (Extra Fee) 0 Yes
2. Article Number 7001 1140 0003 2514 2982
(Transfer from service 1abeQ
?P.w-mm-S61t}August~bMl.n~!!jti'llllIJif
102595-02-M.1540
SENDER: COMPLETE THIS SECT/ON
. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece,
or on the front if space pennits.
1. Article Addressed to:
PABLO OLIVA
1800 HIGH STREET CORP
34 TEABERRY DRIFE
CARLISLE PA 17013
2. Article Number
(Transfer from service label)
PS Form 3811, August 2001
3. Service Type
~ Certified Mall 0 Express Mail
o Registered 0 Return Receipt for Merchandise
o Insured Mail 0 C.O.D.
4. Restricted Delivery? (Extra Fee) 0 Yes
7003 2260 0000 8709 3315
Domestic Return Receipt 102595-02.M.1540
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Group & Group Excavating LP
1545 Holly Pike
Carlisle, PA 17013
IN THE COURT OF
COMMON PLEAS OF
CUMBERLAND
COUNTY, PENNSYL VANIA
v.
1800 High Street Corporation, a Pennsylvania
Corporation, 34 Teaberry Drive, Carlisle, PA; and,
Angel Pablo Oliva, individually; and, Carlisle Diner,
Inc., 800 West High Street, Carlisle, PA; and, Ruben DOCKET NO: 04-6388 Mr.)\
Lemus, individually; and, Craig Berdenier, individuaIIy,:
1434 State Road, Duncannon, P A, 17020.
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Please reinstate the above-captioned matter.
Date: January 18,2005
SALZMANN, HUGHES & FISHMAN PC
By: ;~1'G1.D;cIL
Kelly M. Dl , Esq.
95 Alexander Spring Road, Suite 3
Carlisle, PA 17013
(717) 249-6333
Supreme Court LD. No. 93167
Attorney for Claimant,
Group & Group Excavating, LP.
(.,-
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SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2004-06388 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GROUP & GROUP EXCAVATING LP
VS
1800 HIGH STREET CORP ET AL
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:
BERDENIER CRAIG
but was unable to locate Him
In his bailiwick. He therefore
deputized the sheriff of PERRY
County, Pennsylvania, to
serve the within MECHANICS LIEN CLAIM
On January
5th , 2005 , this office was in receipt of the
attached return from PERRY
Sheriff's Costs:
Docketing
Out of County
Surcharge
6.00
.00
10.00
.00
.00
16.00
01/05/2005
SALZMANN HUGHES
S~~~'l.: .......... /~.:.::.:::~~:~._:.::-.;?
~~
R. Thomas Kline
Sheriff of Cumberland County
FISHMAN
Sworn and subscribed to before me
this .2:~ day Of,-)"A -'1u~u1
-2,u"v .~ A . D .
C;~ < . 9,:o~!o1~~y ~
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2004-06388 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GROUP & GROUP EXCAVATING LP
VS
1800 HIGH STREET CORP ET AL
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:
LEMUS RUBEN
but was unable to locate Him
in his bailiwick. He therefore
deputized the sheriff of PERRY
County, Pennsylvania, to
serve the within MECHANICS LIEN CLAIM
On January
5th , 2005 , this office was in receipt of the
attached return from PERRY
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep Perry County
6.00
9.00
10.00
30.25
.00
55.25
01/05/2005
SALZMANN HUGHES
So ans..we~rs: /./..:? .'- -:::-...__~.:::::::.. .7
~~ ~../~
~... //~e::~~
R. Thomas Kline... ....-
Sheriff of Cumberland County
FISHMAN
Sworn and subscribed to before
this ;LLf~ day OfC~
y
;2l-v'/ A.D.
o
," Ar~LpGt~f;~, ~
me
SHERIFF'S RETURN - REGULAR
CASE NO: 2004-06388 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GROUP & GROUP EXCAVATING LP
VS
1800 HIGH STREET CORP ET AL
JASON VIORAL
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within MECHANICS LIEN CLAIM
was served upon
1800 HIGH STREET CORPORATION
the
OWNER
, at 1000:00 HOURS, on the 3rd day of January ,2005
at 34 TEABERRY DRIVE
CARLISLE, PA 17013
by handing to
ANGEL PABLO OLIVA, OWNER
a true and attested copy of MECHANICS LIEN CLAIM
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
4.44
.00
10.00
.00
32.44
r~,. J~~;,{~~~:<c.,..~-!~ ,/ ~
,~~~-"Y';'''::''~' i~.. J'.r~
,
R. Thomas Kline
01/05/2005
SALZMANN HUGHES FISHMAN
Sworn and Subscribed to before
By:
~~. ---zJZ.
//Dep'Uty Sheriff
o
c::-
..). 'I -
day of
me this
YtA L( A-( d-t'17 !/ A. D .
/ . 7
~ f2 Iv7J PP;", J {qPii
P othonotary I
SHERIFF'S RETURN - REGULAR
CASE NO: 2004-06388 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GROUP & GROUP EXCAVATING LP
VS
1800 HIGH STREET CORP ET AL
RON KERR
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within MECHANICS LIEN CLAIM
was served upon
OLIVA ANGEL PABLO
the
OWNER
, at 2056:00 HOURS, on the 30th day of December, 2004
at 800 WEST HIGH STREET
CARLISLE, PA 17013
by handing to
RUBEN LEMUS, OWNER OF
CARLISLE DINER
a true and attested copy of MECHANICS LIEN CLAIM
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
3.70
.00
10.00
.00
19.70
,;.~
i;<<~
,/.i,::-:';-~R
R. Thomas Kline
01/05/2005
SALZMANN HUGHES FISHMAN
Sworn and Subscribed to before
6'
me this .:11:.;....-' day of
~<<''':7 di'lYiI A.D.
. '~QA~ .-'
~thonotary , ~
~~
Deputy Sheriff
By:
~
SHERIFF'S RETURN - REGULAR
CASE NO: 2004-06388 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GROUP & GROUP EXCAVATING LP
VS
1800 HIGH STREET CORP ET AL
RON KERR
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within MECHANICS LIEN CLAIM
was served upon
CARLISLE DINER
the
OWNER
, at 2056:00 HOURS, on the 30th day of December, 2004
at 800 EAST HIGH STREET
CARLISLE, PA 17013
by handing to
RUBEN LEMUS, OWNER
a true and attested copy of MECHANICS LIEN CLAIM
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
.00
.00
10.00
.00
16.00
"
; < <;/t
;:<.,'t~#
"r
,;
.,.
R. Thomas Kline
01/05/2005
SALZMANN HUGHES FISHMAN
Sworn and Subscribed to before
By:
~/~
Deputy Sheriff
t;;,
me this ;l'i '-- day of
,
L}r .:JiHJ..( A.D.
~-'-- (1 'rYu~..) 1frZ;
Prothonotary I
In The Court of Common Pleas of Cumberland County, Pennsylvania
Group & Group Excavating LP
VS.
1800 High Street Corporation et al
SERVE: Ruben Lemus
No.
04-6388 civil
Now DecEmber 28, 2004
,
, I, SHERIFF OF CUMBERLAND COUNTY, P A, do
hereby deputize the Sheriff of
Perry
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
~."...., .;:;/7"'. f ./ h'
~. V'//~
. "';.-'~~C{!Jt!'<, .....?# ,.;;;,~:~ .~
,r - "f'4' ,~"-,"""",,,'~~--'l.--r-
Sheriff of Cum berland County, P A
Affidavit of Service
Now,
,20_, at
o'clock
M. served the
within
upon
at
by handing to
copy of the original
a
and made known to
the contents thereof.
So answers,
Sheriff of
County, PA
Sworn and subscribed before
methis_dayof ,20_
COSTS
SERVICE
MILEAGE
AFFIDA VIT
$
$
In The Court of Common Pleas of Cumberland County, Pennsylvania
Group & Group Excavating LP
VS.
1800 High Street Corporation et al
SERVE: Craig Berdenier
No.
04-6388 civil
Now DecEmber 28, 2004
,
, I, SHERIFF OF CUMBERLAND COUNTY, P A, do
hereby deputize the Sheriff of
Perry
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
~'/'? ~;,.::/ {;'.,/:/.)'
~~ _,.....".,,"'.<tf" _~rr!'._'"," -"'.
. ,.,.?~+-7..,,;;.,,,.:..z_ ,;;<' .."/'..~~."'...-.?'
t' .......f: .-.'~.. ',,..,...... - ~ .
Sheriff of Cum berland County, P A
Affidavit of Service
Now,
,20_, at
o'clock
M. served the
within
upon
at
by handin g to
a
copy of the original
and made known to
the contents thereof.
So answers,
Sheriff of
County, PA
Sworn and subscribed before
me this_day of ,20_
COSTS
SERVICE
MILEAGE
AFFIDA VIT
$
$
SHERIFF'S RETURN
In the Court of Common Pleas
Of the 41 st Judicial District
of Pennsylvania-
Perry County Branch
No. 2004-6388 Cumb Co.
Group & Group Excavating LP
vs
Ruben Lemus
1434 State Rd.
Duncannon, P A 17020
Carl E. Nace, Sheriff, who being duly sworn according to law, says that he made a
diligent search and inquiry for the within named Defendant(s) to wit, Ruben Lemus. ,
but was unable to locate him/her in his bailiwick. He therefore returns the within
Mechanics Lien for the above named Defendant(s) Ruben Lemus, , at 1434 State
Rd. Duncannon, PA 17020 NOT FOUND. PROPERTY IS VACANT.
SOl!li > ~
Carl E. Nace
Sheriff of Perry County
NOTARIAL SEAL
MARGARET F. fLICKINGER, NOTARY PUBLIC
BLOOMFIELD BORO., PERRY COUNTY
MY COMMISSION EXPIRES FEB. 16 2008
SHERIFF'S RETURN
In the Court of Common Pleas
Of the 41 st Judicial District
of Pennsylvania-
Perry County Branch
No. 2004-6388 Cumb Co.
Group & Group Excavating LP
vs
Craig Berdenier
1434 State Rd.
Duncannon, PA 17020
Carl E. Nace, Sheriff, who being duly sworn according to law, says that he made a
diligent search and inquiry for the within named Defendant(s) to wit, Craig Berdanier
but was unable to locate him/her in his bailiwick. He therefore returns the within
Mechanics Lien for the above named Defendant(s) Craig Berdenier, , at 1434 State
Rd. Duncannon, PA 17020 NOT FOUND. PROPERTY IS VACANT.
::~
~
Sworn and subscribed to before me
this _? ( d day of ~J (ill."" &-' 20~.
777tvld~td '1i'&h<Y'-
Sheriff of Perry County
NOTARIAL SEAL
MARGARET F. FLICKINGER, NOTARY PUBLIC
BLOOMFIELD BORO., PERRY COUNTY
MY COMMISSION EXPIRES FEB. 16 200S
SHERIFF'S RETURN - REGULAR
CASE NO: 2004-06388 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GROUP & GROUP EXCAVATING LP
VS
1800 HIGH STREET CORP ET AL
SHANNON SHERTZER
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within MECHANICS LIEN CLAIM
was served upon
LEMUS RUBEN
the
OWNER
, at 1556:00 HOURS, on the 21st day of January
2005
at 800 WEST HIGH STREET
CARLISLE, PA 17013
by handing to
JAIME PHILLIPS, WAITRESS,
ADULT IN CHARGE
a true and attested copy of MECHANICS LIEN CLAIM
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
3.70
.00
10.00
.00
19.70
~.,,-. ..-:? ~.
.-' . .,.'''' {;?~)./.:~..... .~ ..J'~
.' ..;~~p~
R. Thomas Kline
Sworn and Subscribed to before
01/24/2005
SALZMANN HUGHES FISHMAN ,~
By: rl r-'t
!r~"" ~ ''0 j
v Deputy Sherl f
me this 3~ day of
J.d~~'j~'"J c207J.{ A.D.
~ () .~ tJA--
, . -r~
Prothonotary
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
GROUP & GROUP EXCA VA TING LP
v.
DOCKET # 04-6388
MECHANICS LIEN CLAIM
1800 HIGH STREET CORPORATION,
ANGEL PABLO OLIVA, individually,
CARLISLE DINER, INC., RUBEN LEMUS,
individually, AND CRAIG BERDENIER,
individually
PRAECIPE TO DISCONTINUE
TO THE PROTHONOTARY:
Please mark the above-captioned matter settled and discontinued. ~ Sa~\5[i.,J ,
Date: 31'1/ Db
By:
SALZMANN HUGHES, PC
J fJ4OJU-.. A, HPrvu !) ~
Susann B. Morrison, Esq.
Supreme Court J.D. No. 77041
95 Alexander Spring Rd., Suite 3
Carlisle, P A 17013
(717) 249-6333
Attorney for Plaintiff,
Group & Group Excavating LP
.1
.-j
IN THE COURT OF COMMON PLEAS OF CUMBERJ"AND COUNTY,
PENNSYLVANIA
GROUP & GROUP EXCAVATING LP
v.
DOCKET # 04-6388
MECHANICS LIEN CLAIM
1800 HIGH STREET CORPORATION,
ANGEL P ABLO OLIVA, individually,
CARLISLE DINER, INC., RUBEN LEMUS,
individually, AND CRAIG BERDENIER,
individually
PRAECIPE TO SATISFY JUDGMENT
TO THE PROTHONOTARY:
Please mark the judgment in the above-captioned matter satisfied.
Date: 1, / I 3 ( DiP
SALZMANN HUGHES, PC
By:
k~ J!q1U/(JL
Susann B. Morrison, Esq.
Supreme Court J.D. No. 77041
95 Alexander Spring Rd, Suite 3
Carlisle, P A 17013
(717) 249-6333
Attorney for Plaintiff,
Group & Group Excavating LP
110
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