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HomeMy WebLinkAbout14-2758 COYNE &COYNE, P.C. Lisa Marie Coyne, Esq. PRO iH0 Nu PA Supreme Court ID No. 53788 3901 Market Street 2 ++°4 M-A Y -5 PH z: 62 Camp Hill, PA 17011-4227 CUMBERLAND (717) 737-0464 COUNTY PENNSYLVA Fax: (717) 737-5161 'Sd for for Borough of Mechanicsburg BOROUGH OF MECHANICSBURG, : IN THE COURT OF COMMON PLEAS OF Claimant : CUMBERLAND COUNTY, PENNSYLVANIA V. . NO. it/-;L75S, M.L.D. George E. Danner and Stacey L. Danner, husband and wife Defendants MUNICIPAL LIEN MUNICIPAL LIEN FOR SEWER/WATER 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, 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. ' 9';2,1,JZ► fA Ck5-73.2 P.9 3�6-39( 6. A description of the property against which this claim is filed is: I 12 Patton Road Borough of,Mechanicsburg Cumberland County Pennsylvania 17055 TAX PARCEL NUMBER 18-22-0519=297 7. This claim has not been the subject of any previous claim.and Judgment in the CoUrt of o,mmori Pleas'of CumberlandCounty for sewer and/or refuse charges. . A r 8. The total amount of the charges for`w*hiclithis cl'aim''is fileddis seven, hund{red,eighty five dollars and eighty cents ($785.80), plus costs and reasonable attorney's fees. ! i 9. The time period.for..which.these charges are filed is January 1, 2013 to March 31, 2014,onySewer and Refuse Account 3827-0. WHEREFORE .Gla mant requests that a Municipal Lien be entered in its favor and against the Defendant in the amount of seven hundred eighty five dollars and eighty cents ($785.80), plus cost and reasonable attorney's fees. BOROUGH OF MECHANICSBURG By: Lisa ar Coyne, Es ire Solid 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: April 25, 2014 I I I I COMMONWEALTH OF PENNSYLVANIA) )ss COUNTY OF CUMBERLAND ) Patrick E. Dennis, being duly sworn according to law, deposes and says that she is the Office Manager for the Borough of Mechanicsburg, and that the facts set forth in the foregoing instrument are true and correct to the best of her knowledge, information and belief. Patrick E. Dennis, Borough Manager Sworn to and subscribed before me this 25th day of April, 2014. Leslie S Hooker NOTARY PUBLIC Notar PUb I lllechanicsbur Boro.Cumberland County My Commission Expires 04/02/2017 ZIEGLER DEEDS PA '02 '02 MY 2 8 58 TAX PARCEL NO. 18-22-0519-297 I'D" RCj _ MADE THE day of in the year two thousand two (2002) BETWEEN KATHLEEN L. SWAIN, single woman, formerly known as KATHLEEN S. PASDA, also known as KATHLEEN L. PASDA, of Mechanicsburg, Pennsylvania, Grantor, AND GEORGE E. DANNER and STACEY L. DANNER, his wife, of Harrisburg, Pennsylvania, Grantees, WITNESSETH, that in consideration of ONE HUNDRED TWENTY-SEVEN THOUSAND-------- ----------------------------------------- ------($127,000.00)--=------------------------------------Dollars, in hand paid, the receipt whereof is hereby acknowledged, the said grantor does hereby grant and convey to the said grantees, their heirs and assigns, ALL THAT CERTAIN lot or piece of land situate in the Borough of Mechanicsburg, Cumberland County and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the southern side of Patton Road, which point is also the dividing line of Lot Nos. 15 and 16, Block D, on the hereinafter mentioned Plan of Lots; thence along said dividing line, South 10 degrees 23 minutes East, 120 feet to a point; thence along the dividing line of Lot No. 15, Block D and Lot Nos. 19 and 20, Block D, South 79 degrees 37 minutes West, 70 feet to a point; thence along the dividing line of Lot Nos. 15 and 14, Block D, North 10 degrees 23 minutes West, 120 feet to a point on the southern side of Patton Road; BOOK 251 PACE2617 12/30/2013 9:57:53 AM CUMBERLAND COUNTY Inst.#200218108-Page 1 of 4 thence along the southern side of Patton Road, North 79 degrees 37 minutes East, 70 feet to a point and place of BEGINNING. BEING Lot No. 15, Block D, on the Final Plan of Part of Blocks A, C, D, E, F, G and H, Wynnewood Park, as recorded in the Cumberland County Recorder's Office in Plan Book 30, Page 116. UNDER AND SUBJECT, NEVERTHELESS, to easements, restrictions, reservations, conditions and rights-of-ways of record or visible upon inspection of premises. BEING known and numbered as 12 Patton Road, Mechanicsburg, Pennsylvania. BEING THE SAME PREMISES which Mark J. Pasda and Kathleen S. Pasda, by Deed dated May 26, 2000 and recorded June 8, 2000 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 222, Page 1118, granted and conveyed unto Kathleen S. Pasda, also known as Kathleen L. Pasda. The said Kathleen S. Pasda, also known as Kathleen L. Pasda, by a Notice of Election to Retake Maiden name, dated August 10, 2000, is now known as Kathleen L. Swain, single woman, Grantor herein. AA54WR C-3 .v n n n 2 F.-.�' �Ss'v r^�v w � Yt::Jt Ott g.-w T�jJ 1 .2 2" I i .'C• g /D +�-•• N N•.•S rT C --i CJ x N •�.• C7 C:-1 � ra C •K .� ae r at a +n C'7 -1 C _D N Cr i-+ry lTl \ -+7 Y•-R en � -4 +tea a W M il, CJlt'z,r•.l G` cr.4 r�.] Oo lT+ ..�, -I . BOOK 2U PAGE .B 12/30/2013 9:57:53 AM CUMBERLAND COUNTY Inst.#200218108-Page 2 of 4 . N v And the said grantor does hereby Warrant Specially the property hereby conveyed. IN WITNESS WHEREOF, said grantor has hereunto set her hand and seal the day and year first above written. Signed, Sealed and Delivered KATHLEEN L. SWAIN in the Presence of KATHLEEN L. PASDA KATHLEEN S. PASDA STATE OF ✓� COUNTY On this, the day of , 2002, before me, a Notary Public, the undersigned officer, personally appeared KATHLEEN L. SWAIN, single woman, formerly known as KATHLEEN L. PASDA, also known as KATHLEEN S. PASDA, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand apq official seal. (SEAL) Notary Public NOTARIAL WL Q' CHERYL A. SWARIZ, Notary Public Hardlburp, Dauphin County CommiaM Explm AM 8,Zoos BACK 251 PsxF26A 12/30/2013 9:57:53 AM CUMBERLAND COUNTY Inst.#200218108-Page 3 of 4 CERTIFICATE OF RESIDENCE I do hereby certify.that the precise residence and complete post office address of the within grantees is: Atientey/Agent for COMMONWEALTH OF PENNSYLVANIA: SS County of RECORDED on this day of A. D. 2002, 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. I Certify this to be recorded In Cumberland County PA Recorder of Deeds soox 251 pacE2620 12/30/2013 9:57:53 AM CUMBERLAND COUNTY Inst.#200218108-Page 4 of 4