HomeMy WebLinkAbout14-2760 COYNE & COYNE, P.C. ,
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Lisa Marie Coyne, Esq. OF THE PROTHONo� -�y
PA Supreme Court ID No. 53788 14 HA
3901 Market Street � �' '3 � �: Giti
Camp Hill, PA 17011-4227
(717) 737-0464 CUMBERLAND COUNTY
PENNSYLVANIA
Fax: (717) 737-5161 Solicitor for Borough of Mechanicsburg
BOROUGH OF MECHANICSBURG, IN THE COURT OF COMMON PLEAS OF
Claimant CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. I/. ;Z71 Q M.L.D.
Darryl L. Kenes and
Debra R. Kenes, 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. a
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6. A description of the property against which this claim is filed is:
45 West Keller Street
Borough of Mechanicsburg
Cumberland County
Pennsylvania 17055
TAX PARCEL NUMBER 16-24-0787-021
7. This claim has not been the subject of any previous claim and judgment
in the Court of Common Pleas of Cumberland County for sewer and/or
refuse charges.
8. The total amount of the charges for which this claim is filed is
eight hundred eighty eight dollars and sixty five cents ($888.65), plus costs and
reasonable attorney's fees.
9. The time period for which these charges are filed is October 1, 2012 to
March 31, 2014 on Sewer and Refuse Account 1298-0.
WHEREFORE, Claimant requests that a Municipal Lien be entered in its
favor and against the Defendant in the amount of eight hundred eighty eight
dollars and sixty five cents ($888.65), plus cost and reasonable attorney's fees.
BO GH OF ECHANICSBURG
By:
Lisa Mar a Coyne, Esquire
Solic
BOD
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
}
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.
TXRIAL SEAL
Leslie S Hocker
NOTARY PUBLIC
Notary Public Mechanicsburg Boro,Cumberland County
My Commission Expires 04/02/2017
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WARRANTY DEED NO, $is .
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LEII0 CciUNTY
i 1 � PF.NNSYIYANfA
y 4 Jul 13 a ozF11'82
fiiabr We 9 day of ,u Ly
in the year of our •
Lord one thousand nine hundred and eighty two (1982)
i ?3rtwrrtt ROGER L. HORTCN and LINDA K. HORTON, his wife, of Mechanicsburg,
Cumberland County, Pennsylvania, GRANInRS
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AND
DARRYL L. KENES and DEBRA R. KEDS, his wife, of Mechanicsburg,
Cumberland County, Pennsylvania,
GRANIEI:S
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3Diturs will, that the said parliesnf the first part,for and in consideration of the swan of
I TWENTY FIVE THOUSAND.NINE HUNDRED AND NO/100•--------------- ----------•--
------- -------•-------- -----------------------------------------($25,900.00).
Dollars,lawful money of the United States unto well and truly 1wid by the said
parties of the second part,the receipt whereof is hereby acknowledged,do hereby grant, •
bargain,sell,alien enfeoff,release,convey and confirm unto the said part ies of the second
per, their heirs and dasigm,
All that certain house and lot'of ground situate on the South side of West Keller
Street, in the Borough of Mechanicsburg, County of Cumberland and State of
Pennsylvania, more particularly bounded and described according to a survey and
plan thereof made by John C. Brilhart, Registered Surveyor, dated July 17, 1973,
! as follows, to wit: (See Final Subdivision Plan for Roy D. Kunkle, recorded .
EEt in Cumberland County Recorder's Office'in Plan Book 24, Page 27.
BEGINNING at a point at a pavement joint in the southern building line of West
Keller Street; which said point is at corner of Lot new our formerly of Robert
J. Eisenhower, South 14 degrees 48 minutes East, one hundred forty (140) feet
to a nail in the Northern line of Hill Alley; thence along the Northern line
of Hill Alley, South 75 degrees 00 minutes West, nineteen and six hundredths
4 (19.06) feet to a point; thence along the line of other land now or formerly
e of Roy D. Kunkle, of which this is a part and passing through the center of a
block garage building and beyond; thence passing through the center of the
partition wall between the double two story frame dwelling house erected on
I the lot herein described and on the lot immediately adjacent hereto on the
West, north 15 degrees 00 minutes West, one hundred forty (140) feet to a
point in the southern building line of West Keller Street, aforementioned;
thence extending along the southern building line of West Keller Street,
North 75 degrees 00 minutes East, nineteen and fifty-five hundredths (19.55)
feet to a point at a pavement joint in said building line at the point and
t place of BEGINNING•
HAVING thereon erected the eastern one-half of a double two story frame,dwelling •
house known and numbered as 45 West Keller Street, Mechanicsburg, Cumberland
County, Pennsylvania.
BEING the same premises which Roy D. Kunkle, single man, by Deed dated February
3, 1978 and recorded in the Office of the Recorder of Deeds in and for
Cumberland County in Deed Book Volume , Page , 'granted and .
conveyed unto Roger L. Horton and Linda K. Horton, his wife, Grantors herein.
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600X\/29 PAGE 452
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41agetlier with all and singular the hereditaments and appurtenances thereunto belong-
ing or in anywise appertaining and the reverAions and remainders,rents,issues and profits
{ thereof,and all the estate,right,title,interest, property, claim and demand whatsoever of
the said part of the first part,in rare,equity or otherwise of,in,and to the same and ererq
• pnrt thereof.
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Cc 3ianr aub to VoNN the above described premises with the appurtenances unto t
! the said parties of the second part their heirs and Assigns, forever. {
COMMONWEALTH OF FENNSYLVA,NJA'= I
E ;N DEPARTMENT OF REVENUE _
N REALTY
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TAXJUU e'e! 259. 00
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jAnb the said part of the first part,do hereby covenant and agree to and with the
said parties of the second part,that the said parties of the first part Fxecu-
tors and Administrators,Shall and Will Warrant and Forever Defend the herein above de-
scribed premises with the hereditaments and appurtenances, unto the said parties of the
sccond'part, heirs and Assigns,against the said part ies of the first part and,against
every other person lawfully claiming,or-who shall hereafter claim, the same or any part
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thereof.
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! 31n 11litur5a illllrrrnf, the said parties of the first part have hereunto set hand
and seal . the day and year first above written. I
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�ammonmraltll of �Irnusploania
(Qaunty of uAs+be¢lai
on thu,the 9 day of JJ, A.D. W el,before n+r
y a notary public the undersigned officer, personally
appeared Boger L. Horton and Linda K. Horton •
known to ncc or (satisfactorily
proven) to be the person whose navlc s are subscribed to the within instrument. and
acicnowledyed that t hcy executed the sage for..the p;mposes therein contained.
Jn Mitnros 'TDhrreaf, hereunto set 'my(rand and official seal.'[. •,,
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CHAR Ta. .r ri3. ,�� .�,`. =u
NOTARY PUSLIC ''`•
my Ca�>a Egirn SePI.11,19&7 X10 tl;•`
Camp rA Pa Cumb"COunb
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?4trrhg Zrritfy, that the precise residence of the Grantee
Attorney for •
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(Gamn7onwra3 oflrnnaglnanla'""'� 80,
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ne�o'aea;an this �.�. dal/ of A• ~ t► —in the
,u d /,,
Recordex'8.Officirof the said County in Decd ok v Yoluvne 7 Page XJo2
Given uhder.my hand and the seal of the said Office,the date above written. _
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