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HomeMy WebLinkAbout14-4123 COYNE &COYNE, P.C. Lisa Marie Coyne, Esq. PA Supreme Court ID No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 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. ��- L�/�,3 M.L.D. �- rrlC— m am, c Cumberland Valley Development, Inc. «3 r -' -<> Cy, Via• 2� Defendant 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, Defendants) 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 seg., 53P.S. §7143, as amended. 401150 Po C -5''74/ 6. A description of the property against which this claim is filed is: 304 South Washington Street Borough of Mechanicsburg Cumberland County Pennsylvania 17055 TAX PARCEL NUMBERS 20-24-0785-188, 20-24-0785-189, 20-24-0785-208 AND 20-24-0785-208A 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 six hundred and ninety-seven dollars and ninety cents ($697.90), plus costs and reasonable attorney's fees. 9. The time period for which these charges are filed is July 1, 2013 to June 30, 2014 on Sewer and Refuse Account 5664-0. WHEREFORE, Claimant requests that a Municipal Lien be entered in its favor and against the Defendant in the amount of six hundred and ninety-seven dollars and ninety cents ($697.90), plus cost and reasonable attorney's fees. BI. UGH,OFtIECHANICSBURG Byle' Lia arie Coyne, Esquire Sol . or 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: July 15, 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 l Rh day of July, 2014. IYWt�� c S Notary Public NOTARIAL SEAL Leslie S Hooker NOTARY PUBLIC Mechanicsburg Boro,Cumberland County My Commission Expires 04/02/2017 T t 'J � J Tax Parcel I.D. Nos. 20-24-0785-188 L5 t t L 20-24-0785-189 20-24-0785-208 THIS DEED 20-24-0785-208A MADE THIS .21 day of April,2004,by and between: SHERRY L. HUGHES,of Mechanicsburg, Cumberland County,Pennsylvania,party of the first part,hereinafter -J { "Grantor" r AND CUMBERLAND VALLEY DEVELOPMENT, INC., a Pennsylvania business corporation, of Mechanicsburg, Cumberland County, Pennsylvania,party of the second part, hereinafter"Grantee" n WITNESSETH: THAT in consideration of the sum of Three Hundred Seventy-Five Thousand and No/100 Dollars($375,000.00}in hand paid by the Grantee to the Grantor,the receipt whereof being hereby acknowledged,the Grantor hereby grants and conveys unto the said Grantee, its successors and assigns: ALL those certain tracts of land with any improvements thereon located in the Borough of Mechanicsburg, Cumberland County,Pennsylvania, as follows: TRACT NO. 1: ALL THAT CERTAIN piece or parcel of land situate in Mechanicsburg Borough, Cumberland County,Pennsylvania as set forth on a Subdivision Plan of William H. May,Jr., as prepared by Alpha Consulting Engineers,Inc., John K. Murphy,P.E./PLS and recorded in the Recorder of Deeds Office of Cumberland County,Pennsylvania in Plan Book 77, Page 140, and more particularly described as follows: BEGINNING at a point on the east side of South Broad Street at the dividing line between Lot No. 2A and Lot No. 3 on the aforementioned Plan;thence by Lot 2A,North 64 degrees 30 minutes 00 seconds East, a distance of 170.11 feet to a point;thence along Lots 2A and IA,North 19 degrees 30 minutes 00 seconds West, a distance of 259.22 feet to a point; thence North 64 degrees 30 minutes 00 seconds East, a distance of 144.39 feet to a point; thence South 25 degrees 26 minutes 00 seconds East, a distance of 307.80 feet to a point;thence South 64 degrees 30 minutes 00 seconds West, a distance of 346.50 feet to an iron pin;thence along South Broad Street,North 19 degrees 30 minutes 00 seconds West, a distance of 50.28 feet to the point and place of BEGINNING. 07/09/2014 3:21:51 PM CUMBERLAND COUNTY Inst.#200418485-Page 1 of 5 BEING Lot No. 3 on the aforementioned Subdivision Plan of William H. May,Jr. and containing 1.3285 acres,more or less. ALSO BEING the same premises which William H. May, Jr. and Helen W. May, husband and wife,by their deed dated the 13`h day of April,2000 and recorded the 13`h day of April,2000 in the Office of the Recorder of Deeds in and for Cumberland County,Pennsylvania in Deed Book 219,Page 306, granted and conveyed unto Sherry L. Hughes. UNDER AND SUBJECT TO setback lines and other conditions as shown on the aforementioned Plan. TRACT NO. 2: ALL THAT CERTAIN piece or parcel of land situate in Mechanicsburg Borough, Cumberland County, Pennsylvania as set forth in a survey by AIpha Consulting Engineers,Inc., John K. Murphy, P.E./PLS and more particularly described as follows: BEGINNING at a point marked by an iron pin on the West side of Washington Street; thence South 21 degrees 43 minutes 00 seconds East, a distance of 152.18 feet to an iron pin; thence South 67 degrees 10 minutes 57 seconds West, a distance of 150.02 feet to an iron pin; thence North 21 degrees 43 minutes 11 seconds West, a distance of 118.22 feet to an iron pin; thence South 68 degrees 17 minutes 00 seconds West, a distance of 34.74 feet to an iron pin; thence North 10 degrees 29 minutes 04 seconds West,a distance of 25.46 feet to a point;thence North 23 degrees 56 minutes 00 seconds West, a distance of 41.46 feet to a point; thence North 77 degrees 32 minutes 19 seconds East,a distance of 183.78 feet to the point and place of BEGINNING. BEING the same premises which William H. May,Jr. and Helen W. May,husband and wife,by their deed dated the 13`h day of April,2000 and recorded the 13`h day of April,2000 in the Office of the Recorder of Deeds in and for Cumberland County,Pennsylvania in Deed Book 219,Page 312, granted and conveyed unto Sherry L. Hughes. TRACT NO. 3: ALL THAT CERTAIN piece or parcel of land situate in Mechanicsburg Borough, Cumberland County,Pennsylvania as set forth in a survey by Alpha Consulting Engineers,Inc., John K. Murphy, P.E./PLS and more particularly described as follows: BEGINNING at a point along an alley which point is also the common corner of Lot 3 of the Subdivision of William H. May,Jr., as recorded in Cumberland County Plan Book 77, Page 140;thence along Lot 3,North 25 degrees 26 minutes 00 seconds West,a distance of 298.92 feet to a point;thence North 67 degrees 34 minutes 00 seconds East,a distance of 102.53 feet to a point;thence South 21 degrees 56 minutes 00 seconds East, a distance of 16.0 feet to a point; -2- Bcok 262 PACE495i 07/09/2014 3:21:51 PM CUMBERLAND COUNTY Inst.#200418485-Page 2 of 5 i thence North 65 degrees 04 minutes 00 seconds East, a distance of 89.74 feet to a point;thence South 23 degrees 56 minutes 00 seconds East, a distance of 247.53 feet to a point; thence South 10 degrees 29 minutes 04 seconds East, a distance of 26.08 feet to a point; thence South 53 degrees 12 minutes 38 seconds West,a distance of 24.47 feet to a point;thence South 64 degrees 49 minutes 00 seconds West,a distance of 153.95 feet to the point and place of BEGINNING. CONTAINING 1.24 acres more or less. BEING the same premises which William H. May,Jr. and Helen W. May,husband and wife,by their deed dated the 13th day of April, 2000 and recorded the 13'h day of April,2000 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book 219, Page 309,granted and conveyed unto Sherry L. Hughes. TRACT NO. 4: ALL THOSE two (2)certain parcels of land situate on the West side of South Washington Street, in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania,more particularly bounded and described as follows,to wit: PARCEL NO. 1 BEGINNING at corner of lot formerly of Abram May,Parcel No. 2 herein,on building line of said Washington Street; thence Westward along line of said lot,Parcel No. 2 herein,one hundred eighty-four(184) feet,more or less,to a sixteen foot alley;thence Southward along said alley thirty-eight and five-tenths (38.5)feet to a twenty foot alley;thence Eastward along said alley one hundred eighty-five and eight-tenths(185.8)feet,more or less, to a building line of said Washington Street;thence Northward along said building line of said South Washington Street, sixty-six and six tenths (66.6)feet to the place of BEGINNING. PARCEL NO. 2 BEGINNING at a point on Washington Street,corner of lot formerly of Simon May,Parcel No. 1 herein;thence along the lot formerly of Simon May, Parcel No. 1 herein,Westward one hundred ninety(190)feet to an alley; thence along said alley seventeen(17) feet Northward to lot now or late of A.K. Hostetler and Lilian Hostetler,his wife;thence Eastward along the lot of said Hosteders one hundred ninety(190) feet to Washington Street;thence South seventeen(17)feet along Washington Street to the place of BEGINNING. BEING the same premises which Donald L. Placido and Michaella A. Placido by their Deed dated October 23,2000 and recorded November 7, 2000 in the Office of the Recorder of Deeds in and for Cumberland County,Pennsylvania in Deed Book 233, Page 492 granted and conveyed unto Sherry L. Hughes. -3- sooK- 262 PuF4952 07/09/2014 3:21:51 PM CUMBERLAND COUNTY Inst.#200418485-Page 3 of 5 Mark A. Hughes, spouse of Sherry L.Hughes, hereby joins in this Deed to convey any right,title and interest he has in the above-described tracts and parcels. AND the said Grantor hereby warrants Specially the premises hereby conveyed. IN WITNESS WHEREOF,the Grantor hereby sets her hand and seal the day and year first above written. Signed, Sealed and Delivered in the Presence of- SEAL) *P&4_A_ Sherry L. ghes (SEAL) ark A. Hu es ./ il+ I 1 1 i f'r . H. C-.+:.0 o� C3 rrJ r.-., y Y• a�j V ei yrs ti: rrr, :arncncn � m�� r, __4 1 Ga Vis • 7: C 2 f r" 40 rp f GI rl G rn r.0 .4 CS u. 01 rA `•Y wh .c ev -4 6-1 - �. , NJ <a c7 N r n •M 'dr♦ M Imo! rp Gt .7 q — G.J C'R�.n Cf r-.•.... a Ln r-+•We='+ �©az Gl r•.:1 2 t..L.R 'Lrl�•) r-• .� _ NS` L •r uv WC.n!a 6 r-ni1C" UnV 4 P e7 G+Gi Gy O C r..a c_� rj a:r Cm 07/09/2014 3:21:51 PM CUMBERLAND COUNTY Inst.#200418485-Page 4 of 5 COMMONWEALTH OF PENNSYLVANIA) . SS. COUNTY OF CUMBERLAND ) On this the VP day of April,2004, before me, a Notary Public in and for the above County and Commonwealth,the undersigned officer,personally appeared SHERRY L. HUGHES and MARK A. HUGHES, wife and husband,known to me(or satisfactorily proven)to be the persons whose names are subscribed to the above Deed and acknowledged that they executed the same as their act and deed for the purposes therein contained. IN WITNESS WHEREOF,I hereunto set my hand and official seal. Notary P blic '. COMMONWEALTH OF PENNSYLVANIA Susan L Notarial Seal ,.? Notary pubic Mechtux anksg g m.cwrtwlww My Crnrr"on Expires Nov.24,2007 Member,Pennsylvania Asaocfation OF Notaries CERTIFICATE OF RESIDENCE I hereby certify that the precise post office address of the within named Grantee is: Alib T rney/Agent for Grantees t`ertify this to 17,c recorded -5- " CLtniberland COunty PA ,;cr o("Deeds aOOK 262 PAC-4954 07/09/2014 3:21:51 PM CUMBERLAND COUNTY Inst.#200418485-Page 5 of 5