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HomeMy WebLinkAbout14-4134 SOYNE &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 : CUMBE�R/LAND COUNTY, PENNSYLVANIA V. . NO. 17-V13 M.L.D. C-) CJ Gregory S. Foulds and Pamela K. Foulds, husband and wife -<n C., Defendants MUNICIPAL LIEN - �=?^ MUNICIPAL LIEN FOR SEWER/WATER RATES i 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 seq., 53P.S. §7143, as amended. *oV—so PA A77Y C#57Qt 6. A description of the property against which this claim is filed is: 212 West Allen Street Borough of Mechanicsburg Cumberland County Pennsylvania 17055 TAX PARCEL NUMBER 19-23-0567-128 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 five hundred fifty-nine dollars and forty cents ($559.40), plus costs and reasonable attorney's fees. 9. The time period for which these charges are filed is April 1, 2013 to June 30, 2014 on Sewer and Refuse Account 4187-0. WHEREFORE, Claimant requests that a Municipal Lien be entered in its favor and against the Defendants in the amount of five hundred fifty- nine dollars and forty cents ($559.40), plus cost and reasonable attorney's fees. ROUGH OPIECHAtrBURG IV Lisa arie Coyne, Esquir Soli . 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. 15� - r, . ur- Patrick E. Dennis, Borough Manager Sworn to and subscribed before me this 15th day of July, 2014. Sl6'ja`- Notary Public NOTARIAL SEAL Leslie S Hocker NOTARY PUBLIC Mechanicsburg Boro,Cumberland County My Commission Expires 04/02/2017 Tax Parcel No. 19-23-0567-128 THIS DEED, MADE THE 29"_day of JUNE in the year of our Lord two thousand two(2002). BETWEEN PEGGY L. BURKETT, now PEGGY L. GREENE and ROBERT E. GREENE, husband and wife,parties of the first part, Grantors, and GREGORY S.FOULDS and PAMELA K FOULDS,husband and wife, parties of the second pad, Grantees. WITNESSETH, that in consideration of Seventy-one Thousand and No/Hundredths($71,000.00)Dollars, in hand paid, the receipt whereof is hereby acknowledged, the said Grantors do hereby grant and convey to the said Grantees, their heirs and assigns,as tenants by the entirety, ALL THAT CERTAIN lot of ground situate on the North side of West Allen Street in the Borough of Mechanicsburg,County of Cumberland and State of Pennsylvania,bounded and described as follows: BEGINNING at a point on said Allen Street and at the corner of lot now or formerly of Robert C. Fry; thence along said Allen Street westward sixteen and three one-hundredths(16.03)feet to a point at comer of lot now or formerly of Leroy H.Norris;thence by line of said lot northward and through the center of a frame partition wall and beyond eighty-seven and six-tenths(87.60)feet to a point at corner of lot now or formerly of Annie Knabe;thence along the line of said lot eastward sixteen and twenty-four one-hundredths(16.24)feet to an iron pin at comer of lot now or formerly of Robert C. Fry, aforesaid;thence along the line of said lot southward and through the center of a frame partition wall eighty-five (85)feet to a point on said Allen Street, the Place of BEGINNING. Having erected thereon a three story frame dwelling house numbered 212 West Allen Street. BEING THE SAME premises which Harry L. Kraly and Alma Louise Kraly, his wife, by their Deed dated March 13, 1964 and recorded June 3, 1964,in the Office of the Recorder of Deeds in and for Cumberland County, at Carlisle, Pennsylvania, in Deed Book"F", Volume 21, Page 724, granted and conveyed to Gary Lee Burkett and Peggy L. Burkett. The said Gary Lee Burkett having died on November 12, 1993,title to the same remained vested by operation of law solely in his surviving spouse, Peggy L. Burkett, now Peggy L. Greene,one of the Grantors herein. Robert E.Greene joins in the within conveyance to quite claim any interest he may have in the above described premises by virtue of his marriage to the said Peggy L.Greene,one of the grantors herein. AND the said Grantors hereby covenant and agree that they will warrant SPECIALLY the property hereby conveyed, ao�r 47"52 1-2663 07/09/2014 3:16:46 PM CUMBERLAND COUNTY Inst.#200226895-Page 1 of 3 IN WITNESS WHEREOF, said Grantors have hereunto set their hands and seals the day and year first above written. Signed,Sealed,and Delivered in the Presence of sEAL) eg . urkett Pegg L. teen _(SEAM Robert t, Greene Commonwealth of Pennsylvania }ss. County of Cumberland On this, the 2Er t"h day of JUNE, 2002, before me, the undersigned officer,personally appeared PEGGY L. BURKETT, now PEGGY L. GREENE AND ROBERT E. GREENE, husband and wffe, known to me(or satisfactorily proven) to be the persons whose names:are subscribed to the within instrument, and acknowledged that they executed the same for the purposes therein contained IN WITNESS WHEREOF,i hereunto set my hand and official seal. ( EAL), NOTARAL SM x; BORot�J( 0�C"'ARYPUBW Co PA ;� r•r I do hereby certify that the precise resid nce and complete post office address of the within named, Grantee is Z/L ! I'17.t ,x- i 7o 2002 Choice 4ropy a lernents-lr?c. Agent for Grenfees $e a x 252 PAGE2664 07/09/2014 3:16:46 PM CUMBERLAND COUNTY Inst.#200226895-Page 2 of 3 O fT -ER LO co D E E D N C3 U NT Y PA Cq C-3 � 02 JUL 3 PM 2 42 Cq in CIA C:) Cumberland County Recortler of Deeds Instrument Filins %N Receipt# rlow Instr# 2002-026995 7/03/2002 14:40:;; Remarks: CHOICE PROPERTY z FOUNDS Z) 0 0 DEED 11.53 z OM - VRIT :50 M OEED - RTT STATE 7 11 0,W M MECHANICSBURG 375.00 WHANICSBURG BDRO 3M.00 DEED - A/H CO INPRWENENT FVD 2,00 REC. IMPRVNT FUND 3.00 Check# 11126 $738.00 Oleck# W28 t.50 Chedd 11127 CL CL '0 io O