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HomeMy WebLinkAbout15-0305 eOYNE &COYNE, P.C. Lisa Marie Coyne, Esq. ,, PA Supreme Court ID No. 53788 - 3901 Market Street " Camp Hill, PA 17011-4227 '� r„ti (717) 737-0464 Fax: (717) 737-5161 �� olxiorr t ;righ of Mechanicsburg raDVISY BOROUGH OF MECHANICSBURG, : IN THE COURT OF COMMON PLEAS OF Claimant : CUMBERLAND COUNTY, PENNSYLVANIA V. . NO. M.L.D. Kelly S. Bonilla 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 seq., 53P.S. §7143, as amended. a�s7jj , C �a 3AS 7K 6. A description of the property against which this claim is filed is: 200 North Market Street Borough of Mechanicsburg Cumberland County Pennsylvania 17055 TAX PARCEL NUMBER 18-23-0565-012 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 and ninety-nine dollars and twenty-eight cents ($899.28), plus costs and reasonable attorney's fees. 9. The time period for which these charges are filed is January 1, 2014 to December 31, 2014 on Sewer and Refuse Account 3370-0. WHEREFORE, Claimant requests that a Municipal Lien be entered in its favor and against the Defendants in the amount of eight hundred and ninety-nine dollars and twenty-eight cents ($899.28), plus cost and reasonable attorney's fees. B \ UGH 0 MECHANICSBURG By: �- Lis rie Coyne, E quire Solicitor 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: January 15, 2015 s, ► COMMONWEALTH OF PENNSYLVANIA ) )ss COUNTY OF CUMBERLAND ) Patrick E. Dennis, being duly sworn according to law, deposes and says that he is the Borough Manager for the Borough of Mechanicsburg, and that the facts set forth in the foregoing instrument are true and correct to the best of his knowledge, information and belief. Patrick E. Dennis, Borough Manager Sworn to and subscribed before me this 15th day of January, 2015. Notary Public NOTARIAL SEAL Leslie S Hocker NOTARY PUBLIC Mechanicsburg Boro,Cumberland County My Commission Expires 0410212017 v37 .� Warranty Deed County Parcel No.This Deed , • L+- ._ Made the day of in the year TWO THOUSAND EIGHT (2008) BETWEEN JAMES E. DOWNS AND JENNIFER R. DOWNS, his wife, of Mechanicsburg, Cumberland County, Pennsylvania, parties of the first part, hereinafter referred to as the GRANTORS AND KELLY S. BONILLA, single woman, of Mechanicsburg, Cumberland County, Pennsylvania, party of the second part, hereinafter referred to as the GRANTEE WITNESSETH, That in consideration of ONE HUNDRED FORTY FIVE THOUSANDAND 00/100------------------------------------------------------------------ --------------------------------------------($145,000-00)------------------------------------- Dollars, $145,000.00)------------------------------------- Dollars, in hand paid, the receipt whereof is hereby acknowledged, the said grantors do hereby grant and convey to the said grantee ALL THAT CERTAIN lot or piece of ground, with the building and improvements thereon erected, situate in the Borough of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, and described according to the Map of Property made by Gerrit J. Betz Associates, Inc., Registered Surveyors and Engineers, dated April 18 and recorded April 25, 1977, as follows, to wit: L ' l' BEGINNING NING at the point of intersection of the easterly side of North Market Streef with the northerly side of Green Street; thence extending from said point of beginning,and;along the easterly side of North Market Street, North 10 degrees 21' minutes East, the distance of'37.00 feet to­ :point at a corner of lands-of.Chalmers-N. Kauffman; thence extending along the lands of Kauffman, South 75 degrees 45 minutes East, the distance of 177.00 feet to a point in a 12-f6ot wide alley; thence extending;through the same, South 10 degrees 21 minutesWest; the distance of 37.00 feet to a point at the intersection,with the northerly side of Green Street; thence extending along the said side of Green Street, North 75 degrees 45 minutes West, the distance of 177:00 feet to the first mentioned .point and-Place of BEGINNING. BEING known and numbered as200-N_o_rth Market:Stre? Mechanicsburg, Pennsylvania. BEING the same premises which Michael C. Shevlin and Susan P. Sheviin, his wife, by Deed dated August 2nd. 1996 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 143, Page 869, granted and conveyed unto James E. Downs and Jennifer R. Downs, his wife, GRANTORS HEREIN. TOGETHER with all and singular the buildings, improvements, way, woods, water, watercourses, rights, liberties, privileges, hereditaments and appurtenances to the same belonging or in anywise appertaining; and the reversion,and reversions, remainder and remainders„rents,;issues and.profits.thereof, and of every part and parcel thereof; AND ALSO all the estate;:right title, interest, use, possession, property, claim and demand whatsoever of the Grantor'both in law and in equity, of, in and to the premises herein described and every part and parcel thereof with the appurtenances. TO HAVE AND TO HOLD all and singular the premises herein described together with the.hereditaments and appurtenances unto-tlie' Grantees and t6 Grantees' proper use and benefit forever. Certificate Of Residence herebycertify, that the precise residence of the grantees herein is as follows: At � (Attorney ent r a ee) Recorder of Deeds Commonwealth of Pennsylvania County of RECORDED on this day of , A.D. in the Recorder's Office of said County, in Deed Book Volume , Page . Given under my hand and the seal of the said office, the date above written. Recorder. ROBERT P. ZIEGLER RECORDER OF DEEDS _ . CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 = ; 717-240-6370 Instrument Number-20081.9837 Recorded On 6/13/2008 At 11:03:14 AM *Total Pages-5 *Instrument Type-DEED Invoice Number-22946 User ID-KW *Grantor-DOWNS,JAMES E *Grantee-BONILLA,KELLY S *Customer-GUARANTEED ABSTRACT SER INC FEES STATE TRANSFER TAX $1,450.00 Certification Page STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $10.00 DO NOT DETACH JUSTICE RECORDING FEES - $11.50 P P now page a e is art RECORDER OF DEEDS AFFORDABLE HOUSING $11.50 of this legal document. COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 MECHANICSBURG SCHOOL $725.00 DISTRICT MECHANICSBURG BOROUGH $725.00 TOTAL PAID $2,938.50 i I Certify this to be recorded in Cumberland County PA aF Cli RECORDER OF DEEDS 1)80 -Information denoted by an asterisk may change during the verification process and may not be reflected on this page. OOOT6L III 1111111111111 E 111111111