HomeMy WebLinkAbout15-0307 -COYNE&COYNE, P.C.
Lisa Marie Coyne, Esq.
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PA Supreme Court ID No. 53788
3901 Market Street
Camp Hill, PA 17011-4227 16 P 12
(717) 737-0464 t,l 5 E
Fax: (717)737-5I61 iq , i�,,i�'lough of Mechanicsburg
BOROUGH OF MECHANICSBURG, : IN THE COURT OF COMMON PLEAS OF
Claimant : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. M.L.D.
Dana M. Mallory
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.
i
6. A description of the property against which this claim is filed is:
221 South Market Street
Borough of Mechanicsburg
Cumberland County
Pennsylvania 17055
TAX PARCEL NUMBER 17-23-0565-077
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
and ninety-seven dollars and thirty cents ($597.30), plus costs
and reasonable attorney's fees.
9. The time period for which these charges are filed is April 1, 2013 to
December 31, 2014 on Sewer and Refuse Account 2896-0.
WHEREFORE, Claimant requests that a Municipal Lien be entered in
its favor and against the Defendants_in the amount of five hundred and
ninety-seven dollars and thirty cents ($597.30), plus cost and reasonable
attorney's fees.
BO H OFAVCHp
ICSBURG
By: WA
Lisrie Coyne, E uire
Sol' itor 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
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 Hooker
NOTARY PUBLIC
Mechanicsburg Boro,Cumberland County
My Commission Expires 04/02/2017
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County Parcel No.1
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JUN 24 RM 9
This Deed,
Made the 20—J-14 day of �u rt c in the year
TWO THOUSAND THREE (2003)
BETWEEN RICHARD D. ADAMS, widower, of Mechanicsburg, Cumberland County,
Pennsylvania, party of the first part, hereinafter referred to as the GRANTOR
AND
DANA M. MALLORY, go , of Wayne, Pennsylvania, party of the second
part, hereinafter referred to as the GRANTEE
WITNESSETH, That in consideration of ONE HUNDRED SEVENTY THOUSAND AND 001100----•-•----
..............••.....---•------.........-••---•••...........-----.....($170,000.00)...............------.----- .
Dollars, in hand paid, the receipt whereof is hereby acknowledged, the said grantor does hereby
grant and convey to the said grantee
ALL THAT CERTAIN lot of ground with the buildings thereon erected, situate on the Northeast
corner of Market and Keller Streets in the Borough of Mechanicsburg, Cumberland County,
Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a post on the corner of said Market and Keller Streets; thence Northward by
Market Street 35 feet to a corner of Lot now or formerly of Samuel Mumma; thence by said Lot
Eastward 130 feet, more or less, to Brandt Alley; thence by said Alley Southward 43 feet to
corner of said Alley and Keller Street; thence Westward by said Keller Street 130 feet, more or
less, to the Place of BEGINNING.
a00* 257 0IU368i
HAVING THEREON ERECTED a brick dwelling house known and numbered as 221 South Market
Street, Mechanicsburg, Pennsylvania.
BEING the same premises which Bruce D. Schwartz and Roseann M. Schwartz, husband and wife,
by deed dated June 1, 1994 and recorded in the Office of the Recorder of Deeds in and for
Cumberland County in Deed Book 106, page 413 granted and conveyed unto Richard D. Adams
and Roberta K. Adams, husband and wife. The said Roberta K. Adams died April 2, 2002
whereby title vested in Richard D. Adams, GRANTOWHEREIN.
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 the Grantees and to Grantees'proper use and benefit forever.
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AND the said grantor will specially WARRANT AND FOREVER DEFEND the property hereby
conveyed.
IN WITNESS WHEREOF, said grantor has hereunto set his hand and seal, the day and year first
above-written.
Sealeden�ered in the presence of
Witness) RICHARD D.ADAMS
(Witness)
(Witness)
Commonwealth of Pennsylvania
County of
On this, the g day of� n2003 before me the
undersigned officer, a notary public, personally appeared RICHARD D. ADAMS, WIDOWER , known
to me (or satisfactorily proven) to be the person whose name is subscribed to the within
instrument, and acknowledged that he executed the same for the purpose therein contained.
IN WITNESS THEREOF, I have hereunto set my hand and notarial seal.
Notarial Seal
Suzanne L.Cramer,Notary Public
Hampden Twp.,Cumberland County
My Commission Expires May 20,2006
Member,Pennsylvania Association Of Nularlm
V.
tory c
;� F BOOK 257 PAGE,3. 683
Certificate Of Residence
I hereby certify, that the precise residence of the grantee herein is as follows:
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�7o.Ss
!Attorney or Atplfor Grantee)
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.
I Certify this to be recorded
In Cumberland County PA
op. • � � 257 PAGE3684
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Recorder of Dc:,us