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HomeMy WebLinkAbout15-0307 -COYNE&COYNE, P.C. Lisa Marie Coyne, Esq. L 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 r 3300 ` corl-)4f- '• Warranty Dead County Parcel No.1 r P. ZIEGL E- OF DE • 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. —4 c",C'7 c i 1-y zr+~i -t -a:: I Ca M =r =1;s r c+ . "I f+r r'rt r" .t CD rD M rG [", 1:7 P, r•7 C•') M M rr) 16C Ut a rf n n �C Xt 3C 3t.-w'q• f 5:-Y• I IOC F 1^ rl h1 tJ RJ 3�C4,111 c ••.1 ::7 .• a -n %... CCS v r af: c".r �tya o CA c> rDCM rt ,o �o .t rl ox CT• r.7 257 Pntj682 1_41 •;C i SO-t.1 Y CI �YJ -�7 '00 Ln e 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: re �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 }X Recorder of Dc:,us