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4
TIM PEIRCE t/d/b/a PEIRCE
CONSTRUCTION,
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
Claimant
v.
:NO. uS- -.L.I9??
fY2 ~D '---r 8L~
ROBERT WRIGHT and TEAGUE
WRIGHT, husband and wife,
Owners
:MECHANICS' LIEN
MECHANICS' LIEN CLAIM
Claimant Tim Peirce t/d/b/a Peirce Construction, through the undersigned
counsel, files this claim against the improvements and property at 810 Crooked Stick
Dr., Mechanicsburg, Cumberland County, Pennsylvania for the payment of a debt due
to claimant as a contractor for labor and materials furnished by claimant in the erection
and construction of the improvements. In support of the claim, the claimant makes the
following statement:
1. The owners of the property are Robert Wright and Teague Wright, with an
address at 810 Crooked Stick Dr., Mechanicsburg, Pennsylvania.
2. The improvement and the property which are subject to this claim are a single
family residence with appurtenant land at 810 Crooked Stick Dr., Mechanicsburg,
Pennsylvania.
3. The labor and materials for which the debt is due were furnished for the agreed
sum of $10,500 pursuant to a written contract with the owners dated July 11,
2005, a copy of which is attached hereto and incorporated herein as Exhibit "A."
"
4. The labor and materials for which the debt is due consisted of the installation of
concrete pool decking on the property.
5. The claimant completed his work at the property on August 2, 2005, which is less
than four months before the filing of this claim.
6. Claimant has been paid $4,300 toward the debt due claimant for the stated labor
and materials, and there is due and owing a balance of $6,200 for which claim is
made of $6,200.
Respectfully Submitted,
FENSTERMACHER AND ASSOCIATES, P.C.
J hn R. Fenstermacher
upreme Court 1.0. #29940
Shane F. Crosby
Supreme Court 1.0. #92530
5115 East Trindle Road
Mechanicsburg, PA 17050
(717) 691-5400
Attorneys for Plaintiff
DATED: '11(0)
~
PEIRCE CONSTRUCTION
TIM PEIRCE
11 WEST MAIN STREET BOX 294
NEW KINGSTOWN ,PA 17072
717-226-2026
PROPOSAL
TO:
ROB WRIGHT
PHONE
363-0041
DATE
07/11/05
JOB LOCATION:
810 CROOKED STICK DR.
MECHANICSBURG
SPECIFICATIONS AND ESTIMATE FOR
PLAN A POOL DECK APPROX 1125 SQ. FT.
1.EXCA VA TE DffiT TO ALLOW FOR STONE BASE,REMOVE PAD AT STEPS
2.GRADE AND COMPACT 2B STONE BASE TO ALLOW FOR 4" OF 4000 PSI
CONCRETE
3.ALL CONCRETE TO HAVE FmERMESH WITH 1/4" EXPANSION JOINT AT
PERIMETER OF POOL
4.PATTERN IS NOTCHED ASHLER SLATE
COLOR IS SLATE GREEN
RELEASE IS GREY
ACCENT COLOR IS SUN BUFF
5.INSTALL 1 PEICE OF 11/4" PLASTIC DRAIN AT EXISTING PATIO
6.APPLY 2 COATS OF 25% SOLIDS SEALER WITH ANTI-SKID
WE PROPOSE HEREBY TO FURNISH MATERIALS AND LABOR COMPLETE IN ACCORDANCE WITII
TIIE ABOVE SPECIFICATIONS ,FOR TIIE SUM OF
1100 SQ FT AND OVER AT $8.75
800-1099 SQFT AT $8.90
799 AND UNDER AT $9.10
PAYMENT TO BE MADE AS FOLLOWS
DEPOSIT OF Vz OF TOTAL PRICE ($ )ONCE JOB IS INITIATED.
COMPLETION( )
BALANCE DUE UPON
-
..
ALL MATERIAL IS GUARANTEED TO BE AS SPECIFIED. ALL WORK TO BE COMPLETED IN A
PROFESSIONAL MANNER ACCORDING TO STANDARD PRACTICES .ANY ALTERATION OR
DEVIATION FROM ABOVE SPECIFICATIONS INVOLVING EXTRA COST WILL BE EXECUTED UPON
WRITTEN ORDERS.
AUTHORIZED SIGNATURE:
ACCEPTANCE OF PROPOSAL-THE ABOVE PRICES ,SPECIFICATIONS AND CONDITIONS ARE
SATISFACTORY AND HEREBY ACCEPTED. YOU ARE AUTHORIZED TO DO THE WORK SPECIFIED.
PAYMENT WilL BE MADE AS OUTLINED.
CUSTOMER SIGNATURE;
DATE I I
VERIFICATION
I, Tim Peirce, hereby certify and verify that the facts set forth in the
foregoing Mechanics' Lien Claim are true and correct to the best of my
knowledge, information and belief. I understand that any false statements herein
are subject to the penalties of 18 Pa. C.S. S4904 relating to unsworn falsification
to authorities.
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Tim Peirce
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TIM PEIRCE t/d/b/a PEIRCE
CONSTRUCTION,
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
Claimant
O$"- .1./99'1 CJu~L l~
:NO. CV0000438-05
v.
ROBERT WRIGHT and TEAGUE
WRIGHT, husband and wife,
Owners
:MECHANICS' LIEN
AFFIDAVIT OF SERVICE
I, John R. Fenstermacher, do hereby swear and affirm that I served a copy of the
Mechanics' Lien Claim upon Mr. Robert Wright by first class mail at 810 Crooked Stick
Drive, Mechanicsburg, Pennsylvania on September 26, 2005.
J hn R. Fenstermacher
I
TIM PEIRCE t/d/b/a PEIRCE
CONSTRUCTION,
Plaintiffs
v.
ROBERT WRIGHT and TEAGUE
WRIGHT, husband and wife,
Defendants
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
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PRAECIPE TO SATISFY
TO THE PROTHONOTARY:
Please mark the above-captioned action SATISFIED.
Respectfully submitted,
FENSTERMACHER AND ASSOCIATES, P.C.
n R. Fenstermacher
upreme Court I.D. #29940
115 East Trindle Road
Mechanicsburg, PA 17050
(717) 691-5400
Attorney for Plaintiffs
DATED: ~y~,~~ ~ ~') ~~/ D
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CERTIFICATE OF SERVICE
AND NOW, on this r~~ day of June, 2010, I, John R. Fenstermacher,
Esquire, hereby certify that I have served the foregoing Praecipe to Satisfy mailing a true
and correct copy by United States first class mail., addressed as follows:
Peter G. Howland, Esq.
Wix, Wenger & Weidner
508 North Second Street
Post Office Box 845
Harrisburg, PA 17108-0845
Attorney for Defendants
FENSTERMACHER AND ASSOCIATES, P.C.
~~
ohn R. Fenstermacher
TIM PEIRCE t/d/b/a PEIRCE :IN THE COURT OF COMMON PLEAS OF
CONSTRUCTION, :CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
v. :NO. 05-4999 MLD Term
ROBERT WRIGHT and TEAGUE
WRIGHT, husband and wife, :MECHANICS' LIEN n
Defendants ~ ~,
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PRAECIPE TO SETTLE AND DISCONTINUE ~-~; ~ - _
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TO THE PROTHONOTARY: ~ ~
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Please mark the above-captioned action SETTLED AND DISCONTINUED. `~" -`
Respectfully submitted,
FENSTERMACHER
By:
SOCIATES, P.C.
,lohn R.~ nstermacher
upreme ourt I.D. #29940
t Trindle Road
Mechanicsburg., PA 17050
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Attorney for Plaintiffs
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DATED: ~f ~3f ~ ~
CERTIFICATE OF SERVICE
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AND NOW, on this ~~^' day of June, 2010, I, John R. Fenstermacher,
Esquire, hereby certify that I have served the foregoing Praecipe to Settle and Discontinue
by mailing a true and correct copy by United States first class mail, addressed as follows:
Peter G. Howland, Esq.
Wix, Wenger & Weidner
508 North Second Street
Post Office Box 845
Harrisburg, PA 17108-0845
Attorney for Defendants
FENSTERMACHER AND ASSOCIATES, P.C.
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J h R
o n enstermacher
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