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HomeMy WebLinkAbout06-3403WHISLER'S WELL DRILLING INC., : IN THE COURT OF COMMON PLEAS Claimant CUMBERLAND COUNTY, PENNA V. DOCKET NO. C?o _ 3?v3 "LE) ERIC BARR, Defendant. TO: Eric Barr 23 Watson Drive Carlisle, PA 17013 MECHANICS' LIEN NOTICE OF FILING OF MECHANICS' LIEN CLAIM You are notified that a mechanics' lien claim in the amount of $11,429.47 has been {ath een A. E R6 Attorney ID# 200616 ABOM& KUTULAJUS, L.L.P. 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 filed on behalf of Whisler's Well Drilling against the property located at 23 Watson Drive, Carlisle, West Penn Township, Cumberland County, Pennsylvania, of which you are the owners or reputed owners. The claim was filed on the 15`h day of June, 2006, in the Court of Common Pleas of Cumberland County, Pennsylvania, at the above-referenced Docket Number. A copy of the claim is attached. 0 WHISLER'S WELL DRILLING INC., Claimant ERIC BARR, V. Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA DOCKET NO. MECHANICS' LIEN MECHANICS' LIEN CLAIM NOW COMES Whisler's Well Drilling, Inc. ("Claimant"), by and through the undersigned counsel, and files this claim of mechanics' lien against Eric Barr, pursuant to the Mechanics' Lien Law of 1963, as amended, against the improvements and the property at 23 Watson Drive, Carlisle, West Penn Township, Cumberland County, Pennsylvania for the payment of all debts due Claimant as a contractor for labor and materials furnished in the construction of the improvements. In support of the claim, the Claimant makes the following statements: 1. The Claimant is Whisler's Well Drilling, Inc., having its principal office at 366-1 Green Springs Road, Newville, Cumberland County, Pennsylvania. 2. The owners or reputed owners of the property and improvements against whom the claim is filed is Eric Barr (the "Owner"). 3. Claimant makes this claim as a contractor. Claimant provided certain work, labor, equipment and materials related to the drilling of a well on Owner's property. Invoices, which describe the work performed in detail, are attached hereto as "Exhibit A" and are incorporated herein. 4. Claimant completed the furnishing of the work, labor and materials that are the subject of this claim on or about April 4, 2006. 5. The total amount claimed to be due and owing is $11,429.47 for work performed. 6. The property subject to the lien is a 23 Watson Drive, Carlisle, West Penn Township, Cumberland, County, Pennsylvania, Parcel I.D. No. 46-08-0587-119, Deed Book 00267, Page 06999, including all equipment that as part of said structure constitutes fixtures, together with the lot or curtilage appurtenant thereto belonging to the same Owner. 7. This lien is claimed from November 1, 2005, the date Claimant commenced performance of the work on the property herein described and against the Owner's interest in that property. WHEREFORE, Claimant files this claim for mechanics' lien in the amount of $11,429.47 plus filing and Sheriff's service costs in the amount of $114.00 with interest as provided by law. Respectfully submitted, ABOM& KUTULAKUS, L.L.P. tthleen A. Engle !i Attorney ID# 200616 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Claimant VERIFICATION I, Kenneth L. Whisler, hereby 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 false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Date: A2' Kenneth L. Whisler, Authorized Agent Whisler's Well Drilling WHISLER'S WELL DRILLING INC., Claimant ERIC BARR, V. Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA DOCKET NO. : MECHANICS' LIEN CERTIFICATE OF SERVICE AND NOW, this I day of June 2006, I, Kathleen A. Engle, of ABOM & KuTuLAKiS, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Mechanic's Lien, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following. Eric Barr 23 Watson Drive Carlisle, PA 17013 a Teen A. En e Attorney for Pl ' ff r:7 T m ? ? r T ` 4, l T, c? n C z - r WHISLER'S WELL. DRILLING INC., Claimant ERIC BARR, V. Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA : DOCKET NO. 2006-03403 MECHANICS' LIEN AFFIDAVIT OF SERVICE I, Kathleen A. Engle, hereby certify that I did serve a true and correct copy of the Mechanics' Lien Claim under Section 1502(a)(2) of the Mechanics' Liens Law, upon the Defendant, by personal service by Cumberland County Sheriff, on July 10, 2006, at Carlisle, Pennsylvania, addressed as follows: Eric Ban 23 Watson Drive Carlisle, PA 17013 Sheriff's Return acknowledging receipt on July 10, 2006 is attached as Exhibit «A„ ABOM & KUTULA"S, LLP Dater Vtb?leen A. Engle, quire` 6 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Claimant I.D. No: 200616 EXHIBIT `A" SHERIFF'S RETURN - REGULAR A CASE NO: 2006-03403 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WHISLER'S WELL DRILLING INC VS BARR ERIC SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within MECHANICS LIEN CLAIM BARR ERIC was served upon the OWNER , at 1828:00 HOURS, on the 10th day of July , 2006 at 23 WATSON DRIVE SLE, PA 17013 SHAWNA BARR, ADULT IN CHARGE by handing to a true and attested copy of MECHANICS LIEN CLAIM together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 4.40 Postage .39 Surcharge 10.00 R. Thomas Kline .00 32.79 07/11/2006 ABOM & KUTULAKIS Sworn and Subscibed to By: k nil before me this day Deputy ShOkiff of A.D. c. WHISLER'S WELL DRILLING INC., Claimant V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA : DOCKET NO. 2006-03403 ERIC BARR, Defendant. MECHANICS' LIEN PRAECIPE TO AMEND MECHANICS' LIEN LAIM NOW COMES Whisler's Well Drilling, Inc. ("Claimant"), by and through the undersigned counsel, and amends this claim of mechanics' lien against Eric Barr, pursuant to the Mechanics' Lien Law of 1963, as amended, against the improvements and the property at 23 Watson Drive, Carlisle, West Penn Township, Cumberland County, Pennsylvania for the payment of all debts due Claimant as a contractor for labor and materials furnished in the construction of the improvements. In support of the amended claim, the Claimant makes the following statements: 1. The total amount claimed to be due and owing is $8,516.27 for work performed, rather than $11,429.47, the amount stated in the initial mechanics' lien claim filed on June 15, 2006. 2. This amended amount is necessary to reflect the actual amount owed to the Claimant, as Mr. Barr rendered a payment on June 1, 2006 to the Claimant in the amount of $2913.20. (Please see attached invoice as Exhibit "A") 3. This payment changes the amount still owed by Defendant to the amount of $8,516.27. WHEREFORE, Claimant amends the earlier claim for mechanics' lien to the amount of $8,516.27 plus filing and Sheriff's service costs in the amount of $114.00 with interest as provided by law. Respectfully submitted, ABOM& KUTULASIS, L.L.P. Attorney for Claimant 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Whislers Well Drilling Inc. 366-1 Green Springs Road Newville, Pa 17241 Phone: (717) 776-6211 Fax: (717) 776-9441 8111 To ERIC BARR 23 WATSON DRIVE CARLISLE, PA 17013 Statement Date 7125/2006 Amount Due Amount Enc, $8,516.27 Date Description Amount Balance 01/01/2006 Balance forward 3,837.98 01/11/2006 PMT#1501, -3,837.98 0.00 01/23/2006 INV #6142, Due 01123/2006, 362.90 362.90 01/2312006 INV 46143. Due 01123!2006. 2,700.00 3,062.90 01/232006 INV 0144. Due 01232006. 10,271.08 13,333.98 01127/2006 INV #6149. Due 01/27/2006. 2,090.00 15,423.98 02/01/2006 INV #6153. Due 02101/2006. 6,350.00 21,773.98 02/21/2006 INV 06188. Due 0212112006. 2,076.97 23,850.95 02/2212006 INV #6189. Due 02/2212006. 149.02 23.999.97 0224/2006 PMT#1505. -16,621.08 7,378.89 03/10/2006 PMT#1508. -511.92 6,866.97 04106/2006 INV #6281, Due 04/06/2006. 2,755.00 9,621.97 0 410612 0 0 6 INV #6282, Due 04/062006. 1,807.50 11,429.47 041062006 INV #6283. Due 04/062006. 10,006.88 21,436.35 041122006 PMT#114. -10,006,88 11,429.47 061012006 PMT # 116. -2,913,20 8.516.27 Curcent 1-30 Days Past Due 31-80 Days Past 61-90 Days Past Over 90 Days Past Amount Due Due Due Due 0.00 0.00 0.00 0.00 8,516.27 $8,516.27 WHISLER'S WELL DRILLING INC., Claimant ERIC BARR, V. Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA : DOCKET NO. 2006-03403 MECHANICS' LIEN CERTIFICATE OF SERVICE AND NOW, this 4Pj { day of August 2006, I, Kathleen A. Engle, of ABOM & KUTuLAKIS, L.L.P. hereby certify that I did serve a true and correct copy of the foregoing document, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Eric Barr 23 Watson Drive Carlisle, PA 17013 rILwuicy 1V1171AMutl WHISLER'S WELL DRILLING INC., Claimant V. ERIC BARB, Defendant. TO: Eric Barr 23 Watson Drive Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA : DOCKET NO. 2006-03403 : MECHANICS' LIEN NOTICE OF FILING OF MECHANICS' LIEN CLAIM You are notified that an amended mechanics' lien claim in the amount of $8,516.27 has been filed on behalf of Whisler's Well Drilling against the property located at 23 Watson Drive, Carlisle, West Penn Township, Cumberland County, Pennsylvania, of which you are the owners or reputed owners. The claim was filed on the June 15, 2006 and this amendment was filed on August 8, 2006, in the Court of Common Pleas of Cumberland County, Pennsylvania, at the above-referenced Docket Number. A copy of the claim is attached. Kathleen Attorney ID# 200616 ABOM&KUTULA"S, L.L.P. 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 C ? m rr: ? ? ? -?. ?e ?G ? ? ? ? < ?? -p t ?? „? SHERIFF'S RETURN - REGULAR CASE NO: 2006-03403 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WHISLER'S WELL DRILLING INC VS BARR ERIC SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within MECHANICS LIEN CLAIM was served upon BARR ERIC the OWNER , at 1828:00 HOURS, on the 10th day of July 2006 at 23 WATSON DRIVE CARLISLE, PA 17013 by handing to SHAWNA BARR, ADULT IN CHARGE a true and attested copy of MECHANICS LIEN CLAIM together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 4.40 --? Postage .39 Surcharge 10.00 R. Thomas Kline .00 32.79,/ 07/11/2006 /a4 ABOM & KUTULAKI S Sworn and Subscibed to ! By: before me this day Deputy S iff of A.D. } OM & KUTLIL WIS John W. Carter, Esquire Abom & Kutulakis 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 WHISLER'S WELL DRILLING INC., Claimant V. ERIC BARR, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 2006-03403 : MECHANICS' LIEN PRAECIPE TO DISCONTINUE AND SATISFY JUDGMENT TO PROTHONOTARY: Please Discontinue this action against Defendant with prejudice and mark as satisfied. Respectfully submitted, ABOM & KUT ULAKIS, L. L. P. Date: ?( / L. John W. Carter, Esquire 36 South Hanover Street Carlisle, PA 17013 717-249-0900 ID No. 202849 Attorney for Plaintiff 'ok J WHISLER'S WELL DRILLING INC., Claimant V. ERIC BARR, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA DOCKET NO. 2006-03403 : MECHANICS' LIEN CERTIFICATE OF SERVICE AND NOW, this day of April 2008, I, John W. Carter, Esquire, of ABOM & KUTULAKis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing document, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Elliot A. Strokoff 132 State Street P.O. Box 11903 Harrisburg, PA 17108 Jo n W. Carter, Esquire Attorney for Plaintiff C?"_ ? , .??; rr £ ,_ h r , .." ?? . ?.. ,? W C ?.J --..,,??_? ` ?"" ? ? a i' ?, -...` ?"' ?'1 `?sr ,? ?t ?. , "? t?yJ ....-