HomeMy WebLinkAbout06-3712IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPR]NG TOWNSHIP AUTHORITY
31 E. MAIN STREET, P.O. BOX 1001
NEW KINGSTON, PA 17072-1001
Plaintiff,
vs.
BRYCE W. THOMPSON
AMY L. THOMPSON
6 CLOVER LANE
MECHANICSBURG, PA 17050
PARCEL# 38-21-0291-012
I Hereby certify that the last known
address of Defendant(s) is/are:
Bryce W. Thompson
A y L. Thompson
6 lover Lane
M char' urg, A 17050
Defendants.
CIVIL DNISION
No.: 07-0218 Civil Term
No.: 06-3712 MLD
TYPE OF PLEADING:
PRAECIPE FOR DEFAULT
JUDGMENT (Municipal Lien)
FILED ON BEHALF OF:
Silver Spring Township Authority
Plaintiff
COUNSEL OF RECORD FOR THIS
PARTY:
// JAMES, SMITH, DIETTERICK & CONNELLY, LLP
~/ Pa. I.D. #55650
intiff P.O. Box 650
Hershey, PA 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY:
31 E. MAIN STREET, P.O. BOX 1001
NEW KINGSTON, PA 17072-1001 :
Plaintiff,
vs. ;
BRYCE W. THOMPSON
AMY L. THOMPSON
6 CLOVER LANE
MECHANICSBURG, PA 17050
PARCEL# 39-21-0291-012
Defendants.:
CIVIL DIVISION
NO.: 07-0218 Civil Term
NO.: 06-3712 MLD
PRAECIPE FOR DEFAULT JUDGMENT
TO: PROTHONOTARY
SIR/MADAM:
Please enter a default judgment in the above-captioned case in favor of Plaintiff and
against Defendants, Bryce W. Thompson and Amy L. Thompson, in the amount of $4,250.10,
which is itemized as follows:
Sewer Rents through 1St Quarter 2006 $ 920.75
Penalties through December 6, 2006 $ 89.35
Attorney' Fees $ 1,000.00
Court Costs and Fees 2 240.00
TOTAL: $ 4,250.10
plus interest, penalties, and Quarterly bills after the 1St Quarter 2006, and additional attorneys'
fees and costs reasonable and actually incurred.
JAMES, SA
CONNELL
BY~ ~~ ~~/
Scott A. Di~tteric~, Esquire
Attorney for Plaintiff
PA I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
AFFIDAVIT OF NON-MILITARY SERVICE
AND CERTIFICATE OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF DAUPHIN
Before me, the undersigned authority, a Notary Public in and for said County and
Commonwealth, personally appeared Scott A. Dietterick, Esquire, attorney for and authorized
representative of Plaintiff who, being duly sworn according to law, deposes and says that the
Defendant is not in the military service of the United States of America to the best of his
knowledge, information and belief and certifies that the Notices of Intent to take Default
Judgment were mailed in accordance with Pa. R.C.P. 27.1, as evidenced by the attached copies.
Scott
Sworn to and subscribed before me
This day of ~1~/~--~ , 2007.
Notary Public
My Commission Expires:
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
MICHELLE ELLIOTT NOTARY PUBLIC
DERRY TOWNSHIP DAUPHIN COUNTY
MY COMMISSION EXPIRES JUNE 9, 2007
IN THE COURT OF COMMON PLEAS OF CUIVIBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY
31 E. MAIN STREET, P.O. BOX 1001
NEW KINGSTON, PA 17072-1001
Plaintiff,
vs.
BRYCE W. THOMPSON
AMY L,. THOMPSON
6 CLOVER LANE
MECHANICSBURG, PA 17050
PARCEL# 3 $-21-0291-012
Defendants.
CIVIL DIVISION
No.; 07-0218 Civil Term
No.: 06-3712 MLD
IMPORTANT NOTICE
TO: Bryce W. Thompson
6 Clover Lane
Mechanicsburg, PA 17050
DATE OF NOTICE: February 20, 2007
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE
ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY
OR OTHER IlVIPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT
ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Phone (717) 249-3166
Phone (800) 990-9108
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY
31 E. MAIN STREET, P.O. BOX 1001
NEW KINGSTON, PA 17072-1001
Plaintiff,
vs.
BRYCE W. THOMPSON
AMY L. THOMPSON
6 CLOVER LANE
MECHAI~TICSBURG, PA 17050
PARCEL# 38-21-0291-012
Defendants.
. CIVIL DIVISION
No.: 07-0218 Civil Term
. No.: 06-3712 MLD
AVISO IMPORTANTE
A. Bryce W. Thompson
FECHA DEL AVISO:
February 20, 2007
USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION
REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS
PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN
CONTRA SUVA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU
PROPIEDAD Y OTROS DERECHOS IlViPORTANTES. USTED DEBE LLEVAR ESTE
DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO O
NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA ABAJO INDICADA PARR QUE LE
INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Phone (717) 249-3166
Phone (800) 990-9108
& CONNELLY, LLP
DATE: V
BY:
PA I.I. #55630
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
FIRST CLASS U.S. MAIL, POSTAGE PREPAID
SHERIFF'S RETURN - REGULAR
'. CASE NO: 2007-00218 'r
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SILVER SPRING TOWNSHIP AUTHORI
VS
THOMPSON BRYCE W ET AL
STEPHEN BENDER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF SCIRE FACIAS was served upon
THOMPSON BRYCE W the
DEFENDANT at 1940:00 HOURS, on the 30th day of January 2007
at 6 CLOVER LANE
MECHANICSBURG, PA 17050 by handing to
BRYCE THOMPSON
a true and attested copy of WRIT_OF SCIRE FACIAS
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 1-8.00
Service 9.68
Affidavit .00
Surcharge 10.00
.00
37.68
Sworn and Subscibed to
before me this day
So Answers:
R . Tlhoma s Kline
01/31/2007
JAMES SMITH DIETTERICK CONNELL
By:
D uty Sheriff
of A.D.
• d
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY
31 E. MAIN STREET, P.O. BOX 1001
NEW KINGSTON, PA 17072-1001
Plaintiff,
vs.
BRYCE W. THOMPSON
AMY L. THOMPSON
6 CLOVER LANE
MECHANICSBURG, PA 17050
PARCEL# 38-21-0291-012
Defendants.
IMPORTANT NOTICE
TO: Amy L. Thompson
6 Clover Lane
Mechanicsburg, PA 17050
DATE OF NOTICE: February 20, 2007
CIVIL DNISION
No.: 07-0218 Civil Term
No.: 06-3712 MLD
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE
ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY
OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THI5 NOTICE TO YOUR LAWYER AT
ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Phone (717) 249-3166
Phone (800) 990-9108
t f
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY
31 E. MAIN STREET, P.O. BOX 1001
NEW KINGSTON, PA 17072-1001
Plaintiff,
vs.
BRYCE W. THOMPSON
AMY L. THOMPSON
6 CLOVER LANE
MECHANICSBURG, PA 17050
PARCEL# 3 8-21-0291-012
Defendants.
AVISO IMPORTANTE
A. Amy L. Thompson
FECHA DEL AVISO:
February 20, 2007
CIVIL DIVISION
No.: 07-0218 Civil Term
No.: 06-3712 MLD
USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION
REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS
PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN
CONTRA SUYA SIN LLEVARSE A CABO UNA. VISTA Y USTED PUEDE PERDER SU
PROPIEDAD Y OTROS DERECHOS IlVIPORTANTES. USTED DEBE LLEVAR ESTE
DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO O
NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA ABAJO INDICADA PARR QUE LE
INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Phone (717) 249-3166
Phone (S00) 990-91Q~8 ~
& CONNELLY, LLP
DATE: ~ v ~
BY: ~
Scott A. ie eric
PA I.D. # 5650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
FIRST CLASS U.S. MAIL, POSTAGE PREPAID
~• CASE N0: 2007-00218
SH~RI~'F~' S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SILVER SPRING TOWNSHIP AUTHORI
VS
THOMPSON BRYCE W ET AL
STEPHEN BENDER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF SCIRE FACIAS was served upon
THOMPSON AMY L the
DEFENDANT at 1940:00 HOURS, on the 30th day of January , 2007
at 6 CLOVER LANE
MECHANICSBURG, PA 17050
BRYCE THOMPSON
by handing to
ADULT IN CHARGE
a true and attested copy of WRIT OF SCIRE FACIAS together .with
and at the same time directing His attention to the contents thereof.
Sheriff ' s Costs :
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
Sworn and Subscibed to
before me this day
So Answers:
R. Thomas Kline
01/31/2007
JAMES SMITH DIETTERICK CONNELL
By.
D putt' Sheriff
of A.D.
'~
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY:
31 E. MAIN STREET, P.O. BOX 1001
NEW KINGSTON, PA 17072-1001
Plaintiff,
vs.
BRYCE W. THOMPSON
AMY L. THOMPSON
6 CLOVER LANE .
MECHANICSBURG, PA 17050
PARCEL# 39-21-0291-0 l 2
Defendants.:
CIVIL DIVISION
NO.: 07-0218 Civil Term
NO.: 06-3712 MLD
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: Bryce W. Thompson
( )Plaintiff
(X) Defendant
( )Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on ~,~, ~ , 2007.
( ) A copy of the Order or Decree is enclosed,
or
(X) The judgment is as follows: $4,250.10
plus interest, penalties, and Quarterly bills after the 1St Quarter of 2006, plus additional attorneys'
fees and costs reasonable and actually incurred and for foreclosure and sale of the Premises.
P othonotary
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY:
31 E. MAIN STREET, P.O. BOX 1001
NEW KINGSTON, PA 17072-1001
Plaintiff,
vs.
BRYCE W. THOMPSON
AMY L. THOMPSON
6 CLOVER LANE :
MECHANICSBURG, PA 17050
PARCEL# 39-21-0291-012
Defendants.:
CIVIL DIVISION
NO.: 07-0218 Civil Term
NO.: 06-3712 MLD
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: Amy L. Thompson
( )Plaintiff
(X) Defendant
( )Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on ,~~~,,_ ~ , 2007.
( ) A copy of the Order or Decree is enclosed,
or
(X) The judgment is as follows: $4,250.10
plus interest, penalties, and Quarterly bills after the 1St Quarter of 2006, plus additional attorneys'
fees and costs reasonable and actually incurred and for foreclosure and sale of the Premises.
Pr thonotary
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY CNIL DNISION
31 E. MAIN STREET, P.O. BOX 1001
NEW KINGSTON, PA 17072-1001
Plaintiff, No.:Dl.,37~eZ' MLD
Vs.
BRYCE W. THOMPSON
AMY L. THOMPSON
6 CLOVER LANE.
MECHANICSBURG, PA 17050
PARCEL# 38-21-0291-012
Defendants.
MUNICIPAL CLAIM FOR SEWER RATES
TO:PROTHONOTARY
SIR/MADAM:
Silver Spring Township Authority, Cumberland County, Pennsylvania, by its attorneys
JAMES, SMITH, DIETTERICK & CONNELLY, LLP, hereby files its claim for the sewer rate
chazged against the real estate hereinafter described, located in Silver Spring Township,
Cumberland County, Pennsylvania, and sets forth its claim as follows:
Statement of Claim
The name of the municipality by which this claim is filed is Silver Spring
Township Authority.
2. The Authority under and by virtue of which this sewer rate was chazged is as
follows: (a) Section 4 of the Act of 1945, P.L. 382, 53 P.S. §306, Municipalities
Authorities Act of 1945, as amended; and (b) Resolution of Silver Spring
Township Authority, adopted December 11, 1991, establishing the sewer rates
and regulations of Silver Spring Township Authority for the sewer system for the
Township of Silver Spring, and authorizing the collection and enforcement of
sewer rates in this manner prescribed by law.
3. All acts, conditions, events and things required to be done by Silver Spring
Township Authority under the Acts of Assembly of the Commonwealth of
Pennsylvania have been done and performed in due and legal form so as to entitle
Silver Spring Township Authority to a lien for the payment of the sewer rates for
which this claim is filed.
4. The name of the owner(s) or reputed owner(s), of the property against which this
claim is filed, aze Bryce W. Thompson and Amy L. Thompson.
5. The property against which this claim is filed is known and numbered as 6 Clover
Lane, Silver Spring Township, Mechanicsburg, Cumberland County,
Pennsylvania 17050.
6. This sewer rate was charged for sewer service furnished to the above-described
property, the sewer lines which services same being installed in 1979 and the
sewer rate being charged for the period commencing April 1, 2005 to and
including the present.
Rental, Penalties, Interest, Collection Fee and Costs
AS OF June 15, 2006
Sewer Rents through ls` Quarter 2006 $ 920.75
Penalties through December 6, 2006 $ 89.35
Attorney' Fees $ 1,000.00
Court Costs and Fees $ 2,240.00
TOTAL: $ 4,250.10
Plus additional attorneys' fees and costs incurred by Silver Spring Township Authority in
collection of the above claim in accordance with the attached fee schedule authorized by
Resolution of Silver Spring Township Authority.
7. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq.
(1977), Defendant(s) may dispute the validity of the debt or any portion thereof.
If Defendant(s) does so in writing within thirty (30) days of receipt of this
pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written
verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if
requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff
will send Defendant(s) the name and address of the original creditor if different
from above.
Payment of the above claim not having been made, enter the same in the proper
Municipal Lien Docket and Judgment Index.
JAMES, SMITH, DIETTERICK &
CONNELLY,LLP
By:
Scott A. quire
Attorney for Plaintiff
PA I.D. #55650
P:O. Box 650
Hershey, PA 17033
(717) 533-3280
J
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORTTY CNIL DNISION
31 E. MAIN STREET, P.O. BOX 1001
NEW KINGSTON, PA 17072-1001
Plaintiff, No.: MLD
Vs.
BRYCE W.THOMPSON
AMY L. THOMPSON
6 CLOVER LANE.
MECHANICSBURG, PA 17050
PARCEL# 38-21-0291-012
Defendants.
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the Municipal Claim for Sewer
Rents was served on the following this ~ day of June, 2006, via First Class U. S. Mail, Postage Pre-
paid:
Bryce W. Thompson
Amy L. Thompson
6 Clover Lane
Mechanicsburg, PA 17050
Respectfully Submitted:
JAMES, SMITH, DIETTERICK & CONNELLY, LLP
Scott 1!r/Dietterick, E
Attorney I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
SILVER SPRING TOWNSIiIP AUTHORITY
CUMBERLAND COUNTY, PENNSYLVANIA
RESOLUTION NO. A-2005-03
A RESOLUTION APPROVING COLLECTION PROCEDURES AND
ADOPTING A SCHEDULE OF ATTORNEY FEES TO BE ADDED TO
THE AMOUNT COLLECTED AS PART OF MUNICIPAL CLAIMS
FOR DELINQUENT SANITARY SEWER ACCOUNTS.
WHERI=:AS, [o be fair to all rate payers of the Silver Spring Township Authority (the
"Authority"), it is necessary for the Authority to recover promptly the amount of delinquent and
other municipal chazges, and if necessary, through legal processing; and
WHEREAS, in the past the an~ount recovered in such proceedings has been depleted by
the cost of reasonable attorney fees incurred by the Authority in the proceedings, thereby
making, in the case of smaller claims, enforcement not financially feasible; and
WHEREAS, the General Assembly of Pennsylvania has recently enacted, as an
amendment to the Municipal Claims Act, Act No. 1 of 1996 (the "Act"), which authorizes the
adding of the amount of reasonable attorney fees and costs the total payable with respect to
unpaid taxes and other municipal claims, but only if the municipality involved has approved by
resolution a schedule of reasonable attorney fees; and
WHEREAS, the Authority has determined that it is in the best interest of all the rate
payers to have vigorous enforcement of all delinquent and other unpaid charges, utilizing the
procedures set forth in the Act; and
WHEREAS, the Authority has reviewed the subject of attorney fees for collection
matters, and has determined that the fees set forth in the schedule hereby adopted are reasonable
in amount for the services herein described:
NOW THEREFORE, IT IS HEREBY ORDAINED AND ENACTED by the Board of
the Silver Springs Township Authority as Follows:
1. Schedule of Fees.
(a) The Authority hereby approves the following schedule of attorney fees for
services in connection with the collection of Accounts, which is hereby
determined to be fair and reasonable compensation for the services set forth
below, all in accordance with the principals set forth in Section 3 (a.l) of the
Municipal Claims Law as amended by Act No. 1 of 1996 (the "Act"):
Legal Services Fee For Services
Initial Review and send first demand $ 250.00
Letter b't Title t+eport
File lien and send second demand letter; $ 500,00
Prepaze Writ of Scire Facias, File Writ
Service of Writ by Sheriff
Prepare and mail letter under Pa. R. C. P. § 237.01; $ 350.00
Prepare Entry of Judgment, Notices,
Pleadings and Affidavits
Prepaze Writ of Execution; $2,100.00
Attendance at Sale; Review Schedule
Of Distribution and Resolve Distribution Issues
Services nat covered above;
Satisfaction of Municipal Lien $ 40.00
Satisfaction of Judgment $ 40.00
Review of Banlauptcy (including Proof of Claim) $ 250.00
Motion for Relief from the Automatic Stay $ 700.00
Motion for Special Service $ 450.00
Petition to Reassess Damages $ 275.00
Forbearance Agreement $ 200.00
Al( other services $ 125,00 per hour
(b) The above amounts include an estimate of the reasonable out-of-pocket
expenses of counsel in connection with each of these services, as itemized in
the applicabie counsel bills, which shall be deemed to be part of the fees,
(c) The amount of fees determined, as set forth above shall be added ro the
Authority's claim in each account.
2, Collection Procedures. The following collection procedures aze hereby established
in accordance with Act No. 1:
(a) At ]east thirty (30) days prior to assessing or imposing attorney fees itt
connection with the collection of an Account, the Authority shall mai[ or
cause to be mailed, by certified mail, return receipt requested, a notice of such
intention to the rate payer or other entity liable for the Account (the '`Account
Debtor")
(b) If within thirty (30) days after mailing the notice in accordance with
subsection (a), the certified mail to an Account Debtor is refused or
unclaimed or the return receipt is not received, then at least ten (10) days prior
to the assessing or imposing such attorney fees, the Authotry shall mail or
cause to be mailed, by first class mail, a second notice to such Account
Debtor.
(c) AlI notices required by this Resolution shall be mailed to the Account
Debtor's last known post office address as recorded in the records or other
information of the Authority, or such other address as it may be able to obtain
from the County Office of Assessment and Revision of Taxes,
(d) Each notice as described above shall include the foilowing:
(i) The Type of tax or other charge, the date it became due and the .
amount owed, including penalty and interest;
(ii) ~ A statement of the Authority's intent to impose or assess attorney
fees within thirty (30) days after the mailing of the first notice, or
within ten (10) days after the mailing of the second notice;
(iii) The manner' in which the assessment or imposition of attorney fees
may be avoided by payment of the Account; and
(rv). The place of payment for the Accounts and the name and
telephone number of the Authority official designated as
responsible for the collection matter.
3. Related Action. The proper offtciats of the Authority are hereby aufhorized and
empowered to take such additional action"as they may deem necessary or appropriate
to implement this Resolution,
DULY ADOPTED By the Boazd the Silver Spring Townslup Authority on ov LMb~~
Zt tr ,2005.
ATTEST:
S retary
SILVER SPRING TOWNSHIP AUTHORITY
By. ~ -
Chairperson
r ~,
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e ~ ~ z-.,
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` IN THE COURT OF C~M~DN PLEAS OF CiMBERI.ArID CO[JNi'Y, PEI~CLVANIA
Silver Spring Township Authority CIVIL DIVISION
31 E. Main Street, P.O. Box 1001 ; File No.07-0218 Civil Term 06-3712 MLD
New Kingston, PA 17072-1001
(Plaintiff)
v
Bryce W. Thompson and Amy L. Thompson
6 Clover Lane
Mechanicsburg, PA 17050
{Defendant(s)
TO THE PROTHONOTARY OF THE SAID COURT:
Amount Due $ 4,25_0.10
Interest fromanio~~6^iPe~~umto .$ 103.88
date of sa e
At ty' s Comm 1 s% $ 653.10
C05tS Judgment, Writ, Sheriff Advance $ 1 53$,00
$ 6,545.08
The undersigned hereby certifies that the below does not arise out of a retail
installment sale, contract, or account based on a confession of judgment, but if it does,
it-is based vn the appropriate original proceeding filed pursuant to Act 7 of 1966 as
amended; and for real property pursuant to Act 6 of 1974 as amended.
PRAECIPE FUR F~CitI'ION
Issue writ of execution in the above matter to the Sheriff of Cumberland
County, for debt, interest and costs upon the following described property of the
defendants}
See Exhibit "A" attached.
PRAECIPE FUR ARTACFME~IT E?~fI'ION
Issue writ of attachment to the Sheriff of Cumberland County, for debt,
interest and costs, as a.Mbove, directing attachment against the above-named garnishee(s) for
the following property (if real estate, supply six copies of the description; supply four
copies of lengthy personalty list)
6 Clover Lane. Mechanicsburg, PA 17050
and all other property of the defendants} in the possession, custody or control of the
said garnishees}.
(Indicate} Index this writ against the garnishee(
real estate of the defendant(s) described in the attached exr
DAB; May 2, 2007
Signature:
Print Name:
Address: James Smith Dietterick & Connelly LLP
F O Box 650, Hershey PA 17033
Attorney for: Plaintiff
TOTAL
Telephone: (717) 533-3280
Supreme Court ID No.: 55650
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LEGAL DESCRIPTION
ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in
the Township of Silver Spring in the County of Cumberland and Commonwealth of
Pennsylvania, more particularly described as follows, to wit:
BEING Lot No. 32, Section C of Shady Acres Plan, which Plan is recorded in the Office
of the Recorder of Deeds of Cumberland County, in Plan Book 19, Page 58, having a frontage
along Clover Lane of 149.78 feet, a depth along the West along Lot No. 33 of Section C of
160.09 feet, a width along South along Lot No. 9 of Section A of 40.09 feet and a depth along
East of 202.86 feet.
BEING improved with a dwelling house known as 6 Clover Lane, Mechanicsburg,
Pennsylvania.
BEING the same premises which Balwinder Singh and Kulwant Kaur, husband and wife,
by Deed dated March 3, 2005 and recorded on March 11, 2005 in the Office of the Recorder of
Deeds in and for Cumberland County, Pennsylvania, in Deed Book 267, Page 4454, granted and
conveyed unto Bryce W. Thompson and Amy L. Thompson, husband and wife.
Parcel No.: 39-21-0291-012
Exhibit "A"
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-218 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff (s)
From BRYCE W. THOMPSON AND AMY L. THOMPSON
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $4,250.10
L.L. $.50
Interest FROM 3/7/07 TO DATE OF SALE @ 6% PER ANNUM - $103.88
Atty's Comm 15 % $653.10
Atty Paid $109.18
Plaintiff Paid
Date: MAY 4, 2007
(Seal)
REQUESTING PARTY:
Due Prothy $2.00
Other Costs
C s R. Lon not
By:
Deputy
Name SCOTT A. DIETTERICK, ESQUIRE
Address: JAMES SMITH DIETTERICK & CONNELLY LLP
P O BOX 650
HERSHEY, PA 17033
Attorney for: PLAINTIFF
Telephone: 717-533-3280
Supreme Court ID No. 55650
i
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY; PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY:
31 E. MAIN STREET, P.O. BOX 1001
NEW KINGSTON, PA 17072-1001
Plaintiff,
vs. .
BRYCE W. THOMPSON
AMY L. THOMPSON
6 CLOVER LANE
MECHANICSBURG, PA 17050
PARCEL# 39-21-0291-012
Defendant.
CIVIL DIVISION
NO.: 07-0218 Civil Term
NO.: 06-3712 MLD
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Amy L. Thompson
6 Clover Lane
Mechanicsburg, PA 17050
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland
County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday,
September 5, 2007, at 10:00 a.m. prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting
of a statement of the measured boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The LOCATION of your property to be sold is:
6 Clover Lane
Mechanicsburg, PA 17050
Cumberland County
The JUDGMENT under or pursuant to which your property is being sold is docketed to:
No. 07-0218 Civil Term No. 06-3712 MLD
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Bryce W. Thompson and Amy L. Thompson
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received
and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities
that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone
objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about
the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of
Cumberland County, South Hanover Street, Carlisle, Pennsylvania 17013.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF I'~OUR
PROPERTY.
It has been issued because there is a Judgment against you. It may cause your property to
be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your
property from being taken. A lawyer can advise you more specifically of these rights. If you
wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
(800) 990-9108
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of Cumberland
County to open the Judgment if you have a meritorious defense against the person
or company that has entered judgment against you. You may also file a petition
with the same Court if you are aware of a legal defect in the obligation or the
procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of Common
Pleas of Cumberland County to set aside the sale for a grossly inadequate price or
for other proper cause. This petition must be filed before the Sheriffs Deed is
delivered.
3. A petition or petitions raising the legal issues or rights mentioned in the
preceding pazagraphs must be presented to the Court of Common Pleas of
Cumberland County. The petition must be served on the attorney for the creditor
or on the creditor before presentation to the Court and a proposed order or rule
must be attached to the petition. If a specific return date is desired, such date
must be obtained from the Court Administrator's Office, Cumberland County
Courthouse, One Courthouse Square, 4th Floor, Cazlisle, Pennsylvania 17013,
before presentation of the petition to the Court.
JAMES,
DATED: ~ ?' ®~ BY:
IETTERICK & CONNELLY, LLP
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
VIA CERTFIED MAIL, RETURN RECEIPT REQUESTED
AND
VIA PERSONAL SERVICE BY CUMBERLAND COUNTY SHERIFF
Pa. I.D. #55650
Attorneys for Plaintiff
LEGAL DESCRIPTION
ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in
the Township of Silver Spring in the County of Cumberland and Commonwealth of
Pennsylvania, more particularly described as follows, to wit:
BEING Lot No. 32, Section C of Shady Acres Plan, which Plan is recorded in the Office
of the Recorder of Deeds of Cumberland County, in Plan Book 19, Page 58, having a frontage
along Clover Lane of 149.78 feet, a depth along the West along Lot No. 33 of Section C of
160.09 feet, a width along South along Lot No. 9 of Section A of 40.09 feet and a depth along
East of 202.86 feet.
BEING improved with a dwelling house known as 6 Clover Lane, Mechanicsburg,
Pennsylvania.
BEING the same premises which Balwinder Singh and Kulwant Kaur, husband and wife,
by Deed dated March 3, 2005 and recorded on March 11, 2005 in the Office of the Recorder of
Deeds in and for Cumberland County, Pennsylvania, in Deed Book 267, Page 4454, granted and
conveyed unto Bryce W. Thompson and Amy L. Thompson, husband and wife.
Parcel No.: 39-21-0291-012
Exhibit "A"
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
SII,VER SPRING TOWNSHIP AUTHORITY:
31 E. MAIN STREET, P.O. BOX 1001
NEW KINGSTON, PA 17072-1001
Plaintiff,
vs. .
BRYCE W. THOMPSON .
AMY L. THOMPSON
6 CLOVER LANE :
MECHANICSBURG, PA 17050
PARCEL# 3 9-21-0291-0 l 2
Defendant.
CIVIL DIVISION
NO.: 07-0218 Civil Term
NO.: 06-3712 MLD
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Bryce W. Thompson
6 Clover Lane
Mechanicsburg, PA 17050
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland
County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday,
September 5, 2007, at 10:00 a.m. prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting
of a statement of the measured boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIl'TION ATTACHED AS EXHIBIT "A").
The LOCATION of your property to be sold is:
6 Clover Lane
Mechanicsburg, PA 17050
Cumberland County
The JUDGMENT under or pursuant to which your property is being sold is docketed to:
No. 07-0218 Civil Term No. 06-3712 MLD
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Bryce W. Thompson and Amy L. Thompson
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received
and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities
that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone
objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about
the Schedule of Distribution maybe obtained from the Sheriff of the Court of Common Pleas of
Cumberland County, South Hanover Street, Carlisle, Pennsylvania 17013.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PROPERTY.
It has been issued because there is a Judgment against you. It may cause your property to
be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your
property from being taken. A lawyer can advise you more specifically of these rights. If you
wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
(800) 990-9108
r
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of Cumberland
County to open the Judgment if you have a meritorious defense against the person
or company that has entered judgment against you. You may also file a petition
with the same Court if you are aware of a legal defect in the obligation or the
procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of Common
Pleas of Cumberland County to set aside the sale for a grossly inadequate price or
for other proper cause. This petition must be filed before the Sheriff s Deed is
delivered.
3. A petition or petitions raising the legal issues or rights mentioned in the
preceding paragraphs must be presented to the Court of Common Pleas of
Cumberland County. The petition must be served on the attorney for the creditor
or on the creditor before presentation to the Court and a proposed order or rule
must be attached to the petition. If a specific return date is desired, such date
must be obtained from the Court Administrator's Office, Cumberland County
Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013,
before presentation of the petition to the Court.
JAMES, SMITI~, I~TTERIC~ B~CONNELLY, LLP
.-, <` ,.~
DATED: ~~~~ ~ BY:
Sco A: Di
Pa. I.D. #SS6S0
Attorneys for Plaintiff
P.O. BQX 6S0
Hershey, PA 17033
(717) 533-3280
VIA CERTFIED MAIL, RETURN RECEIPT REQUESTED
AND
VIA PERSONAL SERVICE BY CUMBERLAND COUNTY SHERIFF
LEGAL DESCRIPTION
ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in
the Township of Silver Spring in the County of Cumberland and Commonwealth of
Pennsylvania, more particularly described as follows, to wit:
BEING Lot No. 32, Section C of Shady Acres Plan, which Plan is recorded in the Office
of the Recorder of Deeds of Cumberland County, in Plan Book 19, Page 58, having a frontage
along Clover Lane of 149.78 feet, a depth along the West along Lot No. 33 of Section C of
160.09 feet, a width along South along Lot No. 9 of Section A of 40.09 feet and a depth along
East of 202.86 feet.
BEING improved with a dwelling house known as 6 Clover Lane, Mechanicsburg,
Pennsylvania.
BEING the same premises which Balwinder Singh and Kulwant Kaur, husband and wife,
by Deed dated March 3, 2005 and recorded on March 11, 2005 in the Office of the Recorder of
Deeds in and for Cumberland County, Pennsylvania, in Deed Book 267, Page 4454, granted and
conveyed unto Bryce W. Thompson and Amy L. Thompson, husband and wife.
Parcel No.: 39-21-0291-012
Ezhibit "A"
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1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY:
31 E. MAIN STREET, P.O. BOX 1001
NEW KINGSTON, PA 17072-1001
Plaintiff,
vs.
BRYCE W. THOMPSON
AMY L. THOMPSON
6 CLOVER LANE
MECHANICSBURG, PA 17050
PARCEL# 39-21-0291-012
Defendant.
CIVIL DIVISION
NO.: 07-0218 Civil Term
NO.: 06-3712 MLD
AFFIDAVIT PURSUANT TO RULE 3129.1
Silver Spring Township Authority, Plaintiff in the above action, sets forth as of the date
the Praecipe for Writ of Execution was filed the following informaXion concerning the real
property located at 6 Clover Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050:
1. Name and Address of Owner(s) or Reputed Owner(s):
BRYCE W. THOMPSON 6 Clover Lane
AMY L. THOMPSON Mechanicsburg, PA 17050
2. Name and Address of Defendant(s) in the Judgment:
BRYCE W. THOMPSON 6 Clover Lane
AMY L. THOMPSON Mechanicsburg, PA 17050
3. Name and Address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
SILVER SPRING TOWNSHIP AUTHORITY
Plaintiff
4. Name and Address of the last record holder of every mortgage of record:
MERS nominee for P.O. Box 660694
AMERICA'S WHOLESALE LENDER Dallas, TX 75266
AMERICA'S WHOLESALE LENDER 4500 Park Granada
Calabasas, CA 91302
5. Name and Address of every other person who has any record lien on the property:
MORTGAGE ELECTRONIC REGISTRATION 8201 Greensboro Drive
SYSTEMS, INC. Suite 350, Mclean, VA 22102
6. Name and Address of every other person who has any record interest in the
property and whose interest maybe affected by the sale:
CUMBERLAND COUNTY
TAX CLAIM BUREAU
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
7. Name and Address of every other person of whom the Plaintiff has knowledge
who has any interest in the property which maybe affected by the sale:
CUMBERLAND COUNTY DOMESTIC
RELATIONS OFFICE
PA DEPT. OF REVENUE
COMMONWEALTH OF PA
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
PA Inheritance Tax Division
Dept. 280601
Harrisburg, PA 17128-0601
PA Dept. of Welfare
P.O. Box 2675
Harrisburg, PA 17105
I verify that the statements made in this Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
DATED:
JAMES,
BY:
Scott A. Dietterick, Esq
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
& CONNELLY, LLP
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LEGAL DESCRIPTION
ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in
the Township of Silver Spring in the County of Cumberland and Commonwealth of
Pennsylvania, more particularly described as follows, to wit:
BEING Lot No. 32, Section C of Shady Acres Plan, which Plan is recorded in the Office
of the Recorder of Deeds of Cumberland County, in Plan Book 19, Page 58, having a frontage
along Clover Lane of 149.78 feet, a depth along the West along Lot No. 33 of Section C of
160.09 feet, a width along South along Lot No. 9 of Section A of 40.09 feet and a depth along
East of 202.86 feet.
BEING improved with a dwelling house known as 6 Clover Lane, Mechanicsburg,
Pennsylvania.
BEING the same premises which Balwinder Singh and Kulwant Kaur, husband and wife,
by Deed dated March 3, 2005 and recorded on March 11, 2005 in the Office of the Recorder of
Deeds in and for Cumberland County, Pennsylvania, in Deed Book 267, Page 4454, granted and
conveyed unto Bryce W. Thompson and Amy L. Thompson, husband and wife.
Parcel No.: 39-21-0291-012
Exhibit "A"
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