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Home My WebLink About02-3407 JUL18 O02 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EESCO, a division of WESCO DISTRIBUTION, INC., Claimant, VS. ATLAS ENERGY PRODUCTS, Owner or Reputed Owner, GEOENERGY INTERNATIONAL, CIVIL DIVISION No. STATEMENT OF MECHANIC'S LIEN CLAIM CODE 060 Con,actor. PROPERTY LOCATION: 817 Spangler Road Camp Hill, PA 17011 Parcel No. 01-22-0535-098 FILED ON BEHALF OF Claimant COUNSEL OF RECORD OF THIS PARTY: NICHOLAS D. KRAWEC, ESQUIRE PA I.D. #38527 Bemstein Law Finn, P.C. Finn #718 1133 Penn Avenue Pittsburgh, PA 15222 412-456-8100 BERNSTEIN FILE NO. G0019238 DIRECT DIAL: (412)456-8103 MEK004207V001 7/9/2002 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION EESCO, a division of WESCO DISTRIBUTION, INC., Claimant, VS. ATLAS ENERGY PRODUCTS, Civil Action No. Owner or Reputed Owner, VS. GEOENERGY INTERNATIONAL, Contractor. STATEMENT OF MECHANIC'S LIEN CLAIM AND NOW comes EESCO, a division of WESCO Distribution, Inc., by counsel, Bemstein Law Firm, P.C., and files this Statement of Mechanic's Lien Claim as a material supplier to a contractor, pursuant to the Mechanic's Lien Law of 1963, 49 P.S. Section 1101 et. seq., against the premises herein described, any and all buildings erected thereupon and the curtilage appurtenant thereto, for the payment of $5,960.15, together with interest from April 19, 2002, due it as a material supplier to the contractor under the contract herein described. The following is a statement of its claim: 1. Claimant is a corporation organized and existing under the laws of Illinois with a place of business located at 2869 Eastrock Drive, Rockford, IL 61109. 2. Owner is Atlas Energy Products, a business corporation organized and existing under the laws of Pennsylvania, with offices located at 817 Spangler Road, Camp Hill, PA 17011. MEK004207V001 7/9/2002 4. This claim relates to materials and labor provided by Claimant as a material supplier to Contractor upon the premises designated at 817 Spangler Road, Camp Hill, Cumberland County, Pennsylvania, situate in the Borough of Camp Hill, being more fully described in the Deed conveying said premises to Owner, recorded in the Office of the Cumberland County Recorder of Deeds at Deed Book Volume 34A, Page 538. 5. Between February 22, 2002, and March 18, 2002, Claimant, pursuant to a contract with Contractor, agreed to furnish and install electrical components for new construction at the premises above described. Tree and c°rrect c°pies °f the invoices describing the labor and materials supplied by Claimant to said premises are attached hereto, marked Exhibits "1" and "2" and made a part hereof. 18,2002. Claimant last supplied materials and labor to the above-described premises on or about March 7. The materials and labor supplied were utilized in the new construction at the above-described premises and were free from defect and were in accordance with Claimant's agreement with Contractor. 8. The total amount claimed by Claimant to be due is $5,960.15, together with interest from April 19, 2002, for materials and labor provided in connection with the agreement to provide construction materials to Contractor upon the premises above described. 9. Formal Notice of Claimant's Intention to File Mechanic's Lien Claim was mailed to Owner on June 17, 2002, by certified mail, return receipt requested, and served upon Owner on or about June 19, 2002. A true and correct copy of Claimant's Formal Notice of Intention to File Mechanic's Lien Claim, dated June 17, 2002, and the receipt for certified mail and domestic return receipt evidencing service of said Notice, are attached hereto, collectively marked Exhibit "3", and made a part hereof. MEK004207V001 6/26/2002 10. This lien is claimed against the premises designated as 817 Spangler Road, Camp Hill, Cumberland County, Pennsylvania 17011, situate in the Borough of Camp Hill. Dated: BERNSTEIN LAW FIRM, P.C. Attorneys for Claimant Pa. ID No. 38527 1133 Penn Avenue Pittsburgh, PA 15222 BERNSTEIN FILE NO. G0019238 MEK004207V001 6/26/2002 ~0 Or" O~ o -~0 Or-. JOSEPH J. BERNSTEIN (PA, FL) ROBERTS. BERNSTEtN (PA. FL, VVV, NY) NICHOLAS D. KRAWEC (PA. NC, OH) LORI A. GIBSON (PA) BERNSTEIN [.AW FIRM~ P.C. MARLENE J. BERNSTEIN (PA, FL) CHARLES E. BOBINIS (PA. WV) JON A. MCKECBNIE (pA) EDWARD S. WEHBENBERG (pA) (STATES OF ADMISSION) Atlas Energy Products 817 Spangler Road Camp Hill, PA 17011 June 17, 2002 CERTIFIED MAII, Re: EESCO, a division of WESCO Distribution, Inc. Contractor: Geoenergy International Project: 817 Spangler Road Camp Hill, PA 17011 FORMAL NOTICE OF INTENTION TO FILE MECHANIC'S LIEN CLAIM Gentlemen: This office represents EESCO, a division of WESCO Distribution, Inc., a supplier of electrical components to Geoenergy International., the prime contractor on the construction job at 817 Spangler Road, Camp Hill, Cumberland County, PA. The last date on welch materials were supplied to 817 Spangler Road job was March 18, 2002. There remains an unpaid balance due from Atlas Roofing Corp. in the amount of $5,960.15 for that material. Please consider this letter your notice under the Pennsylvania Mechanic's Lien Law, 49 P.S. §1 i01 et. seq. that if payment of said amount is not made in full to EESCO within thirty days of the date of this notice, it is EESCO's intention to file a Mechanic's Lien Claim against the building and real estate at 817 Spangler Road, Camp Hill, Cumberland County, PA 17011, as fully described in Deed Book Volume 34A, Page 538 in the Recorder of Deeds Office of Cumberland County, Pennsylvania. If you have any questions regarding this notice, please contact the undersigned. Very truly yours, BERNSTEIN LAW FIRM, P.C. CCi NDKOOI093VO01 EESCO 2869 Eastrock Drive Rockford, IL 61109 Attn: Tom McMahon Nicholas D. Krawec DIRECT DIAL: (412) 456-8103 FILE COPY rvu! tI..3.. 1133 PEN N AVENUE. Pf~-YSBURGH, PEN NSYLVANIA 15222-4252 1-80(~927-3197 412-456~ 100 FAX 412-456-8135 WWVE.BERNSTEIN LAW.C OM MAIL~B ER NSTEI N LAW.C O M OFFICIAL USE Hate r~ · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · JPrint your name and address on the reverSe lso tha~ we can return the card to-you. ' - Il-Attach this card to the back of the mailpiec~, w or on the fl'ont if space permits. 2. A B. D~e of Delivery If YES, enter delivery address below: 3. Service Type i~Certified Mail [] Express Mail [:] Registered [:]~'Return Receipt for Merchandise [] Insured Mail [] C.O.D. 4. Restricted Delivery? (Extra Fee) [] Yes 7002 0460 0001 3360 0349 VERIFICATION The undersigned does hereby verify under penalty of perjury, that he/she is the ~of ~.<SF_~): enc~ LO~:$(-,OClaimant herein, tlfi. t he/she is duly authorized to make this Verification and that the facts set forth in the foregoing STATEMENT OF MECHANIC'S LIEN CLAIM are true and correct to the best of his/her knowledge, information and belief. (Sign in Blue Ink) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION EESCO, a division of WESCO DISTRIBUTION, INC., Claimant, VS. ATLAS ENERGY PRODUCTS, Owner or Reputed Owner, VS. GEOENERGY INTERNATIONAL, Contractor. Civil Action No. 02-3407 MLP AFFIDAVIT OF SERVICE Before me, the undersigned authority, personally appeared Jon A. McKechnie, who being duly sworn according to laws deposes and says as follows: 1. That he is an attorney for the Claimant authorized to make the Affidavit. 2. Service was made on the 22na day of July, 2002, as evidenced by a copy of the Sheriffs return attached hereto and marked Exhibit "A," by served upon Owners herein, the notice of filing of Mechanic's Lien Claim, specifying the Court, term, number and date of filing of the Statement of Mechanic's Lien Claim, and a true and correct copy of the Statement of Mechanids Lien Claim. Sworn to and subscribed before me this ~ day of ~ ,2002. 0 Notar~ublic ' 0 SHERIFF'S RETURN - REGULAR CASE NO: 2002-03407 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND EESCO A DIV OF WESCO DISTRIBUT VS ATLAS ENERGY PRODUCTS CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within MECHANICS LIEN CLAIM was served upon ATLAS ENERGY PRODUCTS the OWNER , at 1420:00 HOURS, on the 22nd day of July at 817 SPANGLER RD , 2002 CAMP HILL, PA 17011 BERNARD PARK by handing to a true and attested copy of MECHANICS LIEN CLAIM together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this day of A.D. Prothonotary So Answers: R. Thomas Kline 07/24/2002 BERNSTEIN BERNSTEIN KRAWEC ~ep~ty SherlfX SHERIFF'S RETURN - CASE NO: 2002-03407 P COMMONWEALTH OF PEN-NSYLVA-NIA: COUNTY OF CUMBERLJ~ND EESCO A DIV OF WESCO DISTRIBUT VS ATLAS ENERGY PRODUCTS REGULAR CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to says, the within MECHANICS LIEN CLAIM was served upon ATLAS ENERGY PRODUCTS the OWNER at 1420:00 HOURS, on the 22nd day of July , 2002 at 817 SPANGLER RD CAMP HILL, PA 17011 BERNARD PARK by handing to a true and attested copy of MECHANICS LIEN CLAIM together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this 2~,~ day of ~P~othonotary ~ So Answers: R. Thomas Kline 07/24/2002 BERNSTEIN BERNSTEIN KRAWEC p~ty Sne'rif~/ EESCO, A DIVISION OF WESCO DISTRIBUTION, INC., Claimant ATLAS ENERGY PRODUCTS, Owner or Reputed Owner, GEOENERGY INTERNATIONAL, Contractor IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3407 MLD CIVIL ACTION - LAW ENTRY OF APPEARANCE TO THE pROTHONOTARY: Please enter the appearance ofP. Kevin Brobson, Esquire, at the addresses listed below as counsel to Owner Atlas Energy Products in the above-captioned matter. BUCHANAN INGERSOLL PROFESSIONAL CORPORATION P. Kevin Brobson Attorney I.D. #76693 One South Market Square 213 Market Street, Third Floor Harrisburg, PA 17101 (717) 237-4845 DATED: August 21, 2002 CERTIFICATE OF SERVICE I, P. Kevin Brobson, hereby certify that I am this day serving a copy of the foregoing document upon the person listed below by United States Mail, postage pre-paid, first class, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure: Nicholas D. Krawec, Esquire Bemstein Law Firm, P.C. 1133 Penn Avenue Pittsburgh, PA 15222 By: ~ P. Kevin Brobson DATED: August 21, 2002