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HomeMy WebLinkAbout02-3599IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSH1P AUTHORITY 6415 (Rear) CARLISLE PIKE MECHANICSBURG, PA 17050 Plaintiff, Vs. ANDREW C. JONES MISHALA S. JONES 901 CEDAR ROAD MECHANICSBURG, PA 17050 PARCEL# 38-19-1612-042 Defendants. CIVIL DIVISION No.: ~ mD ~'~?-~ MUNICIPAL CLAIM FOR SEWER RATES TO: PROTHONOTARy SIR/MADAM: Silver Spring Township Authority, Cumberland County, Pennsylvania, by its attorneys JAMES, SMITH, DURKIN & CONNELLY LLP, hereby files its claim for the sewer rate charged against the real estate hereinafter described, located in Silver Spring Township, Cumberland County, Pennsylvania, and sets forth its claim as follows: Statement of Claim 1. The name of the municipality by which this claim is filed is Silver Spring Township Authority. The Authority under and by virtue of which this sewer rate was charged 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 Silx;er 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. 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 are Andrew C. Jones and Mishala S. Jones. Legal Services Lrfitial Review aid send first demand Letter & Title repoi~c Fee For Services $ 200.00 File !ien and send second demand letter; Prepa'e Writ of Sc/re Facias, File Writ Sm'vice of Writ by Sheriff $ 500.00 Prepm-e mid mail letter under Pa. R. C. P, § 237.0~; Prepa-e Entry of Judgment, Notices, Pleadings and Affidavits $ 350.00 Prepaa'e Writ of Execution; Attendance at Sale Review Schedule Or Distribution and Resolve Distribution Issues Sci'vices not covered above: $1,975.00 Satisfaction of Municipal Lien Sat/sfac/ion of Judgment Review of BazkruDtcy (including Proof of Claim Moticn fo' ReJJef h'om the Automatic Stay Motion tbr Special Service Petition to Reassess Damages Forbearance Agreement All other services $ 40.00 $ 40.00 $ 250.00 $ 625.00 $ q~O.O0 $ 275.00 $ 200.00 $ !25.00 per hotu: The above amounts include an estknate of the reasonable out-of-pocket expenses of co tinsel Ln connection with each of these services, as itemiz~ in the applicable counsci bills, whicll shal! be deemed to be pm't of the fees. The amotmt of f ' ecs determined, as set fon:h above skall be added to Autho ~t> s c,aml m each account. 2. Collection Procedures. The followin colic ', m accordance with Act No. 1: g cticn procedm-es a'e hereby established (a) At least thkty (30) days prior to assessing or imposJag attorney fbes m com~ection with the collection of an Account, the Authority shall maii or cause to be marled, by certified mail. retiwn receipt requested, a notice of such intention to the rate payer or other entity liable for the Accotmt (the "Account Debtor") IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY : 6415 (Rear) CARLISLE PIKE : MECHANICSBURG, PA 17050 : Plaintiff, : Vs. : ANDREW C. JONES MISHALA S. JONES 901 CEDAR ROAD IV[ECHANICSBURG, PA 17050 PARCEL# 38-19-1612-042 Defendants. CIVIL DIVISION No.: MLD CERTIFICATE OF SERVICE The undersigned hereby certifies that a tree and correct copy of the Municipal Claim for Sewer Rents was served on the following this ~2 day of ~ ,2002, via First Class U. S. Mail, Postage Pre-paid: Andrew S. lones Mishala S. Jones 901 Cedar Road Mechanicsburg, PA 17050 Respectfully [gu _b~nitted: JAMES,~ By: ? ~--~/ J r Scott ~. Dtett~O~, Esquire Attorney I.D.#55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 & CONNELLy LLP IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY 6415 (Rear) CARLISLE PIKE MECHANICSBURG, PA 17050 Plaintiff, Vs. ANDREW C. JONES MISHALA S. JONES 901 CEDAR ROAD MECHANICSBURG, PA 17050 PARCEL# 38-19-1612-042 Defendants. CIVIL DIVISION No.: MLD CERTIFICATE OF SERVICE The undersigned hereby certifies that a tree and correct copy of the Municipal Claim for Sewer Rents was served on the following this ~z-~ day of ~ ,2002, via First Class U. S. Mail, Postage Pre-paid: Andrew S. Jones Mishala S. Jones 901 Cedar Road Mechanicsburg, PA 17050 Respect fully ~ u _l~nitted: JAMES,~IN & By: ¢/ ~/~/J r ~ [/ Scott ~I. Dtet~, Esquire Attorney I.D.#55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 CONNEL'LY LLP SHERIFF'S RETURN CASE NO: 2002-03599 P ~D COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SILVER SPRING TOWNSHIP AUTHORI VS JONES ANDREW C ET AL BRYAN WARD - REGULAR Cumberland County, Pennsylvania, says, the within MUNICIPAL LIEN JONES ANDREW C Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the DEFENDANT , at 1853:00 HOURS, on the 9th day of September, 2002 at 901 CEDAR ROAD MECHANICSBURG, PA 17050 by handing to ANDREW C JONES a true and attested copy of MUNICIPAL LIEN together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.21 Affidavit .00 Surcharge t0.00 .00 34.21 Sworn and Subscribed to before me this /~ day of ~--~ ~ ~j~ A.D. 7 ifrothonot ary So Answers: R. Thomas Kline 09/ 0/2002 JkMES SMITH DURKIN CONNELLY By: ~'eput ~ Sheriff SHERIFF'S RETURN - CASE NO: 2002-03599 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SILVER SPRING TOWNSHIP AUTHORI VS JONES ANDREW C ET AL BRYAN WARD , REGULAR Cumberland County, Pennsylvania, says, the within MUNICIPAL LIEN JONES MISHALA S Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the DEFENDANT , at 1853:00 HOURS, at 901 CEDAR ROAD MECHANICSBURG, PA 17050 MISHALA S JONES on the 9th day of September, 2002 by handing to a true and attested copy of MUNICIPAL LIEN together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this /~J day of 2 ~/7J~-~ ~2~ A.D. /P~ot honor ary So Answers: R. Thomas Kline 09/10/2002 JAMES SMITH DURKIN CONNELLY Deput~ Sheriff