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SILVER SPRING TOWNSHIP
AUTHORITll ,
IN THE COURT OF COMMON PLEAS OF
CUMBER~D COUNTll, PENNSllLVANIA
Plaintiff
vs.
NO. 95-4327
EQUITll TERM
LARRY RUSSELL KIEFFER,
Dllltendant
CIVIL ACTION - EQUITY
TO: LARRll RUSSELL KIEFFER
293 Locust Point Road
New Kingstown, PA 17072
(Defendant)
DATE OF NOTICE: February 12, 1996
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN waITING
WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST llOU. UNLES~ YOU ACT WITHIN TEN DAllS FROM THE DATE
OF THIS NOTICE, A JUDGMENT MAll BE ENTERED AGAINST llOU WITHOUT A
HEARING AND llOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
llOU SHOULD TAKE THIS NOTICE TO A LAW~ER AT ONCE. IF llOU 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:
Court Administrator
One Court House SqUAre
carlisle, PA 17013-3387
(717) 240-6200
NEMAN, P.C.
By
C. Snelbaker
44 West Main Street
Mechanic.burg, PA 17055-0318
(717) 697-8528
Attorneys tor Plaintitf
L.AW O"IC..
SNIL.OAKEIIt
a
BIltINNIMAN
..
SNELBAKER 8 BRENNEMAN
A PIlO'U~IONAL C::OIll.POl'AnON
^rrORNEY~ ^T LAW
oW WL."IT MAIN Hl'lIT
MECHANIC5BURG, PENN5YLVANIA 17055
p. O. 110)( 31.
MOIMIU C1l7l aW.1el1l
IUCHMll C. $NRMKlR
ICtml O. .IUNN1W\N
PHIUP H. ''''Ill
11.7,nQl.ft!!),2lS
February 12, 1996
Larry Rus.ell Kiefter
293 Locust Point Road
New Kingstown, PA 17072
Re: Silver spring Township Authority
vs. Larry Russell Kietfer
No. 95-4327 Equity Term
Court of Common Pleas ot Cumberland County
Dear Mr. Kieffer:
Pursuant to an order ot Judge Oler ot the Cumberland County
Court ot Comman Pleas, formal trial in your case is scheduled tor
March 20, 1996 commencing at 2:30 o'~lock P.M. in Court Room No.
5 of the CUmberland County Court House at Carlisle, Pennsylvania.
Enclosed you will find a notice wlth respect to your tailure
to file a response to the original complaint in this case. It is
suggested that you carefully rGad the notice as prepared.
This letter is being sent to you by both regular and
certitied mail, return receipt requested. Should you retuse to
accept delivery ot the certified mail, you will be presumed to
have received the regular first-class mail.
Very truly yours,
Richard C. Snelbaker
RCS:pjt
Inclosure
. ......""..
, .,..-
".90-9(, ~
.
SILVER SPRING TOWNSHIP IN THE COURT OF COMMON PLEAS OF
AUTHORITY, CUMBERLAND COUNTY, PENNSYLVANIA
plaintiff
VS. NO. 95-4327 EQUITY TERM
LARRY RUSSELL KIEFFER,
Defendant CIVIL ACTION - EQUITY
TO: LARRY RUSSELL KIEFFER
293 Locust Point Road
New Kingstown, PA 17072
(Defendant)
DATE OF NOTICE: February 12, 1996
IMPORTANT NOTICE
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 DAYS PROM THE DATE
OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
FOLLOWING OFFICE TO rIND OUT WHERE YOU CAN GET LEGAL HELP:
Court Administrator
One Court House Square
Carlisle, PA 17013-3387
(717) 240-6200
By_
char a er
44 West Main Street
Mechanic.burg, PA 17055-0318
(717) 697-8528
Attorney. foe Plaintiff
LAW 0.,,1<:1.
SNIL.IIA.ICI"
.
...INNIMAN
"
SILV.R SPRING TOWNSHIP
AUTHORITY ,
Plaintiff
I IN 'm. COURT OP COMMON PLDS OP
I CUKB.RLAND COUNTY, P.NNSYLVANIA
I
I CIVIL ACTION - .QUITY
I
I
I NO. 95-4327 .QUITY T.RN
v.
LARRY RUSS.LL KI.PPIR,
D.f.ndant
D.CR" NISI
AND NOW, thi. 20th day of March, 1996, upon
con.id.ration of the Plaintiff'. complaint in the
abov.-caption.d matt.r, and following a trial at which the
D.f.ndant fail.d to app.ar notwithEtanding that notic. had b..n
.ent to him, and the Plaintiff having ..rved upon the D.f.ndant
a notice of int.ntion to take a d.fault judgm.nt, and the
Def.ndant having fail.d to fil. an an.w.r to the complaint,
th.r.by r..ulting in the d....d admi..ion of the av.rm.nt. of
the complaint, the Court (a) find. that the all.gation. of the
complaint have b..n ..tabli.h.d by a pr.ponderanc. of the
.vidonc., (b) find. in favor of the Plaintiff and again.t the
D.f.ndant and (c) accordingly ORD.RS. DIR.CTS and D.CR..S a.
follow..
1. A c.rtifi.d copy of thi. Decr.. .hal1 b.
.erv.d upon the D.f.ndant by p.r.onal ..rvic. by Plaintiff.
2. Th. D.f.ndant i. h.r.by .njoin.d, prohibit.d
and pr.v.nt.d from di.charging .anitary ..wag. into any on-.it.
di.po.al faciliti.. from and aft.r th. .ff.ctiv. date of thi.
D.cr...
3. Th. D.f.ndant i. h.r.by .njoin.d, ordor.d and
dir~ot.d to conn.ct the improvem.nt. to the pr..i... at 293
.
Locu.t Point Ro.d, Silv.r Spring Town.hip, Cumb.rl.nd County,
Penn.ylvani., to the Pl.intiff', municip.l .ew.g. .y.tem by (.1
making .ppropri.t. .pplication and p.ying all n.c....ry f... .nd
charg.. to the Authority within thirty d.y. from the d.t. of
.ervic. of . copy of thi. D.cr.., and (bl phy.ic.lly conn.cting
hi. .anitary ..w.g. g.n.rating faciliti.. on the .ubj.ct
premi... to the municip.lity'. .y.tem, within .ixty day. from
"
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the d.t. of .ervic. of thi. D.cre..
4. If D.f.nd.nt neglect., fail. or refu... to
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comply with the for.going dir.ctiv.., Pl.intiff, through it.
agent.. employ... or contractor., i. h.r.by authori..d to .nt.r
upon the D.fend.nt'. premi... and to con.truct the n.c....ry
conn.ction or conn.otion. of ..nit.ry ..w.ge g.n.r.ting
facilitie. to the municipal ..wag. .y.tem in .ccord.nc. with the
requirement. of Ordin.nc. No. 85-7 of Silver Spring Town.hip .nd
Def.nd.n~ i. hereby ord.red .nd direct.d to p.y .nd r.imbur..
Pl.intiff for .11 co.t. and expen.e. incurred in .ffecting the
connection .. provid.d for h.r.in by .ny lawful m..n., including
but not limtied to the impo.ition of . municip.l li.n.
THIS DECR.. NISI .hall b.come a Pin.l D.cr..
without furth.r Ord.r of Court if no motion for poet-tri.l
r.li.f pur.uant to p.nn.ylv.nia Rul. of Civil Procedure 227.1 i.
fil.d within t.n d.y. of the d.t. of .ntry of thi. Ord.r.
By the Court,
,
J.
I
I
SILVER SPRING TOWNSHIP
AUTHORITY,
IN THe COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
vs.
NO. 95- 'I.J.;J 1
EQUITY TERM
LARRY RUSSELL KIEFFER,
Defendant
CIVIL ACTION - EQUITY
NOTIC..f,;
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are
served, by entering a written appearance personally or by
attorney and filing in writing with a court your defenses or
objections to the claims set forth against you. You are warned
that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further
notice for any money claimed in the Complaint or for any other
claim or relief requested by the Plaintiff. You may lose money
or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
One Courthouse square
Carlisle, PA 17013-3387
(717) 240-6200
N, P.C.
~
A eys for Plaintiff
L.AW ol'lI'rc:u
S~U:LIIAKII'I
.
S"INNIMAN
l..AW O""IClII
SNEL.BAKER
.
BRENNlEMflN
SILVER SPRING TOWNSHIP
AUTHORITY,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
vs.
NO. 95- '11) I
EQUITY TERM
LARRY RUSSELL KIEFFER,
Defendant
CIVIL ACTION - EQUITY
COMPLAINT
AND NOW comes the Plaintiff, SILVER SPRING TOWNSHIP
AUTHORITY, by its Attorneys, SNELBAKER' BRENNEMAN, P.C., and
avers the following cause of action:
1. The Plaintiff herein is SILVER SPRING TOWNSHIP
AUTHORITY, a body politic, having been created under the
Pennsylvania Municipality Authorities Act of 1945, as amended,
having its principal office at 6475 Carlisle Pike, Mechanicsburg
(Silver Spring Township), Cumberland county, Pennsylvania.
2. The Defendant herein is LARRY RUSSELL KIEFFER, an adult
individual, who resides at 293 Locust Point Road, New Kingstown
(Silver Spring Township), Cumberland County, Pennsylvania 17072.
3. Plaintiff is the owner and operator of a municipal
sanitary sewerage system in the Township of Silver Spring,
Cumberland County, Pennsylvania which exists for the protection
of the health and welfare of the residents of said Township.
4. Defendant is the owner of a parcel of real estate
situated in said Township of Silver spring known and numbered as
293 Locust Point Road, New Kingstown, being the same premises
which Defendant acquired from Donald W. and J. Lorraine Valentine
LAW 0"101:15
SNILB^KEPI'
.
S"INN!MAN
by Deed dated May 28, 1993, and recorded in the Office of the
Recorder of Deeds in and for Cumberland County, Pennsylvania, in
Deed Book "J", Volume 36, Page 997, hereinafter called "Subject
Premises".
5. Plaintiff has installed a portion of its municipal
sewerage system in such location as to provide sewage collection
service for the Subject Premises.
6. The Board of Township Supervisors in and for the
Township of silver spring duly enacted Ordinance No. 85-7 on July
24, 1985, which provides in relevant part as follows:
a. That an owner of Improved Property whose
principal building is within 150 feet from a municipal
Sewer system shall connect said Property with and use
the Sewer System within 60 days after notice to make
connection for the purpose of discharge of all sanitary
sewage and industrial waste from the Improved Property;
and
b. If any such owner shall fail to connect such
Improved Property as required, the Township may enter
upon the Improved Property and construct such
connection and may collect from the owner the costs and
expenses thereof.
7. The Subject Premises is Improved Property and Defendant
is the Owner thereof within the meaning of said Ordinance No. 85-
7.
-2-
8. Plaintiff is the duly authorized representative of the
Township of Silver Spring for the purposes of administering and
enforcing said Ordinance No. 85-7.
9. On or about November 22, 1993, Plaintiff gave notice to
Defendant to connect the sUbject Premises to the municipal sewer
system adjacent to said Premises within 90 days from receipt of
said notice.
10. Defendant received said notice to connect on November
26, 1993.
11. subsequent to said notice aforesaid, Plaintiff has
reminded Defendant of the obligation to connect with and use the
municipal sewer system.
12. Defendant has failed and refused to connect the Subject
Premises to the municipal sewerage system in disregard of the
notice and reminder.
13. The Subject Premises generates sanitary sewage which is
not being discharged into the municipal sewerage system but is
being discharged into on-site facilities on the Subject Premises,
now in violation of said Ordinance No. 85-7.
14. Defendant's continued use of the on-site facilities and
LAW OFl"lCall
SNfLBAI<I;!"
.
8IUNNIM,\N
failure to use the municipal sewerage system constitutes a threat
to the health and welfare of the general public and specifically
to the residents of Silver Spring TownShip. 1'herefore, it is
necessary to force Defendant to comply with said Ordinance No.
85-7 by connecting the Subject Premises with the municipal
sewerage system.
-3-
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I.
I'
UW O"ICI:S
SNILIIIAKEA
.
lI'UNNIE:MAN
15. Plaintiff has no adequate remedy at law.
WHEREFORE, plaintiff respectfully prays your Honorable
Court:
a. Enjoin, prohibit and prevent Defendant from
discharging sanitary sewage into on-site disposal
facilities;
b. Order, direct and enforce Defendant to connect
his sanitary sewage generating facilities on the
Subject Premises to the Plaintiff's municipal sewage
system;
c. Order and direct Defendant to pay all required
tapping and connection fees;
d. Authorize and empower plaintiff through its
agents, employees and/or contractors to enter upon the
Subject Premises and to construc~ the necessary
connection or connections of sanitary sewage generating
facilities on and in the subject Premises to the
municipal sewerage system in accordance with the
requirements of said Ordinance No. 85-7;
e. Order and direct Defendant to pay and
reimburse plaintiff for all costs and expenses incurred
in effecting the connection as required under paragraph
d. above.
f. Order and direct Defendant to pay the costs
of this proceeding; and
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SILVER SPRING TOWNSHIP IN THE COURT OF COMMON PLEAS OF
AUTHORITY, CUMBERLAND COUNTY, PENNSYLVANIA
plaintiff, f
vs. CIVIL ACTION - EQUITY I
~.
LARRY RUSSELL KIEFFER, NO. 95-4327 EQUITY TERM
Defendant
PETITION FO]LfRELIMINARY INJUNCTION
TO THE HONORABLE, THE JUDGES OF SAID COURT:
AND NOW comes the plaintiff, SILVER SPRING TOWNSHIP
AUTHORITY, by its Attorneys, SNELBAKER & BRENNEMAN, P.C., and
respectfully represents as follows:
1. That your Petitioner herein is the SILVER SPRING
TOWNSHIP AUTHORITY, the Plaintiff in the above captioned action
and as more fully identified in the Complaint attached hereto as
recited hereinbelow.
2. That your Petitioner commenced the within action by duly
filing its Complaint on August 14, 1995, a true and correct copy
of said Complaint being attached hereto and incorporated herein
by reference thereto.
3. That Defendant persists in his violation of the
L.AW O"'IClitJ
SI'lI:l.ElAKe:R
a
B'UN~[MAN
applicable ordinances, resolutions, rules and regulations being
enforced by Plaintiff as set forth in the Complaint.
4. Defendant's continued violation of said ordinances,
resolutions, regulations and rules and his continued use of on-
site sewage facilities and failure to use the municipal sewerage
system constitutes a threat to the health and welfare of the
general public and specifically the residents of silver Spring
Township.
WHEREFORE, your Petitioner respectfully prays your Honorable
Court, after hearing, to preliminarily enjoin Defendant from
continuing to use his on-site sewage disposal facilities and to
compel his connection of his improvement~ containing sewage-
generating facilities to the municipal sewerage system.
Respectfully submitted,
By
I..AW OflllCKIJ
SNII.E1AKIUI
a
BIUNNIMAN
-2-
,I
COMMONWEALTH OF PENNSYLVANIA )
: SS.
COUNTY OF CUMBERLAND)
JOHN E. FREILINO, being duly sworn according to law, deposes
and says: that he is the Manager of the SILVER SPRING TOWNSHIP
AUTHORITY (the Plaintiff in the within acticn) and, as such, is
the chief operating officer of said Authority; that he is
authorized by said Authority to make this affidavit on its
behalf; that said Authority is the Plaintiff in this action; and
that the facts set forth in the within Petition for Preliminary
Injunction within his personal knowledge are true and correct,
and as to facts supplied on information from others, he believes
said facts to be true and correct.
, ,
Il'(t.~IL ' .'./t't't[!.,t(1
j John E. Fre I no
(Manager)
/"
Sworn to and subscribed before me
this .1{)V- day of october, 1995.
C~~',J (). ,::i~~
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f'.lltIl'.l.\1 flndl,'",!. I'l'Jl.1ry PHI)lie
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I.I\W O.IIICI[I'
SN!I.BAKIiFt
a
IIIUNNIMAN
SILVER SPRING TOWNSHIP
AU'I'HORITY,
IN THE COUR'!' OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
plaintiff
va.
: NO. 95- Y 3J 1
,. '
EQUITY TERM
LARRY RUSSELL KIEFFER,
Defendant
CIVIL ACTION - EQUITY .
NOT ICE
.
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you mu.t'~ake action
within twenty (20) days after this complaint and Notice are
served, by entering a written appearance personally or by
attorney and filing in writing with a court your defenses or
objections to the claims set forth against you. You are warned
that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further
notice for any money claimed in the Complaint or for any other
claim or relief requested by the Plaintiff. You may lose money
or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OU'I' WHERE YOU CAN GET LEGAL HELP.
"
Court Administrator
One Courthouse Square
Carlisle, PA 17013-3387
(717) 240-6200
By
, P.C.
Ir.,AW omcl5
IHI".A"I"
.
I"INNIM.IIN
SILVER SPRING TOWNSHIP
AUTHORITY,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
plaintift
vs.
NO. 95- <{?:J. 1
EQUITY TERM
l
,
LARRY RUSSELL KIEFFER,
Defendant
CIVIL ACTION - EQUITY
COMPLAINT
AND NOW comes the Plaintitf, SILVER SPRING TOWNSHIP
AUTHORITY, by its Attorneys, SNELBA1<ER & BRENNEMAN, P.C., and
avers the following cause of action:
I
I,
!;
1. The plaintiff herein is SILVER SPRING TOWNSHIP
AUTHORITY, a body politic, having been created under the
Pftnnsylvania Municipality Authorities Act of 1945, as amended,
havinq its principal office at 6475 Carlisle Pike, Mechanicsburg
(Silver spring Township), cumberland county, Pennsylvania.
2. The Defendant herein is LARRY RUSSELL KIEFFER, an adult
individual, who resides at 293 Locust Point Road, New Kinqstown V
,
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....,. O"IU'
INIL.AIeIIll
.
IfllNNIMAN
(Silver Sprinq TownShip), cumberland County, pennsylvania 17072.
3. Plaintiff is the owner and operator of a municipal
sanitary sewerage system in the Township of silver Spring,
Cumberland county, Pennsylvania which exists for the protection
of the health and welfare of the residents of said Township.
4. Defendant is the owner of a parcel of real estate
situated in said TownShip of Silver Spring known and numbered as
293 Locust Point Road, New Kingstown, beinq the same premises
which Defendant acquired from Donald W. and J. Lorraine Valentine
by Deed dated May 28, 1993, and recorded in the ottice ot the
Recorder ot Deeds in and tor cumberland County, Pennsylvania, in
Deed Book "J", Volume 36, Page 997, hereinatter called "SUbject
Premises".
5. Plaintitt has installed a portion ot its municipal
sewerage system in such location as to provide sewage collection
service tor the subject Premises.
6. The Board of Township Supervisors in and tor the
Township ot Silver Spring duly enacted ordinance No. 85-7 on July
24, 1985, which provides in relevant part as tollows:
a. That an owner ot Improved Property whose
principal building is within 150 teet trom a municipal
Sewer system shall connect said Property with and use
the Sewer System within 60 days atter notice to make
connection tor the purpose ot discharge ot all sanitary
sewage and industrial waste trom the Improved Property;
and
....w 0"1"'
.NIL.AK.1lI
.
....NNEMAN
b. If any such owner shall fail to connect such
Improved property as required, the TownShip may enter
upon the Improved Property and conatruct such
connection and may collect from the owner the costs and
expense. thereof.
7. The subject Premises is Improved property and Defendant
is the owner thereof within the meaning ot said Ordinance No. 85-
7.
-2-
8. Plaintiff is the duly authorized representative of the
Township of silver spring for the purposes of administering and
enforcing said Ordinance No. 85-7.
9. On or about November 22, 1993, Plaintiff gave notice to
Defendant to connect the subject Premises to the municipal sewer
system adjacent to said premises within 90 days from receipt of
said notice.
10. Defendant received said notice to connect on November
26, 1993.
11. subsequent to said notice aforesaid, Plaintiff has
reminded Defendant of the obligation to connect with and use the
municipal sewer system.
12. Defendant has failed and refused to connect the Subject
premises to the municipal sewerage system in disregard of the
notice and reminder.
13. The SUbject Premises generates sanitary sewage which 1s
not being discharged into the municipal sewerage system but is
being discharged into on-site facilities on the Subject Premises,
now in violation of laid Ordinance No. 85-7.
IoAW O"'lall
.NILIAKI..
.
....NNIM..N
14. Defendant's continued use of the on-site facilities and
failure to use the municipal sewerage system constitutes a threat
to the health and welfare of the general public and specifically
to the residents of Silver spring Township. Therefore, it is
necessary to force Defendant to comply with said Ordinance No.
85-7 by connecting the subject Premises with the municipal
sewerage system.
-3-
15. Plaintitf has no adeq~ate remedy at law.
WHEREFORE, plaintiff re.pectfully prays your Honorable
Court I r
a. Enjoin, prohibit and prevent Defendant from
discharging sanitary .ewage into on-site disposal
facilities;
b. Order, direct and enforce Detendant to connect
his sanitary sewage generating facilities on the
Subject Premise. to the Plaintitf'. municipal sewage
.y.tem;
c. Order and direct Defendant to pay all required
tapping and connection tees;
d. Authorize and empower Plaintiff through it.
agents, employees and/or contractors to enter upon the
Subject premi.e. and to construct the necessary
connection or connections of sanitary sewage generating
facilities on and in the SUbject Premises to the
municipal sewerage syotem in acc~rdance with the
requirements ot said Ordinance No. 85-7;
e. Order and direct Defendant to pay and
reimburse plaintiff tor all costs and expenses incurred
in etfecting the connection as required under paragraph
d. above.
uw o",ca.
INIL.A"."
.
....NN.MAN
t. Order and direct Detendant to pay the costs
at this proceeding; and
-4-
COMMONWEALTH OF PENNSYLVANIA )
: SS.
COUNTY OF CUMBERLAND)
I
JOHN E. FREILINO, being duly sworn according to law, deposes
and says: that he is the Manager of the SPRING TOWNSHIP
AUTHORITY (the plaintiff in the within Complaint) and, a. such,
is the chief operating officer of said Authority; that he is
authorized by said Authority to make this affidavit on its
behalf; that said Authority is the Plaintiff in this action; and
that the facts set forth in the within Complaint within his
I
l.
I
I
,
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I
personal knowledgp are true and correct, and a8 to facts supplied
on information from others, he believes said facts to be true and
correct.
/
,
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'~E , ''It.A(,~
Jo n E. Frs no
(Manaqer)
I
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Sworn to and subscribed before me
'this q';'L day of 0 "r(Lot , 1995.
.>.t/~(i/.t a. .;q~/J~d.IJ/l
NOTARIAL SEAL
\.. "S Y A, BEARDSLEY, Nllar, !WI
~, ",. ~p"nl Top" Cumlltlln. CIIIlII,
I \~, :(~"""," F...'rtl all. 21. 1996
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SILVER SPRING TOWNSHIP
AUTHORITY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - EQUIT~
LARRY RUSSELL KIEFFER,
Defendant
95-4327 EQUITY TERM
08DER OF COURT
AND NOW, this 12th day of February, 1996, due to
a scheduling conflict related by counsel for the Plaintiff,
Richard C. Snelbaker, Esquire, the trial scheduled in this
matter for Friday, March 22, 1996, at 9:00 a.m. is RESCHEDULED
for Wednesday, March 20, 1996, at 2:30 p.m., in Courtroom No.5,
Cumberland County Courthouse, Carlisle, Pennsylvania.
Notice of the rescheduled time, date, and place
of this trial is hereby provided to the Defendant through this
Order.
By the Court,
J
RICHARD C. SNELBAKER, ESQUIRE
For the Plaintiff
LARRY RUSSELL KIEFFER
293 Locust Point Road
New Kingstown, PA 17072
Court Administrator
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