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JOSEPH B. MoCORKEL and I
MoCORKEL HOMES AND REMODELING,1
Claimant I
v. I
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
9!)- Lo(I~J:1, mcWVIL 'I'ERM
YOUNG HO LEE, CHONG OK LEE,
BRUCE HOROWITZ, and B , C
MARKET
MOTICI O. .ILING or MICHANIC.' LIIN CLAIM
'1'01' Young Ho Lee
chong Ok Lee
Bruce Horowitz
159-161 South pitt Street
Carlisle, PA 17013
You are notified that a Mechanics' Lien Claim in the amount
of $79,415.15 has been filed on behalf of Joseph B. McCorkel
doing business as McCorkel Homes and Remodeling, against the
property at 159-161 South pitt street, carlisle, Pennsylvania, of
which you are the ownor or reputed owner. The claim was filed on
DfL(~, l!i~h 1'7'1') in the Court of Common Pleas of cumberland
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County as of 95- lv'l'-tl Civil Term. A copy of the claim is
attached.
by
Respectfully submitted,
. Ja;tt/
an e E. Chertok, Esq.
I. D. No. 52651
44 South Hanover street
Carlisle, PA 17013
(717) 249-1177
Attorney for Claimant Joseph B.
McCorkel dba McCorkel Homes and
RemOdeling
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JOSEPH B. McCOR~EL and
MoCOR~EL HOMES AND REMODELING,
Claimant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
95- (.;,? L/.J.. CIVIL TERM
YOUNG HO LEE, CHONG OK LEE,
BRUCE HOROWITZ, and B , C
MAR~ET
KICHANICB' LIIN CLAIM
Claimant, Joseph B. MCCorkel, doing business as McCorkel
Homes and Remodeling, through the undex'signed counsel, Ule8 this
claim against the improvements and property at 159-161 South Pitt
Street, Carlisle, Pennsylvania, for the payment of a debt due to
claimant as a contractor for labor and materi~ls furnished by the
claimant in the alteration and repair and improvements to the
property. In support of the claim, the claimant makes the
following statement:
1. The owners of the property are Young Ho Lee, Chong Ok
Lee, and Bruce Horowitz with an address at 159-161 South pitt
Street, Carlisle, Pennsylvania. A copy of the deed is attached
a8 Exhibit "A".
2. The improvement and the property \.'hich are subj oct to
this claim are a three-story brick building located at 159-161
South Pitt street, Carlisle, Pennsylvania and described as
follows: A three-story brick building with the first floor
containing store front (B&C Market) and warehouse area, the
second floor containing three residential apartments and a
laundry room, and the third floor containing four residential
apartments.
3. The labor and materials for which the debt is due were
furnished for the agreed sum of $463,830 approximated costs
pursuant to a written contract with the owners dated March 28,
1995, a copy of which is attached as Exhibit "8".
4. The labor and materials for which the debt is due
consists of the purchase and installation of various materials
from October 2, 1995 until November 24, 1995, along with the
furnishing of labor at the agreed upon hourly rate. The
materials include electrical supplies, lumber, insulation,
equipment rental, caulking, oil, paint, drywall, vent louvers,
ceiling tile and gridwork, fire door~, plywood, and miscellaneous
supplies and materials.
5. Tho claimant reduced the workforce and ceased to
furnish supplies and materials at the property on November 24,
1995, which is less than four months before the filing of this
claim.
6. Claimant has been paid nothing for the labor and
materials that he has furnished from October 2, 1995 through
November 24, 1995, and there is due and owing a balance of
$79,415.15 for which claim is made of $79,415.15 plus interest,
costs and attorney's fees.
by
submitted,
.: c:?:tr.~fI'~
~t han e E. Chertok, Esq.
1.0. No. 52651
44 South Hanover Street
Carlisle, PA 17013
(717) 249-1177
Attorney for Claimant Joseph B.
McCorKel dba McCorkel Homes and
Remodeling
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IIAD. 'tB' 12th ., ., July
.f ..., !.oN... ~ ..... A.'''' dghty-f1 ve (1 98~) .
....."..N AUGUST W. SAPORl'rO and LEE S. SAPORITO, Huaband and Wite,
of the BorOugh of Carliale, cumberland County, Pennaylvanie, h.rei~fter
cened
GNl\tor a,
..... YOUNG HO LEE arid CHONG OK LEE, Husban!! and Wlfe, of North ,
Middleton T~wn.hip, cumberland County, Pennaylvania, hereinafter celled
Gra.u- :
W/fNf:SSlfB"IlAI.1I COIIIid"AlIo. 0' One Hundred Ten Thousand ($110,000.00)
Do/IGn,
... /14"" ,./4, 'A. ..eel,l' ViA...o' " Mr,bl/lIOlntmuW/1.d, lA, 0Gi4 .,...""" a do .....bv /11'81III
MId _"., lo'AI.dd .,...",... his heir. and anlgne,
ALL THAT CERTAIN tract of land altuate in the Third Ward of the
Borough of Carl1s1e bounded and described aa followal
BOUNDED on the West by South Pitt Street; on the North by property
now or formerly of F. M, Trout and Lovice V. Trout. on the Eaat by
a private alley; and on the South by South West Street. contalnlng
thirty-two (32) feet ln front on sald South Pltt Street snd
extendlng ln depth on West South street a distance of one hundred
ten (110) feet to sald prlvate alley.
Having thereon erected a three (3) story brlck bul1ding known and
numbered a. 159-161 South Pi tt street.
BEINO the aame premlll1es whlch Harold E. starkweather and Sandra L.
starkweather, huaband and wife, by thelr deed dated July 27, 1983
and recorded August 8~ 1983 in the Off lee of the Recordar of Deeda
in and for cumberland County in Deed Book "1", Vol. 30, Page ~7
granted and conveyed unto August W. saporlto arid Lee S. Saporito,
huabsnd and wife. the Grantors herein.
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Ik lfemodtJI/nll !crvlcu
Home II18pect/OM
McCorkel
lIomes & Remodeling
1405 Zimmerman Road
Carlisle. Pennsylvania 17013
Phone (717) 243.71122
Pble a.m6
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Shedl
Mr. Young Lee
Young's Supermarket
161 South Pitt Street
Carlisle, PA 17013
Dear Mr. Youngl
The following breakdown represents details for the remodeling of
the structure located at 161 South Pitt Street, Carlisle.
Remodeling of two eXisting apartments including a fire-code
drywall on walls and ceilings as needed. Bring electric
service up to da te. Insta 11 new tr im and baseboard. Use
existing materials as much as possible. Paint all walls
and trim, one coat or ,primer and two coats of finish paint.
Frame out apartments as designated approximately by drawings.
Install new windows as designated by drawings using wood
windows to match existing as close as possible. Install
electric service, fire alarm systems, one telephone jaCk
and one cable TV jaCk in each apartment. Insulate exterior
walls, walls between apartments and ceilings. Install necessary
plUmbing lines, install one-piece tUb/shower unit, vanity,
toilet and fixtures in each apartment. Install drywall
on all walls and ceilings (useing fire code as per standards
and also fire code doors where needed). Install all trim
and doors as needed using paint grade trim and flush doors;
paint as needed.
Install kitchens as
sinks and faucets.
apartment.
per allowances complete with countertops,
Install one 50-gallon water heater per
Install electric baseboard heat throughout apartments.
Install carpet/linoleum as per allowanced. Install bathroom
fan/light combinations and lighting as per allowanced.
Install refrigerators and stove as per allowances.
EXHIBIT "B"
COmplete lJulldlng
tJt If,modeUnll ~rvICU
lIome IMped/on,
McCorkel
Domes 8t Remodeling
14011 Zimmerman Road
Carlisle. Pennsylvania 17013
Phone (717) 243.11122
Ib/e lJIIm,
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Shed'
PAGE 1'WO
Install entranceway on first-floor apartments as
as approved by Historical Review Board. Install
to stops. cover with fire-cod8 drywall. Provide
per drawings
hallway
permits.
TOTAL APPROXIMATED COSTS I
$235,000.00
,
NOTE: Price quoted is approximated and may fluctuate due
to unforeseen problems in building or due to the increase
in the price of building supplies. Also. jab will be conducted
on a time-and-matecial basis and shall be billed and paid
weekly.
AJ.,LOWANCE,2'
Lighting ~ $300 per unit including bathroom fans;
Kitchen - $2,000 per unit including countertops;
Apppliances - $i.200 per unit;
Carpet/Linoleum - $15 per square yard (installed);
Bathrooms (to include, tub/shower. vanity. mirror. toilet
fixtures, and paperholder) - $15.000 per unit;
All trim work and flush luan doors to be paint-grade lumber;
100 AMP electric service to each unit;
Paint windows on exterior and patch in brick work for installling
of new windo~ls;
Paint new entrance door and panels on South Street side
of building; as pth" drawings approved by Historical
Review Doard;
Replace drop ceilings in market area to fire-code rated
gridwork and ceiling tiles;
Install fire-code drywall in basement as marked on blueprint
by the Department of Labor & Industry;
Install emergency lighting system and fire system in market
and hallways as designated on blueprints by the Department
of Labor & Industry;
NO ALLOWANCES FOR UNFORESEEN WORK.
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JOSEPH B. McCORKBL and
IIcCORKBL nOMES AND REMClDElI.ING,
Clailllllnt
IN THE COURT Cll' COMMON PLEAS OF
CUMBBRLAND COUNTY, PENNSYLVAIIIIA
frll..,(J
95-69112 ~ TBRM
v'
YOUNG HO LEE, CIIONG OK LEE,
BRUCE HOROVITZ, and B & C
MARKET
~PllXP-AVJfJl~_,~Y J~,JW J'ROG~
Roger C, Spitz beinp; duly 6worn aecnrdinp; to law deposes and l!Illya
that on December ", 1996, he 6~rved the attached Nl1tice of Filing of
){echanics' Lien Claim nn Chong Ok Lee by delJ.verinp; a true copy of the
attached Notice of Fllinp; of Meehan iCn' Lien Cl/lim to Chong Horowitz at
the address of 159-161 South Pitt Street, Carl1ale, PA 17013 at 4100 p,m,
1 hereby depose and eay that 1 am of the necessary age and sound
mind to execute said service and I am not a party to the ..cHon and I do
not have any interest in it.
Further affid/lfits eayeth not.
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JOSEPH B. McCORKEL ana
McCORKEL HOMES AND REMODELING,
claimant
IN THE COURT OF COMMOn PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
95- G; C;'l-j.,~
CIVIL TERM
YOUNG HO LEE, CHONG OK LEE,
BROCE HOROWITZ, and B , C
MARKET
NOTICI OF FILING OF KBCHANIC8' LXlN CLAIM d ~ ~
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TO: Young Ho Lee I ~
en
Chong ole Lee P;Cj ="
Bruce Horowitz ';;8 :,:
159-161 South Pitt Street ore.. ~ i
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Carlisle, PA 17013 .~
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You are notified that a Mechanics' Lien Claim in the amount
of $79,415.15 ha3 been filed on behalf of Joseph B. McCorkel
doing business as McCorkel Homes and Remodeling, against the
property at 159-161 South pitt street, Carlisle, Pennsylvania, of
which you are the owner or reputed owner. The claim was filed on
Ch..C!~\n~ ~-\lll P'IS,in the Court of Common Pleas of Cumberland
county as of 95- l"q~;;J. Civil Term. A copy of the claim is
attached.
by .o:z:: .~
~~~~~k, Esq.
/~:D. No. 52651
44 South Hanover Street
CarliSle, PA 17013
(717) 249-1177
Attorney for Claimant Joseph B.
McCorkel dba McCorkel Homes and
Remodel ing
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JOSEPH B. McCORKEL and
McCORKEL HOMES AND REMODELING, I
Claimant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
95-lJ'C(l-f], CIVIL TERM
YOUNO HO LEE, CHONG OK LEE,
BRUCE HOROWITZ, and B , C
MARl<ET
NOTICB or rILING or MECHANICS' LIBN CLAIM
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the amount
TO: Young Ho Lee
Chong ok Lee
Bruce Horowitz
159-161 South Pitt Street
Carlisle, PA 17013
You are notified that a Mechanics' Lien 'Claim in
of $79,415.15 has been filed on behalf of Joseph B. McCorkel
doing business as McCorkel Homes and Remodeling, against the
property at 159-161 South pitt Street, Carlisle, Pennsylvania, of
which you are the owner or reputed owner. The claim was filed on
CkQA,n~ ~~l\, f19S,in the Court of Common Pleas of Cumberland
County as of 95- <"Dqcj.~ civil Term. A copy of the claim is
attached.
Respectfully submitted,
~
by
51 neE. Chertok, Esq.
I.D. No. 52651
44 South Hanover Street
Carlisle, PA 17013
(717) 249-1177
Attorney for Claimant Joseph B.
McCorkel dba McCorkel Homes and
Remodeling
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JQSIPH B. McCORKEL MCI
McCORKEL HOMES AND REMODELING
P1l1ndfT
I IN mE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
:
I NO. 98.6942 CIVIL TERM
v.
YOUNG HO LEE, CHONG OK LEE,
BRUCE HOROWrn, IRd B " C MARKET
Defendant
PRELIMINARY OBJECTION
'\""V"-----
AND NOW comes Defendants Young Ho Lee, Chong Ok Lee, Bruce Horowitz and B & C
Market who file this Preliminary Objection in accordance with the act of AUllust 24, 1963, PL
117~, Section ~O~, 49 PS 1~05 and PaRCP at 1017,
I. Defendants preliminarily object to the claim filed in the above captioned action by
showinll exemption and immunity of lhe property described from Ihe mechanics' lien on
account of waiver and release of liens having been execuled on May 5. 1995 by the PlaintifT
in this action whereby no lien can be filed for the claim asserted, Copy of waiver of liens is
attached hereto,
stricken from the record,
DECEMBER 13, 1995
JOliN H. B lIiOS. ESQIIIR
BROUJOS, GILROY & HOUSTON, P.C,
4 NORTII HANOVER STREET
CARLISLE, PENNSYLVANIA 17013
717/243.4~74 7171766.1690
FAX Ii 717/243.8227
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PRAECIPE fOR LISTING CASE FQ&..ARGUMENT
(Mull be lypcwrincn llI1d Kuhmlttcd III duplicute)
o Pre.Trial Argument Court
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TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please list the within matter for the next:
'R: Argument Court
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CAPTION OF CASE
(entire caption must be stated in full)
Jo.eph B. McCorkel and McCorkel Home. and Remodellnl
PlaIntiff
VI.
YOUnl Ho Lee, Chong Ok Lee, Bruce HorowItz and B & C Market,
Defendants
f1?J....l'J
No. 95- 6942 Chll
I. State matter to be argued: Defendants' preliminary objections to Mechanics
Lien.
Defendant's Preliminary Objections
2, Identify counsel who will argile case:
(a) for plaintiff:
(b)
for defendant:
John H, Broujos, Esquire
3. 1 will notify all parties in writing within two days thaI this case has been listed
for argument. ( --r~
. '-~-{'
ey for Defendaht)
Date: February fI, 1996
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