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MONROE TOWNSHIP,
Claimant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
WILLIAMS GROVE, INC.,
Owner
NO. 30772 M.L.D. 1991
9& -I.{JD C,~,l /cq"1
NOTre!:
You have been sued in court. If you wish to defend against
the Writ of Scire Facias set forth in the following pages, you
must take action within fifteen (15) days after this Writ and
Notice are served, by filing your Affidavit of Defense to the
municipal claim set forth against you, if defense you have
thereto, in the office of the prothonotary of this court. If no
Affidavit of Defense be filed within said time, judgement may be
entered against you for the whole claim, and the property
described in the municipal claim sold to recover the amount
thereof. You are hereby warned that if you fail to file an
Affidavit of Defense, 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 claim or for any other claim
or relief requested by this claimant. You may lose money or
property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
00 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
Cumberland County Courthouse
Courthouse Square
Carlisle, Pennsylvania 17013
(717) 240-6200
(717) 697-0371
1 West Main Street
Shiremanstown, PA 17011
(717) 737-8761
Solicitors for Monroe
Township, Claimant
I'
MONROE TOWNSHIP, : IN THE COURT OF COMMON PLEAS OF
Claimant . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
VB. .
.
. NO. 30772 M.L.D. 1991
.
WILLIAMS GROVE, INC., .
.
Owner .
.
!
WRIT O~ SCIRE ~ACIAS
MONROE TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, TO
WILLIAMS GROVE, INC., GREETING:
WHEREAS, Monroe Township, on the twenty-ninth (29th) day of
November, A.D. 1991, filed its claim in our Court of Common PleaB
of cumberland County: at No. 30772 Municipal Lien Docket 1991 for
the sum of $19,560.04, with interest, penalties and costs from
the first day (1st) day of May, A.D. 1988 through the thirtieth
(30th) day of september, A.D. 1990, for delinquent
amusement/admission taxes, against the following property situate
in Monroe Township owned or reputed to be owned by you, described
as follows:
One Park Avenue
Mechanicsburg, PA 17055
CUmberland County Recorder of Deeds Office
Deed Book "D", Volume 20, Page 88:
Deed Book "L", Volume 24, Page 747, and
Deed Book "G", Volume 13, Page 272
Parcel Numbers: 22-31-2158-075, 22-31-2158-012,
22-12-0350-005, 22-31-2158~051, 22-31-2158-113,
22-31-2158-101, 22-31-2158-081, 22-31-2158-069,
22-31-2158-067, 22-31-2158-024, 22-31-2158-019,
22-31-2158-115, 22-31-2158-105, 22-31-2158-046,
22-31-2158-044, 22-31-2158-041, 22-31-2158-111,
22-11-0278-031
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And whereas, We have been given to understand that said
claim is still due and unpaid, and remains a lien against the
said property,
Now, you are hereby notified to file your Affidavit of
Defense to said claim, if defense you have thereto, in the office
of the prothonotary of our said court, within fifteen (15) days
after the service of this writ upon you. If no Affidavit of
Defense be filed within said time, judgment may be entered
against you for the whole claim, and property described in the
claim may be sold to recover the amount thereof.
WITNESS, the Honorable
our said court, this .;Ji.,"'1..
Harold E. Sheely, President Judge of
day of JdUU,.;jf>-1 A.D. 1996.
, Ll~ ~ P. ~/Z,~ if~
Lawrence E. Wel er, protho 0 ry
Court of Common Pleas of
Cumberland County, Pennsylvania
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MONROE TOWNSHIP,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Claimant
VB.
NO. 30772 M.L.D. 1991
91.:.-'130 e/Ul'{ ~IL",
WILLIAMS GROVE, INC.,
Owner
PRABCIPE ~OR WRIT O~ SCIRB FACIAS
TO: Lawrence E. Welker, Prothonotary of cumberland county
Please issue a writ of scire Facias against the following
named entity in the amount of $19,560.04, with interest,
penalties and costs from October 25, 1991.
williams Grove, Inc.
One Park Avenue
Mechanicsburg, PA 17055
DATE: January 26, 1996
BY/
James D.
Solicitor r Monroe
Township, Claimant
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MONROE TOWNSHIP,
I
IN THE COURT OP COMMON PLEAS OP
CUMBERLAND COUNTY, PENNSYLVANIA
96-430 CIVIL TERM
Claimant
.
.
.
.
vs.
WILLIAMS GROVE, INC.,
Owner
and
PoNe BANK, N.A., Successor to
The First Bank and Trust
Company,
Mortgagee
PRAEC%PB ~ STIPULATION TO DELETE ~ P~RTY PROM THE CAPTION
TOI Lawronoe B. Welker, Prothonotary
Court of common P1e.s of
CUmberlan4 County, Pennsylvani.
Kindly delete PNC BANK, N.A., Successor to The First Bank and
Trust Company, as a party in the above-captioned matter in
accordance with the attached StipUlation.
BY('
Ja es D.
1 West Ma street
Shiremanstown, PA 17011
(717) 737-8761
Solicitor tor Monroe
Township, Claimant
DATE I FEBRUARY 9, 1996
.
MONROE TOWNSHIP,
I IN THE COUR'l' OF COMMON PLEAS OF
Claimant I CUMBERLAND COUNTY, PENNSYLVANIA
VS.
WILLIAMS GROVE, INC.,
Owner
and
PRO BANK, N.A., Successor to
The First Bank and Trust
Company,
Mortqaqee :
.
.
: 96-430 CIVIL TERM
I
.
.
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STIPUUTION
AND NOW, this 9th day of February, 1996, Monroe Township, and
PNO BANK, N.A., by and through their counsel, hereby stipUlate and
aqree that PNC BANK, N.A., Successor to The First Bank and Trust
company, shall be dismissed as a named party in the above-captioned
action as they have no ownership interest in the land subject to
the municipal lien. All pleadinqs, papers, docketed entries in
this matter hereafter filed shall use the followinq caption:
MONROE TOWNSHIP,
Claimant
vs.
WILLIAMS GROVE, INC.,
Owner
/ ~
J ar, Esquire
Solicitor or Monroe TownShip
1 West Main Street
Shiremanstown, PA 17011
717-737-8761
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
96-430 CIVIL TERM
, '
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Attorney for PNe BANK, N.A.,
Successor to The First Bank
and 'l'rust company
Legal Division
Fifth Avenue and Wood Street
pittsburgh, PA 15265
.
CZRTIPICATB OP SERVICE
I, "alles D. Bogar, Esquire, hereby certify that I am this day
serving the foregoing stipulation upon the following named individuals
this day by depositing sallie in the United states Mail, First Class,
postage prepaid, at Shiremanstown, pennsylvania, addressed as follows:
williams Grove, Inc.
One Park Avenue
Mechanicsburg, PA 17055
John B. Fowler, III, Esquire
Fowler, Addams, Shughart , Rundle
28 South pitt Street
carlisle, PA 17013
Attorneys for Williams Grove, Inc.
Date: February 9, 1996
, 7rll~
James D. Bo , Esquire
,
CBRTIPICATB OP SBRVICB
I, James D. Bogar, Esquire, hereby certify that I am this
day serving the foregoing stipulation upon the following named
individuals this day by depositing same in the United states
Mail, First Class, postage prepaid, at Shiremanstown, pennsyl-
vania, addressed as follows:
williams Grove, Inc.
One Park Avenue
Mechanicsburg, PA 17055
c/o
John B. Fowler, III, Esquire
Fowler, Addams, Shughart & Rundle
28 South Pitt street
Carlisle, PA 17013
Attorneys for Williams Grove, Inc.
Date: February 15, 1996
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Ja es D. Bo , Esquire
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MONROE TOWNSHIP,
Claimant
vs.
WILLIAMS GROVE, INC.,
Owner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
96-430 CIVIL TERM
PRABCIPB POR BHTRY OP APPBARANCB
TO: LAWRENCE E. WELKER, PROTHONOTARY
Please enter the appearance of the undersigned as counsel of record
for Williams Grove, Inc., owner, in connection with the above-captioned
matter.
,,-
By'
J hn B. Fowler, III, Esquire
owler, Addams, Shughart & Rundle
Attorney for Williams Grove, Inc.
28 South Pitt Street
Carlisle, PA 17013
(717) 249-8300
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MONROE TOWNSHIP,
I IN THE COURT OF COMMON PLEAS OF
Claimant CUMBERLAND COUNTY, PENNSYLVANIA
vs.
.
.
: NO. 30772 M.L.D. 1991
WILLIAMS GROVE, INC.,
Owner
and
.
.
.
.
PNC BANK, Successor to The
First Bank and Trust Company
Mortgagee
.
.
.
.
PRABCIPB POR WRIT OP SCIRE PACIAS SUR MUNICIPAL CLAIM
TO: Lawrence E. Welker, Prothonotary of Cumberland County
Please issue a Writ of Scire Facias Sur Municipal claim
against the following named entity in the amount of $19,560.04,
with interest, penalties and costs from October 25, 1991.
PNC Bank, Successor to The
First Bank and Trust company
4242 Carlisle Pike
Camp Hill, PA 17011
DATE: January 26, 1996
gar, Esquire
or Monroe
Claimant
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MONROE TOWNSHIP,
Claimant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 30772 M.L.D. 1991
qlc- 4.3C C'w...t;:r ~..~
vs.
WILLIAMS GROVE, INC.,
Owner
and
PNC BANK, Successor to The
First Bank and Trust Company
Mortgagee
NOTICB
You have been sued in court. If you wish to defend against
the Writ of Scire Facias set forth in the following pages, you
must take action within fifteen (15) days after this Writ and
Notice are served, by filing your Affidavit of Defense to the
municipal claim set forth against you, if defense you have
thereto, in the office of the prothonotary of this court. If no
Affidavit of Defense be filed within said time, judgement may be
entered against you for the whole claim, and the property
described in the municipal claim sold to recover the amount
thereof. You are hereby warned that if you fail to file an
Affidavit of Defense, 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 claim or for any other claim
or relief requested by this claimant. 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
Cumberland County Courthouse
Courthouse Square
Carlisle, Pennsylvania 17013
(717) 240-6200
(717) 697-0371
Andrew C. Sheely,
1 West Main Stree
Shiremanstown, PA
(717) 737-8761
Solicitors for Monroe
Township, Claimant
VS.
NO. 30772 M.L.D. 1991
MONROE TOWNSHIP,
Claimant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WILLIAMS GROVE, INC.,
Owner
and
PNC BANK, Successor to The
First Bank and Trust company
Mortgagee
WRIT OF SCIRE FACIAS SUR MUNICIPAL CLAIM
MONROE TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, TO PNC
BANK, SUCCESSOR TO THE FIRST BANK AND TRUST COMPANY, MORTGAGEE,
GREETING:
1
WHEREAS, Monroe TownShip, on the twenty-ninth (29th) day of
November, A.D. 1991, filed its claim in our Court of Common Pleas
of CUmberland county against your mortgagee, Williams Grove,
Inc.i at No. 30772 Municipal Lien Docket 1991 for the sum of
$19,560.04, with interest, penalties and costs from the first day
(1st) day of May, A.D. 1988 through the thirtieth (30th) day of
september, A.D. 1990, for delinquent amusement/admission taxes,
against the following property situate in Monroe TownShip owned
or reputed to be owned by Williams Grove, Inc., a portion of said
property being subject to a mortgage dated December 24, 1987
between williams Grove, Inc., Mortgagor and the First Bank and
Trust company, now PNC Bank, Mortgagee, said mortgage being in
the principal amount of Fifty-One Thousand Sixty-Seven and 72/100
Dollars ($51,067.72), and being recorded in the cumberland County
,
,
~
.
,
i
"
:
. .
. .
Recorder of Deeds Office in Mortgage Book 892, Page 290,
described as follows:
One Park Avenue
Mechanicsburg, PA 17055
CUmberland County Recorder of Deeds Office
Deed Book liD", Volume 20, Page 881
Deed Book "L", Volume 24, Page 747, and
Deed Book "G", Volume 13, Page 272
Parcel Numbersl 22-31-2158-075, 22-31-2158-012,
22-12-0350-005, 22-31-2158-051, 22-31-215S-113,
22-31-2158-101, 22-31-2158-081, 22-31-2158-069,
22-31-2158-067, 22-31-2158-024, 22-31-2158-019,
22-31-2158-115, 22-31-2158-105, 22-31-2158-046,
22-31-2158-044, 22-31-2158-041, 22-31-2158-111,
22-11-0278-031
And whereas, We have been given to understand that said
claim is still due and unpaid, and remains a lien against the
said property I
Now, you are hereby notified to file your Affidavit of
Defense to said claim, if defense you have thereto, in the office
of the prothonotary of our said court, within fifteen (15) days
after the service of this writ upon you. If no Affidavit of
Defense be filed within said time, judgment may be entered
against you for the whole claim, and property described in the
claim may be sold to recover the amount thereof.
WITNESS, the Honorable Harold E. Sheely, President Judge of
our said court, this ,;u.,A day of ~~ A.D. 1996.
~ (l.--e~". b.;Lt;,
Lawrenc E. WelKer " prot onotary
Court of Common Pleas of
Cumberland County, Pennsylvania
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SHERIFF'S RETURN - REGULAR
CASE NO: 1996-00430 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MONROE TOWNSHIP
VS.
WILLIAMS GROVE INC
TIMOTHY REITZ
CUMBERLAND County, Pennsylvania.
to law, says. the within WRIT OF
. Sheriff or Deputy Sheri!! of
who being duly sworn according
SCIRE FACIAS was served
upon WILLIAMS GROVE INC
defendant. at 924:00 HOURS. on the 30~h day of January
1996 at ONE PARK AVE
MECHANICSBURG. PA 17055
County, Pennsylvania. by handing to SALLY LOH.
the
. ::;UMBERLAND
SECRETARY AND ADULT
IN CHARGE
a true and attested copy of the WRIT OF SCIRE FACIAS
together with NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
15.6B
.00
2.00
So answer~ ~
~-/? /y /--:/. .
7 >>~/C'.....:<:. ~ c.f!
R. Thomas Rhne. SherJ.ff
$35.b8 JAMES D. BOGAR
,~~ .U0"::9k~ j y-
/'eputy SherJ.
Sworn and subscribed to before me
this (.!!:- day of j....t... ~...,
19 elL A. D.
-.q~~ ~~lrh:~;fiI~
.~'-_.
...__._._---._-~~
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
2.00
So answer~:
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~homaa-K11ne. 5her1ff
RECiULAfI
SHERIFF'S flETUR~
CASE NOI 1996-00430 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MONROE TOWNSHIP
V5.
WILLIAMS GROVE INC
TIMOTHY REITZ , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who be1ng duly sworn according
to law, saya, the within !iB.lI OF SCIRE FACIAS was served
upon PNC BANK SUCCESSOR TO THE FIRST BANK AND TRUST COMPANY the
defendant, at 942:00 HOURS. on the ~lst day of January
19~ at 4242 CARLISLE PIKE
CAMP HILL. PA 17011 . CUMBERLAND
County, Pennsylvania. by handing to ROXANNE DEIHL. ASSISTANT
MANAGER
a true and attested copy of the WRIT _~SCIRE FACIAS
together with NOTICE
and at the same time directing lIer attention to the contents thereof.
$8.00 JAMES D. BOGAR
02/01/1996
br1
Sworn and subscribed to before me
this t. If- day of J..Lk.......,_____
19 q(,. A.D.
(-\....,.....- C. Yh.. ''-0. . 0,....., ~
~-- t'rothonotary=;.:=7----
MONROE TOWNSHIP,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
96-430 CIVIL TERM
Claimant
vs.
WILLIAMS GROVE, INC.,
Owner
PRABCIPB POR BNTRY OP DBrAULT JUDGMENT
TO THE PROTHONOTARY:
LAWRENCE E. WELKER
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
Kindly enter a default judgment in favor of Monroe Township,
plaintiff, and against Williams Grove, Inc. Owner, for failure of
Williams Grove, Inc., to file an Affidavit of Defense to the
Praecipe for Writ of Scire Facias Sur Municipal Claim, in the
amount of $19,560.04, with interest, fees, penalties and costs from
October 25, 1991, as authorized by law.
A copy of the Notice of Intent to take a Default Judgment is
attached hereto as Exhibit "A" and a certificate of mailing the
Notice of Intent to take a Default Judgement is attached hereto as
Exhibit "B".
DATE: MARCH 8, 1996
, ESQUIRE
laintiff
PA 17011
MONROE TOWNSHIP,
Claimant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
96-430 CIVIL TERM
VS.
WILLIAMS GROVE, INC.,
Owner
TO: Williams Grove Inc., and
John B. Fowler, III, Esquire
Fowler, Addams, Shughart & Rundle
28 South pitt Street
Carlisle, PA 17013
DATE OF NOTICE: February 2~ 1996
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS FROM
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 FIND OUT WHERE YOU CAN GET LEGAL HELP:
Cumberland County Court Administrator
Cumberland County Courthouse
1 Courthouse Square
CarliSle, PA 17013
717-240-6200
717-697-0371
. ,.'
By:" .' .1
J S D. ESQUIRE
Attorney 0 Plaintiff
One West Main Street
Shiremanstown, PA 17011
717 737-8761
uma1 "A"
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.
CBRTIPICATB OP SBRVICB
I, James D. Bogar, Esquire, hereby certify that 1 am this day
serving the foregoing Notice as required by Pa. R.C.P. 237.1 upon the
following named individual this day by depositing same in the United
states Mail, First Class, postage prepaid, at Shiremanstown, Pennsyl-
vania, addressed as follows:
Williams Grove, Inc.
One Park Avenue
Mechanicsburg, PA 17055
John B. Fowler, III, Esquire
Fowler, Addams, Shughart & Rundle
28 South Pitt Street
carlisle, PA 17013
Attorneys for Williams Grove, Inc.
Date: February 23. 1996
r, Esquire
:......-,~
CERTIPICATB OP NAILING
I, James D. Bogar, Esquire, hereby certify that a copy of the
Notice of Intent to take a Default Judgment was served upon
Williams Grove, Inc., and its counsel, John B. Faller, III, on
February 23, 1996, by United states Mail, First Class, postage
prepaid, at Shiremanstown, pennsylvania. I further certify that
counsel for Williams Grove Inc. received the Notice of Intent to
take a Default Judgment and that Williams Grove Inc. is not opposed
to the entry of a default judgment as indicated by the attached
correspondence dated February 27, 1996.
DATE I MARCH 8, 1996
B4~
J S D. AR, ESQUIRE
Attorney Plaintiff
One West Main street
Shiremanstown, PA 17011
717 737-8761
EXHiBiT 'I e,1I
....-'-\o'.~+~'4-~
FOWLER, ADDAMS, SHUGHART" RUNDLE
ATTORNEYS AT LAW
P.O. BOX 208
28 SOUTH PITT STREET
CARLISLE. PENNSYLVANIA 17013.0208
JOHN '0 'OWL.... UI
WILLIAM A. ADDAM'
MICHAIL R. RUNDLI
"ICIAL COUMln
GALl Po IHUGHART. .....
TELEPHONE 17' 71 241.8300
FAX 17171 24t.IU4
paWLIK, ADD AM' . IHUGHA"T
11'71.'11'1
0' CO UN ilL
HONORAIU DALI P. tHUGHA"T
Febr.uary 27, 1996
James D. Bogar, Esq.
One West Main street
Shiremanstown, PA 17011
RE: Monroe Township v. Williams Grove, Inc.
Writs of Scire Facias
96-430 civil Term, 96-437 civil Term
and 96-438 Civil Term
Dear Jim:
Thank you for your letter of February 23, 1996. As requested,
I filed the three Praecipes for entry of appearance and return
time-stamped copies of each Praecipe.
since the above Writs were simply filed to obtain default
judgments on municipal tax claims previously filed in Cumberland
county against my client, which claims it did not contest, my
client neither intends to contest the final default judgments
nor opposes the entry of the same.
Thank you for providing me with copies of the documents
pertaining to these matters and for your courtesies to me
and my client.
Very truly yours,
FOWLER, ADDAMS, SHUGHART & RUNDLE
JBF,III/mp
cc: Williams Grove, Inc.
.- 0-#11,).
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CBRTIPICATB OP 8.R~xga
I, Jame. D. Bogar, Esquire, hereby certify that I am this day
serving the foregoing Praecipe for Entry of Default Judgment as required
by the rule. of court upon the following named individual this day by
depositing same in the United states Mail, First Class, postage prepaid,
at Shireman.town, Pennsylvania, addressed as followsl
John B. FOWler, III, Esquire
Fowler, Addams, Shughart & Rundle
28 South Pitt Street
Carlisle, PA 17013
Attorneys for Williams Grove, Inc.
Date I MARCH 13, 1996
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MONROE TOWNSHIP, . IN THE COURT OF COMMON PLEAS OF
.
Claimant . CUMBERLAND COUNTY, PENNSYLVANIA
.
vs. .
.
96-430 CIVIL TERM
WILLIAMS GROVE, INC. , .
.
Owner . (No. 30772 M. L. D. 1991)
.
PRAECIPE ~OR SATIS~ACTION O~ JUDGMENT
TO THE PROTHONOTARY:
LAWRENCE E. WELKER
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
Kindly mark the judgment recorded against Williams Grove,
Inc., in the above-captioned matter, SATISFIED.
DATE: June 5, 1996
B
SOLICITOR
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MONROE TOWNSHIP,
vs.
. IN THE COURT OF COMMON PLEAS OF
Claimant CUMBERLAND COUNTY, PENNSYLVANIA
WILLIAMS GROVE, INC., NO.,:i N MUNICIPAL LIEN DOCKET 1991
Owner
acs-y3f) e;4
MUNICIPAL 'X'
AND NOW, comes Monroe Township, of 1220 Boiling Springs Road,
Mechanicsburg, Pennsylvania, by its Solicitor, James D. Bogar, Esquire,
and files the following municipal tax claim against Williams Grove,
Inc., owner of all that certain tract of land including improvements
thereon, owned by Williams Grove, Inc., and described as follows:
1 Park Avenue
Mechanicsburg, PA
Tax Property Map: 22-11-0278
Parcel Number: 031
Cumberland County Recorder of Deeds Office,
Deed Book "L", Volume 24, Page 747, and
Deed Book "D", Volume 20, Page 88
for delinquent amusement/admissions taxes levied and assessed from May
1988 through and including September 1990. Said amusement/admissions
taxes were levied and assessed pursuant to Monroe Township Ordinance
No. 4, 1968, same being known and cited as the "Township Amusement Tax
Ordinance". Attached hereto and incorporated herein is a statement of
the amusement/admissions taxes so levied and assessed with an indica-
tion of the amount thereof, said statement being a true and correct
copy of the Notice of Assessment forwarded to Williams Grove, Inc.,
from Monroe Township, which sum of $19,560.04 was duly assessed against
Williams Grove, Inc., and its property on October 25, 1991 and for
which sum with interest, penalties and costs, a municipal lien is
claimed against the above-described property and premises in accordanc(
with the Act of May 16, 1923, P.L. 207, as amended, (53 P.S. Section
,7102 et,seq.).
DATE: November 29, 1991
MONROE TOWNSHIP
By 4/au / 4'
JaMes D. Bogilrl Esquire
Solicitor for\ onroe Township
7.) )r),0 17(i:
SHERIFF'S RETURN
COMMONWEALTH OF PENNSYLVANIA:
COUN'T'Y OF CUMBERLAND
Monroe Township
VS
Williams Grove, Inc.
In The Court of Common Pleas of
Cumberland County, Pennsylvania
No. 30772 Civil Term 1991
Municipal Tax Claim
Timothy Reitz , Shertiffxor Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law, says,
that he served the within
Municipal Tax Claim
upon Williams Grove, Inc. , the defendant, at 9:15 o'clock
A .M. EST /X3, on the 04 day of December , 1991at
1 Park Avenue, Mechanicsburg
Pennsylvania, by handing to
, Cumberland County,
Erenz Saluti, Book Keeper and adult in charge
at time of service
a true and attested copy of the Municipal Tax Claim
and at the same time directing her attention to the contents thereof and
the "Notice to Plead" endorsed thereon.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
14.00
5.50
2.00
21.50 Pd. by Atty.
12.05-91
Sworn and subscribed to before me
this ! day of
19 9/ A.D.
. X.,0/R7
Prothonotary
So answers:
R. Thanas Kline, Sheriff
by ---.
Deputy Saeriff /
1 JAM ES D. BOGAR
1 ATI1OI1NEY AT
r, ‘A•liST MAIN Si NEE"(
SHMEMA TOWN. PENNSYLVANIA 17011
October 25, 1991
Williams Grove, Inc.
1 Park Avenue
Mechanicsburg, PA 17055 I
Attention: Irene Saluti
RE:
Dear Ms. Saluti:
TELEPHONE
(717) 737-8701
1ELECOPIER
(717) 737-2000
Al fC?9
• 96 Ci
i1(_;542' S'co,2-L
L'94,
NOTICE OF ASSESSMENT pursuant to
Monroe Township Amusement Tax
Ordinance No. 4 of 1968
am writing to you on behalf of Monroe Township and it's
Treasurer relative to the Monroe Township Amusement Tax. Please
refer to my letter to you of June 5, 1991.
As you are aware, Greenawalt & Company, P.C., auditors for
Monroe Township, conducted a review of the various Monroe Town-
ship Amusement Tax Returns and other pertinent information
relative to Williams Grove, Inc. for the period from May 1988 to
and including September 1990.
Based upon the audit, Greenawalt & Company, P.C., has
determined that the amount of $19,220.04 is due and payable by
October 31, 1991. The exact computations including tax due.and
penalty for these periods, all in accordance with the Monroe
Township Amusement Tax Ordinance, are enclosed herewith, marked
Exhibit "A" and made a part of this letter. The audit was
performed due to the failure of Williams Grove, Inc. to file the
required reports and other information in accordance with the
Monroe Township Amusement Tax ordinance. In addition, Monroe
Township was of the belief that the amount due and owing on
account of amusement taxlwas not properly stated or had been
mistakenly stated and improperly remitted. Monroe Township's
belief in this regard was substantiated by the audit.
I
Based upon the above, it has been determined by the Monroe
Township Treasurer that an assessment be issued against Williams
Grove, Inc. and the principals of that corporation, for the total
amount of $19,560.04. This assessment consists of the above -
referred to amount of $19,220.04, same constituting the amount
due for amusement tax penalties and interest all under the
is. Irene saiuri
October 25, 1991
Page 2
tvlui) lq(?
Ordinance, along with the!cost of the audit performed by
Greenawalt & Company, P.C., said cost being in the amount of
$340.00. Please note that said assessment, constituting amuse-
ment tax due, including penalty and interest, and the cost of the
assessment, is through October 31, 1991. Please note that the
assessment will increase due to additional interest and penalty
if full and complete payment is not made by October 31, 1991.
Please note that the interest that will be due and owing will be
in the amount of ten (10%) percent, all in accordance with the
Municipal Lien Law, 53 P.S. §7143. In addition, Monroe Township
will seek recovery for costs advanced on account of attorney's
fees and other additionalicosts, all as allowed for under the
Municipal Lien Law.
This letter will constitute written notice of the assess-
ment, as referred to hereinabove, in the amount of $19,560.04.
This assessment fixes and;determines the amusement tax due unless
Williams Grove, Inc. and/or its principals, files an appeal in
writing to the Board of Supervisors of Monroe Township within
thirty (30) days of the date of this Notice. As such, you have a
right to request a hearing before the Board of Supervisors. If
you request a hearing, same will be held in accordance with the
provisions of Ordinance No. 4 of 1968. Ordinance No. 4 of 1968
also provides for criminal penalties for ordinance violation.
I would like to note and specifically advise that the audit
conducted by Greenawalt & 'Company, P.C. and this Notice of
Assessment does not include and accordingly does not cover and
make an assessment for any and all amusement tax due or any other
license or registration fees due to Monroe Township on account of
the activities conducted by Recreational Enterprise Service Team,
Inc. of Camp Hill, Pennsylvania. According to information
furnished to our auditors,by you, Recreational Enterprise Service
Team, Inc., beginning in the 1988 operating season, operated
games at Williams Grove, Inc. on a fee basis. Accordingly, it is
requested that you provide to Monroe Township, within ten (10)
days from the date of this letter, a full and complete copy of
the contract or other arrangement by and between Williams Grove,
Inc. and the Recreational Enterprise Service Team, Inc. from the
1988 operating season to the present, as well as a full and
complete accounting of any and all receipts and the like
generated by Recreational Enterprise Service Team, Inc.
Monroe Township looks forward to having this matter resolved
October 25, 1991
Page 3
/1:1) . I)L)
-?`?
within the mandates of Ordinance No. 4 of 1968 by receiving from
Williams Grove, Inc. the amount of $19,560.04 as soon as
possible. Please be advised that Monroe Township has no choice
but to move to protect its interests in this matter.
Vey truly yours,
7 kvo
JAMES D. Oe R, Solicitor
Monroe Township
JDB/cb
Enclosure
cc:. Monroe Township Board of,Supervisors
Certified Mail No. P 979 078 396
Regular Mail
Hay, 1988
June, 1988
July, 1988
August, 1988
September 1988
Apr i l , 1989
Hay, 1989
Julie, 1989
July, 1989
AuyusL, 1989
;epte nber-, 1989
Hay. 1990
WNW, 1990
July, 1990
Auqusl., 1990
September, 1990
Paid to date
Tax
$ 375.00
414,70
1,299.50
1,645.52
1,030.73
190.48
238.57
922..91
1,567.27
2_,703.37
718.85
$ 497.25
770.64
2,151.2.1
1,906.03
1 347_80
X17 779.83
Due and payable by October 31, 1991
Penalty Total
$ 18.75
103.68
87.26
411.38
257.68
47.62
23.86
230.73
391.82
675.84
179.71
$ 86.19
64.90
537.80
476.51
_336_96
$3,930.69
1''Yi.iI13J.T "A"
$ 393.75
518.38
1,386.76
2,056,.90
1,2.88.41
238.10
2.62.43
1,153.64
1,959.09
3,.379.21
898.56
$ 583.44
835.54
2,689.01
2,382.54
_1,684.76
21,710.52
2490.48
$19,220.04
No, .36 7 > > I u.) 05'1
PS Form 3800. June
RECEIPT FOR CER I Ir"IED MAI
NO INSURANCE COVEHA.' ) «PVlt;E 1)
NUE FOR )Ni ERNAUONAI '044
(See RevetSP)
r i
to AZTfENTION : IRENE SAL -0 ' I
WILLIAMS GROVE
1 PARK AVENUE
, i 7Ir' (�I•
MECEIANICSBURG PA 17055
',i•r•(,.II 1)f'hVI'ry F. r!
^_.
Et, ,Ir•?,•ii t)Pir.'ry FPC
SENDER: Complete Items 1 end 2 when additional services are desired, end complete items
. 3 end 4.
Put your address In the "RETURN TO" Space on the reverse side. Failure to do this will prevent this
card from being returned to you. he return receipt fee will provide you the name of the person delivered
to and the date of delivery. For a tions fees the following
services ere available. Consult postmaster
2. 0 Restricted Delivery
(Extra charge)
for fees and check boxiest for additional servicels► requested.
1. 0 Show to whom delivered, date, and addressee's address.
(Extra charge)
3. Article Addressed to:
ATTENTION: IRENE SALUTI
WILLIAMS GROVE INC
1 PARK AVENUE
!':iECHANICSBURZ PA 17055 .
4. Article Number
P 979 078 396
Ire of Service:
Registered
1 Certified
• Insured
■ COD
■ Express Mall • iftttarc endise
Always obtain slgnature.df add; kee
or agent and DATE DELIVEtiEII. r G
\
5. Signature — Address
X
8. Addressee's
requested and
dross if -O
paid) f,` P
. 1921
6., nature — Agent
�D&Ive\ry
7.
r
PS Form 3811, Mar. 1988 * U.S.G.P.O. 1988-212-885
DOMESTIC RETURN RECEIPT
//. 30 !T1L0)C
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