On December 11, 2021 a
Clerk Order
was filed
involving a dispute between
Stormwater Authority Of The City Of Chester,
and
Mccarthy, Christopher James,
for Civil NR - Municipal Lien - Sewer
in the District Court of Delaware County.
Preview
efile_12-09-2021_DY4_ 21-58214-0 _KLO
21-58214-0/DY4/KLO
PORTNOFF LAW ASSOCIATES, LTD. ATTORNEY FOR PLAINTIFF
BY: MICHELLE R. PORTNOFF, ESQUIRE ATTORNEY ID 45163
P.O. BOX 391
NORRISTOWN, PA 19404
(866) 211-9466
Stormwater Authority of the City of Chester : IN THE COURT OF COMMON PLEAS
Plaintiff
vs. : DELAWARE COUNTY, PA
Christopher James McCarthy
Defendant(s) : NO.
: IN REM
MUNICIPAL CLAIM
Stormwater Authority of the City of Chester hereby files a lien for non-payment of
stormwater fees for the period from August 2018 through May 2021 duly assessed against the
following owners and described properties in accordance with Resolution of Stormwater
Authority of the City of Chester, authorizing the fee schedule which is attached hereto, to be
imposed upon the debtor.
I certify that this filing complies with the provisions of the Case Records Public Access
Policy of the Unified Judicial System of Pennsylvania that require filing confidential information
and documents differently than non-confidential information and documents.
OWNER NAME AND
LAST KNOWN MAILING ADDRESS PROPERTY AMOUNT
Christopher James McCarthy 1222 Crosby Street $838.54
1222 Crosby Street Chester, Pennsylvania
Chester, PA 19013-3913 Tax Parcel No. 49-02-00817-00
Respectfully submitted,
PORTNOFF LAW ASSOCIATES, LTD.
Date: December 9, 2021 BY: /s/ Michelle R. Portnoff
MICHELLE R. PORTNOFF, ESQUIRE
Attorney for Plaintiff
Fee Schedule
ACTION COLLECTION FEES
$40.00 per notice, plus applicable
Prepare and Provide Notice Pursuant to 53 PS § 7106
postage
Handling fee for returned check Bank Charge, if any
Bookkeeping fee for payment plan of 3 months or less $25.00
Bookkeeping fee for payment plan of more than 3 months $50.00
Guaranteed Payoff Fee $25.00
ACTION ATTORNEY FEES
Initial review and sending first demand letter $175.00
File lien and prepare satisfaction $250.00
Prepare Writ of Scire Facias $250.00
Obtain re-issued Writ $175.00
Prepare and mail letter under Pa. R.C.P. §237.1 $50.00
Prepare Motion for Alternate Service $250.00
Prepare Praecipe to Amend $50.00
Prepare and present Motion to Amend $200.00
Obtain vehicle identification number (VIN) for mobile home $100.00
Prepare Motion to Consolidate Claims $250.00
Prepare Motion to Add United States as Defendant $175.00
Prepare Pre-Trial Memorandum $200.00
Prepare Motion for Judgment for Want of Sufficient Affidavit of
$175.00
Defense pursuant to 53 P.S. §7271
Prepare Default Judgment $175.00
Prepare Writ of Execution $800.00
Attendance at sale; review schedule of distribution and resolve
$400.00
distribution issues
Continue sheriff sale $50.00
Prepare Petition for Free and Clear Sale $400.00
At an hourly rate between
Services not covered above
$75.00-$275.00 per hour
There may also be added to a delinquent account the costs, expenses and fees incurred in collection such as, but
not limited to, postage, title searches, court fees and sheriff fees. Additionally, should a lien be filed, interest in
accordance with 53 P.S. § 7143 of the Municipal Claims and Tax Liens Act will begin to accrue on the date of
the filing of the lien and will continue to accrue on a daily basis, increasing the amount of the balance due.
The collection fees and the attorney fees listed above will be assessed only if the corresponding action is
performed. If legal proceedings had begun prior to the mailing of this letter, one or more of the actions listed
above may have been performed and the corresponding fee(s) may have been assessed prior to the date of this
letter.
Stormwater Authority of The City of Chester
21-58214-0/DY4/KLO
PORTNOFF LAW ASSOCIATES, LTD. ATTORNEY FOR PLAINTIFF
BY: MICHELLE R. PORTNOFF, ESQUIRE ATTORNEY ID 45163
P.O. BOX 391
NORRISTOWN, PA 19404
(866) 211-9466
Stormwater Authority of the City of Chester : IN THE COURT OF COMMON PLEAS
Plaintiff
vs. : DELAWARE COUNTY, PA
Christopher James McCarthy
Defendant(s) : NO.
: IN REM
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the Municipal Claim and
fee schedule in this matter was served upon:
Christopher James McCarthy
1222 Crosby Street
Chester, PA 19013-3913
by first class United States mail, postage pre-paid on December 10, 2021.
/s/ Kiyah L. Owens
KIYAH L. OWENS
Legal Assistant
Dated: December 10, 2021
Document Filed Date
January 14, 2022
Case Filing Date
December 11, 2021
Category
Civil NR - Municipal Lien - Sewer
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efile_12-09-2021_DY4_ 21-58214-0 _KLO 21-58214-0/DY4/KLO PORTNOFF LAW ASSOCIATES, LTD. ATTORNEY FOR PLAINTIFF BY: MICHELLE R. PORTNOFF, ESQUIRE ATTORNEY ID 45163 P.O. BOX 391 NORRISTOWN, PA 19404 (866) 211-9466 Stormwater Authority of the City of Chester : IN THE COURT OF COMMON PLEAS Plaintiff vs. : DELAWARE COUNTY, PA Christopher James McCarthy Defendant(s) : NO. : IN REM MUNICIPAL CLAIM Stormwater Authority of the City of Chester hereby files a lien for non-payment of stormwater fees for the period from August 2018 through May 2021 duly assessed against the following owners and described properties in accordance with Resolution of Stormwater Authority of the City of Chester, authorizing the fee schedule which is attached hereto, to be imposed upon the debtor. I certify that this filing complies with the provisions of the Case Records Public Access Policy of the Unified Judicial System of Pennsylvania that require filing confidential information and documents differently than non-confidential information and documents. OWNER NAME AND LAST KNOWN MAILING ADDRESS PROPERTY AMOUNT Christopher James McCarthy 1222 Crosby Street $838.54 1222 Crosby Street Chester, Pennsylvania Chester, PA 19013-3913 Tax Parcel No. 49-02-00817-00 Respectfully submitted, PORTNOFF LAW ASSOCIATES, LTD. Date: December 9, 2021 BY: /s/ Michelle R. Portnoff MICHELLE R. PORTNOFF, ESQUIRE Attorney for Plaintiff Fee Schedule ACTION COLLECTION FEES $40.00 per notice, plus applicable Prepare and Provide Notice Pursuant to 53 PS § 7106 postage Handling fee for returned check Bank Charge, if any Bookkeeping fee for payment plan of 3 months or less $25.00 Bookkeeping fee for payment plan of more than 3 months $50.00 Guaranteed Payoff Fee $25.00 ACTION ATTORNEY FEES Initial review and sending first demand letter $175.00 File lien and prepare satisfaction $250.00 Prepare Writ of Scire Facias $250.00 Obtain re-issued Writ $175.00 Prepare and mail letter under Pa. R.C.P. §237.1 $50.00 Prepare Motion for Alternate Service $250.00 Prepare Praecipe to Amend $50.00 Prepare and present Motion to Amend $200.00 Obtain vehicle identification number (VIN) for mobile home $100.00 Prepare Motion to Consolidate Claims $250.00 Prepare Motion to Add United States as Defendant $175.00 Prepare Pre-Trial Memorandum $200.00 Prepare Motion for Judgment for Want of Sufficient Affidavit of $175.00 Defense pursuant to 53 P.S. §7271 Prepare Default Judgment $175.00 Prepare Writ of Execution $800.00 Attendance at sale; review schedule of distribution and resolve $400.00 distribution issues Continue sheriff sale $50.00 Prepare Petition for Free and Clear Sale $400.00 At an hourly rate between Services not covered above $75.00-$275.00 per hour There may also be added to a delinquent account the costs, expenses and fees incurred in collection such as, but not limited to, postage, title searches, court fees and sheriff fees. Additionally, should a lien be filed, interest in accordance with 53 P.S. § 7143 of the Municipal Claims and Tax Liens Act will begin to accrue on the date of the filing of the lien and will continue to accrue on a daily basis, increasing the amount of the balance due. The collection fees and the attorney fees listed above will be assessed only if the corresponding action is performed. If legal proceedings had begun prior to the mailing of this letter, one or more of the actions listed above may have been performed and the corresponding fee(s) may have been assessed prior to the date of this letter. Stormwater Authority of The City of Chester 21-58214-0/DY4/KLO PORTNOFF LAW ASSOCIATES, LTD. ATTORNEY FOR PLAINTIFF BY: MICHELLE R. PORTNOFF, ESQUIRE ATTORNEY ID 45163 P.O. BOX 391 NORRISTOWN, PA 19404 (866) 211-9466 Stormwater Authority of the City of Chester : IN THE COURT OF COMMON PLEAS Plaintiff vs. : DELAWARE COUNTY, PA Christopher James McCarthy Defendant(s) : NO. : IN REM CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the Municipal Claim and fee schedule in this matter was served upon: Christopher James McCarthy 1222 Crosby Street Chester, PA 19013-3913 by first class United States mail, postage pre-paid on December 10, 2021. /s/ Kiyah L. Owens KIYAH L. OWENS Legal Assistant Dated: December 10, 2021