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Original_4NF_1 1-4 5493 -0
`11-45493-0232-J-3 28Richard DelavegaBorough of Wil kinsb urg815 Glen n AvenueWil ki nsburgPennsy lvania00000 18,800 Boroug h of Wil kinsburg1 1-45493-01 1-45493-011-4 5493-111-45 493-211-454 93-311-454 93-411-4549 3-511-45493-6DelavegaDelavegaRichard DelavegaRichard DelavegaLorettaLorettaMr. and Mrs. Mr. and Mrs. Richard Delavega815 Glenn Avenue8 15 Glenn AvenueWi l kin sburg0000 0206 Rust ic Lodge Road206 Rust ic Lodge Road206 Rust ic Lodge RoadApartm ent 13Apartm ent 13Apartm ent 13IndianaIndianaPA1570115 701m unicipal service fees and real estate taxesm unicipal service fees and real estate taxes550.40550.40550 .40550. 40550. 40550.4 0550.4 0550.40 1,440.3 5232-J-328 20104N F489 .90$13 79.85.0 0$0.00. 00$0.00 60.50.0 060.50 489.901 ,379.85 .00$0.0 0.00$0. 00.00.0 060.50 60.50.0 0.00.00. 00489. 901,379 .85.00. 00.00.0 0.00.00 Megan O. Iannacone307230Wi l kins burg@portnoff online.com 444.004 5.90
`
`11-45493-0/12-30199-0/13-26323-0/4NF/JAK
`
`
`
`
`
`
`
`
`
`Borough of Wilkinsburg
`Plaintiff
`
`vs.
`
`Richard Delavega
`Loretta Delavega
`Defendant(s)
`
`
`
`Property Address:
`815 Glenn Avenue
`Wilkinsburg, Pennsylvania
`
`Lot & Block No.: 232-J-328
`
`
`
`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PA
`
`Civil Division
`No.
`
`Entry of Appearance
`
`Filed on Behalf of Plaintiff,
`Borough of Wilkinsburg
`
`
`Counsel of Record for this Party:
`Megan O. Iannacone, Esquire
`Attorney ID 307230
`
`
`Portnoff Law Associates, Ltd.
`P.O. Box 391
`Norristown, PA 19404
`Phone: (866) 211-9466
`Fax: (484) 690-9301
`
`
`

`

`ATTORNEY FOR PLAINTIFF
`ATTORNEY ID 307230
`
`IN THE COURT OF COMMON PLEAS
`
`ALLEGHENY COUNTY, PA
`
`NO.
`
`IN REM
`
`
`
` :
`
`:
`
`:
`
`:
`
`11-45493-0/12-30199-0/13-26323-0/4NF/JAK
`PORTNOFF LAW ASSOCIATES, LTD.
`BY: MEGAN O. IANNACONE, ESQUIRE
`P.O. BOX 391
`NORRISTOWN, PA 19404
`(866) 211-9466
`
`
`Borough of Wilkinsburg
`Plaintiff
`
`vs.
`
`Richard Delavega
`Loretta Delavega
`Defendant(s)
`
`
`
`
`
`
`ENTRY OF APPEARANCE
`
`Kindly enter my appearance on behalf of Plaintiff, Borough of Wilkinsburg, in the above-
`
`captioned matter.
`
`
`
`
`
`
`Date:
`
`Respectfully submitted,
`
`PORTNOFF LAW ASSOCIATES, LTD.
`
` BY:
`MEGAN O. IANNACONE, ESQUIRE
`Attorney for Plaintiff
`
`
`
`
`

`

`11-45493-0/12-30199-0/13-26323-0/4NF/JAK
`
`
`
`Borough of Wilkinsburg
`Plaintiff
`
`Richard Delavega
`Loretta Delavega
`Defendant(s)
`
`vs.
`
`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PA
`
`Civil Division
`No.
`
`Tax Claim/Municipal Claim
`
`Filed on Behalf of Plaintiff,
`Borough of Wilkinsburg
`
`
`Counsel of Record for this Party:
`Megan O. Iannacone, Esquire
`Attorney ID 307230
`
`
`Portnoff Law Associates, Ltd.
`P.O. Box 391
`Norristown, PA 19404
`Phone: (866) 211-9466
`Fax: (484) 690-9301
`
`
`
`
`Property Address:
`815 Glenn Avenue
`Wilkinsburg, Pennsylvania
`
`Lot & Block No.: 232-J-328
`
`
`
`
`
`
`
`

`

`ATTORNEY FOR PLAINTIFF
`ATTORNEY ID 307230
`
`IN THE COURT OF COMMON PLEAS
`
`ALLEGHENY COUNTY, PA
`
`NO.
`
`IN REM
`
`
`
` :
`
`:
`
`:
`
`:
`
`11-45493-0/12-30199-0/13-26323-0/4NF/JAK
`PORTNOFF LAW ASSOCIATES, LTD.
`BY: MEGAN O. IANNACONE, ESQUIRE
`P.O. BOX 391
`NORRISTOWN, PA 19404
`(866) 211-9466
`
`
`Borough of Wilkinsburg
`Plaintiff
`
`vs.
`
`Richard Delavega
`Loretta Delavega
`Defendant(s)
`
`
`
`
`
`
`TAX CLAIM/MUNICIPAL CLAIM
`
`Borough of Wilkinsburg hereby files a lien for non-payment of municipal service fees
`
`and real estate taxes for the years 2010-2012 duly assessed against the following owners and
`
`described properties in accordance with Ordinance of Borough of Wilkinsburg, authorizing the
`
`fee schedule which is attached hereto, to be imposed upon the debtor.
`
`OWNER NAME AND
`LAST KNOWN MAILING
`ADDRESS
`Richard Delavega
`Loretta Delavega
`206 Rustic Lodge Road
`Apartment 13
`Indiana, PA 15701
`
`
`
`
`
`Date:
`
`
`PROPERTY
`815 Glenn Avenue
`Wilkinsburg, Pennsylvania
`Lot & Block No.: 232-J-328
`
`
`
`AMOUNT
`$1,440.35
`
`Respectfully submitted,
`
`PORTNOFF LAW ASSOCIATES, LTD.
`
` BY:
`MEGAN O. IANNACONE, ESQUIRE
`Attorney for Plaintiff
`
`
`
`
`

`

`
`
`Fee Schedule
`
`ACTION
`Prepare and Mail Legal Notice pursuant to 53 PS §7106
`
`COLLECTION FEES
`Not to exceed $50.00*
`
`ACTION
`Initial review and sending first demand letter
`File Lien and mail second demand letter
`Prepare Writ of Scire Facias
`Obtain Re-Issued Writ
`Prepare and mail letter under Pa. R.C.P. §237.1
`Prepare Motion for Alternate Service
`Prepare Default Judgment
`Prepare Writ of Execution
`Attendance at Sale; Review Schedule of Distribution and Resolve
`Distribution Issues
`Services not covered above
`
`ATTORNEY FEES
`$150.00
`$150.00
`$150.00
`$25.00
`$25.00
`$175.00
`$150.00
`$750.00
`
`$400.00
`
`At an hourly rate between
`$60.00-$225.00 per hour
`
`
`There shall be added to the above amounts reasonable out-of-pocket charges, costs, expenses and fees such as but not
`limited to postage, title searches, Department of Court Record’s fees, and Sheriff’s fees.
`
`The collection and attorney fees listed on the fee schedule will be assessed only if the corresponding action needs to be
`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.
`
`*Presently the charge for this notice is $35.00.
`
`Borough of Wilkinsburg
`
`
`
`
`

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