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Home My WebLink About00-00784 "~',l .,.J ~ , . ~'-- , i '~',', ALLFIRST BANK, Successor Dauphin Deposit Bank & Trust Company, to IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW _ I No. ';<000- 7,fr do: ( ~17 i I I. . ~ i Plaintiff vs. THE NEW CUMBERLAND AGENCY, INC. , Defendant CONFESSION OF JUDGMENT Pursuant to the authority contained in the warrant of attorney, a copy of which is attached to the Complaint filed in this action, I appear for the Defendant and confess judgment in favor of the Plaintiff and against the Defendant as follows: Principal - Interest to 2/4/00 - Collection Fees (15% of unpaid principal and interest) - Total - $45,490.45 1,541.86 7,054.85 $54,087.16 Plus all future alcruing interest until paid in full ($11.68 per diem), a reasonable attorneys' commission, together with costs of suit and all other amounts, fees, and costs incidental to execution and levy. Prothonotary if C'~<___ ' ,,-,,",', 'f - r -'~ ,-~- . 0 -~-~-,,~ _, ALLFIRST BANK, Successor to Dauphin Deposit Bank & Trust Company, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff No. vs. THE NEW CUMBERLAND AGENCY, INC. , Defendant COMPLAINT 1. The Plaintiff is Allfirst Bank, a Maryland State Chartered Commercial Bank, successor to Dauphin Deposit Bank & Trust Company, with an office located at 305 West Chesapeake Avenue, 4th Floor, Towson, Maryland 21204. 2. The Defendant, The New Cumberland Agency, Inc., is a Pennsylvania corporation with an office located at 156 Bridge Street, New Cumberland, Cumberland County, Pennsylvania 17070. 3. On February 15, 1996, the Plaintiff loaned to the Defendant the sum of Fifty Thousand Dollars ($50,000.00) as evidenced by a demand Commercial Loan Note Line-of-Credit, a true and correct copy of which is attached hereto as Exhibit "A" and incorporated herein by reference. 4. Said Note and debt have not been assigned. 5. Judgment has not been entered on said instrument in any jurisdiction. , " II 'I' -. 6. Defendant is currently liable to Plaintiff as follows: Principal - Interest to 2/4/00 - Collection Fees (15~ of unpaid principal and interest) - Total - $45,490.45 1,541.86 7 054.85 $54,087.16 Plus all future accruing interest until paid in full ($11.68 per diem), a reasonable attorneys' commission, together with costs of suit and all other amounts, fees, and costs incidental to execution and levy. 7. Judgment is not being entered by confession against a natural person in connection with a consumer credit transaction. WHEREFORE, Plaintiff requests that judgment be entered in favor of the Plaintiff, Allfirst Bank, successor to Dauphin Deposit Bank & Trust Company, and against the Defendant, The New Cumberland Agency, in the amount of Fifty-Four Thousand Eighty- Seven Dollars and Sixteen Cents ($54,087.16), plus all future accruing interest until paid in full ($11.68 per diem), a , ,I reasonable attorneys' commission, together with costs of suit I "~I and all other amounts, fees, and costs incidental to execution and levy. By: MARC I.D. #55774 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 Attorney for Plaintiff - 2 - 1/ L_ AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA: ss. COUNTY OF LEBANON Vivian P. Merenbloom, Vice President, of Allfirst Bank, being duly sworn according to law, deposes and says that she has authority to sign this Affidavit on behalf of the Allfirst Bank and that the facts set forth in the foregoing Complaint are true and correct to the best of her knowledge, information and belief; and that the copy of the Commercial Loan Note Line-of- Credit, Exhibit "A" attached to the Complaint, is a true and correct copy of the original which is held in the files of the Plaintiff and which was executed and delivered by the Defendant to Plaintiff. ALLFIRST BANK By: urn UlA P AltJ&uh[OD/lA Vivian P. Merenbloom Vice President Sworn and this L\~ 2000. subscribed ~o before day of ~... ",,,,-<,,, \ me: C::;,,""'Q.... ,\\.~ \," d .o",,"""'-~ Notary Publil:: ~'\ tc"",, ~'<;'<;"Oh (", ~\<.<;.\ W\O,\ 0\ L ......"t'. ,.. _____ . ~~,L __ _...__ .J!6w ~Ufl?619"/.-/I/J Cj Commercial Loan Note Line 01 Credit 'j GE-J Cj;' .-,,,...... o (1;!-.'t-7/J7- Oeo/ Dauphin Deposit Bank and rust Company Membe. fDle. _.AF, $ 50.000.00 Date/&,6, /5. /9Y''::: , The Undersigned, jointly and severally, promise to pay to the order of Dauphin Deposit Bank and Trust Company (the "Bank") or Its Assigns at any of its bank offices Fi fty t n011!'101'1nr'1 ::InCl 00 /100 ********************* Dollars, to be paid as follows: Principal payable On DPm:mrl At R rRt~ pr::!r ;:mmlffi PqJ1:11 tn thp n:l1Iphin nppn~it fu:al'lj:> 1?AI-O At:! in pf'fpI"'t- f'rnm timA tn t;m/3 pll1<:! %%. Interest shall he calculated on the basis of the actual number 01 daY' In the then current calendar year dlvlded by 360. Both principal and lntelesl are payable In lawlul money or lhe United S1'll88 of America at any olflce of Bank In Immediately allailable fund8. PREPAYMENl. This note may be prepaId In whole or In part at any Ume at !he opllon of Undersigned without premIum or penalty. Each prepayment shall be applied f1rsllo in. terest, "any, IMn due Bnd then to principal. srATEMENrcJF ACCOUNr. The Bankwlfl fumfsll the Borrower with a statement of accounl on a perIodic basis. Each and eVllfY efatement o(8000unl shall be finel, conclusive end binding upon the Undersigned In all respects as to the outstanding balance 01 princIpal and as to all loana, fll8fl, Inlerest, charges, paymenls, receipts, balances, and all other matters renacted therein unless the Borrower, within len (10) days after the posling thereof In the Unlled Slates mall, shall gIVe nollce to the Bank In wrmng of any obJec. t~ns which the Undersigned may have to any such statement of aocol.lnl; and In such eVllnl, only lhose Ilems expressly objected to In such wrItlen notice shall be consldered to be disputed by the UndersIgned and all other 1I9ms shall be bIndIng. SECURITY. Ai security for Ihe payment of this note and foJ the payrnenl,. pllrformance ami discharga 01 all other present or luIura Indebtedness. obllgaUons and undllrtakings Qndlvldual"jolnt,eever8I, direct, contIngent or otherwise) of lhe BtlITOW9r to or for the benelil of the Bank whether arl9lng dlrecUy ICl the Bank under this note or Under any other agreement, promissory note or undertakIngs now eXlsllng or hereinafter entered by the Borrower 10 the Bank. The UndllTSigned hereby asslgn8 and Ir8nsfers to and pled1les with the Bank end grants the Bank e sacurlty lnlerest In lhe following proporty: With Interest AR RPt forth in flp-cnrity AgrppmpntR ~..pnpr:<ll :<Inn Tnvpnt'nry :<Inn At"'t"'rnmh:! 'Qot"'o;'nlhlo nRtpn ~//,;f" /9'~ COUA7E'RAL. The term "Collateral" as used hereIn mean8 all oIlhs forogolng property, together wllh all property Inlere81s 01 any nature wh8looever ollhe Undersigned, or any oIlhem, new (If herBlnaft6r In fils possession or or ass/grr6d or ht'pothscared ro the Sri for 8lIf purpose, including w1Ulout llmltaUon any pIftperty II8fed sbove and any balanca or share, belongIng to the Undersigned or any of tham, 01 any deposIt, agency or othsr accounts wllh Ihs Bank end any olher amounts WhIch may be owing Irom lime 10 time by IhEl Bank to the Underslgnsd or eny of them. The Undersigned agms IIlallhe Bank shell have a lien upon and security Imerest In Ihs Collateral, and an rights in con. nectlon wlth thE' Collateral, 10 aecurB the paymenl of this nole end any renewals, BIIlensron8 and modlDcallon8 lherlKlland all other exletlng nablliUes, whether absolute or con- tingent, of the Undersigned, or any of thsm, to the Bank, 8ald note and any renewal8, extenslon8 and modlDcsllons thereof and Mid other i1sblllllrts being herell'lafler oollectlvely referred 10 lIS Ihe "Uabllllles". If any other UablOUes are in exl8tence when thIs note Is paId, then, notwlthslandlng the surrender 01 this nole, the Bank may relaln the Collateral and shall haw with respect t1Ifu9W all I'lghts and rBnI8d/es avallab!& to If, including Ihoss herein granl8d 01 refS/red to, and a true ccpy of thls /l(IfS Bh8Il be Sufflclsnf proof of the rights granhd herein. SaId lien and aecurlty Inter. shall be Independent of any right of &et..olf Which Iha Bank may haVll. The Undersigned assumes full responsibility lor preservation of !he Collateral, Including laking any Slape necessary to preserve any rlght8 of the Undersigned, or any 01 them, or ths Bank In It against prior parties. II any pro- perty IndUded In the eoneteral 01' the valUe thereof shall at any lime bscome unsatIsfactory to.the Bank, the Undersigned shall withIn 24 houra alter demand and 8S the Bank may direct, dsliver, assign or hyp::lthecale to the Bank as part 01 the Collateral addillonal property which Is sallsfactory to ths Bank. RIGHTS OF flANK. In addlllon to all other rights granted hereIn or otherwi8e possessed by ii, the Bank shall haft the followIng tights, ssch or which may be exercIsed al any time without prior notice to or coru;ent 01 any of the Undersigned: Q) to pledgs or lransfer Ihl8 note s,nd any renewals, eklsnslons and modifications thereof, asslgnll1g lherewlth the Bank'a rights In the Collateral or any portion thereor, and any such pledgee or tlllNlleree shall have all the rlghls of ths Bank hereundar wllh respect to this note end any renewals, 9Xlenslona and modlflcal1on8 thereof and any ollhe Collateral so assigned Iherawllh, and lhe Bank shall be thereafter relieved from 1111 liability with resp8l::1 10 any of the Collateral s') uslgned; Qij 10 transfer the whole or'any part of the Collateral Into the nems of Itself or lis nominee; (IIQ 10 vole'the Collateral; (IY) 10 notIfy lhe persons obligated on BJ'Y of the Collalerallo make paymenl to the Bank 01 any amounts due or to become due thereon; (v) to take oonlrol of any proceeds of the Collateral; and (vi) 10 release or exchange any 01 the Conateral at any lime before or after maturity hereol. PAYMENT OF cosrs. In addttlon to Ihe principal and Interesl paymenls specified above, Ihs Undersigned shall pay to Ihe Bank; or any other holder hsreof, upon demand, all costs and expel1S89 QnellJdlng reasonable attorneys' fses and legal expsnses) which may ba Incurred by the Bank or such holder In lhe custody, preservation, use, operetlon. preparation for sale or saJe of the CoIlsteral or tho enforcement upon defaull of thIs nole. Said costs shalllnctuds reasonable altorneyg' faes and costs In bankruptcy pro- ceedings. Also Include fees Incurred for any legal actIon In relatIon to the loan lransaclion ~.e. being Joined In any ectlon between our borrower and a 3rd party). DEFAULTS. The UJHle~erl shall be In dBlauf! hereumfe.r vpon tm. OOCU1feme of any of the klllowlng e\l91lls: (El) fhe nOllpa)'mflnl when 0011' tA any alTlDWlI payaOla on SIIyof Ihe UabURtea, t)l' the failure of any Obligor to observe or perform any agreemenl of sny nalure whalllOever wllh Iha Bank (the term "Obngor" as used herein being meanllo In- clude the Undt1rslgned, and all persons secondarily liable on this nole or any renewals, elllen81orts, or modlncatlon thereof, such sa endorsers or guarantors): (bl If any Obligor Decornealnsoll'enl or makes an asslgnmenl for the benefit of creditors, or If any pellllon Ie filed by or against any Obligor under any provisIon of any law or slatule alleging Ihat such Ob1Jgor l!-Insofvsnl or unable to pay debts as they malure; (c) lhe entry or any Judgment agaInst any Obligor or the IssuIng Of eny ettachmenl or garnishment 8galn81any property of any Obligor or the occurrenCe 01 any change In the financIal cond1l10n of any Obligor which In Ihe sole Judgment of the Bank Is matsrially adverse; (dllhe dissolulion, m9JpeI. consolidation or rewganl2alkm 01 any QblJ9Di WhltH Is a corpo.ralJon or pa1'Inershlp; fe) the death of any Ob-ligM who Is e na.tIJlDI pelSOIl; ff) any Informs/loll harstofOlI1' or hereinafter funrished to the Bank by any Obl1gor In connecUon with the loan evidenced hereby or any guaranty 8hould be materlally.fslse; snd (g) the fallure 01 any Obligor to ll.lr. nlsh such llnarrelal and olher inforrnaliolt as the Bank may reasonably requast. ACCEI,.eRAT1ON AND ENFORCEMENT RIGHTS. Whenever the Undersigned shall be In derault es aforesaid, (1) unless the Banll ell1cts otherwIse, 1111;1 entire unpaid smounl or such oJ the L1e,billtles 88 ere not then due and payable shall bll<<lms ImmedIately due and payable without notice to or demand on any Obl1gor; and (2) the Bank mey as lIs op. lion lIXerclse 110m lime to lime any or all rIghts and remedies avatlable to II under Ihe Pennsylvania Unllorm Commercial Code or olherwlse avallllble 10 II, Including the right to dispoee of the Collaleraf at publfc or prlvale sale(s) or other proceedings, and the UndelSfgnsd agrees Ihat the Bank or its nominee may become the purchaser al any such 8819(s). The Ullderslgned waIves sll rlghllo stay of execution end exempl10n 01 property In any action to enforce any 01 ths Uabllilles. APPl1CAT10"i~OF COlLATERAL. Ths proceeds of any Collaleral received by lhe Bank; at any time before or after derault whether Irom sale of Collsteral or otherwise, may bo applied 10 or on account of the payment 01 such 01 the UablUUss and In SUCh order as ths Bank may elect. Eech 01 the Undersigned 10 the extent thai he has any right, !llIe or Inlerest In any of Ihe Coltaleral, walvss and releases any right to requfre the Bank 10 collect any ollhe Lfab1lilles from any of Ihe Cotlsleral under any theory of marshalling of assets, 01 cthelWlse, and specifically .auUtorlzss!he Bank to apply any of 1M Ccllal61alln which he has a righi, tll!& or Inlerest agaInsl any of the liabilities in any manner Ihat it may determine. JUDGMENT. The Undersigned does hersby authorlle and smpower any atlorney of any Court of Record 01 PennsylvanIa or elsewhers 10 appear for and enlel judgment egalnstthe Undersigned for Ihe above sum, wllh or wllhout declaration, with costs of 8ull. Including r90!somlble altorney's fees anti fess In bankruptcy proceeds, 11 any, release of elTOrs, Without stay 01 9XecuUon, and wlfh fiftesn (.15%) percent. added for coIlecllon lee8; ~"'~ ,. ('.or! further agree8 that real, personal or mixed property may be sold upon any Writ of execution as now or hereinafter provided by law or the Pennsylvania Rule!>' . i;oVllrnlng the enforcsment of Judgmsnls; snd the Undersigned hereby waives and relsases all relisf from any appralsemenl, stay or exemption laws of any.,. N hereafter enacted. If s copy hereol, verified by aflldavit, shall have been IIled Ih such proceeding, It shall not be nscessary 10 lile the original as a worrant or ,\. " ; h& Undersigned (and each ofihem, If more Ihan one,} hereby waives the right to an', slay of eltBCUllon and tha benefil of all 9Xemption laws now or hereInafter In effect Nc. IJlngle exercise of this warrsnt and power to confess Judgment shall be deemed 10 exI181ls1 thIs pOWer, whether or not any euch exertlse shall be held by any court to be invalid, vloll!ble or void, bullhle powsr shall conllnus undiminished and may be exercised from Ume to time as often BlIlhe Bank shall elect unlU all eums due hereunder shall haVll been paid In fun. MlSCEUAN.:OUS. Any rouure of the Bsnk 10 exercise any right hereunder shall not be OOllStrued as 8 waiver of Ihe right fa eJ<<trclse the SlImG or lIny other rigl1l at any olher tlms. lithe Undsrslgned conslst8 01 more than one pel'8On, 8uch persons shall be jointly and severalty neble hsreunder. Ths UndersIgned Inlends thle to be a sealed instrument and 10 be legally bound hel'8by. AlIl8sues arising hereUnder shall bs governed by lhe laws 01 Pennsylvania. WITNESS OR ATIEST: BOR110WER: N.m.!&;~ /&7 11~ ~ (SEAL) (SEAL) Npw {;llmMr1;:;nn Agpn~:y Tnt' (Name ollndMdual, Corporation or arln&rshlp) q.......(~~ Name pd TlUe \'RiO",>. (SEAL) 1 EXHIBIT "A JJ Name and Tllle 51fi Bridoe Street Address Name and Title -, I :r.: tTI z :;; ;:0 '" ::l ~ -< "T1 -I ~ '1-1 ~i'lO"~~GP SS.zOr:iiio; ~~~o~;;;m "" " :> >- 'J ';-.J :::::; = V> -I < ~ .If 0 .t:> -I ~ ~ tG 0 ?;; >. tTl ~ == ~ ~ ;:0 15 r r '<:J 9 ,c~ ) ') , ,) t~~ - w F .() ~ j E ~ (lr () ~ ~ ~ d (, 1,._1 '"'"1 FY' =::J B ..-' , ',"1 -nr:-f; f"i-'jr-; I '7::JI ~:bJ ~, ~~S ):.:;(~ ~ C) '-', ',,..-" 1". C,..' ~'- :1-\ ~;-l:~~' u ::;;.:.1 ~u ;< ~-;:J ::1' "V F $ .- .. ,,.) OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TO: The New Cumberland Agency, Inc. 156 Bridge Street New Cumberland, PA 17070 ALLFIRST BANK, Successor to Dauphin Deposit Bank & Trust Company, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. ~~ -71>,/ Ciozl '7iA.J 1 vs. THE NEW CUMBERLAND AGENCY, INC. , Defendant NOTICE Pursuant to Pa.R.C.P. Rule 236 please be advised that judgment by confession in the above proceeding was entered against you on ~~ I() ,2000, in the amount of: Principal - Interest to 2/4/00 - Collection Fees (15% of unpaid principal and interest) - Total - $45,490.45 1,541.86 7.054.85 $54,087.16 Plus all future accruing interest until paid in full ($11.68 perl diem), a reasonable attorneys' commission, together with costs of suit and all other amounts, fees, and costs incidental to execution and levy. Copies of all documents filed are attached hereto. lsja~A-h~Y2~ ' prothonot " __C' ,-,-.'<-,-,';. - '" -,,-~, ,,!,- ALLFIRST BANK, Successor to Dauphin Deposit Bank & Trust Company, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff c<..>,.('y~ vs. No. ..:IOao- ?-fj THE NEW CUMBERLAND AGENCY, INC. , Defendant PRAECIPE FOR ENTRY OF APPEARANCE TO: PROTHONOTARY Please enter the appearance of Marc A. Hess, Esquire, of the firm of Henry & Beaver LLP, whose address is 937 willow Street, Lebanon, Pennsylvania 17046 as attorney for Allfirst Bank the Plaintiff Dated: ,A...eJ"), g in the above-captioned matter. , 2000 By: RC A. E I.D.#55774 937 Willow Street P.O. Box 1140 Lebanon, PA 17042 (717) 274-3644 II ... ,..L.,,,~.-:- '- ~..;-, '~ -.\ -~ -.&jr~(- __Co. _~< _," o c ">- -off; rnn-, 2~:: 2:C- ~~2' r--C )5~ .?c< 5>c:: 2:: ::;i , m ',.:1 1", " !!~ 'I',' 11 I'i :1 II 'I " ;1 I <::::> <::) ..,., '''''''} C:?') o 'Tl .-[ r~!:i ;'"JJ ")~ +i? ~B~~ ~~-ll ') -- ;?:~ffi ~" s! ::0 "< <::) 3: "'- --,' 1. Article Addressed to: D.: Is delivery address differeT1t m 1 '? If YES, enter delivery address below: New cumberland Agency, Inc. 156~ridge street New cumberland, FA 17070 .~ Jo , ~ DAgen! o Addressee DVes DNo 3. Service Type ~ertffled Mall 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted,Delivery? (Extra Fee) 0 Yes 1" Z 531 608 942 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do not use for International Mail S' Sent to ee reverse New Cumberland A enc Street & Number 56 Brid e Street Post Office, Stale, & ZIP Code New Cumber1andr FA Postage $ Certified Fee 17070 .33 1. 40 Special Delivery Fee Restricted Delivery Fee ~ ~,,~ '"". 0) Return Receipt Showing to : Whom & Date DeU a. Retum Receipt S ng to <.. Date, & Addr 's o :g TOTALP CO> Postmal1< . 9 8 E o lL UJ 0.. -'-'~'" 102595-99-M-1789 - + "-'--",,-' ALLFIRST BANK, Successor to Dauphin Deposit Bank & Trust Company, Plaintiff vs. THE NEW CUMBERLAND AGENCY, INC. , Defendant ":J IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANI CIVIL ACTION - LAW No. 2000-784 Civil Term AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF LEBANON ss. I, Lisa I. Fox, of the law firm of Henry & Beaver LLP, do hereby certify that on February 11, 2000, I forwarded a true and correct copy of the Notice Under Rule 2958.1 of Judgment and Execution Thereon - Notice of Defendant's Rights by First Class United States Mail, Certified, Return Receipt Requested, to the Defendant, The New Cumberland Agency, Inc., at 156 Bridge Street, New Cumberland, Pennsylvania 17070. Said Notice was received by Defendant on February 14, 2000. Attached hereto and made a part hereof is the United States Postal Service Domestic Return Mail. for Certified Sworn and subscribed to before me: this 16th day of February, ,2000. ~, rf\JJ--~ ~ Notary Public NOTARIAL SEAL l TERESA MARIE SHAAK, Notary Public I M leb~n~n, Lebanon County ,t CommIssIon Ex _ jre~ Feb. 14, 2002_J II ~- ALLFIRST BANK, Successor to Dauphin Deposit Bank & Trust Company, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. J,ooo -IsH (1v; I T-e urL vs. THE NEW CUMBERLAND AGENCY, Ii'iJC., Defendant NOTICE UNDER RULE 2958.1 OF JUDGMENT AND EXECUTION THEREON NOTICE OF DEFENDANT'S RIGHTS To: The New Cumberland Agency, Inc. 156 Bridge Street New Cumberland, PA 17070 A judgment in the amount of: principal - Interest to 2/4/00 - Collection Fees (15% of unpaid principal and interest) - Total - $45,490.45 1,541.86 7.054.85 $54,087.16 Plus all future accruing interest until paid in full ($11.68 per diem), a reasonable attorneys' commission, together with costs of suit and all other amounts, fees, and costs incidental to execution and levy, has been entered against you and in favor of the Plaintiff without any prior notice or hearing based on a confession of judgment contained in a written agreement or other paper allegedly signed by you. The Sheriff may take your money or other property to pay the judgment at any time after thirty (30) days after the date on which this notice is served on you. You may have legal rights to defeat the judgment or to prevent your money or property from being taken. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT AND PRESENT IT TO A JUDGE WITHIN THIRTY (30) DAYS AFTER THE DATE ON WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS. 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: Central Pennsylvania Legal Services 7 North Hanover Street Carlisle, PA 17013 (717) 243-9400 By: C A. I.D. #55774 937 willow Street P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 Attorney for Plaintiff AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact the Court Administrator's Office at (717) 240-6200. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. - 2 - 1ilW~!l;m~Hd:>J~l!<l*""",,""'_d'..Ill!lll!!ollb!ill~~-<;Iillll'Ii:il!l.~~ ,~., ^ ~ -~,-......-....... ~~ .&. " "~ ltii -o;~\-_i rn(;-" z;n :z::c ~~ ~~:~ r::::-\",j ;'~~ 2~ ::;( C) C -".- ~ - C,j II C:1 C) -rj f"'q ':',0 () .'n ,~ J.) '.. >-1 .'"'1 '"j , () "(', -'.-..-n .--',...-. ~.~~,r{C~, ~ ~2: .,,-1