HomeMy WebLinkAbout00-08211
WAYNEF. SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
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PATRICIA MILLER RODE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
v.
: NO. oo-f.;t II CIVIL TERM
ROBERT B. PARK and
ALICE PARK,
Defendants
: CONFESSION OF JUDGMENT
CONFESSION OF JUDGMENT
Pursuant to the authority contained in the warrant of attorney, the original or a
copy of which is attached to the Complaint filed in the above-captioned matter, the
undersigned hereby appears for the Defendants and confesses judgment in favor of
Plaintiff and against Defendants, jointly and severally, as follows:
Principal
Interest to November 20, 2000
TOTAL
$27,635.37
785.92
$28,421.29
Date: November 21,2000
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Wayn F. Shade, EsqUire
Supreme Court No. 15712
53 West Pomfret Street
Carlisle, Pennsylvania 17013
Telephone: 717-243-0220
Attorney for Defendants
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WAYNEF. SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
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PATRICIA MILLER RODE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
v.
: NO. oo-f;;V I CIVIL TERM
ROBERT B. PARK and
ALICE PARK,
Defendants
: CONFESSION OF JUDGMENT
COMPLAINT
1.
PlaintiffP A TRICIA MILLER RODE is an adult individual who resides at 322
Hogestown Road, Mechanicsburg, Cumberland County, Pennsylvania 17050.
2.
Defendants ROBERT B. PARK and ALICE PARK are adult individuals whose
last known address is 319 West Main Street, Mechanicsburg, Cumberland County,
Pennsylvania 17055.
3.
On or about April 1 0, 1992, Defendants executed and delivered to Plaintiff an
Agreement of Sale, a copy of which is attached hereto and incorporated herein by
reference as though fully set forth.
4.
The purchase price for the retained client list as set forth in '\12 of said Agreement
of Sale was calculated by the parties hereto to be $86,642.
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WAYNEF. SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
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5.
Defendant Robert B. Park made ninety-one installment payments of principal and
interest on account of the aforesaid purchase price between January 15, 1993, and July 26,
2000.
6.
Defendants are in default by virtue of the failure to make payments due since the
payment of July 26, 2000, which was due on July 15, 2000.
7.
On September 25, 2000, Defendant Robert B. Park received written notice by
certified United States mail, postage prepaid, return receipt requested, of Plaintiffs
demand for the payment due August 15,2000.
8.
This judgment by confession is not being entered against a natural person in
connection with a consumer credit transaction.
9.
There has been no assignment of said Agreement of Sale.
10.
Judgment has not previously been entered on said Agreement of Sale in this or any
other jurisdiction.
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WAYNEF. SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
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11.
An itemized computation of the amount due Plaintiff is, as follows:
Principal
Interest to November 20, 2000
TOTAL
$27,635.37
785.92
$28,421.29
WHEREFORE, Plaintiff demands judgment against Defendants as authorized by
the warrant of attorney contained in said Agreement of Sale for $28,421.29 plus interest
from and including the date of this Complaint at the rate of eight (8%) percent per annum
as set forth in said Agreement of Sale and costs of suit.
Date: November 21,2000
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Supreme Court No. 15712
53 West Pomfret Street
Carlisle, Pennsylvania 17013
Telephone: 717-243-0220
Attorney for Plaintiff
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WAYNEF.SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
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The statements in the foregoing Complaint are based upon information which has
been assembled by my attorney in this litigation. The language of the statements is not
my own. I have read the statements; and to the extent that they are based upon
information which I have given to my counsel, they are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to
authorities.
Date: November /9, 2000
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AGIIEEJ1E!'J:I'__QF SI\[,I~
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THIS AGREEMEN'l', ma e tIns ~~ day of _~/'-
1992, by and among PIITRICIII MJI,L,ER RODE, Executrix of the Estate
of Ralph R. Rode, Jr., Deceased, of 322 lIogestown Road,
Mechanicsburg, Pennsylvania 17055, hereinafter referenced as
"Seller",
11 N D
ROBERT B. PARK of 403 Allendale ~~ay, Camp lIill, pennsylvania
17011, hereinafter referenced as "Buyer".
WITNESSETH:
Buyer ROBERT B. PARK is an accountant, qualified to practice
before the Internal Revenue Service of the United States of
America. Seller is the Executrix of the Estate of Ralph R. Rode,
Jr., Deceased, who was, prior to his death on January 3, 1992,
duly licensed to practice the accounting professiol1 in the
Commonwealth of Pennsylvania and before the Internal Revenue
service of the United States of America as a certified public
accountant. Prior to his death, Seller's decedent had an
established accounting practice in which Buyer was actively
engaged as a full-time employee, with offices located at Side 322
1I0gestown Road, Mechanicsburg, Pennsylvania 17055. Seller
desires to sell and Buyer desires to purchase the practice upon
the terms and conditions and for the consideration set forth
hereinbelow.
ALICE PARK joins herein to guarantee the obligations of
Buyer ROBERT B. PARK.
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1. Purchase and Sale. Buyer shall purchase from Seller and
Seller shall sell to Buyer the following:
(a) The files and records pertaining to the clients of
the accounting practice on the date of death of Seller's
decedent, and Buyer shall continue to provide services to
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such clients provided they desire to ~BUyer's
services; and r T r .-
(b) All other files, books, records, work papers,
furniture, fixtures, equipment, library and other tangible
assets of or pertaining to the accounting practice which
were located in the offices of the accounting practice on
the date of death of Seller's decedent; provided,
nevertheless, that such tangible assets shall not include
photographs, licenses, sentimental mementos and other items
of insignificant monetary value which were personal to
Seller's decedent and which will be removed by Seller from
the offices of the accounting practice prior to execution of
this Agreement.
2. Purchase Price. The total purchase price to be paid by
Buyer to Seller for the retained client list of the accounting
practice which is the subject of this Agreement will be
calculated as one hundred (100%) percent of the fees generated by
the practice from December 1, 1991, through November 30,1992,
from retained clients of the accounting practice on the date of
death of Seller's decedent. Fees generated shall be defined as
fees attributable to work done for the retained clients between
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December 1, 1991, and November 30, 1992. Buyer shall provide
Seller on or before December 15, 1992, with an accounting of the
fees generated by the retained clients of the accounting practice
between December 1, 1991, and November 30, 1992. The
consideration for the tangible assets of the accounting practice
shall be Thirteen Thousand and NO/100 ($13,000.00) Dollars. The
purchase of the assets, for the previously agreed upon price of
Thirteen Thousand and NO/100 ($13,000.00) Dollars, is to be
accomplished in the following manner:
$3,000 to be paid immediately upon complete agreement of the
terms of the sale. The balance of $7,000 to be paid by the end
of the year 1992, so that Park Financial Service can take
advantage of the IRS Code section 179 for this year. The
remaining balance of $3,000 will be paid in 1993 for the same
reason just stated.
The payment schedule is to be accomplished in the following
manner:
The purchase price for the retained client list shall be
payable in equal monthly installments of principal and interest
amortized over a period of ten (10) years at eight (8%) percent
simple interest per year commencing January 1, 1993. Buyer shall
have the privilege of paying as much or more than the required
monthly installment of principal and interest as desired,
provided that such excess payments be in the exact amounts of the
next succeeding installments of principal upon the amortization
schedule derived from the payment terms calculated in December of
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1992, payments of principal and interest to continue with the
next monthly payment as though there had been no prepayment with
the payments of principal and interest to be computed as though
the interest reflected upon said amortization schedule with
respect to each installment of prepaid principal have been paid
when due. The purpose of these requirements as to prepayments is
to avoid the necessity of recalculating an amortization schedule
with each excess payment of principal. other than these
requirements as to the amounts of prepayments, there shall be no
penalty for prepayment of all or any portion of the consideration
for this Agreement.
3. Time and Place of Sale. hlosin~ shall ?e held o~.~his
3,;}:-) ;/ol/Csloll1/1 /l{f'l fJ/('0/-n?7l('.3bllI"Yl V,IU"'T
Agreement at l-\y'vffiees et'Way'!'l~=f7""Shad-e,oESEJu--i:r..B.r- 8J..~bh
SrI', n\j T(')t-l.~n,shl r, l\llYl p~:I",'\C'\ l'ol In 1'-1, Il>~ n <'y/U<11\ in, 1/0-5 '6 (l n 'I h,'.$
t;.~Thtd~~;~"~rA~~t-er:t\~'~"'j ~~a~~",~~c'. \"' ~~t~r ''tT~~1
~ .._...f.<=l.ee..af the-'pa.Ftd:es bu1;-.in-::anv evant -ne later th::m ~:iJ
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30, ;un. f'
4. Assumption of Obliqations. As additional consideration
for the purchase and sale set forth in this Agreement, Buyer
shall, in addition to the total purchase price specified in
Paragraph 2 of this Agreement, assume and pay as they become due,
the amounts remaining unpaid on the obligations and accounts of
the accounting practice as of the close of business on January 2,
1992. seller shall indemnify and hold Buyer and the property of
Buyer free and harmless from any and all claims, losses, damages,
injuries and liabilities arising from or on account of the
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operation of the accounting practice or ownership of the property
of the accounting practice prior to January 3, 1992.
5. Representations. It is understood and agreed that this
Agreement is being consummated in contemplation of the successful
consummation of a Lease between Seller as Landlord and Buyer as
Tenant for the portions of the property at Side 322 Hogestown
Road, Mechanicsburg, Pennsylvania, which were being utilized for
the purposes of the accounting practice as of January 3, 1992.
In the event of failure of successful consummation of a mutually
satisfactory Lease, this Agreement shall be null and void. Buyer
agrees with and represents to Seller that all aspects of the
accounting practice and the property thereof have been inspected
by Buyer and that Buyer is entering into this Agreement as a
result of that inspection and not as a result of any
representations made to Buyer by Seller or Seller's decedent or
by any agent of Seller or Seller's decedent that are incorporated
in this Agreement.
6. Buyer shall be considered to be in default under this
Agreement in the event of failure to make any payment due for a
period of thirty (30) days after receipt of written notice
therefor. Time shall be of the essence of this Agreement with
respect to the required payments.
7. In the event of such default, this Agreement may, at the
option of Seller, be forthwith terminated and become absolutely
void without any right on the part of Buyer, or those claiming
under Buyer, to reinstate the same by payment or other removal of
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default. In the alternative, at the option of Seller, all
remaining payments due under the terms of this Agreement shall at
once become due and payable by Buyer together with costs of suit
and reasonable attorney fees. Seller may then, at the option of
Seller, among other remedies available to Seller, proceed by any
attorney to sign for Buyer or for those claiming under Buyer an
agreement for entering in any competent court an amicable action
and confession of judgment in ejectment of any term then past or
present against Buyer and all persons claiming under Buyer for
the recovery by Seller of possession of the within premises,
without any liability on the part of Seller or of the said
attorney, for which this shall be a sufficient warrant, and in
like manner, such attorney may file an agreement for entering in
any competent court an amicable action in confession of judgment
for all sums due under the terms of this Agreement~ or which may
at anytime become due under the terms of this Agreement or any
extension hereof, and so on from time to time as often as any of
said payments as aforesaid shall follow or become due or in
arrears, without any liability on the part of said Seller or said
attorney and Buyer does hereby release Seller for itself and
those claiming under it from all errors and defects whatsoever in
entering such actions, judgments or proceedings. No such
acceleration of the terms of this Agreement shall deprive Seller
of any remedy or action against Buyer or those claiming under
Buyer. It is further provided that Seller shall have the right
in any subsequent default or defaults to bring one or more
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amicable actions in the manner and form as hereinbefore set forth
and any previous confession of judgment shall not exhaust the
authority for the same herein nor deprive Seller of entering
judgment upon any future default. Acceptance by Seller of any
payments under the terms of this Agreement after default by
Buyer, or any failure of Seller to enforce any of the rights
herein reserved to Seller, shall not be considered a waiver of
the right to enforce any of the terms of this Agreement at
anytime; and all of the terms of this Agreement may be enforced
together or successively at the option of Seller.
8. Any notice or demand hereunder shall be sufficiently
given if delivered to the receiving party, personally or by mail,
at the office of the receiving party set forth herein. If by
mail; it shall be certified mail with return receipt.
9. This Agreement constitutes the entire agreement of the
parties hereto and supersedes any prior understandings or written
or oral agreements between the parties with respect to the
subject matter of this Agreement.
10. This Agreement may be amended or modified only by a
written instrument signed by both parties,
11. This Agreement will be governed by and will be
construed in accordance with, the laws of the Commonwealth of
Pennsylvania in effect at the date of execution hereof.
12. The provisions of this Agreement shall be binding upon
and inure to the benefit of the parties hereto and their
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respective heirs, executors, administrators, successors and such
assignees and sublessees as may be permitted hereunder.
IN WITNESS WHEREOF, the parties hereto have hereunto set
their hands and seals, intending to be legally,bound hereby, the
day and year first above written.
WITNES. SES: r n.
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RoyEaJleCool<.NDIaJyPul1lIc
MethanicslluI1l BoIOllllh. Cumberland eDllllly
My COmmisslDll ExpII8S A1Jg. 22, 1992
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P. riei. Mille~
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Al~ce Park, Guarantor
(SEAL)
(SEAL)
(SEAL)
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WAYNEF. SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
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PATRICIA MILLER RODE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
v.
: NO. oo-cf'~ I ( CIVIL TERM
ROBERT B; PARK and
ALICE PARK,
Defendants
: CONFESSION OF JUDGMENT
. CERTIFICATE OF ADDRESS
The undersigned hereby certifies that the precise address ofPlaintitT is 322
Hogestown Road, Mechanicsburg, Pennsylvania 17050, and that the last known address
of Defendants is 319 West Main Street, Mechanicsburg, Pennsylvania 17055.
Date: November 21,2000
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Wayn . Shade, EsqUire
Supreme Court No. 15712
53 West Pomfret Street
Carlisle, Pennsylvania 17013
Telephone: 717-243-0220
Attorney for Plaintiff
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WAYNEF.SHADE
Attorney at Law
53 WestPomfret Street
Carlisle, Pennsylvania
17013
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PATRICIA MILLER RODE,
Plaintiff
v.
ROBERT B. PARK and
ALICE PARK,
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
: NO. OO-f~l( CIVIL TERM
: CONFESSION OF JUDGMENT
AFFIDAVIT OF NON-MILITARY SERVICE
TO: Curtis R. Long, Prothonotary
The undersigned hereby certifies that, to the best of his knowledge, information
and belief, Defendants in the above-captioned matter are not presently on active or
inactive military status.
Date: November 21,2000
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Wayne . Shade, EsqUIre
Supreme Court No. 15712
53 West Pomfret Street
Carlisle, Pennsylvania 17013
Telephone: 717-243-0220
Attorney for Plaintiff
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WAYNEF. SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
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PATRICIA MILLER RODE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL V ANlA
: CIVIL ACTION - LAW
v.
: NO. oo-Jl'.l./( CIViL TERM
ROBERT B: PARK and
ALICE PARK,
Defendants
: CONFESSION OF JUDGMENT
TO: Robert B. Park
319 West Main Street
Mechanicsburg, Pennsylvania 17055
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby
notified that JUDGMENT BY CONFESSION has been entered against you in the above-
captioned matter and that enclosed herewith are copies of all of the documents filed in
support of said judgment.
You may address any questions concerning this Notice to the following in writing.
Wayne F. Shade, Esquire
Attorney-at-Law
53 West Pomfret Street
Carlisle, Pennsylvania 17013
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Prothonotary
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WAYNEF.SHADE
Attorney at Law
53 WestPomfret Street
Carlisle, Pennsylvania
17013
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PATRICIA MILLER RODE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIViL ACTION- LAW
v.
: NO. 00- ~J.\( CIViL TERM
ROBERT B. PARK and
ALICE PARK,
Defendants
: CONFESSION OF JUDGMENT
TO: AlicePark
319 West Main Street
Mechanicsburg, Pennsylvania 17055
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby
notified that JUDGMENT BY CONFESSION has been entered against you in the above-
captioned matter and that enclosed herewith are copies of all of the documents filed in
support of said judgment.
You may address any questions concerning this Notice to the following in writing:
Wayne F. Shade, Esquire
. Attorney-at-Law
53 West Pomfret Street
Carlisle, Pennsylvania 17013
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Prothonotary
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WAYNEF.SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
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P A TRlCIA MILLER RODE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL V ANlA
: CIViL ACTION - LAW
v.
: NO. 00- 8'.2.1\ CIViL TERM
ROBERT B. PARK and
ALICE PARK,
Defendants
: CONFESSION OF JUDGMENT
PRAECIPE FOR ENTRY OF APPEARANCE
TO: Curtis R. Long, Prothonotary
Please enter the appearance of the undersigned on behalf of Defendants ROBERT
B. PARK and ALICE PARK in the above-captioned matter.
Date: November 21,2000
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Wayne . Shade, EsqUire
Supreme Court No. 15712
53 West Pomfret Street
Carlisle, Pennsylvania 17013
Telephone: 717-243-0220
Attorney for Defendants
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WAYNEF. SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
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PATRICIA MILLER RODE,
Plaintiff
v.
ROBERT B. PARK and
ALICE PARK,
Defendants
TO: Curtis R. Long, Prothonotary
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL V ANlA
: CIViL ACTION - LAW
: NO. 00-8211 CIViL TERM
: CONFESSION OF JUDGMENT
PRAECIPE
Please mark satisfied the judgment in the above matter including Court costs.
Date: February 9, 2001
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Wayne ~ade, Esquire
Attorney for Plaintiff
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