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HomeMy WebLinkAbout01-1090 FX ~ ~''''' . ~-^ , 'I~ --'~o",e"""-' - """ " - .;~' -~ PNC BANK, NATIONAL ASSOCIATION Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01 - /696 CIC..)~l l~ MODERN CONCEPTS, INC. Defendant : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW 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 this action, I appear for the Defendant and confess judgment in favor of the Plaintiff and against Defendant as follows: Principal $ 29,755.92 Other authorized items: Interest to January 31, 2001 $ 311.46 Attorney's Commission $ 2,907.99 TOTAL $ 31,987.84 Respectfully submitted, SAIDlS, SHUFF, FLOWER & LINDSAY Date: 1-(6(rJl By: K 1 M. edebohm, Esquire preme Court ill #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 ~ . ,........ -'"""'"'"""''fiiiIIJll"f; PNC BANK, NATIONAL ASSOCIATION : IN TIlE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. MODERN CONCEPTS, INC. Defendant : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW COMPLAINT FOR CONFESSION OF JUDGMENT UNDER RULE 2951 1. The name and address of the Plaintiff is PNC Bank, National Association, 4242 Carlisle Pike, Camp Hill, Pennsylvania 170 II. 2. The names and last known address of the Defendant is Modern Concepts, Inc., 734 State Street, Lemoyne, Pennsylvania 17043. 3. Defendant executed and delivered to Plaintiff a Promissory Note ("Note"), a true and correct photostatic reproduction of the original of which is attached hereto as Exhibit "A" and made a part hereof. 4. Defendant is in default of Defendant's obligations to make payment to Plaintiff as required in the Note, and Plaintiff has demanded payment in full of all outstanding amounts as provided in the Note. A copy of Plaintiffs demand is attached hereto as Exhibit "B" and made a part hereof. 5. Judgment is not being entered by confession against a natural person in connection with a consumer credit transaction. 6. There has not been any assignment of the Note. 7. Judgment has not been entered on the Note in any jurisdiction. 8. The amount due to Plaintiff as a result of Defendants' default is as follows; Ii : ~ , I .~ '_I ''--'1: Principal $28,768.39 $ 311.46 Interest to January 31, 2001 Attorney's Commission $ 2,907.99 TOTAL $31,987.84 9. Interest continues to accrue at the default rate provided in the Note. WHEREFORE, Plaintiff demands judgment against Defendant, Modem Concepts, Inc., as authorized by the warrant of attorney contained in the Note for Thirty One Thousand Nine Hundred Eighty-seven and 84/100 ($31,987.84) Dollars, plus interest from and including the date of this Complaint and judgment entered hereon at the default rate provided in the Note, additiona11egal fees and costs of suit. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Date: '-Ii !IY ! By: I M. Ledebohm, Esquire upreme Court ill #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 ~ I~ . ~'"" '"!.i PROMISSORY NOTE il?ril1cipalL> $3(1;000:00> .. LO!lrjil)fl!~>MI11l!~(!y;'LoaIlNOQonl1teqi' . .I\Cc;()unt.. m i Officer Initials OS;;'1a;.1999 :oasta;';20OIlmm ... ........ .... ...it:i6 .008043734,ft !26581 References in the shaded area are for Lender's use only and do not limit the applicability of this document to any particular loan or item." Borrower: MODERN CONCEPTS, INC (TIN: 251616693) 734 STATE STREET LEMOYNE, PA 17043 Lender: PNC BANK, NATIONAL ASSOCIATION 4242 CARLISLE PIKE CAMP HILL, PA 17001-8874 Principal Amount: $30,000.00 Initial Rate: 9.000% Date of Note: August 18, 1999 PROMISE TO PAY. MODERN CONCEPTS, INe ("Borrower") promises to pay to PNC BANK, NATIONAL ASSOCIATION ("Lender") or order in iawful money of the United States of America, the principal amount of Thirty Thousand & 001100 Dollars ($30,000.00) or so much as maY'be outstanding, together with Interest on the unpaid outstanding principal balance of each advance. Interest shall be calculated from the date of each advance until repayment of each advance. PAYMENT. Borrower will pay this loan in accordance with the following payment schedule: Borrower will pay regular monthly payments of accrued interest beginning on the first day of the Billing Cycle after the initial advance, and all subsequent interest payments are due on the same day of each month after that. Borrower will pay this loan in one payment of all outstanding principal plUS all accrued interest on the Expiration Date. Borrower may borrow, repay and reborrow hereunder until the Expiration Date, subject to the terms and conditions of this Note. The "Expiration Date" shall mean August 18, 2000, or such later date as may be designated by written notice from Lender to Borrower but in no event after the te,nth anniversary 01 'the date of this Note. Borrower acknowledges and agrees that in no event will Lender be under any obligation to extend or renew the loan or this Note beYOnd the initial Expiration' Date. In no event shall the aggregate unpaid principal amount of advances under this Note exceed the face amount of this Nole. Borrower will pay Lender at Lender's address shown above or at such other place as Lender may designate in writing. Unless otherwise agreed or reqUired by applicable law, payments will be applied first to accrued unpaid interest, then to principal, and any remaining amount to any unpaid collection costs and late charges. VARIABLE INTEREST RATE. The interest rate on this Note is subject to change from time to time based on changes in an Independent index which IS the highest Prime Rate as published in the "Money Rates" section of The Wall Street Journal (the "Index"). The Index is not necessarily the lowest rate charged by Lender on its loans. If the Index becomes unavailable .during the term of this loan, Lender may designate a suostitute index after notice to Borrower. Lender will tell Borrower the currenllndex rate upon Borrower's request. Borrower understands that Lender may make loans based on other rates as well. The interest rate change will not occur more often than each month. The Index for a Billing Cycle is determined on the first day af that cycle based on the Index for the last day of the preceding calendar month which is reported. Interest on this Note is computed an the basis af a year of 366/365 days, by applYing the ratio of the annual interest rate on the first day of the Billing Cycle over a year of 366/365 days to obtain a daily periodic rate, multiplied by the average daily balance during the Billing Cycle, multiplied by the number of days In the Billing Cycle. Billing Cycle means the monthly interval between regular periodic statements. The Index currently is 8.000% per annum. The interest rate to be applied to the unpaid principal balance of this Note will be at a rate of 1.000 percentage point over the Index. resulting in an initial rate of 9.000% per annum, NOTICE: Under no circumstances will the interest rate on this Nate be more than the maximum rate allowed by applicable law. PREPAYMENT, Borrower may pay without penalty all or a portion of the amount owed earlier than it is due. Early payments will not, unless agreed to by Lender in writing, reiieve Borrower of Borrower's obligation to continue to make payments of accrued unpaid interest. Rather, they will reduce the prinCipal balance due. LATE CHARGE. If aoayment is 15 days or more late, Borrower Will be charged 5.000"10 of the unpaid portion of the regularly scheduled payment or S100.00, whichever is less. DEFAULT. Borrower will be In default if any of the follOWing happens: (a) Borrower fails to make any payment when due. (b) Borrower breaks any promise Borrower has made 10 Lender, or Borrower tails to comply with or 10 perform when due any ather term, obligation, covenant. or condition contained In this Note or any agreement reiaied to this Note, or In any other agreement or loan Borrower hes with Lender. (c) Any representation or statement made or furnished to Lender by Borrower or on Borrower's behalf is false or misleading in any material respect either now or at the time made or furnished. (d) Borrower becomes insolvent, a receiver is appointed for any part of Borrower's property, Borrower makes an assignment for the benefit of creditors, or any proceeding is commenced either by Borrower or against Borrower under any bankruptcy or :nsolvency laws. (e) Any creditor tries to take any of Borrower's property on or In which Lender has a lien or security interest. This includes a garnishment of any of Borrower's accounts with Lender. (f) Any guarantor dies or any of the other events described in this default sectIOn occurs with respect to any guarantor of this Note. (g) A matenal adverse change occurs in Borrower's financial condition, or Lender believes the prospect of payment or performance of the Indebtedness is impaired. LENDER'S RIGHTS. Upon default. Lender may. after giVing such notices as required by acplicable law, declare the entire unpaid pnncloal balance on thiS Note and all accrued unpaid Interest Immediately due, and then Borrower Will Day thal amount. Upon default. including failure 10 pay upon final maturity. Lender, at its option. may also, if permitted under applicable law, increase the vanable interest rate on thiS Note to 6.000 percentage pOlnts over the Index. The Interest rate WIll not exceed the maximum rate permitted by applicable law. Lender may hire or pay someone else to help collect thiS Note If Borrower does not pay. Borrower also wilt pay Lender that amount. ThiS includes, subject 10 any limits under applicable law, Len~er's attorneys' fees and Lender's legal exoenses whether or not there is a lawsuit, including attorneys' fees and legal expenses far bankruptcy proceedings (Including efforts to modify or vacate any automatic stay or injunctIOn), appeals, and any anticipated post-judgment collectIon servIces. If ~ol prohIbited by applicable law, Borrower also will pay any court costs, in addition to all other sums prOVIded by law. If Judgment IS entered In connecllan With lhls Note, Interesl will continue to accrue on this Note after judgment at the Inlerest rate applicable to thiS Note at the lime Judgment IS entered. This Note has been delivered to Lender and accepted by Lender in the Commonwealth of Pennsylvania. If there is a lawsuit, Borrower agrees upon Lender's request to submit to the juriSdiction of the courts of CUMBERLAND County. the Commonwealth of Pennsylvania. Len~er and Borrower hereby waive the right to any jury trial in any action, proceeding, or counterclaim brought by either Lender or Borrowp.r against the ather. This Note shall be governed by and construed in accordance with the laws of the Commonwealth of Pennsylvania. RIGHT OF SETOFF. Borrower grants to Lender a contractual security Interest In, and hereby assigns, conveys. delivers, pledges. and transfers to Lenaer all Borrower's right. title and :nterestln and to. Borrower's accounls wilh Lender (.....melher checking. savings. or some other account), Includmg '.'Jllhoul :Inlllallon all :lccounls held IClntly With someone else and .all accounts Borrower mav ODen In the future. excluding ~O'Never ail IRA and Keogh accounts. and all rrus: accounts tor which the grant of a security Interest would be prohibited by law. Borrower authorizes Lender, to :he extent Dermlne::: bv acoilcao'e laW, to charge Jr seloff all sums oWing on thiS Note against any and all sucn accounts LINE OF CREDIT :nlS Note eVloe".ces a reVolVing line of crecI! Advances under thiS Nele may be requested only I;; .'mtmg by Borrow~r or as orOVles,:] n ~hls Car3G~ach All ':Or."'r1unlcatlons. Instructions. or .Jllecnons bv telephone ::;. :;therwlse to "-sneer are 10 oe :::rected \0 U;!nder S office seo,,"' ~~.,"".,:> "Tr.e .~, o""n~~a'I'" ~, .....arlies are autnonze"'s ....r,.-,".'Ioeo ](l trllS parag,racr ~(: request acvances unaer In,: :ne at Greelt until Lender " ......-.; - " ',",' ". ",.. , ~ ~ '-' '"' ~ -' cx.'n\ b~+ tiM-" > ~~lli!!I_i,iij:.j~~"~'~;'I;,i;I;;;,_BI"'li!i<\l;"(-!ii~2-i!.;tf.ift,0,,-,gj;,,- 0"_"';,hic,~,,,,,\d~f)b;~",,1- 08-18-1999 Loan No ~'''''''''';~-''~.iIlD'~'' PROMISSORY NOTE (Con~inued) ._~ - ~mw.~ Page 2 -".'-'1 .~ I receives from Borrower at Lender's address shown above written notice of revocation of their authority: CHARLES E. BINGMAN._ PRESIOENT. Borrower may obtain advar1ces from time to time by writing checks in amounts of not less than $100.00 or by using other methods which Lender n:aay permit and may continue to obtain advances until this lo~n is terminated. Lender agrees to pay checks, so long as they d"o not cause the principal batance to exceed the face amount of this Note:, which are dated, drawn and issued by Borrower on or prior to the Expiration Date and received by Lender on or prior to the Expiration; Date or within five business days after the Expiration Date, except as provided in the next sentence. Lender has no obligation to pay any check dated, drawn or issued by Borrower or received by Lender during any period when Lender is not obligated to advance funds under this Note. Borrower agrees to be liable for aU sums either: (a) advanced in accordance with the instructions of an authorized person or {b} credited:to any of Borrower's accounts with Lender. The unpaid principal balance owing on this Note at any lime may be evidenced by endorsements on this Note or by Lender's internal records, Including_ daily computer print-outs. Lender will have no obligation to advance funds under this Note if: (a) Borrower or any guarantor is in default' under the terms of this Note or any agreement that Borrower or any guarantor has with Lender, including any ,agreement made in connection with the signing of this Note; (b) Borrower or any guarantor ceases doing tJusiness or is insolvent; (c) any guarantor s8f:!ks. claims or othelWise attempts to limit, modify or revoke such guarantor's guarantee of this Note or any other loan with Lender; or (d) Borrower has'applied funds provided pursuant to this Note for purposes other than those authorized by Lender. FEES. If applicable, at closing. Borrower will pay to Lender a fee in the amount of up to two percent (2%) of the maximum principal amount of this Note. An annual renewal fee in the amount of up to two percent (2%) of the maximum principal amount of this Note may also be charged if this Note is renewed beyond the current Expiration Date in Lender's discretion. FINANCIAL INFORMATION PROVISION. Borrower agrees 10 deliver any financial and other business information concerning Borrower Ihat Lender may request from time to time, such as annual and interim financial statements (all of which shall be prepared in accordance with generally accepted accounting principles) and federal income tax returns. YEAFI 2000 COMPLIANCE. Borrower has reviewed the areas within its business and operations which could be adversely affected by, and has developed or is developing g, program to address on a timely basis the risk that certain computer applications used by Borrower may be unable to recognize and perform properly date-sensitive functions involving dates prior to and after December 31, 1999 (the "Year 2000 Problem"), The Year 2000 Problem will not result, and is not reasonably expected to result, in any material adverse effect on the business, properties, assets, financial condition, results of operations or prospects of Borrower, or the ability of Borrower to duly and punctually payor perform its obligations hereunder.and under the Related Documents. GENERAL PROVISIONS. Lender may delay or forgo enforcing any of its rights or remedies under thiS Note without losing them. Borrower and any other person who signs, guarantees or endorses this Note, to the extent allowed by law, waive presentment, demand for payment, protest and notice of dishonor. Upon any change in the terms of this Note. and unless otherwise expressly stated in writing, no party who signs this Note, whether as maker. guarantor, accommodation maker or endorser, shall be released from liability. All such parties agree that Lender may renew or extend (repeatedly and for any length af time) thiS loan, or release any party or guarantor or collateral; or impair. fail to realize upon or perfect Lender's security interest in the collateral; and take any other action deemed necessary by Lender without the consent of or notice to anyone. All such parties also agree that Lender may modify this loan without the consent of or notice to anyone other than the party with whom the modification is made. If any portion of this Note is for any reason determined to be unenforceable, it will not affect the enforceability of any other proviSions of this Note. CONFESSION OF JUDGMENT. BORROWER HEREBY iRREVOCABLY AUTHORIZES AND EMPOWERS ANY ATTORNEY OR THE PROTHONOTARY OR CLERK OF ANY COURT IN THE COMMONWEALTH OF PENNSYLVANIA, OR ELSEWHERE, TO APPEAR AT ANY TIME FOR BORROWER AFTER A DEFAULT UNDER THIS NOTE, AND WITH OR WITHOUT COMPLAINT FILED, AS OF ANY TERM, CONFESS OR ENTER JUDGMENT AGAINST BORROWER FOR THE ENTIRE PRINCIPAL BALANCE OF THIS NOTE, ALL ACCRUEO INTEREST, LATE CHARGES, AND ANY AND ALL AMOUNTS EXPENDED OR ADVANCED BY LENDER RELATING TO ANY COLLATERAL SECURING THIS NOTE TOGETHER WITH INTEREST ON SUCH AMOUNTS, TOGETHER WITH COSTS OF SUIT, AND AN ATTORNEY'S COMMISSION OF TEN PERCENT (10%) OF THE UNPAID PRINCIPAL BALANCE AND ACCRUED INTEREST FOR COLLECTION, BUT IN ANY EVENT NOT LESS THAN FIVE HUNDRED DOLLARS ($500) ON WHICH JUDGMENT OR JUDGMENTS ONE OR MORE EXECUTIONS MAY ISSUE IMMEDIATELY: AND FOR SO DOING, THIS NOTE OR A COPY OF THIS NOTE VERIFIED BY AFFIDAVIT SHALL BE SUFFICIENT WARRANT. THE AUTHORITY GRANTED IN THIS NOTE TO CONFESS JUDGMENT AGAINST BORROWER SHALL NOT BE EXHAUSTED BY ANY EXERCISE OF THAT AUTHORITY, BUT SHALL CONTINUE FROM TIME TO TIME AND AT ALL TIMES UNTIL PAYMENT IN FULL OF ALL AMOUNTS DUE UNDER THIS NOTE. BORROWER HEREBY WAIVES ANY RIGHT BORROWER MAY HAVE TO NOTICE OR TO A HEARING IN CONNECTION WITH ANY SUCH CONFESSION OF JUDGMENT, EXCEPT ANY NOTICE AND/OR HEARING REQUIRED UNDER APPLICABLE LAW WITH RESPECT TO EXECUTION OF THE JUDGMENT, ANO STATES THAT EITHER A REPRESENTATIVE OF LENDER SPECIFICALLY CALLED THIS CONFESSION OF JUDGMENT PROVISION TO BORROWER'S ATTENTION OR BORROWER HAS BEEN REPRESENTED BY INDEPENDENT LEGAL COUNSEL. PRIOR TO SIGNING THIS NOTE, BORROWER READ AND UNDERSTOOD ALL THE PROVISIONS OF THIS NOTE, INCLUDING THE VARIABLE INTEREST RATE PROVISIONS. BORROWER AGREES TO THE TERMS OF THE NOTE ANO ACKNOWLEDGES RECEIPT OF A COMPLETED COPY OF THE NOTE. THIS NOTE HAS BEEN SIGNED AND SEALED BY THE UNDERSIGNED. By: (SEAL) VanaOle Rate. line Of C~e:jlt lAScR PRO. Reg. U.S. Pat. &. T M_ Of' . Ve, J.26c (C) 1999CFI ProSer>,o;ces, Inc. All rlghlsreservea, fPM-D2'J =J.26b N081700. __,\j G21,OVL; '. ~-- R"--:ORP. . 4242 Carlisle Pike Camp Hill, PA 17011 E-mail: eric:.krimme.:i!lpncbank.com . ::,'- '~:. ,,'"' ~-' - ~~~'. '"' -.Mlililil) , Eric D. Krimmel Assistant Vice President (717) 730-2492. Tel (717)730-2373 Fax Certified and Regular Mail PNC Capital Recovery Corp. January 3, 2001 Modem Concepts, Inc. Mr. Charles E. Bingman 734 State Street Lemoyne, PA 17043 Ms. Connie L. Bingman 712 Hilltop Drive New Cumberland, P A 17070 In re: Obligor/Obligation Nos.: 31681754-601604927 Dear Modem Concepts, Inc.: Dear Mr. Bingman: Dear Ms. Bingman: As you know, you are obligated to PNC Bank, National Association ("PNC") fora certain loan in the original principal amount of $30,000 (the "Loan"), as evidenced by a certain Promissory Note dated August 18, 1999, and by certain other related loan documents (the "Loan Documents"). As you also know, you are in default under the Loan and Loan Documents for your failure to make payments when due to PNC on the above loan account and two other loan accounts, whereby PNC made demand for payment in full by letter dated December 11,2000, which constitute Events of Default under the Loan and Loan Documents. As a result of the above Events of Default, all liabilities and obligations under the Loan and Loan Documents have been accelerated and all liabilities and obligations under the Loan and Loan Documents are immediately due and payable to PNC. Additionally, as aresult of the defaults PNC exercised its rights of setoff with regards to checking account number 5140230708, and applied the $1,605.79 to the above loan obligation. As of this date the amount due under the Loan and Loan Documents is as follows: Oblil!or/Oblil!ation Nos.: 31681754-601604927 Principal Interest to 01/04/00 Late charges Sub-total Less proceed from setoff Total Due Per Diem $8.56 $29,755.92 605.54 12.72 $30,374.18 - 1.605.79 $28,768.39 plus satisfaction fees and costs 11"lr.", 1',_ .i:.~, k.: " \. t\".?fl E';<.",.\::).-r u Modem Concepts, Inc. January 4, 200 I Page 2 In addition, pursuant to the tenns of the Loan Documents you are hereby notified that effective this date PNC has exercised its option to increase the interest rate on the Loan to PNC Bank's prime rate plus 6.00%. Please be advised that unless payment in full is immediately delivered to PNC Bank, National Association at 4242 Carlisle Pike, Camp Hill, P A 170 II, in the fonn of a cashiers check or money order, PNC shall take all action it deems appropriate to collect the above sums due and owing, preserve, protect and enforce its rights under the Loan and Loan Documents. Very truly yours, =-~;R:2Q Eric D. Krimmel Assistant Vice President Certified Mail Nos.: Z 231 540 970 Z231540971 Z 231 540 972 cc: Regular Mail Geoffrey S. Shuff, Esquire . ';; SENDER: "C . CJmplete items 1 and/or 2 lor addllione.l saNicas. 'en "Complete items 3. 4a. and ..b. Q) . Print your name and address on the reverse of this form so that we can ralum this ~ card ,0 vou. ~ . A;tach this form to the front of the mailpl8ce. or on the back if space does not ~ ~erm1t. ,,"'I'ite 'Return Receipt Requested" on the mailpiece bele.,., the article number. Q) . Ti'-.er Return Receipt will shew to whom the article was ceil'Jared aM the date .;: :l8i1Vered. , L.~ ........c.~......< fA, ! '/(J-{ J 1 also wish to receive the following services (for an extra fee): 1 . 0 Addressee's Address 2. 0 Restricted Delivery I Consult postmaster for fee. c. 4a. ArticJe Number ~ ;z. 2J I 5'-f() ~ 4b. Service Type :; b-~ ;; ,0 RegIstered ;.:::::r-.vertlfled a: o Express Mail 0 Insured ~ ~Return Receipt lcr Merchandise 0 COD ~ 7, Date 'Jf Delivery . / .E - "-"-0 t !~ r\)\ l 5 8. Addressee's Address (Only if requested ; and jee is paid) ~ ;:: ci Q 1: m "' g 3. '0 m ;; a. E " o Article Addressed to: 11c-cJ"-l^- (O"~'t\..s .1:.... <:... /3" .s~1.,,-- ;I.,r~,,--'>.,. 1>0 I ,.... WI co :.-; :~,;?7..--__ 102595.98-8.0229' Domestic Return Receipt ~ <5 >- .$ PS r:~ ';; SENDER: "'C . Complete items 1 3l"lOiO( 2 !or additional services. '(ji .. Complele Items 3. 4a. and <lb, ~ . Print your name ant! address er: the reverse of thiS ::)rm so that we can relurn thiS _ card to you. ~ II Anacn thiS form to :ne frOnt of :Me rnailplece, or en :i"t~ back If space does (tOI e permit. _<;: . 'Nrile .'{fe,um Receipt ReaU~$le(r on the mallplece :;J,.:::lW the artide r:lJmb-ar - . The Fle:,un ReceiPt Will Show to whom the al'1lCle was -:tehvered and the date aeIIVen'JC. '5 3, A,rtlcle Addressed to: I also wish to receive the follOWing ser/lces (for an extra fee): 1 . 0 Addressee's Address 2, 0 Restricted Delivery _ _ Consult postmaster for ree. ArtiCle Numoer ci Q .~ o "' 1!iI WI ~, Ci 01 <:1 '~ -, >- WI ~ LQ>,c')',\ '< r:'+ r)D'-( 1 +- ?1 4b, ServIce 'ype :i o Registered J2I: Certified ~ o Express Mail 0 Insured ~ Return Receloi for Merchandise 0 COD .~ Date or Delivery /-2 I-:==;-(;;{ (),U~ . Addressee's Address (Omy If requested and fee is paid) .S''fe 7/1 '0 Q o c:: "a, ~ I c. Q ft..i,r ,.:.J....(.-,..-'\~-'" E I':), .,~. ........,<:......-.. j -( \ " ..-S h.....:;\,~-..: \",....~..:....... .> '3 C_( ....---- .--J 5. ::3.ec~ved Sy: IP~jnt Name) /" /(.?': 7~~ __~,/:, .-;, . ~ ~ 0 Siqb,,~''''(Ave:;se~. Ageny.../ x' /, ",/,' /-" ,/",,, - --, :;. ':,/-';;/':::'~ 'f,'.~. ,'.< ". ~ .)'; .~. ;(,:.-,....;;-~:~. ~ P;:'; For":: 3~~r 199.:1. .." <5 >- ~ ~ .c >- '02;:'",,':'.';l'o.S..)"::Z~ Domestic Return Receipt "" L , .. _ ""1$1 PNC BANK, NA TIO'NAL ASSO'~IATIO'N : IN THE CO'URT O'F COMMO'N PLEAS Plaintiff : CUMBERLAND CO'UNTY, PENNSYLVANIA : NO'. v. MO'DERN CO'NCEPTS, INC. Defendant : CO'NFESSIO'N O'F mDGMENT : CNIL ACTIO'N - LAW VERIFICATION I, Eric Krimmel, Assistant Vice President, for PNC Bank, National Association, being authorized to do so on behalf ofPNC Bank, National Association, hereby verifY that the statements made in the foregoing pleading are true and correct to the best of my infonnation, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. PNC BANK, NATIONAL ASSOCIATION Date: /110/0' By: L~;/ ~J) Eric Krimmel Assistant Vice President ~ 1 -.." ",.-'" .~ ',' .---~ : . ~,- ~ ~ 1_0 '"" "~'" PNC BANK, NATIONAL ASSOCIATION : IN THE COURT OF COMMON PLEAS Plaintiff ; CUMBERLAND COUNTY, PENNSYLVANIA v. ': NO. MODERN CONCEPTS, INC. Defendant ; CONFESSION OF JUDGMENT I : CIVIL ACTION - LAW CERTIFICATE OF ADDRESSES I hereby certify that the precise address of Plaintiff, PNC Bank, National Association., is 4242 Carlisle Pike, Camp Hill, Pennsylvania 17011; and that the last known address of the Defendant is Modem Concepts, Inc., 734 State Street, Lemoyne, Pennsylvania 17043 Respectfully submitted, SAlDlS, SHUFF, FLOWER & LINDSAY Date: 1--(6 ~ f 'By: I ,... arl M. edebohm, Esquire upreme Court ID #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 '-'C"" --<-' _ilIiIii~~_OO!i!iiiliiF,~nw~;k~::';J:iL-'i.;'I""",";_I';~.i'!~i'.ui.;iM.fJ!'lIl,ii;1i&lr"....'" aili"'''''''';''';'in "IMmM:l. ~... " ~ ..l::- . B if! ~ ~ t~ ~ - tv pi ~ ~ 3 ~ ~ (!r t - "" . ~~~ ,<=~, ~ ,".._~-"-" '" .. .0 ~ ....~ n-- n'l ~~: L._'-' t~,~:~ -<: -~ ~c> ~~i :::-:::; =< n ~; C":",1 ~ :'jl CD f'.j G.-,:; -1:') GO 1'0 <0 3 ---I ;:; -< '" " g m ....~" . " I' I~. .. -., ~ " )'1.'<(; PNC BANK, NATIONAL ASSOCIATION : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYL V ANlA ~a ~ NO. 01- /O'tO C;t.>~(!-~ C~ES E. BtNQ:~~I(.~~OPOOE L.:: CONFESSION OF JUDGMENT BiNGMAN : CIVIL ACTION - LAW Defendants NOTICE TO: Modem Concepts, Inc., Defendant Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a JUDGMENT BY CONFESSION has been entered against you in the above proceeding and that enclosed herewith is a copy of all the documents filed in support of the said judgment. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: KARL M. LEDEBOHM, ESQUIRE TELEPHONE NUMBER: (717) 737 -3405 a~p-,~ Prothonotary ~, " ,~ '~ ~ ,:' I ' .. ,....;.1,..' .., '~ ,. ,"..~ ;~, , ~ ~",.. "~1!;'-:' PNC BANK, NATIONAL ASSOCIATION Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 0 1- ICfiO G-c.>,{ Cy-~ : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW MODERN CONCEPTS, INC. Defendant ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of the undersigned on behalf of PNC Bank, National Association, Plaintiff in the above captioned matter. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Date: 1-{6 {tJ, By: U71!!&- Supreme Court ill #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 ~~ltiti ~lli'~M"-i!ioil~m,,'''_''':M;<ZittnJllfW;mE~i$i~il~Irr.!''Hii&~'l''<;I'14t,~~~'';'''J.'lI1","U~lIf~H$tll1l~m!liiiSt"' "bilillill. , illi._llti.~ -..,"'"..;-~ I'j . , ,~... () ~ "'t)":' tlll:C:' 7-- ~~7_: C:C.~ ~~E:; ,Y"r" 2'; ~-< ('5 .:..,.' ,,' '" IIj['1 I -n ,-~\ :::J j'...) G) -''J ::"'-.) ,"'-:J ,0 ~ "