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Home My WebLink About01-1173 FX , , , j" .oi ,l', ~ , , , /"'~ "" ," ".,,~; _ ~ 1 '1-. PNC BANK, NATIONAL ASSOCIATION, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. or - II7J C'uJ '--r~ NORSOFT, INC., Defendant : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW CONFESSION OF JUDGMENT Pursuant to tbe autbority contained in tbe warrant of attorney, tbe original or a copy of wbich is attached to tbe complaint filed in this action, I appear for tbe Defendant and confess judgment in favor of tbe Plaintiff and against Defendant as follows: Principal $338,723.21 Otber autborized items: Interest to February 22,2001 $ 12,320.38 Lien Search Fee $ 65.00 UCC-l Search Fee $ 139.00 Attorney's Commission $ 35.1 04.36 TOTAL $386,351.95 Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Date: 2.-/2.:; lot By: 11' arl . Ledebohm, Esquire Supreme Court ill #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 -<<--' '" ""':"' , .,1 ,I ,~ ",I ,~, ' ".:;;:,: , , ... PNC BANK, NATIONAL ASSOCIATION, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANlA : NO. NORSOFT, INC., Defendant : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW COMPLAINT FOR CONFESSION OF JUDGMENT UNDER RULE 2951 I. The name and address of the Plaintiff is PNC Bank, National Association, 4242 Carlisle Pike, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The name and last known addresses of the Defendant is Norsoft, Inc., 3438 Trindle Road, Camp Hill, Cumberland County, Pennsylvania 17011 and c/o Lawrence Berger Knorr, President, 8 Appaloosa Way, Carlisle, Cumberland County, Pennsylvania 17013. 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 Plaintiff's 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 Defendant's default is as follows: , '~ I .~ ,~'" ,j ,_ ,"U"'l .~,d...',:.:;"", ."~ _~',_"'^__ "''-'i;" .. Principal $338,723.21 Interest to February 22,2001 $ 12,320.38 Lien Search Fee $ 65.00 DCC-l Search Fee $ 139.00 Attorney's Commission $ 35.1 04.36 TOTAL $386,351.95 9. Interest continues to accrue at the default rate set forth in the Note. WHEREFORE, Plaintiff demands judgment against Defendant, Norsoft, Inc., as authorized by the warrant of attorney contained in the Note for Three Hundred Eight-Six Thousand Three Hundred Fifty-One and 95/100 Dollars ($386,351.95), plus interest from and including the date of this Complaint and judgment entered hereon at the default rate provided in the Note and costs of suit. Respectfully submitted, Date: '2..- [ 'Z- ~ ~ 0 1 F, FLOWER & LINDSAY By: arl . Ledebohm, Esquire Supreme Court ID #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 , -~" ;, - ,L" .' -=" ~" '] FEB-22-2001 15:17 PNC BANK 7177302373 P.03 4,. ~ ,. PNC BANK, NATIONAL ASSOCIATION, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. NORSOFT, ThC., Defendant CIVIL ACTION - LAW VERIFICATION I, Eric Krimmel, Assistant Vice President, for PNC Bank, National Association, being authorized to do so on behalf of PNC Bank, National Association, hereby verifY that the statements made in the foregoing pleading are true and correct to the bellt of my information, 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 authorit.cs. PNC BANK, NATIONAL ASSOCIATION Datl': 21:22 (0 I By: r,,~GJ. t: .9 Eric Krimmel Assistant Vice President TOTAL P.03 - ~~ ~ '. c~ _J~,",~ -, ~"~ '.., 1 1Hi~ fu~l! Borrower: NORSOFT, INC. (TIN: 23-2746897) 3438 TRINDLE ROAD CAMP HIll., PA 17011 Lender: PNC BANK, NATIONAl ASSOCIATION 4242 CARLISLE PIKE CAMP HIll., PA 17001-8874 Principal Amount: $350,000.00 Initial Rate: 7.750% Date of Note: September 9, 1999 PROMISE TO PAY. NORSOFT, INC. ("Borrower") promises to pay to PNC BANK, NATIONAl ASSOCIATION I"Lender") or order In lawful money of the United Slates of Amertca, the principal amount of Three Hundred FIfty Thousand & 001100 Dollars ($350,000.00) or s.i mUCh as may be outstanding, together with interest on the unpaid outslanding prtncipal balance of each adVance. Interest shall be calculated from tne date of each advance unlll repayment of each advance. PAYMENT. Borrower will pay this loan In accordance with Ihe following payment schedule: Borrower will pay regular monthly payments of accrued Interest beginning OCTOBER 9, 1999, and all subsequent interest payments are due on the same day of each month after thaI. Borrower will pay this loan in one payment of all outslandlng principal plus all accrued unpaid Interesl on the expiration Date. Borrower may borrow, repay and reborrow hereunder untlllhe Expiration Date, sUbject to the lerms and condlllons of this Nole. The "Expiration Date" shall mean SEPTEMBER 9, 2000, or such later date as may be designated by wrlllen notice from Lender to Borrower. Borrower acknowledges and agrees Ihat In no event wtll Lender be under any obligation 10 extend or renew the loan or this Note beyond Ihe initial expiration D8\e. In no event shall the aggregate unpatd principal amount 01 advances under this NOle exceed Ihe face amount of this Note. The annual interest rate for this Note is computed on a 365/360 basis: that is, by applying the ratio of the annual inleresl rate over a year of 360 days. mUltiplied by the outstanding principal balance, multiplied by the actual number of days the principal balance is outstanding. 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 firslto accrued unpaid interest, then to principai, 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 index which is the Lende,'s prime rate (the "Index'~. The Index is a rate per annum as publicly announced by Lender from time to time as its prime rate. The prime rate is not tied to any external rate or index and it does not necessarily reflect the lowest rate of interest actually charged by Lender to any particular class or category of customers. Lender will tell Borrower the current Index rate upon Borrower's request. Borrower understands that Lender may make loans based on other rates as well. The interest rate cnange will not occur more ollen than each day. The Index currently is 8.250% per annum. The interest rate to be applied to Ihe unpaid principal balance of this Note will be at a rale of 0.500 percenlage polnls under Ine Index, resulllng In an Inlllal rale of 7.750% per annum. NOTICE: Under no circumstances will the interest rate on this Note be more than the maximum rate atlowed by applicable law. PREPAYMENT. Borrower may pay without penaity ail or a portion of the amount owed eariier than it is due. Early payments wlU not, unless agreed to by Lender in writing, relieve 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 a payment is 15 days or more lale, Borrower will be charged 5.000% of the unpaid portion of Ihe regularty SCheduled payment or $100.00, whiChever ts 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 to Lender, or Borrower fails to comply with or to perform when due any other term, obligation, covenant, or condition contained in Ihis Note or any agreement related to this Note, or in any other agreement or loan Borrower has wilh Lender. (c) Borrower defaults under any loan, extension of credit, security agreement, purchase or sales agreement, or any other agreement, in favor of any other creditor or person that may materially affect any of Borrower's property or Borrower's ability to repey this Note or pertorm Borrower's obligations under this Note or any of the Related Documents. (d) 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. (el Borrower becomes insolvent, a receiver is appointed for any part of Borrower's property, Borrower makes an assignment for the benefit at creditors, or any proceeding is commenced either by Borrower or against- Borrower under any bankruptcy or insolvency laws. (1) 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. (g) Any guarantor dies or any of the other events described in this default section occurs with respect to any guarantor of this Note. (h) A material adverse change occurs in Borrower's financial condition, or Lender believes the prospect Of payment or pertormance of the Indebtedness is impaired. LENDER'S RIGHTS. Upon default, Lender may, aller giving such notices as required by applicabielaw, declare the entire unpatd principai balance on Ihis Note and all accrued unpaid interest immedialely due, and then Borrower will pay that amount. Upon default, including failure to pay upon final maturity. Lender, at its oplion, may also, if permilled under applicable law, increase the variable interest rate on Ihis Note 5.000 percentage points. The interest rale will not exceed the maximum rate permllled by applicable law. Lender may hire or pay someone else to nelp collect this Nole if Borrower does not pay. Borrower also will pay Lender that amount. This includes, subject to any limits under applicable law, Lender's allorneys' lees and Lender's legal e.penses whether or not there is a lawsuit, including allorneys' fees and legal expenses for bankruptcy. proceedings (including efforls to modify or vacata any automatic stay or injunction), appeals, and any anticipated post-judgment collection services. If not 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 connection with this Note, interest will continue to accrue on this Note after judgment at the interest rate applicable to this Note at the time 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 10 submit to the jurisdiction of Ihe courts of CUMBERLAND County, Ihe Commonwealth of Pennsylvania. Lender and Borrower .herebY waive the rlghllo any jury trial In any, actton, proceeding, or counterclaim brought by ellher Lender or Borrower agalnstlhe olher. Th.s Nole shall ba governed by and construed in accordance with Ihe'laws of Ihe Commonwealth of PennsylvanIa. RIGHT OF SETOFF. Borrower grants to Lender a contractual security interest in, and hereby assigns, conveys, delivers, pledges, and tra,nsfers, to Lender all Borrower's right, title and interest in and to, Borrower's accounts with Lender (whether cl1ecking, savings, or some other account), Including without limitation all accounts held jointly with someone else and all accounts Borrower may open in the future, excluding however aU IRA and Keogh accounts. and all trust accounts tor which the grant of a security interest would be prohibited by law. Borrower authorizes Lender. to the extent permitted by applicable law, to charge or setoff all sums owing on this Note against any and all such accounts. LINE OF CREDIT. This Note evidences a revolving line of credit. Advances under lhis Note may be requested orally by Borrower or by an authorized person. Lender may, but need not, reQuke that alt oral requests be confirmed in w,nting. AU com",!unications, in~tructions, or directions by telephone, or otherwise to Lender are to be directed to Lender's office shown above. The follOWing party or parties are authonzed to request advances under the line Exhi it "A: " - , .~ ~' 0 ~o""i ~~ 7177302373 PNC BANK ", FEB-22-2001 ...,.-...... 17:39 . .._...I........~n' ~I'" p.nt'n"""l POIgrl - . "T .- -- ~ d \.ftlhr ___ .... Wl'WW al: l.aIIWs UlSrI!JJ ~ .. WIIIIft ~ II 1IfIW;c.dan gr Ihair ~tr. U_A!NCr. IL ,RIIIIM'''-R,;-, ~ ,.. .....__lD.......,..~~ tt.r,~la4\-&_.._~...,..~ _"11I1__.._01"--'___. .....-~-_..lIlll_.."'1..._..._., ..-..-....._......---""-~...-........... '-...-.............-.......... v6 "_It lI).QItt.........~...... ......4IitIIIICl......ItIf__,tA ,*"'ar"'~I'W~ rI".OUilU:.." 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"""""""''''''''.101I OF """ _ alN"'Sli (lOI '_.l\IlGMENf _.' . __M__...._CI'ms~""-~.,.,....,..,........c:>_""'__AU.~ IilIl'alllIll QII__"'~ I\SA\1nliW _ ~__lIl!C\.III.NG TIlls _ll~""H...-"" IlLOl AII~, "RlGEflBI """ c:osTS. Ill! """. _ "'" A11'<lIlNEf'S COlIMIS_ OF ... flil""'" If'l'Il C. """ ."'''!\lIl ............. .......a """_ ~-,ra,CC<UCll""...... ,. _-... _1lESS""" _ ~_ """-""5'~ "" MtCi' _'llR~'c..""_,~....v 1.....~:!1.-I."f8DDC.....".."""'."".""""'CFl>lIS NQlE _.""""""" S>W.L "".......-_. "'" ........" ~ '" TIiI: _10 __ _"-"".!lMi!J.IlIOT"'l_iiY.MI'_.!lI'_~.klrsl""'~'_,"""1O~_ ATIoll l..""'uoil"(....._ INIUL OF.... """"""'''lie ....,........llCTf. ............ _~ rjtr__ ....v ""'4.lO.jjQtIC%.""IO':~IN ~ _.Iff &U!>I_'DF~. .,.... _. NCIflO;_QA ";..,,,__.- ~..... """ _ECr 19 """""'''' Of TIiI! _. _ 8T"""'lIW _ A AS. .,.4ENTA_ 0IIl' ~ ~y ~l,PP TWlS ~ C'I- ~NT PIVJYf_ -ro aOllAowPs ATTBtftdN OR .-ow... ....__.../lillI!l'ElIDOl<TImALCCllN.... ....1DSIGfIII. WllIICJTf;...~_~_..IiIUD"'" ~l..;OCi.... THf ~DfS. TtfI$ NDI1i.INc;:LWIIIKI'1N: YiUUA&E IJfrEReI1'IIAn;iPRQIISICItS. .c:.-....~ ~'fO"r'ttIf;URIII&-'l1IE~MD~~RI!CCIP'I~.~ ___... tIC oem!. l'tUi N01'I! HAS'" SI~ _11IO ~lfIv 'ftElMIEMIIiiRED. -~ .~~;: ~.- e;.~~~l t;'.;II:;;.l.;"~~."':'on--._,~tu\"'~""~-'''''~~'''''~f;J,~",,,:QfU~l ~""l_.fQ'lJd. - P.02 :-~~ L ~ tic 4242 Carlisle P e Camp Hill, PA 11011 E-mail: eric.krimmel@pnc.com . " J . Asska;.~ ~I^cel're;;t;;t . , (717) 730-2492 Tel (717) 730-2373 Fax '1t: . .. ~ Certified and Regular Mail PN C Capital Recovery Corp. January 9, 2001 Norsoft, Inc. . 3438 Trindle Road CampHiII,PA 17011 In re: Obligor/Obligation Nos.: 31762985-60.443625 Dear Norsoft, Inc.: As you know, you are obligated to PNC Bank, National Association ("PNC") for a certain loan in the original principal amount of $350,000 (the "Loan"), as evidenced by a certain Promissory Note dated September 9, 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 payoff the above loan account when it matured on November 2, 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 a result of the defaults PNC exercised its rights of setoff with regards to checking ac,count number 5000771334 as of this date, and applied the $1,523.31 to the above loan obligation. As of this date the 8II10unt due under the Loan and Loan Documents is as follows: Oblillor/Obli"lItion Nos.: 31762985-601443625 Principal Interest to 0 1/09/00 Sub-total Less proceed from setoff Total Due Per Diem $78.88 $338,723.21 8.224.60 $346,947.81 1.523:31 $345,424.50 plus sat. fees, costs and expenses 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 5.00%. Exhibit "B" l~myt.~~ .ll.l". January 9,2001 Page 2 Please be advised that unless payment in full is immediately delivered to PNC Bank, National Association at 4242 Carlisle Pike, Camp Hill, PA 17011, in the form ofa 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. ". !lJ ~ ~ Very truly yours, PNC Capital Recovery Corp. &--Q,~ Eric D. Krimmel Assistant Vice President Certified Mail Nos.: Z 23 I 540 977 CC: Regular Mail Geoffiey S. Shuff, Esquire "S:J!AJ8S ;d!8081::1 UJn~af::f 6Ulsn JOI nOA )(UBI.fJ. '" '" e ~ ai CD e "C CD Q) .0: co '0 > - -.... <( ~ ..2 .i~ ~ ~ CD ~.~ ! ~ ~ 02: l!?:S E -<I) "OU)U) J: rJJ "' "0 CD 0 .!Q 0)Q) <( a:: Q. 3:oS.2!OO"3 ~ ~ ~ . . CJ) ~~~ .- t\J 8 ~ ~ 'S iiis ! ; ~~ &i ~ f!~ 1 i U!J~> g ~ :: E " S Ql .alii VI -5 B~ u::i 5 a alQl ~ - C5 'Q,u .~ 0 'a'E OIl ~ Jlf E<'ll ItI Ql ai Ql,! .~ e i ~~ '5 5 ~ ~i i e -5 .2!0 es.Q~ '5 6-~iO -~. N"O!! c: ~ 0 es&i:g g ~~ .:: l:t -<<I Ql ol<o_i i a:-g -5 Qf If) -Mas g g.s. gJ EE~ e c:~ -0 .. Ql QJ <lI 0 Sa: '0 a:-=-=C:2; .ac <( W2S!Sg,;g ~.3ti Q) O,!!~g-5'=~~ ~ ~ ZE:E'E'E,!gE'''=Ql.o: "5- w88if ~< !~~~ --: (I)... . .. M "0"0 " " .- '- Cl i ~ 0 ~ ,a~~ \l""A ." S 111 " 0- ...... Ii! ':') ~ ~ ~ :g I. ~ .! ~; oJ ~ CI') '-1 ~........Ii! ~ ~ ._ ~ ~ I ~~ E - >0 -c ~ .S =............ _0 a :;J M I- IV ...:; B CD CD '",flD(j)fni!O ~.~ Q) I..'\J 0 ~~ ~ '0 rn Q) "0 .~. .... E CD.! t: CD Co2!! -0"0 ",:"V~a:~~~ ~~ ~ ~D r' cO \:) q a o <l,/.~ - "'"J ~ '" is t 0- I!! ~t) .2 J .J Hi -i:: -i- l- 'i ~ ~ ('-< ~ ;:; :.:: '" E ~ .s ~ ;.;. '" "0 " > Oil " " a: .,; - -. ~ "r u Cl i:ii <0 <.aPIS aSJaAEU 841 UQ pal81dWQO SS3t:1(]CY Nt:Ul..L3t:1 J :~ , - ~.<" - 4 l~;!i!t';J Q. o(jj " '" a: E ~ - '" a: " <= rn '" E o Cl ~ ; '" m ~ !! I ,-,'- . ~ ,'<0 ",- - w-<iliIlI1,,- T. PNC BANK, NATIONAL ASSOCIATION, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. NORSOFT, INC., Defendant : CONFESSION OF JUDGMENT : CNIL ACTION - LAW CERTIFICATE OF ADDRESSES I hereby certify that the precise address of Plaintiff, PNC Bank, National Association, is 4242 Carlisle Pike, Camp HilI, Cumberland County, Pennsylvania 17011; and that the last known addresses of the Defendant, Norsoft, Inc., is 3438 Toodle Road, Camp HilI, Cumberland County, Pennsylvania 17011 and c/o Lawrence Berger Knorr, President, 8 Appaloosa Way, Carlisle, Cumberland County, Pennsylvania 17013. Respectfully submitted, """, -vI Z-Z}'!I By: I M. L debolun, Esquire upreme Court ill #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 0,";";;':1km~~~;m~!jIlJ!lJil<:~!'"\h~it..-"iJf~SH;l(;h>'''''iit(ijffil\otlWi''l-,",'''"","-''~~J~~~~OJ~llii;ll~ilIll8!l' '''''lD.i: "'n" .~~ ,~~ ~ ., ". ~... ,- P," ,.. ,- ~'-' '" - ~~'" , C to ~ -Iq. ....... ~ ~ ~ V) <) -e::'} c' r tv 0 _0 -.;:]i: "":'1 -. 6' n-j 0 f' , 3 ~ ~ -" 0_) ~ ('I cc' r;~ ~ '-' ,) -. - ~ .-:::::..' :i1' ":-"C' r:.'~) .0....., % -' :0 -< (.,.) -........... .^-- ~ -, " , ~,~.""," . - ~,,-- ".- , r ^ ,,,'__~ .-' ~~"":1.j . 't,'v . L .... ~ , ~~'" "- . " L " -;--" ",'''-0 '" -, It"': PNC BANK, NATIONAL ASSOCIATION, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 01- /I?...!J C-o~( <-y-~ NORSOFT, INC., Defendant : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW NOTICE UNDER RULE 2958.3 OF JUDGMENT AND EXECUTION THEREON TO: Norsoft, Inc. A judgment in the amount of $386,351.95 plus interest from and including the date of the Complaint and judgment entered thereon at the default rate provided in the Note and costs of suit 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 court has issued a Writ of Execution which directs the sheriff to take your money or other property owned by you to pay the judgment. If your money or property has been taken, you have the right to get the money or property back if you did not voluntarily, intelligently and knowingly give up your constitutional right to notice and hearing prior to the entry of judgment or if you have defenses or other valid objections to the judgment. You have a right to a prompt court hearing if you claim that you did not voluntarily, intelligently and knowingly give up your rights to notice and hearing prior to the entry of the judgment. If you wish to exercise this right, you must immediately fiU out and sign the petition to strike the judgment which accompanies the Writ of Execution and deliver it to the Sheriff of Cumberland County at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IT IS IMPORTANT TIIAT YOU ACT PROMPTLY. IT WILL BE TOO LATE TO REGAIN YOUR PROPERTY IF YOU WAIT UNTIL AFTER THE PROPERTY HAS BEEN SOLD BY THE SHERIFF OR TURNED OVER TO THE PLAINTIFF. 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. ,~= ~~ . ". ~ . "",-", . ,...1 , I; ..-.[- . , ~' " -, --', ---""";1 ,~ ".. YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PAl 70 13 (717) 249-3166 or 1-800-990-9108 Respectfully submitted, Date: z-{ v'? I rJ f -::Mgi~AY Supreme Court ID# 59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff )~t?~i&lIifiM"~-"1l~W~~'i"~.~Eilfu~,[t...Mi'liMo.lh\""'0&i,~g~,"i~d!1i! _~ , ~ 'V~~ "" '"~- ~- ---",,~ .-"'- lIliblillilJlUiIiilIIi'iilIi_iIliil~ -"-~ o ...... C) c: <:" -0 tT~ nl,-----, if ~2~ 2: :< ~ - ,~~ ~ ... ,.~'-, -q -'~ <---:J ;",,) CJ ~~0 . ":"- j ;-'"J t..) C,J !1i ~I ._, , ,-,'t_- '': ;';',,", .~'~"- -, ,-', "F~;-.. At ... PNC BANK, NATIONAL ASSOCIATION, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. ; NO. 01 - /170 C,o~('-r~ NORSOFT, INC., Defendant : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW PETITION TO STRIKE JUDGMENT REQUEST FOR PROMPT HEARING I hereby certify that I did not voluntarily, intelligently and knowingly give up my right to notice and hearing prior to the entry of judgment. I petition the court to strike the judgment on this ground and request a prompt hearing on this issue. I verify that the statements made in this Request for Hearing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. g4904 relating to unsworn falsification to authorities. Notice of the hearing should be given to me at Street Address City, State Telephone Number Date: Defendant 'f. ,.",.,0, , , ,_"1.,, .-- ""~ -w' ", ,;., '!U'\ " .. PNC BANK, NATIONAL ASSOCIATION, Plaintiff v. : IN lHE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 0 1- (!/(..~'I ( ~~ NORSOFT, INC., Defendant : CONFESSION OF mDGMENT : CIVIL ACTION - LAW NOTICE TO: Norsoft, Inc. Pursuant to RuIe 236 of the Supreme Court of Pennsylvania, you are hereby notified that a JUDGMENT BY CONFESSION has been t;ntered 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 HA VB ANY QUESTIONS CONCERNING TillS NOTICE, PLEASE CALL: KARL M. LEDEBOHM, ESQUIRE TELEPHONE NUMBER: (717) 737-3405 (Id..; ) Q ~;;;Jr Prothonotary ,~ll .. PNC BANK, NATIONAL ASSOCIATION, Plaintiff v. NORSOFT, INC., Defendant ,,. < ",-- . " '" ~ ~,.,"'-. '; : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA '- : NO. 01- /17~ C<->"l/~ : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW 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. Date: 2- /t-t-/o I Respectfully submitted, SAlDIS, SHUFF, FLOWER & LINDSAY By: ~. I M, edebohm, Esquire upreme Court ill #59012 2109 Market Street CampHill,PA 17011 (717) 737-3405 -:a. < ... , '~~E'I , I I PNC BANK, NATIONAL ASSOCIATION, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 0/ - 1/::[3 Qv~l 'T~ NORSOFT, INC., Defendant : CONFESSION OF JUDGMENT : CNIL ACTION - LAW PRAECIPE FOR WRIT OF EXECUTION UPON A CONFESSED JUDGMENT To the Prothonotary: Issue a writ of execution upon a judgment entered by confession in the above matter. (I) directed to the sheriff of Cumberland County; (2) against Norsoft, Inc., c/o Lawrence Berger-Knorr, President, 8 Appaloosa Way, Carlisle, PA 17013 Defendant; and (3) against Commerce Bank, 100 Senate Avenue, Camp Hill, PA 17011 Garnishee; (4) and index this writ (a) against Norsoft, Inc., c/o Lawrence Berger-Knorr, President, 8 Appaloosa Way, Carlisle, P A 170 I 3 Defendant; and (b) against Commerce Bank, 100 Senate Avenue, Camp Hill, PA 7011 as Garnishee and levy upon and attach as required the following: (a) Any and all personal property of Defendant, Norsoft, Inc., in the possession of Garnishee, Commerce Bank, including without limitation any fimds held on account. (5) Amount due: Interest from 2/22/0 I Attorneys fees Costs $386,351.95 (to be added) (to be added) (to be added) Certification I certify that (a) This praecipe is based upon ajudgment entered by confession; and '.,-. 1- , ~..~ " , .,., o_.l .; .:. ~'-;:' :.. \Co? (b) Notice will be served with the Writ of Execution Pursuant to Rule 2958.2. , FLOWER & LINDSAY Attorney for Plaintiff ,d~[M~!limMiKilll!H"hl!Jhl&&:iil't>fu:"1f,iWMilbi{M~-_~iI<.I'J,~;"'-ll>",-,BifEi1'_",,!"'r~"~~..,~iJih,~.!IiI' ""-''''''d~~l\Ililiilllj~jjfi!\'lli_.iil1illlilii.'rl'~Ii<~~~"~'i1Ill''' -' ..,",'" ,-'~ f:J~ ft-1- Vv Ii' .... ~ ........ C\ ~ ~ ~ - " l' --.- . -,~ - ,-."" ~ :iQ '1 o ~ ~ ~ ,~ ^' ll..J 0 '^ ~ .-( VI' . O ::J II) h \. 0 () I I -;t) ~ ~ ~ ~ ~~~ o C> ~ ""rJr-- S,~j r.-'- t:~,: ,.,.---- ~c.. .L - {) (:~ ""'1 (' i"'.J :" ("":1 ~.~ . ... [ .. ~~ bi!1 ; ~ ~ :~ L ,--.- - -_ 0,' l"t>: SHERIFF'S RETURN - GARNISHEE CASE NO: 2001-01173 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND PNC BANK NATIONAL ASSOCIATION VS NORSOFT INC And now RICHARD E. SMITH ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 1505:00 Hours, on the 5th day of March 2001, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT NORSOFT INC , in the hands, possession, or control of the within named Garnishee COMMERCE BANK 100 SENATE AVE. CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to TINA HAAS, ASSISTANT MANAGER personally three copies of interogatories together with THREE true and attested copies of the within WRIT OF EXECUTION, PETITI and made the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 So an~.rs: ~~... ~./~ . ~ r.~~ . . Thomas Kl ine Sheriff of Cumberland County 00/00/0000 Sworn and subscribed to before me this 1 ~ day of~ :Lo-o1 A.D. Q't/' .(2 ~ ~ Proth n tary By ~________u ,. Deputy Sheriff I ~ , -" _... I ~ , -, , -, 1"., " ,~ _-",,-c-_:"" "<"':~ . .... PNC BANK, NATIONAL ASSOCIATION, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-1173 NORSOFT, INC., Defendant : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW PRAECIPE FOR JUDGMENT UPON ADMISSION To the Prothonotary: Please enter judgment in favor of the Plaintiff, PNC Bank, National Association, and against the Garnishee, Commerce Bank, in the amount of Nineteen Thousand Four Hundred Twenty-Seven and 46/1 00 Dollars ($19,427.46) plus interest and costs of suit, for the following property of the Defendant: Any and all funds held by Commerce Bank in the following account of Nor soft, Inc.: Account Number: 030017974 Balance: $19,427.46 Garnishee admitted in the answer to interrogatories that it was in possession of said property. Respectfully Submitted, SAIDlS, SHUFF, FLOWER & LINDSAY n.w 71~2(o( By: M 0 arl Ledebohm Supreme Court ill #59012 2 I 09 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff w-~- , " "-,),e .'" - ~ c " PNC BANK, NATIONAL ASSOCIATION, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAm:> COUNTY, PENNSYL VANIA : NO. 01-1173 NORSOFT, INC., Defendant : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW NOTICE OF JUDGMENT UPON ADMISSION TO: Norsoft, Inc. and Commerce Bank You are hereby notified that on '~...f"4\..3 .,2001, the following judgment has been entered against you in the above captioned case: Judgment in favor of PNC Bank, National Association, Plaintiff, and against Commerce Bank, Garnishee in the amount of Nineteen Thousand Four Hundred Twenty-Seven and 46/100 Dollars ($19,427.46) and for the following property of the Defendant, Norsoft, Inc.: Any and all funds held by Commerce Bank, in the following accounts of Nor soft, Inc.: Account Number: 030017974 Balance: $19,427.46 Judgment is entered pursuant to Pa. R.C.P. 3146(b), Garnishee having admitted in the answer to interrogatories that it was in possession of said property. O-rto > /) .~ Dated: {)p(L'~ \ J I d-06( Prothonotary I hereby certify that the proper person/entity to receive this notice under Pa. R.C.P. 236 is: Norsoft, Inc. 3438 Toodle Road Camp Hill, PA 17011 Norsoft, Inc. c/o Lawrence Berger Knorr, President 8 Appaloosa Way Carlisle, P A 17013 1 - . " Date: I~' - I .. ^ I Commerce Bank 100 Senate Avenue Camp Hill, PA 17011 . Respectfully submitted, -'"-' "" / . ,c;:;;- '~.~ SAIDIS, SHUFF, FLOWER & LINDSAY 3IV7/(or 'By: M. Le ebohm, Esquire Supreme Court ill #59012 2 I 09 Market Street Camp Hill, P A 17011 (717) 737-3405 Attorney for Plaintiff 2 .. , I '.J.'" ~,,"- """-'-- .-,,,'. -u . PNC BANK, NATIONAL ASSOCIATION, Plaintiff v. : IN 1HE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-1173 NORSOFT, INC., Defendant : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW NOTICE TO: Norsoft, Inc. and Commerce Bank Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a JUDGMENT BY ADMISSION has been entered against you in the above proceeding and that enclosed herewith is a copy of all the docwnents filed in support of the said judgment. IF YOU HAVE ANY QUESTIONS CONCERNING TillS NOTICE, PLEASE CALL: KARL M. LEDEBOHM, ESQUIRE TELEPHONE NUMBER: (717) 737-3405 ~~~ - . Prothonotary 0 .'l- ~~~Itlti*~~""llil!L~mJ!ii!i\g-~1ilM!)>'~$~t"-..JiW!i'"*,~.;.'",I;.",,,*,,,,0!,,~,;'~lfi!<!iII.iliJlli!!lll~~il1!Ifl~_ ~_ '"~O~ ~I..-o" IilWIiiIiI. ~ ,- . 0 C' 0 ~ C '! ~ 7J ~ <" """ ...() u[--C " - T~ '""7--, ~ , CPC ::::l.J 1;.__-,: g ""',- --'..' ~:;:; I I" (..) C.' ~ , r ..... tv r---,'-' C::'J () ~~~ :::::', -...:J r .~. -. " .4\ ~C) :',..-: C':! lV >c 5 ijiT1 ~ i'" -.-J ~ -:."-1 ?' ~-- :..., ~ =< :l:J ~ ....J -< ~ rf ~ ~ , _,",'~~'_, ~A,=_',.___ ,., -'~- .~,. ~ . ~ ' I.--c ,_,,0, ",,".\f ,-, V"".,C,'j " . PNC BANK, NATIONAL ASSOCIATION, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CrnvtBERLAND COUNTY, PENNSYLVANIA ; NO. 01 - II7J NORSOFT, INC., Defendant : CONFESSION OF JUDGMENT : CIVIL ACTiON ~ LAW P~~..Jo INTERROGATORIES TO GARNISHEE TO: Commerce Bank You are required to file answers to the following interrogatories within twenty (20) days after service upon you. The l!IlSwers must be in writing and under oath. You are warned that if you fail to do so, a Judgment may be entered against you by the Court without further notice for any money claimed by the Plaintiff against the Defendant. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 or 1-800-990-9108 :Jii[ ,-,,'1 ',- J ~ ., ~ ..f' PNC BANK, NATIONAL ASSOCIATION, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. NORSOFT, INC., Defendant : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW 0" INTERROGATORIES To: Commerce Bank You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you: 1. At the time you were served or at any subsequent time did you owe the Defendant any money or were you liable to them or any of them on any negotiable or other written instrument, or did they or any of them claim that you owed them or any of them any money or were liable to them or any of them for any reason? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the vaiue and location of any property and the amount of consideration given for any transfer of property. \) t' +r",.o\c, ~~ 1, ,,^uJ , 0, ~ C' \ c, ", c 1:' [) t \ 0 h."" o. 1 1\::-, 0 J ,/;I L'" t" C H "'~':.J' L u, - v."O I 0 ::> 0 C i 7 'J '7 I ~v I "1""1-1. f./ i'i ~ ).7, <f!P 11.+ +Llt'+,'wlf' C;fY"vfJ J -'".-1 -~/'- " . 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the Defendant? If so, explain in detail including, without limitation, the names and addresses of ail persons or entities taking part in any ;.- transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property, 5(' t' C\V'Su...e..- -./-e, 7ut5 tJ'O '^ -::1 /. 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the Defendant or in which Defendant held or claimed any interest? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. f j. 4/ .,:;€e CtV'5'-<.-ev -ro J ut'5 J c", ' --- .. -> -: . , At the time you were served or at any subsequent time did you hold as fiduciary any property in which the Defendant had an interest? If so, explain in detail including, without 4. limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. No" 5. At any time before or after yolu were served did the Defendant transfer or deliver any I property to you or to any person or place PUfSuant to your direction Of consent and if so what was the consideration therefor? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and 1!he amount of consideration given for any transfer of property. Det",) ,1", 1- W,".oJ" ell" fes If.5 ) VI ic 'f-ht' a.b C "It' fff.,<y" C ej 0.(((>\.-",+ 1v. \l-lct' o,"^{.t\''''V'j (~''-rSt_ f'rl'or Ie SP"'C";'C~ ~\D.1e ot Lvll.\'ck tc"",.." (\t- r.;.t"" r,{"v't'c/'ov,- cf. COw>VV't'lrLF t5o.,J. 6. At any time aftef you were served did you pay, transfer or deliver any money or property to the Defendant or to any person or place pursuant to the direction of them Of any of them " or otherwise discharge any claim of the Defendant against you? If so, explain in detail including, No" -- ~~- . I .:.1 .~ . I "" j 1I. -' -^"~-j . , No. 7. At the time you were serve<l or at any subsequent time, did you have any safe deposit boxes, pledges, documents of title" securities, notes, coupons, certificates, receivables, collateral, checking, savings, tax or other accounts or deposits in which Defendant has an interest? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the sp~ific amount of the debt, the vaiue and location of any property and the amount of consideration given for any transfer of property. No. .= .'t ., -~ , '., These Interrogatories shail be deemed to be continuing Interrogatories. If after the time of your answer, you or anyone acting in your behalf learn or obtain additional information requested, but not supplied in your answers, you shall promptly furnish a supplemental answer under oath containing the same. ,. Respectfully submitted, Date: ~ I Z--ti! /j ) SAIDIS, SHUFF, FLOWER & LINDSAY B~a etPJ)~ ;1 Karl M. Ledebolun, Esquire Supreme Court ID #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff For signature by Garnishee: 'rie(~j H. 8"," \'fY states subject to the penalties of 18 Pa. C.S.Section 4904 relating to unsworn falsification to authorities, that he/she is authorized by Garnishee to make this affidavit, and that the facts set forth herein are true and correct to the best of his/her knowledge, information and bel~~f. 1 L/-{. 1/ //}/J/1 c, j /7 _ l:::!1LCV,c j'I' I. u~,-- Dated:=]- /1 ' 200 I c.c'-"'r'J I"e, tI ",/ 5("( vy-,/.::; (}f1,'dV ~~~iltif;"",:'~\l):ibfil""-<!>.>4'&ltlt_;>.",*-i,j!~'"~'!j<1Oi4~~,;';,,"r.t;,,(-,,t~:i~";-'e-iI"",'~M.;~i,]-,:,_,~"~t!ii!M8!l~~~~~iiI~_~I~ ".~ =",~>"" ,~,_ <, "'_,,",i""'=~ -'-"'.-' ""P"-~" <<"",,,. ,.- ,~ .~ ~ 0 -C'J Q ~ n :'-:::,. ,!':'I~ -- , v r~~ ~Q m c: :CO u_ '," :~ ;:.= r~' I U~ "'r___ (.~) , -<c CC - , -' ~ J:-l'. ;?: C) -, -.. ~-:_~ (-"5 )> Ci C) ,-~ 1'(" c: 5-:! z :,0 --, Xl -< ..... -< ~ " _-I"" .,,'~" IU~(I ~ '_ I, ,.."....( , ,-. .- .-;.,~-, ~\: WRIT OF EXECUTION and/or ATTACHMENT CdMMbNWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01-1173 CIVIL m TERM CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due PNC Bank. National Associati on PLAINTIFF(S) from NOrsoft. Inc., c/o Lawrence Berqer-Knorr, President, 8 Appaloosa Way. Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of Corrmerc@.: 'J3;:Jnk. 1 nn Spn;=l'h:. avpn"p, r.=amp Hi 11. 17f'l11 ~ny 7no ~ll p~r50n~1 prepertv of Norsoft. IncH in the possession of Gi'lrni<<I1"". in"lllcling Wit-11011t- limit->>tion any funds held on account. GARNISHEE(S) as follows: and to notny the gamishee(s)' that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or. for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property ofthe defendant(s) not levied upon an subjectto attachmerilis found il")the possession of anyone other than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $386,351. 95 % L.L. Due Prothy Other Costs $.50 Interest from 2/22/01 Atty's Comm Atty Paid $1 nn $32.50 Plaintiff Paid Dme: February 28, 2001 Prothonotary, Ci IVISlon 'by: dfYJJ -' P. 71~ r- Deputy REQUESTING PARTY: Name Karl M. Ledebohm, Esq. Address: 2109 Market Street Camp Hill, PA 17011 Plaintiff Attorney for: Telephone: Supreme Court 10 No. , 717-737-3405 59012 . ~ -," ~ '" ~ ~~ "~~,=. - ~. "' - ~-"'--~. ,,~ <~.-.., " " ~ OfFICE Of THE SHERIFF e\jMBn\L'\l'~ cnl.!!lTV HAR I 3 42 PM '01 Ci\il.L!SLE PENNSYLVANIA R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Garnishee Docketing Pound acre Law Li5rary Prothonot11ry Mi.lage Surcharge Levy $ $ 9.00 18.00 1. 75 .50 1. 00 9.30 30.00 20.00 89.55 Advance Costs: Sheriff's Costs $ 150.00 89.55 60.45 Refund to Atty 4/23/01 this .2~ ~ day of Oph-J 2001 A.D. Y:'{' 0 'rvw"p''',AD.r'f p othonotary So ~r;;,w7' :~. r~ ~~f ~. ;homas Kli e, Sheriff ~ ~ - . Sworn and Subscribed to before me By - r 1 (l J !~tL ~ t , ,j\edt<../- 2 - I ::,'0 . c.-vz 3.) I f7 fu"...I/D77L ~. l1""j ~"',1liM""'- ,~, L "', _, ~."",~,"ryr1..q~~'~,:" '_:"_ '0. ~,," :1%,",~~j~~-w,'ili'!ll:"""'>;iJ>'lB!"<f-'J'''i'~;1!b"$'-'_~ffifu~~,~ifj:!};;pl~!lw.9!'1jF'1,.'<i~~~ ,1- i, . -. ~"-", -"-"", , ' > , PNC BANK, NATIONAL ASSOCIATION, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANlA : NO. NORSOFT, INC., Defendant : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW INTERROGATORIES TO GARNISHEE TO: Commerce Bank You are required to file answers to the following interrogatories within twenty (20) days after service upon you. The answers must be in writing and under oath. You are warned that if you fail to do so, a Judgment may be entered against you by the Court without further notice for any money claimed by the Plaintiff against the Defendant. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 or 1-800-990-9108 ~H Co ~,- 'L - ~. , PNC BANK, NATIONAL ASSOCIATION, Plaintiff v. : IN TIIE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. NORSOFT, INC., Defendant : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW INTERROGATORIES To: Commerce Bank You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you: 1. At the time you were served or at any subsequent time did you owe the Defendant any money or were you liable to them or any of them on any negotiable or other written instrument, or did they or any of them claim that you owed them or any of them any money or were liable to them or any of them for any reason? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. ." ',I '--. - .'--';;x , ' 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the Defendant? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the Defendant or in which Defendant held or claimed any interest? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. 01 o,~ 1 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the Defendant had an interest? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. 5. At any time before or after you were served did the Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefor? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. 6. At any time after you were served did you pay, transfer or deliver any money or property to the Defendant or to any person or place pursuant to the direction of them or any of them or otherwise discharge any claim of the Defendant against you? If so, explain in detail including, - , , ." without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. 7. At the time you were served or at any subsequent time, did you have any safe deposit boxes, pledges, documents of title, securities, notes, coupons, certificates, receivables, collateral, checking, savings, tax or other accounts or deposits in which Defendant has an interest? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. ---_.._-~- ;0 ,-..---,.--.' .. ~,,- ,. These Interrogatories shall be deemed to be continuing Interrogatories. If after the time of your answer, you or anyone acting in your behaIfleam or obtain additional information requested, but not supplied in your answers, you shall promptly furnish a supplemental answer under oath containing the same. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Date: v! 'V'!/I tJ ) By: Kar M. Ledebohm, Esquire Supreme Court ill #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff For signature by Garnishee: states subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, that he/she is authorized by Garnishee to make this affidavit, and that the facts set forth herein are true and correct to the best of his/her knowledge, information and belief. Dated: ,2001 t!iif~~am~1IiIl>>~8f~\4m,!!iil~1 j11 i_.wilill:UUli .......;..,1 ,; ""c""'~ r~.ib:".'" 'J' V/NVI, , :"!-k.?!SNl1] .. ., " '1 .J - ,_) -' : 'l--~ U ,,'. .1 10, /{d [IJ -. ,.". , .,.." C I lit AIfJ.fJ.Cc"'''"',., 'It filliN<' ',.',' I",:,,,., " , "I' ~",.,/)~ J.; .:J'/l :Y,,_ q v 01'diJ1(/ , '~ , ,. (==) CViJ I::jj:j] C=:::J G7) If\i1J IN' - ,I; - ,~~.. ~ ~. " '" ., ~ ;r,lIh PNC BANK., NATIONAL ASSOCIATION, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-1173 NORSOFT, INC., Defendant : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Please mark the judgment entered against Commerce Bank in the above-captioned action satisfied. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Date: 11<10 ~\ By: I M. edebohm, Esquire upreme Court ill #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff ~~-.t...:uildlJimi~~lr~#;mt.:!l!,f~"iffi!;tllffii";llit,U!;;,.\ilID~"",~,;i,"""",,1,",*'~"""i~'~1od:ti.;""'i!'~_')E;:'~~<ilJI;~lIIIiiiilliilillii-'''' "f' ~t't"" L- ',~ .,0 , ~ - jj'if ~-: t ~ h f( 0 ~ 0 ,...., CJ ,~ ,~, ~ c -" ?:.: :r. 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