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Home My WebLink About01-1992 FX CONSUMERS LIFE INSURANCE COMPANY, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, CIVIL ACTION - LAW MATT CORPORATION, No. 01- 1'1'9.;:(. C,,~( '-r~ Defendant COMPLAINT 1, Plaintiff is Consumers Life Insurance Company ("Consumers"), a Delaware Corporation with offices located at 1200 Camp Hill By-Pass, Camp Hill, Pennsylvania 17001- 0026. 2. Defendant is Matt Corporation, a Pennsylvania Corporation with offices located at 2016 Yale Avenue, Camp Hill, Pennsylvania. 3. On March 31, 1999, Consumers and Matt Corporation executed a Judgment Note (the "Note"). A true and correct copy of the Note and an affidavit verifying the Note are attached hereto as Exhibit A. 4, The Note provided that Matt Corporation would pay $15,668.25 to Consumers in three equal payment of$5,222.75. See Paragraph 2 of Exhibit A, 5. The Note contains confession of judgment and warrant of attorney provisions which, upon tenant's default of the note, authorize any attorney of any court of record to appear for Matt Corporation and to confess judgment for the recovery of the unpaid principal sum, plus interest and all other charges due under the Note, including an attorney's commission consisting of 10% of the amount due and costs of suit. See Paragraph 6 of Exhibit A. """"~!!1"l'Mffi1ll!ll1~,""!,,, ,~. , Il"']''''~ , I T .' II~" , ' ~.- ~~~ 6. The Note states that the first payment is due on or before June 1, 1999, that the second payment is due on or before September 1, 1999, and that the third payment is due on or before December 1, 1999. See Paragraph 2 of Exhibit. A. 7. The Note provides that the failure to pay the full amount of principal on or before any payment due date constitutes a default of the Note. See Paragraph 4(B) of Exhibit A. 8, Matt Corporation has failed to make any payment of any amount required by the Note, 9, Matt Corporation is in default ofthe Note. 10, The Note provides that any payment which is not received within five days after the due date is subject to a late charge of 5% ofthe payment. See Paragraph 4(A) of Exhibit A. 11, The Note provides that any payment that is not made on or before the due date is subject to default interest at a yearly rate of 12%, See Paragraph 5 of Exhibit A. 12, An itemized computation of the amount due through April 4, 2001, is as follows: First Payment Second Payment Third Payment 5% Late Charge on First Payment 5% Late Charge on Second Payment 5% Late Charge on Third Payment Default Interest on First Payment Default Interest on Second Payment Default Interest on Third Payment Subtotal 10% Attorneys Commission TOTAL $5,222.75 $5,222,75 $5,222,75 $ 261.14 $ 261.14 $ 261.14 $1,157.30 $ 999.33 $ 843.08 $ 19,451.38 $1,945.14 $ 21,396.52 plus costs. 13, Judgment is not being entered by confession against a natural person in connection with a consumer credit transaction. 2 ~r, ,,~ " - I~ 11 I ,I , 14. Neither Consmners nor Matt Corporation has assigned the Note to any other party, 15. Judgment has not been entered on the Note in any jurisdiction. WHEREFORE, Consmners Life Insurance Company demands judgment against Matt Corporation in the amount of$21,396.52, plus costs. McNEES, WALLACE & NURICK BY~f!/. ~ 'rob ly M. Colonna J.D. No, 80362 100 Pine Street P.O, Box 1166 Harrisburg, PA 17108-1166 (717) 237-5278 Attorneys for Plaintiff Dated: April 5, 2001 3 .~lr: ,. -<' I-I I ,,-- ., ! 04/05/2001 10:49 7177619473 MCNEES,WALLACE,NURICK2 ID:fl(~25(-o5UU CONSUMERS FINANCIAL Hr'K U~'Ul lU::<~ N "PAGE 02/02 O.UH> r'.UO VRRlIIJCATJON Subject to the penaliiell of 18 Pa, C,S.A. ~ 4904, relating to unsworn falsification 10 authorities, I herebY cerlilY thaI I am the Treasurer ofColls\lm~ Life Itlsuml1ce Company, that I am aut)1ori:zcd to make this vorification on its behalf, that J have reviewed 1M foregolllg and that the facls set fortll therein are true and correct to the besl of my Jmowlroge, infonnation and bolief. CONSUMERS LIFE INSURANC.E COMPANY Pated: "f(5~1 <""', ,~, " ,. 1"'1 ,'~ 1" JUDGMENT NOTE $15,668.25 M I\/,,~ 'Sl , 1999 1. BORROWER'S PROMISE TO PAY FOR VALUE RECEIVED, Matt Corporation, with an office at 20 16 Yale A venue, Camp Hill, Pennsylvania, ("Maker") promises to pay Fifteen Thousand Six Hundred Sixty-Eight Dollars and 25/100 Cents ($15,668.25) (this amount is called "principal"), to the order of Consumers Life Insurance Company ("Consumers"). Maker understands that Consumers may transfer this Note. Consumers or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder." 2. PAYMENTS Principal on this Note is due and payable in three equal payments of $5,222.75 each, as follows: the sum of $5,222.75 on or before June 1, 1999; the sum of $5,222.75 on or before September 1, 1999; and the sum of $5,222.75 on or before December 1, 1999. Maker will make the required payment at 1200 Camp Hill By-Pass, Camp Hill, Pennsylvania 17001- 0026 or at a different place if required by the Note Holder. 3. BORROWER'S RIGHT TO PREPAY Maker has the right to make payments of principal at any time before the Payment Due Date without paying any prepayment charge. When Maker makes a prepayment, Maker will tell the Note Holder in writing that Maker is doing so. The Note Holder will use all of Maker's prepayments to reduce the amount of principal that Maker owes under this Note. 4. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payment If the Note Holder has not received the full amount of a payment pursuant to paragraph 2 hereof by the end of five (5) calendar days after the payment due date, Maker will pay a late charge to the Note Holder. The amount of the charge will be five percent (5%) of the payment not paid when due. Maker will pay this late charge promptly. (B) Default If Maker does not pay the full amount of principal on or before any payment due date, Maker will be in default. ."" , . '." """- ~- ,~ "..., 5. DEFAULT INTEREST If a payment is not made in full on or before a payment due date, interest will be charged until the full amount of the payment has been paid. Maker will pay interest at a yearly rate of twelve percent (12 %). The interest rate required by this Section 6 is also the rate Maker will pay after a judgment, if any, is entered on this Note. 6. CONFESSION OF JUDGMENT UPON EVENT OF DEFAULT MAKER DOES HEREBY IRREVOCABLY AUTHORIZE AND EMPOWER ANY PROTHONOTARY, CLERK OR ATTORNEY OF ANY COURT OF RECORD WITHIN PENNSYLVANIA OR ELSEWHERE TO APPEAR FOR AND ENTER JUDGMENT AGAINST IT FOR THE UNPAID PRINCIPAL SUM DUE HEREUNDER, TOGETHER WITH INTEREST, IF ANY, AND ALL OTHER CHARGES OR SUMS DUE HEREUNDER, TOGETHER WITH A REASONABLE ATTORNEYS' COMMISSION FOR COLLECTION OF TEN (10%) PERCENT OF THE AMOUNT DUE, WITH OR WITHOUT DECLARATION, WITH COSTS OF SUIT, RELEASE OF ERRORS, WITHOUT STAY OF EXECUTION; AND MAKER ALSO WAIVES THE RIGHT OF INQUISmON ON ANY REAL ESTATE THAT MAY BE LEVIED UPON TO COLLECT THE NOTE, AND DOES HEREBY VOLUNTARILY CONDEMN THE SAME, AND AUTHORIZE THE PROTHONOTARY TO ENTER UPON THE WRIT OF EXECUTION SAID VOLUNTARY CONDEMNATION; AND FURTHER AGREES THAT SAID REAL ESTATE MAY BE SOLD ON A WRIT OF EXECUTION, AND MAKER HEREBY WAIVES AND RELEASES ALL RELmF FROM ANY AND ALL APPRAISEMENT, STAY OR EXEMPTION LAWS OF ANY STATE NOW IN FORCE OR HEREINAFTER TO BE PASSED. IF copms OF THIS NOTE, VERIFIED BY AFFIDAVIT OF THE HOLDER HEREOF OR SOMEONE ON THE HOLDER'S BEHALF, HAS BEEN FILED IN SUCH ACTION, IT WILL NOT BE NECESSARY TO FILE THE ORIGINAL OF TInS NOTE AS A WARRANT OF ATTORNEY. THE AUTHORITY AND POWER TO APPEAR FOR AND ENTER JUDGMENT AGAINST MAKER WILL NOT BE EXHAUSTED BY THE INITIAL EXERCISE OF THE AUTHORIZED POWER, AND THE POWER MAY BE EXERCISED FROM TIME TO TIME AS OFTEN AS THE HOLDER DEEMS NECESSARY OR DESIRABLE; AND TInS INSTRUMENT WILL BE A SUFFICmNT WARRANT. THE PRECEDING PARAGRAPH SETS FORTH A WARRANT OF AUTHORITY FOR AN ATTORNEY, PROTHONOTARY OR CLERK TO CONFESS JUDGMENT AGAINST MAKER. IN GRANTING THIS WARRANT OF ATTORNEYTO CONFESS JUDGMENT, MAKER HEREBY KNOWINGLY, INTENTIONALLY AND VOLUNTARILY, AND, AFTER CONSULTATION WITH LEGAL COUNSEL OF ITS OWN CHOOSING, UNCONDITIONALLY WAIVES ANY AND ALL RIGHTS IT HAS OR MAY HAVE TO PRIOR NOTICE, AND AN OPPORTUNITY FOR PRIOR HEARING UNDER THECQNSTlTUTIONS AND LAWS OF THE UNITED STATES OF AMERICA, THE COMMONWEALTH OF PENNSYLVANIA AND ALL OTHER APPLICABLE JURISDICTIONS. 2 ,"~- - -"'~'~ M,I'l"'1W"" . I MAKER UNDERSTANDS THE MEANING AND EFFECT OF THE WARRANT OF AUTHORITY TO CONFESS JUDGMENT CONTAINED IN THE FOREGOING PARAGRAPHS. SPECIFICALLY, MAKER UNDERSTANDS, AMONG OTHER THINGS, THAT (1) MAKER IS RELINQUISHING THE RIGHT TO HAVE NOTICE, AN OPpORTUNITY TO BE HEARD, AND THE RIGHT TO HAVE THE BURDEN OF PROOF OF DEFAULT REST ON THE NOTE HOLDER PRIOR TO THE ENTRY OF JUDGMENT, (II) THE ENTRY OF JUDGMENT MAY RESULT IN A LIEN ON MAKER'S PROPERTY, (Ill) MAKER'S PROPERTY MAY BE TAKEN TO PAY THE PRINCIPAL AMOUNT, INTEREST, LATE CHARGES, COSTS AND ATTORNEYS' FEES AS PROVIDED ABOVE. TO THE EXTENT PERMITTED BYLAW, ACTING UNDER REPRESEN'fATION OF COUNSEL, MAKER HEREBY IRREVOCABLY WAIVES ANY DUE PROCESS RIGHTS TO PREJUDGMENT NOTICE AND HEARING AND/OR pOST-SEIZURE RELIEF ARISING IN CONNECTION WITH, OR IN ANY WAY RELATED TO, THE NOTE HOLDER'S RIGHT TO CONFESS JUDGMENT AGAINST MAKER AS HEREIN PROVIDED, AND MAKER ACKNOWLEDGES AND UNDERSTANDS mAT BY WAIVING THESE RIGHTS, MAKER HAS CONSENTED TO ALLOW THE NOTE HOLDER TO ENTER A COURT JUDGMENT AGAINST MAKER WITHOUT PRIOR NOTICE OR HEARING IN ORDER TO SATISFY THE OBLIGATIONS OWED BY MAKER TO THE NOTE HOLDER. MAKER HEREBY KNOWINGLY AND IRREVOCABLY WAIVES TRIAL BY JURY IN ANY ACTION OR PROCEEDING TO ENFORCE, OR OTHERWISE INVOLVING, TillS NOTE. MAKER FURTHER IRREVOCABLY CONSENTS TO THE JURISDICTION AND VENUE OF ANY STATE OR FEDERAL COURT SITTING IN OR FOR DAUPHIN COUNTY, PENNSYLVANIA. [Initials: ~ 7. GMNG OF NOTICES Unless applicable law requires a different method, any notice that must be given to Maker under this Note will be given by delivering it or by mailing it by frrst class mail to Maker at the Property Address above or at a different address if Maker gives the Note Holder a notice of our different address. Any notice that must be given to the Note Holder under this Note will be given by mailing it by first class mail to the Note Holder at the address stated in Section 2 above or at a different address if Maker is given a notice of that different address. 8. WAIVERS Maker waives the rights of presentment and notice of dishonor. "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of dishonor" 3 ,",.n' ,_. l d ,~" 1"'1. r ' - I - '_ " 3'" _ "~_~ . , .' ,t means the right to require the Note Holder to give notice to other persons that amounts dne have not been paid. WITNESS THE HAND(S) AND SEAL(S) OF THE MAKER. ATTEST/V- T" ...- -!to MATT CORPORATION --::::::=-~L BYC=-~O President ~ 175525,1 4 .. " , > .- , ~ " 11 l' 1 I ~ " " ~ , CONSUMERS LIFE INSURANCE COMPANY, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CNIL ACTION - LAW MATT CORPORATION, No. Defendant Affidavit Verifyin2 Jud2ment Note Kimberly M. Colonna, on behalf of Consumers Life Insurance Corporation, being duly sworn, declares and affirms as follows: 1. I am an attorney with the law firm of McNees, Wallace & Nurick. 2. McNees, Wallace & Nurick represents Consumers Life Insurance Corporation, the Plaintiff in the above-captioned matter. 3. A copy of a Judgment Note is attached to the Complaint in the above-captioned matter as Exhibit A. 4. By consulting with a representative of Consumers Life Insurance Corporation, I have verified that the copy of the Judgment Note attached to the Complaint as Exhibit A is a true and correct copy. Further the affiant saith not. ~,~ Kim erly . Colonna NOTARIAL SEAL ANNE E. MARCHAND, Notary Public Harrisburg, PA Dauphin County My Commission Expires Dec. 2, 2004 fb!, Subscribed and sworn before me this ~ day of April 20 1. '-'~~ I~n ~I ~""'-' < . CERTIFICATE OF SERVICE I hereby certify that a true copy of the foregoing docmnent was this day served upon the following via first class mail, postage prepaid: Matt Corporation 2016 Yale Avenue Camp Rill, PA 17011 ~~ Kim erly . Colonna Date: April 5, 2001 i1:; f" -L,-"~_,,,,,. -- ~.,. 1""1 .,.. . -- ~....-~, .....c "-" ~ - ~ ,~ ,"'~ -,. "'"'~~ .< ~~- . """ ,,', ~-'-~'., . . c' C) '-'! ~ :~"F> .e ~ ~ -n p -on -t , 1 It- er. -:'-:1 C3 R C; '" r ~ "'Cl C> '" r-" :J~ {}: Lv ,.i;- -<. Df tv ~ -- ~J R: _~..,_,."lI'.wl'f!1!l~~~'1II':'~~~""".?".t_'I!~.-l!!i!~I'IIfiffiffi~~!'ff->""""'1-:,"""'-''''''"'--";1 ^;;;~-:',""'v_- ~ ' -,.;~ '~-~~r-';f";:-""",WT;f:""-"J~\"",:w",,"r.'!'P"f'dq''''''';'~~,^Tt''~~JI'1'''--i:;j ;""'>;;:'f'mf~~0 CONSUMERS LIFE INSURANCE COMPANY, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, CIVIL ACTION - LAW No.OI- Iq9~ C?'O;( y~ MATT CORPORATION, Defendant 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 plaintiff and against the defendant as follows; Subtotal $ 15,668.25 $ 783.42 $ 2,999,71 $ 19,451.38 Principal Late Charges Interest Attorneys Fees $ 1,945.14 TOTAL $ 21,396.52 plus costs McNEES, WALLACE & NURICK By ~fI1, ~ Kim erly]\i[. Colonna LD, No. 80362 100 Pine Street P.O. Box 1166 Harrisburg, PA 17018-1166 (717) 237-5278 Attorneys for Defendant Dated: April 5, 2001 ~"\l , ':1"10: ,~ '<F' ''1'1' , . ~ . ~ ,......",.. ~~'" ~,~. O~. "---~-.='4'~ ,,,--" , .~'T' , .^, "" T """"11"- g. -rJff.: I,-n! ~}~~: ~,\~-~. :g~; ~,.,--; ....<.:. I,::} '~e' jjl TiTl'''1 ,- _.,.-, ~" _~",,~~Ia~fl!!m'/N!!>!'!!liill",Il!~~~~m\!~!!!I.J0!I!ll\!'lWm~F~."'\~"""'F>""'H1~""~'Hjf,'i"')-'~':;"~'?-;3=,<~-ry-"!'!:''i:lf:'W-~'''":'f'P~~'l;'"l't'P'''''''(~~!ll!!:-''fJI'WiOl[ml!'W!ll'l~~~ . CONSUMERS LIFE INSURANCE COMPANY, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CIVIL ACTION - LAW MATT CORPORATION, No. 01- /9'i'J.... Co:l 'r~ Defendant Notice of Judgment TO: Matt Corporation, Defendant 2016 Yale Avenue Camp Hill, PA 17011 Y Oil are hereby notified that on f) on I {S , 2001, judgment by confession , was entered against you in the sum of$ 21,396.52, plus costs, in the above-captioned case. Copies of the documents filed in support of the confession of judgment (the Complaint and the Confession of Judgment) are enclosed herewith. DATE: "1/-.'/0/ e'~AJk~ Prothonotary Copy to Attorneys for Plaintiff: Kimberly M. Colonna McNees, Wallace & Nurick 100 Pine Street P,O. Box 1166 Harrisburg, P A 17108-1166 '~,~_ ,'. m~ IT I 1 ~ _O~I " - ," ~~ . ... CONSUMERS LIFE INSURANCE COMPANY, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, CIVIL ACTION - LAW MATT CORPORATION, No. 01- 1q1)... (3'Ot( /~ Defendant Notice under Rnle 2958.3 of Judgment and Execution Thereon Notice of Defendant's Rights TO: Matt Corporation: A judgment in the amount of$21,396.52, plus costs, has been entered against you and in favor of the plaintiff without prior notice and hearing based upon 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 of 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 judgment. If you wish to exercise this right, you must immediately fill 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 1 Courthouse Square, Carlisle, P A 17013-3387. IT IS IMPORTANT THAT YOU ACT PROMPTLY. IT WILL BE TOO LATE TO REGAIN YOUR PROPERTY IF YOU WAIT '~'Ii"i"''"W'\.''!'f!IlIiJllll!l!,lll . ~ I 11 , , , ~ ~r ~ -, ~ ~, '" . . UNTIL AFTER THE PROPERTY HAS BEEN SOLD BY THE SHERlFF 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 RlGHTS. ANY PETITION SEEKlNG RELIEF FROM THE JUDGMENT AND TO REGAIN POSSESSION MUST BE FILED WITHIN THIRTY (30) DAYS AFTER THE DATE ON WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RlGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland Connty Bar Association 2 Liberty Avenne Carlisle, P A 17013 (717) 249-3166 1 (800) 990-9108 McNEES, WALLACE & NURICK By--e~, U~~ imb rly M. Colonna LD, No. 80362 100 Pine Street P.O. Box 1166 Harrisburg,Pi\ 17108-1166 (717) 237-5278 Attorneys for Plaintiff Dated: April 5, 2001 ""WoI'''''';!' 0jI~"""!"''''I "", 1""'1'.' " , I . , ... . . CONSUMERS LIFE INSURANCE COMPANY, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CIVIL ACTION - LAW MATT CORPORATION, No. Defendant 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 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,A. S 4904 relating to unsworn falsification to authorities. Notice of the hearing should be given to me at Matt Corporation 2016 Yale Avenue Camp Hill, PA 17011 Dated; Defendant -'~:_: ,. " ,- -, , . " I" I 'I , : ~'fi "I" , , ~ ~, " ~ """ . ~~ I' , '," q, '"",", "'."-"'=''''",''>,",,,'''''''''''' ." Tr'H "-~Tllllml ~ ~lLT1M'''''''''iI~ o f;. -rJi-~: Q)i~_:: "'---- 65 ~"'i -C:::.:-' :_.-=-, c, .-.-. ~/ -'" ..t:1 :,J: .... -1'1 :Mi~ -t"~ , ,'-.,' ';' ,~ I (..oj --; ~~~~iI\f!l"'i!R~~~'ll.'f'tit'JlI"~~","~~~~Jii'>!iW,/:''''jW"g,,,,,,,,,,~,!,;,,,<,!~._.,-,,-!,,_.'!~:;-''''---'i'\''."-ii;;,''T''l''''j'''MI'''P_~_<!''~F~,'''_"~,;%_"~l*""''')!1''':''l"~~",~\,,rj'!l;1W'''"~W'~~!''I''f~~ . CONSUMERS LIFE INSURANCE COMPANY, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CIVIL ACTION - LAW MATT CORPORATION, No. 01 - 1992 Civil Term Defendant PRAECIPE FOR WRIT OF EXECUTION UPON A CONFESSED JUDGMENT To the Prothonotary: Issues a writ of execution upon a judgment entered by confession in the above matter, (1) directed to the sheriff of Cmnberland county; (2) against Matt Corporation, defendant; (3) and index this writ against Matt Corporation (4) Amount due: Principal Late Charges Interest Attorneys Fees Subtotal Costs $ 15,668.25 $ 783.42 $ 2,999.71 $ 1,945.14 $ 21,396.52 $ TOTAL $ Proceed to levy upon any and all personal property of the Defendant located at 2016 Yale Avenue, Camp Hill, Pennsylvania. '-"'<0"1"""" ~~_,= ., ,'''. , , . " -~-"~" . Certification I certify that: (a) This praecipe is based upon a judgment entered by confession, and (b) Notice pursuant to Rule 2958.3 will be served with the writ of execution. McNEES, WALLACE & NURlCK BY~/(. ~ rob rly M. Colonna I.D, No. 80362 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 237-5278 Attorneys for Plaintiff Dated: April 10, 2001 '"-. -, , 'I~'l' ., I' , ~ , < ,. ~,~, ~ ....~ ,~~. '"~ ,~",=.""'~,~..~..- -.. '''n .... . 11Ji',il~rm"nrmr o ~. c:=-' --;--c'-' /'.. "-~) \.C ~ ?' ( f t .. l,. ill t :-. ~ '" ';:- , ~ ~ () ~ "\. :<. i '6 & d ~ C) " ,.. ~ ,1 r~ ._W., ~Ul!'l.,,., J~~_:""""",,,,~~II'~,...~~~nl~.~I?B\P"'-''''''V'''')''''''P'~'4':1'''''n_F"1~~l'(,*Mf.l$.1IJ!'fl!~,Wl"~~"l\I~{l@~~!'!lifI~ R. Thanas Kline. Sheriff, who being duly sworn according to law. states this writ is returned STAYED. Sheriff's Costs Advance Costs: Sheriff's Costs: $ 150.00 70. J7 79.8:1 Docketing Poundage Law Library Prothonotary Milage Surcharge Levy $ 18.00 1'.37 .50 1.00 9.30 20.00 20.00 70.17 Refunded to Atty 5/21/01 . So Answers: ~/..",tI! ~M:~~4!~ ~. Thanas Kline, Sheriff Sworn and Subscribed to before this S"= d~Y o~ 2001 A.D. (,)0""" 0 'JJ",PiJ.. '~f' I " t?) prothonotary By(}jO I;dJ~@' ;ZkuJW/ Q, - , '- ~ ~ ~ ~ = .~ u '\ },S :~~: ~ -.I\",1t--. "'U' 'j 'f?,'\S' 't\.\\ . Got. to \ \ '<\'j\~~'O I l' .. ~\ >;\, ::l, ~).\. :I:Iil'" \,(0 e.k.3J.. <I'''' ~. II), :f;;L @J ':::;;11 , ~} F'" r.::~-- ", ~) r;:c"1 u'w .~~, .-""'~ ~. ,:' ~.J '., . 1'-11 -~ , ~.& - ~^~_.-,<~ ~, ^"""r'" , --",". - ~__ 1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO, 01-1992 CIVIL D TERM CIVIL ACTION. LAW TO THE SHERIFF OF CUmberland COUNTY: To satisfy the debt, interest and costs due Consumers Life Insurance Canpany PLAINTIFF(S) from Mr:tt-t- I'nrpnrr:tt-inn )016 Vi'll" A""nll". Ci'lmp Hill. Pi'l. 17011 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Pmr.eF>d to levy upon i'lny and all personal Drooertv of the Defendant located at 2016 Yale Avenue, Camp Hill. pennsylvania {2} You are also directed to attach toe property of the detendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to nomy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) islare 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 of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as agarnishee and is enjoined as above stated. % L.L. Due Prothy Other Costs $0,'>0 Sl. 00 Amount Due $71 1%. '>) Interest Atty's Comm Ally Paid PI<lintiff Paid s 32.00 Date: April 10. 2001 Curtis R. Lonq Prothonotary, Civil Division by: q.'r" (I~ Deputy REQUESTING PARTY: Name Kimberlv M. Colonna ~Address: 100 Pinp. Street P. O. Box 1166 IlanisbUfg, ra. 17102 11€€ Attorney for: Plff Telephone: (717) 237-5278 Supreme Court ID No, 80362 _ lE'iI~RlIm"~~''i~''>/ii!~--:l--n_~~!lIl'",f!r-6'''f-1","~'!'''',~I~'M;q'"" -':":11'0-,,',"'>'--' ,'_fc(~' ~i:;,1!""""""t~~~J;~;;~~'IjJ.!iW~"''':''p''''5''"''''ifj'H'iM,'''J?!';"i''1,:,,!q:!,,,' f~i'&t~~~:;.TI['\\1:0i~~t:~.;f;:i: ,. CONSUMERS LIFE INSURANCE COMPANY, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CIVIL ACTION - LAW MATT CORPORATION, No. 01 - 1992 Civil Term Defendant PLAINTIFF'S PRAECIPE TO MARK JUDGMENT SATISFIED To the Prothonotary: Kindly mark the judgment entered in this action SATISFIED. McNEES, WALLACE & NURICK By Ctt~ ~ Kim erly M. Colonna J.D. No. 80362 100 Pine Street P,O. Box 1166 Harrisburg, P A 17108-1166 (717) 237-5278 Attorneys for Plaintiff Dated: May 21,2001 ~'''."''''l'I 'r . 1;-1, ,--- r ,,,,," " -~ . I --- -------',_: ~%r:;;&:;rj,~i~~tf;i~~~~;.1r,::~w,~ CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date, a true and correct copy of the foregoing was served by regular first class mail, postage prepaid upon the following: Thomas B. Schmidt, III Pepper Hamilton, LLP 200 One Keystone Plaza North Front and Market Streets Harrisburg, PA 17108-1181 .t~~ Kimberly M. Colonna Dated: May 21,2001 '..._~~ t' ',"', -~t \'''''- "-'0- "" - -'I-~I,~'i - .-,'r"l - -.-- ~~~, . ~ ~" ,m ,. << <~-< '" --v-. [11l'l'l~"'T I" . ~- -' ,-~,--, ;,,' , " ",'=- " ~" ~" "~~,."",,,-,-- "'-:ffi-~'" .-;&:;"~"'''''-'''''''f,;;-,t~~';:''''MS!7~~~"~-~'\li1trm wI'" -"7%~%D~Wi::ij!Mfl1l~; () 0 0 C -n 7' L -~ --~ v'Ct~ c: ;-':;-;," O)[T' -<~ ",- r- -"'--.J...' -;.~~. -~-:'; (Ii G:j~: ,;~~T -<..-..::::: ""0 r-o " .-.Jll < :);> C'; ;"~:l" -'. (--.J~~ 20 ~o Pc:: OITI Z ~n ;:.::! =< (n ~ _'IIl~' ~<, '~",~_;!i:;","_l"'_!f,ej;)lfW'!!""'11_WPFi'V'''''',";,,;,,?!"C;?i~'''_''~''r',.II;"'];~~~':tl1f!illIil'!OO!I'!ll'!~I~~~~~[