HomeMy WebLinkAbout01-2455 FX
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FIRST UNION NATIONAL BANK
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNT1::,YENNSYL VANIA
: CIVIL ACTION - LAW
vs
No. 01 - .:lLl$'S
C~~iL 't~
RONALD B. CLIPPINGER and
NANCY K. CLIPPINGER,
husband and wife,
jointly and severally,
Defendants
CONFESSION OF JUDGMENT
CONFESSION OF JUDGMENT
Pursuant to the authority contained in the Warrant of attorney, a copy of which is
attached to the Complaint filed in this action, I appear for the Defendants and confess judgment in
favor of the Plaintiff and against Defendants, jointly and severally, as follows:
Principal Balance
Interest as of 04/13/01
with a continuing per diem
interest rate of $7.50 as per
terms of the Note
Release fees
$24,032.91
322.50
11.50
Attorney fees of 15 % as per
terms of the Note ' ,
(Only actual attorney
fees will be collected ..
at the time of payoff)
TOTAL
3,655.04
$28,021.95
with interest continuing from April 13, 2001 at the pe
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Attorney for Defen
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LINTON, DISTASIO, ADAMS & KAUFFMAN, P.C.
By: Anthony R. Distasio, Esquire
Attorney.ID# 46890
1720 Mineral Spring Road, P.O. Box 461
Reading, PA 19603-0461
(610)374-7320
FIRST UNION NATIONAL BANK : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
No. I') / _,J. '16'.1 C.u;J. ...., ~
vs
RONALD B. CLIPPINGER and
NANCY K. CLIPPINGER,
husband and wife,
jointly and severally,
Defendants
CONFESSION OF JUDGMENT
COMPLAINT
1. Plaintiff, First Union National Bank, successor by merger to CoteStates Bank, N .A. is
a national bank organized under the laws of the United States, with an office address of 123 South
Broad Street, Philadelphia, Philadelphia County, Pennsylvania, 19109.
2. Defendants, Ronald B. Clippinger and Nancy K. Clippinger, are adult individuals
whose last known address is 351 North Street, Carlisle, Cumberland County, Pennsylvania 17013.
3. On December 17, 1997, the Defendant, Ronald B. Clippinger, made, executed and
delivered to CoreStates Bank, N .A. a Small Business Line Of Credit Agreement (the" Agreement") in
the principal amount of Twenty-Five Thousand Dollars ($25,000.00), evidencing the obligation of
Defendant to repay a commercial loan made that day to Defendant by CoreStates Bank, N .A. A copy
of said Agreement is attached hereto as Exhibit" A" .
4. As part of the consideration and inducement to CoreStates Bank to enter into the
Agreement, the Defendant, Nancy K. Clippinger, executed and delivered to CoreStates Bank: a
Guaranty, which guarantees the aforementioned commercial Agreement. Defendant agreed to and did
thereby become unconditionally bound and obligated to CoreStates Bank for any and all indebtedness
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incurred by the Debtor, plus all costs and expenses, including attorney's fees and legal expenses. The
Guaranty is evidenced on page 11 of the Agreement which is attached hereto as Exhibit" A . .
5. First Union National Bank is a successor by merger to CoreStates Bank, N.A.
6. The within judgment is not being entered by confession against a natural person in
connection with a consumer credit transaction but is being entered based upon a commercial
transaction.
7. Said Agreement has not been assigned since the merger.
8. No prior judgment has been entered in any jurisdiction on said Agreement.
9. The aforesaid Agreement authorizes confession of judgment against the Defendants
upon default.
10. The Defendants are in default on their obligation to Plaintiff on the Agreement for
failure to make timely monthly payments of principal and interest owed on the loan obligation.
II. Under the terms of the Agreement the Defendants are immediately liable to the
Plaintiff for the entire principal balance, accrued interest, and other costs and charges as follows:
Principal Balance
Interest as of 04/13/01
with a continuing per diem
interest rate of $7.50 as per
terms of the Note
$24,032.91
Release fees
322.50
11.50
Attorney fees of 15 % as per
terms of the Note
(Only actual attorney
fees will be collected
at the time of payoft)
TOTAL
3.655.04
$28,021.95
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WHEREFORE, Plaintiff, First Union National Bank, demands judgment against the
Defendants, jointly and severally, in the amount of Twenty-Eight Thousand Twenty-One Dollars and
Ninety-Five Cents ($28,021.95) together with interest continuing from April 13, 2001 at the per diem
rate of $7.50 and costs of suit.
LINTON, DISTASIO, AD
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FIRST UNION NATIONAL BANK : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
No.
vs
RONALD B. CLIPPINGER and
NANCY K. CLIPPINGER,
husband and wife,
jointly and severally,
Defendants
CONFESSION OF JUDGMENT
NOTICE UNDER RULE 2958.1 OF
JUDGMENT AND EXECUTION THEREON
Notice of Defendant's Rights
TO: RONALD B. CLIPPINGER
NANCY K. CLIPPINGER
351 NORTH STREET
CARLISLE PA 17013
A judgment in the amount of $28,021.95 has been entered against you and in favor of the
plaintiff without any prior notice or hearing based on a confession of judgment contained in a written
agreement or other paper allegedly signed by you. The Sheriff may take your money or other property
to pay the judgment at any time after thirty (30) days after the date on which this notice is served on
you.
You may have legal rights to defeat the judgment or to prevent your money or property from
being taken. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT AND
PRESENT IT TO A JUDGE WITHIN THIRTY (30) DAYS AFTER THE DATE ON WHICH THIS
NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS.
YOU SHOULD TAKE THIS P4PER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT ARRPRD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
.
Court Administrator
4th Floor Cumberland County Courthouse
I'Courthouse Square
Carlisle Pennsylvania 17013
T{llephone 717-240-6200
SIO, ADAMS & KAU fMAN, P.C.
.,
,;
Antho R. Distasio, Es
Attorney for Plaintiff
1720 Minerai Spring Road
P.O. Box 461
Reading, PA 19603-0461
610-374-7320
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FIRST UNION NATIONAL BANK : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
No.
vs
RONALD B. CLIPPINGER and
NANCY K. CLIPPINGER,
husband and wife,
jointly and severally,
Defendants
:' CONFESSION OF JUDGMENT
CERTIFICATION OF ADDRESSES
I, Anthony R. Distasio, Esquire, counsel for Plaintiff, hereby certify that the last known
address for the Plaintiff and Defendants are as follows:
Plaintiff:
First Union National Bank
123 South Broad Street
Philadelphia PA 19109
Ronald B. Clippinger
Nancy K. Clippinger
351 North Street
Carlisle PA 17013
Defendant:
J .lib
Anthony R. Distasio, Esquire
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FIRST UNION NATIONAL BANK : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
No.
vs
RONALD B. CLIPPINGER and
NANCY K. CLIPPINGER,
husband and wife,
jointly and severalIy,
Defendants
CONFESSION OF JUDGMENT
AFFIDAVIT THAT CONFESSION OF
JUDGMENT IS NOT BEING ENTERED
AGAINST A NATURAL PERSON IN
CONNECTION WITH A CONSUMER
CREDIT TRANSACTION
I, Anthony R. Distasio, Esquire, counsel for Plaintiff, hereby represent that the confession of
judgment filed against the Defendants in the within action, . s not being entered ag st a natural person
in connection with a consumer transaction.
Notarial Sea'
Renee D. Lenning, Notary Public
Reading, Berks County
My Commission Expires May 6, 2004
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FIRST UNION NATIONAL BANK : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
No.
vs
RONALD B. CLIPPINGER and
NANCY K. CLIPPINGER,
husband and wife,
jointly and severally,
Defendants
CONFESSION OF JUDGMENT
AFFIDAVIT THAT THE DEFENDANT
IS NOT IN THE MILITARY SERVICE
PURSUANT TO "SOLDIERS AND
SAILORS" CIVIL RELIEF ACT
OF 1918, RE-ENACTED 1940,
BERKS COUNTY, SS: Before me, the undersigned authority, personally appeared Anthony R.
Distasio, Esquire, who being duly sworn according to law, doth depose and say that RONALD B.
CLIPPINGER and NANCY K. CLIPPINGER, Defendants are not in the Military or Naval Service,
based on the following facts:
Age of the Defendant;
Present place of employment;
Present place of residence; 351 North Street, Carlisle, Cumberland County, Pennsylvania 7013.
ADDITIONAL FACTS, if any,
Notarial Seal
Renee D. .Lenning, Notary Public
Re~dl~g, Berks County
My Co.mmlsslon Expires May 6, 2004
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OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA 17013
TO:RONALDB.CL~PINGER
NANCY K. CL~PINGER
351 NORTH STREET
CARLISLE PA 17013
DATE:
RE: FIRST UNION NATIONAL BANK,
Plaintiff
v.
RONALD B, CLIPPINGER et ai,
Defendants
NO.
You are hereby notified in accordance with the Pennsylvania Supreme Court Rule #236
and #1519(c) that Judgment has beel). el).tered on a
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() FIn~Wrder *
() DeCree Nisi *
() Verdict *
() Certified Transcript from
() Default
() Stipulation
() Arbitration Award
(XX) Confession of Judgment Complaint
() Transfer from Berks County, Pennsylvania
Court of Common Pleas
and entered to No. against RONALD B. CLIPPINGER and NANCY K.
CLIPPINGER, Defendants, concerning Civil Suit No. on
2001 in the amount of Twenty-Eight Thousand Twenty-One Dollars and Ninety-Five Cents
($28,021.95) together with interest continuing from April 13, 2001 at the per diem rate of $7.50
and costs of suit.
** And that a Certificate has been.filed indicating that each of the parties have been notified of the
intention to file said judgment, by the Attorney for the Plaintiff(s) Defendant(s).
Curt Long, Prothonotary
By:
Deputy Prothonotary
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CoreStates
SMALL BUSINESS LINE OF CREDIT AGREEMENT
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Ace-ount No.:
CBC?0'-ji ) ?-'<:./I L/'
Date of Agreement:~/ December 17, 1997
Borrower: Ronald B. Clippinger
Billing Date:
Pledgor:
N/A
Guarantor:
Nancy K. Clippinger
Credit Umit:
$25,000.00
I. Defined Terms. Unless otherwise specifically stated. the following terms. when capitalized and used
herein~ shall have the meanings indicated:
"Acceleration" means that of the Obligations have become immediately due and payable under the provisions
of Paragraph 17 of this Agreement --
"Account" means the Small Business Line of Credit Account identified by the account number specified above.
"AgreemenC' means this Small Business Line afCredit Agreement. including any written amendments and
mOllifications.
'~Agreement Date" means the date of this Agreemem specified above.
"Authorized Representative- means (a) ifBorTower is an individual (including any individual who may conduct
business under one or more fictitious names). Borrower or any person authorized to obtain Loans 6n behalf of Bon-ower
under a power of attorney which has been delivered to and accepted by the Bank: (b). if Borrower is a corporation, any
representative afthe corporation aurnorized to obtain Loans on behalf of BOlT ower under resolutions of Bon- ower's board
ofdireclors. certified copies of which have been delivered to and a.ccepted by the Bank: (c) if Borrower is a partnership,
any representative of the partnership who is aurha:rized [0 obtain Loans on behalf of Borrower;:under a partnership
authorization which has been delivered to and accepted by the Bank: (d) if Borrower is a limited liability company. any
representative of the Borrower who is 3U[horized to obtain loans on the Borrower's behalf under resolutions of
Borrowers' members. certified copies of which have been delivered [0 and accepted by the Bank; and (e) in any case.
any person whom the Bank in good faith believes is authorized to obtain Loans on behalf of Borrower. The Bank may
continue to rely on the authority of an Authorized Representative until the Bank receives wrjnen notice in accordance
with Paragraph 21 of this Agreement that such authority has been duly revoked_
"Bank" means CoreStates Bank, N.A.
"Banking Day" means any day other than a Saturday. Sunday. legol holiday observed by the Bank or a day on
which the Bank's operations are substantially cun<lilcd due 10 natural disaster. inclement weather or other causes beyond
the Bank's control.
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UBilling Daten means the date specified above fOT purposes of billing interest and other items with respect to
the Account. If. in any calendar month, that dale falls on a day other than a Banking Day. the Billing Date will be the
Banking Day immediately preceding that date.
"Billing Period" means the period which begins on the Billing Date in a given calendar month and ends on the
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.da;' which .mmediately precedes the Billing Date in the following calendar month.
"Borrower" means each of the individuals or organizations identified above as Borrower.
"Chl.:ck" means-.a Lint: of Credit check used to obtain a Loan.
"Collateral" means (j) the n.:al and .ur personal property. if any. identified in Section 5 belo\\'. In or on whicb
the B~nk l~ bemg g.iven alien. mortgage or security interest. as the case may be, to secure repayment of the Obligations:
and (in any real or personal property previously or hereafter pledged by an Obligor or Pledgor as collateral for any other
Indebtedness of any Obligor to tile liank .
"Credit Limit" means the dollar amount specified above.
"Guarantor" means each of the individuals or organizations identified above as Guarantor.
"Line of Credit" means the line of credit described in Paragraph] of this Agreement.
'"Loans" means advances made by the Bank to Borrower under this Agreement.
"Obligations" means the unpaid balance of all Loans and all accrued and unpaid interest. togethcr with all fees.
costs and expenses payable by Borrower under the terms of this Agreement. "Obligations" shall include. but not be
limited to. any fees. expenses and charges described in paragraph 14 below.
"Obligor" means each Borrower and each Guarantor.
"Payment Due Date" means the date on which each required payment on the Account is due.
"Pledgor" means each of the individuals or organizations identified above as Pledgor.
"Prime Rate" means the highest prime rate published in the "Money Rates"table of The Wall Street Journal.
"Security Instrument" means any mongage, security agreement. pledge, assignment agreement or similar
document or agreement which gives the 8ank rights in the Collateral.
"Term ination" means term ination of the Bank's commitment to lend under the provisions of Paragraph I S of
this Agreement.
o Comminnent to Lend (Line of Credit). Subject to the terms and conditions of this Agreement. the Bank
hereby establishes a line of credit for Borrower and agrees to make Loans requested by the Borrower from the Agreement
Date until Termination. it being understood that the Bank shall not be required to honor any Loan request if the principal
amount of all outstanding Loans. after giving effect 10 the requested Loan, would exceed the Credit Limit. Subjeclto the
aforesaid terms and conditions. Borrower may borrow. repay and reborrow up to and including the amount of the Credit
Limit. Borrower agrees that each Loan requested will be used by Borrower solely for business purposes. but
"cknowledges that the "Loans" include all advances to Borrower under this Agreement, regardless of purpose.
3. Borrowers Promise 10 Pay. The Borrower promises to pay to the order of the Bank each and all of
the Obligations when due. as provided in this Agreement, whether the Obligations have a stated due date. are payable
on demand or arc due by reason of Acceleration. If Ihere is more than one Borrower. each Borrower is jointly and
se"erallv obligated for payment of the Obligations. The Bank may, at its option. require any Borrower to pay all of the
Obligations without making any effort to require any other Obligor to pay any of the Obligations. or to exercise any of
(he Bank' 5 rights under any Security Instrument.
4. Guarantor" Liability. The Guarantor unconditionally and irrevocably promises to pay when due
(whether by stated due date, demand or Acceleration) each and all of the Obligations. This is a guaranty of payment and
not a guaranty of collection, and if there is more than one Guarantor, each Guaramor is jointly and severally obligated
for payment of the Obligations. The Bank may, at its option, require any Guarantor to pay all of the Obligations without
making any effon to obtain payment of any of the Obligations from any olher Obligor or exercising any of the Bank' s
rights under any Security Insttument. The Guarantor shall be liable hereunder whether or not there is any consideration
for this guaranty which includes a direct economic benefit from the Loans or this Agreement.
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'. 5. Collateralldentit1cation' Pledgor's Resnonsibilities. As security forrepayment of me Obligations, the
Bank is being given a lien or mortgage on. a security interest in, or a pledge or assignment of the following real and.'or
personal propenv Collateral. which is more panicularly described in the applicable Security Instrument (iflhis Account
is unsecurcd. insert "None"): ~4Non('"
bch Pledgor agrees to comply with the tenns of any Security Instrument(s) signed by such Pledgor. Unless Pledgor is
alsu an Obligor. Pledgor's liability for payment of the Obligations is limited to Pledgor's interest in the Collateral. Each
Pledgor agrees that if there is any default under this Agreement or any Security Instrument, the Bank may. at its option.
exercise any or all of its rights under any Security Instrument without making any effon to obtain payment of any of the
Obligations from any Obligor or to exercise any of the Bank's rights under any other Security Instrument. The Pled~or
shall be liable as aforesaid whethcr or nOI Pledgor has received or will receive any direct or indirect economic ben~nr
or other consideration in exchang.e fOT subjecting the Collateral to the applicable Security Instrument.
6.
procedures:
Procedure for Loan Reauests. Loan Requests may be made by any Borrower under any of the following
(a) Credit l.ine Checks. The amount of each Check must be at least S~50.00. The BanI< mal
refuse to honor any Checl< if:
- It is received by the BanI< after Tennination;
- Honoring the Check would cause the total of all Obligations to exceed the Credit Limit;
Chccl<s may not be used to mal<e any payments due to the Bank under this Agreement. The Bank may refuse to cash any
Check presented by the payee thereof or other third pany.
Any Authorized Representative of Borrower may stop payment on any Check. A stop payment order
must be given in time for the Bank to act upon it and must state the exact amount, exact date and precise identity of the
payee oflhe Check. Oral stop payment orders must be confinned in writing within 14 days.
Checks are subject to the same Rules and Regulations as apply to the Bank's business checking
accoums.
(b) In Person Reauest. Any Authorized Representative of Borrower may request Loans in person
at any branch of the Bank. Loans requested in person must be deposited to Borrower's business checking account with
the Bank.
(e) Automated Teller MaChine Authorization. Borrower may also obtain Loans by using an
authorized automated teller maehine (A TM) Card For Business and personal identification number (PIN) at any A TM
whieh pemlits such transactions. The minimum and maximum Loans Borrower may obtain at anyone time or in one day
arc subject to the policies oflhe institution which controls the A TM. Borrower may also obtain Loans (which must be
deposited into Borrower's business Checking account with the Bank) through the A TM Card For Business Telephone
Banking Service. See the A TM Card for Business agreement for additional conditiQns and details.
o If this box is checked, Borrower authorizes the Bank to add access to Borrower's A~count to
Borrower's existing ATM Card for Business number
(d) Overdraft Protection.
o If this box is checked. Borrower authorizes the Bank to make Loans 10 Borrower to pay any checl<
or unpaid serviee charge an Borrower's business checking account No. when Ihe balance
of that account is insufficient to cover sueh item(s). Loans will be credited to the account in the lesser of (i) lowest
multiple of$IOO necessary to cover the shonage; or (il) the available credit under the Borrower's Aceount.
7. The Account. The Bank shall establish the Account for the purpose of recording and evidencing the
amount of the Obligations due and owing from time to time. Loans made by the Bank shall be recorded as debits to the
Account and payments shall be recorded as credits. The Account shall also reOect, in accordance with customary
practice. accrued interest, fees. expenses and charges payable under this Agreement. The Bank shall send Borrower, at
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the}lddress provided herein, a monthly statement of the Account, which shall specify the Payment Due Date and which
'shall be presumed complete and correct, except to the extent shown by the Borrower to be manifestly erroneous. Except
as required by law, the provisions of Federal and State consumer credit laws, such as the Federal Truth in Lending Act,
shall not apply to the Account. Although the Bank may voluntarily follow some of the requirements of such laws in its
handling of the Account and in providing statements of the Account and related information, Ihis voluntary compliance
shall not be inlerpreted as the Bank's agreement that such laws apply to the Account.
8.
as follows:
Reouired Payments. Prior to Termination. required payments will be due on the Payment Due Date
Agreement; and
(a) monthly payments of accrued interest determined in accordance with Paragraph /1 of this
(b) fees, expenses and charges payable under Paragraph 14 of this Agreement.
9. Reouired Pavments A fler Termination. Payments required under this Agreement after Termination
(provided there has been no Acceleration) will be due On the Payment Due Date as foJ/ows: (a) monthly payments
of accrued interest determined in accordance with Paragraph 12 of this Agreement; (b) fees, expenses and charges
payable under Paragraph 14 of this Agreement; and (c) monthly principal payments. beginning in the month immediately
foJ/owing the month of Termination, each of which shall be in an amount determined as foJ/ows, based on the outstanding
principal balance of the Loans at the time ofTerminalion:
Loan Balance at Termination
Monthlv Princioat Pavmenl Amount
$10,000 or less
$10,001 to $25,000
$25,00 I to $50,000
More than $50,000
J/24th of Loan Balance
J/36th of Loan Balance
J/48th of Loan Balance
1/60th of Loan Balance
lIpon Acceleration, aU outstanding Obligations shaU be immediately due and payable as provided in Paragraph
J7 of this Agreement.
10. Ootional PaYments. The Borrower may. at any time make any payments of principal on the Loans in
excess of those required under this Agreement without premium or penalty.
II. Procedure for Payments. Payments of the Obligations may be made as foUows:
(a) Automatic Chame to Deoosit Account.
GJ If this box is checked, Borrower hereby authorizes the Bank to charge any and all required
payments of the Obligations to Borrower's deposit account at the Bank. number 1419846704 . This authorization
does not modify the Bank's right of setoff or its security interest in deposit accounts as provided in Paragraph 18 of this
A.reement. This authorization is not required in order to enter into this Agreement or to open or maintain the Account
an-d may be revoked by Borrower by giving wrinen notice to the Bank not less than tifteen (15) days before the next
Payment Due Date. .
When the Payment Due Date falls on a day which is not a Banking Day, the transfer will be made on the next
Banking Day. BOlTower agrees to keep a balance in the deposit account identified above sufficient to cover each monthly
minimum payment when due. If Borrower fails to do so, the Bank may terminate the automatic payment service, in which
event Borrower shall make payments by check in accordance with Paragraph II (b).
(b) Payment bv Check - Payment of any ponion of the Obligations may be made at any branch
of the Bank or by mailing Borrower's check to the mailing address provided in Borrower's monthly statement of the
Account.
12. Interest. Interest shall be payable monthly as billed and shall accrue on the outstanding principal
balance of the Loans until the Obligations are paid in full in accordance with the following:
<a) 0 If this box is checked, from the date of this Agreement through the end of the .l:YA- month
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'th~reoftcr (the "lntroduClOf) Period"). at a tixed rate of..1!LA. % per annum_
(b) After any Introductory Period and prior to Acceleration, at 1.74000 % per annum in excess
0i'the Prime Rote. The interest rote will change on the same date the Prime Rate changes.
IC) After Acceleration. at 4.5 % per annum in excess of the Prime Rate. The interest ratc will
change on the same date the Prime- Rate changes.
13. Comoutotlon of Accrlled Interest. Interest shall accrue on a simple interest basis and sholl not be
compounded. Interest shall be calculated on the basis of a 365-day year (366 days in leap years) and shall be char~ed
for the actual number of days elapsed durin~ each billing period.
14. Fees Exoenses and Charges.
(a) Origination Fee - On or prior to the Agreement Date, Borrower has paid the Bank on
origination fee in the amount of S125.00 The origination fee is non-refundable and is deemed to be earned by the
Bank upon receipt.
.
(b) Reimbursed Costs and Fees InCurred Bvthe Bank - Borrower shall reimburse the Bank upon
request for lien and title search costs. appraisal COSIS and filing and recording fees actually incurred by the Bank. These
payments by Borrower are not refundable.
(c) Annual Fee - On each anniversary of the Agreement Date, the Borrower will pay the Bank
an annual fee in the amount equalto....s!L % of the Credit Limit (minimum fee $250.00). This fee represents payment
hy llorrower. in advance, for use of the line of credit provided under this Agreement. If the effective date of Termination
occurs less than one year after the due date of an annual fee, Borrower will be entitled to a pro-rata refund of such annual
fee payment. said refund to be applied as a credit against any then-existing Obligations or refunded to Borrower if there
ore no such Obligations. The imposition of an annual fee does not: (i) modify the right of any party to give norice of
Tennination as provided in Paragraph 15: or (ii) change the effect of any such notice of Termination.
(d) Late Payment Charge - Prior to Acceleration, ifany required payment is not received by the
Bank on or before the 15th day following a Payment Due Date, Borrower will pay a late payment charge equal 10 the
greater of 5~o of the required payment or $20.00. but in no event shall such late payment charge exceed S 100.
(e) StOO Payment Fee - A fee of$20.00 will be charged for each check on which a stOp payment
order is placed.
(f) Returned Check Fee - If the Bank does not pay a Check for any permitted reason. Borrower
will pay a returned Check fee of520.00.
(g) Returned Pm'ment Fee - If a check. draft or money order submitted to the llank as a payment
to be credited to the Account is returned unpaid for any reason. Borrower will pay a returned payment processing fee
of S25 .00.
(h) Minimum Loan Fee - A fee of $4.00 will be charged for any Loan of less than 5250.00.
including oyerdron protection transfers under Section 6(d) above.
(i) Payment Historv/Account Analysis Fee - A fee of$/O.OO for each request for a wrinen
payment history or an analysis of the Account. No fee will be imposc:d if Borrower's request is made in connection with
BOrTower s bona tide assertion of an error by the Bank or other dispute with the Bank concerning one or more payments.
(j) Document Convin~ Fee - A fee of 57.00 per hour will be charged for reproduction of
statements. checks or other documents relared to the Account. No fee will be imposed to the extent the request is made
in connection with a Borrower's bona tide assertion of an error by the Bank or other dispute with the Bank as to
payments or advances on the Account.
(k) Collateral Administration Costs and Exoenses - Without implying any limitation or moditication
of any other provisions of this Paragraph 14, Borrower agrees to pay on demand any costs or expenses actually incurred
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hy tne Bank to administer, perfect. preserve or protect the Bank's interest in' any Collateral or to comply with an\'
applicabk Jawor regulation with respect to any Collateral. .
(i) Collection COstS and Exoenses - After Acceleration, the Borrower will pay to the Bank. on
demand. all costs and expenses. including reasonable attorney's fees, incurred by the Bank in enforcing an\' or all of its
nghlS and remedies under this Agreement or any Security Instrument. ... .
Fees imposed under sections (c) through (h) above will be added to the prinCipal balance of the
Account as additional Loans.
15. Tennination - The Line of Credit and the Bank's commitment to make Loans shall tcmlinatc at the
earliest of the following times:
(a) The close of business on the fifteenth (15th) day following receipt by the Bank ofwrinen
notice of Termination from any Obligor or any Pledgor;
(b) The close of business on the date specified in the Bank's wrinen notice of Termination to cach
Obligor and each Pledgor, it being understood that (i) such notice may be given by the Bank at any time and for any
rcason whatsoever. and (ii) the date specified must be not less than 60 days after the date on which the Bank's notice is
sent;
(c) When the Bank receives notice that (i) any Obligor or any Pledgor has filed a petition for
reliefas a debtor under any bankruptcy or insolvency law, or (ii) any such petition has been filed against any Obligor
or any Pledgor and not been dismissed within 30 days; or
(d) When the Bank gives written notice of Acceleration as provided in Paragraph 17 of this
Agreement.
If, under any provision of subparagraphs !5(a)-(d) above, any Termination would become effective
on other than a Banking Day, such Termination will automatically become effective as of the close of business on the
next Banking Day after such effective date.
16. Events of Default - Each of the following shall be an Event of Default under this Agreement:
(a) The failure of the Borrower to pay any of the Obligations when due;
(b) If any representation, statement or certification by any Obligor contained in or given in
connectioo with this Agreement or if aoy representation by any Pledgor contained in or given in connection with any
Security Instrument shall be untrue in any material respect;
(c) Ifany Obligor shall fail to comply with aoy agreemeot with the Bank, or if any Pledgor shall
fail to comply with any agreement in any Security Instrument;
(d) [fthe Borrower shall incur or permit to exist any indebtedness for borrowed money tother
than indebtedness to the Baok) except for (i) iodebtedness in connection with consumer loans not related to the
Borrowers business. and (ii) other indebtedness for borrowed money in an aggregate principal amount which does not
exceed 25~o of the Credit Limit;
(e) If there shall exist, at any time, any material liens or encumbrances on the Collateral other
than Ih::lI crc:llcd by a Security Instrument and the following (if none. insert "None"): "None"
(I) If, in the reasonable judgment of the Bank. any Obligor or any Pledgor is or becomes
Insolvent or generally unable to pay his, her or its debts as they become due;
(g) Ifany Obligor shall default in the payment of any material indebtedness for borrowed money,
or if there shall be entered against any Obligor any judgment;
(h) If any account of any Obligor at the Bank or any property of any Obligor held by the Bank
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7
sJ1all be subject to any anachment, levy or garn ishment;
. (i) If any Obligor or any Pledgor shall file a petition under any bankruptcy or insolvency law,
or If any such petition shall be filed against any Obligor or any Pledgor and not be dismissed within 30 days;
(j) If any Obligor which conducts business shall cease to conduct business or shall materially
alrer the nature of its business;
(k) If any Obligor who is an mdividual dies;
(I) If any Obligor shall fail to promptly provide any financial statements or other financial
infonnation reasonably requested by the Bank;
(m) If the Bank shall become aware of an\' facts or circumstances which, in the reasonable
judgment of the Bank, have had or are likely to have a material adv~rse effect on the financial condition, income, cash
flow, business prospects or general creditwonhiness of any Obligor;
(n) If there shall be, with respect to any Obligor which is not an individual, any change in control,
as that tenn is defined in Rule 12b-2 under the Securities Exchange Act of 1934, or if any such Obligor merges or
consolidates with another business entity. sells any substantial ponion of its assets or dissolves, liquidates or commences
any fonn of dissolution or liquidation, or enters into any agreement to do any of the foregoing;
(0) If there shall be any default under any Security Instrument, even if such default is not an
Event of Default under this Paragraph 16; or
(P) If the Bank reasonably detennines that any Security Instrument does not represent a perfected
lien on, interest in or pledge of the Collateral or that there has been a material adverse change in the market value of the
Collateral.
17. Acceleration. Upon the occurrence of any Event of Default referred to in clause (i) of the preceding
Paragraph, all of the Obligations shall aUlomatically become immediately due and payable without any demand, notice
or declaration by tbe Bank. Upon the occurrence of any other Event of Default, or at any time thereafter during the
continuance ofsucb Event of Default, the Bank may. at its option, declare all oftbe Obligations to be immediately due
and payable by sending wrinen notice of Acceleration to Borrower. Guarantor and Pledgor in the manner and to the
addresses provided in Paragraph 21 of this Agreement. Upon Acceleration. and at any time thereafter, the Bank may
exercise any or all of its rights and remedies under applicable law against any Obligor and under any Security Instrument.
The Bank may, at its option, exercise or decline to exercise, without waiving, any such rights and remedies, and may
exercise them simultaneously or in any order whatsoever. The provisions of this Paragraph 17 shall be applicable whether
or not there bas been any previous Tennination pursuant to Paragraph 15.
18. Ril1.bt of Setoff and Securitv Interest in Denosit Accounts. Each Obligor acknowledges the Bank's right
of setoff against deposit accounts of such Obligor and against any other amounts which may be at any time owed by the
Bank to such Obligor. In addition to the foregoing, each Obligor grants to the Bank a security interest in and lien upon
any deposit account at the Bank in which such Obligor has an interest. The Bank's rights and remedies under this
Paragraph 18 may be exercised upon or after Acceleration or upon or after the occurrence of an Event of Default referred
to in clause (h) in Paragraph 16 of this Agreement.
19. Waivers Bv Oblioor and Pledoor. In addition to the other waivers and consents in this Agreement, each
Obligor and each Pledgor acknowledges and agrees, to the extent pennined by law, that ilS liability under this Agreement
is unconditional and shall not be diminished, impaired or postponed by (a) the bankruptcy, insolvency or change in legal
status of any Obligor or any Pledgor; (h) the Bank's failure to obtain such Obligor's or Pledgor's consent to, or to give
nOlice of (i) any waiver, forbearance, indulgence or inaction by the Bank with respect to the Account, the Line of Credit,
the Loans or the Obligations or with respect to the Bank's remedies against any Obligor or under any Security Instrument,
(ii) any agreement between the Bank and Borrower to modify the tenns of this Agreement, other than a modification
which modifies such Obligor's or Pledgor's right to terminate the Line of Credit pursuant to Paragraph 15 or which
increases the Credit Limit, or (iii) any misrepresentation by any Obligor or Pledgor, or any other Event of Default; (c)
the release from, or the limitation of liability of, any other Obligor or Pledgor; (d) any impairment of such Obligor's or
Pledgor's right of recourse, subrogation, indemnification or contribution against or with respect to any other Obligor or
Pledgor; or (e) the unenforceability of any provision of this Agreement or any provision of any Security Instrument
.........,...~__,.~""_o.~._ ~
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8
. against any other Obligor or Pledgor. Each Guarantor and each Pledgor agree that they will not exercise any right of
!ub~ogatlon whIch they may have against Borrower until all of the Obligations have been paid in full and the line of
credit has been terminated.
20. Reinstatement ofObli~ations. lfand to the extent that any payment or reduction of the Obligations is
resCinded .or must be retUrned or disgorged by the Bank, as a result of any Obligor's or Pledgor's bankruptcy, i';-solvency
or otherWise. the Obligations so paid or reduced shall be deemed to be reinstated for purposes of this Agreement. and
each Obligor and Pledgor shall be obligated and have liability therefor in accordance with the terms of this Agreement.
except tu the extent prohibited by applicable law. In the event that any Obligations are reinstated subs~quent to
termination of a Secunty Instrument, each Pledgor shall execute and deliver to the Bank a replacement Seeurit\
Instrument. -
21. Notices. All notices under this Agreement shall be in writing. A notice of termination given bv ani
Obligor or Pledgor shall be effective upon actual receipt thereof by the Bank at the address shown below. Vnle;s
otherwise expressly provided, all other notices shall be effective when sent via prepaid first class mail or recognized
overnight courier service. addressed to the recipient althe address shown below. -
Jfto the Bank: CoreStates Bank. N.A.
Revolvinl!: Credit. P. O. Box 16022
Reading. PA 19603
If to Borrower: Ronald B. Clippinger
351 North Street
Carlisle. PA 17013-2220
If to Guarantor: Nancy K. Clippinller
351 North Street
Carlisle. PA 17013-2220
I f to Pledgor:
Any party may change ils address for purposes of this notice provision by giving notice as provided above to each other
party.
22. Representations to the Bank. Each Borrower represents that the proceeds of eaeh Loan shall be used
by the Borrower solely for business purposes. Each Obligor and each Pledgor which is a corporation. limited liability
company or a general or limited partnership represents and warrants that it is validly existing and in good standing in
the jurisdiction under whose laws it was organized. Each Obligor and each Pledgor which is a corporatiun or limited
liability company represents and warrants that the execution. delivery and performance of this Agreement (and. as to each
Pledgor, the applicable Security Instrument) are within its organizational powers. have been duly authorized by all
necessary action by its board of directors (or of its members. in the Case of a limited liability company), and are nOI in
conrravention of the terms of its charter, by-laws, any applicable operating agreement or any resolution of such board
of directors or members. Each Obligor and each Pledgor which is a partnership represents and warrants that the
execution, delivery and performance of this Agreement (and, as to each Pledgor. the applicable Security Instrument)
have been duly authorized and are not in connict with any provision of its partnership agreement or certificate of limited
partnership. Eaeh Obligor and each Pledgor represents and warrants that this Agreement and each Securiry Instrument
to which any Obligor or Pledgor is a parry have been validly executed and are enforceable in accordance with their
terms. that the execution, delivery and performance of this Agreement and such Security Instrument are not in
contravention of law and do not contlict ith any indenture, agreement or undertaking to which such Obligor or Pledgor
is a party or is otherwise bound, and that no consent or approval of any governmental authority or any third party is
required in connection with the execution, delivery or performance of Ibis Agreement or such Security Instrument. Each
of the foregoing representations and warranties is made solely for the Bank's benefit and is not to be relied upon by any
Obligor, any Pledgor or any other person.
23. Additional Waivers Etc. Each Obligor waives presentment, dishonor, notice of dishonor, protest and
notice of protest. Neither the failure nor any delay on the part of the Bank to exercise any right. remedy, power or
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p'ri~ilege hereunder shall operate as a waiver or modification thereof. No consent, waiver or modification of the tenns
'. oLthis Agreement shall be effective unless set forth in a writing signed by the Bw_ All rights and remedies of the Bank
are cumulative and concurrent and no single or partial exercise of any power or privilege shall preclude any other or
funher exercise of any right, power or privilege.
24, CONFESSION OF JUDGMENT EACH OBLIGOR IRREVOCABLY AUTHORIZES AND
EMPOWERS ANY A nORNEY OR ANY CLERK OF ANY COURT OF RECORD, UPON OR AFI'ER THE
OCCURRENCE OF AN EVENT OF DEFAULT, TO APPEAR FOR AND CONFESS JUDGMENT AGAINST
OBLIGOR FOR SUCH SUMS AS ARE DUE AND OWING UNDER THIS AGREEMENT, WITH OR
WITHOUT DECLARA nON, WITH COSTS OF SUIT. WITHOUT STAY OF EXECUTION AND WITH AN
AMOUNT NOT TO EXCEED THE GREATER OF FIFTEEN PERCENT (15%) OF THE PRINCIPAL
AMOUNT OF SUCH JUDGMENT, OR $5,000, ADDED FOR COLLECTION FEES. IF A COPY OF THIS
AGREEMENT, VERIFIED BY AFFIDAVIT BY OR ON BEHALF OF THE BANK, SHALL HA VE BEEN
FILED IN SUCH ACTION, IT SHALL NOT BE NECESSARY TO FILE THE ORIGINAL OF THIS
AGREEMENT. THE AUTHORITY GRANTED HEREBY SHALL NOT BE EXHAUSTED BY THE INITIAL
EXERCISE THEREOF AND MAYBE EXERCISED BY THE BANK FROM TIME TO TIME. THERE SHALL
BE EXCLUDED FROM THE LIEN OF ANY JUDGMENT OBTAINED SOLELY PURSUANT TO THIS
PARAGRAPH ALL IMPROVED REAL ESTATE IN ANY AREA IDENTIFIED AS HAVING SPECIAL
FLOOD HAZARDS UNDER REGULATIONS PROMULGATED UNDER THE FLOOD DISASTER
PROTECTION ACT OF 1973, IF THE COMMUNITY IN WHICH SUCH AREA IS LOCATED IS
PARTICIPATING IN THE NATIONAL FLOOD INSURANCE PROGRAM. ANY SUCH EXCLUSION SHALL
NOT AFFECT ANY LIEN UPON PROPERTY NOT SO EXCLUDED.
EACH OBLIGOR ACKNOWLEDGES AND UNDERSTANDS THA TTHE PROVISIONS OF
THIS PARAGRAPH 24 INCLUDE A W AlYER OF IMPORTANT RIGHTS WHICH WOULD OTHERWISE
BE A V AILABLE TO EACH OBLIGOR AND THAT BY SIGNING THIS AGREEMENT. EACH OBLIGOR:
(A) IS AUTHORIZING THE BANK. UPON OR AFTER THE OCCURRENCE OF AN EVENT OF DEFAULT,
TO ENTER A JUDGMENT AGAINST OBLIGOR AND IN FAVOR OF THE BANK, WHICH WILL GIVE
THE BANK A LIEN UPON ANY REAL ESTATE WHICH OBLIGOR MAY OWN IN ANY COUNTY WHERE
THE JUDGMENT IS ENTERED FOR ANY AMOUNTS WHICH ARE OR MA Y BECOME DUE UNDER THIS
AGREEMENT; (B) IS GIVING UP THE RIGHT TO ANY NOTICE OR OPPORTUNITY FOR A HEARING
BEFORE THE ENTRY OF JUDGMENT ON THE RECORDS OF THE COURT; (C) WILL BE UNABLE TO
CONTEST THE VALIDITY OF ANY JUDGMENT ENTERED BY THE BANK UNDER THIS PARAGRAPH
24 UNLESS OBLIGOR CHALLENGES ENTRY OF THE JUDGMENT THROUGH A PETITION TO OPEN
OR STRIKE THE JUDGMENT, WHICH WILL REQUIRE OBLIGOR TO RETAIN COUNSEL AT
OBLIGOR'S EXPENSE; (0) IS GIVlNGUP AN IMPORTANT RIGHT TO ANY NOTICE OR OPPORTUNITY
FOR A HEARING BEFORE THE BANK MAY REQUEST AND USE THE POWER OF STATE
GOVERNMENT TO DEPRIVE OBLIGOR OF ITS PROPERTY PURSUANT TO THE JUDGMENT BY
SEIZING OR HAVING THE SHERIFF OR OTHER OFFICIAL SEIZE OBLIGOR'S BANK ACCOUNTS,
INVENTORY. EQUIPMENT, FURNISHINGS. OR ANY PERSONAL PROPERTY THAT OBLIGOR MAY
OWN, TO SATISFY OBLIGOR'S OBLIGATIONS UNDER THIS AGREEMENT; AND (E) OBLIGOR MAY
BE IMMEDIATELY DEPRIVED OF THE USE OF ANY PROPERTY THAT IS SEIZED BY THE BANK
PURSUANT TO THE JUDGMENT WITHOUT NOTICE OR HEARING. AND THERE IS NO ASSURANCE
THAT A HEARING WILL BE AVAILABLE TO OBLIGOR PROMPTLY AFI'ER OBLlGOR'S PROPERTY
IS SEIZED. FULLY AND COMPLETELY UNDERSTANDING THE, RIGHTS WHICH ARE BEING GIVEN
UP AS DESCRIBED HEREIN, EACH OBLIGOR KNOWINGLY AND VOLUNTARILY WAIVE!! THESE
RIGHTS BY SIGNING THIS AGREEMENT. IN CONNECTION WITH THE FOREGOING. OBLIGOR HAS
EITHER CONSULTED OBLIGOR'S LEGAL COUNSEL OR YOLUNT ARIL Y DECIDED NOT TO CONSULT
LEGAL COUNSEL.
25. CONSENT TO JURISDICTION AND VENUE. IN ANY LEGAL PROCEEDING INVOLVING,
DIRECTL Y OR INDIRECTLY, ANY MA TIER ARISING OUT OF OR RELATED TO THIS AGREEMENT OR
THE RELATIONSHIP EVIDENCED HEREBY, EACH UNDERSIGNED PARTY HEREBY IRREVOCABLY
SUBMITS TO THE NONEXCLUSIVE JURISDICTION OF ANY STATE OR FEDERAL COURT LOCATED IN
ANY COUNTY OF THE STATE SPECIFIED IN PARAGRAPH 24 ABOVE IN WHICH THE BANK MAINTAINS
AN OFFICE AND AGREES NOT TO RAISE ANY OBJECTION TO SUCH JURISDICTION OR TO THE LAYING
OR MAINTAINING OF THE VENUE OF ANY SUCH PROCEEDING IN SUCH COUNTY. EACH UNDERSIGNED
PARTY AGREES THAT SERVICE OF PROCESS IN ANY SUCH PROCEEDING MAY BE DULY EFFECTED
UPON IT BY MAILING A COpy THEREOF, BY REGISTERED OR CERTIFIED MAIL. POST AGE PREPAID, TO
EACH UNDERSIGNED PARTY.
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26. WAIVER OF JURY TRIAL. EACH UNDERSIGNED PARTY HEREBY WAIVES TRIAL BY
'JURY IN ANY LEGAL PROCEEDING INVOLVING, I}IRECTLY OR INDIRECTLY. ANY MAlTER
'(WHETHER SOUNDING IN TORT, CONTRACT OR OTHERWISE) IN ANY WAY ARISING OUT OF OR
RELATED TO THIS AGREEMENT OR THE RELATIONSHIP EVIDENCED HEREBY. THIS PROVISION
IS A MATERIAL INDUCEMENT FOR THE BANK TO ENTER INTO THIS AGREEMENT.
27. No Imolied Modification. Unless otherwise expressly agreed in writing: (I)the provisions of this
Agreement are cumulative and concurrent with any and all other instruments and agreements between the Bank and any
or all of the undersigned Obligors. Guarantors'or Pledgors: and (ii) no such instrument Dr agreement shall be deemed
to be modified. canceled or replaced by this Agreement.
28. Miscellaneous. If any provision of this Agreement shall be held invalid or unenforceable, such
invalidity or unenforceability shall not affect any other provision hereof. Except for the Billing Date, in the event that
any due date specified or otherwise provided for in this Agreement shall fall on a day which is not a Banking Day, such
due date shall be postponed until the next Banking Day. and interest and any fees or similar charges shall continue to
accrue during such period of postponement. This Agreement has been delivered in and shall be governed by and
construed in accordance with the laws of the state of Pennsylvania (including the Unifonn Commercial Code as
in effect in that state) applicable to contracts formed and intended to be performed in that state. This Agreement shall
be binding upon and benefit the panies hereto and their respective personal representatives, heirs, successors and assigns.
No assignment of rights or delegation of duties under this Agreement by any Obligor or any Pledgor shall be effective
without the prior wrillen consent of the Bank.
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IN W1n1ESS WHEREOF, each undersigned party haS executed this Agreemen~ intending to be legally bound
, hereby, as of the Agreement Date.
[Signature of BorrowerL
[Signature of Pledgor]
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Ronald B. Clippinger
[Signature of Guarantor]
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Nancy K. Clippin~er
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By:Ji,(J'it.u-~./
COREST A TES BANK, N.A.
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FAX NO.: 2159855587
b'~~/qLDqL LINTON DISTASIO ADAM
04-12-01
e3:!i~)P P.05
f'~3E El5
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VEIUFJ:CATION
I, ANTlfONY JENKINS, heteby verify thl1,1 1l1,1n a Bank Officer of P:tll.ST UNION
NATIONAL BANK, that I am aurborb:ed to make this verification on its behalf and that the f3ct, ~~:
forth in the within Instrument atl: true and correct to the b~t of my knowledge, information and belle{
and that the same are made 9ubjccr to tlJe penalties of 18 Pa. C.S.A. Section 4904 relating 10 UIlSW('ln
fulsifkaiion to antlJorJlies.
Dated:-.D\I ~\1- .~C'lc'! I
(Nt ~IDny Jt:)
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-02455 P
"
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
?
,
FIRST UNION NATIONAL BANK
VS
CLIPPINGER RONALD B ET AL
DAWN L. KELL
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
CLIPPINGER RONALD B
the
DEFENDANT
, at 1850:00 HOURS, on the 27th day of April
, 2001
at 351 NORTH ST
CARLISLE, PA 17013
by handing to
NANCY CLIPPINGER WIFE
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So
Answer~~~
18.00
3.10
.00
10.00
.00
31.10
R. Thomas Kline
04/30/2001
LINTON DISTASIO ADAMS KAUFFMAN
Sworn and Subscribed to before
By:
\J~~. 'Lu
Deputy Sheriff
me this
day of
A.D.
061{r
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-02455 P
,
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FIRST UNION NATIONAL BANK
VS
CLIPPINGER RONALD B ET AL
DAWN L. KELL
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
CLIPPINGER NANCY K
the
DEFENDANT
, at 1850:00 HOURS, on the 27th day of April
2001
at 351 NORTH ST
CARLISLE, PA 17013
by handing to
NANCY CLIPPINGER
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.DO
.00
.00
10.00
.00
16_00
~fl/~~~
R. Thomas Kline
04/30/2001
LINTON DISTASIO ADAMS KAUFFMAN
Sworn and subscribed to before
By:
\j~~ ~
Deputy Sheriff
me this _~
day of
A.D.
prq,th
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