HomeMy WebLinkAbout01-03089
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ALLFIRST BANK,
Plaintiff
vs.
VICTOR D. MACOMBER and
WANDA W. MACOMBER, his wife,
Individually and Jointly,
Defendants
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: No. ()f -.$'6P9
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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 the Defendants as follows:
Principal Sum Due -
Interest to 5/18/0 I -
Late Fees -
Attorney's Fees (15% of principal, interest and charges)-
Total-
$ 431,058.28
7,075.97
220.25
65,753.18.
$ 504,107.68.
Plus all future interest accruing at the contract rate ($110.76 per diem) until paid in full,
charges, fees, expenses and court costs.
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ALLFIRST BANK,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
Plaintiff
vs.
: No,
VICTOR D. MACOMBER and
WANDA W. MACOMBER, his wife,
Individually and Jointly,
Defendants
COMPLAINT
1. The Plaintiff is Allfirst Bank, a Maryland State charted commercial bank, with
offices located at 213 Market Street, Harrisburg, Pennsylvania 17105.
2, The Defendants, Victor D. Macomber and Wanda W. Macomber, his wife,
individually and jointly, are adult individuals last known to reside at 3452 Lisburn Road,
Mechanicsburg, Pennsylvania 17055.
3. On September 7,2000, the Plaintiffloaned to the Defendants the sum of Four
Hundred Sixty Thousand Dollars ($460,000.00) as evidenced by a Commercial Promissory
Note (the "Note") and Commercial Promissory Note Modification Agreement and Declaration
of No Setoff, a true and correct copy of which is attached hereto as Exhibit "A" and
incorporated herein by reference.
4. The Note, as modified, and debt have not been assigned.
5. Judgment has not been entered on the Note in any jurisdiction.
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6. Defendants are currently liable to Plaintiff as follows:
Principal Sum Due -
Interestto 5/18/0 I -
Late Fees -
Attorney's Fees (15% of principal, interest and charges)-
Total -
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$ 431,058.28
7,075.97
220.25
65.753.18
$ 504,107.68
Plus all future interest accruing at the contract rate ($110.76 per diem) until paid in full,
charges, fees, expenses and court costs.
7. Judgment is not being entered by confession against a natural person in connection
with a consumer credit transaction.
WHEREFORE, Plaintiff requests that judgment be entered in favor of the Plaintiff,
Allfirst Bank, and against the Defendants, Victor D. Macomber and Wanda W. Macomber, his
wife, individually and joint, in the amount of:
Principal Sum Due -
Interest to 5/18/0 I -
Late Fees -
Attorney's Fees (15% of principal, interest and charges)-
Total -
$ 431,058.28
7,075.97,
220.25 !
65,753.18
$ 504,107.68
Plus all future interest accruing at the contract rate ($110.76 per diem) until paid in full,
charges, fees, expenses and court costs.
HENR YAIZ - ,ro <fER LP
By:
M CA,
J.D. #55774
937 Willow Street
P.O. Box 1140
Lebanon, PA 17042-1140
(717) 274-3644
Attorney for Plaintiff
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AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA:
ss.
COUNTY OF
Jeffrey S. Linden, Assistant Vice President, of A1lfirst Bank, being duly sworn according
to law, deposes and says that he has authority to sign this Affidavit on behalf of Al1first Bank
and that the facts set forth in the foregoing Complaint are true and correct to the best of his
knowledge, information and belief; and that the copy of the Commercial Loan Note and
Commercial Promissory Note Modification Agreement and Declaration of No Setoff, Exhibit
"A" attached to the Complaint, is a true and correct copy of the original which is held in the files
of the Plaintiff and which was executed and delivered by the Defendants to Plaintiff.
ALLFIRST BANK
BY~ll,mJ"
J . lJ nden
ssistant Vice President
Sworn and subscribed to before me this
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Notary IC
Notarial Seal
Edle I. lingle, Notary PubliC
Lebanon, Lebanon County
My Commission Expires 001. If, 2004
Member, Penn.yll/llnla AssOcIaIlon ol Notarie.
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COMMERCIAL PROMISSORY NOTE
$ 460,000.00
107 West Market St., York, PA
September 7 ,2000
(Amount)
(Bank Office and Location)
Subject to the provisions of this Commercial Promissory Note (this "Promissory Note"), Allfirst Bank, a Maryland state-chartered
commercial bank (the "Bank") may, in its sole and absolute discretion and at any time and from time to time hereafter, until the close
of business on March 7th, ,2001 (the "Advance Period"), lend to the Undersigned (the "Maker" whether one or more than one)
such swns of money as may be requested orally or in writing by the Maker (or by anyone or more of the Maker if more than one) up
to but not exceeding in the aggregate at anyone time outstanding an amount equal to the face amount of Four Hundred Sixry Thousand
and 00/100 Dollars.
This Promissory Note is not revolving in nature, i.e., after the Maker has received funds totaling $460,000.00, no additional funds
will be advanced.
Principal and Interest Payment Schedule.
The Maker promises Gointly and severally if more than one) to pay accrued interest on the 15th. day of each month,
commencing on October 15th. ,2000 and continuing through and including March 15th. ,2001. Thereafter, the Maker promises
Gointly and severally if more than one) to pay to the order of the Bank the principal amount of this Promissory Note or so much
thereof as may then be advanced and outstanding hereunder (the total of all such advances outstanding ar the time of determInation
being herein called the "Principal Amount") over a period of 114 months in consecutive and equal installments of principal and
interest in the amount of $4.405.01 each, payable on the 15th. day of each month in each year, commencing on the 15th.
day of April ,2001.
A fInal installment in the amount of the unpaid balance of the Principal Amount together with accrued and unpaid interest thereon
shal! be due and payable on the 15th -day of September,20l0.
Interest Rate Schedule.
The per annum rate of interest on the Principal Amount of this Promissory Note from the date hereof until the maturity of this
Promissory Note (whether by acceleration, declaration, extension or otherwise) is 9.25%.
If all or any portion of the Principal Amount is paid prior to its scheduled maturiry, the Maker shall pay a prepayment fee to the
holder of this Promissory Note. The prepayment fee shall be due and payable in connection with all of such payments, from whatever
source, including, but not limited to, payments made at the voluntary election of any Other Obligor (as hereinafter defined), payments
made as a result of the acceleration of this Promissory Note by the holder of this Promissory Note or payments made as a result of
casualry to or the condemnation or sale of any collateral securing the repayment of this Promissory Note. The prepayment fee shall be
calculated by discounting to present value, as of the date of the prepayment, the remaining payments of principal and interest on this
Promissory Note being prepaid, using a discount rate equal to two percent (2%) above the yield to maturiry of the non-callable debt
obligation of the United States Treasury having a maturiry date nearest in time to the maturiry date of the portion of the Principal
Amount being prepaid. If such discounted value exceeds the unpaid Principal Amount being prepaid, then the prepayment fee shall be
an amount equal to such excess, but in no event less than one percent (1 %) of the amount being prepaid. If the discounted value does
not exceed the unpaid Principal Amount being prepaid, the prepayment fee shall be equal to one percent (l %) of the amount being
prepaid. The maturiry date and yield to maturiry of the applicable United States Treasury obligation shall be determined on the basis of
quotations published in "The Wall Street Journal" on the date of prepayment or from such other source as the holder of this Promissory
Note, in its sole discretion, shall deem appropriate.
Late Charge.
If the Maker fails to make any payment of the Principal Amount or of interest thereon within fifteen (15) days of the date due and
payable, the Maker shall pay to the Bank on demand a late charge equal to fIve percent (5%) of the amount of any such payment.
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Additional Provisions.
Interest on this Promissory Note shall be calculated on the basis of a 360 day year applied to the actual number of days the Principal .
Amount, or any portion thereof, is outstanding.
After maturity of this Promissory Note (whether by acceleration,' declaration, extension or otherwise), the unpaid balance of the
Principal Amo~t outstan~in~ on the date of ma~ty plus accrued and unpaid interest earned to maturity shall bear interest at a per
annum rate of mterest which IS equa1to the rate of mterest on the Principal Amount of this Promissory Note until maturity, as provided
above, plus 2 % per annum.
Application of Payments.
All payments made pursuant to this Promissory Note shall be applied first to accrued and unpaid interest, then to unpaid expenses
and charges payable hereunder, and then to principal, or in such other order or proportion as the holder, in the holder's sole discretion,
may elect from time to time.
Year 2000 Issues.
Maker represents, warrants and covenants that, (a) based on a comprehensive review and assessment of its systems and equipment
and those of its material suppliers, vendors and customers, the Maker reasonably believes that Year 2000 Issues (hereinafter dermed)
including costs of remediation, could not be expected to result in a material adverse change in the financial condition of the Maker or
any Other Obligor from that expressed in the financial statements most recently submitted to the Bank prior to the date hereof; (b) the
Maker and any Other Obligor have developed plans for responding to Year 2000 Issues and the implementation of such plans, including
testing, are on schedule in all material respects; (c) Maker and any Other Obligor have developed feasible contingency plans to insure
uninterrupted and unimpaired business operation in the event of fallure of their own systems or equipment or those of their material
suppliers, vendors or customers due to Year 2000 Issues; and (d) the Maker and any Other Obligor shall provide the Bank with any
further assurances as to resolution of Year 2000 Issues requested by the Bank. The tenn "Year 2000 Issues" shall include, but not be
limited to, the inability of computers and computer software, as well as embedded microchips in non-computing devices, to perform
properly, including performance of date-sensitive functions with respect to certain dates prior to and after December 31, 1999.
Confession of Judgment.
The Maker authorizes any attorney admitted to practice before any court of record in the United States to appear on behalf
of the Maker in any court in one or more proceedings, or before any clerk thereof or prothonotary or other court official, and
to appear for, confess judgment and enter judgment against the Maker at any time, whether before or after the occurrence of
any default hereunder, witb or without averment of default, with or without complaint filed, and without prior notice to or
opportunity of Maker for prior hearing, in favor of the holder of this Promissory Note in the full amount of the indebtedness
evidenced by this Promissory Note (including principal, accrued interest and any and all charges, fees and expenses) plus court
costs, plus attorneys' fees equal to fifteen percent (15%) of the unpaid balance of principal, interest, charges, and other sums
due or which may become due hereunder, with release of all errors and without right of appeal. In addition to all other courts
in which judgment may be confessed against Maker upon this Promissory Note, Maker agrees that venue and jurisdiction shall
be proper in the courts of any county or city of the Commonwealth of Pennsylvania or in the United States District Court for
the Middle District of Pennsylvania. Maker waives the henefit of any and every statute, ordinance, or rule of court, whether
now in force or hereinafter enacted, which may be Iawfu1ly waived conferring upon Maker any right or privilege of exemption,
homestead rights, appraisement, stay of execution or supplementary proceedings, or other relief from the enforcement or
immediate enforcement of a judgment or related proceeding on a judgment. (To the extent prohihited hy applicable law, any
judgment ohtained hy confession shall not constitute a lien on any real property located in Pennsylvania which is the residence
of any Maker.) The authority and power to appear for and enter judgment against Maker shall not he exhausted hy one or
more exercises thereof, or hy any imperfect exercise thereof, and shall not be extinguished by any judgment entered pursuant
thereto; such authority and power may be exercised on one or more occasions from time to time, in the same or difference
jurisdictions, as often as the holder shall deem necessary or advisable. MAKER HEREBY ACKNOWLEDGES THAT THE
CONFESSION OF JUDGMENT PROVISIONS HEREIN CONTAINED WHICH AFFECT AND WAIVE CERTAIN LEGAL
RIGHTS OF MAKER HAVE BEEN READ, UNDERSTOOD AND VOLUNTARILY AGREED TO BY MAKER.
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Security.
Sums due under this Promissory Note are secured by, and the Maker grants to the Bank a security interest in, all deposits and
property of the Maker now or at any time hereafter in the possession of or on deposit with the Bank whether as custodian or depository
or in any other capacity. In addition, this Promissory Note is secured by any property descnl>ed as collateral in any security
agreement, mortgage, deed of trust, pledge agreement or other document previously 1 simultaneously, or hereafter entered into by the
Maker in connection with any obligation or liability of the Maker to the Bank or any corporate affiliate of the Bank.
Default.
Any of the following will be a default under this Promissory Note: (a) failure to pay any principal, expense, fee, charge or interest
when due, or failure to perfOJIIJ. any other obligations hereunder; (b) a default by any Maker upon any of the existing or future
obligations of any Maker to the Bank; (c)a default by any guarantor or other person that is now or hereafter liable upon or in connection
with any of the obligations of any Maker to the Bank or that has granted any lien or security interest to or for the benefit of the Bank to
secure any of the obligations of any Maker to the Bank ("Other Obligor"), upon any of the existing or future obligations of any Other
Obligor to the Bank; (d) a default in any other agreement, instrument or document between any Maker or Other Obligor and the Bank
or any corporate affiliate of Bank, including, without limitation, any security document referred to above, whether previously,
simultaneously, or hereafter entered into; (e) a material adverse change in the financial condition of any Maker or Other Obligor from
that expressed in the fmancial statement most recently submitted to the Bank prior to the date of this Promissory Note, as detennined in
good faith by the Bank in its sole discretion; (t) institution of bankruptcy, insolvency, reorganization or receivership proceedings by or
against any Maker or Other Obligor in any state or federal court; (g) the appoinnnent of a receiver, assignee, custodian, trustee or
sirnilarofficial under any federal or state insolvency or creditors' rights law for any property of any Maker or Other Obligor; (h) failure
of any Maker or Other Obligor to furnish to the Bank such collateral or additional collateral as the Bank may in good faith request; (i)
any warranty, representation, or statement to the Bank by or on behalf of any Maker or Other Obligor proving to have been incorrect in
any material respect when made or furnished; (j) the occurrence of any event which is, or would be with the passage of time or the
giving of notice or both, a default under any indebtedness of any Maker or Other Obligor to any person other than the Bank; (k) any
material loss, theft or substantial damage, not fully insured for the benefit of the Bank, to any of the assets of any Maker or Other
Obligor, or the sale, transfer, lease, encumbrance or other disposition of all or any material part of the assets of any Maker or Other
Obligor other than in the ordinary course of business of the Maker or Other Obligor; (I) the entry of any fmal judgment against any
Maker or Other Obligor for the payment of money in excess of $5,000; (m) the levy upon or attachment of any assets of any Maker or
Other Obligor; (n) the recordation of any federal, state or local tax lien against any Maker or Other Obligor; (0) a change of ownership
or dissolution, merger, consolidation, liquidation or reorganization of any Maker or Other Obligor which is a corporation, partnership
or other legal entity; (P) the death of any Maker or Other Obligor who is a natural person; (q) the failure of any Maker or Other
Obligor to furnish to the Bank such financial information as the Bank may require from time to time; or (r) the determination in good
faith by the Bank, in its sole discretion, that the ability of any Maker or Other Obligor to payor perform any of their respective
obligations to the Bank is impaired for any reason.
Remedies.
Upon a default, in addition to all other rights and remedies available to the holder of this Promissory Note under any other
document or agreement between the Maker and the Bank or under applicable law, the holder of this Promissory Note, in the holder's
sole discretion and without notice or demand, may declare the entire unpaid principal balance plus accrued interest and all other sums
due hereunder immediately due and payable. The Maker agrees that a default under this Promissory Note is a default by the Maker
under all other liabilities and obligations of the Maker to the holder, and that the holder shall have the right to declare immediately due
and payable all of such other liabilities and obligations.
Interest Rate After Judgment.
If judgment is entered against the Maker on this Promissory Note, the amount of the judgment entered (which may include
principal, interest, charges, fees, and expenses) shall bear interest at the higher of the above-described default interest rate as
detennined on the date of the entry of the judgment, or the legal rate of interest then applicable to judgments in the jurisdiction in which
judgment was entered.
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Expenses of Collection.
The Maker sha1l pay all costs and expenses incurred by the Bank in collection sums due under this Promissory Note, including
without limitation the costs of any lien, judgment or other record searches, appraisals, travel expenses and the like. In addition, if this
Promissory Note is referred to an attorney for collection, whether or not judgment has been confessed or suit has been filed, the Maker
sha1l pay all of the holder's costs, fees (including, but not limited to, the holder's attorneys' fees, charges and expenses) and all other
expenses resulting from such referral.
Negotiable Instrwnents.
The Maker agrees that this Promissory Note shall be deemed to be a negotiable instrwnent, even though this Promissory Note may
not qualify under applicable law, absent this paragraph, as a negotiable instrument.
Waivers.
The Maker, and all parties to this Promissory Note, whether maker, indorser, or guarantor, waive presentment, demand, notice of
dishonor and protest.
Extensions of Maturity.
All parties to this Promissory Note, whether maker, indorser, or guarantor, agree that the maturity of this Promissory Note, or any
payment due hereunder, may be extended at any time or from time to time by the Bank without releasing, discharging, or affecting the
liability of such party.
Notices.
Any notice or demand required or pennitted by or in connection with this Promissory Note, without implying the obligation to
provide any notice or demand, sha1l be in writing at the address set forth below or to such other address as may be hereafter specified
by written notice to the Bank by the Maker. Any such notice or demand shall be deemed to be effective as of the date of hand delivery
or facsimile transmission, one (1) day after dispatch if sent by telegraph, mailgram, or overnight delivery, express mail or federal
express, or three (3) days after mailing if sent by first class mail with postage prepaid.
Assignability .
This Promissory Note may be assigned by the Bank or any holder at any time.
Joint and Several Liability.
If more than one person or entity is executing this Promissory Note as Maker, all liabilities under this Promissory Note shall be
joint and several with respect to each of such persons or entities.
Binding Nature.
This Promissory Note shall inure to the benefit of and be enforceable by the Bank and the Bank's successors and assigns and any
other person to whom the Bank may grant an interest in the Maker's obligations to the Bank, and shall be binding and enforceable
against the Maker and the Maker's personal representatives, successors and assigns.
Invalidity of any Part.
If any provisions or part of any provision of this Promissory Note shall for any reason be held invalid, illegal or unenforceable in
any respect, such invalidity, illegality or unenforceability shall not affect any other provisions of this Promissory Note, and .this
Promissory Note shall be construed as if such invalid, illegal or unenforceable provision or part thereof had never been contamed
herein, but only to the extent of its invalidity, illegality or unenforceability.
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Maximum Rate of Interest; Commercial Loan.
Notwithstanding any provision of this Promissory Note to the contrary, the Maker shaI1 not be obligated to pay interest hereunder in
excess of the maximum rate of interest permitted by the laws of any state detennined to govern this Promissory Note or the laws of the
United States applicable to loans in such state. If any provision of this PromissOry Note shaI1 ever be construed to require the payment
of any amount of interest in excess of that permitted by applicable law, then the interest to be paid hereunder shall be held subject to
reduction to the amount allowed under applicable law, and any sums paid in excess of the interest rate allowed by law shaI1 be applied
in reduction of the principal balance outstanding under this Promissory Note. The Maker acknowledges that it has been contemplated at
all times by the Maker that the laws of the Commonwealth of Pennsylvania will govern the maximum rate of interest that it is
permissible for the holder of this Promissory Note to charge the Maker under this Promissory Note. The Maker warrants that this
Promissory Note evidences a loan made solely to acquire or carry on a business or commercial enterprise.
Choice of Law; Consent to Venue and Jurisdiction.
This Promissory Note shaI1 be governed, construed and interpreted in accordance with the laws of the Commonwealth of
Pennsylvania, even if the Pennsylvania rules governing conflicts of laws would otherwise require that the laws of another jurisdiction
govern this Promissory Note. The Maker consents to the jurisdiction and venue of the courts of any county or city in the
Commonwealth of Pennsylvania and to the jurisdiction and venue of the United States District Court for the Middle District of
Pennsylvania in any action or judicial proceeding brought to enforce, construe or interpret this Promissory Note.
Unconditional Obligations.
The Maker's obligations under this Promissory Note shall be the absolute and unconditional duties and obligations of the Maker and
shall be independent of any rights of set-off, recoupment or counterclaim which the Maker might otherwise have against the holder of
this Promissory Note, and the Maker shall pay absolutely the payments of principal, interest, fees, charges and expenses required
hereunder, free of any deductions and without abatement, diminution or set-off.
Actions Against Banle
Any action brought by the Maker against the Bank which is based, directly or indirectly, or in whole or in part, upon this
Promissory Note or any matter related to this Promissory Note shall be brought only in the courts of the Commonwealth of
Pennsylvania.
WAIVER OF JURY TRIAL.
THE MAKER (BY EXECUTION OF THIS PROMISSORY NOTE) AND THE BANK (BY ACCEPTANCE OF THIS
PROMISSORY NOTE) AGREE THAT ANY SUIT, ACTION, OR PROCEEDING, WBETIIER CLAIM OR
COUNTERCLAIM, BROUGHT OR INSTITUTED BY THE MAKER OR THE BANK ON OR WITH RESPECT TO THIS
PROMISSORY NOTE OR WHICH IN ANY WAY RELATES, DIRECTLY OR INDIRECTLY, TO THE OBLIGATIONS OF
THE MAKER TO THE BANK UNDER THIS PROMISSORY NOTE, OR THE DEALINGS OF THE PARTIES WITH
RESPECT THERETO, SHALL BE TRIED ONLY BY A COURT AND NOT BY A JURY. THE MAKER AND THE BANK
HEREBY EXPRESSLY WAIVE ANY RIGHT TO A TRIAL BY JURY IN ANY SUCH SUIT, ACTION, OR PROCEEDING.
THE MAKER AND THE BANK ACKNOWLEDGE AND AGREE THAT THIS PROVISION IS A SPECIFlC AND
MATERIAL ASPECT OF THE AGREEMENT BETWEEN THE PARTIES AND THAT THE BANK WOULD NOT ENTER
INTO THE TRANSACTION WITH THE MAKER IF THIS PROVISION WERE NOT A PART OF THEIR AGREEMENT.
The signature(s) and seal(s) of the Maker are subscribed to this Promissory Note the day and year written above.
WITNESS! A TIEST:
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Victor D. Macomber
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Wanda W. Macomber
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COMMERCIAL PROMISSORY NOTE MODIFICATION AGREEMENT
AND DECLARATION OF NO SET-OFF
THIS AGREEMENT, made this I zilt day of ;:JUl' / ,2001, by and between
VICTOR D. MACOMBER and WANDA W. MACO~intly and severally (the
"Sorrower") and ALLFIRST BANK, a Maryland state-chartered commercial bank (the
"Sank") to modify the Commercial Promissory Note dated September 7, 2000, given in
connection with that certain Mortgage also dated September 7, 2000 (the "Mortgage") to
secure payment of an original principal indebtedness of Four Hundred Sixty Thousand
Dollars ($460,000), said Mortgage having been recorded in the Office of the Recorder of
Deeds of Cumberland County, as a lien on real estate located at 704 Lisburn Road,
Camp Hill, Cumberland County, Pennsylvania (the "Mortgaged Property"),
WITNESSETH:
WHEREAS, on September 7,2000, Borrower made, executed and delivered to
Bank a Commercial Promissory Note in the principal amount of Four Hundred Sixty
Thousand Dollars ($460,000) (the "Note"), which Note is incorporated herein by
reference thereto and made a part hereof; and
WHEREAS, Borrower is indebted to Bank under the Note for monies advanced
and required to be advanced to or on behalf of Borrower by Bank under and subject to
the terms of the Note and related documents and instruments (the "Related
Documents"); and
WHEREAS, the parties hereto have agreed to amend certain repayment terms of
the Note; and
WHEREAS, Borrower has no defense, charge, defalcation, counterclaim, plea,
demand or set-off against the Note or any of the Related Documents, and
acknowledges and agrees that said Mortgage is now and shall remain as a valid lien on
the Mortgaged Property; and
WHEREAS, the parties hereto desire to formalize their agreement for this
modification and amendment of Note and Mortgage.
NOW, THEREFORE, for good and valuable consideration, the receipt and
sufficiency of which are hereby acknowledged, and intending to be legally bound
hereby, the parties hereto covenant and agree as follows:
1, That the introductory clauses set forth above are incorporated herein by
reference and made a part hereof.
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2. That the Note be and hereby is amended to substitute "June 7, 2001" for
"March 7, 2001" appearing therein as the last day of the Advance Period and to
substitute "June is, 2001" for "March 15, 2001" appearing therein as the last day on
which interest only payments will be due and payable and to substitute "July is, 2001"
for "April is, 2001" appearing therein as the first day on which 111 consecutive equal
installments of principal and interest will be due and payable. The monthly installments
of principal and interest will be based on a 231-month amortization. The final payment
in the amount of the entire unpaid principal balance and all accrued and unpaid interest
will still be due and payable on September is, 2010.
3. That the Note is secured, among ether things, by said Mortgage.
4. That it is understood and agreed by the parties hereto that this Agreement
does not constitute the creation of a new debt or the extinguishment of the debt
evidenced by the Note and Mortgage, nor does it in any way affect or impair the lien of
the Mortgage, which the parties hereby acknowledge to be a valid and subsisting lien on
the Mortgaged Property, or any additional and other security provided by Borrower to
Bank, and the lien of said Mortgage, as well as any such additional and other security,
is agreed to have continued force and effect from the date thereof, unaffected and
unimpaired by this Agreement, and the same shall so continue until fully satisfied.
5. That in all other respects, the Note and Mortgage shall remain in full force
and effect, and without limiting the generality of the foregoing, all remedies and warrants
of attorney therein are ratitied and confirmed and incorporated herein by reference.
6. That any and all references to the Commercial Promissory Note dated
September 7, 2000, in writings of the same or subsequent date shali be deemed to be
or to have been made and to refer to the Commercial Promissory Note dated
September 7,2000, as amended and modified from time to time. -
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IN WITNESS WHEREOF, this Modification Agreement has been duly executed
as of the day and year first above written.
WITNESS:
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ctor D. acomber.
.1tf2tL~~/m~~(SEAL)
Wanda W. Macomber
"Borrower"
ALLFIRST BANK
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF el{I1JS~~t"".~p
55.
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I hereby certify, that on this IaZ. day of ~.p1? I!... , 2001, before
me, the subscriber, a Notary Public of the Commonwealth of Pennsylvania aforesaid,
personally appeared Victor D. Macomber and Wanda W. Macomber, known to me or
satisfactorily prov~n to be the persons whose names are subscribed to the within
instrument and acknowledged that they executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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..... Notary Public,____~_..__ .._________.
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
58.
On this, the day of , 2001, before me, the undersigned
officer, personally appeared , who acknowledged (her)
himself to be of ALLFIRST BANK. and that (s)he, as such
officer being authorized so to do, executed the foregoing instrument for the purposes
therein contained by signing the name of the organization by (her)himself as such
officer.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Notary Public
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ALLFIRST BANK,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
vs.
VICTOR D. MACOMBER and
WANDA W. MACOMBER, his wife,
Individually and Jointly,
Defendants
: No. C>1-.JOFt
<ZLO;.l~
PRAECIPE FOR ENTRY OF APPEARANCE
TO: PROTHONOTARY
Please enter the appearance of Marc A. Hess, Esquire of the fIrm of Henry & Beaver
LLP, whose address is 937 Willow Street, Lebanon, Pennsylvania 17046 as attorney for AllfIrst
Bank the Plaintiff in the above-captioned matter.
Dated: /l!1CU6' If, 2001
BliiJiir'
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OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
TO: Mrs. Wanda W. Macomber
3452 Lisbum Road
Mechanicsburg, PA 17055
ALLFlRST BANK,
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C--f";';
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs.
VICTOR D. MACOMBER and
WANDA W. MACOMBER, his wife,
Individually and Jointly,
Defendants
: No. 01 - .36Ft
NOTICE
0o~CT~
Pursuant to Pa.R.C.P. Rule 236 please be advised that judgment by confession in the
above proceeding was entered against you on m~r ;J I
Principal Sum Due -
Interest to 5/18/01 -
Late Fees -
Attorney's Fees (15% of principal, interest and charges)-
Total -
,2001 in the amount of:
$ 431,058.28
7,075.97
220.25
65,753.18
$ 504,107.68
Plus all future interest accruing at the contract rate ($110.76 per diem) until paid in full,
charges, fees, expenses and court costs. Copies of all documents filed are attached hereto.
C,.--fv ) K- 4
Prothonotary
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OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
TO: Mr. Victor D. Macomber
3452 Lisbum Road
Mechanicsburg, P A 17055
ALLFIRST BANK,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
Plaintiff
vs.
(!:K>~L ~
VICTOR D. MACOMBER and
WANDA W. MACOMBER, his wife,
Individually and Jointly,
Defendants
: No. 01 - .?6Ft
NOTICE
Pursuant to Pa.R.C.P, Rule 236 please be advised that judgment by confession in the
above proceeding was entered against you on fY/';Jy .J. I
Principal Sum Due -
Interest to 5/18/0 I -
Late Fees -
Attorney's Fees (15% of principal, interest and charges)-
Total-
,2001 in the amount of:
$ 431,058.28 .
7,075.97 i
220.25
65.753.18
$ 504,107.68.
Plus all future interest accruing at the contract rate ($110.76 per diem) until paid in full,
charges, fees, expenses and court costs. Copies of all documents filed are attached hereto.
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Prothonotary
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
FLEET MORTGAGE CORPORATION,
F/KIA FLEET REAL ESTATE FUNDING
CORPORATION
No.: 01-3089-CNIL
VS.
WILLIAM H. DEVORE, JR.
DONNA M. DEVORE
199 RIDGE HILL ROAD
MECHANICSBURG, P A 17055
PRAECIPE TO VACATE JUDGMENT
TO THE PROTHONOTARY
Kindly mark the judgment that was entered in the above captioned matter on
JULY 11, 2001 vacated upon payment of your costs only.
~AMili1_ iJdMA1~_
Fr Federman, EsqUIre
Attorney for Plaintiff
July 26,2001
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