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Home My WebLink About01-04244.. ~, CAROLYN A. MANGOLD, Plaintiff v. DAVID E. MANGOLD, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. o I- U ~- ~F ~ ~-~ ~z^ PRAECIPE Please enter Judgment Against Defendant, DAVID E. MANGOLD, in the amount of FOUR HUNDRED THOUSAND DOLLARS ($400,000.00), together with interest at the rate of 6% per annum compounded monthly from March 12, 2001, pursuant to the attached Judgment Note dated June 27, 2001. Respectfully submitted, DATE: 7/(cr~7 L~/~~,/~~f~ CONSTANCE P. BRUNT, ESQUIRE Supreme Court I.D. No. 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717)232-7200 Attorney for Plaintiff ~' • ~ CAROLYN A. MANGOLD, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW DAVID E. MANGOLD, NO. 01-1491 Defendant : IN DIVORCE TO: DAVID E. MANGOLD, Defendant You are hereby notified that on ,Z 2001, a judgment by confession was entered against you in the sum of $400,00 .0 ,together with interest at the rate of 6% per annum, compounded monthly from March 12, 2001, in the above-captioned case. DATE: l~n, ~ / ~, oL~o Prothonotary 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 County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 I hereby certify that the following is the address of the Defendant(s) stated in the Certificate of Residence: David E. Mangold 920 West Trindle Road Mechanicsburg, PA 17055 Date: 'T io a r Gam-' /,~, ~~~~i( ' l CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID# 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717)232-7200 Attorney for Plaintiff ~' . r ' ~, c n;' v, ` _._ ~ F ~,~ r ~ C_ F~ ~~ K ~ G W v ~~ 9 ~c ~o C` .~ R.s O ~' JUDGMENT NOTE $400,000.00 Harrisburg, PA /~. 2 7 , 2001 Within five (5) years from March 12, 2001, I promise to pay to CAROLYN A. MANGOLD the sum of Four Hundred Thousand and 00/100 ($400,000.00) Dollars, together with interest at the rate of six percent (6%) per annum compounded monthly, or an amount equal to twenty-five percent (25%) of the sale price of my interest in Real Estate Technology Initiatives, Inc. ("RETI") or Keystone Programming, Inc. d/b/a ANTEIL, INC. ("ANTEIL") or the value of cash or other negotiable instrument received in exchange for my said interest, whichever is greater, without defalcation, without offset, and for value received, . And further, I hereby authorize and empower the Prothonotary or any attorney of a court of record of Pennsylvania or elsewhere to appear for and enter judgment against me for the above sum, with or without declaration, with costs of suit, release of errors, without stay of execution, and with fifteen (15%) percent added for collection fees; and I hereby agree not to make any motion or any application whatsoever to any Court for an inquisition on any real estate that may be levied upon to collect the aforesaid sum, and I voluntarily condemn same, and authorize the Prothonotary to enter said voluntary condemnation upon the Writ of Execution. I fiu4her agree that any property, real, personal or mixed may be sold through a Writ of Execution and further hereby waive and release all relief from any and all appraisements, stay or exemption laws of any State now in force or which are passed hereafter. WAIVER IN EXECUTING TffiS NOTE, I HAVE HAD EXPLAINED AND UNDERSTAND THE TRANSACTION, AND KNOWINGLY AND VOLUNTARILY WAIVE ALL RIGHTS UNDER PENNSYLVANIA LAW, INCLUDING WITHOUT LIl~IITATION, THE RIGHT TO BE SERVED WITH PROCESS, THE RIGHT TO BE NOTIFIED OF THE ENTRY OF JUDGMENT AND THE EXECUTION PROCESS, THE RIGHT TO ENTER A DEFENSE OF THE JUDGMENT, AND ALL EXEMPTION LAWS. I DO HEREBY CONSENT TO THE ENTRY OF THIS JUDGEMENT BY CONFESSION. I HEREBY CERTIFY THAT I HAVE EARNINGS OF $10,000.00 OR MORE PER YEAR. WITNESS my hand and seal the day and year first above written. SIGNED, SEALED AND DELIVERED I~~ENCE OF ~~ (SEAL) VID E. MA OLD _ s' DISCLOSURE FOR CONFESSION OF JUDGMENT I AM EXECUTING THIS SAY OF ~[.-~---- , 2001, A NOTE FOR FOUR HUNDRED THOUSAND DOLLARS AND 00/100 ($400,000.00),OR AN AMOUNT EQUAL TO TWENTY-FIVE PERCENT (25%) OF THE SALE PRICE OF MY INTEREST IN REAL ESTATE TECHNOLOGY INITIATIVES, INC. ("RETI") OR KEYSTONE PROGRAMMING, INC. D/B/A ANTEIL, INC. ("ANTEIL") OR THE VALUE OF CASH OR OTHER NEGOTIABLE INSTRUMENT RECEIVED IN EXCHANGE FOR MY SAID INTEREST, WHICHEVER IS GREATER, TO THE ORDER OF CAROLYN A. MANGOLD, OBLIGATING ME TO REPAY THAT AMOUNT WITHIN FIVE (5) YEARS FROM MARCH 12, 200E I UNDERSTAND THAT THE NOTE CONTAINS WORDING THAT WOULD PERMIT THE HOLDER OF THIS NOTE TO ENTER JUDGMENT AGAINST ME AT THE COURTHOUSE FOR THE ENTIRE AMOUNT OF SAID NOTE, WITHOUT NOTICE TO ME AND WITHOUT OFFERING ME AN OPPORTUNITY TO DEFEND AGAINST THE ENTRY OF JUDGMENT, AND THAT THE JUDGMENT MAY BE COLLECTED AND ENFORCED BY ANY LEGAL MEANS. IN EXECUTING THIS NOTE, I KNOWINGLY, UNDERSTANDINGLY, AND VOLUNTARILY WAIVE MY RIGHT TO RESIST THE ENTRY OF JUDGMENT AGAINST ME AT THE COURTHOUSE, AND I CONSENT TO THE CONFESSION OF JUDGMENT. I HEREBY CERTIFY THAT MY ANNUAL INCOME EXCEEDS TEN THOUSAND AND NO/100 ($10,000.00) DOLLARS, THAT I HAVE READ THIS ENTIRE DISCLOSURE AND THE NOTE AND UNDERSTAND IT AND THAT I HAVE RECEIVED A COPY OF BOTH AT THE TIME I SIGNED THEM. I HAVE READ THIS FORM AND FULLY UNDERSTAND ITS CONTENTS. a CAROLYN A. MANGOLD, Plaintiff v. DAVID E. MANGOLD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW . NO. CERTIFICATE PURSUANT TO Pa.R.C.P. 29511aN21 I, CONSTANCE P. BRUNT, ESQUIRE, counsel for Plaintiff, CAROLYN A. MANGOLD, hereby certify as follows: The judgment being entered by confession against Defendant, DAVID E. MANGOLD, is not in connection with a consumer credit transaction. 2. The residences of the Plaintiff and the Defendant are as follows: Carolyn A. Mangold, Plaintiff 1082 Tunberry Court Mechanicsburg, PA 17055 David E. Mangold, Defendant 920 West Trindle Road Mechanicsburg, PA 17055 DATE: 7r~v~~d Respectfully submitted, ~~~ CONSTANCE P. BRUNT, ESQUIRE Supreme Court I.D. No. 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717)232-7200 Attorney for Plaintiff