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Home My WebLink About03-2496FULTON BANK, Plaintiff VS. WELLS PRINTING, INC. SCOTT A. WELLS and KAY WELLS Defendants TO: Wells Printing, Inc. P. O. Box 284 New Cumberland, PA 17070 · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA : : · CIVIL ACTION - LAW Scott A. Wells and Kay Wells 1450 Yocumtown Road Etters, PA 17319 You are hereby notified that on '-~x~,~, ,2 ~ ,2003, judgment by confession was entered against you in the sum of $27,431.7-5 in the above-captioned case, plus costs of suit. 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. Lawyer Referral Service Cumberland County Bar Association Carlisle, Pennsylvania 17013 (717) 249-3166 /45655 FULTON BANK, Plaintiff VS. WELLS PRINTING, INC. SCOTT A. WELLS and KAY WELLS Defendants · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA : : : · CIVIL ACTION - LAW TO: Wells Printing, Inc. P. O. Box 284 New Cumberland, PA 17070 Scott A. Wells and Kay Wells 1450 Yocumtown Road Etters, PA 17319 A judgment by confession has been entered against you in Court. If you wish to open the judgment or otherwise attack the claim set forth against you in the following pages, you must take action as soon as possible after this Complaint and Notice are served, by entering a written appearance personally or by an attorney, and filing in writing with the Court your defenses or objections to the judgment entered against you. You are warned that if you fail to timely do so, you may be foreclosed and not able to do so at some alternate date and execution may be issued against you without further notice. You may lose money or property or other rights important to you. CALD~& KEARNS By ~ey~or P~t Atto iff YOU SHOULD TAKE THIS PAPER TO YOUR"I~WYER 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: Lawyer Referral Service Cumberland County Bar Association Carlisle, Pennsylvania 17013 (717) 249-3166 FULTON BANK, Plaintiff VS. WELLS PRINTING, INC. SCOTT A. WELLS and KAY WELLS Defendants · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · NO. a~.aVqG ~ ~.~ · CIVIL ACTION - LAW TO: Wells Printing, Inc. P. O. Box 284 New Cumberland, PA 17070 Scott A. Wells and Kay Wells 1450 Yocumtown Road Etters, PA I7319 A judgment in the amount of $27,431.79 has been entered against you in favor of the Plaintiff without prior notice and 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 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. Lawyer Referral Service Cumberland County Bar Association Carlisle, Pennsylvania 17013 (717) 249-3166 Dated: ~,C~:~ 12_(J~ Respectfully submitted, C.z ,DWELL & KEARNS By:_ ~5~ng~ J3~C' ;,,~;quire qorth Front Street Harrisburg, PA 17110 (717) 232-7661 FULTON BANK, Plaintiff VS. WELLS PRINTING, INC. SCOTT A. WELLS and KAY WELLS Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW CONFESSION OF JUDGMENT COMPLAINT PURSUANT TO Pa. R.C.P. 2952 AND NOW, comes the Plaintiff, Fulton Bank, by and through its attorneys, Caldwell & Keams, who makes the following Complaint for Confession of Judgment for Money pursuant to Pa.R.C.P. 2952, and states in support thereof as follows, to wit: 1. Plaintiff, Fulton Bank, is a Pennsylvania Bank and Trust Company duly incorporated and existing under the laws of the Commonwealth of Pennsylvania. Plaintiff's principal place of business is located at One Penn Square, Lancaster, Lancaster County, Pennsylvania, 17604. Plaintiff does regularly conduct business within Cumberland County, Pennsylvania. 2. Wells Printing, Inc. is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, having a last known address of 151 Reno Avenue, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Defendants Scott A. Wells and Kay Wells are both adult individuals whose last known address is 1450 Yocumtown Road, Etters, York County, Pennsylvania 17319. 4. On or about April 15, 1995, Wells Printing, Inc. did enter into a certain Line of Credit Note and Agreement in favor of Fulton Bank in the amount of $10,000.00, payable on demand, with interest at the annual variable rate of 1.50% above the annual floating rate of interest designated from time to time by Fulton Bank as prime rate. A true and correct copy of said Line of Credit Note and Agreement is attached hereto, marked Exhibit "A", and made a part hereof by reference thereto. 5. On or about July 11, 1997, said Line of Credit Note and Agreement, Exhibit "A", was modified by Supplement increasing said principal sum from $10,000.00 to $25,000.00. A true and correct copy of said Supplement to Line of Credit Note and Agreement is attached hereto, marked Exhibit "B", and made a part hereof by reference thereto. 6. In conjunction with said obligations, the individual Defendants, Scott A. Wells and Kay Wells did execute and deliver, on or about September 25, 1995, to Fulton Bank an unlimited personal Guaranty of the obligations of Wells Printing, Inc. to Fulton Bank. A true and correct copy of said Guaranty of Scott A. Wells and Kay Wells is attached hereto, marked Exhibit "C", and made a part hereof by reference thereto. 7. Defendant, Wells Printing, Inc., did fail and/or refuse to pay the monthly installments of interest due and billed for the months of October 2002 through April 2003. Said Defendants were furthermore provided by Fulton Bank a notice of demand of said delinquent payments due through February 28, 2003 on February 27, 2003 advising that a failure to pay said amount due could result in acceleration of the full obligation as provided in the Line of Credit Note and Agreement. 8. The balance due on the obligation as of May 7, 2003 is as follows: Principal $24,987.27 Interest through 05/07/03 $ 887.56 Late Fees $ 56.96 Total $25,931.79 It is noted furthermore that the Note carries a per diem interest of $3.99 per day, after May 7, 2003. 9. Fulton Bank has made demand upon all Defendants, and furthermore, herein makes further demand, to pay said obligation, with accrued interest and costs, but said Defendants have failed and/or refused to pay any and all delinquent sums now due. 10. Confession of judgment at any time that liability exists under the instruments is authorized by the confession of judgment provisions contained in Exhibit "A", the Line of Credit Note and Agreement, and Exhibit "C", the Guaranty. 11. Judgment has not hereinbefore been entered on this obligation in this or any other jurisdiction with regard to any of the Defendants. 12. The individual Defendants are not members of the armed forces of the United States or its allies. 13. Demand is also made for reasonable attorneys fees in the amount of $1,500.00 as authorized by the Line of Credit Note and Agreement and the Guaranty. 14. The transaction, as represented by Exhibits "A" through "C", is for a commercial transaction and not, in any manner or form, a consumer transaction. WHEREFORE, PlaintiffFulton Bank demands judgment against Defendants Wells, Printing, Inc., Scott A. Wells and Kay Wells, in the total amount of $25,931.79 plus attorneys fees of $1,500.00, cost of suit and accruing interest after May 7, 2003. Date: By: Respectfully submitted, CALD~ 7ELL & KEARNS James ~ i~.n~squire Attom~,. Attorne~,,36r Plaintiff 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 20-531/56981 Exhibit A ~ Fulton Bank ' " , , Lancaster, Pennsylvania $ ~*~**~10~000o00 Line or Credit Note and Agreement Date FOR VALUE RFIiP~VED, Wells Print£ngt Inc. (~c 'Borvowe~) pmmis~s to ~y to t~ o~er ~ Ba~ ~dicatcd ~ov~ at any ~ i~ ban~ug officer~ the ~1 ~m of ~N THOUS~ ~ ~O/lOO DOLLARS ($ * * * * * * 10 · 0 0 0.0 0 ~ or such les~r or ~.ater principal amount a~ may bc ouL~t~ding from time to gmc under ~ Linc of CFadil Note and Ag~ement (the 'Note arid Agreement') as shown o~ Batik's record~ payable oa DF. MAND by Bank, with interest at the Fate ~ified below. INTERP_.b~ RATI~ - Thc intcx~t rate is thc annual variable ~ ~ 1 · 5 0 % ~ ~ ann~ ~thg me of ~ d~ f~ ~ m fl~ by ~c ~nk ~ j~ ~r~e rate a~ ~ ~ ~ ~ a ~rc~ m~ ~th ~ ~ d~c~t ~ ~ ~ ~ m ~~ ~ htc~all~b~ ~th~ ~ ~th ~y~m~ ~taaUsumd~u~cr th~ha~n ~d~ fullafldt~mdit a~bUi~ ~ hc~y ~ ~ ~ ~n te~t~ Thc intcreM rntc shah change &utonmtleaHy and ~mulm~ u~n thc ~f~ ~ M ~ ~ti~ of ~y ~an~ M ~ ~fm ~t~ ~nk's ~a~ from time to ~mc ~ iu 'palm' ~te ~l ~ ~ any ~y p~lu~ ~ from ~g 1~ to ot~r ~ at a ~tc ~h ~ ~er or I~r ~n or diffc~nt from t~ p~ ~te. ~l iatc~ ~1 ~ ~mputcd ~ the ~1 numar of ~ claud on t~ ~ ~ a y~r ~tiflg of ~ ~ ~ ~RGE - ~c ~r ~ p~ m ~y to hnk ~ a la~ ~a~ and ~t n a~ition~ inte~ un amo~t ~ual ~ 5~ ~ any ~cflt n~ ~ by ~k ~ ~ ~f~ t~ ~th ~u ~y after t~ ~te it ~ du~ The fotJowifl~ paFagrnpb s~s ~orsh a rant or ~om~ ~ ~ess JuSt ~in~ t~ ~r. in ~nt~ t~ wa~t of ~ to co~ u~ondil~ ~s a~ ~ ~ ~s tb ~r ~ ~ my bye ~o p~ m~ a~ ~ ~M~ for ~ u~ the ~ and ~ of the U~t~ ~ ~ ~e ~m~h of CONFESSION OF JUDGMENT -- THE BORROWER HEREBY AUTHORIZES AND EMPOWERS IRREVOCABLY THE PROTHONOTARY OR ANY CLERK OR A'FrORNEY OF ANY COURT OF RECORD TO APPEAR AND TO CONFESS JUDGMENT AGAINST THE BORROWER IN FAVOR OF THE HOLDER OF THIS NOTE AS oFrEN AS NF. CF..SSARY UNTIL ALL LIABIIJ'I'iES HAVE BEEN PAID IN' rt/LL, AS OF ANY TERM, FOR ALL AMOUNTS OWING OVHKTHER OR NOT THEN DUE} UNDER THIS NOTE AND AGREEMENT, TOGETHER WITH COSTS OF ~ PROCEEDINGS AND A RF. KSONABLE A'ITORNEY~ FEE FOR COLLECTION (WHICH laOR PURPOSES OF EXERCISING THIS WARRANT OF ATTORNEY TO CONFE.q~ JUDGMENT SHALL BE DEEMED TO BE EQUAL TO IS~ OF THE SUM OF THE PRINCIPAL PLUS INTEREST FOR WHICH JUDGMENT IS THEN CONFE~qED), WITH RELEASE OF ALL ERRORS, WAI~ER OF APPEALS, AND WITHOUT STAY OF EXECUTION. THE BORROWER HEREBY WAIVES ALL REUEF FROM ANY AND ALL APPRAISEMENT~ STAY OR EXEMPFION LAWS OR RULES OF COURT NOW OR HEREkFrER IN EFI~,CT. Thc tcm~ and condition~ stated on the w~r~e side and thc ~g~ a~a~ed hc~ a~ ~mt~ hc~ by ~c~n~. Witn~ t~ due cx~t~ ~ th~ No~ and ~ un~r ~1 on ~c ~ ~d ~ ~t a~ ~en. Wells Printing, Inc. (SEAL) .(SEAL) (s~) Addre,~: 151 Reno Avenue, New Cumberland, PA 17070 (SEAL) , Ltne of Credit Note and Agreement (Continued) This Note ]tad ,'s~rceancflt evidences thc ]~Jormwcr's lilbilitics and ~fi~tio~ to ~nk in ~nc~ioa ~h a li~ ~ ~dit (thc '~flc') ~ ~ c~ h thc a~tc at ~ ~c ~ ~ f~ a~at ~ ~ N~ a~ ~cmcnt, ~b ~11 bc ~Uablc ~ thc ~r u~ thc f~ng tc~ ~nd ~nditio~: ~ ~k~ bc~, t~ L~ s~l[ ~ a ~ng line of ~it under ~ch ~r may ~, ~y and ~bo~ amoun~ n~ to ~ in ~tc at a~ o~ ~ the f~ am~nt of the ~ and ~mcnt. ~ ~ ~ hc~ ~c ~ ~ ~ a n~ I~c ~ ~it u~cr ~h ~r m~ ~ am~n~ not ~ e~ ~ thc a~ the am~nt of ~ ~ a~ ~cnc a. ~ -- ~C ~ "~F m~ ~ and ~y ~ or mo~ ~ the ~ ~ enti~ cx~uting th~ N~ and ~mcnt ~ in ~ · mo~ t~n ~c ~r ex~u~ th~ ~tc end ~t+ all such ~ a~ j~ntly ~d ~lly ~) ~ ~ ~ any nam~ ~a~ ~ th~ ~r n~ or ~ftcr in the ~n of ~ ~i~ or h~h~t~ ~ ~ f~ any pu~ and any ~ or s~ ~ng ~ t~ ~r of ~y ~t, a~ or other a~ ~th ~n~ and any ot~r amount ~h ~y ~ ~g ~ ~ ~ fi~ ~ ~k m ~e ~r. d. ~ - ~ ~ ~nb~- i~ud~ (1) aH amoun~ at any fi~ ~n~ un~r ~ Note and ~men~ ~luding any ~ p~nt or ~ ~r ou~ to ~ ~cthcr ab~u~ ~ ~n~n~nk di~ or ind.. ~int, ~1 or i~c~n~nt, d~ or to ~mc duc, ~r d~r~ ~ker, ~r, ~nt~. su~ or othc~ h~d ~ to ~.h~d ~ ~nk for i~ ~ ac~nt or ~ a~nt for another or ot~ ~ ~n ~fi~ by P~ml ~ ~ ~la~ ~ 12 CF.~ ~ ~1 et ~., and ~ch ~ n~ exempt~ from t~ a~fi~tion ~ ~t ~lati~ ~n~ ~ in the fu~ ~ ~ ~k a ~ ~tc~ in, ~ li~ u~n, p~ to ~ t~ Note and ~mcnt ~1~ or ~n~ ~biflfi~ of ~ ~ to t~ ~ ~. ~ ~ C~ Av~ - F~m ~c ~ hc~f a~ p~or to ~mand ~ ~ ~ to thc te~ ~d ~dit~ ~ ~ No~ and ~r may ~ ~cr. ~r s~ ha~ the ~t ~lun~ ~ p~y ~t~ ~nal~ or p~um. at aay t~c ~ f~ t~ to t~ any ~ ~ of thc ~f ~a~ ~d~g u~r the ~ncl p~ ~t ~ intc~ u~ t~ a~unt ~ ~11 ~ ~id at t~ ti~ of any ~ p~enL ~r ~ and ~ ~ ~ p~ he~. ~r any ~ of ~ ~ ~ion he~t~ s~H ~ d~ to ~ or ~m ~r ~ -- ~ ~ unt~ f~cr not~ f~ ~nk that, u~n ~Fs ~u~t by telephone f~ time ~ time f~ either or ~ to bo~ ~ey un~r t~ ~n~ ~k ~fl lend ~d f~lh ~dit ~s ~maad ~it ~nt ~tutc a ~p~t~ ~ ~ that ~ of thc ~ndili~ ~t f~h ~ ~i~ 5 hc~ ~ ~n ~t~fi~ ~r a~ to fo~ ~t~n ~n~ ~ s~h ~mt f~ a~n~ ~ ~llm~ on the ~ ~y a ~t~r of ~ation ~cd ~ the P rn n ~ d ~n~ ~r V 4 e~ P r~n t ~ ~r ~fi~ing t~ amount ~ ~d. P~di~ ~ipt ~ s~ ktter by ~ t~ o~ ~ ~ the ~i~ any su~ of mon~ ~ by ~f~hone in a~ ~lh the fo~n~ ~n~enU shaft ~m~t~y ~ ~r at ~ ff f~ ~ ~ ~unt ~ ~t, ~ ~e un~nfi~ ~n~ and a~ly tke ~bit~ amou~ to t~ p~ b~ ou~d~ 4. P. eprasentmtons and Warranties - The Borrower herr. by mak~ ~ f~l~g ~p~n~io~ and ~nti~ ~ of ~ ~t~ and ~ of ~ ~ ~ any ~n~ he.unit and ~6n~g until ~H amou~ ou~Ming un~r t~ ~ M~ been ~id in ~ ~ -- [f the ~r ~ a ~t~n or a ~ne~i~ (1) ~e ~ ~ du~ o~, ~id~ t~ing ~d h ~ ~nd~[ t~ la~ ~ the ju~on in ~h t~ ~r ~ ~t~ or ~ fo~ (2) thc ~r h~ t~ ~r and auth~ ~ ~ i~ p~ and ~ ~ to ~ ~ i~ b~ ~ n~ being ~nd~cd; and (3) the ~r k q~fi~ to do b~a~ in ~ j~ion in ~ it ~ ~ui~ to qu~i~ to ~ ~h~. b. ~ A~ -- ~ ~ ~r ~ a ~ ~ a ~ip, ~ e~tlon, del~ and ~o~ ~ ~ N~c ~ ~mcnt, thc ~1 ~n~ ~d afl m~r d~n~ a~ ~t~mcn~ ex~t~ and de~ m ~nk ~ ~nne~ h~th and the~ h~ ~n du~ auth~ ~ all ~u~ ~te ~ ~nc~ip ~. c. Co~ l~ - ~ ~fi~, ~ ~d ~o~a~ of t~ ~ and ~ement, t~ ~ie~l D~men~ and aU ~her ~en~ ~ ~ c~ut~ a~ ~ m ~nk in ~on he~th ~ t~ ~ ~:. (I) ~o~tc any p~ion ~ law, any ~er any ~ or ~en~l ~, ~%' ~r ~nm ~d ~ ~ a~mnt o~ thc ~r, m any p~on ~ ~ ~ of ti~) a dcfa~t un~r any Indents, a~e~nt ~ ~her imt~nt b~g ~n thc ~r or any ~ i~ ~ ~ ~ ~ (3) ~It d. Va~ B~ Nm -- ~ ~r h~ ~ ~r ~ c~, ~r ~ ~o~ th~ ~e and ~ment and ~ ~ateml ~ ~n ~ a~ ~ t~ N~e and ~e~m and th~ ~tml ~men~ ~ ~ ~ ~d ~d~g ~li~tio~ of the ~r, e~b~ ~ ~u~ ~ the~ ~ ~pt ~ ~fo~bi~ may be li~ted by ~n~, ~n~ or other ~ar ~ aff~ing e. ~on -- ~ ~ ~ ~ ~l~g to ~n~ t~ ~ no ~, suit ~ p~g at ~ or ~ ~ui~ ~ ~ ~fo~ ~y ~1 ~men~i~ or a~ ~n~ or, m t~ ~ ~ t~ ~r, th~ten~ ~ or ~i~ or aff~ng t~ ~r ~ any ~ P~ ~ ~ ~c~ if ~e~d a~ to I~ ~ ~ ~r the ~Fs ~t to ~ ~ i~ b~inm ~ n~ ~ f. Authorization and Consent - No authorization, consent, approval, license or cxcmptinn os', and no regulation, qualification, designation, declaration or filing with any court or governmental cle~artmcnt, Commission, board, bureau~ agency or instrumentality, domestic or f~orcign, is anCeStry to the valid execution, delivery or peff'ormance Of this Note and Agreement, the Collateral DOcomcnts.or any other dorumcntz or instruments executed and delJvcrod to Bank in connection hct~'with or therewith. g. Finaachl Condition -- The m~,t recent financial statements Of thc [~orrowcr delivered to Bank arc true and correct and represent accurately nad compgctely the Bofl'owcr's financial condition as of the date thcrcof and the resulu of its oFcrations for thc pcrioda indicated and show all IJabilkca of the Borrower, dhcct or contingent, as Of the date thereof. S~nce thc date of such trmaflcial mtements, thera has been no material adverse change in the financ/al conditio~ of thc Bosro~cr or in its operatinns, busincsc~ pn~cts or properties, and fince such date, thc Borrower has not incurred, other than in the ordinary cours~ of bualne~ any indcblcdnssr,, I~ab[lities, obligations or commitments. h. Cousplinmce with Laws - Th~ I~o~r is ~ in v~olatJon of o~ subject to any contingent liab[llty on account of any law or any order or ragulation issued by any court or governmental authority, ~tate or federal, including, without limitation, the ~mpioycr I~tircmcnt Income Security Act Of 1974, &mended (*]~RISA'), thc lntcroal as ReVenue Code of 1986, as amended (the *Code'), any applicable occupatiov~i and health or snfcty L~w, cnvicontocnlal protection or poHutinn control law or hazardovs waste or toxic substances managemnnt, handling or disposal $. Conditions Prat -- Thc Borvo~,cr's ability to requcat an advance heraunder is tuhject to the performance by the Bocrow~r of the o~ligatinn to hc performed by the Bot'xo~cr under this Note and Agreement, under the Collateral Document~ and under the other documents and instruments executed in c°nnnctJon hcrawith and therewlth ors or hcfore t he date Of each advance. . hereunder and also to thc sett~fnctton Of the fofloWing addit~al condition~: · . 'The re--tat/cats and xtcncranties contained in this i~otc and ?~ccmcnt and in thc Collateral Documents shall bc truc on and as of thc date Of cnch advance hcteundcr with thc same cffec~ as though each such rcptesentation and urarranty ,was made on a~d as of thc date of each advance hereunder, b. 'The cot~ditions, if any, spe~fied in thc Collateral Documents and in any document or iostrument amending, modify~g or supplamcnting this Note and Ag~emcnt shall have been fvlfil]cd. 6. A/g*wnmtfve Core,mits The Borrower here~y covenants end agrees that so long ns any ot thc LhbsfiUex or any other os' Borrower's obligations to Bank cranium pursuant to this Note and Agx~cmcnt or any of thc Collateral Documents are outstanding or unpcrformed, the Borrower shaft, except as ]lank may oth~ ag~c in writing: L F'uume'ml S~utements o A~nual -- Furnish to Bank, within 120 day~ afte~ the end of each fl~cal year of the Borrower, & balance sh~-t and inCOme statom~nt, co~,ofidatcd and consol;dating and with a reconci~ation Of surplus for such fiscal )~r, and setting forth in compar~t~c form thc conzsponding figusc~ for the pracedlng f'~cal year, all in ~m~ble detaU aad all prepared by an independent, certified public accountant satisfactoD, to l~aflk; in c~xform~ty with genc~l]y accepted accounting stafldarck consistently appliccl. b. ~'~llmm~iM hffotmafloa . (Mher -- Furnish to ~aflk each finanfial statement or certifieste required to be del~vcl~l by thc BoFrc,~r to ~k purstmnt to nny amendment or supplement to this Note and Ag~emcnt, and such other information concerning thc Borrower's finans/al or basins~ affairx as I~nk may frmu time to time require. c. J~v0pevty -- Maintain, pre.eryc and kccp all of its properties in good repair, condition and M~Flfing order and mahe or cause to bc made all renewals, rcl~acements, aubstitutionx, additions and improvements thereto nece~ary or apl~ropr~te to properly preserve and maintain the cfficicncy of all such properties. Tazes and Asse~meots -- Pay and discharge all taxc~, asses~ncnre and governmental chat~_s Ic~ed upon or ~ against the Borrower or its prot~2~rties or i~com¢ prior to the date any pcns]tiex arc attached thereto. e. Llt~gMion -- Notify l~ank pcomptly of the commencement of any'material lltigatien, ay'nitration or go~rnmcntal proceeding a~cctlag thc Borrmver, and notKy Bank of any govzrnmental inve~,tJgation or labor dlsputc peadlng, or to the knowledge of thc [?,orrc~r, threatened, which could interfe.~ with thcf.nornral operations Of thc Borg.vet's businsus or materially adveracly affect th~ Borrower's financial conditk)n, businc~ or opcrations~ Books and Ibx-~ords -- Maintain nnd hccp proper records and books Of account' ia conformity w/th generally accepted accounting standards applied on · ctms~cnt bas~ which shall nccucately end completely reflect the Bolx~wcr's buboes3, operations and affair& g. Aecns~ to Books. Records and l~per~s - Permit of TIcet~, employees and other representatives Of Bank to visit and ifupect the Borrower's properties and to examine thc Borrc~zr's books and rex~rds, "nd shall discuss thc Borrower's accounts, finances, businc~ and affairs with Bank rcptr~cntat~cf,, during normal baslness hours and as often as Bank may h. Fbm~scb, I IM'ormat~on. Ge~rautora - Caul: any guazantor and any surety of the I~abilil]cs to submit to Bank peraoflal and business fiflanc/al statnngnts aMtaining snch finnnciai information m; Bank may from ¢imc to time raqunst. i. O~her Obligations - Maintain in n current statu~ ail of/ts obligatiot~ hov,,~,cr incurr~ including, without limitation, obligations for borrow~ money or for setv/cc~ or goc~s parchac. M by the Borrower, and not amend or modify any existing agreement with any per,,on,or entity in any manner materially ad~t~ to the shall Bm~a~ss Oper~ioas I~asntaln the management, secluding management personnel, Of its b~mess as It currantiy exists aM is currently conducted, not engage in any llne of buMAe~ other then those in which thc Borrower is actively engaged as of the date of this Note and .Ag~emcnt, and shall not e~tabl]sh any partnet~tip, subsidmry, corporation, Jams ,,q~nture or other form Of business combtnatio~n. k. Compliance With Laws - Comply with all laws and all rules, regulations and order3 issued pursuant thereto including, without limitation, thc Code, any appficabJc' . . . occupational and health or safety law~ cnvzronmental protection or pollution control Iow or hasardons ~tstc or toxic substances nunngement, handiing or disposal law. L ][muram - K~cp all of ia properties, raal and persor, a~, now owned or hereafter acquired, annUl'Cd it all times agaj~t k~ or damage by fire and extended coverage r~sks and other hazards customarily insured against, shall maintain liability insurance and such other insurance cox~cage required by Bank or by law, with car~rs and in amounts, form and substance satisfactol~ to Bank lad naming Bank as additional lnsured/k~ payee, us Bank's inter~t my appear, and shah pcomptly d~liver to Bank from time to time upon request a summa.,y schedule indicating aH insurancc in effect. m. IUse ar La~n Proceeds ~ f~se advances under the L~nc only for the pot'poses stated in thc application suhnfitled by the Borrower to Bank ia connection w/th thc Linc if any, or iA any commisment letter issued by Bank to the Borrower in connncVion with the n. Other Linb~rias ~ Not endorse, assume, become guarantor or surety for or otherwise hoc'oran liable h connection with thc obligations of any j)cr'~on, firm or cat, oration, except in favor of Bank; provi~d, however, that the Borrower may endorse flcgorlabL~ or other instruments for daposit or collection or sim~tar transactions in thc ordinary course of its bminess. o. ~ od' Asses ~ Not scl], lease, transfer or othcl~;ise dispose of in a single transaction or series of cransuctions, all or a sub~.antial part of the Borrowers assets and properties, whether now owned or hereafter acquired. p. InvestmefMa ~ Not purchase, ow~, inve~t in or acquire, directly or indirectiy, any stock or other securities or any other intcrcat whatsoe~r in any other corporation or other entity or permit to e~ any loans or adv~hces for such pncposcs except for investments in di~'t obligations of thc United States or any agency thereof. q. S~Uinf Accounts ReceivabLe -- fqot sell, reign or discount an), Of Jta aCCOunts receivable or any pcomissory notus held by it~ with or without recourse, other than the discount Of such receivables or notc~ for collection in the ordla&cy Course of business. r. ]qo41ce of Brueh ~ Promptly give notice in writing to Banh of the occurrence or existence of any event, condition, act or omission, which cons'titute a bra~h or vinhtinn of any of the repi~entatiofls, warrantius or cox~ants made by thc []orrowcr in this Note and Agecemcot or in any Collateral Documents. 7. Co[lateral; [ntorpo/ation of Otifer Deeuments - The Collateral ~all secure payment to Bank of any and all amounts due under ~is l~ot?and Agreement Thc Botx'ov~t hereby grantt or confirms the grant to Bank o[ a s~curity interest in. licn upon. and 'right of sctoff against the Collateral The holder of this Note and Agreement shall be entitlnd to all rights, vemndies and benefits of any of thc Collateral Documents and any oti~t document~ and im'truments erecuted and dalivet'nd to Bank in connection hcre~th or Cherewith and aU of such documents are incorporated in this Note and Ag~cment by reference. Without limiting the generality of the foregoing, tbe Collateral Documun~ a~ of the date hereof, include the following: ~usr~t¥ of Scott k. ~etLs and Kay ~etls Accounts recefvnb|e, |nYe~tory, general Intangibles, anchi~ry nnd equil~ne~t of Borrower 8. A,orneT~ Fees; Kzpenses - The Borrcmer also agrees m ~y to ~n~ ~n ~nd at ~y fim~ all ~ a~ ~ (~lndi~ ~le atm--' f~ and le~ ~) ~ ~ ~nk ~ ~e enfo~ent ~ the ~s fiab~ a~ ~li~ ~ ~ under t~ Note ~d 9. ~ ~ ~ _ If the ~r ~ ~ ~y ~ ~d t~ b~ or any ~r amount de~d (or ~t duc ~ to ~mand) ~m~L ~ ~H ~ the ~ti~ to ~m m ~ ~m~ d~ ~d ~ any and all ot~r ~iHti~ ~ ~ n~ it ~ m ~mte thc ~ ~nk may ~ off ~n~ ~ may ~ any ~ a~ ~mcdi~ a~ any Ob~ ~ ~ ~to~l ~ may ~ ~l~le to ~nk un~ ~ ~ ~mcnt. the ~llat~ ~en~ ~ Unifo~ ~m~ ~e or ~h~ ~p~bl~ law. ~t~shaH ~ ~ to ~ aR~ any ~ult ~ ~enl~ ~ether or n~ ~y ~k or ~unfing ent~ shall ~ ~en m~ If ~ent ~ ~ a~un~ ~ ~r t~ N~e a~ ~nt ~ ~ ~ by ~nk m~ 15 ~ a~r ~nk's ~nd the~for. ~te~ ~aH ~ at t~ opt~n ~ ~ and ~t. at a ~ 5~ ~r ~ a~ t~ ~te~ ~te s~fi~ ~ ~tH ~ moun~ d~ ~r th~ ~te and ~nt ~a~ ~ a~ after ~ of j~ent by ~f~i~ or ~h~ at the ~n~ inte~ n~ un~ aH ~u~ d~ ~der ~ ~ a~ ~ut and un~r any juSt a~ ~ - · ~ ~ t~ ~t to p~ a~ any Ob~ aM ~ a~ ~ ~ ~te~l to ~nm ~t ~ to any ~er ~li~ in ~ am~nu ~d ~ su~ o~r ~ ~nk m~ in i~ ~le ~t~n 1~ M~ - (a) ~ ~ ~ ~ ~t for ~ ~i~ ~ ~ n~ ~ ~nt or ~r. ~ ~d a~ ~ber no~ ~ ~ ~th t~ ~!~. a~n~. ~ffo~ ~ e~o~ment ~ ~ent of th~ N~ No~t~n~ng ~y ~r p~ ~ th~ ~ ~d ~emem. at no ~e s~H the ~t ~ ~H~t~ ~ ~y inte~ he~u~et at e~ ~ ~e ~um n~ ~itt~ ~ hw. a~ if. by t~ ~ ~ ~ ~te a~ ~menL ~e ~r ~ at any t~e ~Hp~ to ~ ~h ~um m~ ~ ~ of inte~ be~un~ s~ ~ ~m~ i~iately ~d to s~ ~m~ ~te ~ ~t; (c) [f any aM ~t ~ f~ any ~ ~d i~d or ~o~ble. ~ ~ber p~ ~ ~ nff~ ~c~. ~ t~ N~e ~ ~nt ~ · the ~ ~ ~o~ble ~ ~ n~t ~ a ~n ~ ~; (d) ~e duti~ of ~e ~t ~a[I ~ ~ding on t~ ~r ~d ~p~nmt~ ~ t~ tu~ a~ ~ of ~ ~r a~. ~th ~ m any ~ne~ ~fing th~ ~ a~ ~nl ~er shall be ~ he~ ~th in ~ ~ne~ ~ft Ind~d~ ~ ~ ~t~ (e) ~ Note and ~ent ~ll ~ ~ by a~ ~t~ ~ ~ ~th t~ ~ ~ the ~ml~ of Pc~ (0 ~ long ~ ~nk ~ ~t ~r he~. ~k'a ~ and ~ ~1 be p~ (~pt ~ the ~ ~ manif~ e~r) ~ a~ly ~ at MI ~ MI ~n~ d~ u~r ~ N~e and ~ment a~ the ~te ~d a~unt of ~ ~u rome puget begin; ~ ~ Nme and ~t ~ ~ ~fid and eff~ m ~ ~ made ~un~r ~ the fm ~at th~ may ~ ~ ~n no in~t~ ~ ou~d~g ~un~G ~d (h) No~t~d~ ~ ~ p~l a~ont ~ing ~r ~ ~c ~ t~ amount for ~h th~ Note ~d A~:nt ~ ~t~n. ~ t~ te~ ~t ~ be~iu and in · e ~te~ ~men~ ~1 a~ly to a~ n~ ~kh ~ ~ mount ~tan~g u~ t~ ~ ~ t~ ~ ~iL Exhibit B Fulton Bank ~qy)£.L 0~, ' ~-,,~' 520 ~,f'la/.~ - I- I Supplement to Line of Credit Note and Agreement ' rage'lof 1 Date:. ?itl/q7. The prov/sions set forth in this Supplement constitute additional provisions or modifications of that certain Line of Credit Note and Agreement dated. AUGUST 15, 1995 (the "Note and Agreement') cover/nE the obi/gations and liab/I/ties of the U'ndersigned (the 'Borrower") to Bank in connea/on w/th the Line (as the term is del'reed in the Note and Agreement). 1. The provisions of th/a Supplement shaU be deemed to be fuUy incorporated by reference in and shall con~itute provisions of the Note and Agreement as of the date of th/s Supplement. 2. Except as expressly supplemented or modified by this Supplement, the Note and Agreement shall continue in full force and effect in accordance w/th/ts terms, conditions, covenants and provisions, all of which are hereby reaffirmed in their entirety c~cept as supplemented or mogified hereby. 3. Terms not defined in th/s Supplement shah have the meanings ascribed to thcm in the Note and Agreement. 4. Borr.ower hereby covenants and agrees as follows: The Note la amended to increase the principal st~ evidenced by the Note fram $10,000.00 to $25,000.00. Witness the due execution of th/s Supplemont to Line of Credit Note and Agreement, under Seal and INTENDING TO BE ~/etls Printing, inc. w~.tGALLY BOLrND HEREBY~_on th_~..dey and year ftt~ above Scott A. Wells, President Exhibit C FULTON BANK ~ ' Bank ' GUARANTY (ALL LIABILITIES) The Undersigned, inteRdin~ to be qegally bound hereby, and in consideration of the credit heretofore, concurrently or hereafter c~tended by Bankto W~lln Pr,int.(no: Tnt~, ('Borrower"), has entered into this Guaranty and Bank has agreed to make available or maintain such credit for Borrower in gcliance on this Guaranty. , 1. DEFINITIONS. As herein the following terms shall have the mean/nfs that follow: The terms "Borrower's Liabilities" or 'Liabll/ties" mean and refer to all existing and future indebtedne~ and other ftabilkies outstanding to Bank from Borrower, whether absolute or contingent, direct or indirect, joint, several or independent, held or to be held by Bank for its own account or as agent for another or others, and even ff acquired by way' of a~ignment. "Collateral" means all real and personal property, tangible and intang~'ble, of even/description, as set forth on any separately e~ex:uted mortgages or other security agreements or documents granting to Bank a security interest to secure this Guaranty specifically or liabilities of thc Undersigned generally;, and afl property of any nature whatsoever of the Undersigned now or herenfter in the - po~ession of or assigned or hypothecated to Bank for any purpose, and am/balance or share belonging to the Undursigned of any deposit, agency or other accounts with Bank and other amounts which may be owing from trine to thne by Bank to the Undersigned. Without l/miting the gnnerallty of the foregoi~_g, thc Collateral includes the following: NONE --~ - .'- 2. CONTINUING SURETY OBLIGATION - The Undersigned does hereby unconditionaUy guarantee, and become surety to Bank for the full and prompt payment when due, whether by acceleration or othelxvise, and at ali times thereafter, of ail the Liabilities. This Guaranty is a Continuing one and shall be effective and binding on the Undersigned regardless of how long before or after the date hereof any of Borrower's Liabilities were or are incurred. Notwithstanding the foregoing, any one of the Undersigned may at any thne not lens than 365 days from execution of this Guaranty, ~ve written notice to Bank of such Underaigned's intention to terminate prospectively their surety obligation for Borrower's Liabi/ities pursuant to this Guaranty. Any notice so given shall be effective with reject to Borrower's Liabilitie~ incurred after receipt by Bank of the written notice, but shall not be effective with re,peet to, nor terminate the Undcrsigned's liability for, Liabilities which are rent. ntis, extensions or modil~tcatioas of existing Liabilities or Liabilities aa to which Bank is then bound by agreement or Conu~tment to thereafter ex'tend. The Undersigned guarantees that all payments and recoveries of collateral (including, but not limited to, the CoUateral) applied by Bank to the Liabilities will, when made, or when so applied, be final and not recoverable in any insolvency or bankruptcy proceeding; and agrees that if any amount applied to the L/abilities ia recovered from, or repaid by, Bank in whole or in part in any bankruptcy, insolvency or similar proceeding instituted by or against Borrower, the obligation of the Undersigne~d ahab continue to be fully applicable to the amount so repaid or recovm'ed to the same extent as though the amount recovered or repaid had n~ver been applied with re~ to the L/abilities. Thc Undersigned hereby grants to Bank authority to maintain of record, and to record, documents nece~nan/ to perfect or to continue Bank's perfected interest in the Collateral until such time as Battk is satisfied in its sole discretion that it no longer has e:~osure to diagotgement. The right of Bank to continue its perfected interest in the Collateral ia for its sole benefit, and the Undersigned shall not be relieved of personal liability for Borrower's L/abilities because Bank elects not to continue an interest in the Collateral. 3. AMOUNT OF LIABILITY- The amount of the Undersigned's liability hereunder shall be limited to the maximum principal sum of $ UNLIMTTED , ~lua interest accrued thereon. If no insertion has been made in the preceding space, the amount of the Undersigned's Liability hereunder shall be UNLIMITED. if the amount of the Undersigned's liability hereunder is herein ~q~ted, the Undarsigued agrees that the amount of Borrower's Liabilities may from time to time ~xceed the limit of the Undersigned's liability hereunder without in any way affecting or diminishing the obligation of the Undersigned, and that Bank may apply any payment by or on behalf of Borrower with respect to Borrower's Liabilities to or on account of such of Borrower's Liabilities and in such order aa Bank may elect. 4. UNCONDITIONAL LIABILITY - The liability of the Undersigned hereunder is absolute and unconditional and shall not be affected in any way by reason of (a) any failure to retain or preserve, or the lack of prior enforcement of, any judgment or other righ~ agai~t any pe~on or persons (including Borrower and any other surety or guarantor) or in any propetXy, (b) the invalidity or unavailability of any such judgment or other rights which may be attempted to be obtained, (c) any delay in enforcing or failure to enforce any such rights even ff such rights are thereby lost, or (d} any delay in making demand on the Undersigned for performance or payment of the Undersigned's obligations hereunder. 3. WAIVERS - The Undersigned hereby waives all notices of any character whatsoever with respec~ to this Guaranty and Liabilities to Bank, including but not being ihnited to notice: of the acceptance hereof and reliunc~ hereon, of the pret~nt enistence or future incurring of any of the Borrower's Liabilities to Bank, of the amount, tcrm~ and conditions thereof, and of any defaults thereon. The Undersigned hereby ennsents to the taking of, or failure to take from time to time without notice to the Undersigned, any action of any nature whatsoever with respect to the Borrower's Liabilities to Bank and with respect to any rights against any person or persons (including Borrower or any of the Undersigned) or in any property, including but not being limited to any renewals, extensions, modifications, postponements, compromise% indulgences, waivers, surrenders, exchanges, and releases, and the Undersigned will rem2in fully liable hereon notwithstanding any of the foregoing; provided, however, that the granting of a release of the liabil/ty hereunder of le~ than all of the Undersigned shall be effective with respect to the liability hereunder of the one or more Undersigned who are specifically released, but shall in no way affect the liability hereunder of aW of the Undersigned not specifically released. The death or incapacity of any of the Undersigned shall in no way affect the liability hereunder of any other of the Undersigned. The Undersigned hereby waives the benefit of ali laws now or hereafter in e~ect in any way li~ting or restricting the liability of the Undersigned hereunder, including~ without limitation, (i) all defenses whatsoever to the Under. ed's liability hereunder, ex ~c~pt the defense of payments made on account of Borrower's L/abilities to Bank and the Unde~igned's liability hereunder and (ii) all right to stay of execution and exemption of property in any action to enforce the liability of the Undersigned hereunder. 6. PAYMENT OF COSTS - In addition to ail other liability of the Undersigned he.under and notwithstanding the limit, if any, set forth in paragraph 3 hereof, the Undersigned also agrees to pay Bank on demand all costs and expanses (including reasonable attorneys' fees and legal ex'penses) which may be incurred in the enforcement of the Borrower's Liab/llties or the liability of the Undersigned hereunder. 7. ACCEU~RATION OF LIABILITIES - If any of Borrower's Liabilities to Bank are not paid when due or ff there occurs a default or event of default under agreements pertaining to any of Borrower'~ Liabilities, all Borrower's L/abilities to Bank shall at Bank's option and without prior notice to the Undersigned be deemed to be forthwith due and payable for purpose~ of this Guaranty and the liability of the Undersigned hea'enndc~r. As bet~veen the Undersigned and Bank, the Liabilitie~ for which the Undersigned is surety hereunder may be declared to be due and payable for purpeaes of this Guaranty notwithstanding any stay, injunction or other prohibition which may prevent, delay or initiate any such declaration aa agnh~ Borrower. 8. DEFAULT- There ~hafl occur a #De, fault' under thin Gueranty ff the Undersigned fails to pay when due any amount owing hereunder or fal~ to do or perform any of its obligations under any documents pertaining to tho Collateral. Lf a Defanli occurs, Bank may exercl.~ its right of scruff and may ~erct~ any and all lights and remedies against the Undersigned or the Collateral as may be available hereunder, under security and other collateral documents pertaining to the Collateral, under the Uniform Commercial Code, or otherwise. The terms of the security and other collateral documents are incoq~orated herein by referenca. The remedies set forth in those other documents shaft be in addition to other remedlea of the Bank hereunder with resp~ to the indebtednes& of the Undersigned, including, without limitation, the right to confess judgment against the Undersigned at any time, whether or not a Default has on:curred. 9. WAIVER OF SUBROGATION-The Undersigned hereby irrevocably waives a ' (whether arising directly or indirectly bt, onerati~- ~, .......... any nd ali rights the Undersi ed · · . ~, -, r v,, v, ,aw uz uy COn[tact to azse . . gn may have ar a tmle under th~s Guaranty including, without/h~tatio ................ ? . rt any,cla/m against Borrower on acCOunt d~ en~ ...... , ....... ,r~,,a or Suorogat,on reimoursernent exoneration contn'butinn orP~m~ddenulJ~,add I0. OTHER GUARANTIES- A subsequent agreement of suretyship or guaranty by the Undersigned or any Other obligor shall not be deemed to be in lieu of or to supersede or terminate tltis Guaranty but shall be construed az an additional or supplementao, agreement of suretysl~p or guaranty unless otherwise exprezdy provided therein; and in the event the Undersigned or any other obligor has given to the Bank any such agreemen! of sureO/shjp or guaranty previouSly, th/s Guaranty shall be construed to be an additionai or supplementav/ agreement of suretyship, and not to be in lieu thereof or to terminate any such previous agreement of Suretyship or guaranty unless expressly so provided herein. ' - 11. MISCELLANEous_ l[ the Undersigned consists of more than one person, such Th/s Guaranty shaU inure to the benefit of the Bank, its succe, ssors, assigns, endorsers and any person or persons, including any banking persons shall be jointly and severally Uable hereunder. institution or in-~titutions, to whom the Bank may grant any interest in Borrower's Liabilities, or any of them; and shal/be binding upon the Undersigned and the Undersigned's heirs, executor% administrators, successors, assigns, and other legal representatives. The Undersigned intends this to be a scaled instrument and to be legally bound hereby. AU /ssue~ arising hereunder shall be governed by thc law of The following paragraph sets forth a warrant of aHorney to confess judgment against the Undersigmed. in granting this worraat of attorney to confess judgment against the Undersigned, the Undersigned hereby knowingly, Ieteutionnlly add voluntarily, add, with opportunity for the advice of separate counsel of the Undersigned, unconditionally waives any and all rights the Undersigned has or may have to prior notice and aD opportlmley for hearing udder the respective coastitutians add laws of the United States and the Commonwealth of Pennsylvania. CONFESSION OF JUDGMENT. EACH OF THE UNDERSIGNED HEREBy AUTHoRIZEs AND EMPOWERS IRREvOCABLy THE PROTHONOTARy OR ANY CLERK OR ATTORNEy OF ANY COURT OF RECORD TO APPEAR AND TO CONFESS JUDGMENT AGAINST THE UNDERSIGNED OR ANY ONE OR MORE OF THEM 11%/ FAVOR OF THE HOLDER OF THIS GUARANTY AS OFI~N AS ~y UNTIL ALL LLA. BILITIEs OF THE UNDERSIGNED HAVE BEEN PAID IN FULL, AS OF ANY TERM, FOR ALL AMOUNTS OW]~G (WMETHER OR NOT THEN DUE) UNDER THIS GUARANTy, TOGETHER WITH COSTS OF LEGAL PROCEEDINGS AND A REASONABLE ATTORNEYS, FEE FOR COLLECITON (WHICH FOR PURPOSEs OF EXERCISING THIS WARRANT OF ATTORNEY TO TO 15% OF THE SUM OF THE PRII%TCIPAL PLUS INTEREST FOR CONFF-'SS JUDGMENT SHALL BE DEEMED TO BE EOUAL OF ALL ERRORS, WAIVER OF APPEALS, AND WHICH JUDGMENT IS THEN COIVFESSED), WITH RELEASE WITHOUT STAY OF EXECUTION. THE UNDERSIGNED HEREBy WAIVES ALL RELIEF FROM ANY AND ALL APPRA.[$EMEFrV, STAY OR EXEMPTION LAWS OR RULEs OF COURT NOW OR HERF_.AFTER IN EFFECT. WITNESS W/tne~ the due execution of this Guaranty on the _(S~,L) _(SEAL) Address: 4 s. P~ 1731~_ FULTON BANK, Plaintiff VS. WELLS PRINTING, 1NC. SCOTT A. WELLS and KAY WELLS Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-2496 Civil : CIVIL ACTION - LAW AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS: Personally appeared before me, a Notary Public in and for said Commonwealth and County, James R. Clippinger, Esquire, who, being duly sworn according to law, states that he served a copy of the Confession of Judgment Complaint upon the Defendants, Scott A. Wells and Kay Wells, by mailing to the said Scott A. Wells and Kay Wells at 600 Beacon Hill Road, New Cumberland, Pennsylvania 17070, by certified mail, return receipt requested, said certified mail piece being No. 7099 3400 0012 8973 0764, on May 30, 2003; and that attached hereto, marked Exhibit "A", and incorporated herein by reference is Postal Receipt Form 3811, bearing the signature of the Defendant, Scott A. Wells, acknowledging receipt of the aforementioned document by the Defendant on May 31, 2003. Sworn to and subscribed this ~/-]¥']~ day of June 2003 Nc;tary Publ~/ My Commission Expires: 23183 NOTARIAL SEAL NANCY L. BRESKI, Notar~ Public Susquehanna Township, Dauphin Counly My Commission Ex?ir~es_March 16, 2004 James R. ~ Attorney ~ ~'ng~i?l~ire · Complete items 1, 2, and 3. Alan COmplete item 4 if Restricted Delivery is desired. · Pdnt your name ancl aadress on the reverse so that we can return the card to you. · Attach this card to the back of the maJlpiece. _or on the front if space Dermifs. Scott A. and Kay Wells 600 Beacon Hill Road New C~land, PA 17070 2. Article Number (Copy from ~ label) PS Form 381 1, Jury 1999 7099 3400 0012 8973 0763 FULTON BANK, Plaintiff VS. WELLS PRINTING, 1NC. SCOTT A. WELLS and KAY WELLS Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-2496 Civil CIVIL ACTION - LAW AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS: Personally appeared before me, a Notary Public in and for said Commonwealth and County, James R. Clippinger, Esquire, who, being duly sworn according to law, states that he served a copy of the Confession of Judgment Complaint upon the Defendant, Wells Printing, Inc., by mailing to the said Wells Printing, Inc. at 600 Beacon Hill Road, New Cumberland, Pennsylvania 17070, by certified mail, return receipt requested, said certified mail piece being No. 7099 3400 0012 8973 0305, on June 25, 2003; and that attached hereto, marked Exhibit "A", and incorporated herein by reference, is Postal Receipt Form 3811, acknowledging that Defendant has refused service of the aforementioned document. Sworn to and subscribed this My Coffimission Expires: 23183 HARRISBURG, PENNSYLVANIA 17110 Wells Printinc 600 Beaco~ New PA