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Home My WebLink About01-05941 '. < WILLIAM C. HOLSTINE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 0\ - $9'-11 c;ulL '7-~ vs. TIMOTHY RAYMOND GREENE, Defendant Pursuant to the authority contained in the warrant of attorney, a copy of which is attached to the Complaint as Exhibit "A" filed in this action, I appear for the Defendant aud confess Judgment in favor of the Plaintiff and against the Defendant as follows: Amount Owed: $8,339.00 Interest: to be determined Court Costs: to be determined Attorney's Fees: $2,501.70 TOTAL: $10,840.70 plus interes court costs By: Steven C. ourtney, E METZGER WICKERSHAM 3211 N. Front Street P.O. Box 5300 Harrisburg, P A 1711 0 Phone: (717) 238-8187 LD. No. 74669 Document #: 178282.1 -;,--~,,~,,"",<''''-l'''W.r, ;; .. '" " - ~_"", ',~ ,. ~. "Uf!lI. ""~_ 'T , --- _.~"""~= >, <~- WILLIAM C. HOLSTINE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW TIMOTHY RAYMOND GREENE, Defendant : NO. 01 - G:'9"1f C~()~l ~~ vs. COMPLAINT IN CONFESSION OF JUDGMENT FOR MONEY AND NOW, comes the Plaintiff, William C. Holstine, by and through its attorneys, Steven C. Courtney, Esquire, and the law firm of Metzger, Wickersham, Knauss & Erb, P.C., and states the following cause of action and in support thereof, avers as follows: 1. Plaintiff, William C. Holstine, is an with a last known address of821 Bower Road, Shermansdale, Perry County, Pennsylvania 17090. 2. Defendant, Timothy Raymond Greene, is an adult individual with a last known address of307B North Bedford Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. A true and correct copy of the instrument (Judgment Note) under which Plaintiffis confessing judgment is attached hereto and made a part hereof as Exhibit "A". 4. The transaction pursuant to which Plaintiff is confessing judgment was for a commerciallbusiness purpose and was not a consumer credit transaction. 5. The instrument and obligation under whichjudgment is being confessed has not been assigned. 6. Defendant has defaulted on his obligation to Plaintiff by failing to pay all amounts owed Plaintiff pursuant to the terms and conditions of the Judgment Note attached hereto as Exhibit "A". Document #: 178282.1 "^q;".'''I\:'~~",, -"""~ V" ~_.~~ , , t "' . .. 7. Judgment has not been entered against the Defendant in any jurisdiction for any amount under the instrument. 8. Judgment is demanded as authorized by the warrant of attorney contained in the instrument attached as Exhibit "A". 9. The warrant appearing in the attached instrument is less than twenty (20) years old. 10. The balance due pursuantto the terms and conditions ofthe Judgment Note attached hereto as Exhibit "A" to date is Eight Thousand Three Hundred Thirty-nine and 00/100 ($8,339.00) Dollars, together with an attorney's commission oftwenty-five (25%) percent in the amount of Two Thousand Five Hundred One Dollars and 70/100 ($2,501.70) for a total ofTen Thousand Eight Hundred Forty and 701100 ($10,840.70) Dollars, plus interest and costs. WHEREFORE, Plaintiff demand the entry of a Judgment against the Defendant in the sum of Eight Thousand Three Hundred Thirty-nine and 00/100 ($8,339.00) Dollars, together with an attorney's commission of twenty-five (25%) percent in the amount of Two Thousand Five Hundred One Dollars and 70/100 ($2,501.70) for a total ofTen Thousand Eight Hundred Forty and 70/100 ($10,840.70) Dollars, plus costs in this action. )OlllfA By: Steven C. Courtney, METZGER WICKERSHAM 3211 N. Front Street P.O. Box 5300 Harrisburg, P A 1711 0 Phone: (717) 238-8187 I.D. No. 74669 Attorney for Plaintiff Document #: /78282.1 'F~~",.," ~_~ ',1" --~ ,~~ ,~.~ VERIFICATION I, William C. Holstine, do hereby certify that the statements made in the foregoing Complaint are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities Dated/ t1 ~ / ~O / ~~drn L ~ WILLIAM C. HOLSTINE Document #: ]62754.1 :!""'~;"""'-~"lfif n ~ , , ~" 1IllN. i?:r'''''- DEMAND PROMISSORY NOTE $8.339..00 Date: 11 September 2001 FOR VALUE RECEIVED. the undersigned, Timothy Raymond Greene, of Carlisle, Pennsylvania, promises to pay to the order of William C. Holstine of Shermansdale, Pennsylvania, the sum of Eight Thousand Three Hundred Thirty-Nine 00/100 Dollars ($8,339.00), to be paid as follows, viz.: Upon demand without defalcation. Presentment for payment, protest and notice of dishonor are waived. If this Note is placed in the hands of an attorney for collection. I do hereby agree to pay an attorney's fee of thirty percent (30%) of the amount of this Note and further hereby authorize and empower, irrevoca~ly. the prothonotary or any Attorney of any Court of Record in the Commonwealth of Pennsylvania 01' elsewhere to appear for us at any time and enter judgment without process against u~" with or without declaration. for the amount of this Note, together with all charges,. costs';' interest and attorney's fees as above provided. and do hereby waive and release all errors in any such proceedings and waive all rights,of appeal, and pursuant to and upon such judgment do hereby authorize and consent to immediate executign upon any property, real, personal or mixed, and do hereby voluntarily condemn'same, and no bill in equity or other petitions shall be filed to interfere in any manner with the operation of such judgment or execution thereupon, hereby ratifying and confirming all that said Prothonotary or Attorney may do by virtue hereof, and waiving and releasing benefit of all appraisement or inquisition of real estate, stay of execution, and all rights under the exemption laws of any State, now in force or hereafter enacted. 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