HomeMy WebLinkAbout99-02637
2. Defendant, Shahnawaz M. Mathias alk/a Shah Mathias tla Easten! Development and
Design, upon information and helie~ is an individual and citizen of the Commonwealth of
Pennsylvania with a last known address of 3255 Cape I-lorn Road, Red Lion, PA ] 7356.
3. On or about June 19, 1997, PNC made a loan to Defendant in the original amount of
$225,000.00 (the "Loan") and Defendant promised in that certain promissory note (the "Note") in
the original principal amount of$225,000.00 and dated June 19, 1997 to repay PNC the amount of
the Loan. A true and correct copy of the Note is attach cd hercto, lIlade part hereof and marked as
Exhibit "A."
4. The Note contains 11 warrant of attorney which authorizes the entry of judgment by
confession against Defendant and in favor ofPNC.
5. As of April 12, 1999, Defendant was in default of his obligations pursuant to the Note
by virtue of various events, including without limitation, the following:
a. The entry of judgment against Defendant by William Hess in the York County
Court of Common Pleas in the anlount of $315,840.00 under Court Teml and
No. 98-4760.
b. On or about December I, 1998, the loan matured causing all sums due
thereunder to becomc immediately due and payable.
6. As a result of the aforementioned default, as of April 12, 1999, the following amounts
are immediately due and payable from Defendant in accordance with the temlS of the Note:
1'1111..1179423.'
NOTE:
Principal
$105,000.00
Intercst
(through 4- I 2-99)
$ 6,023.64
Late Chargcs
$ 5,399.38
Attomcys' Fees
(10% of principal and interest
pursuant to terms of Note)
$ ] 1.102.36
TOTAL
$127,525.38
Interest continues to accrue from and after April 12, 1999, at the ~ Qi.\;m rate of$33.54, which is
subject to change as provided for in the applicable loan documents.
7. Judgment has not been entered pursuant to the warrant of attorney contained in the
Note, in this or any other jurisdiction,
8. This judgment is not being entered by confession against any natural person in
connection with a consumer credit transaction.
WHEREFORE, Plaintiff, PNC Bank, National Association, demands judgment in its
favor and against the Defendant, Shahnawaz M. Mathias a/k/a Shah Mathias tla Eastern
Development and Design in the amount of$127,525.38 plus interest Irom and after April 12, 1999,
1~11ll.,\J 7~423.1
,,", -,' ,".,: " '." " '" ':, <:, ," .'," " :,,'.-.... ,',".; .. " -'. .:', ' , ", ' ,"'. ", " ,:' '. '.' "", , .::. .,,' "
..... .'-.
I
.I
I
Exhibit A
@ ,.,' "I ,.~,:; "'''''fr".. W,.~".;,,',~l1.
, . . . '. ' ,
....,~. , '. . '
. ',.)
.' " " .
--,
TERM/TIME NOTE
S225,OOO.00
June 19,1997
FOR VALUE RECEIVED, SHAHNA W AZ M. MATHIAS aka SHAH MATHIAS Ua EASTERN
DEVELOPMENT AND DESIGN (the "Borrower"), with an address at 3255 Cape Hom Road, Red Lion,
Pennsylvania 17;56, promises to pay to the order of PNC BANK, NATIONAL ASSOCIATION (the "Bank"), in
lawful money of the United States of America in immediately available funds at its offices located at 4242 Carlisle
Pike, Camp Hill, Pennsylvania 17011, or at such other location as the Bank may designate from time to time, the
principal sum ofTWO HUNDRED TWENTY FIVE THOUSAND DOLLARS (S225,000.00), together with interest
accruing on the outstanding principal balance from the dare hereof, as provided belowl
I. R3te of Interest. Amounts outstanding under this Note will bear imerest as follows:
A rate per annum ("Floating Rate") which is at all times three-quarters of one percentage point (.75%) in
excess of the Prime Rate,
Interest will be calculated on the basis of a year of360 days for the actual number of days in each interest period.
As used herein, "Prime Rate" shall mean the rate publicly announced by the Bank from time to time as its prime
rate. The Prime Rate is not ticd to any external rate or index and does not necessarily reflect the lowest rate of
interest actually charged by the Bank to any panicular class or category of customers. If and when the Prime Rate
changes, the Floating Rate will change automatically without notice to the Borrower, effective on the date of any
such change. In no event will the rate of interest hereunder exceed the maximum rate allowed by law.
2. P3vment Terms. Principal and interest will be payable as provided below:
Interest shall be due and payable commencing on August 1, 1997, and continuing on the fu-st day of each
month thereafter until December I, 1998, on which date all outstanding principal and accrued interest shall
be due and payable in full.
Ifany payment under this Note shall become due on a Saturday, Sunday or public holidoy unde; the laws oflhe
State where the Bank's officc indicated above is localed. such payment shall be made on the next succeeding
business day and such extension of time shall be included in computing interest in connection with such payment
The Borrower hereby authorizes the Bank to charge the Borrower's deposit account at the Bank for any payment
when due hereunder. Payments received will be applied to charges, fees and expenses (including anorneys' fees),
accrued interest and principal in any order the Bank may choose, in its sole discretion,
3. l.JlJe Pavment" Defaul1 Rale. If the Borrower fails to make any payment of principal, interest or other amount
coming due pursuant to the provisions of this Note wit "in fifteen (15) calendar days of the date due and payable, the
Borrower also shall pay to the Bank a late charge equal to five percent (5,00%) ofule amount of such payment.
Such lifteen day period shall not be construed in any way to extend the due date of any such payment. The late
charge is imposed for the purpose of defraying the Bank's expenses incident to the handling of delinquent payments
and is in addition to, and not in lieu of, the exercise by the Bank ofany rights and remedies hereunder, underthe
other Loan Documents or under applicable laws, and any fees and expenses or any agents or anomeys which the
Bank may employ. Upon maturity, whether by acceleration. demand or otherwise. and at the option of the Bank
upon the occurrence of any Event of DefaOJlt (3.\ hereinafler dermed) and during the continuance thereof, this Note
shall bear interest at a rate per annum (based on a year of 360 days and actual day's elapsed) which shall be three
p~rcent.1gc points (3.00%) in excess oflhe inlert'Sl rate in effect from lirn~ to time: under this No:e but not more than
the maximum rate allowed by law (the "Default Rate"), The Default Rate shall continue to apply whether or not
judgment shall be entered on this NOle,
4. Prepavmenl. If this Note bears interest at the Floating Rate, the indebtedness may be prepaid in whole or in part
,t any time Wilhoulpen,lty, If this Note bears interest at, Fixed Rate, notwithstanding anything contained herein to
the conlrary, upon any prepayment by or on behalf of the Borrower (whether voluntary, on default or otherwise-r-
thc Bank may require, if it so elects, the Borrower to pay the Bank as compensation for the cost of being prepared to
advance fixed rate funds hereunder an amount equal to the Cost of Prepayment. "Cost of Prepayment" means an
amount equal to the present value, if positive, of the product of (a) the difference between (i) the yield, on the
begiMing date of the applicable interest period, of a U,$, Treasury obligation with a maturity similar to the
applicable interest period lIlinJIj (ii) the yield on the prepayment date, of a U,S, Treasury obligation with a maturity
similar to the remaining maturity of the applicable interest period, and (b) the principal amount to be prepaid, and
(c) the number of years, including fractional years, from the prepayment date to the end of the applicable interest
period. The yield on any U,S. Treasury obligation shall be determined by reference to Federal Reserve Statistical
Release H.15(519) "Selected Interest Rates". For purposes of making present value caICU!>lions, thc yield to
maturity of a similar maturity U,S, Treasury obligoti"., on ihe prepayment date shall be deemed the discount rate.
The Cost of Prepayment shaH also apply to any payments made after acceleration of the maturity of this Note while
a Fixed Rate is in effect.
S. Other Loan Doruments. This Note is issued in connection with an Open-End Mortgage and Security
Agreement, and a Letter Agreement, the terms of which are incorporated herein by reference (the "Loan
Documents"), and is secured by the property described in the Loan Documents (ifany) and by such other collateral
as previously may have been or may in the future be granted to the Bank to secure this Note,
6. Events of Default. The occurrence of any of the following events will be deemed to be an "Event of Default"
under this Note: (i) the nonpayment of any prillcipal, interest or other indebtedness under this Note when due; (Ii)
the occurrence of any event of default or default and the lapse of any notice or cure period under any Loan
Document or any other debt, liability or obligation to the Bank of any Obligor; (iii) the filing by or against any
Obligor of any proceeding in bankruptcy, receivership, insolvency, reorganization, liquidation, conservatorship or
similar proceeding (and, in the case of any such proceeding instituted against any Obligor, such proceeding is not
dismissed or stayed within 30 days of the r.ommencement thereof); (iv) any assignment by any Obligor for the
benefit of creditors, or any levy, garnishment, anachment or similar proceeding is instituted against any property of
any Obligor held by or deposiled with the Bank; (v) a default with respect to any other indebtedness of any Obligor
ior borrowed money, if the effect of such default is to cause or permit the acceleration of such debt; (vi) the
commencement of any foreclosure or forfeiture proceeding, execution or anachment against any collateral securing
the obligations of any Obligor to the Bank; (vii) the entry of a final judgment against aay Obligor and the failure of
such Obligor to discharge the judgment withL~ ten da)'s of~'1c en::-; thereof; (viii) in the event that this Note or any
guarantee executed by any Guarantor is secured, the failure of any Obligono provide the Bank with additional
collal<ral ifin the opinion of the Bank at any time or times. the market value of any of the collateral securing this
Note or any guarantee has depreciated; (ix) any material adverse change in the business, assets, operations, fmancial
condition or results of operations of any Obligor; (x) the Borrower ceases doing business as a going concem; (xi)
the revocation or anempted revocation, in whole or in part, of any guarantee by any Guarantor; (xii) the death or
legal incompetency of any individual Obligor or, if any Obligor is a pilrtnership, the death or legal incompetency of
any individual general partner; (xiii) any representation or warranty made by any Obligor to the Bank in any Loan
Document, or any other documents now or in the future securing the obligations of any Obligor to the Bank, is false,
erroneous or miSleading in any material re>pect; or (xiv) the failure of any Obligor to observe or perform any
covenant or other agreement with the Bank contained in any Loan Document or any other documertts now or in the
future securing the obligations of any Obligor to the Bank, As used herein, the term "Obligor" means any
Borrower and any Guarantor, and the term "Guarantor" means any guarantor of the obligations of the Borroweno
the Bank existing on the date of this Note or arising in the future,
Upon the occurrence of an Event of Default: (a) the Bank shall be under no further obligation to make advances
hereunder; (b) if an Event of Default specified in r.Iause (iii) or (iv) above shall occur. the outstanding principal
balance and accrued inl<rest hereunder logethel' with any addition'l amounts payable hereunder shall be
immediately due and payable without demand or notice of any kind; (c) if any other Event of Dcfault shall occur,
rhe outsunding principal balance and accrued interest hereund.r togeth.r wilh any additional amoun15 payable
hereunder, at the option of the Bank and without demand or nctice of.ny kind, may be accelernted...,d become
2
immediately due and payable: (d) at the oplion ofthc Bank, this Notc will bcar imerest at thc Default Ratc from the
dale oflhe occurrencc of the Evcnt of Dc fault; and (c) thc Bank may exercise from lime to lime any of the rights
and remedies available 10 the Bank under the loan Documents or undcr applicable law. _
7. Power to Confess .lud?TUW. The Borrower hereby empowcrs any attornoy of any court of record, after
the occurrence of any Event of Default hereunder, to appear for the Borrower and, with or without complaint
filed, confess judgment, or a series of judgments, against the Borrower in favor of the Bank or any holder
hereof for the entire principal balonce of this Note, all accrued interest and all other amounts due hereunder,
together with costs of suit and an attorney's commission of the greater of 10% of such principal and interest
or 51,000 added as a rcasonable attorney's fee, and for doing so, this Note or a copy verified by affidavit shall
be a sufficient warrant. The Borrower hereby forever waives and releases all errors in said proceedings and
all rights of appeal and all relief from any and all appraisement, stay or exemption laws of any stale now in
force or hereafter enacted. Interest on any such judgment shall accrue at the Default Rale.
No single exercise of the foregoing power to confess judgment, or a series of judgments, shall be deemed to
exhaust the power, whether or not any such exercise shall be held by any court to be invalid, voidable, or
void, butlhe power shall continue undiminished and it may be exercised from time to time as often as the
Bank shall elect until such time as the Bank shall have received payment in full of the debt, interest and costs.
8. RiVht of Setoff. In addition to all liens upon and rights of seloffagainst the money, securities or other property
of the Borrower given to the Bank by law, the Bank shall have, with respect to the Borrower's obligations to the
Bank under this Note and to the extent pennined by law, a contractual possessory security interest in and a
contractual right of setoff against, and the Borrower hereby assigns, conveys, delivers, pledges and transfers to the
Bank all of the Bon'ower's right, title and interest in and to, all deposits, moneys, securities and other property of the
Borrower now or hereafter in the possession of or on deposit with, or in transit to, the Bank whether held in a
general or specialaccounl or deposit, whether held jointly with someone else, or whether held for safekeeping or
otherwise, excluding, however, all IRA, Keogh, and trust accounts, Every such security interest and right of setoff
may be exercised without demand upon or notice to the Borrower. Every such right of setoff shall be deemed to
have been exercised immediately upon the occurrence of an Event of Default hereunder without any action ofthc
Bank, although the Bank may enter such setoff on its books ond records at a later time,
9. Miscellaneous. No delay or omission of the Bank to exercise any right or power arising hereunder shall impair
any such right or power or be considered to be a waiver of any such right or power, nor shall the Bank's action or
inaction impair any such righl or power. Thc Borrower agrees to pay on demand, to the extent pennined by law, all
com and expenses incurred by the Bank in the enforcement of its rights in this Note and in any security therefor,
including without limitation reasonable fees and expenses of the Bank's counsel. Ifany provision of this Note is
found to be invalid by a coun, all the other provisions of this Note will remain in full force and etTect, The
Borrower and all other makers and indorsers of this Note hereby forever waive presennnent, protest, notice of
dishonor and notice of non-payment. The Borrower also waives all defenses based on suretyship or impainnent of
collateral. If this Note is executed by more than one Borrower, the obligations of such persons or entities hereunder
will be joint and several. This Note shall bind the Borrower and its heirs. ex<cutors, administrators, successors and
assigns, and the benefits hereof shall inure to the benefit of the Bank and its successors and assigns.
This Note has been delivered to and accepted by the Bank and will be deemed to be made in the State where the
Bank's office indicated above is located. THIS NOTE WILL liE INTERPRETED A:'IID TUE RICIITS A:-.'D LIABILITIES OFniE
BA~K AND THE BORROWER OETER,\f1:"o1EO 1:'1/ ACCORDA!\CE WITH rUE LAWS orrnE STATE: WHERE THE BANK'S OFnCE
I~DICAT[D r\DOVE IS lOCATED, r.XCLl'D1NG ITS CONruCT Of lAWS RL'ttS. The Borrower hereby irrevocably consents to
the exclUSIve jurisdiction of any state or federal coun for the couuty or judicial district where the Bank's office
indicated above is located, and consents that all service of process be sent by nationally recognized overnight
courier service directed to the Borrower at the Botrower's address set forth herein and service so made will be
deemed to be completed on the business day after deposit with such courier; provided that nothing contained in this
NOle wil! prevent the Bank from bringing any action, enforcing any award or judgment or exercising any rights
against the Borrower individually, against 'my security or against any property of the Borrower within any other
3
KLEHR, HARRISON, HARVEY, BRANZBURG & ELLERS LLI'
!lY: Morton R, Brllllzburg, Esquire/Dimitri L. Karapelou, Esquire
I.H. Nos.: 24477/76708
1401 Walnut Street
Philadelphia, l'A 19102
(215) 568-6060 ATTORNEYS FOR
PNC BANK, NATIONAL ASSOCIATION
PNC BANK, NATIONAL ASSOCIATION
1600 Market Street
II th Floor
Philadelphia, P A 19103
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff,
v.
CIVIL ACTION - LAW
SI'IAI-INA W AZ M, MATI'IIAS a/k/a
SHAH MATHIAS tla EASTERN
DEVELOPMENT and DESIGN
3255 Cape Horn Road
Rcd Lion, P A 17356
Dcfendants.
.HIHGMENT BY CONFESSION
AND NOW. to wit this _ day of
. 1999, a Complaint in Confession
of Judgm.:nt having becn filed and an Affidavit as to thc amount due having bccn tiled:
JUDGMENT IS HEREBY ENTERED in favor of the plaintin: PNC Bank. National
Association and against the Dcfcndant. Shahna\\'az Ivl. Mathias a/k/a Shah Mathias tla Eastem
Development and Design, inthc amount ofS; 127.525.38 plus intcrest from and afier April] 2, 1999.
at the I2U iliru1 rate of $33.54, \Vhich is sllbject 10 elwngc as provided t(lr in the applicable loan
documents. and costs of suit.
PIWlIlONOTARY
!'1I11 I ~94~1.1
copics of thc original instruments.
3. Thc dclendalll is in default of his obligations undcr the Instrumcnts, as morc fully set
forth in the Complaint in Confession of Judgmcnt. The allegations set forth in the Complaint in
Confession of Judgment are true and correct.
4. By rcason of the Defendant's dclilUlt under thc aforementioned Instruments, as of
April 12, 1999, therc was due and owing to I'NC Bank, National Association the amount of
$127,525.38, comprised as follows:
Principal
$105,000.00
Intercst
(through 4-12-99)
$ 6,023.64
Late Chargcs
$ 5,399.38
Attorneys' Fces
(I 0% of principal and interest
pursuant to tcrms of Note)
$ 11.102.36
TOTAL
$127,525.38
Interest continues to accruc from and aflcr April 12. 1999, at thc I2IT dicm ratc of$33.54. whieh is
subjcct to change as providcd for in thc applicable loan documcnts, and late charges continue to
accruc.
SWORN TO andaJ.!BSCRIBED
hdW mc Vlis~ day
O~}lJ t, , 1999.
~^ 1 /?
" :1" r
,- ;d.,llL 0 ,QtM_
(-Nt rARY I'll
Nu~;>' :::,., S(,:~I
P','J.IIl(,Jil!' f'"... .!Yir 1\ltlfl(
"Itll \17{~t!ii.u;I.I(Jtl"~ :~'l,'...l-~:'~,~a CUll'i!~
My C~'''.~.II.I;;~;' IY""<-h'Y. 2. 20(11
Mrmbf'r, Peoo&,'tv3I'Ud ~~soCiJtlOn 01 N01311€S
".'..;l.:,,-_
KLElm, HARRISON, HARVEY, URANZUURG & ELLERSLLP
BY: Morton R. Brunzburl:, Esquirefl)imitri L. K:lI'llpelou, ESlIuire
I.n. Nos,: 24477/76708
1401 Walnut Street
l'hillldclphill,I'A 19102
(215) 568-6060 ATTORNEVS FOR
I'NC BANK, NATIONAL ASSOCIATION
PNC BANK, NATIONAL ASSOCIATION
1600 Market Strcet
11th Floor
Philadclphia, PA 19103
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff,
v,
CIVIL ACTION - LAW
SHAHNA W AZ M. MA T11IAS a/k/a
SHAH MATHIAS tla EASTERN
DEVELOPMENT and DESIGN
3255 Capc Horn Road
Red Lion, PAl 7356
Defendants.
AFFInA VIT OF AI)))RESSES AND CON.JlIGAL INCOME
STATE OF PENNSYLVANIA
ss
COUNTY OF I'IIILADELPIIIA
J. William Brehm being first duly sworn upon his oath according to law, dcposes and says:
1. I :Ull a Vicc President of PNC Bank, National As,odatioll. plaintiff hcrein, and I am
authori/.cd to make this aflidavit on its bclwlf,
., Plaintin's address is 1600 Market Strc:et, I I th Floor, Philadelphia. Pennsylvania
191m,
1'1111 I'N~:'~.I
3. The last-known addrcss ofthc Defendant Shahnawaz M, Mathias a/k/a Shah Mathias
tla Eastclll Developmcnt and Dcsign is 3255 Capc Horn Road. Rcd Lion. P ^ 17356.
4. To the best of my knowledgc. information and bclicf; thc household income of the
Dcfendant is in execss of $ I 0,000.00 pcr year.
SWORN TO and~UBSCRIBED
bcfor me t9is dO day
of ." 1999.
, ARY ~.~~f.lt~;r, Public
PatriCia f,.,. n&i~, N'tt.; I
Ph;l(ldelph"~. PhI13delphl[~ CSu~~~
My CommiSSIon ()',lwes Jl.lnh t:-, ...
M(ll'tlh(H Ponnsyl\'tn18 ASsoClllllon 01 Notirles
1'11I1\17')4~_\.1
2. This is not an action hy a sellcr, holdcr or assignee arising out of a rctail installmcnt
sale, contract or account.
SWORN TO and ~YBSCRIBED
befor me his ~ day
of . ,1999.
yp
NQliiiiAi B~'nl I
"P'a\\'f:\~ A IWh Nelol', Puohc
. t'~\~:~~\~~}\\1,!\, ti\\;t~~lilW,hl,"1 (':OIJnt\'
.1~.:!~~&~~~~,~;-;'.~._r.,......",-'l; ,"J'1tl~
-.........,...,.,..""t"""-.."~ . .-
~Jtft\t'er. ~'l.hl\Wti;M;~ A!\SOC~llon ot NotarIes
)'Jlllllil}.tH.1
".' ~',' ': ,; ",::", :::'~".',"':" ~'\,~;,'. :':':..;I;~~:;:~~~:,<i:~~:~~;":';;"l~ij~~.~':~~~,;",~~,,;,,:~;,:':':.':~:: :~' ",'r;,'" :~,:.~,~' ,,',,',::.1,;,<,,;, "::..\~:.~I-'-';:~"j.;:~:.'-> :':1"
-.
KLEHR, HARRISON, HARVEY, BRANZHURG & ELLERS LLP
HY: Morlon R. Bntnzburg, EsquirelI>imitri L. Karllpelou, Esquire
I.D. Nos.: 24477/76708
1401 Walnut Street
l'hiladelphia,I'A 19102
(215) 568-6060 ATTORNEYS FOR
I'NC HANK, NATIONAL ASSOCIATION
PNC BANK, NATIONAL ASSOCIATION
1600 Market Strect
11 th Floor
Philadelphia, PA 19103
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff,
v.
CIVIL ACTION - LAW
SI'IAHNA W AZ M. MATHIAS alk/a
SHAI'I MATHIAS tJa EASTERN
DEVELOPMENT and DESIGN
3255 Capc Horn Road
Rcd Lion. I'A 17356
Defendants.
AFFIDA VIT OF BlJSINESS TRANSACTION
STATE OF PENNSYLVANIA
SS.
COUNTY OF PHILADELPHIA
J. William Brchm bcing first duly sworn upon his oath according to law. deposcs and says:
I. I am a Vice Prcsidcnt of I'NC Bunk. National Association. thc plaintiffhcrcin. and
I am authorized to makc this at11davit on its hchall:
"11l1 'I ;',l41 ~.i
.... co >-
~ ~ t;"; ;:l
~, '-') r'
f'~: ~ 7?:E
LJ.JC~! \J'.0
~f.~C? .~ , , >
..
I, "" w... (~, .~.~
(;)!-)
C).~/. "'~ ,....,
I -..1..;':'" jfJ
LIJ.__ I;:. ."
~'ltl :-- ;, ~ (.0
~ t,,;.... ~~t: tJ...
~:
"_ co-, :::>
0 '" U ~
~
~ ~
"-{) ~ --
~~ 0
-- ....,) ~
~~~
~
"',
,
"
~
~
~
~
.~
7
..In r)'
'" -r"lr.
...
...
..
...
..
1a
.'
COUNTY OF YORK
OFFICE OF THE SHERIFF
SERVICE CALL
(717) 771-9601
26 EAST MARKET ST, YORK, PA 17401
PNC Bank, N,A.
INSTRUCTIONS
PLEASE TYPE ONLY LINES 1 TO 12
DO NOT DETACH ANY COPIES.
2, COURT NUMBER 99-2637(Cumberland
4. TYPE OF WRIT OR COMPLAINT
SHERIFF SERVICE
PROCESS RECEIPT, and AFFIDAVIT OF RETURN
1. PLAINTIFF/S!
3, DEFENDANTlSI
Shahnawaz
SERVE
.
AT
t/a Eastern Developm nt Rule 2958.1 Notice
M. Mathias, a/k/a Shah Mathias, and Desil;n
5. NAME OF INDIVIDUAL, COMPANY, CORPORATION. ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIE[? ATTACHED. OR SOLO.
Shah Mathias
6. ADDRESS:J~T5'5Ec~~':~ro'~7t 1i'R'&~~,BER,tST t1oC;:~' ~'AROl ~5CTATE AND ZIP CODE
7, INDICATE SERVICE: a PERSONAL a PERSON IN CHARGE fl(OEPUTlZE CumimllllJldlld a 1ST CLASS MAIL
NOW 9 /27 /99 19 _ I, SHERIFF oFl't'tl'R1< COUNTY, PA, cio her
Vorl<-, COUNTY to execute this W
to law. This daputollon being modo at the requost and risk olthe plalntlll.
8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE:
Cumoemlando
"n
."
":r")
Serve pursuant to deputized service from Cumberland County.
'"
~J
_< C) ."
0;":"1 r.:
;0 C) (. ~
~ -'; ~.
ADVANCE FEE PD BY I\'ITY
r--v
CD
~ . U)'
:::J -u -r- f-,.
NOTE ONLY APPUCABlE ON WRIT OF EXECUTION: N,B, WAIVER OF WATCHMAN. Any deputy sheriff levying upon or anaching any property u~r wiltl'1n v.tJl:maY..laa~'e
same withoul a walchman. In custody of whomever is lound in possession, after nOtifying parson 01 levy or aUachmcnl, wllhoulliabihly on tho part 01 sJcti;dcputy or ~~ sMriff to any
plaintiff horein lor any lOS5, dostrucllon. or rmooval 01 any property boloro 6horilf's sala therool. ' ' ..
9. TYPE NAME AND ADDRESS 01 ATTORNEY/ORIGINATOR and SIGNATURE 10. TELEPHONE NUr"_qEA 11. OATE FilED
Dimitri L. Karapelou
260 S. Broad Street, Phila" PA 19102 (215)568-6060 8/29/99
12. SEND NonCE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (Thia area muat be completed il nollce lalo be mailed).
13. I ackOOn1i'rdWG fl>CGJpl 01 :tit; 'itTit
or complalnl as indicatod abovo.
Cumberland County Sheri.ff
SPACE BELOW FOR USE OF THE SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE
SIGNATURE OF AUTHORIZED CLERK 1A Oil!" Rf>("l';"\lM 15 Et.r'~<",lil;>""'I4€,~'I"'~ D!!:!e
B. Feeser 1_ 9/28/99
POSTED ( ) POt ( ) SHERIFF'S orF ( )
OTHER ( I
SEE REMARKS
(See remarks below.)
22,REMARKS:
~,
c'~3. Ad'o'ance Cosls 2~ ti'f -~MI16aUfl ];'7~r~1>I1lI\l~j2lt~,~) 10~';~fT17);;;d -j :m- NCl~;;;-r;;131 '""""112 ,,,..' Go,:, 33 Co,, D"" o,~~1
u: $75.00 18.00 1._6.20 24_2~L 2.00 20.20 $48.80
3Horo'gn County eo,,, 3> Ad..nce eo." J6 Sc_~_: <;0;;01: ";,,., :~T~~::.?,;;j;",;;",,, :.~ ~_-- _--] ~ 101a1 C"'~J: Co" D"" 0' Re'"nO
- spA,NSWrR:
..10m (~I&ili~~I~:~:::T'~,,/: 9 ~~~~~~~~,,:1):;]~%lt~-?ji~ ...._,.==~~=--:-~=1;~-:~:~-~Lqi
42,ClalO1 . ",," la"c,~_'.. - COun', '''",,' ,/" ,
43---.L2", "I'''~', 'OIiJ' ~ ;,1. __ \,)}J.JNI, 1,1. jJ(EE, SIiLlHFF.____1 ....., J.~~S/99
Pmltl~ry~')' "'''' 1-4t-StQ'llIIlure orrQi-P,.tgn 1 'i\,l Oil'.
UY COUUIS$ION EXPIRES Ar ~_/;.1~.___J__J;'~I~!L1i~~_" 1 \
$0.1 ACKNOWlE.OGE REcCEIPT OF notE $H[RTf"-Ri."nJRH fHG,H1T\Jnf. ~11- Roc'flI\'O~
OF AUTHORIZED ISSUlNG A,lITHORITY ~N::> llTl [ __~_.__",._.._,,___...~._ _.___________~_
i ~ftOl't\f'; S C.t.t\i".HY. !;t'l~n'" Oftll.:C' .. Blue ' ~:.MIl"" onll'fl
1-:' /~,
~i- r./~c/'Jl,0
: ,:',",' ',,'..,~, ::," , ,'.-' ;,';. ,:,::: ." '~,) ,~:; '), ';;",~";~,:;::;,,,;:~j:'-i:),;:::;;,:.~~;",,\ :<;,:~-,~:,:::~",~,:::..:':," ~,L'<'::" :",~ ,: '~:',' ',':' .:> '.:,-:' ,~,; \ """ ':', :
'.' "
KLEHR, HARRISON, HARVEY, BRANZBURG & ELLEI~S LLf'
BY: Morton R. Branzburg, Esquire/Dimitri L. Karapclou, Esquire
I.D. Nos.: 24477/76708
1401 Walnut Street
Philadelphia, PA 19102
(215) 568-6060 A TTORNEYS FOR
PNC BANK, NATIONAL
ASSOCIATION
PNC BANK, NATIONAL ASSOCIATION:
1600 Market Street
11th Floor
Philadelphia, PAl 91 03
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff,
CIVIL ACTION - LA W
v.
NO. 99-2637
SHAHNA W AZ M. MATHIAS a/k/a
SHAH MATHIAS tla EASTERN
DEVELOPMENT and DESIGN
3255 Cape Hom Road
Red Lion. PA 17356
Defendants.
PRAECIPE TO MARK .JUDGMENT SATISFIED
" TO THE PROTHONOTARY:
Kindly mark satisfied the jUdgment entcred by confession in the above-captioned action on
May 3,1999 in the amount of$127.525.38.
\ _\ f/-' '\ UcU
Dated: It 0-
~. \~ r.
By::;fv')
~~
Dimitri L. Karapelou, Esquire
JI77K7/3~3QOI6