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ALLFIRST BANK, SUCCESSOR TO IN THE COURT OF COMMON PLEAS OF
DAUPHIN DEPOSIT BANK AND CUMBERLAND COUNTY, PENNSYLVANIA
TRUST COMPANY
CIVIL ACTION - LAW
Plaintiff J,
NO. 99-
v.
LOJAN ASSOCIATES
Defendant
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, you must take action within twenty (20) days after this Complaint and
notice are served, by entering a written appearance personally or by attorney and filing in
writing with the Court your defenses or objections to the claims set forth against you. You are
warned that if you fail to do so the case may proceed without you and a judgment may be
entered against you by the Court without further notice for any money claimed in the Com-
plaint or for any other claim or relief requested by the Plaintiff. You may lose money or
property or other rights important to you.
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.
C? , 4a . Dd2 /YSS'ocl??
rthzuse a Aoc_
Carlisle, Pennsylvania 17013
(7=P40_6200_ 717- -19F-,ML
KEEFER WOOD ALLEN & RAHAL, LLP
Date: July 23 , 1999 By:
Eugene epinsky, Jr.
Attorney I.D. #23702
210 Walnut Street
P.O. Box 11963
Harrisburg, PA 17108-1963
(717) 255-8051
ALLFIRST BANK, SUCCESSOR TO
DAUPHIN DEPOSIT BANK AND
TRUST COMPANY
Plaintiff
V.
LOJAN ASSOCIATES
Defendant
CIVIL ACTION - LAW
NO.
1. Plaintiff Allfirst Bank, successor to Dauphin Deposit Bank and Trust
Company, is a Maryland state-chartered commercial Bank, with an office at 213 Market
Street, Harrisburg, Pennsylvania 17101.
2. Defendant Lojan Associates is a partnership, whose last known address is
1515 Slate Hill Road, Camp Hill, Pennsylvania 17011.
3. On or about April 20, 1987, Defendant, for good and valuable
consideration, executed and delivered a Promissory Note (the "Note") to Plaintiff. A
true and correct copy of said Note is attached hereto, made a part hereof and marked
Exhibit "A".
4. The Note referred to in Paragraph 3 above has not been assigned by
Plaintiff to any person or organization.
5. Judgment has not been entered on the Note referred to in Paragraph 3
above in any jurisdiction.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
6. The Note is in default.
7. The current unpaid principal amount of the Note is $135,848.09.
8. Accrued interest to date is $6,698.19.
9. In addition to principal and interest, Plaintiff is entitled to an attorney's
commission of fifteen percent (15%) on the unpaid principal sum and costs of suit by
reason of Defendant's default.
WHEREFORE, Plaintiff demands judgment against Defendant in the sum of
$162,923.46, together with costs of suit.
KEEFER WOOD ALLEN & RAHAL, LLP
Date: July? '1999 By:
210 Walnut Street
P.O. Box 11963
Harrisburg, PA 17108-1963
(717) 255-8051
Attorneys for Allfirst Bank
-2-
The undersigned Kenneth L. Milliken, hereby verifies and states that:
1. He is Assistant Vice President of Allfirst Bank, Plaintiff herein;
2. He is authorized to make this Verification on its behalf;
3. The facts set forth in the foregoing Complaint are true and correct to the
best of his knowledge, information and belief; and
4. He is aware that false statements herein are made subject to the penalties
of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities.
'Kenneth L. Milliken
Dated: July z 3 , 1999
May•.17-99 10:32A
P. W!
Manpowe bond to o Couvrailon-SeL Pa. Ina., Eta. No. 562A
XnaW all Mtn bu t4por f reopnts
043t LOYAL F. OSTERLUND and JAN A. OSTERLUND, t/d/b/a LOJAN ASSOCIATES, a
Partnership
1"hi and JFmy bound unto DAUPHIN DEPOSIT BANK AND TRUST COMPANY
a Corporation duly organised. Incorporated and now exdaina under and in accordance with the Jv..•,, of thv Seat,
of Penatylvanla, In the sum of FIVE HUNDRED FORTY THOUSAND AND N0/100-------------------
-- ------------- ----($540,000.00) Dollars, lawful money, to be pad to thr wid Obligee ,
its smocevorr or awlgtu.
To which payment well and truly to be made by it do es
and each and "try of then, firmly by these presenu. , ,
Seeded with its real . Dated the 0' day of April
in the year of our Lad Nineteen Hundred and eighty-seven (1987)
AIR f6aabttlan of 14in IOblion lan Is suth. That if the add Oblittar , its
helm, executors or administrators shall and do well and truly pay. fir cause to he paid unto the said Ob Ar,, ,
.rurr•eeMrt of avlgas, the sum o1 Five Hundred Forty Thousand and no/100 ($540,000.00)
Dollars, lawful money of the United Statec of America, within fifteen (17)
years from the data hereof, with interest at a rate equal to Dauphin Deposit
Bank's National Base Rate, plus one (12) percent per annum, to be adjusted
when said Base Rate changes. Adjustmenra wi11 he made on tho first day
of the month following any change in said Base Rate. BEGINNING on the
first day of May, 1987, and on the first day of each succeeding month,
the Obligor shall pay the sum of Five Thousand Nine. Hundred Sixty-nine and
no/100 ($5,969.00) Dollars, which shall be applied first to the payment of
the interest then due at the then applicable rate and the balance of tha
payment shall be applied on accotmt of the principal debt. In the event the
aforesaid monthly payment is not sufficient to pay the interest due for any
month, the interest must be paid and an adjustment in the monthly payment
will be made for future payments.
bind itself, its
helm, e.ceetttors and adminlctraton•
Its
,May-17-99 16:32A
P. O'2
Mortgage Bond so a Corrorallon-Sal. Pa Itu., Eta No. 562A
maw all Mtn by thror 'Presputs
04at LOYAL F. OSTERLUND and JAN A. OSTERLUND, t/d/b/a LOJAN ASSOCIATES, a
Partnership
hrhl and firmly bowl wrw DAUPHIN DEPOSIT BANK AND TRUST COMPANY
u Corporation duly organised, Incorporated and now exlnlns undo and In oecordaux Ielrh the la„•x of the slat,
of Peansy)vanla, U /1tc sum of FLVH HUNDRED FORTY THOUSAND AND N01100-------------------
----------------(1}540,000.00) Dollars, lawful money, to be paid 10 thr• said ObAsIf ,
its succaVOrt or assiM.
To which payment, well and truly to be made by it do es bind itself, its
heirs, e.rrnuon and admtnlaraton•,
and each and every of them, firmly by them presents. , ?
Sanded with its seal , Dated the 19 i day of April
in the year of our Lord Nineteen Hundred and eig ty-seven (1987)
4148 a ctobttlas of ibis (ohltoalton to such. Thar If the said Oblism , its
heirs, executors or adminbtn ors shall and do well and truly pay, or sure to be paid unat the said Ohliprr , itt
xurressnrs or aides. the sum of Five Hundred Forty Thousand and no/100 ($540,000,00)
Dollars, lawful raunuy, of the United Statue of America, within fifteen (15)
years from the dare hereof, with interest at a rate equal to Dauphin Deposit
Bank's National Base Rate, plus one (1T) percent per annum, to be adjusted
when said Base Rate changes. Adjustments w•111 bt• made on the first day
of the month following any change in said Base Rate. BEGINNING on the.
first day of Hay, 1987, and on the first day of each succeeding month,
the Obligor shall pay the sum of Five Thousand Nine Hundred Sixry-nine and
no/100 ($5,969,00) Dollars, which shall be applied first to the payment of
the interest then due at the then applicable rate and the balance of the
payment shall be applied on account of the principal debt. In the event the
aforesaid monthly payment is not sufficient to pay the interest due for any
month, the interest must be paid and an adjustment in the monthly payment
will be made for future payments.
and also violl pay the tares, keep the buildings upon the land dearibed in the Mortgage amarapanying this bo ab
insue d Air the hrnefi: at the Morle4w.r:, to Ae amour, rlai!ean --- ----Five 3uldrM Forty Thcusditd
and no/100 ($340,000.00)------------- --------- Minn and take our an Insurance
au .void huddiogv run marked for the benefit of the Mortgagee, :hen the abave Oblkation to be void, or the to be
turd resnuiu try full funs and rintm. AND the Loden Condition vI this ObllRatirm It such that If at any tlmr drpnilt
,half he oxide in the faUvnent of the princirml or the
inn•rrrr as alorexald. for the .xpaee of thirr v
,eat. uftrr arks' pa!x'namt thrmal shall fall due, or if a hreach of any other of the foregoing tvididnar be math ly the,
said Obligor . turd the mid prineiryrl sum shall become dur, and payment of the rarer n•ith haerni, tares and
coma, ul hma turre due thereon, as afarr.atd nogether with an Anornry''s Gomminlan of 1-?3 percent. an the
said principal cant berhlex Caws of stilt, mm bn enforced and recovered at once.
:ktlh lfairihrr do es hereby empower ony Allarney to appear for it
and enrt4ax lodgment againa it In lasor of the above mentioned Obl4:ee
it, wit-revvox ar arsigns and agabul ................ ........................................................................................................................
far the prowl stun above nteolloned, with Cori, 0 wit. "Aing xhrv of eserution, inqubirion and all exemption Inws.
wad Ohligor lurflor q,•rer a that lie Laid real estate intr be
sold upon a Mrd 3f:IClnu .,
AS4?/IATii
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R-96% 05-17-99 10:37AM P002 #18
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C, z? g C
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-04485 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ALLFIRST BANK ET AL
VS.
LOJAN ASSOCIATES
CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within NOTICE AND COMPLAINT was served
upon LOJAN ASSOCIATES - the
defendant, at 15:49 HOURS, on the 29th day of July
1999 at 1515 SLATE HILL ROAD
CAMP HILL, PA 17011 CUMBERLAND
County, Pennsylvania, by handing to JAN OSTERLUND (OWNER)
a true and attested copy of the NOTICE AND COMPLAINT
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 18.00
Service 8.68%%??4 / P
Affidavit .00 Es ??
Surcharge 8.00 R:' omas inef S e i
$-34.b e KEEFE WOOD, ALLEN & RAHAL
07/30/1999
by
epu y ri
Sworn and subscribed to before me
this 30 P-- day o
1999_ A.D.
T Fro onotar,
ALLFIRST BANK, SUCCESSOR TO
DAUPHIN DEPOSIT BANK AND TRUST
COMPANY
Plaintiff
V.
LOJAN ASSOCIATES
Defendant
To: LOJAN ASSOCIATES
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-4485 Civil Term
You are hereby notified that on September /3 `? , 1999, the following Judgment has been
entered against you in the above-captioned case.
By default in the sum of $162,923.46, with
interest and costs of suit.
DATE: September /3'- , 1999
Urar.: /C aLo" h=`
Prothonotary 11
-
I hereby certify that the name and address of the person(s) to receive this notice is:
Lojan Associates
1515 Slate Hill Road
Camp Hill, PA 17013
KEEFER WOOD ALLEN & RAHAL, LLP
By:
Eugene E. P J .
Attorney No. 370
210 Walnut Street
P.O. Box 11963
Harrisburg, PA 17108-1963
(717) 255-8051
Attorney for Plaintiff
ALLFIRST BANK, SUCCESSOR TO
DAUPHIN DEPOSIT BANK AND TRUST
COMPANY
Plaintiff
V.
LOJAN ASSOCIATES
Defendant
To: Curt Long, Prothonotary:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-4485 Civil Term
Please enter judgment in favor of Plaintiff and against Defendant by default in the sum of
$162,923.46, with interest and costs of suit, for Defendants failure to answer or otherwise plead
to Plaintiffs Complaint. I hereby certify that written notice was given Defendant in accordance
with Pa. R.C.P. 237.1 (copy attached).
Dated: SeptemberlD , 1999
KEEFER, WOOD, ALLEN & RAHAL
Attorneys for Plaintiff
210 Walnut Street
P. 0. Box 11963
Harrisburg, PA 17108-1963
717-255-8051
ALLFIRST BANK, SUCCESSOR TO
DAUPHIN DEPOSIT BANK AND
TRUST COMPANY
Plaintiff
V.
LOJAN ASSOCIATES
Defendant
TO: LOJAN ASSOCIATES
DATE OF NOTICE: AUGUST 26, 1999
V
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-4485 Civil Term
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM
THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT 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.
COURT ADMINISTRATOR
4th Floor, Cumberland County Courthouse
Carlisle, Pennsylvania 17013
(717) 240-6200
Dated: August 26, 1999
KEEFER WOOD ALLEN & RAHAL, LLP
By: ??
Eugene . epinsky, Jr.
Attorney No. 23702
210 Walnut Street
P.O. Box 11963
Harrisburg, PA 17108-1963
(717) 255-8051
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ALLFIRST BANK, SUCCESSOR TO
DAUPHIN DEPOSIT BANK AND
TRUSTCOMPANY
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-4485 Civil Term
V.
LOJAN ASSOCIATES
Defendant
TO THE PROTHONOTARY:
Please mark this judgment "satisfied" by order of the Plaintiff.
KEEFER WOOD ALLEN & RAHAL, LLP
Date: June 27, 2000 By: L
Eugene E. pi sky, Jr.
Attorney No. 23702
210 Walnut Street
P.O. Box 11963
Harrisburg, PA 17108-1963
(717) 255-8051
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