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Home My WebLink About03-3268MANUFACTURERS AND TRADERS TRUST COMPANY, SUCCESSOR BY MERGER TO KEYSTONE FINANCIAL BANK, N.A., Plaintiff R. E. GRANT COMPANY, 1NC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. C1VIL ACTION - LAW CONFESSION OF JUDGMENT CONFESSION OF JUDGMENT Pursuant to the authority contained in the warrant of attomey, the original or a copy of which is attached to the complaint filed in this action, I appear for the Defendant and confess judgment in favor of the Plaintiff and against Defendant as follows: Principal $49,203.24 Other authorized items: Interest to July 2, 2003 $ 5,434.85 Attorney's Commission $ 5~463.81 TOTAL $60,101.90 plus additional interest, and costs from the date of the Complaint. Date: July 2, 2003 Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY By: Su'p~me Cou~ ID #24848 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff MANUFACTURERS AND TRADERS TRUST COMPANY, SUCCESSOR BY MERGER TO KEYSTONE FINANCIAL BANK, N.A., Plaintiff R. E. GRANT COMPANY, 1NC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW CONFESSION OF JUDGMENT COMPLAINT FOR CONFESSION OF JUDGMENT UNDER RULE 2951 Successor by Merger to Keystone Financial Bank, N.A., The name and address of the Plaintiff is Manufacturers and Traders Trust Company, Pennsylvania 16601. 1331 Twelfth Avenue, Altoona, 2. The name and last known address of the Defendant is R. E. Grant Company, Inc. ("Defendant"), 342 Walton Street, Lemoyne, Pennsylvania 17043. 3. Defendant executed and delivered to Plaintiff a Promissory Note in the original principal amount of Fifty Thousand and 00/100 Dollars ($50,000.00) ("Note"), a true and correct photostatic reproduction of the origknal of which is attached hereto as Exhibit "A" and made a part hereof. 4. Defendant is in default of Defendant's obligations to make payment to Plaintiff as required in the Note, and Plaintiff has demanded payment in full of all outstanding amounts as provided in the Note. A copy of Plaintiffs demand is attached hereto as Exhibit "B" and made a part hereof. 5, with a consumer credit transaction. 6. There has not been any assignment of the Note. $50,000 Note ~ 10.75% Judgment is not being entered by confession against a natural person in connection Judgraent has not been entered on the Note in any jurisdiction. The amount due to Plaintiffas a result of Defendant's default is as follows: Principal Interest to July 2, 2003 Attorney's Commission TOTAL $49,203.24 $ 5,434.85 $ 5~463.81 $60,101.90 9. Interest continues to accrue at the rate of Eight and 88/100 Dollars ($8.88) per day as provided in the Note. WHEREFORE, Plaintiff, Manufacturers and Traders Trust Company, Successor by Merger to Keystone Financial Bank, N.A., demands judgment against R. E. Grant Company, Inc., Defendant, in the amount of Sixty Thousand One Hundred One and 90/100 Dollars ($60,101.90), plus interest at the rate of Eight and 88/100 Dollars ($8.88) per day, through the date of payment, including on and after the date of entry of judgment on this Complaint, and costs. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Date: July 2, 2003 By: hufCsquire St~'e~e Court ID #24848 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff $50,000 Note ~ 10.75% ~C~C_~/ -~-- PROMISSORY NOTE---~- '~' [ / I',: '~'~.'.+-Principa[!~":~,]~,'l~b~t~D~le~i ~:M~tdrlty'~ ,' ~'~;:~fl~No~.~h"~all~,' ].,,C~llat~': A~t~'~ :~,L'~',:~ PROMI~ TO PAY. R. E. Granl Compenv, t~c. ("Bo~rowe~"J ~oml~s lo ~ Io Farmers Ir~sl Company ("Lender"), or Order, I~ lawful of lh~ Unlled Steles of America, on demand, the principal amount of Filly Th~d & 0~100 Dollere ($~0,~0.~) o~ ~ much as may b~ jun i, ~007 ~:~- ~,, PROMISSORY NOTE Pag~ (ConUnued) OR CLERK OF ANY COURT IN THE COMMONWEALTH OF PENNSYLVANIA, O/~ rLSEWH~RE, TO APPEAR AT ANY TiME FOR BO,qROWER AFTER ATTOf~NEY*S COMMI~ION OF TEN PERCENT (T0%) OF TH~ UNPAID PRINCIPAL BALANCE AND ACCRUED INTERE,c~ FOR COLLECTION, ~ORROWER: Ros~ary E, Grant~r~e~ldent Jun.11, 2003 IO:04AM ~T BANK N's,8559 :, 2 Manufacturers and Traders Trust Company 1331 12th Avenue, Altocna, PA 16601 (814) 947-1924 Fax: (814) 947 1922 OCtO~ 9, ~2 Speci~ ~et~ Oepadment **~ORTCT NOTICE** VIA CERTIlqED MAIL Ms. Rosomary E. Grant RE Grant Co. Inc. 342 Walton Street Lemoyne, PA 17043-2026 Re: Account Number: Amount Due: 3966323017 Account Ntanber: $20,065.23 Amount Due: 198979~30012 $49,203,24 Account Number: Amount Due: 198979-30004 $49,293.06 Dear Ms. Grant: THE ABOVE ACCOUNTS ARE 1N DEFAULT due to payment delinquency, and the cessation of business and/or insolvency of RE Grant Co., Inc. These are events of default under the loan documents entitling the Bank to accelerate the indebtedness. Accordingly, Manufacturers and Traders Trust Company (M&T Bank) demands mediate and full payment of the above accounts. The amounts shown above must be fully paid in order to avoid M&T Bank commencing legal actions against you, RE Cmant Co., Inc., and/or all guarantors to recover the unpaid pt/nc/pal amount, s, plus all unpaid interest, costs and fees. In accordance with local Com-t rules, once any judgmcmt is on record for thrty (30) days, M&T Bank can request that the Sheriff levy on yom- property, or any other items of collateral, and thereafter conduct a public sale. Obviously, any legal acfi(m by the Bank would place your continuing ownership of real estate and/or other personal assets in significant jeopardy. Please telephone me if you have any question.s about M&T Bank's position in this Keith P. Mangan, Assistant Vice President /kpm MANUFACTURERS AND TRADERS TRUST COMPANY, SUCCESSOR BY MERGER TO KEYSTONE FINANCIAL BANK, N.A., Plaintiff R. E. GRANT COMPANY, INC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW CONFESSION OF JUDGMENT VERIFICATION I, Keith P. Mangan, Assistant Vice President, for Manufacturers and Traders Trust Company, successor by merger to Keystone Financial Bank, N.A., being author/zed to do so on behalf of Manufacturers and Traders Trust Company, successor by merger to Keystone Financial Bank, N.A., hereby verify that the statements made in the foregoing pleading are true and correct to the best of my information, knowledge and belief. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to author/ties. MANUFACTURERS AND TRADERS TRUST COMPANY, SUCCESSOR BY MERGER TO KEYSTONE FINANCIAL BANK, N.A. MANUFACTURERS AND TRADERS TRUST COMPANY, SUCCESSOR BY MERGER TO KEYSTONE FiNANCIAL BANK, N.A., Plaintiff R. E. GRANT COMPANY, iNC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW CONFESSION OF JUDGMENT ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of the undersigned on behalf of Manufacturers and Traders Trust Company, Successor by Merger to Keystone Financial Bank, N.A., Plaintiff in the above captioned matter. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Date:3k[~ c~x ~03 By: Supreme Court ID #24848 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff $50,000 Note @ 10.75% MANUFACTURERS AND TRADERS TRUST COMPANY, SUCCESSOR BY MERGER TO KEYSTONE FINANCIAL BANK, N.A., Plaintiff R. E. GRANT COMPANY, INC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW CONFESSION OF JUDGMENT CERTIFICATE OF ADDRESSES I hereby certify that the precise address of Plaintiff, Manufacturers and Traders Trust Company, Successor by Merger to Keystone Financial Bank, N.A., is 1331 Twelfth Avenue, Altoona, Pennsylvania 16601; and that the last known address of the Defendant, R. E. Grant Company, Inc., is 342 Walton Street, Lemoyne, Pennsylvania 17043. Date: 3tx~ Respectfully submitted, SA/DIS, SHUFF, FLOWER & LINDSAY By: ~~sq Ge uire Supreme Court ID #24848 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff $50,000 Note ~ 10.75% MANUFACTURERS AND TRADERS TRUST COMPANY, SUCCESSOR BY MERGER TO KEYSTONE FINANCIAL BANK, N.A., Plaintiff R. E. GRANT COMPANY, 1NC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW CONFESSION OF JUDGMENT NOTICE TO: R.E. Grant Company, Inc. Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a JUDGMENT BY CONFESSION has been entered against you in the above proceeding and that enclosed herewith is a copy of all the documents filed in support of the said judgment. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: GEOFFREY S. SHUFF, ESQUIRE TELEPHONE NUMBER: (717) 737-3405 ~-~/5~ro~hthonod°~gg~a~ '&