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Home My WebLink About99-07513I No. civil Term Ii 3 VS. I court of common Pleas Cumb. Co. I 4 1 , , I , ? .Y , i LJ f ? S 1 IJ 1 It y S 1?? 4 1 r I f, r i ,? I GRAND TREE FARMS INC. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO.99 - rl,55'13 C; v't L KATHLEEN C. DATOLO Defendant PRAF.CIPE TO ENI .R i ID =MENT Please enter judgment in accordance with Pennsylvania Rule of Civil Procedure 2951(a) against Kathleen C. Datolo in the amount of $1,943.64. In support of this praecipe, please find the following documents: I. The original Judgment Note signed by Defendant with warrant of confession; 2. An affidavit that the judgment is not being entered by confession against a natural person in connection with a consumer credit transaction; and 3. A certificate of residence of both Plaintiff and Defendant. Respectfully submitted, REAGER & ADL-ER, P Date: December 15, 1999 THOMAS 0. WIELIAMS, Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011-4642 (717) 763-1383 Attorney for Plaintiff .U GRAND TREE FARMS INC. V. KATHLEEN C. DATOLO : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. Defendant NOTICE TO: Kathleen C. Datolo You are hereby notified that on December 15, 1999, judgment by confession was entered against you in the sum of $1,943.64 in the above-captioned case. DATE: 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717/249-3166) I hereby certify that the following is the address of the Defendant stated in the Certificate of Residence: 1101 Rana Villa Avenue Camp Hill, PA 17011 THOMAS O. WILLIAMS, Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011-4642 (717) 763-1383 Attorney for Plaintiff GRAND TREE FARMS INC. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. KATHLEEN C. DATOLO Defendant TO: Kathleen C. Datolo Por este medio sea avisado que en el quince dia (15) de Deciembre 1999, un fallo por admision fue registrado contra usted por la contidad de $1,943.64 del caso antes escrito. DATE: PROTHONOTARIO LLEVA ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENNE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SEVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIDRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717/249-3166) Por este medio certifico que to siguiente es la direccion de demandado en el certificado de residencia: 1101 Rana Villa Avenue Camp Hill, PA 17011 THOMAS 0. WILLIAMS, ESQUIRE Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011-4642 (717) 763-1383 Attorney for Plaintiff d16grnndo6Wa1o1o.not October4. 1999 51,927.80 eo*? el?) . #4? r'w,? October 1, 1999 FOR VALUE RECEIVED, the undersigned promises to pay to the order of GRAND TREE FARMS, INC., 300 Hummel Avenue, Lemoyne, Pennsylvania 17043, or at any other place in the Commonwealth of Pennsylvania that any holder of this Note may designate in writing the sum of ONE THOUSAND NINE HUNDRED TWENTY-SEVEN DOLLARS AND EIGHTY CENTS ($1,927.80) including interest from the date above written until paid. This Note is given in recognition of and to satisfy an outstanding obligation consisting of back rent, late charges, and water and sewer charges for property located at 1101 Rana Villa Avenue, Camp Hill, Pennsylvania 17011. Failure to pay any part of the principal or interest of this Note when due shall authorize the holder of this Note to declare it immediately due and payable, the then unpaid principal and to exercise any and all of the rights and remedies provided by the Uniform Commercial Code of Pennsylvania as well as all other rights and remedies either at law or in equity possessed by the holder of this Note. If this Note is placed in an attorney's hand for collection, or collected by a suit or through a bankruptcy, probate or other court proceeding, either before or after maturity, there shall be paid to the holder of the Note reasonable attorneys' fees, costs and other expenses incurred by the holder in enforcing the terms of this Note. Makers, signers, and endorsers of this Note severely waive demand, presentment, notice of dishonor, diligence in collection and notice of protest and agree to the extensions and partial payments before or after maturity without prejudice to the holder. The undersigned hereby authorizes and empowers, irrevocably, the Prothonotary or any attorney of any court of record of the Commonwealth of Pennsylvania or elsewhere to appear for me at any time, enter judgment without process against me, 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 execution upon any property, real, personal, or mixed, and do hereby voluntarily condemn same, and no bill in equity or other petition shall be filed to interfere in any manner with the operation of the 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. dl&gr ndonWatolo.not Oalober4, 1999 Witness: COMMONWEALTH OF PENNSYLVANIA COUNTY OF Maker: Kathleen C. Datolo I 101 Rana Villa Avenue Camp Hill, PA 17011 SS. On this day of October, 1999, before me, a notary public, the undersigned officer, personally appeared KATHLEEN C. DATOLO, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Note and acknowledge that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set me hand and official seal. NOTARY PUBLIC ..zero dlblgrandonidalolo.not October 4, 1999 EXPLANATION OF RIGHTS A. I clearly and specifically understand that by signing a Note dated October 1, 1999, in the amount of $1,927.80 payable to Grand Tree Farms, Inc., which contains a Confession of Judgment Clause: 1. I will authorize Grand Tree Farms, Inc., Plaintiff (Creditor) to enter a judgment against me in its favor which will give the Plaintiff a lien upon any real estate which I may own, including my home; 2. I will give up the right to any notice or opportunity to be heard prior to the entry of this judgment on the record of the court; 3. I will agree that Grand Tree Farms, Inc., Plaintiff (Creditor) can enter this judgment without any proof of nonpayment or other default on my part; 4. I will subject all of my property, both personal property and real estate, to execution (and Sheriff); pursuant to this judgment, prior to proof of nonpayment or other default on my part; 5. I will be unable to challenge this judgment, should the Plaintiff enter it, except by a proceeding to open or strike the judgment; and such a proceeding will result in attorney's fees and costs which I will have to pay. B. I know and understand that it is the Confession of Judgment clause in the above- described note which gives Plaintiff the rights enumerated in subparagraph 1 through 5 of Paragraph A above. The right to have notice and an opportunity to be heard prior to judgment; 2. The right to have the burden of proving default rest upon the Plaintiff before my property can be exposed to execution; and 3. The right to avoid the additional expense of attorney's fees and costs incident to opening or striking off confessed judgment. ?? dlb%graridoMdalolo.not October 4, 1999 C. FULLY and completely understanding these rights which I have prior to signing the above-described Note, and clearly aware that these rights will be given up, waived, relinquished and abandoned if I sign the Note, I nevertheless freely and voluntarily choose to sign the Note, my intention being to give up, waive, relinquish and abandon my known rights (as described in Paragraph B above) and subject myself to the circumstances described in Paragraph A above. D. The undersigned hereby certifies that I, signatory to a Note, dated on the 1st day of October, 1999, in favor of Judgment clause entered, I have earnings of $10,000.00 or more per year. WITNESS: I HAVE READ THIS ENTIRE FORM AND I FULLY UNDERSTAND ITS CONTENTS Kathleen C. Datolo Swom to and subscribed before me this day of October, 1999. Notary Public GRAND TREE FARMS INC. V. KATHLEEN C. DATOLO : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Defendant . NO. Commonwealth of Pennsylvania ) County of Cumberland ) SS: I, RAYMOND C. GRANDON, JR., being duly sworn according to law, hereby state that the judgment being entered by confession is not being entered against a natural person in connection with a consumer credit transaction. RAYMOND C. GRANDON, JR. Sworn to me this Lfm-day of 1999. AIlrr(.f -bdeIV17(t Notary Public taotanal Seal Lon A. gichard. Notary Public Camp Hip BorC. Cumburlano Cuumy My COmm;ssirn E.pin3:; Oct 70ni ?l1dmrn:r rnm!svivan;a 45stKaapor?„I __J rlgi,i q;;p GRAND TREE FARMS INC V. KATHLEEN C.DATOLO To the Prothonotary: : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. Defendant The address of the Plaintiff, judgment creditor, is 300 Hummel Avenue, Lemoyne, Pennsylvania 17043, and the last know address of the Defendant, judgment debtor, is 1101 Rana Villa Avenue, Camp Hill, Pennsylvania, 17011. REAGER & Date: December 15, 1999 v Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 170114642 (717) 763-1383 Attorney for Plaintiff EEEVe9L (LILT ZPWIML Vd'IIIH dVYVD 133USANIM LEEZ MVl IV SA3NNOILV 'Od'8310V V 1130 V i S