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HomeMy WebLinkAbout99-07679 r ti i. --- No. 94.76>r Civil Term vs. . ?v, Court of Common Pleas Cumb. Co. r? I ?I 1 1 I i r i KEYSTONE FINANCIAL BANK N.A. IN THE COURT OF COMMON PLEAS Plaintiff COUNTY OFCUMBERLAND COMMONWEALTH OF PENNSYLVANIA VS. CIVIL ACTION LAW KATHLEEN W. LOSCHER EDWARD A. LOSCHER Defendants CIVIL TERM 1999-%7? CONFESSION OF JUDGMENT Pursuant to the Warrant of Attorney contained in the aforementioned Commercial Guaranty, the original or copy of which is attached to the Complaint filed in this action, I appear for the Plaintiff and confess judgment in favor of plaintiff and against the Defendants, Kathleen W. Loscher and Edward A. Loscher, as follows: Principal $ 212,990.99 Interest to 6-10-99 $ 11,247.17 Attorney's Fees $ 22,423.82 TOTAL $ 246,661.98 with interest from June 10, 1999, on the principal sum of $246,661.98 at the rate of 9.50 % per annum. Respectfully submitted, Duncan & Hartman, P.C. Dated: BY: William A. Duncan, Esquire PA ID # 22080 Attorney for Plaintiff KEYSTONE FINANCIAL BANK N.A. Plaintiff VS. KATHLEEN W.LOSCHER EDWARD A. LOSCHER Defendants IN THE COURT OF COMMON PLEAS COUNTY OFCUMBERLAND COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION LAW CIVIL TERM 1999- COMPLAINT FOR JUDGMENT BY CONFESSION PURSUANT TO PENNSYLVANIA RULES OF CIVIL PROCEDURE 2951, ET SEQ. Plaintiff, Keystone Financial Bank, N.A., by its attorney, William A. Duncan, files this Complaint in Confession of Judgment. 1. Plaintiff, Keystone Financial Bank, N.A., is a Pennsylvania banking Corporation existing under the laws of the Commonwealth of Pennsylvania, with its principal place of business located at 1415 Ritner Highway, Carlisle, Cumberland County, Pennsylvania. 2. Defendants are Kathleen W. Loscher and Edward A. Loscher, with a last known address of 39 Greenspring Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. On or about July 27, 1998, Defendants Kathleen W. Loscher and Edward A. Loscher, entered into a Commercial Guaranty in favor of Plaintiff, Keystone Financial Bank, N.A., in the original principal amount of Two Hundred Thirty Thousand and 00/100 ($230,000.00) Dollars. A true and correct copy of the Guaranty, which contains the Warrant of Attorney upon which this judgment is confessed, is attached hereto as Exhibit "A" and is a part hereof. 4. Defendants Kathleen W. Loscher and Edward A. Loscher, have defaulted in this obligation under the Guaranty by failing to make their June 1999, July 1999, August 1999, September 1999, October 1999, November 1999 and December 1999 payment of principal and interest due thereunder. 5. Pursuant to the Guaranty, judgment may be entered against Defendants Kathleen W. Loscher and Edward A. Loscher, for all monies due without notice or demand. 6, Pursuant to the Guaranty, and by reason of Defendants Kathleen W. the following amounts Loscher and Edward A. Loscher's default, , by Kathleen W. Loscher and Edward A. owing Plaintiff Keystone Financial Bank, N.A., by Loscher, Defendants. $ 212,990.99 Principal Amount due to date: Interest Accrued and unpaid $ 11,24717 through June 10, 1999 Attorney's Fee's pursuant $ 22,423.82 to the terms of the Note TOTAL $ 246,661.98 Interest accrues at a rate of $ 56.21 for each day after June 10, 1999 that this indebtedness remains unpaid. In an event of a petition to strike or open this judgment is filed. Plaintiff Keystone Financial Bank N.A., reserves the right to have interest and attorney's fees brought current. 7. There has been no assignment of the Guaranty. 8. Judgment has not been entered on the Guaranty in any other jurisdiction. 9. Pursuant to the Guaranty, $ 246,661.98 is currently due and owing Plaintiff Keystone Financial Bank, N. A. from Defendants Kathleen W. Loscher and Edward A. Loscher, and Defendant Kathleen W. Loscher and Edward A. Loscher, have failed to pay the amount due. WHEREFORE, Plaintiff Keystone Financial Bank, N.A. request that judgment be scher and Edward A entered in its favor and against Defendant Kathleen W. Lo. Loscher, in the sum of $ 246,661.98 and all costs of suit. Duncan & Aartman, P.C. DATED: ??,???-?j \ By Vyillism A. Duncan, Esquire Attorney for Plaintiff ann m,RCf9?R4JAS1 " CERTIFICATION OF COMMERCIAL TRANSACTION I, Jack V. Hutchison, hereby verify that I am an Asst. Vice President of Financial Trust Company, and, as such, duly authorized representative of Financial Trust Corporation deposes and says subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities that the underlying transaction relative to this Complaint in Confession of Judgment is a commercial transaction to the best of his knowledge, information and belief. Asst. Vice President Financial Trust Company VERIFICATION I, Jack V. Hutchison, hereby verify that I am an Assistant Vice President of Financial Trust Company, that I make this verification being authorized to do so, and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. ack V. utchison Asst. Vice President Financial Trust Company 241-0060 FINRNCIRL TRUST 914 P03 DEC 16 '99 12:34 COMMERCIAL GUARANTY Ballet Etc., Inc. 1:206 Simpson"Road Mechanicsburg, PA 17065 This is a gum" of Payment of the Mole, including without limltallen the principal Note amount of Two Hundred AMOUNT OF GUARANTY. Thirty Thousand A boltaa Goiters (Sa,o0011e). absolutely and United letes of schar and Edward GUARANTY. For good and valuable Cons deratitioon, VJMle artcial Torusl Company f•Lender) or Its (order, n1 tlegal legal tender 0tend Of athe nited SlUan Y guarantee and promise to pay, loamy Amrrlka the Indebtedness (as that 20Is defined below) of Sane Etc, Inc, f•BOrrower'y to Corder on the terms and conditions sal forth In this Guaranty. ni when used in This Guaranty: DEFINITIONS. The following wads shall have Ire following mate nos this GuamnH jointly and severally. Sommer. The word'Bonowor mean Ballot Etc., Inc.. Guarantor. The word'Guarantce means Nalhleon W. Losccer and Edward A. Loscher, who are signing Guarantor Guaranty, The word'GuaranW means the Guaranty made by or for the benefit of Lander detOd Jury 27,1998. Indebtedness. The word'Indablodrimo means the Note, Inducing (a) all principal, (b) an Interest (a) all late charges, (d) all loan leas and loan charges, and (e) all collection costs and expenses rattling )o the Note or to any oollaterel for the NOW. Collection costs and expanses includis Zees and Landars lagal expenses, whetter or not suit is instituted. and adornoys' flas and Waal oxpensos (including eeons to modify or vacate. any automatic stay or Injunction), appeals, and any anticipated forgbank ruPkY proceedings f ttornoys' post-judgment collection servIces• Lender. The word 'Lander' moans financial Tent Company, its successors and asSIgns• In the original principal amount of $7Ja,0ab as Note. The word'NoW means the pronxssory note at ouch agreement dated July 27, 1998 from Borrower to Lender, together with an ranawals of, adonstars of, modifications of, refinancings of, consolidations of, and substitutions for the promissory note or agreement. notes, cradd agreements, town Related tlocgmlron Tie words 'Reeled Documents" security mean agrreements mat9ag xi. d0ads o truall st, and all anon instruments, agreements and promiss agroont anents , bather now agreements, m guarantim r.2. as exis in tog tlnx;uments. whemer now or hafe9aar alesrn4auWd in connection with the Indebtedness. no time the emounl at the MAXIMUM LIABILITY. The maximum IlWuty of Guaramor under. this Guaranty shall not exceed at any o Inaebledneaa described above, plus an costa and expenses of (a) enforcement of this Guaranty and (b) collection and sale of any collateral securing this Guaranty. of Borrower to Lander either In the aggregate or at any one rime, The above limitation on liability is ante restriction on the amount of the Indebtedness the Ids of ar under all guaranties additional from Guarantor, If Lender upresently mula holds one or Maio s gum specifically piovided below to the contrary) Hoot or Invalidate any such other guarantles. The unlarminstod d e, guaranNa. the aggregate not ot (unless spedsWN P shay be cumNao. This Guaranty of oaniar liability of Guarantor Wyl be the agotOgalo liability of Guarantor under the terms of this and Guaranty any such other OF Guarantor kftld3 tae At an times the,ParW= m Ito romptAnp section a 1du Guaranty. The only or i of NATURE o GUARANTY. r other sse. o aablodam within the omits set foM of Guarantors, or ?mt all by reason of all b eation or otherwise. ri alit any of the Guuanlom IndividuayY, 3411115t arty Group this Guaranty. Ira Guaran shwa be jdnt and ? euecang the right L Lander to proceed ageinsVolher Guarantors for amoumS that are covered by Lendea my action. An Guarantors In one to proceed agalmt any Guarantor (whether ausad by actions of a Guarantor or of Lander) will not ~ Londeh right to 0110 yl?f? I or partol Ire arranints i;tivO(eCI by this Guaranty. MY eed against of Landon to P Lander, or any notice OF any or DURATION OF effect when reaatved by Lander without the necessity of any acceptance by GUARAanNTY. remaining and a continue in full force until al Indebtedness shall have been fully and finally paid and satisfied and an ouwr pURAT W Gubran o or to Borrower, stag have been performed in full. Raloase of any other aguarantor or le"in nany onertinatlOn Or of mny any othOthGuarantorguaGuarantguaranty of stag van rulers of ess slid or under rain 2k11 Guarantor under this Guaranty. A rV0callon received by Lender fro affect e t the li b an shat) any rvmanbg Gparardors etloct trio I a of under tine Guaranty. G afloat the IS A T to Borrower, to itties . DARAU Under is GU =ty. ONTO LENDER, Guarantor (1) o 4141106:013 Ofonder. without l notice S =red demand Csaw without U 0 "M leaInp i atfu ds liability under antity, from mdine eto grna: (is to make e one of morn additional Sommer or () to act", of compromise, renew, wida the •...inc(utli ld, aqu(pmenl or other this Qu gouda to Sommer. r, or t otherwise to p or o? ems of the inebledrless or any, pmt rat times lee time for for ayment raff bit Melded and may be for kuW then )bit. sceudlnghrramea t ate, or oBla ar and M°rea Onto or ffwb times Onc) to tetra a ke and f ti hom eb cad security of N Interest Bit on sathe cr enant ofle h Guaran°fthe I nOWtedness, and excha nga, amerce, waive, -..::• nd relo original loan land; (c) such aeeuriH, with or wldwul the substitution of new Wlla}arM; (d) to ease, one or more of eomower'a surelles, endorsers, or other guarantors on Only terms at to arty cub near te, Tall or dato take not M paled, and ra>aad0 any am credits elan be made on the Indebladnsss: glbebtute, cocoa not to sue, of deal with any manner Lender may choose (s) to detarntrte how, when and what applk2bon of paYnun to of Sale thereo , including n fwnr udkJal cola permitted by the may fm tow any delonalnel (a) to sell, transfer, assign, or graft IA to apply ouch cecudH and dhat the or order or deed of trl manner at. ad Lender f In Its without terms of the controlling security faagreement . and (h to nation participations In all at Fry pad or rimester this Guaranty In WNW of in Part GUARANTOR'S tion ts mREPRFSI37TATIONS AND WARRANTIES., Guarantor represents and warrants to fended that (e) no representations or agreements for which would limit or quality In any way the Wrens of this Guli (b) his a the nrielted at f of any kind hew boon madam requestof Lender. (c) Guarantor has full power, right and authority to enter I?his are ant ; (duh r a i do not res In olation o: Gusions at this Guar request and not at ith ornragUeu . e aoment or other. instrument bindng upon aranty da not corselet deem or order app U under any aGuarantor its not and will not without the prior wriden consent of Lender, of any tow, rogWtlon, eoun decree Ilublo to Guarantor,, (e) and Edward A. Losenar Ka G Guarallt ir: lem W-1-Ocrhre nit t-mcc 241-0060 FINRNCIFL TRUST 914 P04 DEC 16 199 12:35 Page 2 COMMERCIAL GUARANTY G7-27-1998 ,w,,.d„• in titan ,ncumber, hypothecate, transfer. or otherwise dispose of all a Substantially all of uaran s Sea, base, Assign, , and all such financial InfOrmallon Uest Guarantor will provide to Lander financial and credo information in lam dd tablo to Lander Lertdars roq Information which wA be provided to Lender is a^ drud will be true and correct in all material raspacb an which rosordMhas been, and all Future financial ,on is ts provided provided; (p) no mah'ral addve oe schange imilar acon Qrlduding currey In Us cocurrod ddAY Present rho financial Condition of Guuanfa AS Of the dates Ina Anandal Infamen fmancwl conditon; (h) no litigation, claim, investigation, administrative pracee g Guarantees financial condition since the data of dM most recent firgneW?t?has made Flo rapresentatl0o to GWralrtOrna9 to the acttwathcludin materially r adversely sraut e for ) agakst oonawor on a continuing bas's imolrmiahon regarding gon,wer's unpaid In In aftoct Guar Guarantor ; pending or mrealar ed; p) . . thho eonawor; and g) Guarantor hits arlabl'uhad adoQmIO rearms of OMOrrurq from financial canditlon. Guarantor agrees to ketato adequdOb informed ham such means of any facts. events, or m7mrm5tane°S which might many w igatian aMOet Guarantees risks under this Guaranty, and Guarantor further agrees that Lander shag have no Ob to dstlose to Guarantor any kmfarmagAn of documents acquVed by LOndef in the course of its relationship with Borrower. t as rohiblad by APPticable law, Guarantor waives any right to require Lander (a) to oonfinuo lending !Honey or to extend other GUARANTOR'S credit WA to Bomma; to BOO Fxep (b) to P Flake 0nY press demand, or nallico of any load, including notice of any nenpaymeat Of the da al. o^t, pmlret. Indebbl tedness o err r of el arty nonpayment related to any collateral. or nodes d any action a nOnaddlon on tno pan at Bedewed, Under, any surety, endorser, u any a or outer guarantor In connection will the Indebtedness of in connOChon with trio creation of claw Or additional loads or obligations: (c) to Faso or payment or to proceed rbmecW or at once against any Person, tnclud°q Borrower or any other guarantor: (d) to proceed Merrolly the againaft or m Comrrier°iW pria to I bald by Lender from Borrower, any alnar guarantor, ar any Other person; (a) to give notice of Ina terms, time, and piece of any D held by Lander from eanower or to tempi with any other applicable provisions Awte Salo of personal ther r aae°rWithin Landoll PoWe r Or (g) to commit any act or omission of any Idnd, or at any time, with respect to any Coda; (g to pursue any og+er remedy matter whatsoever. Guarantor also waives any and all fights or defonses arising by temn of (9) anyone action' or "ring-dafidaneY law Or any other law ich aMAY dversely prevent Lander from bringing army action, including a oof p fd ? 'roc any Guarantor, of mmadlas by Lander whichdrsboYS ant Of ise adv rs ly any foreclosure action, either JuduaetlY a by Oxen agents Guarantor may author dphts a It lu'S rights proceed against gth erbbtedness? any disaabiiiliiit(ynor ottheradalalnsse a BWOwef, of e rights Guvanbr may !tiger by reason ot any ny mw gmitlng, uallYng. of discharging the any other Guarantor, or of arly other Person, a Dy reason of trio tna cessation of Bomawers liability from any cause whatsoever, other than payment In thfull in dander, of the Indebteaross: an hi to claim discharge of this Indebtednass on the basis of unjustified Impairment of arty scollateral f?lga (d) Y rig tor is omen to ed tWO IS at law or In quaratitars Indaebtedness; (e) any salute 015 1 do ns. at b time any t/ action or s Iwle st l? at treRLOMW allonse or n any sa defenses is commenced mate art/ third at era ndeb te Candor which is s not t barred by am PPS ent to Bortowaes trustee in bankruplay or to any equity other than actual PaYmald and parfarrturce of the Indebtedness. If payment is made by Borrower, wheNa voluntonly of otherwise, of by the d forced trial ltur0 pen1Y, an the IndOblodmres! and trifNeaftef Lon aw or Iaw fortthat regal of debt rs. the IdebP tedness shall be considered un similar parso n under am/ rodaral or paid for the purpose of state banlvuptcy catch enforcement of this Guaranty Guarantor further waives and agrees • - not to Assert or claim any tiro any r:oductiolis to the amount guaranteed under this Guaranty Barr?awor, the t Smith, counterclaim, counter demand, reoeuplheM of Similar right, whether such tier, demand or fight may be asserted by the Guarantor, or bath. contrary to G , 'S UNDERSTANDING WITH RESPECT TO WAIVERS Guarantor warrantsand agrees that each of rs sat forth &be" IS made Co coptransequences ry to and any that app undo ira thbfde ciIawlcuroristatlCpublic05, policy, the licy, waslvuch waiver am are shall be reasonable and ?&b not Only t the ,=0 toRrs full knowledge, 11 any such of as slit waiver mfiscance and delernuned consequences pubic perky lbw. U n ad udgas or other property of Guarantor given to Ipot adept pertained a ? by law or a public LENDER'S RIGHT Lander SETOFF- have, ddmgan to an hens upon end rights of setaft against this moneys, sac brad ent p Lender by law, Lander shah hew. with respect to Guarantees ablgatlors to Linda unrsodr^w Gdulvers p edo the , extent permitted by law, a again moneys, uar a for and other WoP°dy of Guaranty now ors and t erm to Lender all of ransf r In this possession o of contraclud security Interest in and a right of I;ehoff 11 de against and , securiti r hereby other prop toys, t, aria and Interest in and to, 0g dap arFOdM or depaas whether hard jointly Wim someone else, a whether hold for Guarantees Agra d In a 90115161 Or sPacu! an deposit with Lender, whew he such security haw been warned by am/ act or conduct on the safekeeping or otherwise, excluding however AA IRA. Neoph? and bus_setaff shall be deemed t hinterest and fight of salon may be axdtt„A interest a fight E t of rAtOff Arid part of demand upon err police t Guaranis. No fight o ily waived or released by an Instrument In part of Lender or by any rspwcl to tuerea.A such fight of setoff Of to entetrza such Security intarrest ASt or by any delay In so doing. vary saeudty Interest shall continue in full tares and offect Until such right of !staff or. sacuft late is sPadfi®gY nave Willing amcubd by Lander. I that Ina Indebtedness of Borrower to Lender, whedsr upon arryer aec° he or not Balrowef gUBOROINATION OF BORROWER'S DE8T5 TO'GUARANTOR. Guarantor have tint e rtOf rioter, any mi existing or hereafter created shell be Prior to any claim that Glarema may now nave or fratlaraa fst acquire against e°nsaower, upon liquidation Of the assets d ? Ban becomes insolvent. Guarantor hereby eViesslY subordinates air/ claim Guarantor may and it have apairot. Bonowa:. In the . voluntary liquidation. or oU affli e. the assets d Borrower app 1, by or hereafter y assign of r usivr claim that b Lander my through bankruptcy, by an tm der for aia benatit of cro l by pea or mower if' andent G the chins of halh Lends and Go Lender shall be paid paid to Lander and shag be rest applied by Lander to this Indobtadness n to Under all claims which it may have or Acquire againsi gainst Borrow or against ?nr full payment In legal lender. uarenta dons tma0by ails nntoat shall be of active only for the purpose of assuring reas and Lander to bankruptr."/` o; a .FOn ?er Prw'°foadndaso roq? oasts, any notes s eredlf ?hk ruaimrra and sl>o?ll b deive!ed tolanderdets b G 0euamMta age of crows to -- -- - ---- -- -..,e,?a„K and to execute fanwr. a V l... - •- our actions as Lander dooms M100059ArY onwrca rights under this Gturanly.- _..-- Pfovislon, are A part of this Guaranty: MISCELLANEOUS PROVISIONS. The rdlawirq miscellaneous Documents. cerstituals On entire undor Aamendmefft standing and agraemant of the paNa as to the This Guaranty, ag No al egewith Any Fialated n in writing and signed by the It" matters sot forth in this Guaranty. NO matlon of or ansndmont to this Guaranty shag be egxtlw unless I)ave a P,,,,,0,,,, to be dtargad or bound by the dmratiai a amendment. It there is a t,endaa and axapted by Lender in this Commonwealth of Penn5yh`AhmmanwaeltM Of Applicable Law. This Guarantl has y boon delivered is IuAsdctlan of tlta courts At Cumberland County. lawsuit Guarantor agrees upon Landers request by and to to s rpmubtnma wd to In th aaordana° wan rho laws of the Commonwo rah of Pennsylvania. ponrsymania. This Guaranty shag be 9OvomeY ri °ft= fees and Landaus Insas, ash and it*( Attorneys' from Erpe"-* GuareMa agrees to pay upon demand an of ULander may pay someone also to ? on INS Guaranty, and pay the in connection with the enfdr15men10l its Guaranty' a roo Landers aadinpa att(and orneys' includ sae, ing and efforts to muddy a legal BrPsnm g Incurred Guarantor shag ?WY the ?ts?amdla dl es ft f such e? a and rl,gal expensand exports" es Costs Psn?0S W ba^Imrptdy D legal expenses 241-0060 FINANCIAL TRUST 914 P05 DEC 16 '99 12:36 - page 3 COMMERCIAL GUARANTY 07-27-1998 (Continued) 11111 ''IF and any antiepated posl_judgmenl collection services. Guarenlw also shill pay all court costa vacate any automatic stay or injunction), aPPeals• may he soot by telcblcaimlle WAWA and such additional 105 as maybe directed by the court. an at m a , to the afr me under this Guaranty sttaa be in wlnlnq, ad or when daPontod with a natlormay recognized overnight nOtieo is to be given at a address Notksi NI notlOOS ragWred to be given by either pang adeOdve When actually tldnrer when m required by the law), and Slates area mW , ail. Taal Otags Postage Drepdd, addressed to the Party to whom ft as either party may dpri rid to be other in writing. If thorn mom ni med at an times of notice to Guaranty Land Otryonyiae h Abavo w to soon oilier addresi G For noeca Purposes Guarantor agrees to koeP shown Guarantor V AU consllheb notlce to all all Ouarantws. than all words used In this Guaranty in the singular shay be 80 currant address. on dace is rows than one SOrfONer or tin so raq . In this Interpretation. In a0 cases es where on the . so Weird •BOe:rcand WfloweY r" 1 atndhere i5 more than m raanspo?vely shell m of named ? of deemed to have been rtod in lhanpl ed where by the more context than and one Guar, cordeuc ?andor I tide the h045, succossOrs. assigra? and hanskraaa Guaranty or when Ins Guava wwds'Guarenlor: 'BORON'w; SaS a" and are not lobe used to interpret or define the provisions Of this any one or mom Of them. this Guam* are for convenience pwpO• to he not tld w unenforceable as to BAY parson of circumstance. if a coon W canPelanl jurisdiction b as to any other parsons or dreumsfanos, and an provisions of this Guaranty Guar.aranty Caption court ends any Provision of this Guaranty aganllorations acting or Parr p ftnershlPS, it is not Gu such ending shell not render mat provision invalid or unenlorWb u alOng W act In all Other feaPac4a slue remain wad and enforceable. It airy tine of more of Borrower or Gtalrant ??' corporations nder this rS of f Borrower or Guaranter or al the Gtfioers, direct such powers shall b tie QUarenleaed u nocesWf for Lander to Inquire into the Podrs or Created in rohrice upon the professed exert' Lender- on their behalf, and BAY Indebtedness Guaranty. n6 under this Guaranty unloss such waiver b given In wdOng n signed by Lender Lend road to have waived any rig Shall operate as a wiuver of such right w any other right, waiver ender of or Waiver. Lender she? not be ad (it Lendar in axerdsing any d91>! ht WVB( so to demand shkt comPlynce with that provision Lander and Guarantor, 5 tud1 coratih s a No delay or omhsion on the Part po demand a provision of this Guaranty shall nal; No pri or cansti by a warvd 1101 any tour a of dealing _ Is required stue not ncoosGlute ontlnuing eonsennt to subsequent eq ?Instances any Other Provision of M Guaranty. No prior WSwar by Lander, the waiver of any of Landafs rights of of any of Guarantor's obtigatlons as t?oa cefuture under this Gaaradl9. Via granting Of 5ueh Consent by Lender In airy Wmd ?wAhoId in the 5ole dISOrefi0n of Landes. whore such ctlnsent is required and in as cases such consent may o gran ?. _ _.... •?..e Auv ATTORNEY OR THE EFFECTIVE', THIS GUanwn.. ... ••...---- ERSIGNED. THIS GUARANTY HAS B@f SIGNED AND SFALED BY THE UIM KEYSTONE FINANCIAL BANK N.A. Plaintiff VS. KATHLEEN W.LOSCHER EDWARD A. LOSCHER Defendants IN THE COURT OF COMMON PLEAS COUNTY OFCUMBERLAND COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION LAW CIVIL TERM 1999- 7? 7? ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter our appearance on behalf of Plaintiff, Keystone Financial Bank, N. A. and enter judgment for Plaintiff and against Defendants Kathleen W. Loscher and Edward A. Loscher, for damages. Duncan & Hartman, P.C. DATED: By: William A. Duncan, Esquire Attorney for Plaintiff KEYSTONE FINANCIAL BANK, N.A.- PLAINTIFF vs. KATHLEEN W.LOSCHER EDWARD A. LOSCHER DEFENDANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL NO. 1999-7679 CIVIL ACTION LAW PLEASE MARK THE ABOVE CAPTIONED MATTER SATISFIED AND DISCONTINUED To:---CURTIS LONG --Prothonotary SEPTEMBER_i /,2000 V- _. rj ?F r_- 'mow 41 : i "' V7 o U .- Lt?