HomeMy WebLinkAbout07-2340COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CNIL ACTION
PNC BANK, NATIONAL ASSOCIATION, DOCKET NO. O'7 -. ,Z.3 ~~ '
~l v ~C,,
Plaintiff
v.
AVP ENTERPRISE, INC., DBA
UNI-MART,
Defendant
CONFESSION OF JUDGMENT
PREVIOUSLY ASSIGNED TO: N/A
CONFESSION OF JUDGMENT
Pursuant to the authority contained in the warrant of attorney, 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 the Defendant as follows:
a. Principal $652,992.72
b. Interest to April 19, 2007 $ 29,835.59
c. Late Charges $ 1,450.68
d. UCC Search Fees $ 96.00
e. Attorneys' Fees fR,2R2_R'i
TOTAL: $752,657.82, plus interest, other
expenses, fees and costs
Respectfully submitted,
McNees Wallace & Nurick LLC
Date: April, 2007 By:
4?~fi'1'y~ Sh ,Esquire
Supreme C ID #24848
100 Pine treet, PO Box 1166
Hamsburg, PA 17108-1166
(717}237-5439
Attorneys for Plaintiff
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION ~ ~'
PNC BANK, NATIONAL ASSOCIATION, DOCKET NO. d'}' -_~3t{~ ~~ v ~ ~, [ ~-
Plamtiff
v.
:CONFESSION OF JUDGMENT
AVP ENTERPRISE, INC., DBA
UNI-MART,
Defendant :PREVIOUSLY ASSIGNED TO: N/A
COMPLAINT FOR CONFESSION OF JUDGMENT
UNDER RULE 2951
1. The Plaintiff, PNC Bank, National Association, is a national banking association
organized and existing under the laws of the United States of America with a principal regional
office located at 4242 Carlisle Pike, Camp Hill, PA 17011 (the "Plaintiff').
2. The Defendant, AVP Enterprise, Inc., dba Uni-Mart, is a Pennsylvania corporation
with a last known address of c/o Stephanie A. Slates, President, 109 George Street, Enola, PA
17025 (the "Defendant").
3. The Defendant executed and delivered to the Plaintiff a U.S. Small Business
Administration Note dated September 27, 2005, in the original principal amount of Six Hundred
Eighty-Two Thousand Dollazs ($682,000), as amended by an Amendment to US Small Business
Administration Note dated April 13, 2006 (together, the "Note"), true and correct photostatic
reproductions of the originals of which are attached hereto as Exhibit "A" and made a part hereof.
4. The Defendant executed and delivered to the Plaintiff a Disclosure for Confession
of Judgment ("Disclosure for Confession"), a true and correct photostatic reproduction of the
original of which is attached hereto as Exhibit "B" and made a part hereof.
5. Defendant is in default of Defendant's obligations to make payment to the Plaintiff
as required in the Note, and the Plaintiff has demanded payment in full of all outstanding amounts
as provided in the Note. A copy of the Plaintiffs demand dated February 13, 2007, is attached
hereto as Exhibit "C" and made a part hereof.
6. Judgment is not being entered by confession against a natural person in connection
with a consumer credit transaction.
7. There has not been any assignment of the Note.
8. Judgment has not been entered on the Note in any jurisdiction.
9. The amount due to the Plaintiff as a result of the Defendant's default is as follows:
a. Principal $652,992.72
b. Interest to April 19, 2007 $ 29,835.59
c. Late Chazges $ 1,450.68
d. UCC Search Fees $ 96.00
e. Attorneys' Fees fiR, R~~
TOTAL DUE: $752,657.82
10. Interest continues to accrue at a rate equal to the Prime Rate published in the Wall
Stre .t Tn ~rnal, plus two and one-quarter percent (2.25%), adjusted monthly.
WHEREFORE, Plaintiff, PNC Bank, National Association, demands judgment against the
Defendant, AVP Enterprise, Inc., dba Uni-Mart, in the amount of Seven Hundred Fifty-Two
Thousand Six Hundred Fifty-Seven and 82/100 Dollazs ($752,657.82), plus interest at a rate equal
to the Prime Rate published in the Wall Street 7~urnal, plus two and one-quarter percent (2.25%),
adjusted monthly, through the date of payment, including on and after the date of entry of judgment
on this Complaint, and for other expenses, fees and costs to which the Plaintiff maybe entitled.
Respectfully submitted,
Date: April 2007
McNees Wallace & Nurick
By:
S. uff, Esquire
ourt ID #24848
100 Pi~fe Street, PO Box 1166
Harrisburg, PA 17108-1166
(717) 237-5439
Attorneys for Plaintiff
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff
v.
AVP ENTERPRISE, INC., DBA
UNI-MART,
Defendant
DOCKET NO.
CONFESSION OF JUDGMENT
PREVIOUSLY ASSIGNED TO: N/A
VERIFICATION
I, Eric D. Krimmel, Vice President, for PNC Bank, National Association, being authorized
to do so on behalf of PNC Bank, National Association, hereby verify that the statements made in the
foregoing pleading are true and correct to the best of my information, knowledge and belief. I
understand that false statements herein aze made subject to the penalties of 18 Pa. C.S. Section
4904, relating to unsworn falsification to authorities.
PNC BANK, NATIONAL ASSOCIATION
Date: ~ ~ (~ `O"`1 gy; ~-
Eric D. Krimmel
Vice President
U8 11 tlt ell Adt Ip
U.S. Small Business Administration
NOTE
SBA Loan # PLP 90988640-04
SBA Loan Name AVP Enterprise, Inc. dba Uni-Mart
Date ~ - d ~
Loan Amount 682,000.00
Interest Rate Floating at WSJ Prime plus 2.25% resulting in an initial rate of 8.75%
Borrower AVP Enterprise, Inc. dba Uni-Mart
Operating
Company
Lender PNC Bank, National Association
1. PROMISE TO PAY:
In return for the Loan, Borrower promises to pay to the order of Lender the amount of
Six Hundred Eighty Two Thousand--------------------- ------00/100 Dollazs,
interest on the unpaid principal balance, and all other amounts required by this Note.
2. DEFINITIONS:
"Collateral" means any property taken as security for payment of this Note or any guarantee of this Note.
"Guarantor" means each person or entity that signs a guarantee of payment of this Note.
"Loan" means the loan evidenced by this Note.
"Loan Documents" means the documents related to this loan signed by Borrower, any Guarantor, or anyone who
pledges collateral.
"SBA" means the Small Business Administration, anAgency of the United States of America.
SBA Form 147 (08/03/02) Version 4.1
Page 1/8
Bankers Systems, Inc., St. Cloud, MN
3. PAYMENT TERMS:
Borrower must make all payments at the place Lender designates. The payment terms for this Note are:
This Note will mature in 10 years from date of Note.
The interest rate on this Note will fluctuate. The initial interest rate is 8.75% per year. This initial rate is the prime
rate on the date SBA received the loan application, plus 2.25%. The initial interest rate must remain in effect until
the first change period begins.
Borrower must pay interest on the disbursed principal balance, plus principal of $5,683.33 every month, beginning
one month from the month this Note is dated; payments must be made on the first calendar day in the months they
are due.
Lender will apply each installment payment first to pay interest accrued to the day Lender receives the payment,
then to bring principal current, then to pay any late fees, and will apply any remaining balance to reduce the principal.
The interest rate will be adjusted monthly (the "change period").
The "Prime Rate" is the prime rate in effect on the first business day of the month in which an interest rate change
occurs, as published in the Wall Street Journal on the next business day.
The adjusted interest rate will be 2.25% above the Prime Rate. Lender will adjust the interest rate on the first
calendar day of each change period. The change in interest rate is effective on that day whether or not Lender gives
Borrower notice of the change.
Lender must adjust the payment amount at least annually as needed to amortize principal over the remaining term
of the note.
If SBA purchases the guaranteed portion of the unpaid principal balance, the interest rate becomes fixed at the rate
in effect at the time of the earliest uncured payment default. If there is no uncured payment default, the rate
becomes fixed at the rate in effect at the time of purchase.
Notwithstanding any provision in this Note to the contrary:
Borrower may prepay this Note. Borrower may prepay 20 percent or less of the unpaid principal balance at any time
without notice. If Borrower prepays more than 20 percent and the Loan has been sold on the secondary market,
Borrower must: (a.) Give Lender written notice; (b.) Pay all accrued interest; and (c.) If the prepayment is received
less than 21 days from the date Lender receives the notice, pay an amount equal to 21 days' interest from the date
Lender receives the notice, less any interest accrued during the 21 days and paid under subparagraph b., above. If
Borrower does not prepay within 30 days from the date Lender receives the notice, Borrower must give Lender a
new notice.
All remaining principal and accrued interest is due and payable 10 years from date of Note.
Late Charge: If a payment on this Note is more than 10 days late, Lender may charge Borrower a late fee of up to
5% of the unpaid portion of the regularly scheduled payment.
SBA Forth 147 (09103/02) Version 4.1 Page y9
Bankers Systems, Inc., St. Cloud, MN
4. DEFAULT:
Borrower is in default under this Note if Borrower does not make a payment when due under this Note, or if Borrower
or Operating Company:
A. Fails to do anything required by this Note and other Loan Documents;
B. Defaults on any other loan with Lender;
C. Does not preserve, or account to Lender's satisfaction for, any of the Collateral or its proceeds;
D. Does not disclose, or anyone acting on their behalf does not disclose, any material fact to Lender or SBA;
E. Makes, or anyone acting on their behalf makes, a materially false or misleading representation to Lender or SBA;
F. Defaults on any loan or agreement with another creditor, if Lender believes the default may materially affect
Borrower's ability to pay this Note;
G. Fails to pay any taxes when due;
H. Becomes the subject of a proceeding under any bankruptcy or insolvency law;
I. Has a receiver or liquidator appointed for any part of their business or property;
J. Makes an assignment for the benefit of creditors;
K. Has any adverse change in financial condition or business operation that Lender believes may materially affect
Borrower's ability to pay this Note;
L. Reorganizes, merges, consolidates, or otherwise changes ownership or business structure without Lender's prior
written consent; or
M. Becomes the subject of a civil or criminal action that Lender believes may materially affect Borrower's ability to
pay this Note.
5. LENDER'S RIGHTS IF THERE IS A DEFAULT:
Without notice or demand and without giving up any of its rights, Lender may:
A. Require immediate payment of all amounts owing under this Note;
B. Collect all amounts owing from any Borrower or Guarantor;
C. File suit and obtain judgment;
D. Take possession of any Collateral; or
E. Sell, lease, or otherwise dispose of, any Collateral at public or private sale, with or without advertisement.
6. LENDER'S GENERAL POWERS:
Without notice and without Borrower's consent, Lender may:
A. Bid on or buy the Collateral at its sale or the sale of another lienholder, at any price it chooses;
B. .Incur expenses to collect amounts due under this Note, enforce the terms of this Note or any other Loan
Document, and preserve or dispose of the Collateral. Among other things, the expenses may include payments
for property taxes, prior liens, insurance, appraisals, environmental remediation costs, and reasonable attorney's
fees and costs. If Lender incurs such expenses, it may demand immediate repayment from Borrower or add the
expenses to the principal balance;
C. Release anyone obligated to pay this Note;
D. Compromise, release, renew, extend or substitute any of the Collateral; and
E. Take any action necessary to protect the Collateral or collect amounts owing on this Note.
SBA Form 14T (08/03!02) Version 4.1 Page 3/8
Bankers Systems, Inc., St. Cloud, MN
7. WHEN FEDERAL LAW AIaPLIES:
When SBA is the holder, this Note will be interpreted and enforced under federal law, including SBA regulations.
Lender or SBA may use state or local procedures for filing papers, recording documents, giving notice, foreclosing
liens, and other purposes. By using such procedures, SBA does not waive any federal immunity from state or local
control, penalty, tax, or liability. As to this Note, Borrower may not claim or assert against SBA any local or state law
to deny any obligation, defeat any claim of SBA, or preempt federal law.
8. SUCCESSORS AND ASSIGNS:
Under this Note, Borrower and Operating Company include the successors of each, and Lender includes its successors
and assigns.
9. GENERAL PROVISIONS:.
A. All individuals and entities signing this Note are jointly and severally liable.
B. Borrower waives all suretyship defenses.
C. Borrower must sign all documents necessary at any time to comply with the Loan Documents and to enable
Lender to acquire, perfect, or maintain Lender's liens on Collateral.
D. Lender may exercise any of its rights separately or together, as many times and in any order it chooses. Lender
may delay or forgo enforcing any of its rights without giving up any of them.
E. Borrower may not use an oral statement of Lender or SBA to contradict or alter the written terms of this Note.
F. If any part of this Note is unenforceable, all other parts remain in effect.
G. To the extent allowed bylaw, Bon ower waives all demands and notices in connection with this Note, including
presentment, demand, protest, and notice of dishonor. Borrower also waives any defenses based upon any claim
that Lender did not obtain any guarantee; did not obtain, perfect, or maintain a lien upon Collateral; impaired
Collateral; or did not obtain the fair market value of Collateral at a sale.
SBA Forth 147 (08103/02) Version 4.1
Page 4/8
Bankers Systems, Inc., St. Cloud, MN
,• . , ~,
10. STATE-SPECIFIC PROVISIONS:
1. POWER TO CONFESS JUDGMENT. UNDERSIGNED HEREBY EMPOWERS ANY ATTORNEY OF ANY
COURT OF RECORD, AT ANY TIME AFTER THE OCCURRENCE OF ANY EVENT OF DEFAULT HEREUNDER, TO
APPEAR FOR THE UNDERSIGNED AND, WITH OR WITHOUT COMPLAINT FILED, CONFESS JUDGMENT, OR A
SERIES OF JUDGMENTS, AGAINST THE UNDERSIGNED IN FAVOR OF THE LENDER OR ANY HOLDER
HEREOF FOR THE ENTIRE PRINCIPAL BALANCE OF THIS NOTE, ALL ACCRUED INTEREST AND ALL OTHER
AMOUNTS DUE HEREUNDER, TOGETHER WITH COSTS OF SUIT AND AN ATTORNEY'S COMMISSION OF 10%
OF SUCH PRINCIPAL AND INTEREST ADDED AS A REASONABLE ATTORNEY'S FEE, AND FOR DOING SO,
THIS NOTE OR A COPY VERIFIED BY AFFIDAVIT SHALL BE A SUFFICIENT WARRANT. THE UNDERSIGNED
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 STATE
NOW IN FORCE OR HEREAFTER ENACTED.
JUDGMENT MAY BE CONFESSED FROM TIME TO TIME UNDER THE AFORESAID POWER TO CONFESS
JUDGMENT AND 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, BUT THE POWER SHALL
CONTINUE UNDIMINISHED AND IT MAYBE EXERCISED FROM TIME TO TIME AS OFTEN AS THE LENDER
SHALL ELECT UNTIL SUCH TIME AS THE LENDER SHALL HAVE RECEIVED PAYMENT IN FULL OF THE DEBT,
INTEREST, COSTS AND FEES.
2. Governing Law; Jurisdiction. This Note will be interpreted and the rights and liabilities of the parties hereto
determined in accordance with the laws of the Commonwealth of Pennsylvania, excluding its conflict of laws rules.
The Undersigned hereby irrevocably consents to the exclusive jurisdiction of the Courts of Common Pleas of the
Commonwealth of Pennsylvania and the United States District Court for the Eastern District of Pennsylvania; provided
that nothing contained in this Note will prevent the Lender or any holder hereof from bringing any action, enforcing any
award or judgment or exercising any rights against the Undersigned, against any security or against any property of
the Undersigned within any other county, state or other foreign or domestic jurisdiction. The Undersigned agrees that
the venue provided above is the most convenient forum for both the Lender and the Undersigned and the Undersigned
waives any objection to venue and any objection based on a more convenient forum in any action instituted under this
Note. The Undersigned agrees that service of process in any such proceeding may be duly effected upon the
Undersigned by mailing a copy thereof by registered mail, postage prepaid, to the Undersigned.
3. WAIVER OF JURY TRIAL. THE UNDERSIGNED IRREVOCABLY WAIVES ANY AND ALL RIGHTS THE
UNDERSIGNED MAY HAVE TO A TRIAL BY JURY IN ANY ACTION, PROCEEDING OR CLAIM OF ANY NATURE
RELATING TO THIS NOTE, ANY DOCUMENTS EXECUTED IN CONNECTION WITH THIS NOTE OR ANY
TRANSACTION CONTEMPLATED IN ANY OF SUCH DOCUMENTS. THE UNDERSIGNED ACKNOWLEDGES
THAT THE FOREGOING WAIVER IS KNOWING AND VOLUNTARY.
SBA Form 147 (08/03/02) Verson 4.1
Page 5/8
Bankers Systems, Inc., St. Cloud, MN
11. BORROWER'S NAME(S) AND SIGNATURE(S):
By signing below, each individual or entity becomes obligated under this Note as Borrower.
AVP Enterprise, Inc. dba Uni-Mart
~J r
SBA Form 147 (08/03/02) Version 4.1
Page 818
Bankers Systems, Inc., St. Cloud, MN
,~ ~~.
#32219479-602636967
Amendment to US Small Business PNCI~A~TI[~
Administration Note
THIS AMENDMENT TO US SMALL BUSINESS ADMINISTRATION NOTE (this "A.mendment") is made as
of April 13, 2006, effective as of April 1, 2006, by and between AVP ENTERPRISE, INC. DBA UNI-MART (the
"Borrower"), and PNC BANK, NATIONAL ASSOCIATION (the "Bank").
BACKGROUND
A. The Borrower has executed and delivered to the Bank (or a predecessor which is now known by the Bank's name
as set forth above), a US Small Business Administration Note, which is more fully described on attached Exhibit A, which is
made a part of this Amendment (collectively as amended from time to time, the "Loan Documents") which evidences or
secures some or all of the Borrower's obligations to the Bank for one or more loans or other extensions of credit (the
"Obligations").
B. The Borrower and the Bank desire to amend the Loan Documents as provided for in this Amendment.
NOW, THEREFORE, in consideration of the mutual covenants herein contained and intending to be legally bound
hereby, the parties hereto agree as follows:
1. Certain of the Loan Documents are amended as set forth in Exhibit A. Any and all references to any Loan
Document in any other Loan Document shall be deemed to refer to such Loan Document as amended by this Amendment.
This Amendment is deemed incorporated into each of the Loan Documents. Any initially capitalized terms used in this
Amendment without defmition shall have the meanings assigned to those terms in the Loan Documents. To the extent that
any term or provision of this Amendment is or may be inconsistent with any term or provision in any Loan Document, the
terms and provisions of this Amendment shall control.
2. The Borrower hereby certifies that: (a) all of its representations and warranties in the Loan Documents, as
amended by this Amendment, are, except as may otherwise be stated in this Amendment: (i) true and correct as of the date of
this Amendment, (ii) ratified and confirmed without condition as if made .anew, and (iii) incorporated into this Amendment
by reference, (b) no Event of Default or event which, with the passage of time or the giving of notice or both, would
constitute an Event of Default, exists under any Loan Document which will not be cured by the execution and effectiveness
of this Amendment, (c) no consent, approval, order or authorization of, or registration or filing with,- any third party is
required in connection with the execution, delivery and carrying out of this Amendment or, if required, has been obtained,
and (d) this Amendment has been duly authorized, executed and delivered so that it constitutes the legal, valid and binding
obligation of the Borrower, enforceable in accordance with its terms. The Borrower confirms that the Obligations remain
outstanding without defense, set off, counterclaim, discount or charge of any kind as of the date of this Amendment.
3. The Borrower hereby confirms that any collateral for the Obligations, including liens, security interests,
mortgages, and pledges granted by the Borrower or third parties (if applicable), shall continue unimpaired and in full force
and effect, and shall cover and secure all of the Borrower's existing and future Obligations to the Bank[, as modified by this
Amendment).
4. As a condition precedent to the effectiveness of this Amendment, the Borrower shall comply with the terms and
conditions (if any) specified in Exhibit A.
5. This Amendment may be signed in any number of counterpart copies and by the parties to this Amendment on
separate counterparts, but all such copies shall constitute one and the same instrument. Delivery of an executed counterpart
of a signature page to this Amendment by facsimile transmission shall be effective as delivery of a manually executed
counterpart. Any party so executing this Amendment by facsimile transmission shall promptly deliver a manually executed
counterpart, provided that any failure to do so shall not affect the validity of the counterpart executed by facsimile
transmission.
Form 17A -Multistate Rev. 3/99
~- ~
6. This Amendment will be binding upon and inure to the benefit of the Borrower and the Bank and their respective
heirs, executors, administrators, successors and assigns.
7. This Amendment 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 in the Loan Documents is located. This Amendment will be interpreted and the rights and
liabilities of the parties hereto determined in accordance with the laws of the State where the Bank's office indicated in the
Loan Documents is located, excluding its conflict of laws rules.
8. Except as amended hereby, the terms and provisions of the Loan Documents remain unchanged, are and shall
remain in full force and effect unless and until modified or amended in writing in accordance with their teens, and are
hereby ratified and confu-med. Except as expressly provided herein, this Amendment shall not constitute an amendment,
waiver, consent or release with respect to any provision of any Loan Document, a waiver of any default or Event of Default
under any Loan Document, or a waiver or release of any of the Bank's rights and remedies (all of which are hereby reserved).
The Borrower expressly ratifies and confirms the confession of judgment '(if applicable) and .waiver of jury trial
provisions contained in the Loan Documents.
WITNESS the due execution of this Amendment as a document under seal as of the date first
written above.
WITNESS /ATTEST:
M
Print Name: j [ ~K ! L / ~ (e /~~~'
Title:
(Include title only if an officer of entity signing to the right)
AVP ENT RPRISE, INC.
DBA RT
By: ~, r~
Steph'~uie A. Slates
President
(SEAL)
PNC BANK, NATIONAL ASSOCIATION
By: .~~~-
~-
Print Name: ~,r ~ .., r7`*~~,., , („~,~f,,f
Title: 'i~'~
- 2 - Form 17A -Multistate Rev. 3/99
~` ~' ~
EXHIBIT A TO
AMENDMENT TO LOAN DOCUMENTS
DATED APRIL 13, 2006, EFFECTIVE AS OF APRIL 1, 2006
A. The "Loan Documents" that are the subject of this Amendment include the following (as any of the
foregoing have previously been amended, modified or otherwise supplemented):
1. US Small Business Administration Note dated September 27, 2005 in the original principal
amount of $682,000.00 (the "Note").
2. All other documents, instruments, agreements, and certificates executed and delivered in
connection with the Loan Documents listed in this Section A.
B. The Loan Documents are amended as follows:
The Note is hereby amended by extending a three (3) month principal deferment on the
outstanding principal balance as of April 1, 2006.
The repayment schedule is hereby modified as defined below:
"The interest rate on this Note will fluctuate. The initial interest rate is 8.75% per year. This initial
rate is the prime rate on the date the SBA received the loan application, plus 2.25%. The initial
interest rate must remain in effect until the first change period.
Commencing on July 1, 2006, Borrower must pay interest due on the disbursed principal
balance, plus principal of $5,835.57 every month; payments must be made on the first
calendar months they are due.
Lender will apply each installment payment first to pay interest accrued to the day Lender receives
the payment, then to bring principal current, then to pay any late fees, and will apply any remaining
balance to reduce principal.
The interest rate will be adjusted monthly (the "change period").
The "Prime Rate" is the prime rate in effect on the first business day of the month in which an
interest rate change occurs, as published in the Wall Street Journal on the next business day.
The adjusted interest rate will be 2.25% above the Prime Rate. Lender will adjust the interest rate
on the first calendar day of each change period. The change in interest rate is effective on that day
whether or not Lender gives Borrower notice of the change. The initial interest rate must remain in
effect until the first change period begins.
Lender must adjust the payment amount at least annually as needed to amortize principal over the
remaining term of this Note.
If SBA purchases the guaranteed portions of the unpaid principal balance, the interest rate becomes
fixed at the rate in effect at the time of the earliest uncured payment default. If there is no uncured
payment default, the rate becomes fixed at the rate in effect at the time of purchase.
- 3 - Form 17A -Multistate Rev. 3/99
~~
All remaining principal and accrued interest is due and payable 10 years from the date of
Note.
Late Charge: If payment on this Note is more than 10 days late, Lender may charge Borrower a
late fee of up to 5% of the unpaid portion of the regularly scheduled payment."
C. Conditions to Effectiveness of Amendment: The Bank's willingness to agree to the amendments set
forth in this Amendment are subject to the prior satisfaction of the following conditions:
1. This Amendment to Loan Documents duly executed by Borrower and Bank.
2. The Consent of Guarantor to this Amendment to Loan Documents duly executed by all
Guarantors.
- 4 - Form 17A -Multistate Rev. 3/99
r~
. ~ ~-
CONSENT OF GUARANTOR
Each of the undersigned guazantors (jointly and severally if more than one, the "Guarantor")
consents to the provisions of the foregoing Amendment (the "Amendment") and all prior amendments
(if any) and confirms and agrees that: (a) the Guarantor's obligations under its US Small Business
Administration Guaranty dated September 27, 2005 (collectively if more than one, the "Guaranty"),
relating to the Obligations mentioned in the Amendment, shall be unimpaired by the Amendment; (b)
the Guazantor has no defenses, set offs, counterclaims, discounts or chazges of any kind against the
Bank, its officers, directors, employees, agents or attorneys with respect to the Guazanty; and (c) all of
the terms, conditions and covenants in the Guaranty remain unaltered and in full force and effect and are
hereby ratified and confirmed and apply to the Obligations, as modified by the Amendment. The
Guazantor certifies that all representations and warranties made in the Guazanty are true and correct.
The Guarantor hereby confirms that any collateral for the Obligations, including liens, security
interests, mortgages, and pledges granted by the Guarantor or third parties (if applicable), shall continue
unimpaired and in full force and effect, shall cover and secure all of the Guarantor's existing and future
Obligations to the Bank, as modified by this Amendment.
The Guarantor ratifies and confirms the indemnification, confession of judgment (if
applicable) and waiver of jury trial provisions contained in the Guaranty.
WITNESS the due execution of this Consent as a document under seal as of the date of this
Amendment, intending to be legally bound hereby.
WITNESS /ATTEST:
A '
Print Name: ~ ~ ~~ '~ ~ ~ .S I7- /~f~
~' -
Print Name: ~-~ ~~~ z ,A ~ Sf f~9-(,~C.~
S ' Form 17A -Multistate Rev. 3/99
Stephan' lates
(SEAL)
Vicki L. McFee
~~
Disclosure for Confession of Judgment
Undersigned: AVP ENTERPRISE, INC. dba UNI-MART
7391 LINCOLN WAY, WEST
SAINT THOMAS, PA 17252
Lender: PNC BANK, NATIONAL ASSOCIATION
8800 TINICUM BOULEVARD
PHILADELPHIA, PA 19153
PNCI~~NI[~
The undersigned has executed, and/or is executing,. on or about the date hereof, the following document(s) under which
the undersigned is obligated to repay monies to Lender:
U.S. Small Business Administration Note.
A. THE UNDERSIGNED ACKNOWLEDGES AND AGREES THAT THE ABOVE DOCUMENTS CONTAIN PROVISIONS UNDER
WHICH LENDER MAY ENTER JUDGMENT BY CONFESSION AGAINST THE UNDERSIGNED. BEING FULLY AWARE OF ITS RIGHTS TO
PRIOR NOTICE AND A HEARING ON THE VALIDITY OF ANY JUDGMENT OR OTHER CLAIMS THAT MAY BE ASSERTED AGAINST TT BY
LENDER THEREUNDER BEFORE JUDGMENT IS ENTERED, THE UNDERSIGNED HEREBY FREELY, KNOWINGLY AND IlVTELLIGENTLY
WAIVES THESE RIGHTS AND EXPRESSLY AGREES AND CONSENTS TO LENDER'S ENTERING JUDGMENT AGAINST IT BY
CONFESSION PURSUANT TO THE TERMS THEREOF.
B. THE UNDERSIGNED ALSO ACKNOWLEDGES AND AGREES THAT THE ABOVE DOCUMENTS CONTAIN PROVISIONS
UNDER WHICH LENDER MAY, AFTER ENTRY OF JUDGMENT AND WITHOUT EITHER NOTICE OR A HEARING, FORECLOSE UPON,
ATTACH, LEVY, TAKE POSSESSION OF OR OTHERWLSE SEIZE PROPERTY OF THE UNDERSIGNED IN FULL OR PARTIAL PAYMENT OF
THE JUDGMENT. BEING FULLY AWARE OF ITS RIGHT'S AFTER JUDGMENT IS ENTERED (INCLUDING THE RIGHT TO MOVE TO
OPEN OR STRHCE THE JUDGMENT), THE UNDERSIGNED HEREBY FREELY, KNOWINGLY AND INTELLIGENTLY WAIVES IT'S RIGHTS
TO NOTICE AND A HEARING AND EXPRESSLY AGREES AND CONSENTS TO LENDER'S TAKING SUCH ACTIONS AS MAY BE
PERMITTED UNDER APPLICABLE STATE AND FEDERAL LAW WITHOUT PRIOR NOTICE TO THE UNDERSIGNED.
C. The undersigned certifies that a representative of Lender specifically called the confession of judgment provisions in
the above documents to the attention of the undersigned, and/or that the undersigned was represented by legal counsel in
connection with the above documents.
D. The undersigned hereby certifies: that its annual income exceeds $10,000; that all references to the
undersigned above refer to all persons and entities signing below; and that the undersigned received a copy hereof at the time of
signing.
Dated: ~- ~~ 7 -O..S'~
A
A.
-MART
' PNC BANK, NATIONAL .' '.OCIATION
'{ ~. 4242 Carlisle Pike-
Camp Hill, PA 17011
E-mail: eric.krimmelna,pnc com
PNCBANK
Certified Mail
February 13, 2007
Ms. Stephanie A. Slates, President
AVP Enterprise, Inc. d/b/a Uni-Mart
109 George Street
Enola, PA 17025
Ms. Vicki L. McFee
AVP Enterprise, Inc. d/b/a Uni-Mart
21 S. Railroad Street
Hummelstown, PA 17036
In re: AVP Enterprise, Inc. d/b/a Uni-Mart ("AVP")
Obligor/Obligation Nos.: 322194'79-602636967 (5682,000 Loan)
Deaz AVP Enterprise, Inc, d/b/a Uni-Mart:
Dear Ms. Slates:
Deaz Ms. McFee:
Eric D. Krimmel
Vice President
(717) 730-2492 Tel
(717) 730-2373 Fax
As you know, you are obligated to PNC Bank, National Association ("PNC") for the above-referenced }oan account
(the "Loan"), as evidenced by a certain Note, Loan Agreements, Guarantees, and other related loan documents (the
"Loan Documents").
As you also know, you aze in default under the Loan and Loan. Documents for your failure to: (1) pay the November
1, 2006, December 1, 2006, January 1, 2007 and February 1, 2007 loan payments, and (2) provide PNC with proof
of adequate insurance coverage.
The above items constitute Events of Default under the Loan and Loan Documents.
As a result of the above Events of Default, all liabilities and obligations under the Loan and Loan Documents have
been accelerated and all liabilities and obligations under the Loan and Loan Documents are immediately due and
payable to PNC. As of this date the amount due under the Loan and Loan Documents are as follows:
Obligor/Obligation Nos ~ 32219479-602636967 (568? 000 Loan)
Prmclpal 5652,992.72
Interest to 2/13/07 25,197.59
Late charges 1.450.68
Total 5679,640.99, plus satisfaction fees.
Member o/ The PNC Financial Services Group
4242 Carlisle Pike Camp Hill Pennsylvania 17011
www.pnc.com
,., ', Ms. Stephanie A. Slates, Pre; ..ant
AVP Enterprise, Inc. d/b/a Uni-Mart
February 13, 2007
Page 2
Please be advised that unless payment in full is immediately delivered to PNC 4242 Cazlisle Pike, Camp Hill, PA
17011, in immediately available funds via wire transfer or cashier's check, PNC shall take all action it deems
appropriate to collect the above sums due and owing, preserve, protect and enforce its rights under the Loan and
Loan Documents.
No forbeazance, delay or inaction by us in the exercise of our rights and remedies, and no continuing performance
by us or you under the Loan: (a) shall constitute: (i) a modification or an alteration of the terms, conditions or
covenants of the documents evidencing the Loan or any related Loan Documents, all of which remain in full force
and effect; or (ii) a waiver, release or limitation upon our exercise of any of its rights and remedies thereunder, all of
which are hereby expressly reserved; or (b) shall relieve or release you or any guarantor in any way from any of
your respective duties, obligations, covenants or agreements under the Loan Documents or from the consequences of
the Defaults described above or any other Default thereunder. We aze not obligated to waive the Defaults described
above or aay other Defaults, whether now existing or which may occur after the date of this letter.
Very truly yours,
PNC Bank, National Association
g
Eric D.1Crimmel
Vice President
Certified Mail Nos.: 7099 3400 0013 38016015
7099 3400 0013 3801 6039
cc: Regular Mail
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION
PNC BANK, NATIONAL ASSOCIATION, :DOCKET NO. d'7 - a 3 ~a ~~ u c ~
Plaintiff
v. :CONFESSION OF JUDGMENT
AVP ENTERPRISE, INC., DBA
UNI-MART,
Defendant :PREVIOUSLY ASSIGNED TO: N/A
AFFIDAVIT OF NON-MILITARY SERVICE
TO THE PROTHONOTARY:
I do certify, to the best of my knowledge, that Defendant, AVP Enterprise, Inc., dba Uni-
Mart, in the above-captioned action is not presently on active or nonactive military status.
Respectfully submitted,
McNees Wallace & Nurick LLC
Date: April 2007 By:
ey S huff, Esquire
upreme Court ID #24848
100 Pine Street, PO Box 1166
Harrisburg, PA 17108-1166
(717)237-5439
Attorneys for Plaintiff
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION
PNC BANK, NATIONAL ASSOCIATION, :DOCKET NO. O'ff' - ~.3 ~{l~ /J' '
l...l(~~C, ~iL~
Plaintiff
v. :CONFESSION OF JUDGMENT
AVP ENTERPRISE, INC., DBA
UNI-MART,
Defendant
PREVIOUSLY ASSIGNED TO: N/A
CERTIFICATE OF ADDRESSES
I hereby certify that the precise address of Plaintiff, PNC Bank, National Association, is
4242 Carlisle Pike, Camp Hill, PA 17011; and that the last known address of Defendant, AVP
Enterprise, Inc., dba Uni-Mart, is c/o Stephanie A. Slates, President, 109 George Street, Enola, PA
17025.
Respectfully submitted,
McNees Wallace & Nurick LLC
Date: Apri ~ ; 2007 By:
~ o y S. ff, Esquire
upreme urt ID #24848
100 Pine Street, PO Box 1166
Harrisburg, PA 17108-1166
(717) 237-5439
Attorneys for Plaintiff
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CML ACTION
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PNC BANK, NATIONAL ASSOCIATION, DOCKET NO. O7 --oZ.3~/1S l~ to ~l, ~'"~
Plaintiff
v.
AVP ENTERPRISE, INC., DBA
UNI-MART,
Defendant
CONFESSION OF JUDGMENT
PREVIOUSLY ASSIGNED TO: N/A
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of Plaintiff, PNC Bank, National Association.
Papers maybe served at the address set forth below.
Geoffrey S. Shull, Esquire
McNees Wallace & Nurick LLC
100 Pine Street, PO Box 1166
Harrisburg, PA 17108-1166
(717)237-5439
Date: April ~ U 2007
Respectfully submitted,
McNees Wallace & Nurick LLC
By:
G-~3~~ S. S ,Esquire
preme ourt ID #24848
100 Pin Street, PO Box 1166
Harrisburg, PA 17108-1166
(717) 237-5439
Attorneys for Plaintiff
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION
PNC BANK, NATIONAL ASSOCIATION, :DOCKET NO. 07 _a3ya ~ ~~
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Plaintiff
v. :CONFESSION OF JUDGMENT
AVP ENTERPRISE, INC., DBA :
UNI-MART, :
Defendant :PREVIOUSLY ASSIGNED TO: N/A
NOTICES IN CONNECTION WITH JUDGMENTS BY CONFESSION
REQUIRED BY 42 Pa. C.S.A. § 2737.1 (Act 105 of 2000)
To: AVP Enterprise, Inc., dba Uni-Mart
Pursuant to 42 Pa. C.S. § 2737.1. please take notice that the Plaintiff in this matter has
entered a judgment by confession against you in the amount of $752,657.82, plus interest, other
expenses, fees and costs.
You are entitled to file a petition to "strike" or "open" the judgment. In order to do so,
you must promptly file a petition with the Court of Common Pleas of Cumberland County,
Pennsylvania, as required by Rule 2959 of the Pennsylvania Rules of Civil Procedure. You will
file a petition by leaving it with the courts or Prothonotary at the courthouse in Carlisle,
Cumberland County, Pennsylvania.
A petition is a formal statement of your reasons for challenging the judgment. You must
include the names of the parties at the top of the first page and the case number, which is shown
above. The petition must state your reasons for challenging the judgment is a separate numbered
paragraphs. You have to sign the petition and include a sworn statement at the end of the
document verifying that the facts you state in the petition are true and accurate. You will waive
any defenses and objections not included in your petition to strike or open. You must therefore
make every effort to raise all possible issues and defenses in your petition to strike or open in
order to avoid waiving any claims.
If you elect to file a petition, it must meet the requirements of Rule 2959 of the Rules of
Civil Procedure. A full copy of Rule 2959 is attached to this Notice. You may also have to
comply with local rules of procedure in effect in the county where the judgment was entered.
If you do not file a petition challenging the judgment, the Plaintiff may take steps to
collect on the judgment by asking the Sheriff to seize your assets. You may have other rights
available to you other than as set forth in this notice. You should take this paper to your
lawyer at once. If you do not have a lawyer, go to or telephone the office set forth below.
This office can provide you with information about hiring a lawyer.
~ 1
If you cannot afford to hire a lawyer, this office may be able to provide you with
information about agencies that may offer legal services to eligible persons at a reduced fee
or no fee.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166 or 1-800-990-9108
Corporations may be unable to represent themselves in court. If the defendants include a
corporation, the corporation must appear through an attorney if it intends to challenge the
judgment.
You may receive other papers and notices regarding the judgment. Those other papers do
not negate or override this Notice. Likewise, this Notice is not intended to and does not negate
any of the notices or information obtained in other papers that maybe served upon you.
We reiterate that you are required to act promptly if you wish to seek relief from the
judgment. Under certain circumstances, you have only 30 days in which to file a petition after
papers are served on you. Even if the 30 day rule does not apply, you must act promptly in order
to protect your interests. Failing to act in a timely manner will render you unable to challenge
the judgment at a later time.
Pursuant to 40 Pa. C.S.A. Section 2737.1, if you have been incorrectly identified and had
a confession or judgment entered against you, you are entitled to costs and reasonable attorney
fees as determined by the court.
Respectfully submitted,
McNees Wallace & Nurick LLC
Date: April, 2007 By:
S. Shu ,Esquire
Supr e Court ID #24848
100 Pine Street, PO Box 1166
Harrisburg, PA 17108-1166
(717) 237-5439
Attorneys for Plaintiff
.,
Pennsylvania Rule of Civil Procedure 2959 -Striking off Judgment
(a)(1) Relief from a judgment by confession shall be sought by petition. Except as
provided in subparagraph (2), all grounds for relief whether to strike off the judgment or to open
it must be asserted in a single petition. The petition may be filed in the county in which the
judgment was originally entered, in any county to which the judgment has been transferred or in
any other county in which the sheriff has received a writ of execution directed to the sheriff to
enforce the judgment.
(2) The ground that the waiver of the due process rights of notice and hearing was not
voluntary, intelligent and knowing shall be raised only
(i) in support of a further request for a stay of execution where the court has not
stayed execution despite the timely filing of a petition for relief from the judgment and
the presentation of prima facie evidence of a defense; and
(ii) as provided by Pennsylvania Rule of Civil Procedure 2958.3 or Rule 2973.3.
(3) If written notice is served upon the petitioner pursuant to Rule 2956.1(c)(2) or Rule
2973.1(c), the petition shall be filed within thirty days after such service. Unless the defendant
can demonstrate that there were compelling reasons for the delay, a petition not timely filed shall
be denied.
(b) If the petition states prima facie grounds for relief the court shall issue a rule to show
cause and may grant a stay of proceedings. After being served with a copy of the petition the
plaintiff shall file an answer on or before the return day of the rule. The return day of the rule
shall be fixed by the court by local rule or special order.
(c) A party waives all defenses and objections which are not included in the petition
or answer.
(d) The petition and the rule to show cause and the answer shall be served as
provided in Rule 440.
(e) The court shall dispose of the rule on petition and answer, and on any testimony,
depositions, admissions and other evidence. The court for cause shown may stay proceedings on
the petition insofar as it seeks to open the judgment pending disposition of the application to
strike off the judgment. If evidence is produced which in a jury trial would require the issues to
be submitted to the jury the court shall open the judgment.
(f) The lien of the judgment or of any levy or attachment shall be preserved while the
proceedings to strike off or open the judgment are pending.
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION
PNC BANK, NATIONAL ASSOCIATION, DOCKET NO. (>'7 ~3 ~O ~ ~ ~ ~ ~ ~/L~
Plaintiff
v.
CONFESSION OF JUDGMENT
AVP ENTERPRISE, INC., DBA
UNI-MART,
Defendant :PREVIOUSLY ASSIGNED TO: N/A
NOTICE UNDER RULE 2958.1
OF JUDGMENT AND EXECUTION THEREON
NOTICE OF DEFENDANT'S RIGHTS
TO: AVP Enterprise, Inc., dba Uni-Mart
A judgment in the amount of $752,657.82, plus interest, other expenses, fees and costs has been
entered against you and in favor of the plaintiff without any prior notice or hearing based on a
confession of judgment contained in a written agreement or other paper allegedly signed by you.
The sheriff may take your money or other property to pay the judgment at any time after thirty
(30) days after the date on which this notice is served on you.
You may have legal rights to defeat the judgment or to prevent your money or property from
being taken. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT
AND PRESENT IT TO A JUDGE WITHIN THIRTY (30) DAYS AFTER THE DATE ON
WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
~~
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166 or 1-800-990-9108
Respectfully submitted,
McNees Wallace & Nurick LLC
Date: April~y2007 By:
G . S uff, Esquire
preme C ID #24848
100 Pine Street, PO Box 1166
Harrisburg, PA 17108-1166
(717)237-5439
Attorneys for Plaintiff
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION
PNC BANK, NATIONAL ASSOCIATION, :DOCKET NO. U'7' -a3Sld ~~ v ~L ~c~¢.,~,,,
Plaintiff l
v.
AVP ENTERPRISE, INC., DBA
UNI-MART,
Defendant
:CONFESSION OF JUDGMENT
PREVIOUSLY ASSIGNED TO: N/A
To: AVP Enterprise, Inc., dba Uni-Mart, Defendant
You are hereby notified that on , 2007, judgment by confession was
entered against you in the sum of $752,657.8 ,, in the ove-caption case.
DATE: ~C/~a.3 ~b
Pr onot
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
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166 or 1-800-990-9108
I hereby certify that the following is the address of the Defendant stated in the certificate of
residence:
AVP Enterprise, Inc., dba Uni-Mart
c/o Stephanie A. Slates, President
109 George Street
Enola, PA 17025
i
Atto ,, aintiff
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A, AVP Enterprise, Inc., dba Uni-Mart, Demandado(s)
Por este medio sea avisado que en el dia de de 2007, un fallo por admision fue
registrado contra usted por la contidad de $752,657.82, del caso antes escrito.
Fecha: el dia de de 2007
Protonotario
LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA
EN PERSONA A LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166 or 1-800-990-9108
Por este medio certifico que to siguiente es la direccion del demandado dicho en el
certificado de residencia:
AVP Enterprise, Inc., dba Uni-Mart
c/o Stephanie A. Slates, President
109 George Street
Enola, PA 17025
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CNIL ACTION
PNC BANK, NATIONAL ASSOCIATION, :DOCKET N0.07-2340 Civil Term
Plaintiff
v.
AVP ENTERPRISE, INC., DBA
UNI-MART,
Defendant :PREVIOUSLY ASSIGNED TO: N/A
RETURN OF SERVICE PURSUANT TO
PA. R.C.P. No. 2958.1(c)
CONFESSION OF JUDGMENT
Plaintiff, PNC Bank, National Association, hereby files this Return of Service and swears
and affirms that the person or persons listed below was or were served pursuant to Pa. R.C.P. No.
2958.1(b) with the Notice of Judgment and Execution Required by Rule 2958.1 by certified mail,
return receipt requested, as provided by Pa. R.C.P. No. 403. A copy of each receipt for certified
mail is attached hereto.
AVP Enterprise, Inc., dba Uni-Mart
c/o Stephanie A. Slates, President
109 George Street
Enola, PA 17025
Respectfully submitted,
McNees Wallace & Nurick LLC
Date: May /~, 2007
By:
eo y .Shull, Esquire
r Court ID #24848
100 P' a Street, PO Box 1166
Harrisburg, PA 17108-1166
(717) 237-5439
Attorneys for Plaintiff
~,
?160 391 9849 971$ 4671
Tp• AVP Enterprise, Inc., dba Uni-Mart
• c/o Stephanie A. Slates, President
109 George Street
~ Enola, PA 17025
SENDER: Geoffrey S. Shull
REFERENCE~NC Bank
RETURN Postage
RECEIPT ~~~ ~
SERVICE b
Return Receipt Fee ~
Restricted Delivery
Total Postage $ Fees. ~ ,
US POS~II Service
Receipt for moo,
Certified Mail °~ ~~
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No Insurance Cowraps Provided ~
Do Not use for Intamational frlail ,
gpeeM
~ddreseee
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Geoffrey S. Shuff
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