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HomeMy WebLinkAbout07-5014j `._ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, DOCKET NO. d7 - ~Ot~f ~ iv1 l ~ ~,rm Plaintiff v. CONFESSION OF JUDGMENT SHAIR KHOKHAR AND HELENA KHOKHAR, Defendants :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 appeaz for the Defendants and confess judgment in favor of the Plaintiff and against the Defendants as follows: a. Principal $419,741.03 b. Interest to August 13, 2007 $ 41,592.65 c. Late Chazges $ 4,642.33 d. UCC Seazch Fees $ 92.00 e. Property Seazch Fees $ 102.50 f. Attorneys' Fees 40,133.37 TOTAL: $512,303.88, plus interest, other expenses, fees and costs Respectfully submitted, McNees Wallace & Nurick LLC Date: August 2007 By: Esquire reme Court ID #24848 100 Pine 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, :DOCKET NO. ~ 9- ,~ o ! y ~ `J-~ Plaintiff v. SHAIR KHOKHAR AND HELENA KHOKHAR, Defendants CONFESSION OF JUDGMENT 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 201 Penn Avenue, Scranton, PA 18503 (the "Plaintiff"). 2. The Defendants, Shair Khokhar and Helena Khokhar, are adult individuals whose last known address is 112 Baros Street, Fairfield, CT 06824 (the "Defendants"). 3. The Defendants executed and delivered to the Plaintiff a U.S. Small Business Administration Unconditional Guarantee (the "Guarantee"), a true and convect photostatic reproduction of the original of which is attached hereto as Exhibit "A" and made a part hereof. 4. Under the Guarantee, the Defendants guaranteed to the Plaintiff the payment of all amounts due to the Plaintiff by Sun & Moon Enterprise, LLC, dba Uni-Mart (the "Debtor") under a U.S. Small Business Administration Note dated May 13, 2005, in the original principal amount of Four Hundred Forty-Five Thousand Dollars ($445,000) (the "Note"), a true and convect photostatic reproduction of the original of which is attached hereto as Exhibit "B" and made a part hereof. 5. The Defendants executed and delivered to the Plaintiff a Disclosure for Confession t ~ of Judgment (the "Disclosure for Confession"), a true and correct photostatic reproduction of the original of which is attached hereto as Exhibit "C" and made a part hereof. 6. The Debtor is in default of the Debtor's obligations to make payment to the Plaintiff as required in the Note and the Defendants are in default of the Defendants' obligations to make payment to the Plaintiff under the Guazantee. As a result of the Debtor's and the Defendants' defaults, the Plaintiff has demanded payment of all outstanding amounts as provided in the Note, which are now due and payable in full. A copy of the Plaintiffs demand dated April 6, 2007, is attached hereto as Exhibit "D" and made a part hereof. 7. Judgment is not being entered by confession against a natural person in connection with a consumer credit transaction. 8. There has not been any assignment of the Guarantee or the Note. 9. Judgment has not been entered on the Guarantee in any jurisdiction. 10. An itemized computation of the amount due to the Plaintiff by the Defendants as a result of the Defendants' defaults under the Guazantee is as follows: a. Principal $419,741.03 b. Interest to August 13, 2007 $ 41,592.65 c. Late Chazges $ 4642.33 ~ d. UCC Seazch Fees $ 92.00 e. Property Search Fees $ 102.50 f. Attorneys' Fees 4fi ~ ~~ ~~ TOTAL DUE: $512,303.88 11. Interest continues to accrue at a rate equal to the Prime Rate published in the Wall ~tr~t Tnnrnal~ ply two and one-half percent (2.50%), adjusted quarterly. WHEREFORE, Plaintiff, PNC Bank, National Association, demands judgment against the Defendants, Shair Khokhaz and Helena Khokhaz, in the amount of Five Hundred Twelve Thousand Three Hundred Three and 88/100 Dollazs ($512,303.88), plus interest at a rate equal to the Prime Rate published in the wall stmt i~„,~,~~~ ply two and one-half percent (2.50%), adjusted quarterly, 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, McNees Wallace & Nurick LLC Date: August, 2007 By; ~~' uff, Esquire e C urt ID #24848 100 Pine 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. SHAIR KHOKHAR AND HELENA KHOKHAR, Defendants DOCKET NO. CONFESSION OF JUDGMENT PREVIOUSLY ASSIGNED TO: N/A VERIFICATION I, Kyra E. Zoranski, Assistant 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: By; ~~ ~ ~ ~~ Kyra r 1 "` ~~~ 1 Assistant Vice President U.S. Small Business Administration UNCO!ND1T1aNA~ GUARANTEE SBA Loan ~! PLP Sfi301840-07 SBA Loan Name Unl-Mart Guarantor Shtair Khokhar Helena Khok#ar Borrower Sun & Moon Enterprise LLC dba Uni-Mart Lender PNC Bank, National Association Date Note Amoun# 445,000.00 t. GUARANTEE: Guarantor unconditiona#ly guarantees payment to Ltndcr of a#t amounts awing under the Note. This Guarantee remains in effect until the Note is paid in fait. Guarantor must pay all amounts due under the Note when Lender makes written demand upon Guarantor. Lender 'rs not requirad to seek payment from any other source before demanding payment from Guarantor. ?. NOTE: The "Nate" is the promissory note dated ~ in the principal amount of Four Hu~rec# Forty Fins Thousand - ------------00!100 Dollars, from Borrower to Lender. It includes any assumption, renewal, substitution. or replacement of the Note, and multiple notes under a line of credit. 3. DEFINITIONS: "Collateral" moans any propem,? taken as security for payment of the Note or any guarantee of the Note. `"l,,oan" means tl7c loan evidenced by the Note. "Caen Documents" means the documents related to the !,lean signed by Borrower, Guarantor ar any other guarantor, or anyone who pledges Collateral. "SBA" means the Small Business Administration, an Agency nfthe United States of America. SBA. Form io8 {tt)t!}8} Previous etlitions obaaaatt. Pps 1!5 Hankers Systems. #nc., St. C#oud, MN k ~ ~~ bit- << ~,~ ~. LF.'vDER'S GENERAI, PQWERS: Lender may take any of the fallowing actions at any time, without notice, without Guarantor's constnt, and without making demand upon Guarantor. A. Modify the terms of the Nate or any other Loan Document txcept to increase the amounts due under the Note; B. Refrain from taking any action on the Nott, ChC Collateral, or any guatarttee; C. Release any Borrower ar any guarantor of the Note; D. Compromise or settle with the Borrower ar any guarantor of the Note; E. Substitute or release any of the Collateral, whether or not Lender receives anything in return; F. Foreclose upon or otherwise obtain, and dispose of, any Coltatemt at public or private sett, with or without advertisement; G. Bid or buy at any sale of Collateral by IxHder or any other lenhnlder, at any price Lender chooses; and H. Exercise any rights it has, including those in the Nate and other Loath Documents. These actions will not release ar reduce the obligations of Guarantor or create any rights or claims against Lender. 5. FEDERAL LAW: When SBA is the holder, the Note and this Guarantee will be construed and enforced under federal law, including SBA rogutations. Lender or SBA may use state ar local procedures for filing papers, recording documents, giving Halite, foreclosing liens, and other purposes. By using such procedures, SBA does Hot. waive any federal immunity from stets or Local control, penalty, tax, or liability. As to this Guarantee, Guarantor may not claim or assert any local or state taw against SBA to deny any obligation, defeat any claim of SBA, or preempt federal law. 6. RIGHTS, NgT1CE5, AND D£FENSIaS'C'HAT GUARANTgR WAIVES: To the extent. permitted by law, A. Guarantor waives all rights tn: 1) Require presentmcm, protest, nr demand upon Harrower; 2} Redeem any Collateral before or after Lender disposes of it; 3) Have any disposition of Collateral advertised; and 4) Require a valuation of Collateral before or after lJcnder disposes of it. B. Guarantor waives any notice of: l } Any default under the Note; 2) Presentment, dishonnr, protest, or demand; 3} Execution of the ?vote; 4} Any action or inaction on the Nate or Collateral, such as disbutsement.5, payment, nonpayment, acceleration. intent to accelerate, assignment, collection activity, and incurring enforcement expenses; 5} Any change in the financial condition or business operations of Borrower or any guarantor; 6} Any changes in the terms of the Nate or other loan Documents, except increases in the amounts due under the Note; and 7) The time or place of any sale or other disposition of Collateral. C. Guarantor waives defenses based upnn any claim that; l} tender failed to obtain any guarantee; 2) Lender failed to obtain, perfect, or maintain a security interest in any property offered or taken as Collateral; 3) Lender ar others improperly valued or inspected the Collateral; 4) The Collateral changed in value, or was neglected, lost, destroyed, or underinsured; SBA Form 148 {70/98} Pnwioua Wftionn obsakte. Pepe 215 Bankers Systems, Inc., St. Cloud, MN S) Lender impaired the Col}ateral; 6) Lander did net dispose of any of the Collateral; 7) Lender did nat catnduct a cammerciatly reasonable salt; 8) Lender did not obtain the fair market value of the Collateral; 9) Lender did »ot make or pert'ect a etaim upon the death ar disabiLtty of Borrower ar any guarantor of the Note; tt3) The financial condition of Borrower or any guarantor was overstated or has adversely changed; L }) I.,endcr made errors ar omissions in Loan Documents ar administration of the Loan; 12) Lender did not seek payment from the Borrower, any ether guarantors, or any Collateral before demanding payment from Guarantor: 13) Lender impaired Guarantor's suretyship rights; l4) Lender modified the Note terms, ether than to increase amounts due under the Note. IfLender modifies the Note to increase the amounts due under the Note without Guarantor's co»sent, Guarantor will not be Liable far the increased amounts and related interest and expenses, but remains liable for all other amou»ts; I S) Banawer has avoided liability an the Nate; or 6) Lender has taken an action allowed under the Nate, ibis Guarantee, ar other iaan documents. ~. DUTIES AS TO COLLATERAL: Guarantor will preserve the Gallatera! pledged by Guarantor to secure this Guarantee. Lender leas na duty to preserve ar dispose of am Collateral. $. SUCCESSORS AND ASSIGNS: tt'nder this Guarantee, Guarantor includes heirs and successors, and Lender includes its successers and assigns. 9. GE?gERAL PROVISIONS: A. F~iFC}RCEMENT EXAI:NSES. Guarantor premises to pay all expenses Lender incurs to enforce this Gttarantte, including, but not Limited ta, attorney's fees and casts.. B. SBA NOT A CO-GUARANTOR. Guarantor's liability will continue Gwen if SBA pays Lender. SBA is not a co-guarantor with Guarantor. Guarantor has no right of contribution from SBA. C. SUBROGATION RLG}iTS. Guarantor has no subrogation rights as to the Nate or the Collateral until the Nate is paid in full. Q )OIN"1" AND SE~%CRAL LIABILI"t'1'. All individuals and entities signing as Guarantor arc jointly end severally }table. 1. >~OCt1M.F..NT SIGNING. Guarantor 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. F. FINANCIAL 5TA'fE'A9EiVTS. Guarantor mast give Lender financial statements as Lender requires. G. LENDER'S IZIGNTS CUM'ULA'I7VE, NOT WAIVED. Lender may exercise any of its rights separately or together, as many times as it chooses. Lander may delay ar forge enforcing arty of its rights without lasing or impairing any of them. I.1. ORAL STATEMENTS NOT BINDING. Guarantor may net use an era! statement to contradict or alter the written terms of the Note or this Guarantee, ar to raise a defense to this Guarantee. 1. SEVERr1BILITY'. if any part of this Guarantee is found to be unenforceable, all other parts will remain in tflect, 1. CONSIDERATION. The eonsideratian for this Guarantee is the Loan or any accommodation by bender as to the Loan. SBA form t48 {tplBB) Prevbus edkMons ot~ofete. Page ~ Bankers Systems, tnc., St. Cloud, MN 10. STATE-SPECIFIC PR©VlSIONS: 1. POWER TO CONFESS JUDGMENT. UNDERSIGNED NEREBY EMPOWERS ANY ATTORNEY OF ANY COURT OF RECORD, AT ANY TIME AFTER THE OCCURRENCE pF ANY EVENT OF DEFAULT HEREUNDER, TO APPEAR FOR THE UNDERSIGNED AND, WITH OR WITHOUT CbMQLA1NT 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 GUARANTY, ALL ACCRUED INTEREST AND ALL OTHER AMOUNTS DUE HEREUNDER, TOGETHER WITH COSTS OF SUIT AND AN ATTORNEY'S COMMISSION OF 10°k OF SUCH PRINCIPAL AND INTEREST ADDED AS A REASONABLE ATTORNEY'S FEE, AND FOR DOING S0, THIS GUARANTY OR A COPY VERIFIED BY AFFIDAVIT SHALL BE A SUFFICIENT WARRANT. THE UNDERSIGNED HERESY 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 MAY BE EXERCISED FROM TIME TO TIME AS OFTEN AS THE LENDER SHALL ELECT UNTEL SUCH TIME AS THE (ENDER SHALL HAVE RECEIVED PAYMENT IN FULL OF THE DEBT, INTEREST, COSTS AND FEES. ', 2. Governing Law: Jurisdiction. This Guaranty 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 tits Commonwealth of Pennsylvania and the United States DkStrirt Court far the East®m District of Pennsylvania; provided that. nothing contained in this Guaranty will prevent the Lender or any hour hereof ftom bringing any action, enforcing any award or jtxlgment or exercising any rights against the Untlerstgned, 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 f~ both the Lender and the Undersigned and the Undersigned waives any objection to venue and any objection based on a more convenient forum in arty action instituted under this Guaranty. The Undersigned agrees that service of process in any such proceeding may be duly effected upon the Undersigned by ma'sGng 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 GUARANTY, ANY DOCUMENTS EXECUTED IN CONNECTION WITH THIS GUARANTY OR ANY TRANSACTION CONTEMPLATED IN ANY OF SUCH DOCUMENTS. THE UNDERSIGNED ACKNOWLEDGES THAT THE FOREGOING WAIVER IS KNOWING AND VOLUNTARY. This guaranty is also secured by a fourth mortgage an land and improvements Dated at 112 Baros Street Fairfield, CT 0682A. SaA Porte ts8 (to/ge3 P~b+i6 sdkbns obsdete. Paps 4/5 Bankers Systems. Inc., Si. Cloud, MN l t . C,UARANTOR ACKNO'N-'LEDGMENT OF TERMS. Guarantor acknowledges that Guarantor hss read and understands the significance of all terms of the Note and this Guarantee, including a!! waivers, 1'?. GUARANTOR NAMES) AND SIGNATURES}: By signing below, each individual or entity becomes obligated as Guarantor under this Guarantee. N.. Shair Khokhar ~, ;~ . Helena Khokhar S6A Fam 7<9 {7tU8H) PrcVrotrs edgtona otmdsia. Page S/5 Bankers Systems, lnc., St. Cloud, MN a U.S. $TiIAtI Btt$1ttCSS t~1t11121t12St1'8.x1o13 NOTE sBA loan ~ ~~ t3s~a~saaoT SBA loan tJatttm ~ Dale .- -- Loan Amount 445,000.00 ` Interest Rate FkaaUng at WSJ Prime plus 2.5046 resuith~g In an 'rnlllai rate tat 8.0046 Bom3wer Sun b Wi00n Entei~fG6a LLC dba tJnl-Mart Oper~g Company lender PNC Bank, National Assaaation 1. PRAA3ISE TO PAY: In return for the Loaa, 8arsowcr prontisas to pay to dte ardex of Lender the at»oant of Four Htuxtrad Forty Five Th ----•-~ ....^ Dollars, interest tm the unpaid prinoipat balnttcx, and all other amoants r+eriuired by this Note. 2 DEFINITIONS: "Collaroentr° mesas say property taktm as security for payment oft]tLR Nora or any guarantu of this Note. "fluarentot°' means each person or cniity that sighs a guatsatee of payment of this Note, "Loan" means ttte loan evidenced by Chia Nou. "Caen Documents" mesas the documettu related to this Loan signal by Botmvwer, aaty Gaazarttor, or arryotu who pkdgts catlaterai. "SBA" means the SmaQ Busiaeas Administration, an Agency of the Llsited States of America. 98A t"«ats, t4r (ealp3i02) Venlon 4.1 ~. »s Bankers Systerna, lnc., St. Ckwd, MN ~ ~7 ~c l,~ ~ 1~, tit' ~3 ~. PAYMEP3T TERMS: $om>wer ravel make aU payments at the place Lander dtxig~tes. The paymcttt tant}a for this Note are: This !Vote will mature in 10 years nom date of Note. The inteteest n;rte on dais Nate will fluctuate. The iNtlal interest rate ~ 8.00°k per year.. This init~l rate is the prime rate on the date SSA received the loan appiica~ion, plus 2.50%. The initial iMere~ cafe must r'ernain in effect until the first change period begins.. Born>wer must pay prindpai and interest patymerrta ot` S$,708.33 every month, tsspinn~tg one mor>th finarr the month ,this Nate is dated; payments must be made on the fast calendar day in the months they air+e due. Lender will apply each installment payment fait to pay interest accrued to the day Lender n>:oeives the payment, then to bring principal cumard, then to pay any late fees, and will apply any remaining balanas bo reduce the princ~ai. The interest rate will be adjusted quarterly {the "change period"}. The "Prirrre Rafe" is the prune rate in effect on the first business day of the rrrorrth in which an interest rate change occurs, as published in the Walt Street Joumai on the next business clay. The adjusted snteresf rate viii be 2.50% above ilia Prime Rate. Lender wlll adjust the interest nave on the first calendar day of each change pericxl, The change in Merest rate is effective on dot day whether or net Lender gives Borrower notice of the mange. Lender must adjust the payment amount at least annually as needed to amortize princ~al over the remaining term of the note. if S6A purchases the guaranteed poRion of the ur~d principal balance, the interest rate becorrtes fbced at the rate in effect a# the time of the earliest uncured payma~nt default. ff there is no uncured payment dt3fau~, the rate becomes fixed at the rye in effect at the time ~ purchase. Notwkhstanc~ig any provision in this Note to the contrary: Borrower may prepay this Nate. >SOrrower rr-a}r prepay 70 percent err less of the unpaid principal balance ~ any time wRhout notice. K Bonower prepays mote than 20 percent and the Loan has been soil on the secondary market, Borrower must: (a } G'nre Lernier wrftfen notice, (b.) Pay all acenred ir~erast~ and {c.) !f prepeyrr-ent is reeoeived less than 21 days from the date Lender receives the notice, pay an amours equal to 21 days' intereest from the date Lender receives tt~ notice. less any interest accued durkrg the 21 days and paid under subparagra~rh b., above. H' Borrower does n~ prepay within 30 days from the date Lender receives the notice, Bc-rr+ayver must give Lender a new notice. All remaining principal and accrued interest is due and payable 10 years from date of l+~e. Late Charge: If a payment on th~ !Nate is more than 10 days late, Lender may charge Borrower a late #~ of up to 595 of the ur~sid portion of tfks regularly scheduled payment. ~ Foam 1~7' i Version 4.t Asge yg Bankers Sysbcma, Inc., St Cloud, tNN ~. DEFAULT: Botiower is in default under this Nate 3f Borrt~wor does myt make a pay-nent when d+x uoder tlxls Note, ar ifBrurower or 8penttiug Courpetty: A. Fai3s to do atrything mquirad by Cilia Note amd other Loan Doak; B. Defaults on any other Iona with Lender, G Does not preserve, or account to Lender's satist~ion for, any of the Collateral or its proceeds; D. Does not disclose, cn anyone aaittg on their behalf doss not dfaelo~„ any m~erial littx to Lender or SBA; >w Makes. or arryone acting on Chair behalfmakes, a m~erially Seise of misleading ration to Lauder or SBA; F. Defaults on airy loss or t with another ereditor, ifLertder beltavea the dali-utt may materially affect Borrower's ability W pay this Note,; G. Fails to pay any tames wheys dae; H Becomes the subject of a proceeding under any bankrssptcy or Inmlvency law; I. Has a reaetver or lirluidator appointed for any part of their busittcss or property; J. tbiakes an assigrsrssent for Cho benefit of creditors; I{. Has any adverse citangc in financial condition or business operrxion that Lender believes may materially af'&ct Borrower's ability to pay this Note; L. Reorganizes, merges, cosssotidates, or otherwise changes ownership or business straciure without L,ezsder's prior writrers conseni; or 'vi. Becomes the subject of a civil or crirnlnai action Chet Lender believes may materially affect Borrower's ability to pay taus ?dote. ~. Lt?,1dDER'S ~~~ ~ THERE IS A DEFAULT: Without notice or dem~sd and without giving up any of Its rig}tts, Lender may: A. Regain ittunediate paynsast of all amounts owing under this Note, B. Called alI amoants ow}tsg from ~„y B©mower or Guarantor, C. Fite suit atMi obtaits jtztfgmeat; D. Take possession of any C.altateral; or E. Sell, lease, ar otherwise dispose os any Collateral at pisbile or private sale„ with cr without advertisement 6. LENDER`S GENERAI, POWERS: W4thoat notice and without &ss'rower's costsezt#, Lander may: A. $id ors or bay the Collateral at tts safe ar the sale of myother lienholrler, ai ffity price It chooses; B. Incur expesssea to collaa amounts dae under this Note, en:tbrcc Ilse tezms of this Nora or any other Loan Document, and preserve or dispose of tt~ Collateral. Among other things, the rxpenses may is~Ia~ payments for pmparty taxes, prior tiaras, izssurattce, appraisals, onvrronmetstal rernadiation costs, arsd reasonabtc attorney's . fees and costs. If Lender ir~urs 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, reteasa, resew, extend or substittm arty of the Collateral; and E. Take arty action necessary to protect the Collateral or eofIeet amounts owing on this Note. SBA FCttti 147 (tlBleJPO'2) Vllaioaf 4.1 AaQlt S16 Bantcers Systems, Its, SL Cloud, Mt+t 7. WHEN FEDERAL. LAW APPLIES: When SBA is the holder, this Note will be lntetpreted arsd eaforcal under fedsxa2 law, including SBA rogations. Ltader or SBA may ust state or !oral proeedut~t fbc 61utg papas, recxir~iitxg documents, givhtg noticq foredasing liens, and other purposes. By using such procxdura, SBA does not waive any federal immunity ilrom state ar local control, penalty, ~ or liability. As tD this Note, Borr+~wer may not claim or assert against SBA any local or state law to deny any obligation, defeat any claim of SBA, ar pt+eemp+t federal law. $. SUCCESSORS AND ASSIGNS: Under this Note, Borrower and Opera9ng Company include the successors of each, and Lender includes its strcce~rs and assigns. 9. GF.NERAi, PItOVISI02d~S: A. All individuals atd entities signing this Note are jointly and ~trtrally Liable. B. Borrower waives alt suretyship defe»ses. C. Borrower must sign aIL docttrnams necessary at any lima to comply with the Loan Docurrtents and to arable Louder to esquire, perfect, or mairrtain Lender's liens on Collateral. D. Lender may exercise any of its rights separately or together, as many times aril in any order it doses. Lender may delay or fiorgo enforcing any of its rights wIthwrt giving up any of them. iw Borrower may not use an oral statement of Lendw or SBA to contradict or alttx the written terms of this Note. P. If arty pert of this Noto is unenforpeable, all other parts remain in effect G. To the extern allowed by law, Borrower waives ail demands and notice in connection with this Note, including ptzseaunent, demand, protest, and notice of dishonor. $orrower also waives any defatses based upon arty claim That Lender did not obtain any guarantor; did not obtain, perfect, or maintain a nett upon Collateral; itttpairaL Collateral; oz did not obtain dte fair utarket value of Collateral at a sale. SSA Farr 147 (tIBH)Sr6?1 VertiDn 4.7 Pspe 4/8 Bankers Systems, Inc,, St Cloud, iiAN I ©. STATErSPT3Gi~'1C PROVISIONS: 1. POWER TO CONFESS JUDGMENT> tNDERSIGNED HEREBY EMPOWERS ANY ATTORNEY OF ANY COURT OF RECORD, AT ANDY T~uIE AFTER THE OCCURRENCE OF ANY EVENT OF DEFAULT HEREUNDER, TO APPEAR FOR T'HE UNt~ERSiC;NED AND, Wt'Fti OR WITFtOUT COMPLAINT FILED, CONFESS JUDGMENT, OR A SERIES OF,JUDt31u~NTS, At3AINST THE UNDERSIGNED OV FAVOR OF THE LENDER OR AhtY HOLDER HEREOF FOR't'HE ENTIRE PRINCIPAL BALAIVC# OF Ttti5 NOTE, ALL ACCRUED INTEREST AND ALL OTHER AMOUNTS DUE HEREUNDER, TOGETHER U1flTH COSTS OF SUIT APIA AN AT'TORNEY`S COMMI85tON OF 1096 OF SUCH PRINCIPAL AND INTEREST ADDED AS A REASONABLE ATTORt~I"S FEE, At+E1 FOR GOING SO, THtS NOTE OR A COPY VERIFIED BY AFFEDAVIT SHALL BE A SUFFICIENT WARRANT. THE UNaERSIGNED HEREBY FOREVER WAIVES AND RELEASES ALL ERRORS IN SAID PROGEEaIAICiS AND ALL Rlt3tiT8 OF APPEAL AND ALL Rt1IEF FROM ANtY AND ALL APPRAt$EMENT, STAY OR EXEMPTION LAWS OF AM' STATE NOVV tN FORCE OR HEREAF'T'ER ENACTED, JUDGMENT MAY BE CONFESSED FROM TIME TO TIME UNDER THE AFORESAID POWER TO CONFE55 JUDGMENT ANa NO SINGLE EXERCISE OF THE FOREGOINt3 POWER TO CONFESS JUDCG3MMENT, OR A SERIES OF JUDGMENTS, SHALL BE DEEMED 70 EXHAUST THE POWER, WHETHER OR NOT ANY SUCH EXERCISE SHALL t3E HELT3 8Y ANY COURT TO BE ItVVAUD, VOIDA6LE, OR VOID. BUT THE POWER SHALL CONTINUE UNDIMtNiSHEO AND iT MAY BE 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, tMEREST, COSTS AND FEES. 2, Governing LaW; Jurisdiction. Thla Note wfq ire interpreted and the rights and liabilities of the parties herein determined in aoeordance with the furs of the Commonwealth of Pennsylvania, exdud'mg its cantk~ of taws rides. The Undersigned hereby irrevocably conser>xs to the exclusive jur~dic#son of the Courts of Common Pleas of the Commonwealth of Penneylvarua and the United States District Cant tot the F~em District of Pannsyhrenla; provided that nothing contained in this Note wiq prevent the Lender ar arry holder hereof from bringing any action, enforcring any awarci or judgrnarrt or exerc~Ing any right agalnR the Undersigned, agetcrst any s8curtiy or sgairat arty prapeny of the Undersigned within any other county, state ar other foreign or domestic jurisdrtior-. The Undaraigr>esi agrees that the mnue provided shave is #hs mosi convsni+ent fons7t for br~lt tfm Lender end the Undersigned and the Undersigned waives any objection to venue and any ot~jection based on a more convenient forum in any action instlluted under this Nate. The Undersigned agrees that service of process in any such prooeading may be duly sifscbed open the Undersigned b1' mailing a oapy thareot bN registered mall, postage prepaid, to the Unders~r~ed. 3. WAIVER OF JURY TRIAL. THE UNDERSIGNED IRREVOCABLY WAIVES ANY AND ALL RIGHTS THE UNDERSIGNED MAY HAVE TO A TRIAL BY JURY IN ANYACTION, PROCEEDINC3 OR CLAIM OF ANY NATURE RELATit~, TO THIS NOTE, ANY DOCUMENTS [DCECUTED IN CONNECTION WITH TNtS NOTE OR ANY TRANSACTION C~ITEMPiATtD IN ANY OF SUCH DOCUMENTS. THE UNDERSIGNED ACKNOWLEDt3E5 THAT THE FOREGOING WAIVER IS KNOIMNG AND VOLUNTARY. se,a rwm ~.t {oesmto2l vaawn a.r v~ ere Bardcers Systems, tnc., 5t. Gard, MN i I. $dRttd'WER'5 NAME{5} AI~iD SIGNA'IVitE(5}; By signing betcnv, each individual or ea~tity btcamcs abiigaaed undor this Nnu as Barrawer. Sum & Moan Em Lt.G di5a Uric-h+tart See a~matura papa attached S9P. Faem t<7 {o8wo,~ V~ntloN t.t Paps @/6 t3anicere Syat~ts, inc., St. Claud, RAN ~. C~GNATUItE PA+GE• SUN .~ M+dON ENTERPRI5~ LLC dDa CTNI--MART ' ,~• ~,rC..•~ ~~. s . DER ~~ ~ ~~ ~xoxa, MEMBER ~~' Disclosure fur Confession of Judgment PN'C~~t~. (Guarnntor) U~xler~aed: ANA KHOKHAtt ll8 ~~ GRE~1 SPAMFORD, CT 46903 Fender. PNC BANK, NATIdtYAL CATION $804 TIMCUM lltliTLIGVARD FfiiLAbELFAtA, FA 19153 The tmdatsigned has exanuted, antUor is executfngr on or xbaut the date herea>7 a US Smail B Ammon auarautj+ and Com~a+ciat t3naranty, in reaped of the obi owed to I.e+edAr by SUN dt MOON:t3N1'SRPRYSE LL+C dba UNC- MART ceder which the wed is abligatect to Y marries ~ Lamder. A. TsE LR~GNm ACJQVpWl,L~'t1~GEt3 AND AGREES THAT T~ ABQVE ~ COtVi'At~ ~i+is UPiDER WIiN~LES'fD~blAY~l8R3rJDG1~N'CBYCf3TtF€SB[ONAGAIl~iSIt'~'[lI~~SIQ~RQ. BOiLYAW+iSR+O!-ll~ItiGHT5'l+p PittQR NO'i[CEAND A DING OI~T'[Z;E VAW,DrIYOFAi~iY]IJ~dr7'~ (~'THYR CLA@I~6 TBATMAYaRA~'TmAGAH+I~' R SY I+ECIDERTVDERttE,~WGIID~TYS E~ TBE ~Di~t~1lt#~EEL.Y, It~tO'Wl1MCD.XATVDMCIIi,FG'F,N'TLY YVA1vE8 TBB~ 1E AND EXlAE~I,Y AGItZES AND 13ONSLNT$ 10 Lt?xVD~t'$ ?M$1tdtYC~ JUDGMT;Nf AGAINST 1T SY C"dTOPt PURSUANT TO TH1: TERMS T;4~R8O8. $. TSE tJtMDERSIGNED AL$O ACKNC?WL6DG6S AND A 'I`9AT TSE A8OVE DO(:ftiVffiNT K.`ONTAAP$ !RO'(+!&tONS ~ lJiVDER WBL(8 LE1"tDlCR MAY, AFTER F.N1RY OF JUDGMENT AND WIT'tYt/U1' A7t'Niit 2'tO1TCE OR A HGRHr~ ~ UPON, A'Y'i'ACH,LBVY,tATt1t ~OHt1TRE~lWMEBESiP~PE'RTYOFTBE'CIEDflMI~[)LL,ORPAItTIALPAYbdiM'4F THE JUDGMElY1: t3E[N6 FULLY AWARE OF 1T$1tIGSTIS AFTER JOD~iT ffi ~ ~llYCitlDpYt3 TIC RtGBT TO ML>V8 TO - Ol'gNC1~S~?$S~J[JD!'MRNT}~T;~UiYDfC»GM6DHEREBYFBB~i.Y.1QVOt9VIItNGt.YA3~[~LLiGENTLYWAIVIB?YIIRICG'1'$ t TO NOTICE AND A BEARING AND ttxF"RESSlY AGR~ AND tANSE~YtfiB TO LENDER'S TAtONG 8008 ACliOt+~ AS MAY BE - PERM1'I'I'Fi~D i1l+tlfER APPWCABLE STATE AND FEDERAL 1.AW Wi18(11JT 1'R1OR tMO1Tt:B TO TSL it(+NED. C, TIC 1~iti0[b~ GEES t~lHt a 3'dpC'VlE 4f~.GLdi~' ~ej~+~jl0d t~i0 C0i0Et O~jtid, pL~DV13~0~ IQ the above docetmeniit> du ttoa ofthe undersigned, ~lor that the tm~aigned was meted by legal counsel m cation with the above document. D. The und~s~aed hdreby txrtirq~: that its annual iacodttu axcroeds 514,000; stmt all ~ ~ tau undersigned above refer to all persons sad entities signing betaw; and that the undersigned roceivod a cop?+ hereof at fire tuna of signing.. ~~~ . C,•1UOCUMFr1tFE19S831T OCAI.S•-I1TesnplC.Noh~.D~talaouf.~areatordoc Forot 9C - t?A Rev. 3t'99 ~ ~- ~ + .. ~~ ~ ~ Apri16, 2007 Gcrtifed and Regular Mail Sun & Maan Enterprises,. LLC 101 Bridge Street Jersey Shore, Pennsylvania 17740 1VIr. & Mrs. Shah Khakhar 112 Baros Street Fairfield, Connecticut 06824 RE: Loan.#31894835/602554346 17ear Mr. & Nirs. Khokhar: Sun & Moon Enterprises, LLC, and you are in default of your obligations to PNC Bank (the "Bank") far failure to make payments an the $445,000 loan {the "Loan") as required in the Prvmissvey Note that evidences the Loan and the Guaranty Agreement{s) that secures the I,aan. As a result of the default of your obligations tv the Bank, the entire outstanding amount of the Loan has been accelerated and is now due and payable immediately in full. The amounts that are due and payable to the Bank are as follows: Principal $4l 9,741.03 Interest $ 30,531.18 {as of4/3/07) Late Charges $ 3.239.40 Total $453,511.61 .Interest continues to accrue at the rate of $123.62 per day through the date an which payment is received by the Bank. In addition to the amounts set forth above, you will be responsible for payment yr reimbursement to the Bank for all attorneys' fees incurred or paid by the Bank with respect to this matter. .Please make arrangements far payment. in full af' yvur vbligatians to the Bank. by contacting the Bank, as follows: Kyra E, Ioranski Assistant Vice President 201 Penn Avenue Scranton, PA 18503 Phone: {570) 961-6266 Fax: {570) 961-6240 Mearr6er oPTh~ PNG ~ir;anci8l Sesvicsx tarou~ fC ~\ ~~~~~~t ~ t` ~ ~ ~ ~&~~ ~ Neither this letter nor anything contained herein waives, limits or otherwise affects in any way the Bank's rights to exercise and enforce ita rights and remedies for collection of yoar obligations to the Bank, ail of which are reserved by the Bank, and remain in full farce and effect, enforceable by the $ank at any time on or after the date of this letter. We look forr~~ard to receiving payment in full of your obligations to the Bank in the immediate future. (hherwise, the Bank may have no alternative but to initiate collection proceedings. Ii' you have any questions please call meat 5701-961-6266. Thank you in advance for your cooperation in this matter. Sincerely, ,. , ~ , -~..~.. ,~ Kyra E. Zoranski ~`F Assistant Vice Present ~„ ,~, ~ r..s ~ - , O ~ J ~ ~"; ~ ° ' c: ~' * _ - ~~~ O ' = rv ~ ~~ ¢j ..-` ~ ~ .~ t t'1 N J~ ~ ~ ' ` ~~. ,;;~ Ca ~ t, 1 ~ ~ `'i) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, DOCKET NO. D? ~'~i vi f ~ e~M Plaintiff ~• :CONFESSION OF JUDGMENT SHAIIt KHOKHAR AND HELENA KHOKHAR, Defendants :PREVIOUSLY ASSIGNED TO: N/A To: Shair Khokhaz and Helena Khokhaz, Defendants You are hereby notified that on 8~~~07 , 2007, judgment by confession was entered against you in the sum of $512,303.88, in the ab -captioned case. DATE: P~2 ~l D l r thonotary 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 Baz 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 Defendants stated in the certificate of residence: Shair Khokhar and Helena Khokhaz 112 Bazos Street Fairfield, CT 06824 Atto a ti A, Shair Khokhaz and Helena Khokhaz, Demandado(s) Por este medio sea avisado que en el dia de de 2007, un fallo por admision fine registrado contra usted por la contidad de $512,303.88, 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 Baz Association 32 South Bedford Street Cazlisle, PA 17013 (717) 249-3166 or 1-800-990-9108 Por este medio certifico que to siguiente es la direction del demandado dicho en el certificado de residencia: Shair Khokhaz and Helena Khokhaz 112 Baros Street Fairfield, CT 06824 Abog te(s) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVII, ACTION PNC BANK, NATIONAL ASSOCIATION, : bOCKET NO. UZ • 501y l:~ v, ('(',era, Plaintiff ~• :CONFESSION OF JUDGMENT SHAIR KHOKHAR AND HELENA : KHOKHAR, . Defendants :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 Respectfully submitted, McNees Wallace & Nurick LLC _ ~, Date: August ~~ 2007 By; S Court II3 #24848 1 ine Street, PO Box 1166 Harrisburg, PA 17108-1166 (717) 237-5439 Attorneys for Plaintiff C ~w o ~~ ~~, ~ -'>' ~ N c--~ ~ . N ,; -_ `' ;'- "c`~ ~ -~ O .~ _C' COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, :DOCKET NO. O'1- 5c>I~ Civ~ I t~rr~, Plaintiff v. CONFESSION OF JUDGMENT SHAIR KHOKHAR AND HELENA . KHOKHAR, Defendants :PREVIOUSLY ASSIGNED TO: N/A NOTICE UNDER RULE 2958.1 OF JUDGMENT AND EXECUTION THEREON NOTICE OF DEFENDANT'S RIGHTS TO: Shair Khokhar and Helena Khokhar A judgment in the amount of $512,303.88, 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 & Nur~ck LLC Date: August ~, 2007 By: Geo . Shu ,Esquire preme Court ID #24848 100 Pine Street, PO Box 1166 Harrisburg, PA 17108-1166 (717) 237-5439 Attorneys for Plaintiff c N - _ ~ ,~, ~~~_ ~ E ~ ~ ~ '1 '~. ~ V J R~ ~ .1.. t ~ ~ ~ j~'. ~! ~ ^ ` , v ~l ' +~ V ~ ~{ ~'~ JJ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION ~~yy PNC BANK, NATIONAL ASSOCIATION, DOCKET NO. a1' - 50tiy C:ivi ( I~ef M Plaintiff v. CONFESSION OF JUDGMENT SHAIR KHOKHAR AND HELENA KHOKHAR, Defendants :PREVIOUSLY ASSIGNED TO: N/A CERTIFICATE OF ADDRESSES I hereby certify that the precise address of Plaintiff, PNC Bank, National Association, is 201 Penn Avenue, Scranton, PA 18503; and that the last known address of Defendants, Shah Khokhar and Helena Khokhar, is 112 Baros Street, Fairfield, CT 06824. Respectfully submitted, McNees Wallace & Nurlck LLC Date: August ~ 2007 By: . Sh ,Esquire upreme Co ID #24848 100 Pine Street, PO Box 1166 Harrisburg, PA 17108-1166 (717) 237-5439 Attorneys for Plaintiff n N O ~..0 ,,s _~ ~ ~` ~:.. T -~ ~' ~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVII, ACTION PNC BANK, NATIONAL ASSOCIATION, :DOCKET NO. prj- 5o~y ~,iv,11 1~err~ Plaintiff : v, :CONFESSION OF JUDGMENT SHAIR KHOKHAR AND HELENA KHOKHAR, . Defendants :PREVIOUSLY ASSIGNED TO: N/A AFFIDAVIT OF NON-MILITARY SERVICE TO THE PROTHONOTARY: I do certify, to the best of my knowledge, that Defendants, Shair Khokhar and Helena Khokhar, in the above-captioned action are not presently on active or nonactive military status. Respectfully submitted, McNees Wallace & Nurtck LLC Date: August N 2007 BY~ eo . Sh ,Esquire upreme Co ID #24848 ,100 Pine Street, PO Box 1166 Harrisburg, PA 17108-1166 (717) 237-5439 Attorneys for Plaintiff Ca ~., .~, ~-, ~ -~ ~. G's ' ~~ ~ ~_: ~`c. ~ ~` ~` _ n ~ J ..' ~r COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, DOCKET N0.07-5014 Civil Term Plaintiff v. :CONFESSION OF JUDGMENT SHAIR KHOKHAR AND HELENA KHOKHAR, Defendants :PREVIOUSLY ASSIGNED TO: N/A RETURN OF SERVICE PURSUANT TO PA. R.C.P. No. 2958.1(c) 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. Shair Khokhaz and Helena Khokhaz 112 Bazos Street Fairfield, CT 06824 Respectfully submitted, McNees Wallace & Nurick LLC Date: September ~r 2007 By: `~. S ,Esquire reme C ID #24848 100 Pine S eet, PO Box 1166 Harrisburg, PA 17108-1166 (717) 237-5439 Attorneys for Plaintiff ..- ?3~6Q 9849 9'Ml9 2~i.3 Tp; Shair Kliokhar and Helena Khokhar 112 Baros Street Fairfield, CT 06824 8ENDER: Geoffrey S. Shuff E 4 REFERENCE: PNC Bank E71JRN p ~~~ G_ Y RECEtP'T rieflliled f1o E SERVICE e Retum Receipt Fie j Reehdctrd DeN Total PoW+De 8 Fees f ~ U8 Postal St)lVlta ~ 0~1TE Receipt for '~'8 ~ ,~~,r, Certified Maii ~~ t~to ln.~,-ana Cwegp. t~ovidw .v+mr t ~~ .. ; rs roan ~ni ~, .ianuary zuua F'?~C Bank Geoffrey S. Shuff t)orr-sedc Return Receipt NM No r fi .xTa ~t3 ~~ ...r .`~ ~C! w ~