HomeMy WebLinkAbout08-3773~ i ~ y 7
MID PENN BANK,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
v.
NO. D$ - 3'7'13
WILLIAM KALDES d/b/a
THE SPOT RESTAURANT, and
STEPHANIE N. KALDES,
Defendants
Civil TerM
ENTRY OF APPEARANCE AND CONFESSION OF JUDGMENT
DEAR CLERK:
Please docket this case by consent and enter the appearance of Marc. W. Witzig, Esquire
and Kelly M. Knight, Esquire, Cunningham & Chernicoff, P.C., for the Defendants William
Kaldes d/b/a The Spot Restaurant and Stephanie N. Kaldes.
With respect to Count I, and 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, we
appear for the Defendant, William Kaldes d/b/a The Spot Restaurant, and confess judgment in
favor of the Plaintiff and against Defendant, William Kaldes d/b/a The Spot Restaurant, in the
amount of:
Principal:
Attorney Fees
$ 3,931.49
~ 3,500.00
$ 7,431.49
Plus continuing pre judgment interest of 7.0% per annum from June 10, 2008; continuing
post judgment interest of 12.0% per annum; continuing costs, continuing late charges and
continuing attorney fees
With respect to Count II, and 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, we
appear for the Defendant, Stephanie N. Kaldes, and confess judgment in favor of the Plaintiff
and against Defendant, Stephanie Kaldes, in the amount of:
Principal: $ 3 931.49
Attorney Fees 3 500.00
$ 7,431.49
Plus continuing pre judgment interest of 7.0% per annum from June 10, 2008; continuing
post judgment interest of 12.0% per annum; continuing costs, continuing late charges and
continuing attorney fees
Date: June 25, 2008
Harrisburg, PA 17110
(717) 238-6570
Attorneys for Defendants
PA Attorney Identification No. 87365
2320 North Second Street
x ~ ~ :
Marc W. Witzig, Esquire
PA Attorney Identification No.29929
Kelly M. Knight, Esquire
PA Attorney Identification No. 87365
CUNNINGHAM & CHERNICOFF, P.C.
2320 North Second Street
Harrisburg, PA 17110
Mailing Address:
P.O. Box 60457
Harrisburg, PA 17106-0457
(717) 238-6570
Attorneys for Plaintiff
MID PENN BANK, IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
NO. d ~- 3"77 3 ~hll~ ~-~~~
v.
WILLIAM KALDES d/b/a
THE SPOT RESTAURANT, and
STEPHANIE N. KALDES, ;
Defendants
COMPLAINT FOR CONFESSION OF JUDGMENT
NOW COMES, the Plaintiff, Mid Penn Bank, by and through its counsel, Cunningham &
w ~ Y
Chernicoff, P.C., and files its Complaint for Confession of Judgment, and in support thereof
avers as follows:
PARTIES AND JURISDICTION
1. Plaintiff, Mid Penn Bank (the "Plaintiff' or "Bank"), is a Pennsylvania banking
institution with a place of business located at Market Square Plaza, 17 North
Second Street, Harrisburg, Dauphin County, Pennsylvania 17101.
2. Defendant, William Kaldes d/b/a The Spot Restaurant, ("William Kaldes") is an
adult individual with a last known address of 5908 Stephens Crossing,
Mechanicsburg, Cumberland County, Pennsylvania 17050.
3. Defendant, Stephanie N. Kaldes ("Stephanie Kaldes") is an adult individual with a
last known address of 5908 Stephens Crossing, Mechanicsburg, Cumberland
County, Pennsylvania 17050.
4. Jurisdiction and venue aze proper in this county.
COUNTI
Plaintiff Mid Penn Bank v. Defendant William Kaldes d/b/a The S of Restaurant
5. The Bank incorporates Pazagraphs 1 through 4 as if more fully set forth herein.
6. On or about February 8, 2007, William Kaldes executed his certain Promissory
Note (the "Promissory Note" or the "Note") for the principal sum of $31,700.00,
together with a variable interest rate at an initial rate of 10.25% per annum. A
true and correct copy of the Promissory Note is attached hereto as Exhibit "A" and
is incorporated herein by reference.
7. According to the Promissory Note, William Kaldes was to pay the loan in one
principal payment of $31,700.00 plus interest on February 8, 2008. Such payment
was to consist of all principal and accrued unpaid interest not yet paid.
8. The interest rate applicable to the Note is a variable interest rate.
9. As set forth in the Promissory Note, if any payment is fifteen (15) days or more
late, then William Kaldes is charged 10% of the regularly scheduled payment or
$25.00, whichever is greater.
10. As set forth in the Promissory Note, any failure by William Kaldes to make any
payment when due under the Note constitutes a default under the Note.
11. Upon a default under the Note, the interest rate on the Note shall be increased by
adding a 5.00 percentage margin.
12. The Promissory Note states that the Bank may, after giving notice, declare the
entire unpaid principal balance and all accrued unpaid interest to be immediately
due.
13. The Bank is permitted, under the Promissory Note, to hire or pay someone else to
help collect under the Promissory Note if William Kaldes defaults in payment,
and William Kaldes agrees to pay the Bank the costs of such. Such amount is to
include attorneys fees and legal expenses.
14. The Promissory Note states that if Judgment is entered against William Kaldes in
connection with the Promissory Note, interest will continue to accrue after the
date of judgment at the rate in effect at the time such judgment is entered.
15. William Kaldes is in default under the Promissory Note because he has failed to
make full timely payments to the Bank as set forth in the Promissory Note.
16. The sum due and owing under the Promissory Note is $3,931.49 plus continuing
pre judgment interest at a rate of 7.0% per annum from June 10, 2008; continuing
.. ,
post-Judgment interest at a rate of 12.0% per annum; continuing costs; continuing
late charges and continuing attorneys fees.
17. The Promissory Note authorizes the Bank to confess judgment against the
William Kaldes after default under the Note.
18. Judgment on the Promissory Note has not been entered in any jurisdiction.
19. The Promissory Note has not been assigned.
20. Judgment is not being entered by a confession against a natural person in
connection with a consumer credit transaction.
21. The failure of William Kaldes to pay the Promissory Note and continuing default
thereunder provide Plaintiff with the authority to file this Complaint.
22. All conditions precedent to the Bank's recovery hereunder and/or entry of
judgment by confession, in favor of Plaintiff, have been satisfied and/or waived.
23. On February 8, 2007, William Kaldes executed that certain Disclosure for
Confession of Judgment (the "Disclosure"), containing William Kaldes' express
acknowledgment that the provision within the Note providing for confession of
judgment specifically was brought to the attention of William Kaldes; and that
William Kaldes knowingly, intelligently, and voluntarily signed the Note
containing the confession of judgment provision and made the other waiver of
rights contained in the Note. A true and correct copy of the Disclosure is attached
hereto as Exhibit "B" and is incorporated herein by reference.
WHEREFORE, Plaintiff, Mid Penn Bank hereby respectfully requests that this Honorable
Court enter Judgment by Confession against the Defendant, William Kaldes d/b/a The Spot
Restaurant, in the amount of:
Principal: $ 3,931.49
Attorney Fees 3 500.00
$ 7,431.49
Plus continuing pre judgment interest of 7.0% per annum from June 10, 2008; continuing
post judgment interest of 12.0% per annum; continuing costs, continuing late charges and
continuing attorney fees.
COUNT II
Plaintiff Mid Penn Bank v. Defendant Ste hanie N. Kaldes
24. The Bank incorporates Paragraphs 1 through 23 as if more fully set forth herein.
25. On or about February 8, 2007, Stephanie Kaldes, executed and delivered her
certain Commercial Guaranty (the "Commercial Guazanty") by which she
absolutely and unconditionally guaranteed full and punctual payment and
satisfaction of the indebtedness owed to the Bank by William Kaldes under the
Promissory Note. A true and correct copy of the Commercial Guazanty signed by
Stephanie Kaldes is attached hereto as Exhibit "C" and is incorporated herein by
reference.
26. As set forth in the Commercial Guazanty, Stephanie Kaldes absolutely and
unconditionally guaranteed full and punctual payment and satisfaction of the
indebtedness of William Kaldes to the Bank, and the performance and dischazge
of all of William Kaldes' obligations under the Promissory Note and related
documents.
27. As set forth in the Commercial Guaranty, Stephanie Kaldes promised to make due
under the Note to the Plaintiff, or its order, on demand, in legal tender of the
United States of America, in same-day funds, without setoffs or deduction or
counterclaim, and promised otherwise to perform William Kaldes' obligations
under the Promissory Note and any related documents.
28. As set forth in the Commercial Guaranty, Stephanie Kaldes agreed to pay all
outstanding principal, all accrued but unpaid interest thereon, and all collection
costs and legal expenses related thereto, attorneys fees, arising for any and all
debts, liabilities and obligations that William Kaldes owes or will owe Plaintiff
under the Promissory Note and any other related documents.
29. Following default of William Kaldes under the Note, the Bank made demand
upon Stephanie Kaldes that she pay in full the indebtedness owed by William
Kaldes to the Bank under the Note. Stephanie Kaldes has refused to pay such sum
to Plaintiff. Said refusal and failure are continuing and are without excuse.
30. The Commercial Guaranty authorizes the Plaintiff to confess judgment against
Stephanie Kaldes for the entire principal balance of and owed under the
Commercial Guaranty as well as all accrued interest, late charges, costs of suit,
and attorneys' fees.
31. The Commercial Guaranty authorizes the Bank to obtain judgment by confession
against Stephanie Kaldes after a default under the Commercial Guaranty.
Stephanie Kaldes properly executed and delivered her certain Disclosure of
Confession of Judgment, dated February 7, 2007, containing her express
acknowledgment that the provision within the Note providing for confession of
judgment specifically was brought to her attention; and that she knowingly,
intelligently, and voluntarily signed the Commercial Guaranty containing the
confession of judgment provision and made the other waiver of rights contained in
the Commercial Guaranty. A true and correct copy of Stephanie Kaldes'
. i
Disclosure of Confession of Judgment, is attached hereto as Exhibit "D" and is
incorporated herein by reference.
32. Judgment on the Commercial Guazanty against Stephanie Kaldes has not been
entered in any jurisdiction.
33. The Commercial Guazanty has not been assigned.
34. Judgment is not being entered by confession against a natural person in
connection with a consumer credit transaction.
35. Stephanie Kaldes' failure to cure William Kaldes' default under the Promissory
Note, and Stephanie Kaldes' continuing default under the Commercial Guaranty,
provide Plaintiff with the authority to file this Complaint pursuant to the
Commercial Guaranty.
36. All conditions precedent to the Plaintiffs recovery hereunder and entry of
Judgment by Confession, in favor of the Bank, have been satisfied and/or waived.
WHEREFORE, Plaintiff, Mid Penn Bank hereby respectfully requests that this Honorable
Court enter Judgment by Confession against the Defendant, Stephanie N. Kaldes in the amount
of
Principal: $ 3 931.49
Attorney Fees 3 500.00
$ 7,431.49
Plus continuing pre judgment interest of 7.0% per annum from June 10, 2008; continuing
post judgment interest of 12.0% per annum; continuing costs, continuing late charges and
continuing attorney fees
,.
submitted,
C.
Date: June 25, 2008 gy;
PA At~orney I~i~ntific~tion No. 29929
PA Attorney Identification No. 87365
2320 North Second Street
Harrisburg, PA 17110
(717) 238-6570
Attorneys for Plaintiff
,,
MID PENN BANK, IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
WILLIAM KALDES d/b/a
THE SPOT RESTAURANT, and
STEPHANIE N. KALDES,
Defendants
AFFIDAVIT OF LAST KNOWN ADDRESS
I, Gregory C. Scheer, Collection Manager of Mid Penn Bank, hereby certify that the last
known address of the Defendant, William Kaldes d/b/a The Spot Restaurant is 5908 Stephens
Crossing, Mechanicsburg, Cumberland County, Pennsylvania 17050.
MID PENN BANK ((~~
Date: t9 a ~ 0 ~ By. ~ ~ c>G~s..~~1,.
Grego . Sc r
Collection Manager
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
SS.
On this, the ~ day of ~Jv12 2008, before me, a Notary Public, the
undersigned officer, personally appeared Gregory C. Scheer, known to me (or satisfactorily
proven) to be the person described in the within instrument, and acknowledged that he executed
the same in the capacity therein stated and for the purposes therein contained.
TN WITNESS WHEREOF, I hereunto s y hand and eal.
S
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal Notary Pu liC
&odc J. Glasstord, Notary Public
Lower Paxton Twp., Dauphin County
My Commission Expires Mar. 27, 2010
Member, Pennsylvania Asspciation of Notaries
~ ~ i
MID PENN BANK,
Plaintiff
v.
WILLIAM KALDES d/b/a
THE SPOT RESTAURANT, and
STEPHANIE N. KALDES,
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
AFFIDAVIT OF LAST KNOWN ADDRESS
I, Gregory C. Scheer, Collection Manager of Mid Penn Bank, hereby certify that the last
known address of the Defendant, Stephanie N. Kaldes, is 5908 Stephens Crossing,
Mechanicsburg, Cumberland County, Pennsylvania 17050.
MID PENN BANK
Date: ~ 2~0 Q ~S' B _ ~, ~ C~
Y~
Grego C. S er
Collection Manager
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN SS.
On this, the ~ day of th'l ~ , 2008, before me, a Notary Public, the
undersigned officer, personally appeared Gregory C. Scheer, known to me (or satisfactorily
proven) to be the person described in the within instrument, and acknowledged that he executed
the same in the capacity therein stated and for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set m hand an 1,
Notary Pub 'c
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Brock J. Glassford, Notary Public
Lower Paxton Twp., Dauphin County
My Commission Expires Mar. 27, 2010
Member, Pennsylvania Association of Notaries
1 . ~ I
MID PENN BANK,
Plaintiff
v.
WILLIAM KALDES d/b/a
THE SPOT RESTAURANT, and
STEPHANIE N. KALDES,
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. d~,~ 7 7 3 c 1v, l f"uti..
AFFIDAVIT OF KELLY M. KNIGHT, ESQUIRE
I, Kelly M. Knight, Esquire, attorney for Plaintiff, Mid Penn Bank, swear and aver as
follows:
1. That the Judgment against Defendant, William Kaldes d/b/a The Spot Restaurant,
is not being entered by confession against a natural person in connection with a
consumer credit transaction.
Date: June 25, 2008
Harrisburg, PA 17110
(717) 238-6570
1 ~ ~ Y
COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OF DAUPHIN
On this, the a~ day of ~~~--' , 2008, before me, a Notary Public, the
undersigned officer, personally appeared Kelly M. Knight, Esquire, known to me (or
satisfactorily proven) to be the person described in the within instrument, and acknowledged that
he executed the same in the capacity therein stated and for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto s t my hand and offic'al seal.
Public
COMMONWEALTH OF PENNSYLVANIA
JULIEANNE AMETRAANO EN to tc
City of Harriaburg, 7auphin County
My Commission Expires r•eb. 22, 2011
MID PENN BANK,
Plaintiff
v.
WILLIAM KALDES d/b/a
THE SPOT RESTAURANT, and
STEPHANIE N. KALDES,
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
No. 6 g, 3 7~ 3 c a ~; I f ~r,~
AFFIDAVIT OF KELLY M. KNIGHT, ESQUIRE
I, Kelly M. Knight, Esquire, attorney for Plaintiff, Mid Penn Bank, swear and aver as
follows:
1. That the Judgment against Defendant, Stephanie Kaldes, is not being entered by
confession against a natural person in connection with a consumer credit
transaction.
Respectfully submitted,
CUNNIN
Date: June 25, 2008
By:
' Harrisburg, PA 17110
(717) 238-6570
.,a
COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OF DAUPHIN .
On this, the ~J day of ~~/w , 2008, before me, a Notary Public, the
undersigned officer, personally appeared Kelly M. Knight, Esquire, known to me (or
satisfactorily proven) to be the person described in the within instrument, and acknowledged that
he executed the same in the capacity therein stated and for the purposes therein contained.
1N WITNESS WHEREOF, I hereunto ~ my handandOfficial seal.
Public COMMONWEALTH OF PENNSYLVANIq
NOTARIAL SEAL
JULiEANNE AMETRANO, Nota
City of Harrisburg, Dauphin County
My Omission Expires Feb, 22, 2011
. , ~.
MID PENN BANK, IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
. NO. ~ ~, 3 7 7 3 c N, ~ t"c tom.
v.
WILLIAM KALDES d/b/a
THE SPOT RESTAURANT, and
STEPHANIE N. KALDES, ;
Defendants ;
CERTIFICATE OF RESIDENCE
The address of the Plaintiff, Mid Penn Bank, is Market Square Plaza, 17 North Second
Street, Harrisburg, Dauphin County, Pennsylvania 17101.
The address of Defendant, William Kaldes d/b/a The Spot Restaurant is 5908 Stephens
Crossing, Mechanicsburg, Cumberland County, Pennsylvania 17050.
Respectfully sul~lni
C~F'F, P.C.
Date: June 25, 2008
Maz W: W~' ' e
P Attorney entif ation No. 29929
Kelly M. Knig rt, quire
PA Attorney Identification No. 87365
2320 North Second Street
Harrisburg, PA 17110
(717) 238-6570
Attorneys for Plaintiff
1 • ~~ ~
MID PENN BANK, IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
v. : No. 6 g , 3 7 ~ 3 ~ : ~: I -f ~~~.
WILLIAM KALDES d/b/a
THE SPOT RESTAURANT, and .
STEPHANIE N. KALDES, ;
Defendants
CERTIFICATE OF RESIDENCE
The address of the Plaintiff, Mid Penn Bank, is Market Square Plaza, 17 North Second
Street, Harrisburg, Dauphin County, Pennsylvania 17101.
The address of Defendant, Stephanie N. Kaldes, is 5908 Stephens Crossing,
Mechanicsburg, Cumberland County, Pennsylvania 17050.
Respectfully submitted,
CU]
Date: June 25, 2008 By;
PA Attorney Identification No. 87365
2320 North Second Street
Harrisburg, PA 17110
(717) 238-6570
Attorneys for Plaintiff
,..
VERIFICATION
I, Gregory C. Scheer, Collection Manager of Mid Penn Bank, verify that the statements
made in the foregoing COMPLAINT FOR CONFESSION OF JUDGMENT are true and
correct to the best of my knowledge, information and belief. I understand that false statements
are made subject to the penalties of 18 Pa.C.S.§ 4904 relating to unsworn falsification to
authorities.
MID PENN BANK
Date: (,Q~~,pf Og ~~ S
By: Gi gory C. 'cheer
Collection Manager
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MID PENN BANK,
Plaintiff
v.
WILLIAM KALDES d/b/a
THE SPOT RESTAURANT, and
STEPHANIE N. KALDES,
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. ~~, 3 7 ~ 3 c t~ , ~ -Ft ~ti,
NOTICE OF ENTRY OF JUDGMENT
TO: Mr. William Kaldes
d/b/a The Spot Restaurant
5908 Stephens Crossing
Mechanicsburg, PA 17050
YOU ARE HEREBY NOTIFIED THAT ON WoZI~/o8 THE
FOLLOWING JUDGMENT HAS BEEN ENTERED AGAIN T OU IN THE ABOVE-
CAPTIONED CASE IN THE FOLLOWING AMOUNT:
PRINCIPAL: $ 3,931.49
ATTORNEY FEES $ 3.500.00
$ 7,431.49
PLUS CONTINUING PRE-JUDGMENT INTEREST OF 7.0% PER ANNUM FROM JUNE
10, 2008; CONTINUING POST-JUDGMENT INTEREST OF 12.0% PER ANNUM;
CONTINUING COSTS, CONTINUING LATE CHARGES AND CONTINUING
ATTORNEY FEES
Pro9ionotary
i
I HEREBY CERTIFY THAT THE NAME AND ADDRESS OF THE PROPER PERSON
TO RECEIVE THIS NOTICE UNDER PA. R.C.P. §236 IS:
Mr. William Kaldes
d/b/a The Spot Restaurant
5908 Stephens Crossing
Mechanicsburg, PA 17050
_ ,.
Por este medio se le esta notificando que el de de12008, el/la siguiente Fallo
he sido anotado en contra suya en el caso mencionado en el epigrafe.
FECHA:
Protonotario
Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado de
residencia:
Mr. William Kaldes
d/b/a The Spot Restaurant
5908 Stephens Crossing
Mechanicsburg, PA 17050
~ ~ it
MID PENN BANK,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
. NO. ~g•3?~3 c,~;I ~-~.M-
~.
Defendants
NOTICE OF ENTRY OF JUDGMENT
WILLIAM KALDES d/b/a
THE SPOT RESTAURANT, and
STEPHANIE N. KALDES,
TO: Ms. Stephanie N. Kaldes
5908 Stephens Crossing
Mechanicsburg, PA 17050
YOU ARE HEREBY NOTIFIED THAT ON ~olcZ(o~08 THE
FOLLOWING JUDGMENT HAS BEEN ENTERED AGA S YOU IN THE ABOVE-
CAPTIONED CASE IN THE FOLLOWING AMOUNT:
PRINCIPAL: $ 3,931.49
ATTORNEY FEES $ 3.500.00
$ 7,431.49
PLUS CONTINUING PRE-JUDGMENT INTEREST OF 7.0% PER ANNUM FROM
JUNE 10, 2008; CONTINUING POST-JUDGMENT INTEREST OF 12.0% PER
ANNUM; CONTINUING COSTS, CONTINUING LATE CHARGES AND
CONTINUING ATTORNEY FEES
Protfionotary
I HEREBY CERTIFY THAT THE NAME AND ADDRESS OF THE PROPER
PERSON TO RECEIVE THIS NOTICE UNDER PA. R.C.P. §236 IS:
Ms. Stephanie N. Kaldes
5908 Stephens Crossing
Mechanicsburg, PA 17050
_. , -
Por este medio se le esta notificando que el de de12OO8, el/la siguiente
Fallo he sido anotado en contra suya en el caso mencionado en el epigrafe.
FECHA:
Protonotario
Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado
de residencia:
Ms. Stephanie N. Kaldes
5908 Stephens Crossing
Mechanicsburg, PA 17050
F:\Home\KKNIGH7IDOCS\Midpenn\Kaldes\The Spot\BIdg.Loan.Complaint 6.12.08.wpd
MID PENN.BANK, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
V.
NO: 0.8-3773
WILLIAM KALDES d/b/a., ,
THE SPOT RESTAURANT, and Civil Action- Law ---
STEPHANIE N. KALDES, ra r,, ?
Defendants C
C� 3:xb rn
PRAECIPE TO SATISFY JUDGMENT AND DISCONTINUEL l
b � ;
TO THE PROTHONOTARY:
Having received satisfaction in full of the judgment entered in the above-docketed matter,
you are hereby authorized and directed to mark the judgment satisfied. Please also mark the
matter settled, discontinued, and ended.
Respectfully Submitted,
C HA CH ICOFF, P.C.
Date: May_[( , 2013 By:
Mark W. Witzig, Esquire
PA Attorney ID No. 29929
Gina L. Lauffer, Esquire
PA Attorney ID No. 313863
2320 North Second Street
Harrisburg, PA 17110
Telephone: (717) 238-6570
Attorneys for Plaintiff
CERTIFICATE OF SERVICE
I, Julieanne Ametrano, Legal Assistant with the law firm of Cunningham& Chernicoff,
P.C., hereby certify that a true and correct copy of the PRAECIPE TO SATISFY JUDGMENT
AND DISCONTINUE will be served by first class U.S. Mail on the following parties indicated:
Mr. William Kaldes Ms. Stephanie N. Kaldes
d/b/a The Spot Restaurant 5908 Stephens Crossing
5908 Stephens Crossing Mechanicsburg, PA 17050
Mechanicsburg, PA 17050
Ms. Amy M. Custer
Mid Penn Bank
5500 Allentown Boulevard
Harrisburg, PA 17112
CUNNINGHAM & CHERNICOFF, P.C.
Date: May 16 2013 B lAw-4D
� :Y
ulieanne Ametrano
320 North Second Street
Harrisburg, PA 17110
Telephone: (717) 238-6570
FAH ome\GLAUFFER\DOCSWIidPenn Bank\Kaldes\Praecipe to Satisfy Judgment.wpd