HomeMy WebLinkAbout08-3821IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CNIL ACTION -LAW
LEZZER HOLDINGS, INC., )
Plaintiff, )
vs. ) NO. D'8 - 38o't.l
ALTIERI ENTERPRISES, INC., )
Defendant. )
PRAECIPE TO ENTER JUDGMENT
PURSUANT TO PA. R.C.P. 3001
TO THE PROTHONOTARY:
1V i ( ~iE:r'M
Please enter judgment against Altieri Enterprises, Inc. in the amount of $580,950.97 plus
interest from the date of judgment and costs, in accordance with the attached certified copy of
the docket entries and the certification of the amount of the judgment entered in the York County
Court of Common Pleas, Civil Action No. 2008-NO-2374-30, and index the judgment against
Defendant Altieri Enterprises, Inc.
BABST, CALLAND, CLEMENTS &
ZOMNIR, PC
By:
Eliza eth . (Betsy) Dupui ,Esquire
~ Attorney for Plaintiff
328 Innovation Boulevard, Suite 200
State College, PA 16803
(814) 867-8055
Attorney I.D. No. 80149
Date: . a3; aI10 ~'
CERTIFICATION
I hereby certify that the judgment initially entered in York County is in the amount of
$580,950.97, plus interest from the date of judgment and costs, as reflected on the certified copy
of the docket entries of York County, attached hereto and made a part hereof.
BABST, CALLAND, CLEMENTS &
ZOMNIR, PC
By:
Elizabeth . (Betsy) Dupui ,Esquire
Attorney for Plaintiff
328 Innovation Boulevard, Suite 200
State College, PA 16803
(814) 867-8055
Attorney I.D. No. 80149
Date: ~1a310~
• ~,
OFFICE OF THE PROTHONOTARY
Of York County
Pamela S. Lee
Prothonotary
Billie Jo Bones
Deputy Prothonotary
Gregory E. Gettle
Solicitor
York County Judicial Center
45 North George Street
York, Pennsylvania 17401
Telephone (717) 771-9611
LEZZER HOLDING INC
Case No. 2008-NO-2374-30
Plaintiff
Vs.
ALTIERI ENTERPRISES INC
Defendant
To Whom It May Concern:
I certify that judgment was entered in favor of LEZZER HOLDING INC and against
ALTIERI ENTERPRISES INC on the 12TH day of MAY, 2008 in said case in the amount of
$580,950.97.
IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the seal of the Court, on
the 10TH day of JUNE, 2008.
Prothonotary
By
Deputy
YR
1N THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
LEZZER HOLDINGS, INC.,
vs.
NO. 2008- V ~ ~ `~~ ~ -
N
ALTIERI ENTERPRISES, INC., ) ~=-
Defendant. ) ~ _ `_~'
--~:.:.
_.~
~.~ __ ,
CONFESSION OF JUDGMENT . - - ~ ~ r ~'
_~
Pursuant to the authority contained in the confession of judgment c~auseri~a the
~ -
instrument, a copy of which is attached to the Complaint filed in this action, I appear ~or the
Defendant ALTIERI ENTERPRISES, INC. and confess judgment in favor of the Plaintiff, Omega
Bank, and against the Defendants as follows:
Unpaid Principal on Note
Interest through May 6, 2008
(per diem $114.14)
Late Charges
Attorney's Commission
Judgment was entered as above
Prothonotary
Plaintiff,
Total Amount
$504,973.84
14,494.80
9,763.53
51,718.60
$580,950.97
BABST CALLAND CLEMENTS ZOMNIR PC
By: _
Eliza eth A. Dupuis, sq re
CE~FlED irom the records of the curt of Co mon Weal of
York County, Pennsylvania this ay ~ Q ~ ~~
F~.mel;:, J. LB?, F;ott;onntary
IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA, -
CIVIL ACTION _
LEZZER HOLDINGS, INC., ) ' ~ ..
'~~ yP .
Plaintiff, ) ~ ~ --
NO. 2008- µ Vb
f,_~
vs. ) ~ -
ALTIERI ENTERPRISES, INC., )
Defendant. )
COMPLAINT FOR CONFESSION OF JUDGMENT
AND NOW comes the Plaintiff, Lezzer Holdings, Inc., by and through its attorneys
Babst Calland Clements Zomnir PC, to file the within Complaint pursuant to PA. R.C.P. 2951(b) for
judgment by confession, averring as follows:
1, Plaintiff is Lezzer Holdings, Inc., (hereinafter referred to as "Plaintiff
°° s lvania corporation, with offices at Schofield Street, Curwensville, Clearfield
Lezzer ), a Penn y
County, Pennsylvania.
2, Defendant is Altieri Enterprises, Inc., a Maryland corporation with offices at
90]7 Red Branch Road, Suite 201, Columbia, Maryland and a principal place of business in
Penns lvania, registered as a foreign entity, situated at 1700 Westgate Drive, York, Pennsylvania.
Y
3. On or about December 31, 2007, Defendant executed a Promissory Note
("Note") in favor of Plaintiff Lezzer in the amount of $504,973.84.
4. Under the terms of the Note, Defendant agreed to repay the amounts due under
' Defendant failed to perform its obligations under the Note, Defendant would be
the Note and if
responsible for any amounts due to Plaintiff Lezzer under the Note, plus all interest, costs, expenses,
r
and attorney's fees. A true and correct copy of the Note is attached hereto as Exhibit "1" and
incorporated herein by reference.
5. At the present time, Defendant is in default of the obligations under the Note
by failing to make the required monthly payments for the months of January, February, March, April
and May, 2008, and Defendant has failed to pay the amounts due despite repeated demands by
Plaintiff Lezzer.
6. Under the terms of the Note, Plaintiff Lezzer provided notice of default to
Defendant on Apri125, 2008, before proceeding with legal action although Defendant's corporate
officers were previously aware of the continuing default of the obligations. A true and correct copy
of the Notice of Default is attached hereto as Exhibit " 2" and incorporated herein by reference.
7. Pursuant to the terms of the Note, Plaintiff Lezzer is authorized to confess
judgment in the event that Defendant defaults under the terms of the Note.
8. The attached instrument has not been assigned to any other entity.
9. Judgment has not been entered in any jurisdiction.
10. Judgment is not being entered by confession against a natural person in a
consumer credit transaction.
11. As a consequence of the foregoing, Defendant is liable to Plaintiff Lezzer for
the following damages:
Unpaid Principal on Note $ 504,973.84
Interest through May 6, 2008
(per diem $114.14) 14,494.98
Late Charges 9,763.53
Attorney's Commission 51,718.60
Total Amount $580,950.97
4
AFFIDAVIT & ACKNOWLEDGEMENT
STATE OF PENNSYLVANIA ~
COUNTY OF CENTRE ~
ROXELL, Controller, LEZZER HOLDINGS, INC•, swear or affirm and verify
I, JOEL A. T
nts made in the foregoing Complaint are true and correct to the best of my
that the stateme
rmation and belief. This Affidavit is made subject to the penalties of 18 Pa.C.S.A.
knowledge, info
Section 4904 pertaining to unsworn falsification to authorities.
' Joe . Troxell
'l; ~ 1 •3
Sworn to and subscribed to before me - ~ `.'
-~- ~ ~•.
this 0 g day of ~_ 2008. .,
c ~~
csti
cn
Notary Public
C FP
NotatfalSeal public
Cu~iMr ecro, C~°id _ 200
My Camn'a~s1°" ~~~ ~~~
~~, PM,nsy~vania gssociaGon of Noleuies
NOTE
(Revolving Line-of-Credit)
5504,973.84
.'~C< 3 1 ~ j.OC
`~?'~~
FOR VALUE RECEIVED AND INTENDING TO BE LEGALLY BOUND HEREBY, the
Undersigned,
Alfieri Enterprises Inc. a corporation, with its principal offices located at 9017 Read
Branch Road, Suite 201, Columbia, MD 21045 (hereinafter called "Borrower"),hereby promises
to pay to the order of:
LEZZER HOLDINGS, INC., a Pennsylvania corporation, {hereinafter called
"Lender"), or its assigns, in lawful money of the United States of America at its office at 332
Schofield Street, Curwensville, Pennsylvania 16833, or at a different place if required by Lender, the
sum of 5504,973.84, plus interest thereon accruing from the date hereof to be payable as follows:
(i) Pa, mats:
(a) Borrower will make monthly payments of principal and interest, the interest
race based upon Wall Street Journal prime rate plus 1%, said rate adjustable
and determined before the close of business each month. First payment is due
February 1, 2008. The 151 of each month will be the due date.
(b) Borrower will make eight monthly payments of 565,090.17.
{c) Borrower will make a final payment of interest and all outstanding principal
on the maturity date, interest to be calculated at the rate as described in
paragraph (a). Amortization Schedule attached.
(ii) Maturity: 1'he entire outstanding balance of principal and interest shall be due on
September 1, 2008 ("Maturity Date"}, if not sooner paid.
(iii) Prenavment Fees: The Borrower may prepay the loan in part or in whole of without
penalty at any time prior to maturity.
Events of Default: Borrower will be in default if any of the following happens: (a)
Borrower fails to make any payment when due, hereinafter referred to as a payment default. (b)
Borrower breaks any promise Borrower has made to Lender, or Borrower fails to comply with or to
perform when due any other term, obligation, covenant, or condition contained in this Note or any
agreement related to this Note, or in any other agreement or loan Borrower has with Lender. (c)
Borrower defaults under any loan, extension of credit, security agreement, purchase or sales
agreement, or airy other agreement, in favor of any other creditor or person that may materially affect
any of Borrower's property or Borrower's ability to repay this Note or perform Borrower's obligations
...EXHIBIT
€ 1
3 .
under any and all promissory notes, credit agreements, loan agreements, environmental agreements,
guaranties, security agreements, mortgages, deeds of trust, and all other instruments, agreements and
documents, whether now or hereafter existing, executed in connection with the Indebtedness. (d)
Any representation or statement made or furnished to Lender by Borrower or on Borrower's behalf is
false or misleading in any material respect either now or at the time made or furnished. (e) Borrower
becomes insolvent, a receiver is appointed for any part of Borrower's properly, Borrower makes an
assignment for the benefit of creditors, or any proceeding is commenced tither by Borrower or
against Borrower under any bankruptcy or insolvency laws. (f) Any creditor obtains a judgment or
court order regarding any of the Borrower's property on or in which Lender has a lien or security
interest. This includes a garnishment of any of Borrower's accounts with Lender. (g) Any of the other
events described in this default section occurs with respect to any guarantor of this Note. (h) A
material adverse change occurs in Borrower's financial condition, or Lender reasonably believes the
prospect of payment or performance of the Indebtedness is impaired. (i) Lender in good faith
reasonably deems itself insecure.
If default shall occur in the payment of any installment of the principal or of interest,
on the indebtedness secured payable under the Note, the Mortgage or any other Loan Document,
Borrower shall have ten (10) days to cure such default. Lender shall be required to give no further
notice before exercising any of the rights or remedies contained herein. As to the occurrence of
defaults other than payment defaults, Lender shall provide written notice to Bon: ower of the default
and Borrower shall have thirty (30) days to cure such default before Lender may exercise any of the
remedies contained herein. if Borrower cures such default within the thirty {30) day cure period,
Lender will not exercise any of the remedies for such default as set forth herein.
Late Fees: Borrower shall pay to Lender a late charge of five (5%) percent of any
monthly payment not received by Lender within five (5) days after the payment is due.
Securit "I1iis Note is secured by the following:
Borrower hereby grants a security interest to Lender in any materials
purchased by Borrower from Lender or Lender's subsidiaries or related
entities all as more fully described in the Security Agreement executed
contemporaneously.
Acceleration: Should any default beyond any applicable grace period occur in the
payment of any installment of interest and/or principal on the date on which the same shall fail due,
or in the performance of any of the agreements, conditions, covenants, provisions or stipulations
contained in any other loan document, by Borrower or any other party thereto, then Lender, at its
option and within ten (10) days written notice addressed to Borrower, may declare immediately due
and payable the entire unpaid balance of principal and all other sums due by Borrower hereunder or
under the other loan documents, together with interest accrued thereon at the then otherwise
applicable rate specified herein to the date of default. Payment thereof may be enforced and
recovered in whole or in part at any time by one or more of the remedies provided to Lender in this
Note or in the other Loan Documents. If Lender employs counsel to enforce this Notc by suit or
otherwise, Borrower will reimburse Lender for all costs of suit and other expenses including
reasonable attorneys' fees in connection therewith, whether or not suit is actually instituted, together
2
with interest on any judgment obtained by Lender at a rate which shall be the rate under this Note,
including interest at the Loan date from and after the then-existing date of execution, judicial or
foreclosure sale until actual payment is made to Lender of the full amount due hereunder.
Confession of Juds~ment: EACH BORROWER HEREBY EMPOWERS ANY
ATTORNEY OF ANY COURT OF RECORD, AFTER THE OCCURRENCE OF ANY
EVENT OF DEFAULT SPECIFIED IN THE LOAN AGREEMENT AND THE FAILURE OF
THE BORROWER TO CURE SUCH EVENT OF DEFAULT DURING THE APPLICABLE
CURE PERIOD, IF ANY, SPECIFIED IN THE LOAN AGREEMENT, TO APPEAR FOR
EACH BORROWER AND, WITH OR WITHOUT COMPLAINT FILED, CONFESS
JUDGMENT, OR A SERIES OF JUDGMENTS, AGAINST EACH BORROWER IN FAVOR
OF THE LENI?ER OR ANY HOLDER HEREOF FOR THE ENTIRE PRINCIPAL
BALANCE OF THIS NOTE, ALL ACCRUED INTEREST AND ALL OTHER AMOUNTS
DUE HEREUNDER, TOGETHER WITH THE COSTS OF SUIT AND AN ATTORNEY'S
COMMISSION OF THE GREATER OF 10% OF SUCH PRINCIPAL AND INTEREST OR
$1,000 ADDED AS A REASONABLE ATTORNEY'S FEE, AND FOR DOING SO, THIS
NOTE OR A COPY VERIFIED BY AFFIDAVIT SHALL BE A SUFFICIENT WARRANT.
EACH BORROWER 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. INTEREST ON ANY SUCH JUDGMENT SHALL
ACCRUE AT THE DEFAULT RATE.
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 PO WER SHALL CONTINUE
UNDIMINISHED 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, INTEREST AND COSTS.
NOTWITHSTANDING THE ATTORNEY'S COMMISSION PROVIDED FOR IN THE
PRECEDING PARAGRAPH (WHICH IS INCLUDED IN THE WARRANT FUR
PURPOSES OF ESTABLISHING A SUM CERTAIN), THE AMOUNT OF ATTORNEYS'
FEES THAT THE LENDER MAY RECOVEK FROM THE BORROWER SHALL NOT
EXCEED THE ACTUAL ATTORNEYS' FEES INCURRED BY THE LENDER.
EACH BORROWER IRREVOCABLY WAIVES ANY ANI) ALL RIGHTS THE
BORROWER 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 TO
OCCUR PURSUANT TO ANY OF SUCH DOCUMENTS. EACH BORROWER
ACKNOWLEDGES THAT THE FOREGOING WAIVER IS KNOWING AND
VOLUNTARY.
Cumulative Remedies: The remedies of this Note and any other documents
evidencing or securing this indebtedness providing for the enforcement of the payment of the
principal sum thereby secured, together with interest thereon, and for the performance of the
covenants, conditions and agreements, matters and things therein and herein contained, are
cumulative and concurrent and may be pursued singly, or successively, or together at the sole
discretion of Lender, and may be exercised as often as occasion therefor shall occur.
Waivers of Lender: Lender's failure to exercise any right hereunder shall not be
construed as a waiver of the right to exercise the same or any other right at any subsequent time. No
agreement with respect to this Note or any collateral shall be binding upon Lender unless signed by
it.
Borrower expressly agrees that no renewal or extension hereof granted, nor any
indulgence shown to Borrower, nor any dealings between Lender and any person now or hereafter
interested herein or in any property, tangible or intangible, securing the indebtedness evidenced by
this Note, whether as owner, encumbrancer or otherwise, shall discharge, extend or in any way affect
any of his obligations under this Note. Demand, presentation, protest, notice of dishonor and notice
of default are hereby waived.
Transferability by Lender: This Note inures to the benefit of the Lender, its
successors and assigns, and is binding upon the Borrower, his heirs, successors and assigns. The
Lender may transfer this Note and may transfer any collateral given under this Note to any transferee,
who shall thereupon become vestedr be forevererelieved and fullyt dgtchargedhfrom any I abil t hor
Note, and the Lender shall thcreaite
responsibility arising under this Note.
Review With Counsel: Borrower has reviewed this Note and the Loan Documents
with counsel of Borrower's own choice and, further, acknowledges understanding of the terms and
conditions of this Note, and any related documents.
Notices: Any notice to be given pursuant to this Note and the Loan Documents shall
be in writing, shall be deemed received when placed in the United States Mail by certified mail (a)
addressed to Lender at P.O. Box 217, Curwensville, Pennsylvania 16833, or at such other address of
which Lender shall give Notice; and (b) addressed to Borrower at the address set forth on Page one
of this Note.
Govcrnin~ Lav%s: This instrument shall be governed by and constructed according to
the Laws of the Commonwealth of Pennsylvania.
Joint and Several: If this Note is executed by more than one Borrower, the
obligations of each such person or entity hereunder shall be joint and several.
4
IN WITNESS WHEREOF, Borrower has executed this document the day, month and
year as set forth previously.
BORROWER:
ATTEST: Alfieri Enterprises Inc.
~ ;~
.,~,
By: _~>
Daren B. tieri, President
By: J~~~.
t .
Principal $ 504,973.84
8.25%
Interest Rate: 8
Term (In Months):
Payment: $ 65,090.17
AMORTIZATION SCHEDULE
Period Payment Principal
7 Interest
70
471
$3 Remainin 443'355 37
$
1 $
$ 65,090.17
17
090
65 $61,618.4
$62,042.10 .
,
$3,048.07
$ 381,313.27
2
3
$ .
,
65,090.17
$62,468.64
$2,621.53
$
$ 818,844.63
946.52
255
4 $ 65,090.17
17
090
65 $62,898.11
330.54
$63 $2,192.06
$1,759.63
$ ,
192,615.98
5
6 $
$ .
,
65,090.17 ,
$63,765.93
$1,324.23
84
$
$ 128,850.05
~ 645.73
• 7 $ 65,090.17
17
090
65 $64,204.32
645.73
$64 $885.
$444.44 $ (0.00}
6 $ .
, ,
BIZ
BABST ~ CALLAND ~ CLEMENTS ~ ZOMNIR
A PROFESSIONAL CORPORAT[ON
ELIZABETH A. (BETSY) DUPU[S
Atttomey at Law
T 814.235.8421
GQupuisC~bcr:. com
April 25, 2008
Darren B. Altieri, President
Altieri Enterprises, Inc.
9017 Read Branch Road, Suite 201
Columbia, MD 21045
Re: December 31, 2007 Note to Lezzer Holdings, Inc.; $504,973.84
Dear Mr. Altieri:
BfILE COPY
Our office has been retained on behalf of Lezzer Holdings, Inc. ("Lezzer") regarding the
above-referenced Note in the amount of $504,973.84 ("Note") to Altieri Enterprises, Inc. ("Altieri").. As
of the present time, the Note is in default as no payments under the same have been received by Lezzer,
those payments due for the months of February, March and April, 2008, each in the amount of
$65,090.17.
Pursuant to the acceleration clause under the Note, Lezzer is herby informing Altieri of
its intention to accelerate the amounts due under the Note. Lezzer demands payment in full of the
balance of this account, including any and all finance charges, late fees and other expenses that may
accrue as a result of this default.
You must cure the default by paying the balance in full by May 5, 2008. Payment may
be made by either cashier's check, certified check or money order made payable to Lezzer Holdings, Inc.
and sent to the attention of Thomas Yontosh, P.O. Box 118 or 332 Schofield Street, Curwensville,
Pennsylvania, 16833.
If full payment is not made by May 5, 2008, Lezzer intends to initiate any legal
proceedings available under the law to collect the amounts due under the Note. Altieri will also be
responsible for the payment of any reasonable attorney's fees actually incurred in the further collection
of this case as well as costs and fees related to any legal proceedings taken to complete collection.
Very truly yours,
BABST, CALLAND, CLEMENTS ZOMNIR, PC
EAD/jrc
cc: Thomas Yontosh, Lezzer Holdings, Inc.
By: ,~~_
Eliz eth A. (Betsy) Dup Is, Esquire
328 INNOVATION BLVD. SUITE 200 STATE COLLEGE, PA 16803 ~ T 814.867.8055 ~ F 814.867.8051
EXHIBR .
~.
._.~---
IN THE COURT OF COMMON PLEAS OF YORK~COUNTY, PENNSYLVANIA
CIVIL ACTION
LEZZER HOLDINGS, INC., )
Plaintiff, )
vs. )
ALTIERI ENTERPRISES, INC., )
Defendant. )
To: Altieri Enterprises, Inc.
1700 Westgate Drive
York, PA 17315
a3-,~ -~
NO. 2008-
NOTICE OF JUDGMENT
Pursuant to Rule 236, please be advised that judgment has been entered against you in
the above-captioned matter in the amount of $580,950.97.
Prothonotary
..
BIZ
BABST ~ CALLAND ~ CLEMENTS ~ ZOMNIR
A PROFESSIONAL CORPORAT[ON
ELIZABETH A. (BETSY) DUPULS
Attorney at Law
r sia.as~.soss
bdaPuts~e~~z~an
May 9, 2008
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Pamela S. Lee
York County Prothonotary
York County Judicial Center
45 North George Street
York, PA, 17401
By Overnight Mail
Re: Confession of Judgment for Lezzer Holdings, Inc.
Dear Ms. Lee:
Please find enclosed a Complaint for Confession of Judgment for filing
with your office. We have included the original filing, a check payable to your office in
the amount of $43.50 (for confession of judgment with complaint), a copy for mailing to
the defendant, an envelope for mailing to the defendant, and a copy to be time stamped
and returned to our office in the enclosed postage-prepaid envelope.
We have also enclosed the original Notice Under Rule 2958.1 for filing, a
copy of the Notice for service by the Sheriff (along with an additional copy of the
complaint to include with the Sheriff's service), a memorandum to the Sheriff with
service instructions, a check for service payable to the Sheriff, and an additional copy of
the Notice to be time-stamped and returned to our office.
Please contact me if you have questions regarding the documents or the
information we have provided. We appreciate your attention to this matter.
Very truly yours,
BABST CALLAND CLEMENTS ZOMNIR PC
By:
Eliza. th A. Dupuis, Esq ire
328 INNOVATION BLVD. I SU[TE 200 I STATE COLLEGE. PA 16803 I T 814.867.8055 (E 814.867.8051 I WWW.BCCZ.COM
.i ,.
' Y~ YORK COUNTY PROTHONOTARY Page 1 of 1
6/10/2008
2008-NO-00234-30
LEZZER HOLDINGS /NC vs. ALTIER/ ENTERPRISES /NC
Action
05/12/2008 JUDGMENT CONFESSED PURSUANT TO WARRANT 04307
OF ATTY 1
05/12/2008 COMPLAINT AND CONFESSION OF JUDGMENT ON 04452
NOTE=12-31-07 12
05/12/2008 NOTICE GIVEN RE: PA RCP 236 W/DOCUMENTS 05032
FILED 05-12-08 1
05/12/2008 AFFIDAVIT RE: NON-CONSUMER CREDIT 05164
TRANSACTION 1
Party Type Party Name
P LEZZER HOLDINGS /NC
A DUPUIS, ELIZABETH A D
ALTIER/ ENTERPRISES /NC
Total Number of Pages 15
CERTIFIED from the records of the urt of Co mon Plees of
Ybdt County, Pennsyhrania this of A, pp~
Paned S Lee, Protlronotary
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
LEZZER HOLDINGS, INC.,
Plaintiff, )
vs. ) NO.
ALTIERI ENTERPRISES, INC., )
Defendant. )
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the within Praecipe to Enter Judgment was
served on the following by depositing the same within the custody of the United States Postal
Service, first-class mail, postage prepared, addressed to:
Altieri Enterprises, Inc.
9017 Branch Road, Suite 201
Columbia, MD 21045
BABST, CALLAND, CLEMENTS &
ZOMNIR, PC
By:
Elizabet A. (Betsy) Dupuis, squire
Attorney for Plaintiff
328 Innovation Boulevard, Suite 200
State College, PA 16803
(814) 867-8055
Attorney I.D. No. 80149
Date: (~/,~~~b~
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