HomeMy WebLinkAbout08-4941COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
R.E. MICHEL COMPANY, INC.
Plaintiff
VS.
No. 08 - 149q 1 0,ivit tech
SUSQUEHANNA VALLEY HEATING
& COOLING, INC. ;
CIVIL ACTION
Defendant
CONFESSION OF JUDGMENT
Pursuant to the authority contained in the warrant of attorney set forth in the Contract
attached as Exhibit "A" of the Complaint filed in this action, I appear for the Defendant,
SUSQUEHANNA VALLEY HEATING & COOLING, INC. and confess judgment in favor
of Plaintiff and against the Defendant as follows:
Principal $9,259.17
Interest at 18.00% per annum
from January 14, 2006 $1,084.46
Attorneys fees (25%) $2,314.79
TOTAL $12,658.42
JUD ENT ENTE AS ABOVE
rothono erk o Court
CiA vision
BMATO ANDtS?C,iATF , P.C.
Rondld A'matd!Esq., Atty ID 432323
Michael J. Kennedy, Esq., Atty ID #72412
Michael R. Lessa, Esq., Atty ID #88617
Justin N. Davis, Esq., Atty ID #84464
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
R.E. MICHEL COMPANY, INC.
Plaintiff
VS.
SUSQUEHANNA VALLEY HEATING
& COOLING, INC.
No.
CIVIL ACTION
Defendant
COMPLAINT FOR CONFESSION OF JUDGMENT FOR
MONEY UNDER RULE 2951 (b)
Plaintiff files this civil action pursuant to Pennsylvania Rule of Civil Procedure 2951 (b) for
judgment by confession and avers the following:
1. The Plaintiff, R.E. MICHEL COMPANY, INC. is located at 1 R.E. Michel Drive,
Glen Burnie MD 21060.
2. The Defendant, SUSQUEHANNA VALLEY HEATING & COOLING, INC., is
an corporation with a last known address at PO Box 496, New Cumberland PA 17070-0496.
3. On or about January 14, 2006, Defendant, SUSQUEHANNA VALLEY HEATING
& COOLING, INC., for good and valuable consideration received, executed and delivered to
Plaintiff a written Application and Sales Agreement (hereinafter "Contract"). A true and correct
copy of Defendant's Contract with Plaintiff is attached hereto, made a part hereof and marked
Exhibit "A".
4. The attached Contract has not been assigned.
5. Judgment is not being entered against a natural person in connection with a consumer
credit transaction.
6. Defendant is currently in default by virtue of its failure to make payments pursuant
to the Contract.
7. Judgment has not been entered on the attached Contract in any jurisdiction.
Pursuant to the terms and provisions of the Contract, Plaintiff exercises its option to
Confess Judgment for the entire sum of money which may be due or become due under the attached
Contract.
9. As a consequence of the foregoing default, Defendant is indebted to Plaintiff in the
following amount:
Principal $9,259.17
Interest at 18.00% per annum
from January 14, 2006 $1,084.46
Attorneys fees (25%) $2,314.79
TOTAL $12,658.42
WHEREFORE, Plaintiff demands judgment against Defendant in the sum of $12,658.42,
plus costs as authorized by the warrant of attorney provisions of the attached Contract.
AMATO AN7?s SC S, P.C.
By:
Ronald Amat , Esq., Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Michael R. Lessa, Esq., Atty ID #88617
Justin N. Davis, Esq., Atty ID #84464
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
Attorney File: 2082429
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city Yin ? State ?N Zip Imo;{ 33 city
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Zip
Phone #
The undersigned here)}' males this application for credit to R.E. Michel Company. Inc., its successors, assigns, affiliated companies, divsicros or subsidiaries ("Creditor").
:thick in making this application the undersigned agrees to be bound b5 all of the terms and conditions contained in this Credit Application, any document,. referenced in this Credit
Application or any supplements. The undersigned agrees that all amounts payable on or before the due date ac shown on each invoice will he paid by the said due date, and if not
paid on or before said date, are then to be deemed to be delinquent. Should a credit availability be granted by Creditor, all decisions with respect to the extension or continuation
(11' credit shall be in the sole discretion of Creditor. Creditor may terminate any credit availability at any time within its sole discretion. ,i odicaCism fi?r business credit
tc dented or there is a denial of a reyimst for an ctiw?.? in basins cr 'it y^n hat'e the ri-kf to a writl? statement at the soaitk t?easoos
statemtytL please aonuml the mWreac or ld oho n number on frad of credit anolitsttnn within 60 days from the date you are notified of our dmision. We will send you a
written statement of reasons for the denial within all days of receiving your request for the statement.
It is understood that Creditor may impose and charge a service/finance charge or del inquency charge which is the lower of one and one-half percent (1-1/2%1 per month 118%
APR) or the highest rate allowed by law on any amount which becomes delinquent. Additionally, the undersigned agrees to be responsible for all collection costs and attorney's
tees. calculated at the rate of 259E of the amount placed, in connection with any delinquent amount placed for collection.
In the event that this application is made by individuals, or at any time the obligations referenced by this application are guaranteed by individuals, the undersigned and any
guarantors acknowledge and agree that any credit to be extended by Creditor to the undersigned is business debt and any epode or services cold by the ditor to the under-
cianed on credit shall not be for personal family or household use.
The undersigned agrees to pay for all purchases of goods and/or services according to the terms of Creditor. No terms or conditions different from the terms of Creditor will
become part of any sales agreement, purchase order. or other document unless specifically approved in writing by Creditor. No item will be accepted for return without prior
approval, and all returns are subject to a restocking charge. Payments may be applied against open charges in the discretion of Creditor. The undersigned agrees that the contin-
ued solvency of the undersigned is a precondition to any sale other than for cash or certified funds made by Creditor. The undersigned agrees to provide Creditor, upon request,
a statement representing that the undersigned is and remains solvent.
In the event that from time to time Creditor may owe credits, refunds or other monies to the undersigned, such indebtedness shall be deemed to be created from this Agreement
and Creditor shall have the right of recoupment of such credits or refunds within its sole discretion. In the event of default, the undersigned authorize any attorney of a Count of
Record to appear for me/us and to confess judgement against me/ns for the full balance owing to Creditor.
The laws of the State of Maryland shall be applicable to all actions arising under any agreement between the undersigned and Creditor. All accounts shall he due and payable
in Baltimore, MD and Sate of Maryland. In the event of litigation, unless otherwise determined by creditor in its sole discretion, personal jurisdiction and venue shall be in The
State of Maryland
THE PARTIES HERETO KNOWINGLY AND IR"TENTIONALLY WAIVE THE RIGHT TO A JURY TRIAL ON ANY ISSUE OR DISPUTE THAT MAY ARISE
BETWEEN THEM. In the event that the use of binding arbitration is desired rather than or instead of a waiver of a jury trial, a separate agreement is required.
THE. PERSONS SIGNING THIS APPLICATION CERTIFY THAT ALL OF THE INFORMATION CONTAINED IN THIS APPLICATION AND ANY ATTACHMENT OR
AMENDMENT IS TRUE. CORRECT AND COMPLETE TO THE BEST OF THEIR INFORMATION, KNOWLEDGE AND BELIEF
Original, handwritten signature of corporate officer
Signed: susQueh nn3 Val P7Z Heating & rml ing. Tnr_ (SEAL)
Please Print Fulf of Compan front page)
B (SEAL) Date lol
Signature Corporate officer, general partner, managing member, or proprietor
Title Ancet:?rtStnt
(plea print-)
Jh rusiderstgned acknou ledmra and agrees that Creditor may idol n outside relltltlinC rykes to &a*n info matki. oc the undersiened L?hc event that the ender-
cil;n4d. islare individralecL the signing fn this agreement bill conistitutt authorization to Creditor to utilia_ Bann=r cndd mpfidin t "ancies to provide repurls nn
% - tndivtdualts) m order to permit Creattpr tn?Rryg.. k..eh etyiluate the extension of anv ir?ntiess credit Add t3rr+i.ut should any individuals guaranltx l "lcdftof
111%Lundcaianod, said individualtsi sbatl hegr ?=-d with a coos of this Credit Apotteadon. and otrrin the st=etne of said naar_a_ my. shall rnmcpU( (.rtditnr's nee id'
consumer credit repgaing reports to assist in the evalnel[^^ ^r rhr rw?lit of mid guarantor(s).
PRINT: )?,ie (N
FULL LEGAL NAME
SIGNATU -(SEAL) Date l -
i ,7 e
VER I TI N
„r,. hereby states that he/she is the
of R l= Mtn (mMg.±W 0 -1?%-L- , Plaintiff in this action, and verifies that the statements
made in the attached document are true and correct to the best of his/her knowledge,
information and belief. The undersigned understands that the statements herein are made
subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to
authorities.
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The undersigned hereby males this application for credit to R.E. Michel Company. inc., its succescorb, assigns, affiliated companies, div;sions or subsidiaries ("Creditor").
and in making this application the undersigned agrees to be bound b) all of the terms and conditions contained in this Credit Application, any documents referenced in this Credit
Application or any supplements. The undersigned agrees that all amounts payable on or before the due date as shown on each invoice will he paid by the said due date, and if not
paid on or before said date. are then to be deemed to be delinquent. Should a credit availability be granted by Creditor, all decisions with respect to the extension or continuation
of credit shall be in the sole discretion of Creditor. Creditor may terminate any credit availability at any time within its sole discretion. tf XM aoniicadon for business credit
is dented or there is a den* of a tsy r [ WeansLin-Wness crediL van hate the right to a writte±+ siatemait of the specific masanl for the denial. Tb obtain the
rtatemenf please Contact within 60 day% from the date you are notified of our de-Lision We will trend you a
written statement of reasons for the denial within 30 days of receiving your request for the statement.
It is understood that Creditor may impose and charge a service/finance charge or delinquency charge which is the lower of one and one-half percent (1-1/2% ) per month (18%
APR) or the highest rate allowed by law on any amount which becomes delinquent. Additionally, the undersigned agrees to be responsible for all collection costs and attorney's
fees. calculated at the rate of 25% of the amount placed, in connection with any delinquent amount placed for collection.
In the event that this application is made by individuals, or at any time the obligadons referenced by this application are guaranteed by individuals, the undersigned and any
guarantor acknowledge and agree that any credit to be extended by Creditor to the undersigned is cosiness debt and any s or ervicee sold by the ditof to the under-
cianed on credit shall not be for personal family orhouse- Id use.
The undersigned agrees to pay for all purchases of goods and/or services according to the terms of Creditor. No terms or conditions different from the terns of Creditor will
become part of any sales agreement, purchase order, or other document unless specifically approved in writing by Creditor. No item will be accepted for return without prior
approval, and all returns are subject to a restocking charge. Payments may be applied against open charges in the discretion of Creditor. The undersigned agrees that the cordin-
ucd solvency of the undersigned is a precondition to any sale other than for cash or certified funds made by Creditor. The undersigned agrees to provide Credits, upon request,
a statement represent ing that the undersigned is and remains solvent.
In the event that from time to time Creditor may owe credits, refunds or other monies to the undersigned. such indebtedness shall be deemed to be created from this Agreement
and Creditor shall have the right of recoupment of such credits or refunds within its sole discretion. In the event of default, the undersigned authorize any attorney of a Court of
Record to appear for me/us and to confess judgement against me/us for the full balance owing to Creditor.
The laws of the State of Maryland shall be applicable to all actions arising under any agreement between the undersigned and Creditor. All accounts shall he due and payable
in Baltimore, MD and State of Maryland. In the event of litigation, unless otherwise determined by creditor in its sole discretion, personal jurisdiction and venue shall be in The
State of Maryland.
THE PARTIES HERETO KNOWINGLY AND INTENTIONALLY WAIVE THE RIGHT TO A JURY TRIAL ON ANY ISSUE OR DISPUTE THAT MAY ARISE
BETWEEN THEM. In the event that the use of binding arbitration is desired rather than or instead of a waiver of a jury trial, a separate agreement is required.
THE PERSONS SIGNING THIS APPLICATION CERTIFY THAT ALL OF THE INFORMATION CONTAINED IN THIS APPLICATION AND ANY ATTACHMENT OR
AMENDMENT IS TRUE. CORRECT AND COMPLETE TO THE BEST OF THEIR INFORMATION, KNOWLEDGE AND BELIEF
Original, handwritten signature of corporate officer
Signed: usQuehann3 Val leY Heating & f`nnl ing. Tnr_ (SEAL)
Please Prim Full of Compan front page)
(SEAL) Date
B
Signature Corporate officer, general partner, managing member, or proprietor
Title nc h_ri,% fxh- . i tlp.t' -
(Plea Print)
Jji underswnN+ acknowledges and agrees that Creditor may utilize outside reporting services to brain LnEwmattia- o. the nn.?xrsie?+ed in the event that Lhp ender-
si"w:.d is/Are indtviduallsi. the sigrii?g of this a;, •?t shall cnncitute authorization to Creditor to utilize ecw!s+!-±er credd reporh agencies- prnvidr reports on
jild inlibJdual(s) In order to ie Creditor to uplimpriately evaluate the extension of any business credit AddLtiMatlc should any individuals guoranttx the deb! of
11iLLipdrirsienedlsaid individual(s) shall be provided with a c(My of this Credit ARplication, and n= the signing of said eua=h. shall roaunt to (n-dltor y arw of
ccuigumer crrdil reporting agencies' rrDarts to assist in the oval •ntion of the credit of said guarantor(s).
Account #288004
1. Larne v ' al`?:;r?+7 ti 'k? •?n • n u - 3. Name zII
i
Street t I '? yu.l?rrt t?A - Street ?_MC`r` K)n`.h.
city state _zip 1 . City ?'h A zip "t 3
?t??
Account No. 1.lrt_`'i?l Pho a Account No. H_ Phone # 1 5
2. Name J.'tntn `? ro(L2 +T?1 ___ 4. Name
Street t,V !j:2- Street _
City •Ycg.>?* State Zp iyi 3 City
(" ic) ??? _ SL t Account No.
Account No. i j i 1 a 7 Phony # , . FT
(SEAL)
Date
1. Name.. 3. Name
' Street Street
City „ State Zip City State ' Zip
Account No. Phone-# Account No. Phone #'
2. Name _ 4: Name
Street _ Street
City State Zip City State Zip
Account No. Phone # Account No. Phone l
The undersigned hereby makes this application for credit to"R.E: Michel Company, Inc,,,its successors, assigns, affiliated companies, divisions or subsidiaries ("Creditor"),
and in; makirig this-application the undersigned agrees, to be bound by all of the terms. and conditions contained in this Credit Application; any documents referenced in this Credit.
Application or airy supplements. The undersigned agrees that all amounts payable on or before the due date as shown on each invoice will be paid by the said due date, and if not
paid on or before said date, are then to be deemed to be delinquent. Should a credit availability be granted by Creditor, all decisions with respect to the extension of continuation
of credrtshal? be in the sole discretion of Credito.-Creditor may terminate any credit availability at any. time within its sole discretion. If
yourapplication'for business r rtit
is"de'nled ortheapis a'deaial of a reanestfor an increase "n b sinecc rreylit yQ havr the rightto a'Wlitten state6Pnt of the gperifir reasonctorth d pia 'To ob in he
SA r d y
m f
please cont9ct telepfrone au_mber-on $onk o credi
the address or t gyp i ation within 60 days from the date: you are notified of our, decision we will send you a
Y?°statemeni"ofYrcw6ns for the demal,withirM0'days of reccivmg your requesr.for the statement ?t F"
µ that Creditor may impose and charge a scrvicelfinance.charge or delinquency charge which is the lower of one and one-half percent (1--1/2%) per month (1 S%
33 ?.
est rate allowed by'law?on any amount,zhich becomes delmquent_Additionally, the undersignedagrees to be responsible for. alfco' l e tion costs and attorney's
Kr atthe rate of ?5% of the amount placed, in
connection with any detinquent ainuuut placed for collccl?on i`-
1, 1-", 1 Xet
ven . ?t• this application is made by individuals, or at any time the obfigaions referenced by;:this applicatioiiarc, qu?ara=te -d by rridiyrduals the undersigned and any,
gu - a pWledge and agree that any credit to be extended by Creditor to tho undersigned is 6usinee5 debt Zd auy EQx ! or serviczS, sold by Lc Creditor Co' he and r-
de' rghe l agrees to payrforall purehases,of goods and/or services according to the terms of Creditor. No terms or conditions different from the terms of. Creditor will
{ any-sales agreement, purchase order; or other document unless specifically approved, in writing byCreditor. No Item will be ac' pied f01-murn anthoutpiioT
reivins are sub ecYto arestockmg cbargc Payments may tie applied o inst open chaiges in the`discrehon ofi Creditor The undersigned agrees that the contin
a s v je undersigned is a precondition t oany sale other than for cash or certified funds made by Creditor The'undersigned agrees. to prbvtdo-Cred for upon request
a s r g that theIru rsigned'is and remains solvant
1 ', ky h -
- from to time Creditor may owe credits:rnfunds or other monies to the underrgned such indebtedness shallbe?deemed to becreated from this Agreement
_ aril e the right of'recoupmen of such credits or refunds within its sole discretion In the eveut of defaul tb4tindersgned authoriz?c any_attomey of a:Court of
for mclus and to confess judgement ag"i ioe/us for the full balanceowing to Creditor. °« r
the State of Maryland shall be applicable to ail actions arising under any ernent between the undersigned and Creditor. All accounts, shallbe due and payable,
., in and State of Maryland' In the, event of litigation, unless otherwisedete>mirieil by creditor in its sole discretio? personal jurisdiction and venue shall be in The
mF. HERETO_KNOWINGLY AND INTENTIONALLY WAIVE THE RIGHT TO A.7URY TRIM ON ANY=ISSUE OR 11 1 . DISPUTE THAT MAY ARISE
B r ' In' the event that the use of binding arbitration is desired rather than or instead of a waiver of a jury trial, a separate agreement isrequired:
TH S"SIGNING THIS'APPLICATION CERT11 Y THAT ALL OF THE INFORMATION CONTAINED IN THIS AFPLICATIOI?'AND ANY'ATT ACHlvIENT OR'
Alv 1.4ETV T IS TRUE, CORRECT AND COMPLETE-TO THE BEST OF THEIR INFORMATION, KNOWLEDGS'AND BELIEF
St
(SEAL)
?4 Pleasq Print Full Legel'Name of Company (as on front page)
`s
BY' (SEAL) Date'
Signature Corporate officer, general partner, managing member, or proprietor
r
Title?' -
(Please Prin')
The undersimed acknow"i!es a-nd aF.r that Cred_tor may utilize outside reporting sexy ct8 to OWnbformation on the undersigned, In the event that the nd r
sign is/s*Y LdividnAl(s). the rig nE of this agrCem' t shall co Otute authorization to Creditor to utilize rnnenmer credit repQrting ggendes to prgvide reports on
said mdtvrdu>•1(s)`in order to permit Creditor to appmpr atelp'evaluate the a ension of any business credit AdditionaAp:'sbould any individuals guarantee the debt of
theundersio++ed said ind_ividualfc) shall be provided with a cogy of this Credit Application. and upon he signing of said guaranty, shall consent to Cre " tor's use -of
consnrner credl+ reporlinL, age_Ddes' reports to as?ict in the evaluation of the credit of said guarantor(s)
u
PRINT:,
FULL LEGAL NAME
SIGNATURE: (SEAL) Date
1. Name 3. Name,
,A
! Strut Street
City State Zip City State Zi
Account No. Phone# Account No. Phone#
2. Name
4 Name -
Street Street
City: State Zip City State Zip
Account No. "Phone # Account No. Phone#
?k.,....
Ttic undersigned hereby makes this application for crediuoR E: Michel Company, Inc., its successors, assigns, affiliated companies, divisions or_subsidiaries (-"Creditor-"),
-
and iu makrrigttus application the undersigned agrees to be bound by all of the terns and conditions contained in this Credit Application, any documents referenced inthis Credit
Application onany supplements. The undersigned agrees that all amounts payable on or before the due date as shown on each invoice will be paid by the said due date, and if not
paid on or before said date, are then to be deemed to be delinquent. Should.a credit availability be granted by Creditor. all :decisions with respect to-the extension or continuation .
of credit shn71 be 'm the sole discretion ofCrcditor: Creditor may terminate any credit availability at any, time within its sole discretion. If vo<r anpLeation for b tines crP?lit
a o ° ' t6 a' cwstaterhexit of the mecific r e . . the
E fease.contact the address or telenfione d b..r on` front of credt anuLcation within 60 days ffom the date you are notified of our decision. We will send you a
r ..
y •.:
a ofrreasons for.the denial Within?3Q?days of receiving yotu requesrfor thcstatement
HK } thaC'Credrtor may rmposr. and charge a servicelfmance.chargc or delinquency charge winch is the lower of one and one-half percent (1-l ) per month (1846
A$R hest rate'allowettby.law on any amount wh ch becomes dcLmquent Additionall}, the undersigned agrees to be responsible for- all collection costs and attorney's
tthe raft of 2596 of the amount placed; iu connection with. any delinquenf unount placed for collection
d ,
at this a mdrv
,,r tt ' Ve PPhcation is made by ideals or at any time the obligations refcrencui by this appbcatfon'are.guaranteed by mdiv duats,'th n undersigned and.any
U ;edge and agrcc.thai any crcdrt to be extended by Creditor to the'undersigned is busiljuG debt and any-P or scni ..'sold by Le ditor to hr under
end a;rees to pay?for all purchases'of goods 9rillor services according to the terns of Creditor.'No terms pr conditions different from the terms of Creditor will
y.
a `siiles agreement, purchase order or other document unless specifically: approved in writing by Crtcitor No ' e'n will be acceQte for re?u anthout prow.
_.r lretums are subject to a re-stockrug charge Payments may tic applied against open charges in tliC dtscrefion'of Cie itor The undewsrgned`_agrees that the contra
u s o y .undersigned is a precondition town} sale other than for cash or c-, a ed funds tirade 'by Creditor The.undcrsigned agrees:to provide-Creditor ulna request;
turn that the'flndersighed'is and remams?solvcnL ?'4 T ' i + x r s't r '
?r
ri a[firom time to time Creditor may owecreditsr refunds or other monies to the undersigned, such indebtedness shall be deemed to be created frotp ths'Agreement_
aye tberr ht ofrecou went of"such credits`or refunds witlaii .its sole discret on. In the event f defaul4 the undersigned authorize any. attomeyof a Court of
R for meAus and to confess judgement agairistmc/us.f6r the full balance owing! to Creditor.
y t? , t .6 State of Maryland shallbe applicable to all actions ar s ng under any agreement between the undersigned and Creditor All. accounts shaKbe due and payable;
in B and SWe of Maryland.' In'the event of litigation, unless otherwise determined by creditor in its'sole discretio? personal jurisdiction and venue sball be inThe
Sta ???' - - c •.J? t 7.-,. ? aYh ? a `-u it-. ..y.:
?
v BERETOXNOW'INGLY AND INTENTIONALLY WAIVE TI-115 RIGHT TO A-JURY TRIAL ON'ANWASSUE OR DISPUTE7THA.T MAY ARISE
B In the event that the "use of binding arbitration is desired rather than" or instead of a waiver of a jury trial: a separate agreement is required:
Y' \ +:. L r
y r. €SIGNIIICT.THIS APPI:JcATION* Y THttT'AI I: OI THE'INFOPIAMON CONTA11MIJ THIS APFUCATION AND ANY ATTACHMENT OR
IS I RLJE CORRECT AND COtv1PL -,TO TH BEST OF THEIR INFORMATION, KNO?VL.EDGEiAND BELIEF.
t .
(SEAL)
Ph ao Print Pull Legal Name of Company (es on fibnt page)
By (SEAL) ' Date „
Siggaturc Corporate officer, general partner, maiiaging member, or proprietor
Title
(Please Print)
The u_dershimeed a6mowledees and asrerc that Creditor map utthzeoutside reporting services to obtaL information on the &rsiened In the event that he nd r
sl2ned g/are adividual(s) the cigp„ine of hie agree: ent shall constitute autho zadon to Creditor to utilize consumer' credit repartinQ agencies proside reports on
on
said LdivkluaIW in order-to_permit Creditor to appropriately evaluate the extension of anybucinm creditAddition°Lly, should any indi guarantee the debt
of
rile undersi»ed - sa?d'individual(s) cli i be proAded with a copy of this Credit' Application and up9p the sing of said guaranty shag consent t Creditor's of
consumer credit repo 'ngigeacies' mpQrts to c t in he evaluation of he credit of said guaranter(a)PRINT:
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FULL LEGAL NAME
SIGNATURE: (SEAL) Date
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
R.E. MICHEL COMPANY, INC.
Plaintiff No. ?$ _ yq4 ?iVi lr h
VS.
SUSQUEHANNA VALLEY HEATING
& COOLING, INC.
CIVIL ACTION
Defendant
CERTIFICATION OF ADDRESSES OF PARTIES
I, Michael Kennedy, attorney for Plaintiff, hereby certify that the last known
address for the Plaintiff and Defendant are as follows:
R.E. MICHEL COMPANY, INC.
1 R.E. Michel Drive
Glen Burnie MD 21060
SUSQUEHANNA VALLEY HEATING
& COOLING, INC.
PO Box 496
New Cumberland PA 17070-0496
AMATO AND AS OCIATE , P.C.
By:
Ronald Amato, sq., Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Michael R. Lessa, Esq., Atty ID #88617
Justin N. Davis, Esq., Atty ID #84464
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
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7-3 - -
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
R.E. MICHEL COMPANY, INC.
Plaintiff No. p$ - 041 C;vi t TQJ-m
VS.
SUSQUEHANNA VALLEY HEATING
& COOLING, INC.
CIVIL ACTION
Defendant
NOTICE OF JUDGMENT
To: SUSQUEHANNA VALLEY HEATING
& COOLING, INC.
PO Box 496
New Cumberland PA 17070-0496
Pursuant to Pa. R.C.P. No. 236, you are hereby notified that judgment by confession has been
entered against you for $12,658.42 in the above captioned matter. A copy of all documents filed
with the prothonotary in support of the within judgment ar nclosed.
Date: $/18/08
P OT T R - OUNTY
Per:
If you have any questions concerning the above, please contact the undersigned.
AMATO AND SO IAT , P.C.
By:
Ronal Amato, sq., Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Michael R. Lessa, Esq., Atty ID #88617
Justin N. Davis, Esq., Atty ID #84464
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
R.E. MICHEL COMPANY, INC.
Plaintiff
No. 08-4941 Civil
VS.
SUSQUEHANNA VALLEY HEATING
& COOLING, INC. CIVIL ACTION
Defendant(s)
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of Plaintiff's Notice Under
Rule 2958.1 of Judgment and Execution Thereon was served via first class mail and
certified mail, postage prepaid on September 12 2008:
Susquehanna Valley Heating & Cooling, Inc.
PO Box 496
New Cumberland PA 17070-0496
AMATO AND ASS CIA ES, P.
By:
Ronald Amato, Es ., Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Michael R. Lessa, Esq., Atty ID #88617
Justin N. Davis, Esq., Atty ID #84464
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
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