Loading...
HomeMy WebLinkAbout09-3601Johnson, Duffle, Stewart & Weidner By: Elizabeth D. Snover I.D. No. 200997 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff Mid Penn Bank MID PENN BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. CIVIL ACTION - LAW//?? BROOKE RHODES, : NO. O9 - %01 eivi I Tet-t + Defendant PRAECIPE TO TRANSFER JUDGMENT PURSUANT TO Pa.R.C.P. 3002 TO THE PROTHONOTARY: Please enter in the judgment index a judgment in the amount of $256,900.00 against Brooke Rhodes. Said judgment is being transferred from the Court of Common Pleas of Dauphin County, Pennsylvania. Attached hereto is an exemplified copy of all the docket entries in the action and a certification of the amount of the judgment which we are herewith filing of record. Respectfully submitted, O?. 2Q Q q Date: Elizabeth D. ver ! I A In The Court of Common 301eag; of Maupbiu Countp, Veun!pYbania Mid Penn Bank VS. No. 2009-CV-05177-NT Brooke Rhodes CERTIFICATION OF DOCKET ENTRIES AND JUDGMENT I, the undersigned Prothonotary of the Court of common Pleas of Dauphin County, Pennsylvania, do hereby certify that the attached is a full, true and correct copy of the docket entries in the above captioned case. I further certify that judgment was entered in favor of Plaintiff, Mid Penn Bank and against Defendant, Brooke Rhodes, on April 21, 2009 in said case in the amount of $256,900.00. In Cft imonp Wbereof, I have hereunto set my hand and affixed the seal of the Court, on Wednesday, May 27, 2009. ' V - ' -- ?. ??el Proth notary By ?e?j Deputy/ *4 jgR Date: 5/27/2009 Time: 10:31 AM Page 1 of 2 Filed: Subtype: Comment: Dauphin County Complete Case History Case: 2009-CV-05177-NT Mid Penn Bankvs.Brooke Rhodes 4/21/2009 Notes Physical File: Y Appealed: N User: KWEBB Status History Pending 4/21/2009 Pending / Judgment 4/21/2009 Judge History Date Judge Reason for Removal 4/21/2009 No Judge, Current Payments Receipt Date Type Amount Johnson Duffie Steward & Weidi 193959 5/27/2009 Miscell aneous 23.00 Exemplified Record 23.00 Snover, Elizabeth D (attorney for 191058 4/21/2009 Civil Filing 35.50 Total 58.50 Miscellaneous Receipts Receipt Date 193959 5/27/2009 Exemplified Record 23.00 Sum: 23.00 Plaintiff Name: Mid Penn Bank SSN: Address: DOB: Sex: Phone: Home: Work: Employer: Send notices: Y Litigant Type: Comment: Attorneys Snover, Elizabeth D (Primary attorney) Send Notices Defendant Name: Rhodes, Brooke SSN: Address: DOB: Sex: Phone: Home: Work: Employer: Send notices: Y Litigant Type: Comment: Attorneys Snover, Elizabeth D (Primary attorney) Send Notices Register of Actions 4/21/2009 Plaintiff: Mid Penn Bank Attorney of No Judge, Record: Elizabeth D Snover New Civil Case Filed This Date. No Judge, Date: 5/27/2009 Dauphin County Time: 10:31 AM Complete Case History Page 2 of 2 Case: 2009-CV-05177-NT Mid Penn Bankvs.Brooke Rhodes Register of Act ions 4/21/2009 Filing: Complaint with Confession of No Judge, Judgment Paid by: Snover, Elizabeth D (attorney for Mid Penn Bank) Receipt number: 0191058 Dated: 4/21/2009 Amount: $35.50 (Check) For: Mid Penn Bank (plaintiff) On Complaint filed Judgment in No Judge, favor of Plaintiff and against Defendant in the sum of two hundred fifty-six thousand nine hundred and 00/100 Dollars ($256,900.00) by virtue of authority contained in the Warrant of Attorney filed dated 3/15/2007 payable installments with interest, costs, etc. --- for colt'n. Inquisition and Exemption Waived. Entered At 11:06 AM Stephen E. Farina, Prothonotary All Documents mailed. Defendant: Rhodes, Brooke Attorney of No Judge, Record: Elizabeth D Snover Judgment Order date In Favor Of Disposition Judgment 04/21/2009 Plaintiff 04/21/2009 Open Judgment Comment: 256900.00 Plaintiff: Mid Penn Bank Defendant: Rhodes, Brooke MAY 2 7 nng I hereby certify that the foregoing is a true nd cgrrect c y o? original filed. User: KWEBB Prothdnotary/Clerk of Courts 0,00nf&fM0c7qj(;l//j ID PENN BANK, Plaintiff V. ROOKE RHODES, Defendant To: Brooke Rhodes IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW P21- You are hereby notified that on 2C against you in the amount of $256,900.00, in the above-captioned APR 212009 Date: by confession was entered 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 FORT)tBELOVVtO FIND OUT WHERE YOU CAN GET LEGAL HELP. Dauphin County Lawyer Referral Service r,'?::, rv `'?c? 213 North Front Street Harrisburg, PA 17101 ;r,' ,, :i (717) 232-7536:. ,- -i .. I hereby certify that the following is the last known address of the Defendant stated in 00certificate of address: Brooke Rhodes 623 Hill Drive New Cumberland, PA 17070 By: Elizabeth Snover Attorney Plaintiff MAY 2 7 20.09 1606 n fi My that the foregoing,is a Mie aril dOtr`M Copy of the original filed. Prethcr, MY APR 212009 MID PENN BANK, IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA n, Plaintiff C.?{/ NO ,5MJ V. CIVIL ACTION - LAW BROOKE RHODES, N Defendant r r...... N !::'Y1 C7 NOTICE UNDER RULE 2958.1 OF JUDGMENT AND EXECUTION THEREON _ r TO: Brooke Rhodes cn A judgment in the amount of $256,900.00 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 the written Installment note agreement at paragraph ten (10) 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Dauphin County Lawyer Referral Service 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 JOHNSON, DUFFIE, STEWART & WEIDNER BY: PX?Z?11 Eli-zabet . Snover 301 Ma *6t Street Lemoyne, PA 17043-0109 Attomeys for Plaintiff Johnson, Duffle, Stewart & Weidner By: Elizabeth D. Snover I.D. No. 200997 301 Market Street P. 0. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 MID PENN BANK, V. Plaintiff BROOKE RHODES, Defendant No ?C!45i 77 CIVIL ACTION - LAW CONFESSION OF JUDGMENT FOR MONEY DAMAGES Pursuant to the authority contained in the warrant of attorney contained on page two of the written Promissory Note agreement and on page two of the Change in Terms agreement, true and correct copies of which are attached as Exhibits "A" and "C" respectively to the Complaint filed in this action, I appear for the Defendant and confess judgment in favor of the Plaintiff and against the Defendant as follows: Unpaid Principal and Interest Balance $252,250.00 Late Charges $ 1,494.00 County Fees $ 156.00 Attorneys' Fees and Costs S 3.000.00 TOTAL: $256,900.00 JOHNSON UFFIE, STEWART & WEIDNER BY: Eliza t . Sn!iver Attorne for Plaintiff 'Attorneys for Plaintiff Judgment entered as above, RTg2 2009. t N im .V- C x•• r7l IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA o' .... ! --N rd es ?3/1y.. M Johnson, Duffle, Stewart & Weidner By: Elizabeth D. Snover I.D. No. 200997 301 Market Street P. 0. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 MID PENN BANK, Plaintiff V. BROOKE RHODES, Defendant : N za Attorneys for Plaintiff `? `v c? n sa rn_..:: N ?._ ?? ?: 7u. s Zs. `?' IN THE COURT OF COMMON REAS OF DAUPHIN COUNTY,. PENNSYLVANIA NO.6V Cv51-77 AJ CIVIL ACTION - LAW COMPLAINT PURSUANT TO Pa.R.C.P 2951(b) FOR CONFESSION OF JUDGMENT FOR MONEY DAMAGES The present action is brought pursuant to Rule 2950 et. seq., of the Pennsylvania Rules of Civil Procedure, whereby the Plaintiff, Mid Penn Bank, confesses judgment against Defendant, Brooke Rhodes, for money damages, on the basis of a Promissory Note executed between the parties on March 15, 2007 and modified by a Change in Terms agreement dated December 30, 2008 whereof the following Is a statement: 1. The Plaintiff, Mid Penn Bank, ( "Mid Penn") is a is a state banking institution, having an office located at 349 Union Street, Millersburg, Pennsylvania, 17061. 2. This action arises out of a Promissory Note and Mortgage related to several commercial properties located in Dauphin County, PA, that was entered into between Mid Penn and Brooke Rhodes on March 15, 2007 for the principal amount of $303,520.00. A true and correct copy of the Installment Note is attached and incorporated herein as Exhibit A. 3. The Defendant Brooke Rhodes, ("Rhodes") is an adult individual whose last know address is 623 Hill Drive, New Cumberland, PA 17070. A Certificate of Address is attached herewith as Exhibit B. 4. The Promissory Note provides that Rhodes was obligated to pay $2,523.21 per month commencing April 15, 2007 with payments due on the 15°i of each month until March 15, 2017 with a final catch up payment. 5. The Promissory Note further provided that should Rhodes default by failing to make payment to Mid Penn, that Mid Penn could confess judgment as to any amount outstanding along with late charges, reasonable court costs, and attorney's fees, by the warrant of attorney contained therein and in bold and caps at page 2 of the Note. See, Exhibit A. 6. The Note also provided that Brooke Rhodes would submit to the jurisdiction of the Court of Common Pleas of Dauphin County. (Exhibit A). 7. Rhodes began making payments on the Note obligation, however, the parties entered into a modification agreement, called a Change in Terms Agreement on December 30, 2008 for a new principal amount of $244,690.18 with monthly payments of interest only due in the first three (3) months with principal and interest payments of $2,026.79 commencing March 15, 2009 with payments being made thereafter on the 15t' of each month until February 15, 2029. A true and correct copy of the Change of Terms Agreement is attached hereto as Exhibit C. 8. Rhodes is currently in default by failing to make timely payments under the Note and Change of Terms. 9. Rhodes currently owes $244,690 in outstanding principal, $7,560 in intere $1;,94 in fate fees, and $156 in county fees, `'r, . L`` rl •, c7 r ' C 10, The Change in Terms Agreement also provides that should Rhodes default by failing to make payment to Mid Penn, that Mid Penn could confess judgment as to any amount outstanding along with late charges, reasonable court costs, and attorney's fees, by the warrant of attorney contained therein and in bold and caps at page 2 of the Change in Terms Agreement. (Exhibit C). 11. Attorney's fees in this matter are estimated to be $3,000. 12. In association with the original Promissory Note, Rhodes signed a Disclosure of Confession of Judgment in which he acknowledged that, upon a default, Mid Penn could take a confessed judgment and proceed to foreclose on his real property thereafter and that Rhodes waived his right to object to the confession and foreclosure. A true and correct copy of the Disclosure of Confession of Judgment Is attached hereto as Exhibit D. 13. Rhodes further acknowledged on that Disclosure that he was represented by his own legal counsel with regards to the loan. (Exhibit D). 14. Mid Penn has demanded payments by Rhodes to bring the Note and Agreement current, however, Rhodes has refused and neglected and continues to refuse and neglect to pay the full amount owing to Mid Penn under the terms of the Promissory Note and Change of Terms Agreement. 15. This judgment is not being entered by confession against a natural person in connection with a consumer credit transaction. 16. Rather, the obligation under the Note and Change of Terms Agreement arises from a loan for a commercial property. 17. Confessed Judgment on the Promissory Note or Change of Terms Agreement has not been entered in any other jurisdiction. WHEREFORE, Plaintiff, Mid Penn Bank, demands judgment against Defendant, Brooke Rhodes, in the amount of $256,900.00 which represents the amount outstanding on the Installment Note obligation, attorney's fees, and court costs. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER BY: E izab D. Snover Attom for Plaintiff 1- . b1 VERIFICATION I, Gregory Scheer, Collections Manager for the Mid Penn Bank, verify that I am authorized to make the statements herein and that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Gregory heer Dated; 4 1"7 0 q PROMISSORY NOTE References In the shaded area are for Lenders u only and do Any Item above containing '""' has limit the a ilcablifly of 9* document to any partlm ler loan in omitted due to text lenath itmitadons- Borrower: Brooke R. Rhodes (99N: 194.9044so) 928 HIO Drive New Cumberland, PA 17070 Lender: Mid Penn Bank Market Square Playa -0 `I 17 North Second Street r °?• Harrisburg, PA 17101 x Principal Amount: $309,520.00 Interest Rate: 7.800% Date of Date: Wroh 15,127 PROMISE TO PAY. Brooke R. Rhodes ("Borrower') promises to pay to Mid Penn Bank ("t.Nider"), or order, In laadul of the United States of Amorhm the prh sipaI amount of Three Hundred Three Thousand Five Hundn?sd Twenty S 001i00 Dollars (together with Interest at the rate of 7.1100% par annwun on the unpaid principal balance from March 15, 2007, until pald In full. The interes rats may change under the terms and conditions of the "INTEREST AFTER DEFAULT" section. PAYMENT. Borrower will pay this loan in 119 regular psyments of $2,1125.21 each and one Irregular last payment estimated at $211,258.49. Borrower's first payment Is duo April 15, 2007, and all subsequent psymahh are due on the sane day of each month after that. Borrower's final payment will be due on March 15, 2017, and will be for all principal and all accrued Interest not yet pail. Payments Include principal and Interest. Unless otherwise agreed or required by applicable law, payments will be applied first to any accrued unpaid Interssh then to principal; then to any unpaid oollsoWon costs; and then to any late charges. The annual Interest rate for ties Notes Is computed on a 8991890 basis; that Is, by applying the raft of the annual Interest rate over a year of 890 days, multiplied by the outstanding principal balance, multiplied by the actual number of days the principal balance is outstanding. Borrower will pay Lender at Lender's address shown above or at such other phtce as Lender may designate In writing. PREPAYMENT. Borrower agrees that all loan fees and other prepaid finance charges are earned fully as of the date of the loan and will not be subject to refund upon early payment (whether voluntary or as a result of default), except as otherwlee required by law. Except for the foregokg, Borrower may lay without penalty all or a portion of the amount owed earlier than it Is due. Early payments will not, unless agreed to by Lender in writing, relieve Borrower of Borrowers obligation to continue to make payments under the payment schedule. Rather, early payments will reduce the principal balance due and may result In Bomowwr's n*kkng fewer payments. Borrower agrees not to send Lender payments marked "pail in full', "without recourse", or similar o?If Borrower sends such a payment. Lender may accept it without Wig any of Leader's rights under this Note, and Borrower will remain to pay any further amount owed to Lender, AN written communications concerning disputed amounts, Including any check or other peymerd Instrument that kndlostes that the payment oonstltutes "payment In full" of the amount owed or that Is tendered with other conditions or limitations or as full satisfaction of a disputed amount must be mailed or delivered to: Mid Penn Bank, Market Square Plaza, 17 North Second Street, Harrisburg, PA 17101. LATE CHARGE. If a payment Is 16 days or more late, Borrower will be charged 10.000% of the regularly scheduled payment or $U.00, whichever is greater. INTEREST AFTER DEFAULT. Upon default, Including failure to pay upon final maturity, the Interest rate on this Note shall be Increased by 6.000 percentage points. If judgment Is entered in connection with this Note, Interest will continue to acone after the date of judgment at the rate in effect at the time judgment is entered. However, In no event will the Interest rate exceed the maximum Interest rate iknitallons under -applicable law. DEFAULT. Each of the following shall constitute an event of default ("Event of Defautt j under this Note: Payment Default Borrower falls to make any payment when due under this Note. Other DefauBt. Borrower taps to comply with or to perform any other term, obligation, covenant or condition contained In this Note or In any of the related documents or to comply with or to perform any term, obligation, covenant or condition contained in any other agreement between Lender and Borrower. False Statements. Any warranty, representation or statement made or famished to Lender by Borrower or on Borrower's behalf under this Note or the related documents Is false or misleading in any material respect, either now or at the time made or furnished or becomes false or misleading at any time thereafter. Death or Insolvency. The death of Borrower or the dissolution or termination of Borrower's existence as a going business, the insolvency of Borrower, the appointment of a recehrer for any part of Borrower's property, any assignment-for the benefit of credhore, any type of creditor workout, or the commencement of any proceeding under any bankruptcy or Insolvency laws by or against Borrower. Creditor or Forfeiture Proceedings. Commencement of foreclosure or forfeiture proceedings, whether by judicial proceeding, self-help, repossession or any other method, by any creditor of Borrower or by any governmental agency against any collateral securing the loan. Thle Includes a garnishment of any of Borrower's accounts, including deposit accounts, with Lender. However, this Event of Default shall not apply If there Is a good faith dispute by Borrower as to the validity or reasonableness of the claim which Is the basis of the creditor or forfeiture proceeding and If Borrower gives tender written notice of the creditor or forfeiture proceeding and deposits with Lender monies or a surely bond for the creditor or forfeiture proceeding, in an amount determined by Lender, In Its sole discretion, as being an adequate reserve or bond for the dispute. Events Affecting Quarentor. Any of the preceding events occurs with respect to any guarantor, endorser, surety, or accommodation party of any of the Indebtedness or any guarantor, endorser, surety, or accommodation party dies or becomes Incompetent, or revokes or disputes the validity of, or liability under, any guaranty of the Mdebtednesa evidenced by this Note. Adverse Change. A material adverse change occurs In Borrower's financial condition, or Lender believes the prospect of payment or performance of this Note Is Impaired. Insecurity. Lender In good faith believes Itself Insecure. LENDER'S RIGHTS. Upon default, Lender may, after giving such nodose as required by applicable law, declare the entire unpaid principal balance under this Note and all accrued unpaid Interest Immediately due, and then Borrower will pay that amount. ATTORNEYS' FEES; EXPENSES. Lender may hire or pay someone else to help collect this Note If Borrower does not pay. Borrower will pay Lender that amount. This Includes, subject to any limits under applicable law, Lender's attorneys' fees and Lender's legal expenses, whether or not there Is a lawsuit, including attorneys' fees, expenses for bankruptcy proceedings (Including efforts to modify or vacate any automatic stay or Injunction), and appeals. If not prohibited by applicable law, Borrower also will pay any court costs, in addition to all other sums provided by law. JURY WAIVER. Lender and Borrower hereby waive the right to any jury trial In any action, prowsding, or counterclaim brought by either lender or Borrower against the other. PROMISSORY NOTE Loan No: 500039631 (Continued) Pape 2 GOVERNING LAW. This Note wlli be governed by federal law applicable to Lender and, to the extent not preempted by federal law, the laws of the Commonwealth of Pennsylvania without regard to Its conflicts of law provisions. This Note has boon accepted by Lender In the Commonwealth of Pennsylvania. CHOICE OF VENUE. If there Is a lawsuit, Borrower agrees upon Lender's request to submit to the jurisdiction of the courts of Dauphin County, Commonwealth of Pennsylvania. RIGHT OF SETOFF. To the extent permitted by applicable law, Lender reserves a right of setoff In all Borrower's accounts with Lender (whether checking, savings, or some other account). This Includes all accounts Borrower holds jointly with someone else and all accounts Borrower may open In the future. However, this does not include any IRA or Keogh accounts, or any trust accounts for which setoff would be prohibited by law. Borrower authorizes Lender, to the extent permitted by applicable taw, to charge or setoff all sums owing on the Indebtedness against any and all such accounts, and, at Lender's option, to administratively freeze all such accounts to allow Lender to protect Lender's charge and setoff rights provided in this paragraph. COLLATERAL. Borrower acknowledges this Note Is secured by the following collateral described In the security instruments listed herein: (A) a Mortgage dated March 15, 2007, to Lender on real property described as 'Real Property located at 2137 N. 4TH Street, 2139 N. 4TH Street, Harrisburg, PA, 17110, 59 N. 13TH Street, 210 N. 14TH Street Harrisburg, PA 17103' and located In Dauphin County, Commonwealth of Pennsylvania. (B) an 2137 N. 4TH Stre TH Street Hardaburg, PA, 17110, 59 N. 13Tto Lender on H 8eat 210 NI. 14 reef Haarrrisburg,ePA r 17103" and located in Dauphin County, 139 N. 4onwealth of, Pennsylvania. (C) a Mortgage dated March 15, 2007, to Lender on real property described as "Real Properly located at 213 Reno Street, New Cumberland, PA 17070' and located In Cumberland County, Commonwealth of Perrnsylvanla. (D) an Assignment of All Rents to Lender on real property described as "Real Property located at 213 Reno Street New Cumberland, PA 17070" and located In Cuanberlan d County, Commonwealth of Pennsylvania. INCORPORATION OF COMMITMENT LETTER, The terms and conditions of a Commitment Letter dated February 19, 2007, between Lender and Borrower, together with any modifications and amendments, are hereby Incorporated into this Note as it the Commitment Letter were restated herein In Its entirety. SUCCESSOR INTERESTS. The term of this Note shall be binding upon Borrower, and upon Borrower's heirs, personal representatives, successors and assigns, and shaft inure to the benefit of Lender and Its successors and assigns. NOTIFY US OF INACCURATE INFORMATION WE REPORT TO CONSUMER REPORTING AGENCIES. Please notify us If we report any inaccurate information abort your account(s) to a consumer reporting agency. Your written notice describing the specific Ineccuracy(les) should be sent to us at the following address: Mid Penn Bank, Market Square Plaza, 17 North Second Street, Harrisburg, PA 17101. GENERAL PROVISIONS. If any part of this Note cannot be enforced, this fact will not affect the rest of the Note. Lender may delay or forgo enforcing any of Its rights or remedies under this Note without losing them. Borrower and any other person who signs, guarantees or endorses this Note, to the extent allowed by law, waive presentment, demand for payment and notice of dishonor. Upon any change in the terms of this Note, and unless otherwise expressly stated In writing, no party who signs this Note, whether as maker, guarantor, accommodation maker or endorser, shall be released from liability. All such parties agree that Lander may renew or extend (repeatedly and for any length of time) this loan or release any party or guarantor or collateral; or impair, fail to reafize upon or padeot Lsrtder's aeourity Interest In the collateral; and take any other action doomed necessary by Lender without the consent of or notice to anyone. AN such parties also agree that Lender may modify this loan without the consent of or notice to anyone other than the party with whom the modification Is made. The obligations under this Note are joint and several. If any portion of this Note Is or any reason determined to be unenforceable, it will not affeot the enforceability of any other provisions of this Note. CONFESSION OF JUDGMENT. BORROWER HEREBY IRREVOCABLY AUTHORIZES AND EMPOWERS ANY ATTORNEY OR THE PROTHONOTARY OR CLERK OF ANY COURT IN THE COMMONWEALTH OF PENNSYLVANIA, OR ELSEWHERE, TO APPEAR AT ANY TIME FOR BORROWER AFTER A ENTIRE DEFAULT UNDER THIS NOTE AND WITH OR WITHOUT COMPLAINT FILED, CONFESS OR ENTER JUDGMENT AGAINST BORROWER FOR THE ADVANCED BY PRINCIPAL RELATING TO ANY COLLATERAL SECURING THIS NOTE, TOGETHER WITH COSTS OF SUIT, AND ANA ATTORNEYS COMMISSION OF TEN PERCENT (10%) OF THE UNPAID PRINCIPAL BALANCE AND ACCRUED INTEREST FOR COLLECTION, BUT IN ANY EVENT NOT LESS THAN FIVE HUNDRED DOLLARS ($500) ON WHICH JUDGMENT OR JUDGMENTS ONE OR MORE EXECUTIONS MAY ISSUE IMMEDIATELY; AND FOR SO DOING, THIS NOTE OR A COPY OF THIS NOTE VERIFIED BY AFFIDAVIT SHALL BE SUFFICIENT WARRANT. THE AUTHORITY GRANTED IN THIS NOTE TO CONFESS JUDGMENT AGAINST BORROWER SHALL NOT BE EXHAUSTED BY ANY EXERCISE OF THAT AUTHORITY, BUT SHALL CONTINUE FROM TIME TO TIME AND AT ALL TIMES UNTIL PAYMENT IN FULL OF ALL AMOUNTS DUE UNDER THIS NOTE. BORROWER HEREBY WANES ANY RIGHT BORROWER MAY HAVE TO NOTICE OR TO A HEARING IN CONNECTION WITH ANY SUCH CONFESSION OF JUDGMENT AND STATES THAT EITHER A REPRESENTATIVE OF LENDER SPECIFICALLY CALLED THIS CONFESSION OF JUDGMENT PROVISION TO BORROWER'S ATTENTION OR BORROWER HAS BEEN REPRESENTED BY INDEPENDENT LEGAL COUNSEL PRIOR TO SIGNING THIS NOTE, BORROWER READ AND UNDERSTOOD ALL THE PROVISIONS OF THIS NOTE. BORROWER AGREES TO THE TERMS OF THE NOTE. BORROWER ACKNOWLEDGES RECEIPT OF A COMPLETED COPY OF THIS PROMI8SORY NOTE. THIS NOTE IS GIVEN UNDER BEAL AND IT IS INTENDED THAT THIS NOTE IS AND SHALL CONSTITUTE AND HAVE THE EFFECT OF A SEALED INSTRUMENT ACCORDING TO LAW. BORROWER: •:N rod es UOU' I TO tr,rp Y.r. 0.M.10000 C.P. N. &W haaw 40A6,W. M, tw.1001. N 10/W A-L • M KWrM LMftN TP,4W FlN1001WN EXHMPT.6 MID PENN BANK, IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA Plaintiff NOAMW / 1( V. I CIVIL ACTION - LAW BROOKE RHODES, Defendant CERTIFICATE OF ADDRESS C: ) I hereby certify that the following is the address of the Defendant: 20 Brooke Rhodes in 623 Hill Drive New Cumberland, PA 17070 Zbw I hereby certify that the following is the address of the Plaintiff. Mid Penn Bank 51 S. Front Street Steelton, PA 17101 By: Elizabeth Snover Attorney r Plaintiff ?j u?r??+???? i'1r??L.a?L • . MANGE IN TERMS AGREEM. AT `.1 References In the shaded area are for Lender's use only and do not limit the applicability, of this document to any partk:nilar loan em. Anv Item above contalninu "'"" has been omitted due to text length limitations. -n -: -, -„ Borrower: Brooke R. Rhodes (SSN: 184.80.8460) Lender: Mid Penn Bank 7" `rri 623 HIII Drive Market Square Plaza r!' New Cumberland, PA 17070 17 North Second Street C } rn Harrisburg, PA 17101 ?R CD Principal Amount: $244,690.18 Interest Rate: 7.800% Date of Agreement: Decefter 30, 2008 DESCRIPTION OF EXISTING INDEBTEDNESS. Note #500039831 In the amount of $244,880.18 dated March 15, 2007, together with any subsequent renewals and modifications. DESCRIPTION OF COLLATERAL. The loan is secured by two mortgages and assignment of rents dated March 16, 2007. DESCRIPTION. OF CHANGE IN TERMS, The maturity date shall be extended to February 15, 2029, The payment amount shall be adjusted according to the 'Payment` section below. . PROMISE TO PAY. Brooke R. Rhodes ("Borrower") promises to pay to Mid Penn Bank ("Lender"), or order, In lawful money of the United States of America, the principal amount of Two Hundred Forty-four Thoussnd Six Hundred Ninety & 18/100 Dollars ($244,690.18), together with interest at the rate of 7.800% per annum on the unpaid principal balance from December 30, 2008, until paid In full. The Interest rats may change under the terms and conditions of the "INTEREST AFTER DEFAULT" section. PAYMENT, Borrower will pay this loan In accordance with the following payment schedule: The loan shall be payable over a term of twenty (20) years three (8) months. Commencing December 1% 2006, the loan shall be payable In three (3) consecutive monthly Interest payments, than, conanendng March 15, 2000, the loot shall be payable In flKy-seven (87) consecutive monthly Installments, Including principal and Interest In the amount of S2,025.79, based upon an smortizedon of twenty (20) years, with all subsequent payments due on the some day of each month after that. Interest shall be calculated an the unpaid prkx** balance at a rate of 7.80% percent per annum. Five (8) years from dw note date, Borrower shall hew the option of a now fixed rate determined solely by Bank or a variable rate equal to the Wall Street Journal Prime Rate ("index") plus one (1,00%) percent, 0 the fixed rats option Is chosen the rate will be fixed for the net five (5) year Interest rate period. If the variable rate option N chosen the Interest rate change will not occur more often then each month, on the first business day of the month. The monthly Installments shall be reset based upon the then outstanding principal balance, the remaining amortization period, and the Interest rate, In an amount sufficient to maintain the original amortization schedule. All outstanding principal, all saorued and unpaid Interest, and any other charges as may have been incurred will be due and payable In full on or before February 15, 2029. Unless otherwise agreed or required by applicable law, payments will be applied first to any accrued unpaid Interesh then to principal; then to any unpaid collection coals; and then to any late charges. Interest on this ban Is computed on a 360M simple Interest basis; that Is, by applying the ratio of the annual interest rate over a year of 300 days, multiplied by the outstanding principal balance, multiplied by the actual number of days the principal balance Is outstanding, Borrower will pay Lender at Lender's address shown above or at such other pine as Lender may designate In writing. PREPAYMENT PENALTY. Upon prepayment of this Agreement, Lender Is entitled to the following prepayment penalty: if refinanced by another lending institution: A penalty of one percent (1.00%) of the outstanding loan principal balance at the time of prepayment occuring at anytime during the term of the ban. Notwithstanding anything to the contrary, Borrower may prepay this loan, without penalty, from internally generated funds. Except for tin foregoing, Borrower may pay all or a portion of the amount owed earlier then h Is due. Early payments will not, unless agreed to by Lender in writing, relieve Borrower of Borrower's obligation to continue to make payments under the payment schedule. Rather, early payments will reduce the principal balance due and may result In Sorroweee making fewer payments. Borrower agrees not to send Lender payments marked "paid In full", 'without recourse', or similar language, If Borrower sends such a payment, Lender may accept it without losing any of Lender's rights under this Agreement, and Borrower will remain obligated to pay any further amount owed to Lender. All written communications omeming disputed amounts, Including any check or other payment Instrument that indicates that the payment constitutes "payment In full" of the amount owed or that Is tendered with other conditions or limitations or as full satisfaction of a disputed amount must be mailed or delivered to: Mid Penn Bank, Market Square Plaza, 17 North Second Street, Harrisburg, PA 17101. LATE CHARGE. If a payment Is 16 days or more late, Borrower will be charged 10.000% of the regularly scheduled payment or $20.00, whichever Is greater. INTEREST AFTER DEFAULT, Upon default including failure to pay upon final maturity, the Interest rate on this loan shall be Increased by 8.000 percentage points. If judgment is entered In connection with this Agreement, interest will continue to accrue after the date of judgment at, the rate In effect at the time judgment Is entered. However, In no event will the Interest rate exceed the maximum interest rate limitations under applicable law. DEFAULT. Each of the following shall constitute an Event of Default under this Agreement: Payment Default. Borrower fails to make any payment when due under the Indebtedness. Other Defaults. Borrower fails to comply with or to perform any other term, obligation, covenant or condition contained in this Agreement or in any of the Related Documents or to comply with or to perform any term, obligation, covenant or condition contained In any other agreement between Lender and Borrower. False Statements. Any warranty, representation or statement made or furnished to Lender by Borrower or on Borrower's 1lehati under this Agreement or the Related Documents Is false or misleading In any material respect, either now or at the time made or furnished or becomes false or misleading at any time thereafter. Death or Insolvency. The death of Borrower or the dissolution or termination of Borrower's existence as a going business, the Insolvency of Borrower, the appointment of a receiver for any part of Borrower's property, any assignment for the benefit of creditors, any type of creditor workout, or the commencement of any proceeding under any bankruptcy or Insolvency laws by or against Borrower. . Creditor or Forfeiture Proceedings. Commencement of foreclosure or forfeiture proceedings, whether by judicial proceeding, self-help, repossession or any other method, by any creditor of Borrower or by any governmental agency against any collateral securing the Indebtedness. This Includes a garnishment of any of Borrower's accounts, Including deposit accounts, with Lender. However, this Event of Default shall not apply N there is a good faith dispute by Borrower as to the vaikifty or reasonableness of the claim which Is the basis of the creditor or forfeiture proceeding and 11 Borrower gives Lender written notice of the creditor or forfeiture proceeding and deposits with gender monies or a surety bond for the creditor or forfeiture proceeding, In an amount determined by Lender, in Its We discretion, as being an adequate reserve or bond for the dispute. .F4HANGE IN TERMS AGREEMEN'b Loan No: 600039631 (Continued) Page 2 Events Affecting Guarantor. Any of the preceding events occurs with respect to any guarantor, endorser, surety, or accommodation party of any of the indebtedness or any guarantor, endorser, surety, or accommodation party dies or becomes Incompetent or revokes or disputes the validity of, or liability, under, any Guaranty of the indebtedness evidenced by this Note. Adverse Change. A material adverse change occurs in Borrower's financial condition, or Lender believes the prospect of payment or performance of the Indebtedness Is Impaired. Insecurity. Lender in good faith believes itself Insecure. LENDER'S RIGHTS. Upon default Lender may, after giving such notices as required by applicable law, declare the entire unpaid principal balance under this Agreement and all accrued unpaid Interest Immediately due, and then Borrower will pay that amount. ATTORNEYS' FEES; EXPENSES. Lender may hire or pay someone else to help collect this Agreement If Borrower does not pay. Borrower will pay Lender that amount. This includes, subject to any limits under applicable law, Lender's attorneys' fees and Lender's legal expenses, whether or not there Is a lawsuit, Including attomays' fees, expenses for bankruptcy proceedings (Including efforts to modify or vacate any automatic stay or Injunction), and appeals. If not prohibited by applicable law, Borrower also will pay any court costs, In addition to all other sums provided by law. JURY WAIVER. Lender and Borrower hereby walve the right to any jury trial in any action, proceeding, or counterclaim brought by either Lender or Borrower against the other. GOVERNING LAW. This Agreement will be governed by federal law applicable to Lender and, to the sMont not preempted by federal law, the laws of the Commonwealth of Pennsylvania without regard to its owflicts of law provisions. This Agreement has been accepted by Lender In the Commonwealth of Pennsylvania. CHOICE OF VENUE. If there to a lawauit, Borrower agrees upon Lender's request to submit to the jurisdiction of the courts of Dauphin County, Commonwealth of Pennsylvania. RIGHT OF SETOFF, To the extent permitted by applicable law, Lender reserves a right of setoff In all Borrower's accounts with Lender (whether checking, savings, or some other account). This Includes all accounts Borrower holds jointly with someone else and all accounts Borrower may open In the future. However, this does not Include any IRA or Keogh accounts, or any trust accounts for which setoff would be prohibited by law. Borrower authorizes Lender, to the extent permitted by applicable law, to charge or setoff all sums owing on the Indebtedness against any and 1 such accounts, and, at Lender's option, to administratively freeze all such accounts to allow Lender to protect Lender's charge and setoff rights provided In this paragraph. COLLATERAL. Borrower acknowledges this Agreement Is secured by the following collateral described In the security Instruments listed. herein: Harrisburg, g, Pa 17or Deed of 1110 and 6g N. to 3ta trustee h Street,21favor of Lender on 0 N. 14th Streets Harriproperty sburg, PA described 17103" and Inca ed InyDauphh located aCounty, 2Comm Commonwealth of Pennsylvania. (8) a Trust to a tru Cuumberland PA 17070' and floc ted In Cu b r and coil ty, Commonwealth property ennsyylvannia as 'Real Property located at 213 Reno Street, New CONTINUING VALIDITY. Except as expressly changed by this Agreement, the terms of the original obligation or obligations, Including all agreements evidenced or securing the obligation(s), remain unchanged and in full force and effect. Conant by tender to this Agreement does not waive Lender's right to strict performance of the obligation(s) as changed, nor obligate Lender to make any future change In tenons. Nothing In this Agreement will constltuts a satisfaction of the obllgatlon(s). It Is the Intention of Lender to retain as liable parties all makers and endorsers of the original obligation(s), Including accommodation parties, unless a party Is expressly released by Lender In writing. Any maker or endorser, Including accommodation makers, will not be released by virtue of this Agreement. H any person who signed the original obligation does not sign this Agreement below, then all persons signing below acknowledge that ta' Agreement to given cndittonnelly, based on the representation to Lender that the non-signing party consents to the changes and provisions of this Agreement or otherwise will not be released by if. This waiver applies not only to any Initial extension, modification or release, but also to all such subsequent actions. SUCCESSOR INTERESTS. The terms of this Agreement shall be binding upon Borrower, and upon Borrower's helrs, personal representatives, successors, and assigns, and shall be enforceable by Lender and Its successors and assigns. NOTIFY US OF INACCURATE INFORMATION WE REPORT TO CONSUMER REPORTING AGENCIES. Please notify us if we report any Inaccurate Information about your account(s) to a consumer reporting agency, Your written notice describing the specific inaoouracy(les) should be sent to us at the following address: Mid Penn Bank, Market Square Plaza, 17 North Second Street, Hardeburg, PA 17101. MISCELLANEOUS PROVISIONS. If any part of this Agreement cannot be enforced, this fact will not affect the rest of the Agreement. Lender may delay or forgo enforcing any of its rights or remedies under this Agreement without losing them. Borrower and any other person who signs, guarantees or endorsee this Agreement, to the extent allowed by law, waive presentment, demand for payment, and notice of dishonor. Upon any change in the terms of this Agreement, and unless otherwise expressly stated In writing, no party who signs this Agreement, whether as maker, guarantor, accommodation maker or endorser, shall be released from liability. All such parties agree that Lender may renew or extend (repeatedly and for any length of time) this loan or release any party or guarantor or collateral; or Impair, fall to realize upon or perfect Lender's security Interest In the collateral; and take any other action deemed necessary by Lender without the consent of or notice to anyone. All such parties also agree that Lender may modify this loan without the consent of or notice to anyone other than the party with whom the modification to made. The obligations tinder this Agreement are joint and several. If any portion of this Agreement Is for any reason determined to be unenforceable, It will not affect the enforceability of any other provisions of this Agreement. CONFESSION OF JUDGMENT. BORROWER HEREBY IRREVOCABLY AUTHORIZES AND EMPOWERS ANY ATTORNEY OR THE PROTHONOTARY OR CLERK OF ANY COURT IN THE COMMONWEALTH OF PENNSYLVANIA, OR ELSEWHERE, TO APPEAR AT ANY 71ME FOR BORROWER AFTER A DEFAULT UNDER THIS AGREEMENT AND WITH OR WITHOUT COMPLAINT FILED, CONFESS OR ENTER JUDGMENT AGAINST BORROWER FOR THE ENTIRE PRINCIPAL BALANCE OF THIS AGREEMENT AND ALL ACCRUED INTEREST, LATE CHARGES AND ANY AND ALL AMOUNTS EXPENDED OR ADVANCED BY LENDER RELATING TO ANY COLLATERAL SECURING THE INDEBTEDNESS, TOGETHER WITH COSTS OF SUIT, AND AN ATTORNEY'S COMMISSION OF TEN PERCENT (10%) OF THE UNPAID PRINCIPAL BALANCE ANb ACCRUED INTEREST FOR COLLECTION, BUT IN ANY EVENT NOT LESS THAN FIVE HUNDRED DOLLARS ($500) ON WHICH JUDGMENT OR JUDGMENTS ONE OR MORE EXECUTIONS MAY ISSUE IMMEDIATELY; AND FOR SO DOING, THIS AGREEMENT OR A COPY OF THIS AGREEMENT VERIFIED BY AFFIDAVIT SHALL BE SUFFICIENT WARRANT. THE AUTHORITY GRANTED IN THIS AGREEMENT TO CONFESS JUDGMENT AGAINST BORROWER SHALL NOT BE EXHAUSTED BY ANY EXERCISE OF THAT AUTHORITY, BUT SHALL CONTINUE FROM TIME TO TIME AND AT ALL TIMES UNTIL PAYMENT IN FULL OF ALL AMOUNTS DUE UNDER THIS AGREEMENT. BORROWER HEREBY WAIVES ANY RIGHT BORROWER MAY HAVE TO NOTICE OR TO A HEARING IN CONNECTION WITH ANY SUCH CONFESSION OF JUDGMENT AND STATES THAT EITHER A REPRESENTATIVE OF LENDER SPECIFICALLY CALLED THIS CONFESSION OF JUDGMENT PROVISION TO BORROWER'S ATTENTION OR BORROWER HAS BEEN REPRESENTED BY INDEPENDENT LEGAL COUNSEL. .CHANGE IN TERMS AGREEMEN. Loan No: 600039601 (Continued) Page 3 PRIOR TO SIGNING THIS AGREEMENT, BORROWER READ AND UNDERSTOOD ALL THE PROVISIONS OF THIS AGREEMENT. BORROWER AGREES TO THE TERMS OF THE AGREEMENT. THIS AGREEMENT IS GIVEN UNDER SEAL AND IT IS INTENDED THAT THIS AGREEMENT IS AND SHALL CONSTITUTE AND HAVE THE EFFECT OF A SEALED INSTRUMENT ACCORDING TO LAW. BORROWER: 13room R. 'Rhodos W pl MW Unft VW. M90.004 Cap. H"-4 RMMW 00A WS, NO. Wf. NW M ROM MWM& • M W^RWM,FC TEAR MW txmjnl6 2:) 0- ' DISCLO: RE FOR CONFESSION OF 'DGMENT DISCLOSURE FOR CONFESSION OF JUDGMENT I AM EXECUTING, THIS ' DAY OF NA-1 , 2041. A PROMISSORY NOTE FOR 1809,ti20.00 OBLIOATINO ME TO REPAY THAT AMOUNT. A. I UNDERSTAND THAT THE NOTE CONTAINS A CONFESSION OF JUDGMENT PROVISION THAT WOULD PERMIT LENDER TO ENTER JUDGMENT AGAINST ME IN COURT, AFTER A DEFAULT ON THE NOTE, WITHOUT ADVANCE NOTICE TO ME AND WITHOUT OFFERING ME AN OPPORTUNITY TO DEFEND AGAINST THE ENTRY OF JUDGMENT. IN EXECUTING THE NOTE, BEING FULLY AWARE OF MY RIGHTS TO ADVANCE NOTICE AND TO A HEARING TO CONTEST THE VALIDITY OF ANY JUDGMENT OR OTHER CLAIMS THAT LENDER MAY ASSERT AGAINST ME UNDER THE NOTE, I AM KNOWINGLY, INTELLIGENTLY, AND VOLUNTARILY WAIVING THESE RIGHTS, INCLUDING ANY RIGHT TO ADVANCE NOTICE OF THE ENTRY OF JUDGMENT, AND I EXPRESSLY AGREE AND CONSENT TO LENDER'S ENTERING JUDGMENT AGAINST ME BY ON AS PROVIDED FOR IN THE CONFESSION OF JUDGMENT PROVISION. INITIALS: muffm B. 1 FURTHER UNDERSTAND THAT IN ADDITION TO GMNG LENDER THE RIGHT TO ENTER JUDGMENT AGAINST ME WITHOUT ADVANCE NOTICE OR A HEARING, THE CONFESSION OF JUDGMENT PROVISION IN THE NOTE ALSO CONTAINS LANGUAGE THAT WOULD PERMIT LENDER, AFTER ENTRY OF JUDGMENT, AGAIN WITHOUT EITHER ADVANCE NOTICE OR A HEATING, TO EXECUTE ON THE JUDGMENT BY FORECLOSING UPON, ATTACHING, LEVYING ON, TAKING POSSESSION OF OR OTHERWISE SEIZING MY PROPERTY, IN FULL OR PARTIAL PAYMENT OF THE JUDGMENT. IN EXECUTING THE NOTE, BEING FULLY AWARE OF MY RIGHTS TO ADVANCE NOTICE AND A HEARING AFTER JUDGMENT 19 ENTERED AND BEFORE EXECUTION ON THE JUDGMENT, I AM KNOWINGLY, INTELLIGENTLY AND VOLUNTARILY WAIVING THESE RIGHTS, AND I EXPRESSLY AGREE AND CONSENT TO LENDER'S IMMEDIATELY EXECUTING ON THE JUDGMENT IN ANY MANNER PERMnT PPLICABLE STATE AND FEDERAL LAW, WITHOUT GIVING ME ANY ADVANCE NOTICE. INITIALS:. C. AFTER HAVING READ AND DETERMINED WHICH OF THE FOLLOWING STATEMENTS ARE APPLICABLE, BY INITIALING EACH STATEMENT THAT APPLIES, I REPRESENT THAT: INITIALS -w-- 1. 1 WAS REPRESENTED BY MY OWN INDEPENDENT LEGAL COUNSEL IN CONNECTION WITH THE NOTE. 2. A REPRESENTATIVE OF LENDER SPECIFICALLY CALLED THE CONFESSION OF JUDGMENT PROVISION IN THE NOTE TO MY ATTENTION. 0. 1 CERTIFY THAT MY ANNUAL INCOME EXCEEDS $10,000; THAT THE BLANKS IN THIS DISCLOSURE WERE FILLED IN WHEN I INITIALED AND SIGNED IT; AND THAT 1 RECEIVED A COPY AT THE TIME OF SIGNING. THIS DISCLOSURE 18 GIVEN UNDER SEAL AND IT IS INTENDED THAT THIS DISCLOSURE IS AND SHALL CONSTITU"D HAVIE EFFECT OF A SEALED INSTRUMENT ACCORDING TO LAW. ' a DECLARANT: ? :',iK :yfjyo ;2:;?irycu?5?%?ihv.'?•?,,•yr^,.•a"`%• ::k, ?:a'?iMt' .i•;'/?iiti:j?kt':?:iK;,'?.+ ?C, ?r i r? HFOORM Rhoda ? ''rw •.+. .... LAM PRO LwArw W. MOAN 0W. fbrWd Fbwm #*kWm M. NIA, JW. N HIM F1 • IA AWftP0W0.10 TPt4W PA4EDOMMMM DeClarent: Brooke R. Rhodes (SSN: 184-W4480) Lender: Mid Penn Bank 829 Hill Drive Market Squere Plan New Cumberland, PA 17070 17 North Second Street Hrarlsburg, PA 17101 MID PENN BANK, Plaintiff V. BROOKE RHODES, Defendant IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW AFFIDAVIT REQUIRED BY PA.R.C.P. 2951(aI)(2)(11) I hereby certify that the judgment is not being entered by confession against a natural person in connection with a consumer credit transaction. By: Elizabeth nover Attorney for Plaintiff t A C7 Wi . ? C- :T ' co V MID PENN BANK, IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA Plaintiff q w (5rn?i I T NO. ??1 V. : CIVIL ACTION - LAW BROOKE RHODES, Defendant AFFIDAVIT OF NN-MILITARY SERVICE 1, Elizabeth D. Snover, attorney for Plaintiff in the above-captioned action, being duly sworn according to law, swear that to the best of my knowledge and belief, Brooke Rhodes, the Defendant in the above-captioned action, is not a member of the United States Military and/or Armed Services. By: Elizabeth E/jSnover Attorney f Plaintiff r • '? V b N ) Q ? "C 0 V MID PENN BANK, Plaintiff v. BROOKE RHODES, Defendant IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA NO. L? C.1/?l CIVIL ACTION - LAW CERTIFICATE OF ADDRESS I hereby certify that the following is the address of the Defendant: Brooke Rhodes 623 Hill Drive New Cumberland, PA 17070 I hereby certify that the following is the address of the Plaintiff: Mid Penn Bank 51 S. Front Street Steelton, PA 17101 By: Elizabeth Snover Attorney r Plaintiff A nIC7 ZC'- rn - . y , , ? r Of- I'll i ice, L:l7v i. %J L; *d9.0o p 4 A'm/ Cic. ?' 3030 ?Ja(?e ?." d