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Home My WebLink About04-2163 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA O&P Partnership 217 Frederick Street Hanov,%! PA 17331 NO. 0 t/ - ~ J (, 3 David J. Raudabaugh and Joyce A. Raudabaugh, husband and wife 60 Sunnyside Drive Carlisle, PA 17013 JUDGMENT NOTE $ 22,500.00 S -\'-\-()'-\ Date: I I I THIS NOTE IS LIMITED TO THIS PURCHASE OF LOT 48, LARCH DRIVE ONLY. I II I For value received, We, David J. Raudabaugh and Joyce A. Raudabaugh, husband and wife promise to pay to the order of 0 & P Partnership, the sum of $22,500.00, without offset, as follows: no interest for the first six (6) months from the date hereof or until the real property is sold, whichever shall occur first: after six (6) months from the date hereof, interest shall begin at seven (7%) percent per annum per month: within one (l) year from the date hereof or upon settlement of the real property, whichever shall occur first. the remaining principal balance shall be due and owing. And further, We, David J. Raudabaugh and Joyce A. RaudabaUgh. husband and wife, do hereby waive and dispense with the benefit of any law of the State of Pennsylvania exempting any real or personal property from levy and sale on execution. And further do empower the Prothonotary or any Attorney of any Court of Record of Pennsylvania to appear for them and confess judgment against me (us) in favor of 0 & P Partnership for the above sum, with costs of suit and release of all errors and without stay of execution. And further, We, David J. Raudabaugh and Joyce A. Raudabaugh, husband and wife, do agree that should a writ of execution be issued on a judgment entered on this note, that all its real estate may be sold on the same without inquisition and condemnation being held or any other writ from court for that purpose; and We, David J. Raudabaugh and Joyce A. Raudabaugh, husband and wife, do agree in case of default of payment at maturity to pay an additional fifteen per cent (15%) for Attorney fees in the collection of this note. D~a~ V~{p j ~{1jJLJ4 Joy~ A. Raudabaugh () (SEAL) (SEAL) Wi~ C9JOO ~ ~ (r~ ~_~~l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA O&P Partnership 217 Frederick Street Hanov'V'S! PA 17331 NO. (') c; ....., = 0 = .1 """ :J': ::::l -< f~~2 ." ~j? .--~1(J :'? )~3) '..j .,--~ ~, --J'...) :'.-:"j-,-; (..:J .-' -1 c.., . ._~1 ~ -<. David J. Raudabaugh and Joyce A. Raudabaugh, husband and wife 60 Surmyside Drive Carlisle, PA 17013 JUDGMENT NOTE c;; $ 22.500.00 s: -il'H)'k? Date: For value received, We, David J. Raudabaugh and Joyce A. Raudabaugh. husband and wife promise to pay to the order of 0 & P Partnership, the sum of $22,500.00, without offset, as follows: no interest for the first six (6) months from the date hereof or until the real property is sold. whichever shall occur first; after six (6) months from the date hereof. interest shall begin at seven (7%) percent per annum per month; within one (1) year from the date hereof or upon settlement of the real property, whichever shall occur first, the remaining principal balance shall be due and owing. THIS NOTE IS LIMITED TO THIS PURCHASE OF LOT 48, LARCH DRIVE ONLY. And further, We, David J. Raudabaugh and Joyce A. Raudabaugh, husband and wife, do hereby waive and dispense with the benefit of any law of the State of Pennsylvania exempting any real or personal property from levy and sale on execution. And further do empower the Prothonotary or any Attorney of any Court of Record of Pennsylvania to appear for them and confess judgment against me (us) in favor of 0 & P Partnership for the above sum, with costs of suit and release of all errors and without stay of execution. And further, We, David J. Raudabaugh and Joyce A. Raudabaugh. husband and wife, do agree that should a writ of execution be issued on a judgment entered on this note, that all its real estate may be sold on the same without inquisition and condemnation being held or any other writ from court for that purpose; and We, David 1. Raudabaugh and Jovee A. Raudabaugh, husband and wife. do agree in case of default of payment at maturity to pay an additional fifteen per cent (15%) for Attorney fees in the collection of this note. ;:;F~I -L-$ (SEAL) David J. Ra6cl~baugh rJl0{{i j 1I..1do./xU.!f11, (SEAL) Joylle A. Raudabaugh (/ Witn,ess:f).. 10 I" 'Q :,.'. I" ~ ,/, \.....-X-Jof~./ . (," \ I".. !\..,f') ( ", 1 ;, '1 I _ \ .> 1.,._.___>cl ~. _ ~-o ~ U\~o..-- -' .....Q D ~ of .\)\ IJ\ S- 0 ~..0~ ~ll' \f\r;- z:- .r ,...~"l c.::" C) ~;~ ,I _".# '"1; 1 ~'\ (:. (..) \,-,'\ 'I,jJ .-< F: \F1LES\DA T AFILEIReaJ Estatel4920_sat.27 &211 O&P PARTNERSHIP v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA DAVID J. RAUDABAUGH and JOYCE A. RAUDABAUGH No. 04-2163 CNIL JUDGMENT NOTE PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please mark the jUdgment in the above captioned case satisfied and issue a certificate reflecting the same. EARDORFF WILLIAMS & OTTO j,{) Carl C. Risch, squire J.D. Number 75901 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 By Attorneys for Defendants Date: June 11,2004 CERTIFICATE OF SERVICE I, Laura K. Marovich, an authorized agent for Martson DeardorffWiIliams & Otto, hereby certifY that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: O&P Partnership 217 Frederick Street Hanover, PA 17331 Mr. and Mrs. David J. Raudabaugh 60 Sunnyside Drive Carlisle, P A 17013 MARTS ON DEARDORFF WILLIAMS & OTTO ~ CZ-~ By Laura K.'~;'viCh Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: June 11, 2004 - 0 ..., 0 = c = -n rBIT- ~ <- ~::n c::: ~~: :z ,..... -om .{:"" ~~ r::i"' ~~-~: """ ..,L.-H 3 ~.:!i:,) )> '-.:::: 5 Z:.irn .c :;z~ ~'-l .::>> =< C' :-.0 w -< T ~ CJ . v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PM_Sf(, 'f5o I 073>1;)... : No. 2004-2863 CAROL HERSHEY, Plaintiff GENE HERSHEY, Defendant CIVIL ACTION - LAW DIVORCE PLAINTIFF'S PFTlTlON FOR CONFFRFNCF, OR HF,ARINC. RFC.ARnINC. AI.IMONV PFNnFNTF. I.ITF AND NOW, comes the Plaintiff, Carol Hershey, by and through her attorney, Jeanne B. Costopoulos, Esquire, and respectfully represents as follows in support of this Petition: 1. The Petitioner is the Plaintiff above-named. 2. The Respondent is the Defendant above-named. 3. Plaintiff /Petitioner filed a Complaint in Divorce on June 22, 2004, which contains a request for alimony pendente lite. 4. Plaintiffi'Petitioner desires that a conference or hearing be held to address her alimony pendente lite claim. WHEREFORE, Plaintiff respectfully requests that a conference or hearing be scheduled regarding her request for alimony pendente lite. RESPECTFULLY SUBMITTED: anne B. Costopoulos, Esquire ATTORNEY FOR PETITIONER 5000 Ritter Road, Suite 202 Mechanicsburg, P A 17055 Phone: (717) 790-9546 PA Supreme Ct ID No. 68735 ated: $t};s- O/C)/G { < CAROL HERSHEY, Plaintiff v. GENE HERSHEY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 2004-2863 : CIVIL ACTION - LAW : DIVORCE CFRTTFWATF OF SFRVWF I, Jeanne B. Costopoulos, Esquire, hereby certify that I am this day serving a copy of the foregoing document upon the person, and in the manner, indicated below, which service satisfies the requirements of the P A RuIes of Civil Procedure by depositing a copy of the same with the United States Post Office at Mechanicsburg, Pennsylvania, through first class mail, prepaid, and addressed as follows: Sally Winder, Esquire 9974 Molly Pitcher Highway Shippensburg, P A 17257 Dated: ~ BY: ./ ~---- ,/Jeanne B. CostopouIos, Esquire ATTORNEY FOR PETITIONER 5000 Ritter Road, Suite 202 Mechanicsburg, P A 17055 Phone: (717) 790-9546 P A Supreme Ct. ID No. 68735 ,,-", ~;"\-\. -s;\ t,';:" --- ~'--. - ~- .,",- r- ;..< .;:;;". -.------