HomeMy WebLinkAbout10-3360
MARK T. SILLIKER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 10 - ZjNoO (2-w
PATTI MATLOCK,
Defendant CIVIL ACTION -LAW
CONFESSION OF JUDGMENT
Pursuant to the authority contained in the warrant of attorney, the original
of which is attached to this action, I appear for the Defendant and confess judgment in
favor of the Plaintiff against Defendant as follows:
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Amount: $22,877.48 ?' ==
Date: U BY
Mark T. Silliker
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MARK T. SILLIKER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 330 cā'I 41er,
PATTI MATLOCK,
Defendant CIVIL ACTION -LAW
COMPLAINT
AND NOW comes the Plaintiff, Mark T. Silliker, Esquire, and
respectfully sets forth the following:
1. Plaintiff, Mark T. Silliker, is a practicing attorney with a business
address of 5922 Linglestown Road, Harrisburg, Dauphin County, Pennsylvania 17112.
2. Defendant, Patti Matlock, is an adult individual currently residing at
509 Woodcrest Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050.
3. Over the last two years, Plaintiff s firm, The Law Offices of Silliker
and Reinhold, has performed legal services for Defendant, Patti Matlock, in the amount
of $22,877.48. Defendant acknowledges that this amount is outstanding and otherwise
due and owing to the Plaintiff.
4. Defendant, Patti Matlock, has voluntarily executed a Note as well as
Explanation of Rights (Full Confession) regarding her debt owed to the Plaintiff, and said
documents are attached to this Complaint. Furthermore, it is the desire of the parties that
these documents be filed with this Honorable Court, and become a lien against the
property of the Defendant, Patti Matlock.
WHEREFORE, Plaintiff, Mark T. Silliker, requests this Honorable Court
enter judgment on his behalf against Defendant, Patti Matlock.
Date:
Respectfully submitted,
THE LAW OFFICES OF
SILLIKER & REINHOLD
Mark T. Silliker, Esquire
5922 Linglestown Road
Harrisburg, PA 17112
(717) 671-1500
I.D. No. 33671
NOTE
DUE ON DEMAND
$22,877.48
ON DEMAND, the undersigned, Patti Matlock, (hereinafter called the
"Obligor"), promises to pay to the order of Mark T. Silliker, Dauphin County,
Pennsylvania, or at such other place as the holder may, from time to time, direct that
Obligor in writing, the principal sum of Twenty Two Thousand Eight Hundred Seventy
Seven Dollars and Forty Eight Cents ($22,877.48) lawful money of the United States of
America, for value received.
AND FURTHER, the said Obligor does empower any attorney of any
court of record within the United States or elsewhere to appear for her and confess
judgment against her, as of any term for the above sum with costs of suit and attorney's
commission of five percent (5%) for collection and release of all errors, and without stay
of execution and inquisition and extension upon any levy on real estate is hereby waived,
and condemnation agreed to and the exemption of personal property from levy and sale
on any execution herein is also expressly waived, and no benefit of exemption be claimed
under and by virtue of any exemption law now in force or which may be hereafter passed.
The Obligor, maker, endorser, and all parties to this Note hereby waive
presentment for payment, demand, notice of demand, notice of non-payment or dishonor,
protest and notice of protest and non-payment thereof.
This Note does not arise from a consumer transaction.
It is the intention of the party hereto to be legally bound by the terms of
this Note.
IN WITNESS WHEREOF, the said Obligor executes this note as of the
date below written.
OBLIGOR:
(/y
Patti atlock
Date: j
IF I DO NOT SIGN A NOTE WHICH CONTAINS A CONFESSION OF JUDGMENT
CLAUSE I UNDERSTAND THAT I WOULD HAVE THE FOLLOWING:
1) The right to have notice and an opportunity to be heard prior to judgment;
2) The right to have the burden of proving default rest upon Plaintiff before my
property can be exposed to execution;
3) The right to avoid the additional expense of Attorney's fees and costs incident to
opening or striking off a confessed judgment.
C) Fully and completely understanding these rights which I have prior to signing the
above-described note; and clearly aware that these rights will be given up,
waived, relinquished and abandoned if I sign the note, I nevertheless freely and
voluntarily choose to sign the note, my intention being to give up, waive,
relinquish and abandon my known rights (as described in paragraph B above) and
subject myself to the circumstances described in paragraph A above.
D) The undersigned hereby further certifies that she, The Signatory to a demand a note
dated M a 0 11) , which has a judgment clause entered, has earnings in
excess of 10,000.00 per year.
I have read this entire form and I
fully understand its contents
Patti Matlock
Sworn to and subscriped
before me this ā3"
day of , 2010.
Notary Public
COMMONWEALTH OF PENN I
NOTARIAL SEAL
Renee Dreisbach, Notary Pubno
Lower Paxton Twp. Dauphin Count/
M COMMISelon Ex {res Nov. 30 2010
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EXPLANATION OF RIGHTS
(Full Confession)
A) I clearly and specifically understand that by signing a note dated, Mam 3 ' O 10 ,
in the amount of $22,877.48 payable to Mark T. Silliker which cc tains a
judgment clause.
1) I will authorize Mark T. Silliker, Plaintiff (Creditor) to enter a judgment against
me in its favor which will give the Plaintiff a lien upon any real estate which I
may own, including my home;
2) I will give up the right to any notice or opportunity to be heard prior to the entry
of his judgment on the records of the court;
3) I will agree that Mark T. Silliker, Plaintiff (Creditor) can enter this judgment
without any proof of non-payment or other default on my part;
4) I will subject all of my property, both personal property and real estate, to
execution (and Sheriff s sale); pursuant to this judgment, prior to proof of non-
payment or other default on my part;
5) I will be unable to challenge this judgment should the Plaintiff enter it, except by
a proceeding to open or strike the judgment; and such a proceeding will result in
Attorney's fees and costs which I will have to pay.
B) I know and understand that it is the confession of Judgment clause in the above-
described note which gives Plaintiff the rights enumerated in sub-paragraphs 1
through 5 of paragraph A above.
MARK T. SILLIKER,
Plaintiff
V.
PATTI MATLOCK,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10 -331oa 1 Terot
: CIVIL ACTION -LAW
CERTIFICATE OF RESIDENCE
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The undersigned hereby certifies the following:
1. The Plaintiff, Mark T. Silliker, is a lawful, licensed attorney in the
State of Pennsylvania.
2. The address if the Plaintiff, Mark T. Silliker, is 5922 Linglestown
Road, Harrisburg, Pennsylvania 17112.
3. The last known address of Defendant Patti Matlock, to the best of
the undersigned's knowledge, information, and belief, is 509 Woodcrest Drive,
Mechanicsburg, Cumberland County, Pennsylvania. 17050.
Date: ?? By:
v
Mark T. Silliker
5922 Linglestown Road
Harrisburg, PA 17101
(717) 671-1500
MARK T. SILLIKER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 10 - 33(00 -Ivi I T+?~N c7 .,
PATTI MATLOCK CIVIL ACTION -LAW f7l ?.
A,
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Defendant
AFFIDAVIT OF NONMELITARY SERVICE
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Mark T. Silliker, being duly sworn according to law, deposes and says:
1. I am an attorney licensed to practice law in the State of Pennsylvania, with
an office address of 5922 Linglestown Road, Harrisburg, Dauphin County, Pennsylvania.
2. I have known and worked with the Defendant, Patti Matlock, for a period
in excess of one year.
3. At no time has the Defendant advised me or given me reason to believe
that she is in the military or naval service of the United States of America.
4. To the best of my knowledge, information, and belief, Defendant Patti
Matlock, is not in the military or naval service of the United States of America.
®$
Date:
Mark T. Silliker
Sworn to and subsc?}bed
before me this r?day
of Mal, i , 2010.
Notary Public
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otary Pubile auphln Co101
Nov. 30 20 O
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MARK T. SILLIKER,
Plaintiff
V.
PATTI MATLOCK,
Defendant
TO: Patti Matlock
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10,3-NeD Onvi1-Te- r
CIVIL ACTION -LAW
You are hereby notified that on 1 , 2010, judgment by
confession was entered against you in the sum of $22,07.48 in the above-captioned case.
Date:
"_ / A-'?
Prothonotary
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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717) 249-3166
I hereby certify that the following is the address of the Defendant stated in
the Certificate of Residence:
Patti Matlock, 509 Woodcrest Drive, Mechanicsburg, PA 17050
By:
Mark T. Silliker
Patti Matlock
Per este medio sea avisado que en el dia de
, 2010, un fallo por admission fue registrado contra usted por la
contidad de $22,877.48 del caso antes escrito.
Fecha: el dia de 92010.
Prothonotario
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE.
SI NO TIENE ABOGADO O SI NO TIENE EL DINOER SUFICIENTE DE PAGAR
TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEPHONO A LA
OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA
AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717) 249-3166
Por este medio certifico que to siguiente es la direccion del demandado
dicho en el certificado de residencia:
Patti Matlock, 509 Woodcrest Drive, Mechanicsburg, PA 17050
By:
ark T. Silliker
MARK T. SILLIKER,
Plaintiff
v.
PATTI HAYCOCK,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10-3360 CIVIL TERM
CIVIL ACTION -LAW
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ACCEPTANCE OF SERVICE
I, Patti Matlock, Defendant in the above-captioned matter, hereby certify
that I accept service of a Confession of Judgment in the above-captioned matter on or
about 2010, by first-class mail, postage prepaid.
I hereby certify that the aforegoing is true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to
authorities.
Date:
Pa i atlock
MARK T. SILLIKER,
Plaintiff
V.
PATTI MATLOCK,
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2010-03360 Civil Term
CIVIL ACTION -LAW
PRAECIPE
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Please mark the above-captioned judgment as satisfied in full and therefore settled
and otherwise dismissed.
Date: _- l?
Respectfully Submitted,
THE LAW OFFICES OF
SILLIKER & OLD
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Mark T. Silliker, Esquire
5922 Linglestown Road
Harrisburg, PA 1.7112
I.D. No. 33671
(717) 671-1500
Plaintiff
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